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 is a category B investment according to IFC’s Procedure for Environmental and Social Review because the potential adverse social and environmental impacts of the proposed investment are limited, site-specific and reversible and may be mitigated by adhering to IFC Performance Standards, generally recognized guidelines and design criteria.

PS 6: Biodiversity Conservation and Sustainable Natural Resource Management does not apply as the housing projects are generally located in urban areas where the habitat is modified and does not have significant ecological value. As the ADI projects are generally in urban area, there are typically no communities in such areas who would be considered as “Indigenous” under the definition used by IFC, and therefore PS 7 - Indigenous Peoples does not apply. PS 8 Cultural Heritage is not applicable as most housing projects will be constructed in urban areas. However, in order to adhere to good international practices, ADI will require that the construction contractor have in place in its Environmental and Social Management Systems (ESMS) a chance finds protocol specifying what procedures will be undertaken should archeological finds be encountered.

The key environmental and social issue is ADI’s capacity to put in place an international standard corporate environmental, social, health and safety management system that will be consistently implemented across its activities such as E&S assessment of prospective projects consistent with IFC Performance Standards 1; fire and life standards in housing design; occupational health and safety for its employees as well as third party workers on ADI’s construction sites; pollution control measures during construction including access to public services (i.e. municipal sewerage system, water, electricity and solid waste services).

During the appraisal, ADI presented information on its policies and practices that seek to address environmental and social risks and impacts associated with its operations. Additional measures have been agreed with ADI to ensure that this investment will, upon implementation of these measures, comply with Moroccan laws and regulations and IFC’s Performance Standards on Environment and Social Sustainability. The additional measures to be undertaken by ADI are listed in the attached Environmental and Social Action Plan (“ESAP”).

The paragraphs below describe how ADI will mitigate potential environmental, health, safety and social risks in compliance with Moroccan law, regulations and IFC Performance Standards.

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.

With regards to low income housing ADI builds to specifications established by the Housing Ministry. Local planning authorities conduct an environmental and social impact assessment (ESIA) as part of the initial planning, noting that ESIAs are only required for housing/hotel projects in coastal zones or ecologically sensitive habitat. ADI will establish a policy defining the E&S principles and objectives that guide its projects to achieve sound environmental and social performance through a defined framework for E&S assessment and management process. As such ADI will formalize a corporate wide environmental and social assessment procedure that will define the scope of environmental and social impact assessment applicable to each type of project based on activity and sensitivity of habitat.



As part of this investment, ADI will be required to develop and implement management programs to address identified risks through adoption of a mitigation hierarchy. The thematic E&S issues to be addressed by the management programs include: (i) local environmental, health and safety requirements; (ii) environmental and social assessment procedure (including site specific pollution prevention and abatement screening, and assessment of site exposure to flooding or landslide) and adoption of adequate mitigation measures; (iii) occupational health and safety practices and training during construction phase for both staff and third party workers; (iv) pollution control measures during planning such as sediment and erosion control; (v) access to public services such as water, electricity, connection to municipal sewerage system, storm water runoff, and solid waste management; (vi) community health, safety and security including established standards governing structural integrity and life and fire safety; (vii) energy efficient green building developments (viii) management of traffic, air quality and noise during the construction phase; (ix) potential economic and/or physical displacement associated with land acquisition; (x) discovery of cultural heritage; (xi) community engagement and grievance mechanism; and (xii) environmental and social performance management and internal reporting.



The responsibility for management of environmental, social, health, safety and labor aspects is fairly decentralized and shared among various departments and individuals of the organization. ADI will strengthen its organizational structure by designating or hiring a corporate environmental and social manager to develop and oversee the implementation of the Environmental and Social Management System (ESMS). In order to adhere to international standards, ADI will ensure that each project has a designated environmental, social, health and safety supervisor.

ADI will develop an Emergency Preparedness & Response Plan (EPRP) that covers all foreseeable emergency scenarios associated with its projects. The Plan should describe the procedures to follow when handling an e
mergency situation such as fire, explosion, hazardous material spills, injuries, natural disasters. This will include establishment of a communication network between ADI, the contractor, and emergency services such as fire departments, traffic police, and local medical services. Furthermore, the system will be tested through drills to confirm effectiveness of the system or rectify any identified oversight. ADI will develop standard EHS signage for its construction site, and ensure adequate provision of extinguishers, first aid kits and communication devices. ADI currently has tested fire and life safety response system within its administrative building.ADI will define data monitoring and reporting requirements consistent with the objectives of its ESMS. Specific parameters will be allocated to each activity in order to track, monitor, analyze EHS and Social performance and ensure compliance with Moroccan laws and IFC Performance Standards. The monitoring result will be summarized and reported to ADI management team.

ADI has a total of 5,000 employees of which 4,000 are within the construction divisions. ADI holding has approximately 125 employees.



There is a corporate level human resource manager who is responsible for ensuring consistency in HR benefits and policies within the organization. Each division has a designated HR professional who has dotted line reporting to the Corporate HR Manager as well as to the Director of the division. Prior to employment, selected candidates must provide birth certificate, undergo a medical visit, and provide a copy of their judicial standing and civil status. ADI has a young labor force; however, no candidates under 18 are hired by the Company. The Company is compliant with local labor laws and regulations and has not received any notice or fines from the labor authorities. All employees (permanent, limit contract, or temporary) are provided with an employment contract and registered to social security. ADI provides a competitive salary and additional benefits to its staff such as supplemental medical insurance, pension, and additional holidays which exceed the requirement of the Moroccan labor laws. Company grievance mechanisms include employees addressing issues to direct supervisor and/or HR; in the case of the construction divisions, unions are present and serve as a liaison between the employees and management. ADI holdings will require staff to elect workers representatives to serve as a formal liaison between management and staff.



Currently ADI is in the process of revising its HR policy, and establishing and harmonizing HR procedures and benefits within the organization. As part of this investment, ADI will develop written policies on equal opportunities, harassment, child labor, freedom of association; and a simple and clear manual which outlines the employees’ rights under national employment laws, any collective bargaining agreement as well as their rights with regards to working hours, wages, overtime compensation, benefits, freedom of association, company code of conduct and disciplinary action, grievance mechanism, and performance management ensuring compliance with this Performance Standard as well.



ADI will ensure that a well functioning health and safety committee (HSC) is in place as per legal requirements. Accidents are currently reported but not used as a risk management tool nor are sufficient indicators established to track occupational health and safety. There is a medical doctor on staff, whose role includes conducting staff medical visit, health awareness raising, and preventive medicine.



Occupational health and safety of the employees, workers engaged by third parties, and potential visitors are not consistently and systematically addressed by ADI. For instance the Benguerir university construction site was operated consistent with international standards on environmental, health and safety practices albeit it was client driven through a contractual agreement. This, however, dem
onstrated that ADI has the internal capacity to operate at international standards with regards to environmental, health and safety. ADI will strengthen it procedures and practices to such standards. EMT and EMT Batiment divisions of ADI are both ISO 9001 certified and are in the process of OHSAS 18001 and ISO 14001 certifications in the next couple of months. ADI will ensure that staff on the site (employees, contractors and subcontractors) will be required to wear relevant personal protective equipments based on risk assessment this include hard hats, gloves, steel toe boots, goggles, ear plugs, and harness which will be supplied by ADI or the contractor. ADI HSE site supervisor will work closely with the contractors to ensure that construction operation follow good international industry practices, including World Bank Group General EHS Guidelines.



Prior to start of operation, designated staff will be trained in fire safety and spill response. Above ground fuel tanks will be equipped with secondary containment, fire extinguishers, hydrants and pumps, first aid kits will be readily available at project sites to ensure compliance with international best practices. An illustrated occupational health and safety manual will be provided to all personnel on the project site and for those who are illiterate detailed explanation will be provided in the local language during training and/or tool box meetings.



ADI will take commercially reasonable steps and establish policies and procedures to comply with the requirements of workers engaged by third party under this Performance Standards.

ADI has some features on energy and water efficiency in their housing projects such as solar shades and dual flush for toilets. During appraisal, IFC’s green building specialist made recommendations to improve energy efficiency and water use hence reducing monthly utility bill – this includes: (i) low to no cost opportunities by providing a welcoming pack of energy saving light bulbs, equip the housing units with low flow shower heads and taps; (ii) equip housing complex with a communal solar water heaters given that water heating is a significant part of the energy bill.



ADI operates 4 golf courses mostly built on previously agricultural land, a total of 3 million m3 of water from municipal networks is used annually to maintain them. ADI is in the process of launching an in-house carbon foot printing initiative.



ADI developments are mostly located in urban areas where basic access to services such as electricity, potable water, and waste management services such as domestic waste pick up services and connection to municipal sewerage system are available. ADI ensures coordination with municipal authorities and connection to these services. Each tenant has its own metering connection to water and electricity.During construction, air quality issues such as fugitive dust from site excavation and vehicular movements are managed through dust suppression techniques. ADI will further strengthen its practices to provide dust masks when necessary and mitigation measures for smoke from equipments and trucks. Increase in ambient noise will be managed by adequate maintenance of construction equipment exhaust noise controls and through restrictions on construction site operating hours based on sensitivity of site surroundings.Waste generated during construction include excavated materials from civil works site preparation such as rock material; various organic and inorganic domestic waste from work site services and offices such as food, paper, cardboard, plastic, wood crates, and construction equipment waste such as used oil from generator, lubricants. Waste produced during construction is segregated and collected at the generation point; metal scrap is sold to local companies, domestic waste is collected by the municipality and construction debris are located temporarily at designated points and as feasible reused within the projects for back filling, sub base work for roads and pavements or send to designated waste facilities. Sanitary waste is managed using septic tanks which are pumped by a third party licensed contractor. As part of its ESMS, ADI will put in place a waste management procedure.

During construction measures are implemented to protect the community, including restricted access to clearly demarcated construction areas. Main risks to health and safety of the community typically consist of traffic and pedestrian safety from the transport of construction materials, equipment, and workers to and from the construction sites and potential for structural damage to local housing located adjacent to transport routes. As part of its ESMS, ADI will put in place procedures to mitigate these issues such as compliance with approved access points, delivery time outside peak hours. 

ADI utilizes in-house and contracted architects and technical specialists to design and develop commercial property and residential housing (condominium, stand-alone houses) projects. All properties are designed in accordance with Moroccan standards, including the low income segment which is constructed according to minimum design standards for low-cost housing according to specifications from Housing Ministry. Access to potable water is provided through the municipal networks.Civil works are designed and constructed according to Moroccan building codes. The construction of new facilities is monitored by experienced project managers hired by the Sponsor to administer the construction of projects. Life and fire safety elements are designed and constructed according to Moroccan standards. Low income housings buildings are in concrete, and have dry column/standpipe on each floor, emergency exit, and fire retardant doors but no smoke detectors or extinguishers. A certificate of occupancy is delivered after a fire and life safety audit has been conducted by the Civil Protection. Each municipality has fire fighting services available. Going forward, ADI will further enhance fire protection in new buildings.

For buildings that are not yet approved for construction, ADI will provide at least two separate exits remote from each other, or other solution(s) acceptable to IFC, and buildings of four storeys or more shall be equipped with fire alarm systems audible in each apartment''s sleeping area and on all levels of the apartment block.

ADI will work with regulatory authorities to seek approval to add similar enhancements to buildings that have approvals but where construction has not started. Where construction is underway, structural changes may not be possible, but ADI shall seek to enhance fire protection systems to the extent that is practical.



The construction of new projects in established urban areas must meet urban planning requirement such as street access, connection to municipal networks; and with regards to low income housing ADI must budget provision of social infrastructures such as schools, health facilities, mosques, law enforcement facilities as determined and required by the local planning authorities.



Even though ADI responsibility ends after construction of the housing unit, ADI has created Alliances Foundation to ensure tempo
rary facility management of common areas, and social integration of the tenant to help them form a community in a safe environment. Alliances Foundation aims to raise awareness of the importance of facility management, inject a culture of financial contribution to facility management, build and train an owner management group and transition responsibility to this group.

The Company outsources security services at their offices and construction sites through security companies. ADI will ensure that security personnel have undertaken necessary screening and training in accordance with good industry practices. In addition, ADI will put in place a system to investigate any credible allegations of unlawful or abusive acts of security personnel, take action or urge appropriate parties to take action to prevent recurrence, and report unlawful and abusive acts to public authorities when appropriate.

Community engagement activities are currently managed through the sales department (for complaints related to clients), by construction site managers, and by Alliances Foundation. The sales department help prospective client with getting all the elements needed to put their loan application together; there is also an after sale services to help tenants connect their utilities and handle any grievances or feedback on the apartments.

Alliances Foundation was create 3 years ago and plays a very important role in ensuring social inclusion of the newly formed community in these low incomes housing. There is a strong commitment from ADI owner for ADI to be a social player. Alliances Foundation recruits and train social supporters to facilitate the integration of first time owners given many come from different backgrounds and many do not have experience with sharing and maintaining common areas. The social supporters also play the role of mediation between owners as well as animators to make the place more of a community, help create social bond and revenue generating activities for unemployed people (i.e. day care, educational support etc.) The social supporters also serve as a grievance mechanism between ADI and the new owners. Alliances Foundation plan to run a 2 years program where it will identify tenants to join the owners’ management group, train them before fully transitioning facility management to this group. The first low income housing units were just delivered and as such Alliances Foundation effectiveness will only now be tested and monitored.

Brahim SkalliDirecteur Stratégie et PartenariatsGROUPE ALLIANCES
16, rue Ali Abderazak, Casablanca, Maroc
Téléphone : (+212) 5 22 99 34 80/63
Fax : (+212) 5 22 99 34 81
http://www.alliances.co.ma

Broad Community Support is not applicable for this project