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

The key environmental and social (“E&S”) issues in this project are in the development and implementation of an integrated E&S management system; food and pharmaceutical safety; and fair, safe and healthy working conditions. IFC’s appraisal considered Facey’s E&S management policies and procedures and gaps between them and IFC requirements. Where necessary, corrective measures, intended to close those gaps within a reasonable period of time, are summarized in the paragraphs that follow. Through implementation of those measures, the project is expected to be designed and operated in accordance with Performance Standard objectives.

As there are no major adverse environmental or social impacts expected to result from the proposed project, and it is possible to avoid or mitigate any limited adverse impacts that might result, the proposed investment has been classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects.

PS3, PS4, PS5, PS6, PS7 and PS8 are not considered applicable given the nature of the project’s operations.

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.

Facey makes use of PBS health and safety policies and procedures, which prescribe worker training, workplace inspections, and hazard analysis, as well as material handling practices and procedures. The policies require that worker training cover protective equipment, emergency procedures, electrical safety, and fire prevention. At warehouses, workers are required to wear helmets, gloves, reflective vests, and if needed, also goggles and noise protection devices.



Facey has entered into agreements with the pharmaceutical manufacturers that it represents on such topics as distribution, pharamacovigiliance, quality, and distribution. These agreements provide guidance on proper handling of pharmaceutical products.



Facey is in the process of developing a screening mechanism for contractors, which will ensure that all key contractors are well-established companies with solid track records in quality management and labor compliance. Facey will include E&S terms in its agreements with key contractors, to ensure that they will use documented procedures consistent with IFC and local standards. Facey will monitor compliance with those terms and require improvement in the event that non-compliance is identified.



In all Facey’s country operations, it uses the Disaster Recovery Manual of its parent company (the Musson Group), which provides for precautionary measures and recovery procedures, and which covers potential hurricanes, earthquakes, and computer crimes.



As a condition of IFC’s investment, Facey will develop a more formal and integrated environmental and social management system (“ESMS”), commensurate to the scale and impacts of its operations. The ESMS will be developed at the corporate level and tailored to the languages and laws, rules, and regulations of each country operation of Facey, and it will be consistent with all applicable parts of IFC Performance Standards and applicable World Bank Group EHS Guidelines. Facey will implement this ESMS across all Facey operations, and will ensure that relevant issues are managed consistently for both employees of Facey and those of its key contractors, both on Facey’s own premises and premises operated by others.



Facey’s ESMS will include a Quality and HACCP system to guarantee food safety management according to applicable IFC EHS standards. Product traceability and recall procedures will be prepared and implemented. The Company’s ESMS will also provide for appropriate safety measures at any of its facilities open to the public, notably its retail pharmacies and Wellness Center in Jamaica.



Facey’s ESMS will also incorporate integrated pest management, solid waste management and disposal, effluent management, and energy efficiency. The ESMS will include policies and procedures to cover its card printing operations, and to cover the use of force by contracted security guards.



The Company’s ESMS will provide for record-keeping of such items such as health inspections,
safety violations, physical injuries, reporting of accidents to appropriate authorities, and recording of safety training. Identified risks will be documented, and mitigated as much as possible. All accidents will be recorded, investigated and acted upon to prevent recurrence.



Facey will nominate at least one employee at its headquarters and at least one employee in each country operation to be an E&S coordinator, responsible for developing and/or implementing the Company’s E&S policies and procedures. The E&S coordinator at Facey’s headquarters will be responsible for the Company’s overall monitoring and reporting structure for environmental and social management. The ESMS will include a feedback loop for continuous improvement. E&S monitoring and reporting from all country operations will be consolidated into an annual E&S performance report to IFC.

The Company has about 3200 employees, including 250-300 temporary ones, 100-150 contract employees. No increase in the number of workers is expected, though it might occur in the future. About 726 employees work in the Company’s telecom operations, about 1373 in its business solutions operations (with 91 outsourced), and about 858 workers in its consumer operations. This includes more than 100 workers in each the Dominican Republic, Nicaragua, Panama, El Salvador, Costa Rica, and Guatemala, and fewer than 100 in each of the Barbados, Jamaica, Honduras, Aruba, Curacao, Cayman, and Belize.



Facey has developed and implemented a formal set of HR policies and procedures in English. These include a policy that employees are age 17 at minimum; a policy that Facey will not discriminate on the basis of color, gender, creed or sexual orientation; and procedures for a multi-dimensional worker grievance mechanism.



Under IFC’s investment, Facey will tailor its HR policies and procedures to the languages and laws, rules, and regulations of each country operation, and it will comply with all applicable parts of IFC Performance Standard 2. This will include respecting national limits on working hours; an expanded non-discrimination policy to cover specifically both recruitment and promotion, and an explicit policy on harmful child labor. Relevant parts of the Company’s HR policies and procedures will specifically apply to employees of key contractors, including access to a worker grievance mechanism.

Broad Community Support is not applicable for this project

Facey Group II(33791) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
INTERLINC will complete the development of and will implement an ESMS, commensurate with the project’s risks and impacts, to meet IFC’s Performance Standards. The ESMS will integrate the existing elements (i.e., Human Resources Manual, Occupational Health and Safety Policy and other existing E&S policies and procedures) and will include at minimum: (i) corporate EHS policy that addresses INTERLINC’s operations in its countries of operation, and aligned to IFC PS requirements; (ii) E&S risk and impact identification and management procedures; (iii) contractors/third-party workers’ E&S management procedures; (iv) revised occupational health and safety (OHS) procedures; and (v) effective procedures for monitoring and reporting of the implementation of all E&S requirements at country level through key performance indicators (KPIs) for direct-staff and third-party workers. The ESMS implementation will be tailored to the operations characteristics and legal requirements at each site, and available in the local language. Evidence of implementation at each site will be shared with IFC. As part of its ESMS, INTERLINC will develop a security policy requiring security personnel are guided by the principles of proportionality and good international practice, including requirements for training on the use of force	01-Nov-2021	Completed	Completed	9/1/2023
PBS will ensure the ESMS, which is in the process of being implemented, includes: (i) appropriate environmental and occupational health and safety corporate procedures, consistent with IFC PS2 and relevant and applicable WBG EHS Guidelines; (ii) tailored EHS policies and procedures to the operations characteristics and legal requirements at each site; (iii) effective procedures for monitoring and reporting of the implementation of all E&S requirements at country level through key performance indicators (KPIs) for direct-staff and third-party workers; and (iv) the relevant policies ad procedures are available in the local language. Evidence of implementation at each site will be shared with IFC. As part of its ESMS, PBS will revise the procedure for contractors to ensure security personnel are guided by the principles of proportionality and good international practice, including training requirements on the use of force to avoid abusing community members.	01-Nov-2021	Completed	Completed	9/6/2023
INTERLINC and PBS will include in their ESMS requirements and will ensure all facilities to have (i) emergency preparedness and response plans (which will be specific to the operation, considering the national/local legislation and the physical structure of each facility); (ii) life and fire safety certificates when required by the local legislation; (iii) trained teams on emergency response (brigades); and (iv) fire drills or emergency exercises conducted at least once a year	01-Nov-2021	In progress	In progress
INTERLINC will formalize a grievance mechanism to receive and facilitate resolution of external parties’ concerns and grievances. In addition, INTERLINC AND PBS will share evidences that all grievances/concerns are registered and addressed, that feedback is provided, and KPIs are reported at the country level.	01-Jan-2022	In progress	In progress
INTERLINC Code of Conduct will be revised to emphasize the company zero-tolerance approach for any case of gender-based violence (GBV), or workplace harassment. The Code of Conduct and HR related documents (such as the HR Policy and Procedures Manual) will be translated into Spanish (and other relevant national languages) to ensure all workers fully understand its content before signing the document.	01-Jul-2021	Completed	Completed	9/1/2022
INTERLINC and PBS will review its internal complaint mechanism to provide employees, including third-party workers and service providers, with a confidential channel to raise grievances about any misconduct or about any other issue in the workplace and improve governance and the working environment. The Company will inform the workers of the grievance mechanism, which will include procedures to address concerns and grievances promptly, using an understandable and transparent process that provides timely feedback to those concerned. The mechanism will allow for anonymous complaints to be raised and addressed, and will not impede access to other judicial or administrative remedies available under the law or through existing arbitration procedures	01-Aug-2021	In progress	In progress