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

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, guidelines or design criteria as is described in the following sections.

Social and environmental issues include: PEIP’s management systems and assessment of the Company’s expansion project; structural, life and fire safety, and sustainable design and construction of the new buildings; constructors’ capacity to manage environmental and social issues, including occupational health and safety; operation of current installations and planned expansion, including life and fire safety, water and wastewater management, use of sustainable materials and appliances; labor and working conditions, and occupational health and safety.
PS5 is not applicable because new acquisitions will be in urban areas under willing-buyer-willing-seller arrangements and will not involve involuntary resettlement. As there are no biodiversity, indigenous peoples or cultural property issues in this Project, PS6, PS7 and PS8 do not apply.

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 part of its management system the Company has established an overarching policy defining the environmental and social objectives and principles that guide the project to achieve sound environmental and social performance commensurable to its size and characteristics.

Identification of Risks and Impacts

A qualified independent consultant engaged by PEIP undertook an assessment of electrical, structural and life and fire safety risks to inform the refurbishment of the building, but a full ESIA was not deemed necessary nor was it required by Peruvian regulations. Construction activities will be done according to internationally-recognized codes such as IBC or ASCE codes for structural soundness, and NFPA (consistent with Peru’s Fire Code) for life and fire safety. PEIP undertook an energy efficiency assessment whose recommendations will also be taken on board in the refurbishment works. PEIP will provide the necessary certifications in conformance with internationally-recognized codes and standards and the ESAP.

Future construction as per PEIP’s expansion program will be managed according to international good practice and Performance Standards requirements (PS2 and PS4). This commitment is reflected in the ESAP.

Environmental and Social Management Programs. The current PEIP site, located within the city of Lima, has become insufficient to accommodate the growing student population. A refurbishment of the PEIP building (where IPAL currently operates) and expansion of academic activities within the premises is being implemented. El Comercio, PEIP’s parent company has an ISO-14001 management system, which PEIP is tailoring to its needs for eventual certification. PEIP is also working on an occupational, health and safety system consistent with ISO 18001 standards, which is also planning to certify in due course.

Organization. PEIP’s Administration Director is responsible for EHS activities. PEIP is recruiting a Human Resources Director to deal with labor and working conditions, which are currently under the PEIP’s Director General. PEIP contracts out its security personnel through a specialized company and is currently enhancing its safety and security procedures in preparation to the forthcoming expansion, to include establishing and training a safety brigade in life and fire and planning fire and evacuation drills. PEIP is also preparing a program to provide regular training to academic staff and other employees in a number of areas according to their roles and responsibilities and also on environment and emergency response. EHS issues are to be included in IPAL’s curriculum, particularly in the engineering areas.

Emergency Preparedness and Response. Security personnel and key administrative staff at IPAL, receive training to prepare them for potential emergencies, including prevention and responses in case of fire, security policies in case of an earthquake, health and security and first aids. In these training events, res
ponsibilities are assigned to enable them to coordinate appropriate response from staff and students so that everyone knows what to do in case of an emergency. These training and coordination activities will be replicated in any greenfield or significant expansion undertaken by PEIP. Community Engagement. IPAL is located in a busy neighborhood of Lima with other educational facilities, government institutions, housing apartments and commercial buildings. It is not envisaged that IPAL will have any deleterious effects on the surrounding community. Any grievances are posed by the neighboring community are addressed immediately by administrative staff as appropriate or elevated to PEIP’s Management’s attention.

Community Grievance Mechanism. IPAL is located in a busy neighborhood of Lima with other educational facilities, government institutions, housing apartments and commercial buildings. It is not envisaged that IPAL will have any deleterious effects on the surrounding community. Any grievances are posed by the neighboring community are addressed immediately by administrative staff as appropriate or elevated to PEIP’s Management’s attention.

Monitoring and Reporting. Commensurate to the size and type of installations, the Company is implementing monitoring programs for operational efficiency, quality, environment, and occupational health and safety. Reporting will be channeled through by the Administration Director to the Director General and to IFC as appropriate.

Human Resource Policy and Management. PEIP has a Human Resources Policy, Manual de Procedimientos Administrativos, and a number of regulations which define workers’ rights and responsibilities, including: Ethics Code, and an Internal Personnel Regulations that cover attendance, permits and holidays, health and safety, among other matter.

Copies of relevant labor related policies and regulations are provided to staff upon inception. The Company’s policies and regulations fully comply with Peru’s labor law and IFC requirements, including non-discrimination and equal opportunity disciplinary, and grievance mechanisms.

Workers Organizations. The total PEIP employee head count is 280, of which 65 people are indirectly employed as subcontractors. The Company’s gender composition is approximately 61% female, some of them in senior management, including the Director General and the Academic Director. The entire workforce receives benefits according to, or better than the Peruvian labor law. Full-time administration staff has additional benefits at PEIP’s discretion. Whilst Company’s human resources policy guarantees freedom of association, workers are not currently unionized.

Working Conditions and Terms of Employment. The recruiting process at the Company involves a background and medical checks, and aptitude exams; additional training is provided to suitable staff to breach any gap identified in the exams. The Company pays competitive salaries throughout the ranks compared with other similar institution in the country. The proportion of permanent to part-time academic staff is also higher than most private universities in Peru, at around 25%. The Company is currently working to integrate administration and academic staff to the payroll. PEIP’s human resources documentation (Manual de Procedimientos Adminstrativos) spells out the working conditions and terms of employment for all personnel. They also describe health and safety procedures, particularly in areas of potential risk, such as engineering and nurse education areas.

Protecting the Workforce. PEIP will document its agreements with staff, confirming the following: payment of workers’ legal benefits; timely payment of wages; occupational safety regulations, including provision of potable water and personal protective equipment. In conformance with ILO age requirements 18 is the minimum age for work at PEIP institutions.

Occupational Health and Safety. OHS risks are very low in PEIP’s operations within its campus. Accidents seldom take place and any injuries are reported and recorded by medical personnel. The Company has a well appointment health clinic with a full time professional nurse. PEIP offers health and life insurance to staff and students in partnership with the nearby hospital (5-minute drive away). Contractual documentation for the construction the new installations, the object of the IFC Project, will include OHS requirements as mandated in PS2.

Pollution Prevention, Resource Conservation, Energy Efficiency. PEIP is compliant with Peruvian environmental requirements and has all the corresponding permits and licenses. The Company’s main source of energy is electricity from the grid for lighting and IT equipment. There is good ventilation throughout the building and no air conditioning or heating is used. Cafeterias and canteens in various locations use both electricity and LP Gas. There is no power generation and the building relies entirely on the municipal services for electricity and water needs.

PEIP engaged specialized consultant (W&H Servicios Generales SAC) to undertake an energy efficiency audit, and is currently implementing the audit’s recommendations. PEIP has included resource efficiency practices in the design, construction and operation of its new installations.

Currently IPC has a monthly electricity consumption of 557,736 kWh and 430 kg of liquefied petroleum gas.

Waste Management. IPAL has negligible air emissions. Wastewater is discharged to the municipal sewer with minimal pretreatment (e.g. grease traps and neutralization in the labs). Domestic waste is collected and disposed of in the municipal landfill by authorized third parties. This will also apply to other PEIP institutions, which would also be located in urban areas.

Hazardous Materials. Given that the municipality does not have the means to manage hazardous materials, small amounts of such materials and wastes are stored within IPAL’s premises. PEIP is studying alternative, safer, means for handling and storing hazmats until Peruvian authorities provide suitable disposal facilities.

Emergency Preparedness and Response. PEIP has emergency preparedness and response procedures which are currently being enhanced in preparation for IPAL’s building refurbishment and future acquisitions and expansions.

Greenhouse Gases. As per CEET calculation PEIP’s GHG emissions in 2012 amount to 1,935 tonnes CO2 equivalent per year. Current population at the Company is about 5,800 (technical and non- technical) students and 280 staff. Given that IPAL’s installations will not be expanded physically, the GHG emissions in the current premises will remain the same. New acquisitions will likely increase overall fuel and electricity consumption.

Community Health, Safety and Security. There is significant interaction between the Company and surrounding urban communities given PEIP’s location within the urban area of Lima and a formal community engagement program is currently in preparation. No deleterious EHS impacts of PEIP’s operations on the community have been identified.

Life and Fire and Building Structural Safety. PEIP’s campus complies with the requirements of the Lima Fire Department in fire prevention and emergency preparedness and response, but does not fully comply with international good practice. As per the agreed ESAP, building activities are being undertaken according to internationally-recognized codes such as IBC or ASCE codes for structural soundness, and NFPA (consistent with Peru’s Fire Code) for life and fire safety. PEIP will provide third-party certification for the design of the new buildings and a post-construction certification confirming conformance with internationally-recognized codes and standards.

Emergency Preparedness and Response. PEIP will enhance its fire and evacuation preparedness and response program, and implement a training plan to ensure that all PEIP students and employees in Peru are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes and organize and implement a fire drill program throughout the building.

Security Personnel. PEIP’s security personnel are hired externally. Guards are trained and equipped to deal with safety events, and to preserve the physical and personal security. The Company applies good practice criteria as regards hiring, rules of conduct, training, equipping and monitoring of security personnel, consistent with PS4 and in accordance to the applicable Peruvian law. PEIP investigates allegations of unlawful or abusive acts of all employees, including security personnel, takes action to prevent recurrence, and informs authorities when such acts are confirmed unlawful.

IPAL is located in a busy neighborhood of Lima with other educational facilities, government institutions, housing apartments and commercial buildings. It is not envisaged that IPAL will have any deleterious effects on the surrounding community. Any grievances are posed by the neighboring community are addressed immediately by administrative staff as appropriate or elevated to PEIP’s Management’s attention.

Mirian Lau
Gerente General
IPAL
Av. Uruguay 514
Lima – Peru
Telephone: (51-1) 411-5888

Julio Noriega
Gerente Central de Estrategia y Desarrollo de Negocios
Grupo El Comercio
Jr. Antonio Miro Quesada 300
Lima – Peru
Telephone: (51-1) 426-4676

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Environmental and Social Management Program. PEIP will engage professional services of a qualified specialist* to develop a formal Environmental and Social Management Program (ESMP) for its operations in Peru with plans and procedures to address, at a minimum, the following aspects: (i) Energy consumption (ii) Water consumption (iii) non-hazardous and hazardous waste management (iv) wastewater management (v) laboratory safety: hazardous materials management; ventilation systems operation; etc , (vi) occupational health and safety and; (vii) any other relevant aspects identified in the risk identification phase of the management system.	06/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Environmental and Social Management Program. PEIP will engage professional services of a qualified specialist* to develop a formal Environmental and Social Management Program (ESMP) for its operations in Peru with plans and procedures to address, at a minimum, the following aspects: (i) Energy consumption (ii) Water consumption (iii) non-hazardous and hazardous waste management (iv) wastewater management (v) laboratory safety: hazardous materials management; ventilation systems operation; etc , (vi) occupational health and safety and; (vii) any other relevant aspects identified in the risk identification phase of the management system.	09/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Certification of Life and Fire Safety System - Design. Provide third party certification by a qualified professional* that the life and fire safety aspects of the designs of (i) greenfield construction projects; and (ii) substantial expansions (25% of more) in the case of existing facilities, in both cases where the buildings are accessible to students or other members of the public comply with all relevant national and an internationally-accepted life and fire safety code.	06/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Certification of Life and Fire Safety System – Completion of Construction. A qualified professional* shall provide a professional certification affirming that facility as built incorporated all elements of the life and fire safety design previously certified to IFC.	09/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Certification of Structural - Design. An independent qualified professional* shall certify that the structural design of the building meets applicable requirements of an internationally-recognized code such as IBC or appropriate ASCE codes, taking necessary account of natural hazards such as earthquakes.	06/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Certification of Structural - Construction. An independent qualified professional* shall provide a professional certification affirming that facility as built incorporated all elements of the structural design previously certified to IFC.	09/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Fire Drill Program. PEIP will develop and implement a training plan to ensure that all IPAL students and employees in Peru are knowledgeable of existing emergency procedures and emergency contingency plans, including evacuation routes and organize and implement a fire drill program in all of its buildings.	09/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client
Contractors’ Human Resources and Safety. PEIP will document in its agreements with contractors that such contractors in Peru should comply with: payment of workers’ legal benefits; timely payment of wages; occupational safety regulations, including provision of potable water and personal protective equipment, and ILO Conventions 138 on Minimum Age.	06/30/2014 12:00:00 AM	In Progress	Due date revised as agreed with IFC client