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.

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.

PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources - Biodiversity Conservation and Sustainable Management of Living Natural Resources: HEM’s proposed expansion will not have impacts upon biodiversity or natural resources due to sites being located in heavily modified urban neighborhoods.

PS 7: Indigenous Peoples - No Indigenous People are impacted by the current locations of the facilities

PS 8: Cultural Heritage - No sites of cultural heritage are impacted by the current locations of the schools; future locations will be screened so as to avoid any significant issues associated with Cultural Heritage.

Based on the site visits to HEM’s premises in Morocco, and discussions with HEM management, this project will have limited potential adverse environmental and social impacts which are site-specific, reversible and easily addressed through the measures summarized below in addition to the agreed mitigation measures as outlined in the Environmental and Social Action Plan (ESAP) attached to this ESRS. This is hence a category B Project.

The main E&S issues related to HEM are land/building acquisition, permits, regulatory compliance; environment, health and safety during construction/renovation/restructuring; building structural safety, life and fire safety, emergency preparedness and response; energy and water efficiency; hazardous materials, wastes, emissions and effluents management and minimization, human resources policy and practices; safety and hygiene control mechanisms both for personnel and students, supply of food and drinking water, engagement with communities.

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.

HEM has a centralized Management system for their HR and administrative issues that are based in their headquarters in Casablanca. HEM does not however have a system to run and operate their environmental and social issues. These are often run separately at each of the campuses by a Maintenance Manager at each location. HEM will develop and implement a corporate Environmental and Social Management System (ESMS) consistent with PS1 requirements for all of HEM. The ESMS will encompass management of social, occupational health and safety, human resources, and environmental matters associated with the full life cycle of operations from the selection of sites for expansion, the construction and/or renovation of new facilities as well as the operation of existing facilities and associated facilities. The ESMS will be applied and implemented on the HEM Group level and be rolled out to all facilities. As the first step, HEM will (1) appoint an ESMS officer to be responsible for the ESMS implementation, and (2) establish a Policy defining the environmental and social principles and specific objectives to guide the Project to achieve sound environmental and social performance, consistent with the national regulatory requirements, IFC’s Performance Standards and World Bank Group’s (WBG) EHS Guidelines.



Risks and Impacts Identification Process

HEM’s process of E&S due diligence for new campuses is done in accordance with national regulations. HEM acquires lands and/or rents buildings for their campuses according to one unique process, which integrates all requirements by law. To commence construction, the client needs an authorization from the authorities which cannot be granted unless they provide the appropriate documentation and screening documents, including environmental and social issues. This process is in addition to the authorization they request from the Ministry of Education to operate the schools. HEM’s current screening process is adequate to fulfill national regulations, however in order to fulfill IFC’s PS1 requirements, HEM will need to incorporate in their ESMS a screening procedure for all new campuses to identify risks and impacts in accordance with IFC’s Performance Standards which are absent from their current screening process including tackling community issues, involuntary resettlement, cultural heritage, and biodiversity.



Management Programs

To manage and mitigate the risks and impacts of their operating assets, HEM will develop a tailored set of pollution standards, design criteria, and operating procedures that apply across all operations. These will include, but not be limited to the following pollution prevention and health and safety issues:

Environmental and Social considerations for land acquisition process;

Consideration of Resource Efficiency and Life & Fire Safety’s features in the building’s design and operation;

Health and Safety of construction workers and public during construction and/or renovation;

Waste management



Organization

To ensure adequate support of the newly designated EHS Officer, HEM will clearly define his/her responsibilities and communicate these to the rest of the Company and site operating staff. The corporate EHS department will also be provided with sufficient authority and resources to achieve effective and continuous E&S performance at all sites. This may include in-house staff, as well as external consultants.



Emergency Preparedness and Response

The school currently has no emergency response plan in the instance of evacuation or crisis. HEM will be required to develop one to be incorporated in the ESMS.



Monitoring and Reporting

HEM will develop a company-wide environmental monitoring framework that can be adapted and used to guide site-specific monitoring plans. The framework will address monitoring of groundwater, swimming pool water, waste, energy, and life and fire safety. It will identify the specific environmental monitoring measures to be implemented at each site - the parameters to be measured, sampling and analytical methods to be used, sampling locations, frequency of measurements, detection limits (where appropriate), and the definition of thresholds that signal the need for corrective actions. Monitoring thresholds will be consistent with those referenced in the General IFC EHS Guidelines.



The results of project-specific social and environmental monitoring should be evaluated and documented at both the project and corporate level. Periodic reporting of progress and monitoring results should be made to the senior management of the Company. Reports should furnish the information and data needed to determine compliance with the E&S Policy. The format of these reports will include a summary of findings and recommendations. This information should also be made available broadly within HEM.

Human Resources:

HEM currently has an HR policy that is being developed and formalized. This HR policy and procedures need to be in line with IFC’s Performance Standard 2, and hence HEM needs to update it to transform it into a Group-wide HR policy and Procedures for all their facilities to meet IFC’s Performance Standard 2 by incorporating but not limited to non-discrimination and equal opportunity, retrenchment, grievance mechanism, Occupational Health and Safety, Third Party workers, etc. These gaps between HEM’s current HR policies and IFC’s Performance Standard 2 need to be addressed and met. HEM has a total of 164 full time staff, including 30 full time professors. HEM also employs 200 part-time temporary professors, 10 part-time auxiliary professors, and 50 part-time foreign professors. The majority of their full time staff (over 50%) has been employed between 2-10 years in HEM with a low turnover rate. The female/male ratio of staff at HEM is exactly 50/50, with women being employed in many Managerial positions and Deans of Campuses. Over 95% of the staff employed is local (Moroccan), while the remaining is International. Recruitment process is conducted in accordance with their HR policies, which is still currently being developed. The HR policies are sent to new recruits along with the contract.



Occupational Health and Safety

HEM has never had any incidents or accidents since its establishment in 1988 at any of their campuses. All staff has medical insurance and students have primary medical care at the on-site campus clinics. There is a clinic on site for staff and students in the Campuses in case of immediate medical attention. The catering service and food in the Cafeteria of each of the schools is outsourced. . Each of the campuses has a different supplier based on proximity.



OHS is an issue of concern primarily during the construction phase of the project. Since HEM has their own architect and designer for the construction of new campuses, they also perform a role of the Project Managers during construction. Contracting activities are outsourced to a contractor during construction, but Project Management responsibilities still lie at HEM and hence the Company is liable for all construction activities at their campuses. As such these construction activities need to be properly monitored. Construction contractors and their sub-contractors will be contractually required to adhere to the HEM’s Occupational Health and Safety (OHS) Policy and specific requirements to avoid accidents and promote safety, including toolbox talks, use of protective equipment as required for noise protection (ear-plugs, etc.), dust protection (goggles, etc.), personal fall protection (life-lines, harnesses, etc.) and other more general protective equipment (steel toe boots, reflective vests, hard helmets, gloves, etc.) and others. Construction contractors will be also required to report monthly on listed safety parameters to the Owner Rep
resentative.

Water and wastewater:

All Campuses have their own well on site that is licensed by the government, and water use is partly from the groundwater pumped from this well which is approximately 80 m deep. Water from the well is used for the showers, the pool, and irrigation of green areas. Source water for the pool is filtered, disinfected and tested regularly for pH levels. Where reason exists to suspect that hazards to human health may be significant, reliable and replicable analyses will be undertaken for testing and monitoring of groundwater prior to use. A pool water sanitization program is regularly implemented for micro-organisms growth control in the pool, and HEM will continue to do so. Potable water is obtained from the national grid and meets national requirements. Wastewater is discharged to the network and the fee is included in the price of water supply distribution. Total water consumption in 2011 was 16,686 m3.



Energy:

Electricity is generally purchased from a private company that has a public private partnership with the government. This is done for each of the Campuses. Energy is reliable and hence on-site generators are not common in Morocco and not needed. The Marrakesh Campus has utilized solar water heaters on the roof of their building. This Campus is the only campus that has implemented this. Total electricity consumption in 2011 for all HEM campuses was 629,447 KWh.



HEM has a total of 22 company cars for staff, 1 large bus, and 2 mini buses for students that all run on diesel. Most students use their own personal cars.



Total GHG emissions by all HEM Campuses in 2011 were 3615 tons CO2 equivalent, with the largest bulk of the emissions (over 80%) coming specifically from refrigerants. Refrigerating systems use Freon R-22, which contributes to depletion of the ozone layer. While its use in the HEM existing systems is acceptable, new systems will use substitute refrigerants.



Waste:

HEM does not separate its waste nor does it monitor or account for its waste in terms of quantification. Waste is collected once daily by the municipality and disposed of. HEM is presently unaware of the final waste disposal method. HEM Marrakesh campus began a waste separation initiative that was founded by one of their students that turned into a campus habit for waste separation and recycling. They now have separate bins for paper, plastic, and aluminum cans. These separate waste bins are collected by a recycling company upon request when bins are full. HEM has expressed interest in doing this on a Group level for all of their schools. Moving forward, HEM will develop a solid waste management program, which will focus on opportunities of waste minimization, recycling and/or reuse, and safe disposal. HEM does not produce any hazardous waste at their facilities.



Resource Efficiency:

HEM will establish an effective monitoring system and develop a water and energy efficiency program at all their facilities to reduce water a
nd energy consumption, and explore opportunities of increasing Energy Efficiency in the building design. Such a program will be mainstreamed into their planning process for efficiency and reduction targets. A series of opportunities for water and energy savings will be identified with a plan of action to outline how to implement each action item in this water and energy savings plan. Internal benchmarking for each building for water and energy will be developed to ensure that targets are met. Similar provisions will be done for any new facilities in accordance with all above activities. HEM will also explore the feasibility of getting LEED certification for their facilities as an option to be outlined in their Energy and Water Savings Plan as a part of their potential opportunities for green building design.

HEM has employed 10 full time security personnel and 3 part-time security personnel for the day, and

8 full-time and 4 part-time security personnel for the night shift. There are no security risks posed by the company’s security arrangement due to the location of the facilities in residential low security risk areas in Morocco.



HEM currently has limited accessibility for disabled persons with few ramps in certain areas, but moving forward HEM will ensure that all future facilities will provide for the mobility of disabled persons so that disabled people may attend.



Life and Fire Safety:

Each of the 5 current Campuses and research institute were designed by the same architect and hence, all follow the same design with respect to life and fire safety. Campuses are built under national standards. Moving forward, HEM will provide a formal verification by a qualified professional, acceptable to IFC that the Master Plan (prototype design) for new buildings is in line with NFPA 101 or any other internationally recognized Life and Fire Safety Code. Upon completion of construction, HEM will provide evidence to IFC’s satisfaction that the buildings’ design and construction faithfully incorporate all elements of the corporate Master Plan.



HEM has a fire procedure for evacuation that was put in by the fire department, but they have never done any fire drills in their campuses. The fire department comes to annually check the fire extinguishers and certifies the premises. Fire departments in most of the campuses are located at close proximities to the schools. HEM has an Emergency Response Plan that was put in place by the National Fire Authority and fire department.

As a part of HEM curriculum, students are required to take a course called “Free Project” whereby they are required to do some community based project. Such projects could be anything from environmental awareness, to charity for the lower income communities in neighboring areas, to socially conscious health care initiatives. These projects often engage the students to better their understanding with their community and to allow them to get involved to make a difference. HEM is hence in contact with all the NGOs in all of the campus locations, for accessibility of their students to get involved in their work directly or to better advise them on how to proceed with their own work. HEM often engages their students through this Free project.

All HEM campuses are carefully selected in locations that are in residential settings close to the urban center. The communities surrounding the campuses are often residential high class neighborhoods. In some of the campuses including Casablanca and Rabat, the campuses are located in the middle of the residential neighborhood whereby creating parking problems for the residents of the neighborhood by their students. Residents have often complained of the parking problems, and HEM are considering expanding their premises to allow for a parking space and to potentially relocate in the future. HEM has no formal grievance mechanism, but the neighborhood is closely connected to HEM and the school is not fenced and interaction occurs regularly. Moving forward, HEM will be required to develop a form community grievance mechanism to ensure proper inclusion and communication at all times.

HEM will be posting the ESRS and ESAP on its website in both English and the local language of French and English (http://www.hem.ac.ma). In addition HEM will also disclose reference to these project documents in the following newspapers: Le Matin and Akhbar El Yom.
Contact Person:
Lamiâe Oudrhiri – HR Manager
e-mail: mailto:l.oudrhiri@hem.ac.ma
Phone : 00212 522 52 52 52

Broad Community Support is not applicable for this project

Action Deadline Develop environmental, health and safety (EHS) procedures. 6/15/2013 Upgrade Human Resources (HR) policy and procedures. 6/15/2013 Appoint a ESMS Officer. 3/15/2013 Develop a Waste Management Procedure. 6/15/2013 Develop a land acquisition and compensation procedure 6/15/2013 Formal Verification of LFS Master Plan. 5/15/2013 Develop a Community Grievance Mechanism. 6/15/2013 Ensure that future educational facilities provide for the easy mobility of disabled persons. 5/15/2013 Develop and submit brief work plan, budget and implementation schedule for an Energy and Water Efficiency Plan 6/15/2013