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 project has been classified as a Category B project as the E&S risks are expected to be limited, generally site specific, and can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key environmental and social issues include identification and mitigation of health and safety, environmental (HSE) and social risks and impacts; to ensure compliance with IFC’s Performance Standards; construction subcontractors HSE management; effluent management including construction waste and waste water; hazardous materials management; managing the risks and impacts of the construction operations on communities; and external grievance mechanism and ongoing reporting to affected communities.

As RCI will be a contractor which obtains contracts for new projects primarily through competitive bidding for construction projects of governmental agencies and/or private entities, PS5, PS6 and PS7 are not considered applicable. If this changes for some reason, RCI will notify IFC for PS5, PS6 and PS7 implementation.

RCI is not expected to encounter issues covered by PS8 Cultural Heritage in this project as the current and potential project sites do not have any features of historic or cultural value. However, the Company will develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage.

Key environmental and social (E&S) issues and relevant mitigation measures are described in detail in the paragraphs below. In addition, RCI will implement an Environmental and Social Action Plan (ESAP). The ESAP is focused on priority mitigation measures to achieve compliance with IFC’s Performance Standards (PSs).

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 and Policy / Identification of Risks and Impacts and Management Program: RCI has corporate level health, safety, and environmental (HSE) policy. The existing management systems were certified according to ISO 14001 Environmental and OHSAS 18001 Occupational Health and Safety Management Standards. According to the existing management system, main environmental impacts and occupational health and safety risks are identified per each project prior to bidding. Bids also include the cost of the relevant mitigation measures such as waste management, occupational health and safety signs, etc. HSE risk assessment also included Job Safety Analysis and Safe Task Analysis Risk Reduction Talks. After the successful bidding, prior to construction, a detailed risk analysis is conducted and an HSE Plan is prepared for each project site, which included mitigation plan to eliminate and/or manage the project specific HSE impacts and risks.



As per the ESAP, RCI will be required to review its existing environmental impact assessment and occupational health and safety risk/ hazard analysis system to cover social impact assessment as well as evaluation of the project against Performance Standard requirements including PS5, 6, 7 and 8. RCI will provide IFC a copy of the updated occupational health and safety risk/ hazard analysis procedures. As a part of the existing HSE management system, RCI will develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage.



Although RCI will be a contractor which obtains contracts for new projects primarily through competitive bidding, as per the ESAP, as a part of the bidding process, RCI will be required to incorporate screening of clients’ designs for structural safety and severe life and fire safety risk within their existing HSE management system.



RCI’s subsidiaries provide project design services according to the Terms of References determined by their clients. To minimize the risks for occupants caused by potential gaps in local requirements, RCI will review clients’ design Terms of References to ensure minimum recognized life safety standards are met.



Organizational Capacity and Competency: According to RC’s HSE management system, prior to commencing any project work activities, the Project Manager should establish the Project HSE team, which consists of an HSE manager, HSE Engineers, HSE Technicians, HSE Officers and HSE Workers. If needed, local HSE experts with experience on the host country’s HSE legislation are also employed. Each project site has various numbers of HSE team members, and at the time of the appraisal, there were more than 250 HSE team members for almost 35 ongoing projects. There were 60 doctors and/or health technicians employed as well. Each country has HSE coordinators and HSE managers are reporting to both project manager and HSE coordinators. HSE coor
dinators are reporting to Central (Corporate) HSE Director. Central HSE team consists of almost 10 engineers/officers, who mainly coordinates the corporate level management system and benchmarks and transfers best practices between the project sites.



HSE teams at project sites are assigned to perform the HSE impact and risk assessment, provide feedback to management on HSE performance, supervise the RCI employees and operations as well as contractors on HSE issues, and conduct HSE trainings. RCI is providing HSE training to its staff as a part of orientation program before they started to their tasks. Periodical awareness trainings as well as weekly toolbox talks on HSE are provided.



Emergency Preparedness and Response: RCI has documented emergency preparedness and response plans including fire prevention, first aid, and response to spills in line with IFC’s requirements. Fire exercises and evacuation drills are conducted periodically on each site.



Monitoring and Review: Project Site HSE team conducts daily site inspections including both RCI and sub-contractors activities. HSE team members have authority to stop any unsafe activity on site until appropriate action is taken. Daily inspection findings are discussed during project daily meetings which are performed on site. Project site’s HSE performance is reported to HSE Coordinators and HSE Director on a weekly and monthly basis. HSE performance indicators included HSE incidents and accidents, emergencies, equipment damages, near misses and dangerous occurrences. As per the ESAP, RCI will be required to include waste generation as well as incident rates of subcontractors as key performance indicators to site level HSE performance reporting.



As a part of HSE management system, bi annual internal audits which include evaluation of the implementation of the HSE system are performed at project sites. Internal audit findings and site level HSE performance are reported and reviewed annually and monthly respectively by RC’s management.



External Communication and Grievance Mechanism and Ongoing reporting to Affected People: As per the ESAP, RCI will be required to establish an external communication and grievance mechanism and ongoing reporting to affected people in line with PS requirements and provide a copy of the documented procedure to IFC.

Working Conditions and Management of Worker Relationship: There are almost 19 000 RCI and 13 000 subcontractor employees who work in 11 countries. RIC has documented Human Resources (HR) Policy and Procedures related to organization and functioning, recruitment, training, performance evaluation, terms of employment, career development, job descriptions in line with IFC PS2 requirements.



There is no discrimination allowed on the basis of personal beliefs, sex or characteristics. Although there is no unionized employee, there is no prohibition or discouragement of freedom of association. There is a grievance mechanism where all employees, including the contractors, can raise and register their concerns through use of a call center.



Protecting the Work Force: In line with the host country laws, there is no child labor and/or forced labor employed in RCI and its subcontractors.



Occupational Health and Safety: RCI has a documented and certified management system to ensure occupational health and safety for the employees. Existing system included documented procedures for confined space entry, work permit system, welding and cutting, vehicle safety and monitoring system, manual handling, lifting safety, electrical safety, night work, incident reporting and investigations, emergency preparedness and response plans. Detailed measures for working at height and weekly control and tagging of safe scaffoldings were included in the site level HSE plans.



The staff to be employed is subject to medical testing and analysis specific to the job where he/she will be employed. The health tests are done periodically according to legislation in force.



New employee induction and periodical training are mandatory for both RCI and subcontractors employees. HSE training included the topics such as management system requirements, individual responsibilities, zero accident philosophy, PPE program, principle hazards in construction, site security, general site safety rules and regulations, toolbox talks, incident / accident / near-miss reporting, emergency procedures, housekeeping and waste management, chemical safety (MSDS), confined space entry, permits to work, material handling, fire prevention, defensive driving and rules of the road, excavation safety, scaffolding safety, working at heights / fall protection, first aid and lifting safety.



Lost time injury rate (LTIR – number of injuries per 200.000 man hour) has been reduced from 3.9 to 0.72 in the last 5 years, which is satisfactory when compared with U.S. Benchmark of 3.7 in construction sector (reference : http://www.bls.gov/iag/tgs/iag23.htm#fatalities_injuries_and_illnesses). The most recent work-related fatality of an RCI employee was in 2008. However, as of September 2013 two sub-contractor employees were lost their lives in incidents related to crane operations. Following this, RCI reviewed its lifting safety measures and developed a new lifting safety procedure for its entire operations
.



RCI is provides accommodation for its own, and if needed, to subcontractors’ employees. The conditions of accommodations were in line with IFC’s requirements.



Workers Engaged by Third Party: RCI employs subcontractors where specific experience (such as electrical installations, steel works) is required. Subcontractors are legally required by construction contract to follow RC’s HSE management system requirements, including implementation of the HSE procedures, attending daily HSE inspections, weekly toolbox discussions. As a part of daily site inspections, sub-contractors compliance to HSE requirements were evaluated and their performance is reported to project site management, HSE Director and HSE coordinator. Sub-contractors HSE performance is considered during tender selection process.

Resource Efficiency and Green House Gases (GHG): The main resource consumption will be related with energy consumption of the vehicles and equipment related with the construction activities. RCI will provide energy consumption figures and related to GHG emissions to IFC through Annual Monitoring Report (AMR).



Pollution Prevention :

Waste Water: Domestic waste water, generated from project sites are discharged to closest existing sewage system in line with host country legislative requirements. RCI will provide waste water amounts and analysis to IFC through Annual Monitoring Report (AMR).



Wastes and Hazardous Materials Management: Hazardous materials consumption for the construction sites mainly includes fuel and machinery oil used by construction vehicles and equipment, cement addictive, isolation materials and paints. RCI has an effective system for chemical and hazardous substances labeling. Material safety data sheets were presented on site. Secondary containment and spill response kits were in use.



There is an effective waste segregation system in place at RC. Excavation wastes, chemical packages, domestic wastes, nonhazardous packaging materials, scrap metals are transported, recycled and / or disposed by third party licensed waste companies. RCI will provide waste figures to IFC through Annual Monitoring Report.

Community Health and Safety: RC’s existing HSE management system required to implement construction area safety measures to protect the community, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. In order to ensure safe movement of construction vehicles within the site and out of the site, RCI has developed training programs and instructions for the drivers.



Other impacts to the community such as noise, air pollution and other nuisances during construction will be assessed and documented procedures to mitigate those impacts will be developed and implemented. Monitoring data for noise and air pollution will be provided to IFC by Annual Monitoring Report.



Security Personnel: RCI employed unarmed security personnel at the gates of the ongoing project sites. The risk posed by these personnel to the public is regarded as being minimal. in fact part of their role is to safeguard passengers and pedestrians.

RCI maintains good relations with local communities. As discussed under PS1, RCI will be required to develop a formal external grievance mechanism where neighboring communities can raise and register their concerns. Based on the discussion at the visited project sites during the appraisal, there were no concerns raised previously for the completed and ongoing projects. The interested parties can share their concerns with the local authorities where the local authorities will follow up and provide feedback. The information related with RCI’s grievance mechanism will be shared at the gates of the project sites.

RCI’s detailed process information will be shared on RCI’s website as well as at construction sites.

For more information please contact:

Name : Mr. Roland Weber & Mr. Evre Ozer Address: St. Petersburg, 26A Shatalena Street. e-mail: mailto:roland.weber@rencons.com & mailto:Evre.Ozer@rencons.com
http://www.rencons.com

Broad Community Support is not applicable for this project

NO	ACTION	DUE DATE
	PS1 Assessment and Management of Environmental and Social Risks and Impacts
1a	Review existing environmental impact assessment and occupational health and safety risk/ hazard analysis system to cover social impact assessment as well as evaluation of the project against Performance Standard requirements including PS5, 6, 7 and 8 and provide IFC a copy of the updated occupational health and safety risk/ hazard analysis procedures;	31-May-14
1b	As a part of the bidding process, incorporate screening of clients’ designs for structural safety and severe life and fire safety risk within the existing HSE management system;	31-May-14
1c	For the project design services, as a part bidding process, to minimize the risks for occupants caused by potential gaps in local requirements, incorporate review of clients’ design Terms of References to ensure minimum recognized life safety standards are met;	31-May-14
1d	As a part of the existing HSE management system, develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage and provide a copy of the procedure to IFC;	31-May-14
1e	Include, waste generation of project sites as well as incident rates of subcontractors as key performance indicators to site level HSE performance reporting and provide IFC a copy of the template of HSE monthly report ;	30-Jun-14
1f	Establish an external communication and grievance mechanism and ongoing reporting to affected people in line with PS requirements and provide a copy of the documented procedure to IFC;	31-May-14
	PS4 Community Health and Safety
2a	Assess impacts to the community such as noise, air pollution and other nuisances during construction;	31-May-14
2b	Develop documented procedures to mitigate the impacts on the community and provide IFC a copy of the procedures;	31-May-14