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 IFC's 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

This is a category B project according to IFC’s Environmental and Social Review Procedure because potential adverse environmental and social risks are limited, reversible and may be readily mitigated.

The key potential environmental, health and safety issues associated with this investment include; i) adequacy of environmental and social assessment and management systems, particularly in relation to the acquisition of hospitals and future implementation of good hospital management practices; ii) labor relations, human resources policy and practices; iii) worker health and safety, including training and housekeeping; disinfection, sterilization, hygiene and life and fire safety including adequacy of emergency preparedness and response programs; iv) solid and liquid waste management and hazardous materials management; v) opportunities for energy conservation and efficiency as well as waste minimization; and vi)community health, safety and security.

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: AAR does not have a formalised Environmental Management System (EMS) or associated plans in place, and does not have an overarching policy on environmental and social objectives to guide performance. AAR has though just signed up to the UN Global Compact that covers human rights, labour, environment and anti-corruption, and the Kenya Code of Ethics as headed by the Kenya Private Sector Alliance (KEPSA). Interviews with management at AAR demonstrate that there is strong commitment to responsible operation, and a willingness to meet international standards in this respect.



The management at AAR acknowledge that they are in capacity building stage with regard to environmental, health and safety (EHS) policies and systems. In particular, quality assurance performance in Tanzania is less advanced than in Kenya and Uganda and will take more time to improve performance around these issues.



Given the above AAR will develop and implement a management system aligned with the requirements of IFC's Performance Standards and ISO 14001. This is described further in the attached environmental and social action plan (ESAP).



Identification of Risks and Impacts: As all of AAR’s clinics are leased within existing buildings and in existing properties, there has been no need for conducting an environmental impact assessment in accordance with regulatory requirements. With the proposed expansion of the Group, clinics will be within existing buildings and therefore require no EIA. Equally, hospitals to be acquired will already be established.



The EMS to be developed by AAR will apply to all existing and new operations. In addition, prior to and post acquisition of a hospital, AAR will be required to undertake an ESDD to assess operations against the Performance Standards and agree with IFC on an action plan to ensure compliance if necessary. These actions are defined in the attached environmental and social action plan (ESAP).



Management Programs: Although AAR does not have a formal EMS in place, they do operate informal systems for managing various environmental and social issues to meet legislative requirements and through their Standard Operating Procedures (SOPs), with occupational health and safety and waste management being areas where much attention is paid. These are currently implemented through the Quality Assurance Management processes and are described in more detail in subsequent sections.



As part of their EMS and as defined in the ESAP, AAR will formalise their systems and define specific plans to manage potential environmental and social risks and impacts associated with their operations. In addition, AAR will review their quality management system against the requirements of a formal quality management system such as ISO 9001 or JCI and based on the gaps identified, enhance the quality management system accordingly.



Organizational Capacity and Competency:
With the recent restructuring of the company, and the commencement of AAR Healthcare, AAR now has a separate management team for each country, led by a General Manager. There is currently a vacancy for the General Manager in Kenya, which the company is working to fill. Three committees have been set up, one of which is for Quality Assurance, and where responsibility for EHS issues will reside. EHS will form part of the responsibilities associated with the Quality Assurance Manager at a Group level and similarly this will cascade down to the Quality Assurance Manager at the country level, and then the General Manager at each clinic / facility. The Quality Assurance Manager of each country works with the clinic managers to ensure that they are compliant with any environmental legislation relevant to their operations.



AAR has recently developed a system of ‘Harmonisation’ whereby managers from each country come together twice a year (with attendance from the CEO) and share learning and processes, with the aim of ensuring consistency in performance across the Group. Actions points arising from these meetings need to be reported on and reviewed by the MD.



Emergency Preparedness and Response: AAR has not developed procedures for facility fire prevention, emergency response or evacuation plans or guest information in this regard. However, due to the recent audits undertaken by Swedfund and IFHA, AAR has become aware of the need for this and have committed to developing procedures in this regard. This is discussed in more detail under PS4.



Monitoring and Review

Internal Quality Assurance audits against the Group’s Standard Operating Procedures (SOPs) and legislative requirements are carried out twice a year. Results of these audits are assessed by the Quality Assurance department and reported to the country General Manager, who is ultimately responsible for correcting any performance issues. These audits are currently undertaken in Uganda and Kenya, but not in Tanzania, although this is currently being introduced.



The National Environment Management Agency in Kenya undertakes annual audits of the clinics against legislative requirements. In general, AAR has performed very well when these were conducted, with few requests for corrective actions.



As part of its overall EMS, AAR will establish systematic procedures to monitor and measure the effectiveness of their management programme, as well as compliance with regulatory requirements and Performance Standards. This will incorporate current quality assurance auditing and include all relevant environmental and social issues requiring management. This is further described in the attached ESAP.



Grievance Mechanism: AAR engages with the public through regular emails from their Healthcare Promotion department, providing healthcare advice to the public. AAR also has a system of using Mystery Shoppers to assess the performance of their operations. The way in which AAR receives gri
evances is through complaints and suggestions boxes that are put up in each clinic. Clinic managers are responsible for collecting these and dealing with the issues that occur. There is currently no formal grievance management system whereby these are assessed and monitored at a country or Group level. However, with the new Quality Management setup in AAR Healthcare, the Quality Assurance Managers will be responsible for collecting these grievances and monitoring trends and issues that arise, along with the results from the Mystery Shopper system. The results are gathered by the Quality Managers and shared with Clinic Managers. Performance against any issues that arise during this assessment is included within the internal audits. Should any grievances be associated with specific members of staff, this is directly taken up with the member of staff by the clinic manager. AAR will be required to document and formalize the grievance mechanism defined and extend this to all new operations.

General: In total, there are 473 Full Time Employees (FTEs) within the AAR Healthcare Group, with 233 of these in Kenya, 127 in Uganda and 113 in Tanzania. All clinical staff such as doctors, nurses and lab technicians are employed as permanent members of staff, while many of the specialists are contracted on a fixed term/ locum or contractual agreement.



Each country has an HR Manager who reports to the Group HR Manager in Nairobi. As with other areas of operation, the HR departments hold harmonisation meetings twice a year so that each country can share learning, experiences and new procedures across the countries. The Group HR Manager oversees harmonisation efforts. Within each clinic, the General Managers are responsible for daily HR management, with the country HR managers providing ‘technical support’. HR management attend the manager meetings that take place every third Friday at the clinics, and provide talks and training on different HR topics. The managers are also included in any HR processes undertaken from headquarters, such as recruitment and disciplinary actions. HR Management undertake random checks at clinics to monitor performance.



Working Conditions and Management of Worker Relationships

Human Resources Policies and Procedures: AAR has signed up to the Global Compact which commits to meeting the requirements of all four of the International Labour Organization (ILO) Core Labour Standards, including freedom of association and the right to collective bargaining; the elimination of forced and compulsory labour; the abolition of child labour; and the elimination of discrimination in the workplace.



AAR has a HR Policy that is shared across the Group, with some amendments per country to account for differences in legislative requirements. The HR Policy commits AAR to meeting all legislative requirements as a minimum within each country. All HR procedures are carried out according to the HR Policy and are standardised across the clinics and the countries through centralisation of HR statistics in a newly implemented HR IT system. Standardisation is also advanced through harmonisation meetings and monitoring of progress against lessons learnt.



Working Conditions and Terms of Employment: All permanent staff at AAR are provided with standardised employment contracts that contain the terms and conditions of employment, including hours of work, wages, compensation and benefits. In addition to benefits as legislated, AAR provide employees with medical insurance, sick leave, personal accident and life insurance, pension and performance bonuses. All permanent staff begin employment on a 6 month probation period (as clearly stipulated in the AAR appointment letter), whereby the employee and employer have a chance to assess working conditions and performance. After 6 months an appraisal is conducted and should both parties decide to continue, a confirmation letter of employment is provided to the employee. Should staff or
AAR decide to discontinue, a 2 week period is allowed for disengagement. Conditions related to termination of employment are included in the contracts and are dependent on the number of years worked at AAR. According to AAR HR management, this meets legislative requirements. Payslips set out the details of payment, deductions and tax.



AAR has a graded salary structure and determines wages and benefits according to staff qualifications, specialities and benchmarking within the industry. As such, there is no difference in remuneration between males and females. Most support services such as cleaning and food supply are contracted out to providers and the most basic wages relate to support staff such as clinical administrators.



All staff undergo induction training, which includes a working safety plan as per OHS requirements, and an overview of policy and procedural requirements. All employees go through a departmental induction programme and a corporate induction programme, whereby they are assisted to understand the company operations, policies and procedures.



Worker’s Organizations: All AAR staff are free to join trade unions and associations appropriate to their occupation. Currently no AAR staff are represented by trade unions.



Non-Discrimination and Equal Opportunity: AAR’s HR Policy and Procedures state that ‘AAR is an equal opportunity employer and is committed to providing employment opportunity and development regardless of gender, ethnic origin, race, age or religion’. AAR’s recruitment process is set out in the HR Policy manual, is systematic and based on the requirement of the job and the applicability of the applicant’s skills and experience. Each member of staff receives a Balance Score Card (BSC) with targets, against which performance is measured every quarter. Performance is assessed at the end of each year, and targets set according to results.



Training and Development: AAR is committed to providing adequate training and learning opportunities to its staff to enable them to carry out their jobs competently and efficiently. AAR has a corporate training manager responsible for conducting all training across the group. Training policy does not allocate training days per employee, but it is needs-driven. AAR holds Continuous Medical Education (CME)/ Continuous Professional Development (CPD) Sessions every month. These sessions are compulsory for all staff and cover a range of topics. AAR encourages further studies by staff and sponsors studies for Doctors, depending on their performance.



Grievance Mechanism: AAR has a grievance policy and procedure as contained within its Human Resources Policy and Procedures. This supports the right of employees to lodge a grievance with their immediate manager if they believe a decision, behaviour or action affecting their employment is unfair. It aims to resolve problems and grievances promptly and as close to the source as possible. If necessary, it can be escalated to
higher levels, and can escalate up until it is resolved. No formal grievance mechanism or system exists beyond this, whereby grievances are collected, managed and monitored and assessed for trends over time.



Occupational Health and Safety

An OHS Policy is contained within AAR’s HR Policy and Procedures manual. This commits AAR to providing a safe working environment for the health, safety and welfare of employees, contractors and visitors and members of the public who may be affected by AAR’s work. It also commits AAR to meeting local legislation regarding workplace safety.



For the prevention of infection, all staff are provided with Hepatitis B vaccinations and with Personal Protective Equipment as appropriate to their position. This includes gloves, masks, boots, overalls, headcaps, goggles and body gowns. Due to the nature of AAR’s operations, most staff are aware of the basic OHS requirements. However, staff are taken through SOPs during their induction, and many of the CME sessions focus on OHS issues. Recent topics included TB and the avoidance of infection, avoiding needle stick injuries, the correct use of PPE etc. While the clinics do have pharmacies, the focus is on dispensing of medicine as opposed to formulation and thus exposure risks to employees are considered limited.



An incident reporting document is currently in place. Through this, incidents are recorded and reported through the clinic managers to HR and then sent to Group. Since operationalization of AAR Healthcare, AAR are in the process of developing policies and procedures around specific areas of performance, such as staff vaccinations, protection against infection etc. AAR recognise that they do not meet international standards with regard to the formalisation of an OHS system and are committed to putting this in place.



City Centre and Mombasa are the only clinics that operate x-ray machines, although this service is contracted out to licensed radiographers. IFC witnessed that strict protocols are followed with regard to personal protective equipment, but the radiographer had not been issued with a dosimetry badge for assessing levels of radiation.



AAR will be required to formalise their OHS management system into written procedures to be applied consistently and systematically across the group. This will include OHS provisions relevant to hospitals to ensure that OHS issues associated with hospital acquisitions are incorporated into the system. A key part of this will be an initial OHS audit undertaken before acquisition to identify the OHS risks and gaps in performance at the hospital being acquired. This will require appropriate organisational capacity from corporate level to operations level, and more formalised systems for monitoring performance in this respect. This is defined in the ESAP.



Workers Engaged by Third Parties

AAR contracts out services such as cleaning, security, medical waste collection and food supply, as well as more
technical services such as radiography. There are currently no requirements (in contracts or otherwise) for these suppliers to meet legislative (or other) requirements in terms of labour and working conditions. Management at AAR are aware of the need to do this, and have committed to requesting them to provide AAR with evidence of compliance to national requirements.



AAR will be required to incorporate legislative labour requirements and those related to PS2 in their contracts with suppliers. Furthermore, this will need to be incorporated into AAR’s HR policy and procedures. This is further described in the attached ESAP.



Overall AAR’s approach to HR is considered to be in line with this PS and will be applied to new acquisitions.

General

AAR does not have a policy or formalised procedures relating to pollution prevention or resource efficiency. AAR complies with all legislative requirements with regard to environmental performance, but do not have any written procedures in this regard. Environmental and social due diligence undertaken by IFHA and Swedfund (and now IFC) has raised their awareness around these matters and they have committed to developing policies in this regard. AAR will develop a policy and procedures in this regard, to be incorporated into their overall ESMS. This will contain requirements related to hospitals, so that any further EHS issues arising in these new acquisitions are also covered by the system.



Resource Efficiency

Clause 11.8 of the HR Manual on Work Place Environment states that employees are expected to respect the environment by conserving water and electricity, disposing of plastics and sharps appropriately and using recycled paper and envelopes wherever possible. Beyond this, AAR do not formally adopt or promote energy or water efficiency measures and have not actively undertaken improved efficiency measures in relation to these resources.



Due to the erratic supply of electricity across the three countries, the clinics make use of backup generators that are often required on a daily basis. These are generally owned by the owners of the buildings in which AAR rents space, and are not the direct responsibility of AAR. Where they are owned by AAR, the running of the generators is the responsibility of the clinic manager, with oversight from the clinical operations manager. AAR currently owns two generators in Kenya, a 20kV and 12kV respectively. AAR has installed inverters into its newest clinics, not for energy efficiency reasons, but for consistency of supply.



AAR does not collect or monitor data on energy, fuel or water useage. Utility bills are provided to AAR either from the building owners (where water and electricity is often amalgamated into one cost) or directly from the utility providers. In some cases, such as at City Centre in Nairobi, utilities are incorporated within the rental. Data collected shows that AAR consumes on average around 600,000 kWh of electricity per year across their facilities, around 31,000 litres of diesel in their generators and approximately 62,000 litres of diesel in their ambulances. Based on this, AAR produces around 500 tonnes of CO2 equivalent per year.

AAR will be required to monitor consumption of electricity, fuel and water at their current and future operations and, where possible, implement measures to improve efficiency. In particular, electricity and fuel use will be monitored such that quantification of GHG emissions can be conducted on an annual basis.



Pollution Prevention

Water and Wastewater Management: AAR sources all of its non-potable water from the municipal water supply and uses it for purposes of sanitation, cleaning and laundry services. Approximately 12,
426 m3 of water is consumed across the facilities. All potable water for patient and staff consumption is sourced from local bottled (PET) water supplies.



Waste water disposal is carried out using municipal water disposal systems and no water discharge from the clinics is separated or treated before disposal, including water from the laboratories.



For purposes of hospital acquisitions, waste water treatment will be assessed in the ESDD against the discharge requirements defined in the World Bank Group (WBG) EHS Guidelines. Where there is non-compliance, actions will be defined to ensure compliance including installation of a waste water treatment plant if necessary. For purposes of existing operations, AAR will analyse the waste water from three clinics (large, medium and small sized) against the requirements of the WBG EHS Guidelines. Based on the findings thereof and in agreement with IFC, AAR will then define the need, if any, for the treatment of waste water from clinics.



Hazardous Materials Management: Due to the nature of the operations, AAR is required to handle and store dangerous substances, including hydrogen peroxide, hydrochloric acid, sulphuric acid, acetone, xylene, methanol, ethanol and diethyl ether. These are all bought in bottles and stored in a predefined area at the clinic. Material Safety data sheets from the WHO are available for these substances.



AAR has a centralised system of monitoring the expiry dates of drugs in their pharmacies. This alerts the pharmacists when any drugs are going to expire within three months. If this occurs, notification is sent to other clinics about the availability of these drugs and resources are shared. Where there are any expired drugs these are sent to the relevant national drug authority for correct disposal.



AAR will be required to incorporate requirements for the safe transportation, management, storage and use of these substances into their EMS.



Solid Wastes: No policy or formalised procedures exist with regard to waste disposal, although AAR clinics adopt a practice of segregation of general waste from infectious health care waste at the point of generation. All facilities have colour-coded bins that are appropriately labelled, and sharps containers are provided for the disposal of sharps and glasses. Bin liners are to be colour coded, although this is not always the case. No waste is collected centrally at any of the facilities, rather the waste disposal service providers collect the bin liners directly from the bins.



AAR contracts with licensed medical waste disposal service providers in each country. The clinic’s medical licenses are dependent on having medical waste disposal service providers that meet legislative and licencing requirements. As such, performance at AAR in this respect is therefore adequate. All contracted companies are licensed by the respective environmental licensing agencies to provide this service and to transport it to privat
ely operated incinerators in Kenya and Uganda, and at Muhimbili National Hospital in Tanzania. There are no incinerators at any of AAR’s facilities.



AAR will be required to develop and implement a Waste Management Plan to be incorporated into the overall EMS. This will incorporate the waste management hierarchy of reducing, recovering and reusing, and then managing waste in a manner that is safe for human health and the environment. Particular attention will need to be paid to the management and disposal of medical wastes. As this is currently conducted by third party suppliers, it will need to incorporate requirements for these third parties.

Patients are looked after through the operation of a safe working environment as described below. Any communicable diseases (such as Ebola, etc.,) are referred on to hospitals that are equipped to deal with these cases and have isolation wards. Communicable diseases are notified immediately to the relevant Ministry of Health.



Infrastructure and Equipment Design and Safety: AAR has 10 ambulances, 8 of which are in Kenya, and 2 in Uganda. In each country, these ambulances are managed under the department known as “AAR Rescue”. Their head, the rescue services manager, reports to the MD (in the absence of the GM). The ambulances operate a 24 hour service and are available to the public and used to cover large public events. They are usually stationed at hospitals and can be called out from this location. Drivers are provided with defensive driving training as carried out by the Automobile Association, and all vehicles are fitted with tracking devices and speed governors.



AAR will be required to incorporate management requirements for ambulance safety in the overall ESS.



Emergency Preparedness and Response (Life and Fire Safety): AAR has not developed procedures for facility fire prevention, emergency response or evacuation plans or patient information in this regard. However, AAR due to the recent audits undertaken by Swedfund and IFHA, have become aware of the need for this and have committed to developing procedures in this regard.



According to management, AAR do meet legislative requirements in terms of fire-fighting equipment, as was observed during IFC’s visits to the clinics. Provision and maintenance of fire-fighting equipment is undertaken by licensed contractors who undertake annual inspections and provide fire fighting training to employees. In Uganda, an independent fire audit has just been undertaken at all clinics. In general, clinics performed well and any findings will be immediately actioned by the Clinical Operations Manager through the development of new procedures. These findings will be shared at the next harmonisation meeting attended by the Clinical Operations and Quality Assurance managers. The clinics in Kenya and Tanzania will also be subject to an audit.



AAR will be required to develop emergency response and prevention plans, in particular in relation to life and fire safety and this will form part of the EMS. For the clinics, a local fire inspector’s certificate of compliance (up to date) will be required, while for larger facilities, such as the hospitals to be acquired by AAR, a qualified specialist will be required to undertake a life and fire safety audit of the relevant facility pre and post acquisition in accordance with the WBG EHS Guidelines and agree with IFC on a corrective action plan if necessary.



Community Outreach and Investment

AAR’s Healthcare Promotion department provides healthcare and advice to the public. This is done through the AAR Trust and the Beckmann Trust in the form
of health camps, emails to clients and corporate training. The health camps take place in public markets and throughout the communities, whereby AAR provides outreach and provides locals with free health checks. Each clinic is required to do 10 health camps per year and it is a requirement that all employees devote 5 hours of their annual working time to these camps. This is assessed as part of an individual’s performance appraisal. Emails to clients comprise of healthcare advice, and the corporate training is taken within companies for employees. Through the Beckman Trust, AAR has done community outreach programmes at 120 schools, including deworming, health education and tree-planting.



Security Personnel:

Currently AAR do not have security personnel directly associated with their operations, however this may change in the event that hospitals are acquired. While the use of armed force would need to be confirmed at the time of the acquisition, in the even this does apply, AAR will compile security protocol to ensure compliance with this Performance Standard.

Given the location of AAR's clinics in existing buildings (shopping centres, offices blocks and factories etc.) there is no community engagement beyond that described under PS1 and it is not considered necessary. The requirement for community engagement will be assessed for new hospital acquisitions will be determined as part of the ESDD as requested in the attached ESAP

This Environmental and Social Review Summary document and companion Environmental and Social Action Plan are available from AAR as per the contact details below. In addition, AAR will lodge an advertisement in a local newspaper notifying the public about the availability of the documentation for review.

Mr. Mark Achola
AAR Health Care Holdings Ltd
Williamson House, 4th Ngong Avenue,
P.O. Box 41766 00100, Nairobi, Kenya
Tel: +254 (0)20 2895000
Email: mailto:machola@aar.co.ke

Broad Community Support is not applicable for this project

Action	Timetable
Performance Standard 1: Environmental and Social Assessment and Management System
Commission a suitably qualified consultant in accordance with an agreed Terms of Reference for the development and implementation of a formalised Environmental and Management System (EMS) that integrates environmental and occupational, health and safety (OHS) requirements. The Terms of Reference will define a schedule for development and implementation of the EMS. This system must include policies, procedures and monitoring and reporting protocols for the various environmental, health and safety aspects of clinics as well as hospitals.	15 July 2013: Appointment of consultant / thereafter documentation confirming compilation of applicable EMS (e.g., policy, objectives / targets, plans etc.) in accordance with the agreed time schedule.
Develop and implement an organisational structure for implementation of the EMS with roles, responsibilities and authority to implement the environmental and social management system. This will include specific personnel, including management representatives, with clear lines of responsibility and authority.	In accordance with the agreed EMS development / implementation time schedule.
Undertake a review / gap analysis of the Group’s quality management system against the requirements of a formal quality management system such as ISO 9001 or JCI. Based on the findings of the review / gap analysis, agree with IFC on a time based action plan to align with the formal management against which the review was undertaken.	1 October 2013.
Prior to acquisition of a hospital, undertake an initial environmental and social due diligence (ESDD) to confirm there are no fatal flaws that would preclude the acquisition. This is to include a review of life and fire safety requirements to define actions required to ensure compliance with the Wold Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines.	Submission of ESDD to IFC prior to acquisition.
Commission an external environmental and social due diligence (ESDD) of all new hospital following acquisitions against the requirements of the IFC Performance Standards and WBG EHS Guidelines (General and for Healthcare Facilities). These are to be carried out by qualified consultants. Where gaps in performance are identified, develop an action plan in agreement with IFC to address these. In respect of waste water, this is to be reviewed against the requirements of the WBG EHS Guidelines and where there is no compliance in terms of discharge requirements, the action plan is to define requirements to ensure compliance, including installation of a wastewater management plan if necessary.	ESDD and agreed action plan to be completed prior to acquisition and 3 months following acquisition.
Document the existing grievance management system and extend to new facilities once developed or acquired.	31 December 2013 (information to be included in EMS documentation as referred to above)
Performance Standard 2: Labor and Working Conditions
Formalize the OHS system to ensure alignment with this Performance Standard and OHSAS 18001. This it to include procedures applicable to all operations – existing and to be developed / acquired – and define OHS performance indicators.	Formalization of OHS management system in accordance with the agreed time schedule as per consultants Terms of Reference as detailed above
Undertake a baseline OHS audit following acquisition of new hospitals to define gaps and alignment with AAR’s OHS management system.	To be completed three months following acquisition
Where there is ongoing provision of contracted workers for purposes of fufilling specific tasks e.g., security or cleaning, require such contractors via the assocaited contracto dcoumentation to comply with the requirements of this Performance Standard.	Prior to appointing contractors.
Performance Standard 3: Resource Efficiency and Pollution Prevention
Develop a system for recording, reporting and analysis (including benchmarking) of energy and water consumption data for each building.	In accordance with the agreed EMS development / implementation time schedule
Develop a policy and procedures for the safe management, storage and use of hazardous substances and incorporate these into the EMS.	In accordance with the agreed EMS development / implementation time schedule.
Develop and implement a waste management plan for all operations. Particular attention is to be paid to the management and disposal of medical wastes. This is to include requirements for duty of care into contracts with medical waste disposal service providers and indicators for monitoring of these providers.	In accordance with the agreed EMS development / implementation time schedule.
Undertake a review of waste water quality at three clinics representative of the large, medium and mid sized operations against the requirements of the WBG EHS Guidelines. Based on the findings thereof, agree with IFC on a time based action plan to ensure compliance with the Guidelines.	1 October 2013
Performance Standard 4: Community Health, Safety and Security
Undertake a life and fire safety audit by qualified specialists against the requirements of the WBG EHS Guidelines for all new hospitals pre and post acqusition. Based on the findings thereof, agree with IFC on a time based action plan to address any deficiencies identified.	Audit and agreed action plan to be completed 3 months following acquisition.
Where armed force is used to secure facilities, develop and implement a security protocol aligned with the Performance Standards.	3 months following development / acquisition of facilities requiring armed force.