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

The Company’s activities have limited potential for environmental and social impacts that are mainly site specific, largely preventable and/or reversible, and that can be addressed through the implementation of specific mitigation measures. This is therefore a Category B according to IFC’s 2012 Policy on Environmental and Social Sustainability.

Risks discussed in this ESRS consist of those associated with the operation of a biomedical laboratory and includes labor and Occupational Health and Safety (OHS) issues related to exposure to blood-borne pathogens and other potential infectious material; solid and hazardous wastes disposal (biological);life and fire safety; EHS management capacity and management systems. Key mitigation measures are described in the Environmental and Social Action Plan.

No land acquisition, conversion of habitats or physical or economical displacement are expected as part of the Project; therefore, PS 5 “Land Acquisition and Involuntary Resettlement”, PS 6 “Biodiversity Conservation and Sustainable Natural Resource Management”, PS 7 “Indigenous Peoples”, and PS 8 “Cultural Heritage” are not expected to be applicable.

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.

Policy:

As set forth in the ESAP, Helix will develop an overarching policy, in line with IFC Performance Standards, defining environmental, health, and safety objectives and providing a framework for the Company’s management and operational activities, including franchises. The policy will signal to both employees and clients the importance that Helix places on managing social, environmental, health and safety risks.



Helix manages its environmental and social aspects in compliance with national and local laws and regulations. The Company has an integrated management system for quality assurance (IMS/QA) and has been certified under ISO 9001:2008 by SGS. The certificate only covers Helix’s laboratory and diagnostic centers (3) located in St. Petersburg; however, the Company is applying the IMS/QA to all its operational centers. All franchises are required, as stipulated in the franchise agreement, to follow the Company Quality assurance management system. Helix is currently preparing for ISO 15189:2007 certification for Medical Laboratories for which a preliminary audit was conducted by Bureau Veritas in February 2013 and a second audit is scheduled for October 2013.

Helix will integrate its existing EHS management system to coverer key environmental, and occupational health and safety issues, consistent with IFC PS1 requirements.



Environmental and Social Assessment:

Helix has not conducted a comprehensive corporate E&S risk analysis. However, the Company does follow Russian Federation directives for risk identification of jobs performed at the laboratories and diagnostic centers. Hazards and risks associated with specific tasks for each of the Company departments (e.g., retail chain, nurses, administrative; laboratories) have been analyzed under detailed standard operating procedures (SOPs) developed as part of Helix certified IMS/QA. All franchises have to operate under these SOPs. As outlined in the ESAP, Helix will conduct a corporate EHS risk analysis to identify major EHS issues and relevant mitigations to assess which EHS elements should fall under the direct control of the Company or specific clauses added to the franchise covenant to mitigate the risks. In addition, the Company will develop specific SOPs for the in-house renovation and maintenance personnel.



Management Program:

Helix laboratories, diagnostic centers and collection points currently have some mandatory environmental and social programs in place as part of the Company IMS/QA. These include occupational health and safety (OHS) risk prevention, OHS health management and solid waste management programs. As part of IMS/QA implementation, Helix will further develop all necessary management procedures and programs to deal with the possible gaps identified during the preparation of the corporate EHS risk assessment.



Organization:

Helix’s deputy administrative director is appointed as the person responsible for most EHS issues. However, the dep
uty is involved only when specific EHS issues are raised and mainly concentrate his duties on fire safety issues. The director of quality and standardization oversees compliance with the required licenses and certifications, the overall Company compliance with the IMS/QA, and handles client grievances. As the business expands the Company may consider the appointment of an EHS manager at the corporate level to oversee EHS issues, to develop Helix corporate standards and to ensure franchises implement the EHS management system and related programs.



Training:

Along with mandatory instructions and tests required by the local legislation for specific jobs (e.g. nurse, doctors.), Helix has developed comprehensive training modules for its administrative personnel and nurses that operate at diagnostic centers and collection points. Mandatory two-week training and a passing grade in a practical and theoretical test is required before applicants are considered for hire. All personnel have to be familiar with Helix’s SOPs and internal policies. Additional training is given if new procedures are introduced or in response to specific and repeated grievances from clients.



Monitoring:

Helix monitors its compliance with local requirements and its IMS/QA procedures through regular formal inspection conducted by area managers. The Company has developed a comprehensive inspection form covering the main aspects of its operations (e.g. waste disposal, cleanliness and sterilization, housekeeping, following of internal procedures). Inspections, which cover both Helix owned and franchised locations, are conducted at least twice per month and reports are sent to headquarters in St. Petersburg for review. As described in the ESAP, the Company as part of the integration of its existing EHS management system will develop standard EHS key performance indicators (KPIs) and target values to monitor sensitive EHS issues. The KPIs will be used by Helix’s senior management to track company EHS performance and indicate areas of improvement.



Reporting:

Inspection reports and client grievances are all reported to headquarters where they are analyzed directly by the ownership and, if required, actions taken. Helix will develop and implement a formal corporate standard for EHS reporting.



Emergency Preparedness and Response

As part of its IMS/QA, Helix has developed specific emergency response procedures for fire and accidental exposure to biological and chemical hazards. As set forth in the ESAP, the Company will develop emergency response and preparedness plans covering emergency scenarios (e.g. fire evacuation plan) for all facilities and conduct training and emergency drills for all its personnel.

Human Resource Policy and Management:

Although Helix does not have a formal general human resource (HR) policy, the Company follows Russian labor regulations, which are consistent with the International Labor Organization (ILO) standards (the Russia Federation is a signatory of most relevant ILO conventions). Helix manages HR issues and terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday, according to national labor regulations. All workers have to sign a contract that clearly defines terms of employment; a copy of the contract is available from the HR department upon request. Contracts for franchisee personnel are determined by each franchise owner with Helix providing advice and standard contract guidance.



Labor unions are not present; IFC’s review found no evidence that the Company restricts workers’ freedom of association.



As set forth in the ESAP, Helix will develop a corporate HR policy and will develop and put in place supporting HR procedures, such as hiring and termination of contract policy, duties and compensation policy(ies), performance assessment and promotion policy, and benefits policy that are consistent with local laws and IFC’s PS 2 provisions.



Non-Discrimination and Equal Opportunity:

Helix’s employment relationship operates based on the principle of equal opportunity and fair treatment. The Company currently employs 485 permanent workers of which 22.5% are male and 77.5% female, a ratio consistent with the nature of the work and other industries benchmarking. About 150 people work in laboratories, 40 are in direct sales, 10 people are involved in renovation/maintenance work, and the balance includes administrative personnel, nurses and doctors. The Company also recruits, screens, and trains all personnel that are then employed directly by the franchisee. During the field visit, no evidence of discrimination based on workers’ personal characteristics unrelated to the job requirements was identified.



Retrenchment:

Since the Company is planning to grow, no retrenchment is expected for this project.



Grievance mechanism:

Currently, internal grievances are dealt with informally with personnel talking to their direct supervisor on work related issues. As outlined in the ESAP, Helix will develop a formal internal grievance mechanism for its workforce to raise concerns and inform personnel on relevant procedures and use. The mechanism will involve the appropriate level of management, address concerns promptly using a transparent process, provide timely feedback and, allow for anonymity.



Protecting the Work Force:

No forced or child labor is used at any of Helix operations. The Company directly hires all its workers (no intermediaries are use) following national laws. The minimum legal working age is 16 but, given the nature of its operations, Helix does not employ anybody below the a
ge of 18.



Occupational Health and Safety:

Helix manages OHS risks in a manner compliant with national and local regulations. A federally registered and authorized company performs annual inspection to assess job risk compliance. The Company has assessed OHS risks for relevant tasks performed as part of its operations and has assigned a specific code to each task. Codes are then paired to workers in order to ensure that personnel with the appropriate training are performing specific tasks. Company SOPs for specific tasks clearly spell out OHS risks, potential workers exposure to hazardous agents, and define the required personal protection equipment to be used. Standard PPE for laboratory and diagnostic centers personnel is provided by Helix and includes gloves, laboratory coat, and clean shoes. Additional PPE requirements (e.g. face masks) are required for specific tasks. As outlined in the ESAP, Helix will adopt and implement minimum requirement PPE for the renovation/maintenance crew. Employees undergo a preliminary medical check before hiring and on a yearly basis as mandated by law. In addition, personnel that may come in contact with blood are vaccinated against hepatitis B, diphtheria and rubella. The Company, on a voluntary basis, provides flu vaccine to all personnel. First aid kits, both generic and specific for infectious diseases, are available throughout the laboratories and diagnostic centers. The Company, as set forth in the ESAP, will ensure that first aid kits are also available on site for personnel involved in renovation/maintenance work.



Helix, will consider enhancing the existing monitoring program to assess workers’ exposure to pathogenic agents and adherence to prevention measures, including periodic inspections, internal corporate audits and reporting.

Resource Conservation, Energy Efficiency:

Helix purchases electricity from the grid with total annual consumption for the two laboratories and the 15 diagnostic centers owned of about 1,271,000 kWh per annum. All Helix appliances (e.g. air conditioning units, refrigerators) are new and have average or above average energy efficiency grading. As part of the management system implementation Helix will monitor energy consumption from its facilities and identify potential areas of energy savings.



Pollution Prevention:

Solid waste streams consist mainly of paper and paperboard, plastic material from sample packaging, and sanitary and organic waste. Hazardous wastes include biological material (laboratory wastes, in St. Petersburg and Yekaterinburg), used needles, and materials such as primary packaging that have been in contact with biological samples. Hazardous waste is segregated from general waste at the source using color coded puncture resistant bags.

Biological material from the laboratories is sterilized using a combination of special disinfectants and microwave treatment. Biological waste from the microbiology laboratory is sterilized in an autoclave, stabilized with an inert material. Hazardous waste from diagnostic centers is sterilized using a liquid rinse. All sterilized hazardous waste in double bagged and sealed. All Helix facilities have a contract with a local licensed waste management contractor for collection and disposal of hazardous waste in licensed facilities according to local regulation. Non-hazardous waste is either handled by a licensed third party contractor or by the local municipality. Spent fluorescent lamps, which contain small amounts of mercury, are recycled by a local licensed contractor. Franchises use their own waste collection and disposal contractors. Used laboratory coats are collected by a specialized company and replaced with clean ones.



As set forth in the ESAP, Helix, will develop and implement audit procedures for its hazardous waste contractor (solid waste and air filters) to ensure they are compliant with local and IFC provisions.



Air emissions – The microbiology laboratory has its own, separate, ventilation system with specialized filters. The system has been installed following local requirements by a specialized contractor that also provides maintenance and filter replacement, which fall under the hazardous waste category.



Wastewater – Wastewater from Helix facilities are mainly sanitary wastewater and laboratory wastewater that is collected and discharged to the local sewage systems. In St. Petersburg and Yekaterinburg laboratories all reagents used in clinical exam equipment are also discharged into the local sewage system. These effluents were recently tested by local authorities and found suitable to be discharged into the sewage system.



Hazardous Materials – Helix does not use any hazardous material in its operations. The Company uses more than 1000 differe
nt laboratory reagents and disinfectants. All reagents are properly managed, kept in refrigerated store rooms, and handled on as-needed-basis.



Greenhouse Gas Emissions- Helix emissions are mainly related to the use of electrical energy from the grid, and eventual loss of chillers refrigerant gas.

Helix is a health service provider and, as such, safety is a key aspect of its operations, in particular for aspects related to safe operation of its facilities. Furthermore, life and fire safety aspects of Helix’s facilities are very important in relation to its own employees and clients safety.



Sample transport from the diagnostic centers and collection points is a critical element of Helix business. Within the St. Petersburg area Helix uses 5 company cars, all equipped with GPS, to collect samples. For other regions, Helix has contracts with local transport company for sample pick-up and delivery or, occasionally, uses freelance drivers. As outlined in the ESAP, Helix, will develop and implement audit procedures for selecting courier contractor to ensure they keep and have a safe record and are compliant with local and IFC provisions.



Life and Fire Safety:

The Company is compliant with the fire safety requirements of the jurisdictions in which its facilities operate. Before moving into a new location, Helix usually renovates and outfit for its new functions following local regulations. All facilities are equipped with smoke detectors and alarms connected to a monitoring company. Fire extinguishers are present and inspected regularly at all visited location. The Company keeps a log of all fire extinguishers and the results of each inspection. As set forth in the ESAP, Helix will develop a screening system for the selection of new location to ensure that key life and fire safety elements (e.g. emergency exits) and in compliance with local and international standards.

Helix has a Consumer Services Center (CSC) system in place at that can be accessed through the internet: http://www.helix.ru , via a toll free number at +7 800 700 0303 or by several local numbers that are automatically connected to the CSC. Each diagnostic center has a bulletin board with the local Helix calling center and other official consumers’ hotline numbers. Clients can also fill out a complain logbook in the local diagnostic/collection centers or talk directly with Helix personnel at diagnostic/collection centers. As outlined in the Company procedures, all grievances are routed to quality assurance department with turnaround time to client averaging 24 hours. Most grievances are received through the CSC and the web site and mainly relate to delays in getting lab results, quality of service received at the diagnostic/collection points, or wrong general information received for Helix representatives (e.g., collection point location, hours, type of analysis offered). Each grievance is answered either with a phone call or sometimes with a letter to the client.

Helix office
Nab.reki Karpovki 5
St. Petersburg, Russia

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Helix will develop an overarching policy, in line with IFC Performance Standards, defining environmental, health, and safety objectives and providing a framework for the Company’s management and operational activities, including franchises.	04/29/2014 02:30:00 PM	Completed	Completed	02/02/2015 05:00:00 PM
Helix will integrate its existing EHS management system to cover key environmental and occupational health and safety issues consistent with IFC PS1 requirements The system should include, among others, the following elements: · a corporate EHS risk analysis to identify which major EHS issues and relevant mitigations should fall under the direct control of Helix; · specific SOPs for the in-house renovation and maintenance personnel; · standard EHS key performance indicators (KPIs) and target value to monitor sensitive EHS elements. The KPIs will be used by upper management to track company EHS performance and indicate areas of improvement; develop and implement a formal corporate standard for EHS reporting	04/29/2014 02:30:00 PM	Completed	Completed	04/02/2015 05:00:00 PM
The Company will develop emergency response and preparedness plans covering emergency scenarios (e.g. fire evacuation plan) for all facilities and conduct training and emergency drills for all its personnel.	04/29/2014 02:30:00 PM	Completed	Completed	03/29/2015 05:00:00 PM
Helix will develop a corporate HR policy and will develop and put in place supporting HR procedures, such as hiring and termination of contract policy, duties and compensation policy(ies), performance assessment and promotion policy, and benefits policy that are consistent with local laws and IFC’s PS 2 provisions.	04/29/2014 02:30:00 PM	Completed	Completed	03/18/2015 06:00:00 PM
Helix will develop a formal internal grievance mechanism for its workforce to raise concerns and inform personnel on relevant procedures and use	04/29/2014 02:30:00 PM	Completed	Completed	02/02/2015 05:00:00 PM
Helix will adopt and implement minimum requirement PPE for the renovation/maintenance crew	02/27/2014 01:30:00 PM	Completed	Completed	03/18/2015 06:00:00 PM
The Company will ensure that first aid kits are also available on site for personnel involved in renovation/maintenance work.	02/27/2014 01:30:00 PM	Completed	Completed	03/18/2015 06:00:00 PM
Helix will develop and implement audit procedures for its hazardous waste contractor (solid waste and air filters) to ensure they are compliant with local and IFC provisions	02/27/2014 01:30:00 PM	Completed	Completed	03/18/2015 06:00:00 PM
Helix will develop and implement audit procedures for selecting courier contractor to ensure they keep and have a safe record and are compliant with local and IFC provisions.	04/29/2014 02:30:00 PM	Completed	Completed	03/18/2015 06:00:00 PM
Helix will develop a screening system for the selection of new location to ensure that key life and fire safety elements (e.g. emergency exits) and in compliance with local and international standards	04/29/2014 02:30:00 PM	Completed	Completed	03/18/2015 06:00:00 PM