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 proposed investment is expected to have limited environmental and social impacts which will be site-specific with none anticipated to be significant. Further, the impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. IFC’s appraisal considered environmental and social management plans for the Project and gaps if any between these plans and IFC requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP) disclosed in this review summary. Through implementation of these management plans and the ESAP the Project is expected to be designed and operated in accordance with Performance Standards objectives.
Key environmental and social issues applicable for this investment are; i) design and construction of the Project in accordance with accepted building codes and standards, notably that related to life and fire safety; ii) effective implementation of the Project’s Environmental and Social Management Plan during the construction phase; iii) labor and working conditions for construction staff and those associated with the Project’s operational phases, inclusive of occupational health and safety; and v) management of waste water and stormwater.
The land on which the project will be based is part of the greater Jabi Lake Master Plan which has a valid leasehold interest and certificate of occupancy and was acquired on a willing buyer willing seller basis. Actis has been issued a sub-lease on this property, as negotiated with Duval Properties Ltd, the developers of the Master Plan. No involuntary resettlement or economic displacement was caused as a result of the acquisition, and, except for some concrete columns from a previously abandoned project, the land was previously vacant as is currently the case. Thus PS 5: Land Acquisition and Involuntary Resettlement does not apply. The site is largely undeveloped, except for the aforementioned concrete columns and some grasses, shrubs and some trees. As such PS 6: Biodiversity Conservation and Sustainable Management of Living Resources also does not apply. Neither does PS7: Indigenous Peoples as there are no such individuals classified as Indigenous in Nigeria. Issues related to PS8: Cultural Heritage are assumed not to apply and no issues of this nature have arisen in the Environmental Impact Assessment (EIA) that was undertaken for the Project. However, a procedure for chance find during construction will be required, as defined in the ESAP.

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.

An Environmental Impact Assessment (EIA) was undertaken for the Project by a local consultancy, Cityscape Planning Services, in May 2013. This assessment included a project description, including the project development phases and activities, required project infrastructure/ utilities and proposed project facilities and equipment. It described the environmental and social baseline, assessed impacts and provided mitigation and an Environmental Management Plan (EMP) for construction and operation. Finally it described project implementation, recording, monitoring and audit arrangements. The EIA concluded that the Project will not have any significant adverse environmental impacts but would help in improving the socio-economic aspects of the immediate environment of the project area and more broadly the EIA has been submitted to the Federal Environmental Protection Agency (FEPA) for approval.

Actis has a comprehensive environmental and social management system (ESMS) which is aligned with IFC’s Performance Standards. To ensure effective implementation of the Actis ESMS there is a dedicated environmental department staffed with two full-time individuals, one of which is dedicated to the Project. Actis’s approach to environmental and social management is defined in the Actis Guidebook; “Responsible Investment – Integration of Environmental, Social and Governance Factors”. The Guidebook includes an Environmental Policy, Climate Change Policy, Health and Safety Policy, Business Integrity Policy and Social Policy with the latter including issues related to the management of labor and working conditions. The Guidebook also defines the approach to address environmental, social and governance (ESG) issues when; i) a project is initially being considered for investment with screening of ESG issues being undertaken; ii) the formal ESG due diligence procedure prior to investment; iii) the approach to management of ESG issues during the life of the investment and; iv) how to address ESG issues when exiting an investment.

The EIA conducted for the Project includes a set of mitigation measures for each project phase (pre-construction, construction, operation, decommissioning) which are then included in an EMP. This assigns responsibility for mitigating, financing and implementation of the mitigation measures for construction and operation, along with required reporting periods. Chapter 8 of the EIA describes implementation, recording, monitoring and audit functions. This includes a description of the Health, Safety and Environment (HSE) committee, responsible for the implementation of the EMP during construction and operation.

In terms of meeting the requirements of the Performance Standards, the EIA and mitigation measures are considered limited to a certain extent, as described under each Performance Standard below. However, where there are gaps, implementation of Actis’s ESMS and the requirements of the Project Environmental and Social Action Plan (
ESAP) will ensure that these gaps are addressed. The EIA/EMP does not contain reference to Actis’s ESMS or its organizational structure. As such, Actis will be required to align the EMP with the ESMS and demonstrate that the environmental and social impacts identified within the EIA, and associated mitigations, are applied within the framework of the ESMS. This is included in the ESAP.

The EIA contains a brief Emergency Response Plan (ERP), including objectives and suggested responses in case of fire and floods. This will be developed into a site-specific plan, to be implemented during operation; this is addressed in the ESAP. To ensure compliance with the (British Standard) for building design, Actis will undertake a review of the Life and Fire Safety (LFS) design prior to construction by a suitably qualified specialist to confirm alignment with the design standard. Further, once construction is complete, Actis will similarly commission a qualified specialist to confirm the Project has been constructed in accordance with the original design standard. These requirements are included in the ESAP.

Aside from potential emergency situations during operations, the primary project risks and impacts associated with Actis’s investments are related to the construction phase. So as to manage occupational health and safety (OHS) Actis has a detailed documented safety management system that is applied to all projects; further information on this is provided in the following section.

Laurus is made up of 13 professional staff, 2 of whom are females. The administrative team comprises of 4 females. Actis’s policies and procedures in relation to human resources are applied at Laurus. Actis employs 260 individuals of whom 101 are female. The majority of these are professional staff and all staff are employed on the basis of a detailed set of employment rules, policies and procedures. In accordance with these, employees are free to join unions though none have done so to date, there is a grievance and complaints policy and procedure, rules governing discrimination and non-harassment, and a policy in respect of equal opportunities. There are clearly defined leave procedures inclusive of that related to maternity, parental and dependants leave. Overall the approach to human resources by Actis is considered aligned with this Performance Standard. While Laurus generally only employ professional staff, Actis will confirm the alignment of their human resources policies and procedures to this Performance Standard. This requirement is contained in the ESAP.

The contractor for the Project is yet to be appointed. Following their appointment, Actis will review the contractor’s human resources documentation and submit the review/ gap analysis to IFC to confirm alignment with this Performance Standard. Where amendments are required, an action plan to address these will be agreed upon by Actis and IFC. Similarly the facilities management company will be required to comply with this Performance Standard and this will apply where relevant to service providers providing regular on-going support to the Project. Finally, Actis will also include a condition in contracts with tenants renting office and retail space to comply with national labor legislation. The actions defined previously are included in the Project ESAP.

Actis’s in-house activities are typically of an administrative nature, though Actis does have a health and safety policy. Actis has an OHS specification that is included with all tender documentation for projects that defines the minimum managerial requirements for OHS on a construction project by the principal contractor. In accordance with this the principal contractor, other contractors or sub-contractors need to also comply with the specification and may only commence work on-site following approval of their health and safety plan in writing.

While contractor OHS requirements are limited within the EIA and associated EMP, the implementation and monitoring recommendations do go some way to meeting the requirements of this Performance Standard. Furthermore, Actis’s OHS specification which will be applied to this Project is comprehensive and in accordance with best international practice. Key components included therein relate to; i) the need for a full-time health and safety representative, regular health safety committee meetings and monthly auditing of OHS performance by the contractor; ii) regular training including th
at related to induction and on the job training e.g., toolbox talks with attendance recorded, and competence assessments for all workers relative to the task to which they are assigned, iii) requirements in terms of personal protective equipment (PPE), first aid and emergency response procedures; iv) requirements for various types of equipment that may be used on-site such as scaffolding, heavy machinery, vessels under pressure, lifting equipment etc.; v) the need for documented risk assessments prior to tasks being undertaken; vi) physical requirements for specific types of works such as earthworks, blasting, traffic diversion etc. and; vii) the approach to work related stresses (e.g., noise and heat). The OHS specification is underpinned by three separate safety files which provide documentation to support implementation of the specification. This includes, for example, the actual risk assessment form for various tasks (civil work, bricklaying, electrical work, formwork etc.), manuals and procedures related to activities such as toolbox talks and inspections, and checklists to be applied prior to various types of work being undertaken such as roofing, electrical work, working at heights etc. The OHS specification will also be applied at the Project. For purposes of operations, as applicable, Actis will require the facilities management company and those providing regular services to the Project to also comply with the Actis approach to OHS management as applicable; these actions are defined in the ESAP.

Potential pollution issues during the construction phase are those typically associated with construction sites and will include, amongst others, the discharge of contaminated (high silt loads / oil and grease) stormwater and diesel and oil spills. In addition, there is the potential for nuisance impacts (e.g., noise and dust) on those living and working in the vicinity, and traffic congestion. These impacts were assessed within the EIA and mitigation measures included in the EMP, and none were considered significant. These impacts may be adequately managed with the effective implementation of the EMP and Actis’s ESMS requirements during the construction phase. Aside from input from Laurus to require compliance with the EMP and Actis’s ESMS requirements, there will also be independent auditing to confirm such. This is defined in the ESAP.

During the operational phase, the primary waste streams from the development will be domestic solid waste (e.g. paper, plastic, glass bottles) and liquid waste, which includes sewage and storm-water runoff. Waste will be collected by the municipality and disposed of at the municipal landfill site.

As defined in the Pre-Concept Sign-Off Report, adequate sewage and water supply systems are available from public mains and no further investment is required for providing these services. Actis will confirm the designated works has sufficient capacity to treat the sewage and that the facility is operating adequately such that the quality of treated sewage is aligned with the national requirements and those associated with the World Bank Group Environmental Health and Safety (WBG EHS) General Guidelines. In the event that there is insufficient capacity or non-compliance in respect of waste water quality, all sewage generated by the Project will be treated via an on-site treatment plant that complies with the requirements of the WBG EHS General Guidelines.

A drainage system and on site retention pond is proposed for stormwater management and management of offsite discharge with the water being piped to an existing canal located a distance of approximately 223 metres south of the south-east corner of the site. Due to the location of the Project next to the Lake there should be confirmation that the stormwater drainage system has been designed to take into account this location and associated flood risk. This is defined in the ESAP.

Water requirements during construction have not been estimated, but a large amount of water will be required for drinking, mixing of cement, bathing, washing equipment, flushing and wetting of open ground etc. During operation, it is estimated that around 385,800 litres of water will be required per day. A metered water supply will be provided from the water mains and monitored for any major leakage. This will be diverted into a concrete potable water tank (with butyl liner) for domestic and drinking water purposes. A water purification system will be required for drinking purposes, an
d the quality of this water will need to be monitored to ensure it conforms to an acceptable quality for potable water. This is defined in the ESAP.

The approach to cooking in the individual kitchens in the food section of the Mall is still to be defined, however may include the use of liquefied petroleum gas. Thus Actis will confirm the building codes to be applied to the installation of the storage tanks and this aspect will be incorporated into the independent life and fire safety audit defined below.

The quantity of electricity to be utilized by the Project is yet to be defined, however this will be supplied via the national grid. Provision has been made for two 33KV underground ground cables to be delivered by the national utility company linking into a new HV substation located at the Mall boundary, with a connection to an on-site transformer. In addition, there will be standby generators. Prior to installation, Actis will confirm the emissions from the generators will comply with the WBG EHS Guidelines and the approach to secondary containment for the fuel storage tanks, whether they are above ground or underground tanks. These requirements are defined within the ESAP.

Actis is a leader in the design and construction of energy efficient real estate projects and have been actively working with IFC’s Green Building Specialist to identify opportunities to enhance their existing approach to energy efficiency. For this Project Actis is seeking certification of the Project against LEED (Leadership in Energy and Environmental Design), a voluntary program that provides third-party verification of green buildings. An assessment was undertaken of the Jabi Lake Shopping Centre design’s current performance in relation to LEED. This found that the current design fell short of the minimum required for projects by 4 points, and the ‘safety’ threshold by 12 LEED points. The Project demonstrated good performance within the ‘D: Materials and Resources’; ‘E: Indoor Environment’ and ‘F; Innovation and Regional Priority’ sectors, but fell short in the ‘A: Sustainable Sites’; ‘B: Water Efficiency’ and ‘C: Energy and Atmosphere’ sectors. The report provided a number of options and scenarios for design and/or operational aspects that would increase the Projects’ scoring to achieve the required points for certification. These options are currently being considered, taking into account value for effort, impact on design programme, capital and/or design cost and the impact on the Project’s Net Present Value. Laurus/ Actis should confirm that measures are being implemented to achieve LEED certification, as defined in the ESAP. In general, Actis is committed to energy savings of 25% when compared with similar developments and Actis will be required to monitor and report to IFC on the Project’s annual electricity consumption and any measures being adopted for reduction in energy use. This will be reported through the Annual Monitoring Report (AMR).

Main
tenance of the Project gardens and buildings will require the use of pesticides on occasion. Thus as defined in the ESAP, Laurus is required to compile and implement a pesticide management plan consistent with the requirements of this Performance Standard.

The Project is located within a larger 35 hectare site that is being master planned by Duval Properties. The area, although accessible, has been largely considered outside the urban envelope of Abuja, the adjacent lands having been developed only within recent history. Besides the land earmarked for the Jabi Lake Master Plan, adjacent uses are almost exclusively high-middle income residential, both single family homes and mid-rise multi-unit buildings.

North of the site is Ahmadu Nahuse Street, to the West is Jabi Lake and to the East is Bala Sokoto Way, the main access road to the proposed site. During project design, a traffic study was undertaken and the results were used to incorporate new roads and roundabouts into the project design in order to mitigate potential congestion and public safety issues. Furthermore, provision has been made for 914 parking bays and designed to ensure a seamless flow of traffic within and around the premises. The EIA determined that the increased traffic flow during operation would have moderate to major impacts, and included mitigation measures for traffic. However, there is no Traffic Management Plan included in the EMP and this should be developed as part of the project’s overall ESMS, to be implemented during construction and operation. This is addressed in the ESAP.

The building standards / codes to be applied to the Project have not been confirmed, though in respect of life and fire safety (LFS) Actis will apply South African or British Standards and adapt them to local conditions. Prior to construction Actis will confirm the code as applied to seismic design and access for disabled persons and this is to be aligned with internationally accepted approaches to such.

Given the location of the Project on the Jabi Lake, a Hydrological Study and Flood Risk Assessment was undertaken to determine the likelihood and significance of flooding at the Project site. This concludes that there is no serious flood risk, although some recommendations were made in terms of leaving some areas free of structures and buildings.

Some shopping centres in Nigeria have recently been subject to security threats. As such, Laurus will be required to ensure that an emergency response plan and evacuation procedure is developed and implemented prior to operation. This is defined in the ESAP. A decision has not yet been made in terms of security arrangements for the Mall. Laurus will be required to ensure that the arrangements and contract meet the requirements of Performance Standard 4 with regard to security arrangements. This is defined within the ESAP.

The EIA summarises concerns raised by those consulted. These include noise pollution, traffic congestion and dust pollution, waste disposal, population increase and associated pressure on existing infrastructure. ‘Serious concern was expressed about the potential loss of recreational and economic activities and access to Jabi Lake. These concerns around access to the lake ha
ve been addressed in the master plan for Jabi Lake, whereby there will be a common boardwalk along the water’s edge which will be 100% accessible to the public. Furthermore, a marina is built into the master plan, including boating and other recreational activities.

Stakeholder engagement was carried out as part of the EIA process. Random interviews were conducted with residents, construction workers and passers-by. No consultation was undertaken with the relevant authorities. No stakeholder engagement plan (SEP) or grievance mechanism is included in the EIA, and these should be developed, particularly for the construction phase of the project. These requirements are raised in the ESAP.

The ESRS, attached ESAP and the EIA will be made available via the World Bank Group’s InfoShop. In addition, an advertisement will be lodged in a local newspaper informing the public that the ESRS and ESAP are available for review.
Company: Actis
Amanda Jean-Baptiste Ritu Kumar
Actis, Fund Manager Actis, Fund Manager
Director, Real Estate Director, Responsible Investment
2 More London, Riverside, London, SE1 2JT

In Nigeria the ESRS can be reviewed at the following address:

Broll Property Services,
264 Tafawa Balewa Way,
CBD, Abuja

Attention: Fati Sobande.

Broad Community Support is not applicable for this project

Action	Timetable
Performance Standard 1: Environmental and Social Assessment and Management System
Align the Environmental Management Plan with Actis''''s overall Environmental Management System requirements and submit documentation to IFC to confirm that the Actis management system will be applied to this project during both construction and operation.	Prior to construction.
Develop and implement a site -specific Emergency Response Plan and evacuation procedures in case of different types of emergencies , including flooding, fires, explosions and bomb threats.	Prior to project commissioning
Develop a stakeholder engagement plan, including a grievance mechanism, and submit to IFC for review	Prior to construction.
Develop a chance find procedure for implementation during construction	Prior to construction
Performance Standard 2: Labor and Working Conditions
Submit documentation to IFC confirming that Laurus HR management aligns with Actis HR policies and procedures	Prior to construction
a) Include relevant clauses in tender documentation for the Project construction requiring compliance with Performance Standard 2. b) Following appointment of the preferred construction contractor, submit review of contractor''''s HR documentation and approach to IFC confirming compliance of the contractors approach to human resources with Performance Standard 2.	a) Prior to construction. b) 2 months prior to commencement of construction
Submit documentation to IFC confirming compliance of contractors involved in the day to day management i.e., overall facilities management or ongoing regular services during operation, confirming compliance with Performance Standard 2	Two months following overall Project commissioning / or commissioning of specific phases.
Submit documentation to IFC confirming the requirement for all tenants associated with the Project to comply with national labor law.	Prior to occupation by any tenant
Confirm requirement for contractors involved in the operational phase to comply with Actis’s occupational health and safety guidelines.	Two months following overall Project commissioning / or commissioning of specific phases
Performance Standard 3: Resource Efficiency and Pollution Prevention
Confirm that the municipal treatment of sewage arising from the Project complies with the World Bank Group (WBG) EHS standards and the municipal system has the capacity to accommodate these new volumes. Should these standards not be met, install a plant on site for the treatment of effluent to ensure that the WBG standards are met. Submit written confirmation from the civil engineer appointed for the Project that, either way, the discharge will comply with the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines.	Six months prior to Project commissioning or commissioning of any phase requiring the disposal of sewerage
Submit confirmation from the design engineer that the stormwater drainage system has been designed to take into account the location of the Project next to the Jabi Lake and has mitigated associated flood risks	Prior to construction
Install a water purifciation system for potable water and monitor water quality. Submit results of this to IFC via the AMR	Prior to project commissioning
In the event of the use of liquefied petroleum gas in the Project, confirm which code to which these have been designed, and that these meet the required applicable WBG EHS standards. This must be included in the independent LFS audit defined below if necessary.	Prior to construction
Confirm the generators will comply with the WBG EHS Guideline emission standards and the approach to secondary containment of the fuel storage tanks.	Six months prior to Project commissioning
Develop and implement a pesticide management program compliant with the WBG EHS Guidelines.	Submission of plan 3 months prior to Project commissioning or commissioning of any specific Project phase
Performance Standard 4: Community Health, Safety and Security
Commission a qualified specialist to confirm the Project has been constructed in accordance with the original design standard.	Upon completion of construction
Confirm the code to be applied to the seismic design and access for disabled person; such codes are to be aligned with internationally accepted practice.	Prior to construction
a) Commission a suitably qualified specialist agreed upon by IFC to audit the Project’s life and fire safety (LFS) design to confirm compliance with the (British Standard) for such design taking into account any adaptation incorporated into the design to address local requirements b) Commission a suitably qualified specialist agreed upon by IFC to confirm the Project has been constructed in accordance with design as confirmed in a) above.	a) Prior to construction b) 3 months following Project completion / or following completion of any defined phases should this approach be applied to the Project, and before public opening.
Submit documentation to IFC confirming compliance of security contractors with the requirements of with Performance Standard 4.	Prior to contracting security providers during contruction, and prior to Project commissioning