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
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category B project according to IFC’s Environmental and Social Review Procedure because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria as is described in the following sections.

Key environmental and social issues identified during the appraisal include the following:

• Environmental and social management capacity;
• Compliance with local permits and licenses;
• Energy, water and natural resources conservation;
• Life and fire safety;
• Protection of mainly student community health through provision of potable water, sanitation, and adequate building infrastructure for the operations;
• Labor and working conditions including occupational health and safety; and
• Protection of cultural heritage, among others.

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.

-Social and Environmental Assessment: Anima Group operates in owned and leased facilities located in urban areas. The majority of the buildings are leased; however, due to infrastructure needs the company renovates some of the buildings. The renovations of new buildings are designed and managed internally by Anima Group through its civil engineering department. Additionally, the company has a well defined planning process to design and construct new facilities. Prior to the development of a new building or renovation of a leased building Anima Group obtains the operation licenses according to the local regulations, which typically include the municipal permits and environmental permits where applicable. During the planning process the Company also considers technical and environmental specifications, such as seismic conditions, some limited aspects of life and fire safety, and proper distribution of internal and external areas.



Going forward, the company will develop and implement a corporate program of internal and external audits for environmental, occupational health and safety (OHS), and fire safety to be applied to all existing assets. For new proposed assets or developments, the company will screen future sites to be leased or acquired. The screening will aim to identify and review potential applicable risks including but not limited to (i) cultural heritage to ensure it will be managed according to Brazilian requirements, and (ii) life and fire safety and structural conditions so that they can be addressed properly according to local and IFC requirements.



-Social and Environmental Management Program: Although the company has assigned staff at each operating unit to be responsible for workplace safety conditions, the company does not yet have a formal internal environmental, health and safety (EHS) policy. Going forward, the company will develop and implement a corporate EHS policy and management program applicable to all installations, complementing existing aspects with additional ones in order to comply with IFC requirements. New elements to be covered include but are not limited to (i) screening and assessment of new facilities; (ii) efficient use of resources such as energy and water; (iii) solid waste management; (iv) life and fire safety; (v) potable water quality monitoring; and (vi) any other aspects identified in the risk identification phase of the management system.



-Organizational Capacity: Responsibilities for social and environmental aspects are shared among several positions throughout the company. During the operative stage the facility services manager ensures proper maintenance, housekeeping and efficient use of resources. The company has one OHS technician in UNIBH, one in UNA and another in UNIMONTE who ensure local compliance through proper application and operation of fire safety procedures, including emergency response plans. In addition there is a Human Resources Manager who coordinates all the HR p
rograms at corporate level and HR coordinators in all the campuses. Environmental and Social responsibilities are shared with the local coordinator at each campus, HR department and the corporative group of sustainability.



In order to effectively manage the EHS aspects of its operations, the company will complement the existing organizational capacity with someone centrally responsible at the corporate level. This corporate level EHS manager will assume responsibility for structuring an EHS group (taking into account persons already engaged in this activities as applicable) and developing a management system, management programs, training, community engagement, monitoring and reporting, and ensure compliance with local regulatory and IFC requirements.



-Training: Training is provided to all the employees. There is an initial institutional training (induction) for all new employees and thereafter training is provided based on specific needs and skills required for the job. Regarding environmental and social aspects the company has provided training on accident prevention, use of Personal Protective Equipment (PPE), first aid, and emergency response. The company is developing a training plan and will include environmental protection and other relevant OHS elements.



-Monitoring and Reporting: The Company has began to publish the results of some aspects of its environmental and social monitoring activities according to the Global Compact Report format. The company has created a report combined with of the reporting indicators of the Earth Charter Principles and Global Report Institute (GRI). However, the content of relevant environmental and social aspects in this report is still limited because the company does not yet monitor environmental and social performance uniformly across its operations. Going forward, and as part of its development of an EHS management program, the company will monitor relevant aspects of its operations and include the results of these monitoring activities in future annual reports.

-Human Resource Policy and Management: Anima Group has 3,643 employees, of which approximately 49 % are female. Approximately 50% of the employees are professional level (professors and instructors) and 50 % are office administrative staff. The workforce is concentrated in the company’s headquarters in Belo Horizonte with approximately 3,200 workers. The company has an ethics code applicable to all the employees, which includes statements regarding non-discrimination, equal opportunities and protection of the workforce. In addition the Human Resources (HR) department has documented procedures including, hiring, selection, disciplinary measures, transfer of employees, payment of benefits, among others. The company will create and implement a formal internal grievance mechanism for the employees to raise reasonable concerns, consistent with IFC’s Performance Standard 2. The grievance mechanism will be communicated to all the employees and for new employees it will be made available at the time of hire.



-Terms of Employment and Workers Organizations: Conditions of employment are defined in the contracts Anima Group signs with the employees and in the list of benefits, both of which are communicated to the employees during induction. Anima Group has signed collective agreements with labor unions for teachers and administrative employees in the campuses of Belo Horizonte and Santos. Collective agreements further define the benefits and conditions of employment.



Benefits provided to the employees include those entitled by law, in addition to grants for education in the courses offered by Anima Group. The company facilitates the access to health care plan, dental services, pharmacy discounts and transportation subsidies. Benefits are communicated to the employees during induction.



-Non discrimination and equal opportunity: Anima Group has well defined statements regarding non discrimination and equal opportunity. Fair treatment is observed in the company, including processes of hiring, promotion and termination of employment. Anima Group has a well defined selection process, an annual performance assessment and leadership programs to promote personnel with defined skills.



-Protection of the Workforce: Anima Group complies with local HR regulations , all the employees are paid at least the legal minimum salary. The minimum age of workers is 14 years, but under a national training program (Young Learners) part-time cooperation with technical schools. Underage workers are not allowed to handle or work with dangerous materials or activities. For other workers, the minimum age is 18 years. The company has the Internal Commission for Accident Prevention (CIPA) in its operational area.



-Retrenchment: The Company’s workforce has increased over the last years and although it fluctuates based on the courses offered per academic cycle, it is expected to keep growing. Retrenchment is not expected from this project. If Anima Group becomes responsi
ble for retrenchment activities it will conduct them in a manner which complies with IFC requirements including development of retrenchment plans which are based on the principle of non-discrimination, reflecting consultation with employees, their organizations and, where appropriate, the government.



-Occupational Health and Safety: The Company applies certain aspects of Brazilian requirements through, for example, implementation of a generic mandatory Risk Prevention Plan (PPRA) and Health Monitoring Program (PCMSO) for its campuses, providing training and Personal Protective Equipment (PPE) to those employees working in the laboratories. Anima Group handles small amounts of chemicals and biological material for practical training of the students. Use of such products is limited to students’ practices, held few times during the academic period. The company provides PPE and training to the employees. Anima Group implements a Lab safety program. However, IFC found evidence of the need for the company to develop and implement a formal, more rigorous, occupational health and safety management program in order to comply with local law and IFC requirements.



Going forward, the company will develop and implement an OHS management program to effectively address the risks of its operations (mainly the operation of laboratories and maintenance of facilities). Examples of areas requiring improvements to meet these requirements include: need for a contractor OHS management program; need for hazardous materials (including gas cylinders) storage areas; review of electrical installations safety (i.e. panels, circuit breakers, etc); need of a formal lock-out-tag-out (LOTO) program during electrical repairs; hazard signage program; work-in-heights program and use of ladders and scaffolds; ergonomics management; and accident and incident reporting and recording (including an accident and incident investigation and follow up program).

-Resource Conservation and Energy Efficiency: Anima Group has a strong orientation to optimize the use of the resources including electricity and water. Classrooms maintain the lights off when vacant. When feasible the design of new buildings has incorporated the use of natural lighting to reduce the use of electricity. The company will continue to identify opportunities to conserve resources in its operations. The total energy consumption at the Anima Group in 2012 was 7,362,066.87 kWh and the energy usage was 47.87 kWh / m2. The total amount of water used in 2012 was around 100,000 m3, that means 2.50 m3/person.



- Solid Waste Management: Waste generated in the campuses includes mainly domestic type of waste, office waste and small amounts of hazardous waste from the labs. Anima Group has initiated in some of the buildings separation and recycling of waste. Adequate segregation was observed on the sites where containers were provided. The company will expand the recycling program to all the campuses and will identify mechanisms to reduce the amount of waste generated, as well as reuse, recycle and dispose properly the waste. The program should include hazardous waste generated throughout the facilities, including those from the labs. The company contracts the collection and disposal of waste with the municipality and with authorized companies.



-Hazardous Materials: The use of hazardous materials is restricted to the laboratories where small amounts of reactants, solvents, preservation agents and biological agars, among others, are used. Anima Group will update its lab safety and solid waste management programs with procedures for the handling, storage and disposal of hazardous materials.



-Liquid effluents: Liquid effluents, mainly sanitary and food service effluents, are in most cases discharged to the municipal sewage systems. Anima Group complies with the conditions defined in the licenses, including the collection of the sludge by authorized companies. Anima Group handles small amounts of chemicals and biological material for practical training of the students. Hazardous substances from the chemical laboratories are collected and pretreated by the coordinator of the laboratories then disposed of in the municipal sewage system. Hazardous substances from the biological laboratories is treated separately which and collected by a certified company due to the pathological risk of discharge via laboratory effluents.



-Greenhouse Gas Emissions: Greenhouse emissions of the project are associated mainly with electricity consumption but also with the use of fuels for daily operations such as a small fleet of company owned vehicles and emergency generators which are operated irregularly. The Greenhouse emissions of the current operations do not exceed 25,000 tonnes per annum CO2 equivalent.

-Life and Fire Safety: The Company follows local building safety requirements during the renovation and operation of its facilities. The buildings have the required firefighter’s licenses (AVCB), but there is still a need for improved management to ensure compliance with local life and fire safety requirements across all of its operations. Therefore, going forward new buildings or those currently scheduled for renovation will be designed, constructed and operated in full compliance with the local life safety code and an internationally accepted life and fire safety (L&FS) standard. The design shall include assessment of fire prevention; means of egress; detection and alarm system; compartmentation; fire suppression and control; emergency response plans; and operation and maintenance as described in the World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines with the Life and Fire Safety requirements of the WBG EHS General Guideline.



The company will also conduct an audit of existing facilities to identify any deficiencies in life and fire safety (L&FS) elements such as fire detection and alarm systems, basic fire suppression systems, emergency exits and emergency signage. Where required, corrective measures will be implemented according to a timetable to be agreed with IFC.



-Emergency Preparedness and Response: Anima Group provides basic training on first aid and emergency response at some of its facilities; however, a detailed emergency response plan will be developed by the company to cover all the facilities. Anima Group will perform and document annual fire drills (include students, visitors and community) and fire safety inspections as required by local law.



-Potable water: The Company obtains potable water from various sources which include private providers, and the municipality. Anima Group has not verified local compliance of the quality and potability of the water supplied to the facilities from the municipality and private companies. Cafeteria services are provided by third parties in the facilities of the company. Anima Group performs an initial assessment of the capacity of such vendors to ensure that they comply with local health requirements.



-Security Personnel: Anima Group has security guards contracted directly by the company. Such guards are not armed and have received training on crisis management.

Anima Group follows local requirements regarding protection of cultural heritage. When applicable the company has modified buildings and has retained facades or structural parts as required by local legislation.

Anima Group has a strong community focus using their own facilities, such as alphabetization of local communities, legal counseling, and physical therapy, creation of local libraries and provision of technical assistance to small enterprises. The Anima Group , in alliance with local partners, created the Oasis Anima with the purpose of integrating students, employees and the society to transform the reality and the life of the residents of some of the communities in which it operates. In 2012, Anima Oasis made 10 community dreams in two different states come true using local resources and talents, involving about 3,000 volunteers. Other projects with local partners include, for example: Green Drinks; Pic Nic of the sustainability; Espaço melhor idade: that consists of a physiotherapeutic environment to promote health to people older than 45 years old.
Such initiatives are recognized locally and frequently cited in press releases.

The company has a process of receiving complaints from neighbors at the reception of each campus, and the complaints are sent to the facilities services. Going forward the company will develop and maintain a procedure to respond to these external complaints according to IFC’s Performance Standard 1.

Broad Community Support is not applicable for this project

Action	Due Date
1.       The company will develop and implement a corporate Environmental and Social Management System (ESMS) policy and management system applicable to all installations, complementing existing aspects with additional ones in order to comply with IFC requirements, as described in the ESRS. Deliverables shall be:
(i) Evidence of hiring a consultant acceptable to IFC to develop and implement a corporate ESMS.	Feb-14
(ii) Identification of key environmental aspects and occupational risks	Jun-14
(iii) Draft documentation of ESMP (plans and procedures)	Dec -14
(iv) Monitoring and reporting system created with defined indicators.	Mar -15
2.       The company will develop and implement a corporate program of internal and external audits for environmental, occupational health and safety (OHS), and fire safety aspects to be applied to all existing assets, as described in the ESRS. Deliverables shall be:
(i) Screening criteria for both newly constructed facilities and leased facilities.	Mar 14
(ii) Evidence of implementation of the screening framework	Oct-14
3.       The company will complement the existing organizational capacity with someone centrally responsible at the corporate level, as described in the ESRS. Deliverables shall be:
(i) Provide a copy of the organizational chart of Anima EHS department.	Dec-13
(ii) Provide a copy of the terms of employment of the new EHS Manager	Jan-14
4.       The company will develop and implement an OHS management program to effectively address the risks of its operations (mainly the operation of laboratories and maintenance of facilities), as described in the ESRS. Deliverable shall be:
(i) Identification of key occupational risks	Jun 14
(ii) Draft documentation of OHS management program (plans and procedures)	Nov-14
(iii) Monitoring and reporting system created with defined indicators.	Jan 15
5. Life and Fire Safety :
Life and Fire Safety System Design:
For all buildings scheduled for construction, engage professional services of a qualified Life and Fire Safety Engineer acceptable to IFC to prepare Master Plan (engineering design) and post construction inspections to verify that the system was installed as designed. Life and fire safety design shall be responsive to one international life safety code and the Brazilian life safety code. The design shall comply with the Life and Fire Safety requirements of the IFC General EHS Guideline.
Deliverable: Signed contract for professional services to perform the Life and Fire Safety system design and post construction inspection and certification of as-built system.	Prior to start of construction activities in all projects
Certification of Life and Fire Safety System Design :
Provide third party certification by a qualified professional acceptable to IFC that the design and construction of life and fire safety systems for new constructions or renovations comply with the specifics of IFC life and fire safety guidelines.
Deliveable: Certification prepared and submitted to IFC by the qualified professional engaged as described above.	Prior to start of construction activities in all projects
Certification of Life and Fire Safety System Construction :
A qualified professional acceptable to IFC shall provide a professional certification affirming that facility construction faithfully incorporates all elements of the life and fire safety design previously certified to IFC.
Deliverable: Certification prepared and submitted to IFC by the qualified professional as described above.	On completion of construction activities in all projects
6. The company will expand the recycling program to all the campuses and will identify mechanisms to reduce the amount of waste generated, as well as reuse, recycle and dispose properly the waste. The program should include hazardous waste generated throughout the facilities including those from the labs. Deliverables shall be:
(i) Solid waste register and implementation procedures developed.	Mar 14
(ii) Solid waste program implemented: records by site and type of waste.	Aug 14
7. Review, develop and implement emergency preparedness and response plans for all the facilities. The plans should include at least evacuation routes, training, fire drills, and use of emergency equipment. The plans should be communicated to employees, students, and community.
Emergency preparedness and response plans/procedures. (a)     25% of facilities: (b)     100% of the total facilities:	(a) May 2014 (b) Nov 14
Where required, in the existing facilities, the company will enhance L&FS elements such as detection mechanisms, alarm systems, fire suppression systems, and emergency signage.
2. Training and fire drills records, as well as photographic evidence of implementation of the plans.	Jan 15
3. Report of updates of life and fire safety mechanisms in the existing facilities.	Feb 15
8. The company will create and complement a formal internal and external grievance mechanisms :
i)         For the employees to raise reasonable concerns, consistent with IFC’s Performance Standard 2. The grievance mechanism will be communicated to all the employees and for new employees it will be made available at the time of hire.
ii)       For the neighbors, particularly with regards to receiving complaints, consistent with IFC’s Performance Standard 1.
Deliverables shall be:
(i) Grievance process in form and content acceptable to IFC.	Aug 14
(ii) Evidence of disclosure to company employees and its neighbors.	Oct 14