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. 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. This is therefore a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy.
Key E&S issues applicable for this investment are: (i) compliance with all local regulatory requirements; (ii) adequacy of environmental and social assessment and management systems, particularly in relation to the acquisition of land and premises, and implementation of medical services; (iii) labor relations, and OHS risk prevention and management; (iv) Life and Fire Safety (L&FS) provisions, emergency preparedness and response; (v) monitoring and disposal of medical waste and expired or damaged medicines/laboratory reagents, and (vi) waste water/effluent treatment of laboratory and x-ray film waste; (vii) opportunities for energy conservation and efficiency as well as waste minimisation, and (viii) community health, safety and security.

PS5, PS6, PS7 and PS8: Existing and new diagnostic centers will be located in urban environments with disturbed habitats, mainly through leasing of existing premises. Thus, PS5 “Land Acquisition and Involuntary Resettlement”, PS 6 “Biodiversity Conservation and Sustainable Natural Resource Management”, PS 7 “Indigenous Peoples”, and PS 8 “Cultural Heritage” are not expected to be encountered during the course of this project. Prior to any land or building lease agreement, ESL will conduct a social and environmental due diligence to ensure that risks and impacts, if any, will be adequately identified and managed in a manner compliant with applicable IFC’s Performance Standards.

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.

Management Programs: Echo-Scan does not have a formal Environmental, Health and Safety policy, nor do they have a documented system to guide environmental and social (E&S) performance. Interviews with the business owner and senior staff at the Head Office and Heart Center demonstrated that there is a strong commitment to responsible operational practice and a willingness to meet IFC standards. ESL has therefore agreed to develop and implement an Environmental, Health and Safety management system (ESMS), which would include the appropriate policies, plans, manuals and procedures, as articulated in the ESAP. The ESMS would comprise (but not be limited to): a Group ESMS Policy, an Occupational Health and Safety (OHS) policy and procedure and the enhancement of Life and Fire Safety (LFS) management; environmental management plans for the construction phase; procedures for waste, water and energy management during operation; an E&S due diligence process for selecting new premises for Diagnostic Centers (DCs), and a community grievance mechanism. This will be in compliance with IFC’s PS1 requirements, national and local laws and regulations and aligned with ISO 14001 requirements. The ESMS will be applicable to all operations across the Echo-Scan network

Licenses: The primary regulatory agencies involved in the supervision of activities of ESL are: Medical and Dental Council of Nigeria; Radiographer Registration Board of Nigeria; Nigeria Nuclear Regulatory Agency and the Federal Ministry of Health. These agencies provide for the control and issuing of Licenses, approvals, and registrations of both the company and its medical personnel. ESL has all licenses in place for existing operations. For each new DC, ESL will apply for all routine licenses required for such operations in Nigeria.

Organizational structure and capacity: ESL has no permanent Environment, Health and Safety (EHS) person on its staff, but will employ a qualified person or EHS consultant to develop and implement a formalised Environmental and Social Management System (ESMS) that integrates environmental and occupational health and safety (OHS) requirements, primarily focused on radiological and machine safety, as well as to support its network and associates/partners. This person will also be responsible for implementing the conditions of the ESAP and World Bank Group EHS General and Health Care Facilities Guidelines. The Managing Director currently takes responsibility for these functions.





Occupational Health and Safety (OHS): The Head Office and existing DCs are located in a variety of residential houses and commercial leased spaces. The OHS conditions are different for each location and are also managed differently (those in leased premises are contractually obliged to comply with the OHS policies of the owner). There is no formal corporate policy or procedure in place to address OHS, although any work-related injuries are recorded and a corrective action is put in place imme
diately. The Sponsor will therefore develop and implement a corporate OHS policy with associated Radiological Safety and Life and Fire Safety (LFS) procedures, to be integrated with the ESMS, as stated in the ESAP. The policy will include appropriate procedures for both acquisition and new construction, and operation phases.

For the construction of any new DC, the OHS requirements will be included in bidding documentation for the technical/financial proposal of the construction contractors in order to ensure that all contractors and sub-contractors are in compliance with Nigerian labor laws and OHS requirements. This requires the contractor to include in their technical proposal a detailed OHS practice handbook that it will implement during construction, including policy, procedures and training requirements. The contractor will be contractually obliged to implement these practices through a full-time OHS officer who will be employed during construction. Weekly reports from the contractors to the client are expected as part of the contractual arrangements. As defined in the ESAP, ESL will confirm that the selected contractor’s OHS documentation is in compliance with the above requirements.

Monitoring and reporting: As part of its ESMS, ESL will institute systematic procedures to monitor and measure the effectiveness of its management program, as well as compliance with regulatory requirements and thresholds referenced in the applicable World Bank Group EHS Guidelines (General, Health Care Facilities).



This will include internal and external audits, as the ESMS is established. ESL will monitor the following EHS parameters during construction of, and operation, of all premises: a) Safety – Number of injuries; and, Lost Time due to Injuries b) Water Usage (Litres/month), Energy Usage (kWh/month), Diesel consumed (L/month) and weight (kg) health waste disposed monthly (medical sharps, vials, gloves, swabs etc); c) Staff Retention (resignations, retrenchments, retirements) and training days; d) radioactivity levels and magnetic force in controlled area. In addition, and as outlined in the ESAP, ESL will develop an integrated Environmental, Health & Safety (EHS) report format based on critical EHS key performance indicators (KPIs) e.g. compliance with legal and regulatory requirements, ESMS progress report and certification, including safety management, energy and water consumption and efficiency; solid waste management and disposal, effluent discharges, compliance with national OHS requirements, including accidents/incidents; customers complaints, and community engagement activities).

Human Resources (HR) Policy and Management: ESL employs 125 people spread across its network of Diagnostic Centers (70% women, 30% men), of which 95% are permanent and Nigerian. ESL conforms to the Nigerian National Labour Act of 1990, which guarantees core labor rights to employees, consistent with the requirements of PS2. The terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity, vacation or holiday, are established by national labour regulations and applicable sector specific collective bargaining agreements.

Individual contracts provide staff with information on their terms and conditions and are presented to new employees at the time of hire. All workers have to sign a formal contract with the terms of employment and retain a copy.

Hiring is conducted in accordance with Nigerian Labor Code, and the HR department asserted that there is no discrimination. The Company considers normal working hours to be from 8am-7pm (labour law specifies 8am – 4pm); overtime is paid at a rate plus 50%.



The Company does not have a Human Resources Policy or Employee Manual with a Performance Management System. However, ESL is committed to equal opportunities, gender equality, and is against sexual harassment and discrimination. The minimum working age in Nigeria is 18 years of age, which is strictly applied.

Employment terms at ESL are permanent, with no fixed term. All candidates are required to go for a medical fitness test, and only when a candidate is certified medically fit to undertake their specific work, the candidate will be employed. The basic salary comprises 85% of the total cost to company, supplemented by a 7.5% housing, food and transport allowance, a mandatory pension scheme (7.5%), and a 13th cheque.

Basic induction training for all new employees is undertaken which only focuses on service quality; this does not include any Health, Safety or Environmental training. All employees are provided with the appropriate uniforms and/or safety equipment/clothing while at work. Sanitary facilities and mineral drinking water are provided for employees.

As set forth in the ESAP, Echo-Scan will develop a formal corporate HR policy statement with a commitment of compliance with local law, non discrimination and equal opportunities, to provide a safe and respectful workplace and to stand against forced labor, child labor, sexual or other forms of harassment. Echo-Scan will also develop and implement a series of formal HR policies, to be compiled in an Employee Manual, which will be given to each staff member. Induction training will include the implementation of these policies.



Occupational Health and Safety: Echo-Scan manages OHS risks in a basic manner. Employees are provided with personal protective equipment (PPE) in accordance with their job descriptions (laboratory coats, gloves, masks, radioactive indicator badges, as appropriate). Employees are requ
ired to have Hepatitis B vaccinations, and are trained on the avoidance of needle sticks and infection, correct use of PPE etc. However the infrastructure (such as protective panels shielding exposure to CT Scanner) is old and requires an upgrade to improve safety of operation of imaging equipment such as X-Ray, Tomography and Magnetic Resonance Machines. All rooms that contain equipment emitting ionizing radiation will have the appropriate lead-based protection, all radiation installations will be highlighted with radiation warning symbols, and periodic protection tests will be conducted.



As stated in the ESAP, the Company will enhance (upgrade) its existing facilities and monitoring program to assess public and employee exposure to radiological agents and adherence to prevention measures, including more thorough periodic inspections, internal safety audits and reporting. Each examination room will have waterless hand cleaner available to the clinician, and areas where testing takes place will be kept clean, tidy and unobstructed.



Echo-Scan will implement and monitor a corporate OHS policy with associated OHS procedures, which will be integrated with the ESMS System. This is indicated in the attached ESAP.



Grievance Mechanism: There is a very basic grievance mechanism procedure, whereby employees may raise concerns and grievances with the Managing Director directly, or at staff meetings. A formal procedure for reporting and addressing grievances will be developed, as articulated in the ESAP, and which will include a fair and transparent process, providing timely feedback to those concerned, without any fear of retribution. The mechanism should also provide for anonymous complaints to be raised and addressed, and not impede access to other judicial or administrative remedies that might be available to employees.



Training: ESL encourages continuous competency development. The company is committed to providing opportunities for staff to develop on the job and to prepare for possible advancement. This is achieved through interaction between supervisors and employees, attendance at conferences/seminars etc. Life and Fire Safety training, and Environmental training are not currently provided to employees, and will form a part of the ESMS, as seen in the ESAP. Induction training will also be included.

Resource management (energy, water, wastewater): ESL does not have a policy or formal procedures relating to pollution prevention or resource efficiency. All premises have septic tanks installed for sewage and all are connected to municipal electricity and water services. A government-approved contractor maintains septic tanks and removes waste. There is a roster for the maintenance of the generators and the diagnostic equipment. Two engineers employed by Echo-Scan do the maintenance and repairs of all equipment.

Energy use: In Nigeria, municipal electricity is generally not reliable and is supplemented with diesel generators (at least one 80KVA generator per site, with separate generators for the Heart Unit). Where they are owned by ESL (and not leased) the running of the generators is the responsibility of the Operations Manager. Diesel for the generators at all premises is delivered weekly by a licensed contractor. ESL does not typically monitor the consumption of water or electricity, however, electricity, which is supplied via the municipality, has been estimated at 60,588 kWh per annum, and vehicles and generators consume approximately 336,000 L of diesel per annum. These collectively translate to < 1,000 tonnes/annum CO2 equivalent/annum, which is well below the IFC reporting threshold. Energy efficient light bulbs, energy efficient air conditioners and appliances will be installed where possible, and any new buildings will be built with sufficient insulation.

Water use:The sponsor does not monitor consumption of utilities regularly. According to a recent audit, ESL currently consumes approximately 1,680,000 L pa (based upon 1000L a day at each center) and estimates that the Project will consume 25% more water from 2014, provided from Lagos Water Authority, which will not be pre-treated on site. The municipal water is not potable; therefore bottled water is used for drinking purposes (consumption is approximately 51,000L pa for all facilities). From 2014, ESL will monitor consumption of electricity, fuel and water at their current and future operations and, where possible, implement measures to improve efficiency.

Waste and Effluent Management Waste is collected by a contractor (AEPB) who is certified by the Waste Management Authority. AEPB collects general waste produced by the Centers twice a week. Healthcare waste (sharps, swabs, vials etc. that are produced from testing) is not currently collected by a specialist waste contractor. The Sponsor will compile a separate healthcare waste management policy, and procedure, to handle, store and dispose responsibly, as articulated in the ESAP, to comply with WBG General and Health Care Facilities EHS Guidelines.The National Guidelines on Drug Distribution, in cooperation with the Pharmaceutical Society of Nigeria (PSN), specify that all expired or damaged drugs must be disposed by official government agencies that destroy the drugs or render them unusable.



Wastewater from Echo-Scan faci
lities is mainly sanitary wastewater, wastewater from the x-ray developers and laboratory wastewater. All effluent is currently discharged to the local sewage systems. ESL will submit plans for the responsible treatment and disposal of wastewater at all centers where laboratories and/or x-ray film development are operating on site. Treatment and disposal must comply with local regulations, as well as the WBG General and Health Care Facilities EHS Guidelines.



Echo-Scan stores and handles radiological products used as contrast agents in some specific exams (low radioactivity, max 0,017 mSv/MBq), and some of the machines are radio transmitters (X-ray; Tomography machines) and contain radioactive elements. Under the ESMS implementation described in PS1, Echo-Scan will develop a specific procedure in accordance with Nigerian legal requirements to store, handle and dispose of radioactive elements. Radioisotopes will be returned to their suppliers when no longer effective.

Emergency Preparedness and Response, including Life and Fire Safety (LFS): ESL has not yet developed comprehensive procedures for potential predictable emergencies, including risks of fires. In general, Life and Fire Safety (LFS) design, equipment and training are not uniform across premises, with most centers having at least one fire extinguisher, but few having smoke detectors, sprinklers, emergency signage.; Fire drills are rarely held, and assembly points, access to fire water, signage and fire exits in some cases are inadequate. The Company will engage the professional services of a qualified Life and Fire Safety Engineer to undertake an independent audit of existing centers to assess LFS gaps, and, if needed, a corrective plan will be agreed between the Sponsor and the IFC, as set forth in the ESAP; and, to design a Life and Fire Safety (LFS) Master Plan for all new DCs to be built or minimum safety requirements for properties to be leased by Echo-Scan. The LFS safety design shall be responsive to the applicable Nigerian regulations and comply with the Life and Fire Safety requirements of the IFC General EHS Guideline.

An emergency preparedness and response plan (to be applied across the network, and integrated with the ESMS) will be established to systematize the appropriate emergency response by either internal capacities or public emergency response systems. This is agreed in the attached ESAP.

Security: Echo-Scan employs 2 unarmed security people per center, operating on shifts of 6 hours each (7am – 1pm; 1pm – 7pm). Their responsibilities are: to control vehicle access, check the movement of goods and people moving through the facility, observe the cash handling process, and to notify armed response (police) in the event of an emergency. Security training is mandatory; no security member is employed without certificates and references. PPE (boots, uniform, helmet/hat, badge) is supplied to the security personnel, however the use of such equipment is not enforced.

Vehicle safety: ESL owns and operates 1 ambulance (at the Heart Center) and 1 staff bus. The Company also employs 3 drivers, all of whom have completed mandatory safety training (before employment) as well as having commercial licenses. Parking is limited; most patients park in the street.

Echo-Scan engages daily with its patients (public), suppliers and clinicians via email, face-to-face contact and through telephonic support. There are plans to develop a website.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop. The Group will also place an advertisement in a local newspaper to inform the public that environmental and social summary of the company’s operations and planned development, including the Action Plan, will be available at the following address:
Dr Ayodele Cole Benson
Echo-Scan Head Office
Area 11,
Garki,
FCT Abuja

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
a) Employ a suitably qualified person or consultant in accordance with an agreed Terms of Reference (ToRs)	09/30/2014
for (b) the development and implementation of a formalised Environmental and Social Management System (ESMS) that integrates environmental and occupational health and safety (OHS) requirements, to comply with all relevant WBG EHS Guidelines, and an Environmental and Social (E&S) due diligence process for selecting new Centers.	06/30/2015
Echo-Scan will develop a formal corporate HR policy statement and related practices to comply with this Performance Standard (PS), and which will be articulated in an Employee Manual. Training of all employees on Echo-Scan policies will be conducted.	09/30/2014
A formal grievance procedure will be developed, which will be applied to all employees and contract workers in the Echo-Scan network.	09/30/2014
Echo-Scan will upgrade its existing X-ray and CT scan facilities (infrastructure) and enhance its monitoring program to assess workers’ exposure to radiological agents and adherence to safety measures, including quarterly inspections, internal safety audits and reporting.	12/30/2014
For purposes of construction of any new diagnostic centers (DCs), the OHS requirements will be included in bidding documentation for the technical/financial proposal of the construction contractors in order to ensure that all contractors and sub-contractors are in compliance with labor laws. The contractor will be contractually obliged to implement this through a full-time OHS officer who will be employed during construction. Weekly reports from the contractors to the client are expected as part of the contractual arrangements.	07/30/2015
Develop a system for monitoring and analysis of Echo-Scan’s total electricity, fuel, and water consumption, effluent discharges, waste generation, OHS accidents/incidents, radiological safety, customer complaints, and community engagement activities	12/30/2014
Echo-Scan will develop and implement a specific healthcare waste and effluent (wastewater) management policy and procedures to: monitor, handle, treat and responsibly dispose of both effluent and healthcare waste, in order to comply with WBG General and Health Care Facilities EHS Guidelines	09/30/2014
Echo-Scan will develop and implement a formal procedure in accordance with Nigerian legal requirements to store, handle and dispose of any radioactive elements in use at any of its DCs. Radioisotopes will be returned to their suppliers when no longer effective.	06/30/2014
For the existing premises, undertake a Life & Fire Safety (LFS) audit by a suitably qualified specialist (to the satisfaction of the IFC) against a recognized international standard, and based upon the findings, agree with the IFC on an action plan to rectify any gaps.	09/30/2014
Establish an emergency preparedness and response policy and procedure and apply to all existing DICs. Personal Protective Equipment is to be issued to employees and security personnel and the wearing of such PPE will be enforced. Emergency drills will be held quarterly, and training will be provided to all employees	06/30/2014
Life and Fire Safety (L&FS) System Design a) Engage professional services of a qualified Life and Fire Safety Engineer to design a Life and Fire Safety (LFS) Master Plan for all new DCs to be built and minimum L&FS requirements for properties to be leased by Echo-Scan. LFS safety design shall be responsive to the applicable Nigerian regulations. The design shall comply with the Life and Fire Safety requirements of the IFC General EHS Guideline.	09/30/2014
b) Conduct inspections on built premises to verify that the L&FS system was built / installed as specified.	12/30/2015
Develop a community grievance procedure and extend to all facilities once developed.	06/30/2014