While all Performance Standards are applicable to this investment, IFC's environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards.

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS 5: Land Acquisition and Involuntary Resettlement - The oncology centers will be located in existing operational hospitals in designated areas, majority of which will be Government run and managed hospitals. 

The Beijing Proton Center will be built at China Japan Friendship Hospital located at Yinghua Dongeii, Chaoyang district, Beijing. The land was acquired through direct purchase from the industrial authority in June 2010 by China Japan Friendship Hospital. The Guangzhou Oncology Hospital (South China Taihe Hospital) will be built at SunYat-Sen University International Health and Medical Research Center, located at the Knowledge Center Development Zone in Guangzhou. The Land use rights have been obtained. There was no economic or physical displacement of people as a result of these acquisitions.

The Project thus does not involve any new land acquisition. Accordingly, the findings of the Project review indicate that there are no impacts related to Land Acquisition and Involuntary Settlement.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources  - There are no forest lands or ecologically sensitive areas in the vicinity of any of the Project sites. Accordingly, the findings of the Project review indicate that there are no impacts related to Biodiversity Conservation and Sustainable Management of Living Natural Resources.

PS 7: Indigenous Peoples - There are no indigenous people in the vicinity of any of the Project sites. Accordingly, the findings of the Project review indicate that there are no impacts related to Indigenous Peoples.

PS 8: Cultural Heritage - There are no cultural heritage in the vicinity of any of the Project sites. Accordingly, the findings of the Project review indicate that there are no impacts related Cultural Heritage.

This is a category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards and guidelines.

Key environmental and social (E&S) risks and issues related to this project include: adequate assessment of the E&S impacts of the Project and implementation of associated mitigation measures; implementation of effective EHS management systems; engagement with local communities in accordance with local requirements and IFC Performance Standards; management of construction and operations of the new hospitals and selection of facilities in which to locate oncology centers; employee occupational health and safety activities, including prevention of nosocomial diseases; management of solid and liquid waste, in particular hazardous and biomedical wastes and wastewater; and life and fire safety management of all the public access buildings (including Chang’an hospital, the Beijing Proton Center and the Guangzhou Oncology Hospital).

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System:



At each of its oncology centers, CCM has an agreement with the respective hospital partners to lease medical equipment (such as head and body Gamma Knife, Positron Emission Tomography - Computed Tomography (PET-CT); Magnetic Resource Imaging (MRI)) and provide management support in the form of administration and marketing. The oncology centers are located in authorized Government run and managed hospitals. The hospital partners procure all required permits/licenses such as Practice License of Medical Institution; Environmental/Radiation Impact Assessment license; radiation security and preventive training certificates for concerned medical staff, etc.



Before entering into an agreement, CCM ensures that all the required permits and licenses are obtained by the hospital partners. CCM will formalize this procedure to ensure that E&S due diligence and monitoring is undertaken for all new oncology centers.



CCM will establish an overarching policy defining the E&S objectives and principles for all operations that will guide them to achieving sound E&S performance. The policy will specify that the CCM operations will comply with the applicable laws and regulations and the IFC Performance Standards. The policy will indicate who within the organization will ensure conformance with the policy and be responsible for its execution. CCM will communicate the policy to all levels of its organization and other stakeholders.



CCM is in the process of building the Beijing Proton Center, with 70% of the building completed to date. It has obtained a Certificate of Approval for Establishment from Beijing Municipal Commission of Commerce (BJCOC) and Business License for Enterprises as Legal Persons from Beijing Administration for Industry and Commerce and has received preliminary approvals for environment evaluation and radiation protection from the MOE. The Beijing Proton Center will obtain all other required approvals and licenses as per the national government norms, which will include renewal of the license to construct the hospital.



The Guangzhou Oncology Hospital will be located in the Sun Yat-Sen University International Health and Medical Research Center, adjacent to two other developments, Sun Yat-Sen University Cancer Center, Knowledge City Branch and Royal Li Hospital. The hospital license has been obtained, and CCM is in the process of obtaining the medical equipment procurement licenses from the provincial healthcare authority and approval to start construction. The Hospital construction is expected to start in 2013.



CCM will obtain licenses to operate the hospitals from the local MOH offices and will implement the environmental management plan associated with each of the permits.



CCM has procedures and practices in place for the day-to-day operations of the oncology centers related specifically to the marketing and administration functions. CCM staff deputed at the o
ncology centers follow operational procedures for management of E&S issues as implemented by the respective hospital partners (such as management of radio-active waste and other bio-medical wastes, prevention and monitoring of radiation exposure, housekeeping, infection control and fire safety management).



At Chang’an hospital, there is a management system that is designed to ensure compliance with the national procedures and protocols of the Ministries of Health and Environment and the hospital has passed the annual inspections of the Health and Environment Bureaus. Since purchasing a controlling interest in the Hospital in March 2012, CCM has upgraded the management systems focusing initially on non-medical management issues. It is planning to obtain ISO 9001 accreditation. The Company will also upgrade the environmental and social management system, including medical equipment management, patient and staff safety management, fire safety and emergency preparedness and response, housekeeping, infection control and radioactive and bio-medical waste management. CCM will contract appropriately qualified consultants to undertake an audit in line with Good International lndustry Practice (GIIP). Based on this audit, CCM will upgrade the existing management system for Chang’an Hospital and develop a corporate Hospital Management System (HMS) which it will implement in all future hospitals. Key aspects of the corporate HMS will also apply to the oncology centers, such as the radiological safety procedures.



Organizational Capacity and Competency:



CCM operations currently comprise of management of the oncology centers and the Chang’an hospital. Human Resources (HR), finance and accounts for the oncology centers are also managed at the corporate level. The corporate General Manager - Operations oversees the E&S requirements across all operations of CCM.



The Manager of each oncology center is responsible for all the day-to-day operational issues including managing the local E&S and HR related issues. This includes implementation of relevant hospital partner operational procedures. The Manager co-ordinates with the hospital management and along with his operational team provides support to the doctors and other medical staff of the hospital partners for effective functioning of the oncology centers.



Training needs for its staff are defined by the center managers. Accordingly, training programs are developed and delivered by the corporate HR team throughout the year. All new employees undergo extensive induction training, which is organized every month. Induction programs also include hospital management related trainings for the staff. Medical staff, such as doctors and physicians are also provided need based training by CCM in collaboration with the respective hospital partners.



Currently, Chang’an Hospital is managed separately to the oncology centers, with the Hospital Director reporting directly to the Board of Directors of the
Hospital. Designated staff have specific roles with respect to E&S and HR related issues. When the corporate HMS is developed, CCM will define a corporate management and reporting system for the hospitals, outlining roles, responsibilities and competencies.



The corporate HMS will include a training management system that enables CCM to ensure appropriate capacity to achieve effective continuous performance and implementation of the HMS.



Emergency Preparedness and Response:



The CCM staff at the oncology centers follow the on-site emergency preparedness and response procedure (EPR) developed and implemented by the concerned hospital partners.



The EPR at Chang’an Hospital has been developed in line with local regulatory requirements. The audit outlined above will recommend any additional amendments required to meet IFC guidelines and will support the development of corporate emergency preparedness and response policy and emergency preparedness and response procedures for the Beijing Proton Center and the Guangzhou Oncology Hospital. The EPR will cover emergency situations such as fire, earthquake and natural disasters and comprehensive preparedness and response procedures for any radiation leak.



Monitoring and Review:



CCM’s corporate office compiles the information related to HR, operational aspects and commercial aspects for each oncology center. CCM has recently commissioned an information technology (IT) enabled web based portal across different operations for effective monitoring and control. The IT system connects different oncology centers and the Chang’an hospital with the corporate office and information such as staff attendance, patient calls and patient enquiries is monitored. The IT web portal also provides information on oncology treatment and facilities and helps in gathering external enquiries which are then transferred to the respective oncology centers.



The Quality Control and Infection Control Departments of Chang’an Hospital are responsible for monitoring compliance with hospital procedures and regulatory requirements. The procedures include monthly inspections and reporting against more than 100 Key Performance Indicators (KPIs) to the hospital President. This monitoring and review procedure will be assessed against GIIP, as part of the management system audit described above and if any enhancements are recommended they will be also incorporated into the corporate HMS and implemented at the Beijing Proton Center and the Guangzhou Oncology Hospital. KPIs will include energy and water consumption values, bio-medical and radioactive waste record, safety related data such as accidents, fire and safety drills, etc. The summary reports coming out of this exercise shall be submitted to the corporate management team on a regular basis.



Stakeholder Engagement



The company is in the process of formalizing its engagement with the communities in a more strategic manner. This process will become part of the HMS. CCM
will develop and implement stakeholder engagement policies and procedures comprising a grievance mechanism and procedures for external communication on the environmental and social impacts of the operations. Local disclosure of this Environmental and Social Review Summary (ESRS) document will form an important aspect of CCM’s community engagement and disclosure program.

CCM employs 278 in the company headquarters, of which around 30% are female staff. The oncology centers currently have around 632 people comprising of both direct and indirect employees, which will be scaled up to around 900 by 2015 once the new oncology centers are operational. Chang’an Hospital employs 1225 staff, of which 1040 are medical professionals. The Beijing Proton Center and the Guangzhou Oncology Hospital will have 108 regular employees and medical staff when they start commercial operations.



Working Conditions and Management of Worker Relationship:



The Company’s corporate HR department oversees HR management across the oncology centers. Corporate HR policies have been developed as a part of an HR Manual covering various issues related to terms of employment and working conditions for the employees. These are related to recruitment, probation, confirmation, performance evaluation, remuneration including incentives and promotion, leave, overtime, maternity benefits, retirement and disciplinary procedures. CCM ensures fair treatment, non-discrimination and equal opportunity for its staff. The HR Manual covers regular as well as contract employees for all operations of CCM.



At the oncology centers, the Head of HR oversees the appointment of non-medical staff such as helpers, technicians and administration and marketing personnel. The Head of HR has the authority and responsibility to make decisions with respect to hiring, placement, salaries, evaluation, training, transfer, promotion, discipline and separation of the staff according to the HR policy of CCM. The medical staff such as doctors and physicians are directly hired by the hospital partners and are covered by the HR policy and procedures of the respective hospital partners.



HR at Chang’an Hospital is currently managed independently by the Hospital HR Department. As part of the upgrade of Chang’an management systems, and integration of the hospital into CCM, a corporate HR manual will be prepared that applies to the Chang’an Hospital, the Beijing Proton Center and the Guangzhou Oncology Hospital and will be aligned with the policies and procedures adopted for the oncology centers, labor laws for these employees and Performance Standard 2.



There is provision for collective bargaining in China and CCM has no restrictions on employees joining unions, although none are active at any of CCM’s businesses.



Currently, employees can raise grievances through a written complaint to their direct supervisors as prescribed in a documented procedure in the HR Manual. Grievances may then be further escalated to the Head of HR or CEO depending on the nature of the complaint. CCM will update its HR manual to include in its grievance handling procedure a mechanism to also allow for anonymous complaints to be raised and addressed and will ensure that contracted workers also have access to this grievance mechanism.



Protecting the Workforce



The minimum employment age for
all employees is 18 years which is verified through college or school certificates before recruitment. No child labor was observed at the time of the appraisal visit to the oncology centers and the Chang’an hospital.



Further, to ensure that no child labor is employed by any of its contractors (especially construction) relevant clauses will be issued in the contracts with these contractors. CCM will regularly monitor and take strict action (penalty / termination) in case of any observed violations.



CCM’s management of human resources, policy and procedures on labor and working conditions comply with local national requirements and are consistent with IFC PS2 requirements.



Occupational Health and Safety:



The oncology centers, Chang’an Hospital, the Beijing Proton Center and the Guangzhou Oncology Hospital present occupational health and safety (OHS) risks for the employees particularly from radiation exposure and bio-medical waste handling.



At the oncology centers and Chang’an Hospital, adequate personal protective equipment (PPE) such as gloves and masks are provided to the employees as needed. Regular medical checkup and monitoring of employees exposed to radiation is conducted. Medical and non medical staff is provided with personal dosimeters for constant radiation exposure monitoring where exposure would require it. There has been no incident to date relating to radiation exposure of employees beyond the prescribed norms as set by Government authorities and international radiation exposure regulations.



As part of the development of the corporate HMS, CCM will develop and implement a corporate Safety Manual to ensure effective management of OHS risks, particularly risks associated with radiation exposure, for the employees. The Safety Manual will be developed, based on findings of a hazard identification and risk assessment (HIRA) to be undertaken by an appropriately qualified professional for the hospitals and oncology centers.

Workers Engaged by Third Parties:



The Beijing Proton Center and the Guangzhou Oncology Hospital construction work will deploy several contractors. Most of the construction labor will be from the nearby areas and no separate labor camp will be required.



CCM will introduce specific clauses in its contracts with the contractors to include appointing a safety officer on site reporting to CCM; requirements to ensure no child labor is employed by any of contractors; develop a safety calendar and accident/incident record for the site and procure insurance for all the workers.

Resource Efficiency:



Management of resources such as energy and water and emissions and wastes at the oncology centers is the responsibility of the respective hospital partners. CCM staff, as a member of the team implements the procedures of the respective hospital partners for the management of above.



The annual green house gas emission at Chang’an Hospital in 2011 was approximately 4,500 tonnes CO2 eq/yr. CCM will monitor and report to IFC water and energy use of the Chang’an Hospital, the Beijing Proton Center and the Guangzhou Oncology Hospital. CCM will consider measures to maximize energy and water efficiency in the design of the new facilities.



Chang’an Hospital currently uses no freons in its daily operation.



Waste Management:



CCM is committed to ensuring its compliance with local regulatory requirements for waste water discharge, emissions to air, hazardous waste, ambient noise and workplace conditions. In this respect, the company has initiated a program of upgrading effluent treatment and hospital waste management, including construction of a new 1,700 ton capacity effluent treatment plant and new hazardous waste storage facilities at Chang’an Hospital to enable it to continue to meet permitted standards.



At the Beijing Proton Center and the Guangzhou Oncology Hospital, the clinical waste water and sanitary water will be treated in a treatment plant and discharged to the municipal waste stream where it will be further treated.



In order to upgrade the management of effluent and medical waste to meet the requirements of the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines for Health Care Facilities, the HMS will incorporate a formal and documented biomedical waste management system based on JCI guidelines to ensure correct handling and disposal of solid and liquid waste.

At the Beijing Proton Center and the Guangzhou Oncology Hospital, water will be sourced from the local municipal sources. The water quality will be tested to ensure it is potable and meets the national prescribed norms.



Infection control is managed and monitored at the Chang’an Hospital. The audit of the hospital management system will identify opportunities to upgrade infection control management or training of staff and incorporate the recommendations in the HMS.



Life and Fire Safety:



The life and fire safety at the oncology centers is managed by the respective hospital partners. As part of its due diligence prior to entering into a new lease agreement for oncology centers in the future, CCM will verify life and fire safety practices are compliant with local regulatory requirements. CCM will commission a qualified fire safety engineer to prepare a L&FS checklist for CCM staff to verify implementation of national fire safety requirements, which will enable CCM to establish if the life and fire safety provisions are deficient and in need of corrective action.



As per WBG EHS General Guideline requirements, for future hospitals to be constructed (including Guangzhou Oncology Hospital), or existing hospitals to undergo major renovations, the Company will commission a qualified fire safety engineer to prepare a L&FS “Master Plan” (i.e. fire safety specification), which when adopted will cause fire safety aspects of building design and operation to comply with local requirements and one internationally accepted fire safety standard (e.g. U.S. NFPA). The Sponsor will also commission a post-construction audit of the facilities by a qualified fire safety engineer to confirm that the works were completed in compliance with the Master Plan.



Beijing Proton Center is currently under construction. In order to ensure that the hospital will be constructed in line with an internationally accepted fire safety standard as well as the Chinese fire code to which it has been designed, CCM will have the drawings audited by a qualified fire safety engineer and where modifications are required ensure that they are incorporated into the final construction. The post-construction audit will confirm that the works were completed in compliance with the chosen international fire safety code.



As part of the ongoing upgrading of the hospital management system, CCM will also commission a life and fire safety review of the Chang’an Hospital by a suitably qualified professional.



Emergency Preparedness and Response



As described above, the audit of Chang’an hospital management system will recommend any additional amendments to the existing emergency preparedness and response planning which may be required to meet IFC guidelines. These recommendations will be incorporated into the HMS which will be implemented at Chang’an Hospital, the Beijing Proton Center and the Guangzhou Oncology Hospital.



CCM security personnel do not carry fire arms.

Concern for the community and the environment and taking the responsibility to protect them is one of the core values articulated by CCM management. Accordingly, CCM implements several corporate responsibility programs such as free treatment and financial support to poor patients, blood donation camps amongst others.

The Company will disclose this ESRS and the ESAP at its website: http://www.concordmedical.com as well as locally at the following address:

18/F, Tower A, Global Trade Center
36 North 3rd Ring Road East
Dong Cheng District, Beijing 100013


All inquiries and comments may be directed to:
Mr. Adam J. Sun
Chief Financial Officer

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
CCM will establish an overarching corporate policy defining environmental and social (E&S) objectives and principles including the requirements for compliance with applicable laws and regulations and IFC Performance Standards; and roles and responsibility for implementation thereof will also be defined.	03/31/2013 12:00:00 AM	Completed	Completed	12/30/2013 12:00:00 AM
CCM will develop a corporate Hospital Management System (HMS) aligned with Good International Industry Practice and implement it in all its hospitals. The HMS shall reference local and national regulatory requirements, IFC performance standards, and applicable requirements of the EHS General and Healthcare guidelines, taking note of the need for each individual hospital and clinic to comply with the local regulations. It will be developed on the basis of an audit of the Chang’an Hospital management system and practices. CCM will contract an appropriately qualified professional acceptable to IFC to undertake the audit. The audit and HMS will cover elements such as: · Permitting and statutory reporting · medical equipment management, · patient and staff safety management, including hazard identification and risk assessment (HIRA) and radiological safety, · life and fire safety · emergency preparedness and response, · housekeeping, · infection control · radioactive and bio-medical waste management, · training · community engagement, including grievance mechanisms. · monitoring and reporting of key performance indicators (KPI) including energy and water consumption values, bio-medical and radioactive waste record, safety related data such as accidents, fire and safety drills, etc.	12/31/2014	In Progress	In Progress
CCM will develop screening criteria to be reviewed as part of their due diligence prior to entering into leasing agreements for new oncology centers with hospital partners. The criteria will include construction safety, life and fire safety, radiation safety and applicable license and permit requirements.	03/31/2013 12:00:00 AM	Completed	Completed	09/25/2013 12:00:00 AM
CCM will update its HR procedures to include a grievance handling procedure to allow for anonymous complaints to be raised and addressed. CCM will ensure that contracted workers will have access to this grievance mechanism.	03/31/2013 12:00:00 AM	Completed	Completed	12/30/2013 12:00:00 AM
CCM will introduce specific clauses in its contracts with the contractors to include: appointing a safety officer on site reporting to CCM; development and implementation of a safety calendar and accident/incident record for the site; procurement of insurance for all the workers; requirements to ensure no child labor is employed by any contractors (especially construction). CCM will regularly monitor and take strict action (penalty/termination) in case of any observed violations.	03/31/2013 12:00:00 AM	In Progress	Under discussion with IFC client
For the Oncology Centers, CCM will develop and implement a Safety Manual to ensure effective management of occupational health and safety risks particularly related to radiation exposure of the employees, based on the procedures in the HMS.	12/31/2013 12:00:00 AM	In Progress	Under discussion with IFC client
CCM will have the drawings for Beijing Proton Center audited by a qualified fire safety engineer and indicate to IFC where modifications are required to ensure compliance with WBG EHS General Guideline requirements.	03/31/2013 12:00:00 AM	In Progress	Under discussion with IFC client
CCM will undertake a post-construction audit of Beijing Proton Center to confirm that the works were completed in compliance with the chosen international fire safety code.	12/31/2014	In Progress	In Progress
CCM will commission a life and fire safety review of the Chang’an Hospital by a suitably qualified professional and implement any corrective actions.	03/31/2013 12:00:00 AM	Completed	Completed	12/04/2013 12:00:00 AM
All future hospitals will be designed in accordance with Chinese life and fire safety requirements and an international life and fire safety code (such as NFPA). CCM will (i) prepare preliminary drawings and specifications that comply with an internationally accepted L&FS standard eg. USNFPA; and (ii) engage suitably qualified professional(s) to certify that the design is in material compliance with local as well as internationally accepted life and fire safety standard(s); and (iii) provide to IFC certification that the construction of the life and fire safety systems has been carried out in accordance with the accepted design.	12/31/2018	In Progress	In Progress