While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the 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
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This proposed investment is classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects, as the environmental and social impacts of the project remain to be limited, site-specific and can be minimized, avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria.

The key environmental and social aspects of the project are; capacity of the SBRE’s corporate E&S management system to effectively manage E&S performance, including its ability to enable current and future project compliance with IFC’s PSs; land/building acquisition, permits, regulatory compliance; environment, health and safety practices during construction; structural design, life and fire safety; waste management particularly including construction waste; hazardous materials management; occupational health and safety including employee training and monitoring programs; contractors management; adequacy of human resources policy and practices; community health, safety and security.

SBRE has presented information on how its current practices and policies address the identified impacts and how it will ensure that the proposed projects, upon implementation of the specific agreed measures, comply with the environmental and social requirements, which include the Georgian laws and regulations and IFC’s Performance Standards (dated January 01, 2012). The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).

As the planned project sites are located in urban areas within the city center and no indigenous people are known to be in the area or affected by the project, no issues have been identified in relation to PS6 andPS7. The SBRE is not expected to encounter issues covered by PS8 Cultural Heritage in this project as the current and potential project sites do not have any features of historic or cultural value. However, since it operates in historic center of Tbilisi, the Company will develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage.

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, Policy and Identification of Risk and Impacts and Management Programs: SBRE is a subsidiary of Bank of Georgia (BoG), an existing client of IFC.

SBRE has a documented management system consisting of the Policy and procedures for identification and management of environmental, social, occupational health and safety (ESOHS) risks and impacts; emergency preparedness; monitoring and reviewing ESOHS performance.



The company performs a comprehensive due diligence of proposed project sites which includes evaluation against IFC’s PS (2006 version). SBRE will update the due diligence with respect to IFC’s PSs (2012 edition) and WBG General EHS Guideline.



SBRE will also be required to provide a copy of the Building Permits for the proposed projects.



Organizational Capacity and Competency: SBRE have a management team consisting of managers reporting to CEO, including Real Estate Development Department, Project Management Department, Property Management Department, Sales &Real Estate Brokerage Department, Finance & Accounting Department. Real Estate Development Department is responsible for overall project management and supervision of the project development as well as establishing and developing relationships with contractors/construction, nominated subcontractors, designers, architects, lawyers, etc. and obtaining permits, approvals and licenses from authorities. Project Management Department and Chief Operations Officer are responsible for design of the project, as well as management of the contractors and construction related consultants. Project Management Department is also responsible for the organization of tenders for selection of contractors. Project Management Department and Chief Operations Officer are responsible for assessing environmental and social risks in line with PSs and if necessary for ensuring mitigation measures were taken during the design and/or construction phases. For the completed and ongoing construction projects, SBRE used local contractor companies. For the proposed projects, SBRE is looking for the opportunity to work with international construction companies.



SBRE’s management has a good understanding of IFC’s PSs and WBG’s General EHS Guideline requirements. For the completed and ongoing construction projects, ESOHS awareness trainings (including risks identified during the ESDD process and related mitigation measurements) were provided for the contractor’s employees. For the proposed projects, similar training will be conducted before the construction works will be started. SBRE will provide IFC a training program to ensure contractors/ will be trained.



Emergency Preparedness and Response: SBRE has a documented emergency preparedness and response plan applicable to both construction site and offices which covers fire, earthquake, flood, heavy rain and wind, personal injuries and first aid, terrorism and civil disturbance, suspicious devices a
nd bombs, mailed suspicious package etc. for both construction sites and offices.



Monitoring and Reviewing: SBRE has a system in place to monitor and review key performance indicators (KPIs), including injuries, near misses, spills / leakages, waste management issues, community complaints on a monthly basis. Based on the documents reviewed during the site visit, no complaints have been raised related with the completed and/or ongoing projects. A consultant company is performing daily site inspections and reports ESOHS issues to SBRE’s management. SBRE will regularly submit to IFC an Annual Monitoring Report on Environmental and Social Performance, including KPIs, prepared in accordance with the IFC’s Performance Standards and guidelines.



External Communications and Grievance Mechanism: SBRE has a system to record complaints from community near its project sites. SBRE will be encouraged to develop an external communication and grievance mechanism –on its website where all interested parties can raise and register their concerns.



Ongoing Reporting to Affected Communities: SBRE will be required to share information related with the progress of the projects on its website through annual performance reports.

Working Conditions and Management of Worker Relationship: SBRE employs almost 50 employees and. during the construction phase, 250-300 employees will be hired by contractors.



There are documented Human Resources (HR) Policy and Procedures defining key responsibilities of HSE consultant, site supervisor and staff, procedures covering, ethics, legal requirements, employment agreements and employment conditions, code of conduct, disciplinary actions and grievance, compensation and supply chain management. There is no discrimination on the basis of personal beliefs, sex or characteristics, and there is no prohibition or discouragement of freedom of association. SBRE is not anticipating retrenchment. There is a formal grievance mechanism where all employees can raise and register their concerns.



SBRE will ensure that adequate facilities and amenities are provided in the construction labor accommodation including: adequate living/sleeping facilities (if needed) and space per person; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste by incorporating requirements to the contractor contracts.



Protecting the Work Force: In compliance with local labor laws and the Company’s policy, SBRE does not use child or forced labor. Contractors are also required to hire only employees older than 18 year of age, which is confirmed through verification of documents and controls during the daily inspections and at construction site gates. Workers Engaged by Third Parties: SBRE verifies that companies/personnel contracted to do the construction work are legal entities with a Certificate of Registration and a labor license issued by the statutory authorities. SBRE has included in the contracts with construction companies explicit clauses regarding labor and occupational health and safety. The company will review these clauses to incorporate conditions for worker’s accommodation, access to grievance mechanism, and any additional conditions derived from the implementation of the ESMS such as management of construction debris or reporting in case of finding archeological property. Occupational Health and Safety: SBRE has a well documented manual for safety and environment. Topics include key responsibilities, medical examination, substance abuse at work, training, communication, new employees and visitors, ESOHS policy, risk assessment, inspections, toolbox talks, work authorization, management review, incidents, workplace safety, worksite setup, walkways and barricades, safety signs, housekeeping, parking areas, access roads, groundwork and excavation, work at heights among others. All construction site workers are required to have initial safety training prior to starting work. For the ongoing project, a consultant company was appointed to perform audits, inspections and training of personnel. SBRE developed
several programs to ensure occupational health and safety for the employees. All contractor employees for the ongoing project received training and are qualified to deal with specific risks of their workplaces. Mitigation measures such as use of personnel protective equipment, work equipment improvement, training, etc. related with the workplace risks were implemented.



SBRE will apply its existing ESOHS control for the contractors during the project construction phase. Occupational health and safety rules and other working conditions, in accordance with the IFC PS2 requirements, will be included in contractor agreements. In addition, SBRE will establish regular inspection mechanisms to ensure compliance of contractors with the contractual requirements.

Resource Efficiency: During the construction phase and when the facilities are in use, water is supplied from the municipal networks and electricity from the city grids. For the heating of the houses, each house unit will be provided with boilers. Natural gas (NG) will be the main source for house heating. Both water and energy (electricity and fuel) consumption will be monitored and reported internally and SBRE will provide the figures to IFC through Annual Monitoring Report.



Resource efficiency measures have been considered in the design of the developments such as double glazing for windows, thermal and water insulation for the roof, cross (natural) ventilation in place and blinds for shadowing.



Greenhouse Gases (GHG): The main source for GHG during the construction phase will be the fuel consumed by construction vehicles and electricity usage during the construction and SBRE will provide the figures to IFC through Annual Monitoring Report.



Waste Management: For the ongoing project, SBRE has a comprehensive waste management system including waste segregation and daily inspections. The excavation wastes, hazardous chemical packages, domestic wastes, non hazardous packaging materials, scrap metals are either sent to Municipality Landfill Area and/or to the licensed waste recycler. SBRE will provide waste figures to IFC through Annual Monitoring Report.



Hazardous Materials Management: SBRE will be required to have specific control measures, including secondary containment, spill kits, and fire safety controls where hazardous materials, such as cement addictives, coating materials, etc. will be stored and/or used.

Community Health and Safety: Local authorities are working on the existing Georgian Building Code to incorporate internationally accepted, life and fire safety requirements. To minimize the risks caused by potential gaps in local requirements, SBRE will engage professional services of a qualified Life and Fire Safety professional, acceptable to IFC, to ensure that the design incorporates the presence of at least two escape routes and a fire detection/alarm system throughout the entire building in line with internationally recognized Life and Fire Safety Code.



Both of the proposed project sites are within the city center and SBRE will be required to implement construction area safety measures to protect the community, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed.



As part of the implementation, SBRE will develop and implement procedures for traffic safety to ensure safe movement of construction vehicles within the site and out of the site.



Other impacts to the community such as noise, air pollution and other nuisances during construction will be assessed and documented procedures to mitigate those impacts will be developed and implemented. Monitoring data for noise and air pollution will be monitored and provided to IFC by Annual Monitoring Report.

Security: SBRE employs unarmed security forces at the gates of the ongoing project site.

As the planned project sites are located in urban areas within the city center and no indigenous people are known to be in the area or affected by the project, no issues have been identified in relation to PS6 andPS7. The SBRE is not expected to encounter issues covered by PS8 Cultural Heritage in this project as the current and potential project sites do not have any features of historic or cultural value. However, since it operates in historic center of Tbilisi, the Company will develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage.

SBRE maintains good relations with local communities and its customers. SBRE has a formal external grievance mechanism where neighboring communities can raise and register their concerns. There were no concerns raised previously for the completed and ongoing projects. The interested parties can share their concerns with the local authorities where the local authorities will follow up and provide feedback. The information related with SBRE’s grievance mechanism is shared at the gates of the project sites.

This Environmental Review Summary and relevant action plan will be available at SBRE’s Head Office, SBRE’s internet site and at proposed project gates,

For more information please contact:

Name Giorgi Nadareishvili

Address: JSC SB Real Estate
27 Gamsakhurdia Avenue,
Tbilisi, 0160, Georgia
Tel: +995 32 244 48 93
Fax: +995 32 238 40 10
e-mail:

http://www.sbre.ge

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
1a) Update the due diligence reports for proposed projects with respect to IFC’s PSs (2012 edition) and WBG General EHS Guideline and provide IFC a copy.	07/01/2013 12:00:00 AM	Completed	Completed	08/02/2013 12:00:00 AM
2b) Establish regular inspection mechanisms to ensure compliance of contractors with the contractual requirements.	04/30/2013 12:00:00 AM	Completed	Completed	10/09/2013 12:00:00 AM
1b) Provide IFC a copy of the Building Permits of the proposed projects	04/30/2013 12:00:00 AM	Completed	Completed	01/29/2014 12:00:00 AM
1c) Develop an external communication and grievance mechanism – on the website where all interested parties can raise and register their concerns and to share information related with the progress of the projects on the website through annual performance reports.	03/31/2013 12:00:00 AM	Completed	Completed	10/09/2013 12:00:00 AM
2a) Review contracts to incorporate clauses including conditions for worker’s accommodation, access to grievance mechanisms, and any additional conditions derived from the implementation of the ESMS such as management of construction debris or reporting in case of finding archeological property.	04/30/2013 12:00:00 AM	Completed	Completed	10/09/2013 12:00:00 AM
2c) Provide IFC a training program to ensure contractors will be trained.	04/30/2013 12:00:00 AM	Completed	Completed	01/27/2014 12:00:00 AM
3a) Incorporate water and energy (electricity consumption by equipments and fuel consumption by construction vehicles) consumption and waste generation monitoring during the construction phase to the key performance indicators.	04/30/2013 12:00:00 AM	Completed	Completed	09/13/2013 12:00:00 AM
3b) Develop and implement control measures, including secondary containment, spill kits, and fire safety controls where hazardous materials, such as cement addictives, coating materials, etc. will be stored and/or used.	04/30/2013 12:00:00 AM	Completed	Completed	11/20/2013 12:00:00 AM
4a) To minimize the risks caused by potential gaps in local requirements, SBRE to engage professional services of a qualified Life and Fire Safety professional, acceptable to IFC, to ensure that the design incorporates the presence of at least two escape routes and a fire detection/alarm system throughout the entire building in line with internationally recognized Life and Fire Safety Code.	04/30/2013 12:00:00 AM	Completed	Completed	08/14/2013 12:00:00 AM
4b) Implemented construction area safety measures to protect the community, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed.	04/30/2013 12:00:00 AM	Completed	Completed	11/20/2013 12:00:00 AM
4c) Develop and implement procedures for traffic safety to ensure safe movement of construction vehicles within the site and out of the site.	04/30/2013 12:00:00 AM	Completed	Completed	11/20/2013 12:00:00 AM
4d) Develop a system to monitor noise and air pollution resulting from the construction activity and implement documented procedures to mitigate those impacts.	04/30/2013 12:00:00 AM	Completed	Completed	10/09/2013 12:00:00 AM
5a) Provide a progress report to IFC about the resettlement of the remaining families at 25 Kazbeghi Avenue.	04/30/2013 12:00:00 AM	Completed	Completed	04/08/2013 12:00:00 AM
6) Develop a procedure in line with IFC’s PS8 requirements to define the steps to follow in case of finding any archeological / cultural property	04/30/2013 12:00:00 AM	Completed	Completed	11/20/2013 12:00:00 AM