While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category-B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Performance Standards 1-2 are those expected to apply for the proposed project. Principal concerns relate to the following: (1) how the sponsor has developed (or proposes to develop) an overarching system and management approach for analyzing, mitigating, and monitoring E&S performance, including stakeholder engagement, life and fire safety measures, and the creation of an appropriate grievance mechanism, and (2) labor standards, worker rights, and relevant occupational health and safety (OHS) standards for the company’s workforce.

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.

Policy and Identification of Risks and Impacts



As a professional services company with minimal negative environmental and social impacts, AfferoLab does not currently have an overarching policy with regard to sustainability issues. AfferoLab operates in a relatively embryonic market for corporate training and e-learning solutions, where there is no government regulation or oversight (with the exception of labor practices, which are described below under PS2). The company has also not engaged in land acquisition or construction of buildings or facilities that might require the review and approval of local environmental or other regulatory authorities. As a result, AfferoLab is not in the practice of systematically identifying and managing risks and impacts, nor has it defined a general approach to such issues. Nonetheless, the company does have elements in place that could serve to inform a policy and risk management approach, including a clearly-demonstrated commitment to employee satisfaction.



In accordance with the ESAP, AfferoLab will therefore review the IFC Performance Standards, the World Bank Group''s General Environmental, Health, and Safety (EHS) Guidelines, and other relevant guidance, develop a comprehensive environmental and social policy to be approved at the board level, and communicate it widely throughout the organization and to key stakeholders as a condition for IFC’s first disbursement.



Management Programs



As the fields of corporate training, personnel development, and e-learning are all relatively young and largely unregulated, there are no enterprise-wide quality certification programs that apply directly to AfferoLab''s sector. Nonetheless, through one of the precursor companies that was eventually merged into AfferoLab, the company has a certification under ISO 9001:2008 (products and services). This certification is currently being updated for the new company as a whole, and the IFC was able to review the third-party certification report. In addition, given its e-learning activities and use of informational technology in its products and services, AfferoLab is seeking certification from BCS, The Chartered Institute for IT. The company also has an internal quality control and corporate performance system based on Success Factors, a SAP program. While AfferoLab does not have an environmental and social management system as such, it does have basic internal management tools for tracking and managing risks and impacts related facilities management, emergency planning, and life and fire safety. (Human resources management is discussed under PS2.)



Organizational Capacity and Competency



AfferoLab does not have a specific company official or team responsible for environmental and social management. Rather, these responsibilities are divided primarily between the CFO/chief administrator (responsible for facilities management and contracting third-party service providers, among other duties) and the hu
man resources department (known as "People"). Personnel occupying these roles are highly-experienced, competent professionals. Under the ESAP, AfferoLab will designate a senior company official (and if appropriate, a committee at the executive and/or board level) to serve as the focal point and principal coordinator of its EHS functions.



Training



As a company dedicated to providing its clients with state-of-the-art solutions for managing the learning needs and training their personnel, AfferoLab has a strong commitment to the training and professional development of its own employees. Part of its decision to locate a new facility in Juiz de Fora was to take advantage of proximity to a number of universities with well-regarded programs in technical areas important to AfferoLab''s business success. The company is in fact discussing with such programs the possibility of establishing a stronger focus on training that combines instructional design, graphic design, and IT-based learning solutions, hitherto separate fields in Brazil. At AfferoLab, there is a structured onboarding, training, and mentoring program, as described below under PS2. IFC noted that within such a dynamic and still-growing organization staff who performed well in a junior or mid-level role have been promoted or reassigned at more senior levels and received support and coaching in these roles. This contributes to high retention levels, a strong internal corporate culture, and reported high levels of job satisfaction. With regard to E&S issues, AfferoLab currently has no formal staff training, with the exception of training in emergency preparedness that a number of staff have undergone as part of response readiness required by local fire departments (see following item).



Emergency Preparedness and Response (EPR)



Under Brazil''s state-level fire codes, buildings are required to undergo a fire safety certification process that yields a safety certificate known as an Auto de Vistoria do Corpo de Bombeiros (AVCB) or equivalent. In addition to checking structural aspects related to life and fire safety, the certification process involves the establishment of an emergency preparedness plan and an emergency response team (known as brigadistas) for each building. As a commercial tenant in buildings owned by others, AfferoLab has designated staff and developed such plans at the building level (for example in São Paulo and Juiz de Fora, where multiple tenants occupy the same building) or on its own (in the case of Rio, where it is the sole occupant of the rented building). For its two principal office locations, evacuation plans have been developed, brigadistas have been trained, and emergency simulations have been carried out. AVCBs have either been issued or are being processed for São Paulo and Juiz de Fora. In the case of Rio, the local fire department required some modifications in the plans for their offices, and a certificate has been requested but not yet form
ally approved.



Under the ESAP, AfferoLab will provide the IFC with a plan for ensuring that the building owners or operators from which the company rents office and training space comply fully with operational requirements to address life and fire safety (L&FS). This plan should detail, office by office, (1) what steps AfferoLab will take to ensure its leases have appropriate contractual requirements on L&FS from an operational perspective (e.g., testing and maintenance of systems and training of staff in fire and emergency response measures), (2) how it will request regular reports from building owners or operators with respect to system testing, maintenance, and inspection (a technical representative of AfferoLab should always witness system tests upon commissioning of a new building and at regular intervals thereafter, together with building owners or operators), and (3) how it will monitor that building staff (including any AfferoLab participants in brigadas) are being trained regularly and appropriately on fire safety and emergency response.



Monitoring and Review



AfferoLab currently has no formal monitoring and review process in place for E&S issues. With the establishment of a sustainability policy and the designation of a senior company official as the coordinator for EHS issues, as per the ESAP, AfferoLab will also institute a monitoring and review system. Ideally, this system will link to and build off of the company''s existing internal reporting and quality control systems.

Working Conditions and Management of Worker Relationship



AfferoLab seeks to provide its personnel with attractive conditions of employment and a positive workplace environment in light of Brazilian legislative requirements, a highly competitive labor market, and the company''s own internal culture and corporate values. Terms of employment and working conditions are spelled out clearly in employment contracts and the collective bargaining agreements to which AfferoLab is subject. In addition, the company seeks to offer its personnel further benefits, such as employer-paid private health and dental plans, access to an attractive life insurance plan, and support for childcare (none of which are formal requirements under Brazilian legislation or collective bargaining agreements). Given the merger of the two companies to create AfferoLab and the competitive nature of Brazil''s labor market, the company has hired an external consultant to benchmark salaries against comparable employers and advise it on establishing a transparent, comprehensive pay scale so that salaries for similar jobs are fully equivalent. One area where the company is seeking to improve its labor practices is to move approximately 50 full-time employees currently working on consultant contracts onto direct-hire contracts. The company intends to develop an action plan in the coming months for doing so.



The company did not report any significant cases of investigations or lawsuits by the Public Prosecutor for labor issues. Relatively minor labor grievances were either being settled amicably with the complainants or being resolved through Brazil''s labor court system. AfferoLab currently has multiple internal mechanisms for employees to raise issues, questions, or complaints, including raising such with supervisors, directly with the employee''s contact in the HR department via a portal on the intranet (called "Abertura de Chamada"), or through an email to the HR department more generally. There is currently no confidential means for lodging a more sensitive complaint where a senior manager or an employee''s direct supervisor is alleged to be implicated. Under the ESAP, AfferoLab will develop an appropriate, independent channel for personnel, including third-party workers, to raise employment-related complaints within the company and any subsidiary or joint venture where it has management control.



Non-Discrimination and Equal Opportunity



AfferoLab has well-defined statements regarding non-discrimination and equal opportunity. As a company focused on helping clients better manage and develop their own workforces, AfferoLab is developing well-structured policies, procedures, and processes for hiring, promotion and termination of employment, based on Brazilian legislation and the best practices of its two precursor companies. It is also putting into place a well-defined selection process, an annual performance assessment, and leadership programs to promote personnel wi
th defined skills.



Protecting the Workforce



AfferoLab systematically applies all Brazilian legislation and regulations on labor standards, including respect for labor rights, minimum age requirements, and prohibitions against forced labor. Conditions of employment are defined in the contracts that AfferoLab signs with its employees and in the list of benefits, both of which are communicated to the employees during induction. Under Brazilian labor laws, virtually all workers are required to associate with unions, and AfferoLab''s employees benefit from the existence of collective bargaining agreements in their sectors. The company in no way restricts union membership, it abides by the terms of collective bargaining agreements, and it respects labor rights. The company does occasionally employ young workers as part of the government-mandated Jovem Aprendiz (Young Apprentice) program and currently has five junior people under this program, which conforms with all official requirements include worker protections.



Occupational Health and Safety



Due to the size of the company''s workforce, AfferoLab is subject to a number of worker safety regulations (known as the Normas Regulamentadoras, or NRs) mandated by Brazilian law, including NR5 on establishing worker safety committees, NR7 on occupational health check-ups, and NR9 on preventing occupational risks. AfferoLab is currently in the process of putting plans and procedures in place to comply with Brazilian legislative requirements, and it intends to hire a consultant specialized in OHS to advise it and help structure and implement its plans and procedures. During its appraisal the IFC noted that ambient noise levels in one open-plan office appeared high. The company explained that with the expansion of AfferoLab''s space in that building (the company is renting an additional floor), the office space in question would become less congested, and noise levels will improve as a result. In addition, the company was open to exploring other options, such as use of sound-dampening materials or office dividers, to help reduce ambient noise. In addition, the company provides peripherals such as keyboards and laptop stands to help alleviate potential ergonomic problems from constant laptop use by their personnel. Ergonomics should be a clear focus of any formal occupational health program that the company develops, given the nature of much of its work.



Workers Engaged by Third Parties



AfferoLab has contracted third-party companies to carry out certain functions, including visitor reception, cleaning and housekeeping, unarmed guard services, and IT support. The total staff hired by these service providers to support AfferoLab''s activities is approximately 150. As part of its contractual requirements with these companies, AfferoLab receives from these service providers copies of all legally-required payments (social security, etc.) each month so that it can verify their compliance with
Brazilian labor laws. To date, there have been only minor labor complaints registered with the labor courts by third-party workers (claims of non-payment of overtime pay), and they were settled amicably. As part of its implementation of the above-mentioned ESAP item on creating an internal grievance system, AfferoLab will publicize that third-party workers are also able to access this mechanism, in addition to whatever complaint management system their own employers might have.



Supply Chain



As a professional services company, AfferoLab has no supply chain to speak of.

As AfferoLab is not engaged in business activities that require environmental and social impact assessments or environmental licensing, it has not had the need to develop formal modalities for stakeholder engagement. Publication of this ESRS and associated Environmental and Social Action Plan constitutes the client’s first community engagement related to its project plans.

External Communications and Grievance Mechanisms

The company''s primary mechanisms for external communications are staff interaction with clients and its website (http://www.afferolab.com.br/contato). As part of the ESAP, AfferoLab will ensure that the company registers external communications from the public received through their website and has an established procedure for addressing any grievances it might receive.

Rua Bambina, 25
CEP 22251-050 Botafogo
Rio de Janeiro, RJ – Brazil

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Policy: AfferoLab will review the IFC Performance Standards, the World Bank's General Environmental, Health, and Safety (EHS) Guidelines, and other relevant guidance, develop a comprehensive environmental and social policy to be approved at the board level, and communicate it widely throughout the organization and to key stakeholders.	03/31/2015
Organizational Capacity and Competency: AfferoLab will designate a senior company official (and if appropriate, a committee at the executive and/or board level) to serve as the focal point and principal coordinator of its EHS functions.	03/31/2015
Emergency Preparedness and Life and Fire Safety: AfferoLab will prepare a plan for ensuring that the building owners or operators from which the company rents office and training space comply fully with operational requirements to address life and fire safety (L&FS). This plan should detail, office by office, (1) what steps AfferoLab will take to ensure its leases have appropriate contractual requirements on L&FS from an operational perspective (e.g., testing and maintenance of systems and training of staff in fire and emergency response measures), (2) how it will request regular reports from building owners or operators with respect to system testing, maintenance, and inspection (a technical representative of AfferoLab should always witness system tests upon commissioning of a new building and at regular intervals thereafter, together with building owners or operators), and (3) how it will monitor that building staff (including any AfferoLab participants in brigadas) are being trained regularly and appropriately on fire safety and emergency response.	03/31/2015
Worker Grievance Mechanism: AfferoLab will develop an appropriate, independent channel for personnel, including third-party workers, to raise employment-related complaints within the company and any subsidiary or joint venture where it has management control.	07/31/2015
External Grievance Mechanism: AfferoLab will ensure the company registers external communications from the public received through their website and has an established procedure for addressing any grievances it might receive.	07/31/2015