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 is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific and reversible environmental and social impacts may result, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Key issues reviewed were: environmental and social management system; labor and working conditions; construction impacts particularly in relation to waste management and occupational health and safety (OHS); waste water and solid waste management; life and fire safety and emergency preparedness and response; water and energy use and efficiency; and community engagement.

The 7-hectare greenfield campus site consisted of two land plots acquired by the sponsor from two individual owners in early 2014, who in turn had acquired these plots from other individuals in 2004 and 2006 respectively. These land plots have been vacant since the original transactions in 2004 and 2006. All transactions were of a willing-buyer-willing-seller nature. Based on the above there are no known concerns with land issues and PS5 is not triggered by this project.

There is no known presence of indigenous people communities at or close to the campus site, and project activities are not expected to have an impact on local biodiversity or local cultural heritage. Based on the above, PS6, PS7 and PS8 are not triggered by this project.

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.

The sponsor put into effect its corporate level Environment, Social, and Community Policy in May 2005, which includes a mission statement, company positions in relation to E&S matters, and an exclusion list of investee activities which AB will not finance as a matter of principle. Also put into place and formally endorsed as company policies were the following documents: Acleda Bank procedures for E&S Due Diligence; and E&S Operating Manual. Employees of AB use these documents mainly during the pre-loan-approval due diligence stage, as a means to screen and categorize potential loan application clients in terms of E&S risks, and as a basis to formulate corrective action plans required of clients. Project-level risk management programs are developed around corrective action plans. Staff is trained regularly to become familiar with the above documents and company requirements on E&S matters.



The 1999 national Sub-decree on Environmental Impact Assessment (EIA) Process contains a list of industries requiring an initial EIA and subsequent detailed EIA as needed, and the list specifies that projects involving buildings with a height equal to or exceeding 12 meters or with a floor area equal to or exceeding 8000 square meters be required to undertake an EIA. As of June 2014, an EIA law was in draft form with public consultation sessions ongoing to gather public opinions on the proposed law.



Once a first draft of the project’s detailed schematic design is available, the company will ascertain with the authorities whether the project would need to undertake an initial EIA and EIA as per the Sub-decree or as per the EIA law if this were subsequently passed into law at that time. If an EIA is deemed to not be legally required, the company will instead conduct on its own (or with help from a qualified external consultant as needed) an appropriately-scaled process of environmental and social risk and impact identification, and develop an E&S management program to address identified risks and impacts of the project.



The assistant vice president of personnel and administration at ATC is responsible for monitoring electricity and water consumption levels and other defined E&S parameters (e.g. mobile vehicle gasoline usage) at the ATC training center, and also for on-site safety and security. Such information is captured in a monthly monitoring report. When project construction commences, representatives from various AB technical departments (e.g. engineering) will form a project management office to be responsible for all construction related activities and contractor oversight, and which will report progress to AB senior management. Under the project management office, the company plans to set up a control commission to supervise contractor activities to ensure that E&S terms to be built into the contractor agreement are duly fulfilled.



The project is currently at the pre-detailed-design stage – the company indicates that it will develop an appropr
iately scaled E&S management system (ESMS) in due course, which will consist of: i) the company E&S policy (which can be adapted based on the sponsor’s overall corporate level E&S policy); ii) appropriate Key Performance Indicators (KPI) and targets; iii) standard operating procedures (SOP) on life and fire safety, emergency preparedness and response; campus safety and security; labor and working conditions; occupational health and safety; contractor E&S management including management of construction related impacts and worker age screening to ensure there is no child labor practice; resource efficiency; waste management; food safety; and stakeholder engagement and external communication; iv) a monitoring and reporting system whereby performance data (according to aforementioned KPI targets) will be regularly reported to senior management; and iv) assigned personnel and roles and responsibilities. Refer to the E&S Action Plan (ESAP) for details.

ATC has a workforce of 92 direct, full-time employees, of which female workers make up about 45%. The turnover rate in the past 24 months was about 1%. The company has human resource policies and procedures in place with terms of employment (e.g. working hours; leave arrangement) of employees formalized into employment contracts in accordance with national labor requirements. Hiring and employment practices recognize the principles of non-discrimination and equal opportunity. The company is not anticipating any future retrenchment. IFC’s review did not find any signs of the use of child or forced labor – as per PS1 the company will require construction contractors to implement worker age screening, and it will regularly review those screening results, to ensure there is no child labor practice.



Most ATC staff members are members of a labor union and joining or not joining is a voluntary choice. The internal auditing department at AB is responsible for receiving and addressing feedback from staff members, and there is a 24-hour telephone hotline for receiving any concerns or grievances from external or internal customers. Various staff communication channels and grievance mechanisms are in place including weekly and monthly one-on-one and group staff meetings and bulletin boards, and they are consistent with PS2 requirements.



At the AB extension building construction site, regular worker safety meetings and direct communications with contractor team leaders are the key means of worker communications. The sponsor engages a qualified construction contractor entity and the contractor agreement includes labor related clauses on labor and working conditions. Daily and weekly site safety inspection reports are prepared, and tool box meeting records were available on site. The same arrangement will be adopted for contractor oversight before construction for this project commences. ATC has internal procedures on safe driving, the content of which is regularly communicated to all staff.



At the extension building construction site, workers attend regular work safety training sessions. IFC noted that workers on site were using personal protective equipment (e.g. helmets, harnesses, work boots), and the site was organized and well maintained, with safety signage clearly displayed throughout. Previously there have been a number of construction worker fatalities and injuries at the site related to falling from heights and electrocutions [Sponsor to re-confirm this]. Failure by the concerned workers to adhere to communicated safety requirements (e.g. workers choosing not to wear safety harnesses despite being instructed to do so) was cited as the key cause of these occupational health and safety events. ATC will as part of its ESMS development efforts (refer to PS1), develop a detailed set of OHS SOPs; and record detailed OHS performance data during the construction phase of this project, including leading indicators such as near misses (i.e. OHS accide
nts which almost materialize), and build relevant monitoring requirements into the construction contractor agreement. Refer to the ESAP for details.

Pollution Prevention:



It is anticipated that sanitary waste water will be the main pollutant arising from the campus operation. The project has completed a master plan, and the detailed schematic design, expected to be available about 12 months from now, will include installation of an on-site waste water treatment plant as well as a parallel but separate storm water discharge system. Waste water treated on site will be discharged directly to surface water, and as such the company will ensure that the outgoing effluent meets World Bank Group (WBG) General Environmental Health and Safety (EHS) Guideline standards. The campus is not expected to have any boilers installed [Sponsor to re-confirm this], but this will be re-confirmed when detailed schematic designs are drawn up. If any boiler exceeding a capacity of 3MWth is to be installed, the company will ensure that appropriate air emission treatment measures and facilities (including those applied to backup generators installed on site) are included so that national and WBG General EHS Guideline limits are not exceeded. The project will also ensure that any hazardous wastes and other non-hazardous solid wastes (e.g. sludge build-up at septic tanks; kitchen food wastes) generated at the campus facilities are handled by licensed third party entities and disposed of as per environmental permitting conditions.



Resource Efficiency and Greenhouse Gas Emissions:



Together, the annual grid electricity consumption of the project is expected to be 280,000 kWh, while the total water consumption is estimated at 4,600 cubic meters. The university campus expects to obtain its water supply from the municipal water supply company – the company will ensure that it meets national requirements for potable water quality. The company will also explore measures such as using building materials with high insulating factors and installing water efficient urinals to achieve resource savings. Measures which are considered technically and financially feasible will be incorporated into the detailed schematic design of the project. Once the campus is operational, the company will continue to monitor water and energy usage on a monthly basis and look for opportunities to achieve savings as it currently does. The company has also committed to the installation of water and electricity sub-meters at key locations of various buildings in order to more accurately monitor location specific usage, and this will be incorporated into the detailed design.



The annual total greenhouse gas (GHG) emission of the project is estimated at 800 ton CO2-equivalent, attributable to the consumption of grid electricity and operation of chillers.

The greenfield campus site is located in the outer perimeter of Phnom Penh city in an urban area of medium to high population density, whereby there are several standalone residential houses and small shops near the planned front entrance of the university, as well as a large gated residential complex about 50 meters away from another side of the site.



In-house security guards will be employed to patrol the project site during construction and operation. There have been no past security incidents at the current ATC center and security guards at the existing ATC center are briefed on rules of conduct and their work practices are monitored by company personnel.



There have been no known fire incidents at sponsor and company facilities in the past [Sponsor to re-confirm this]. A Phnom Penh based consulting firm was commissioned by the Sponsor to develop fire detection and fire-fighting system and network specifications for the AB extension building and was incorporated into the detailed design of the building. The specification document references a number of international standards such as U.S. National Fire Protection Association (NFPA) Life Safety Code and the British Standard.



The company will develop a life and fire safety (LFS) Master Plan which will: (i) identify major fire risks associated with the project, applicable local and international fire codes and national regulatory requirements; (ii) address the following LFS elements i.e. fire prevention; means of egress; detection and alarm systems; compartmentation; fire suppression and control; emergency and response plan; and operation and maintenance; (iii) list a set of LFS objectives and LFS related performance indicators of the project; (iv) include a narrative document describing design and operational measures to be adopted to achieve the LFS objectives and indicators, and to address the abovementioned LFS elements and identified LFS risks; and (v) include relevant floor plans, architectural drawings, and equipment and facility specifications.



Once developed, the LFS Master Plan will be reviewed by a qualified LFS engineer or entity who has demonstrated experience working with an internationally recognized fire code – to verify that its content is consistent with the requirements of local LFS regulatory requirements as well as one of the internationally recognized LFS codes (e.g. NFPA) as specified in the WBG General EHS Guideline.



Within three months of completion of project construction, the company will commission a post-construction completion audit by similarly experienced LFS professional(s), to verify that buildings have been constructed in accordance with the LFS Master Plan.



The company will also develop and implement LFS SOPs (refer to PS1), and implement an appropriate system to regularly and proactively monitor potential LFS risks at the campus, as well as to train campus users on LFS and emergency preparedness through fire drills and other relevant activiti
es. Refer to the ESAP for details.



The company will ensure that the campus and building detailed design fully incorporates the principles of universal access i.e. ensuring safe and open accessibility and egress for persons with disabilities.

Through its banking activities and particularly microfinance lending, the sponsor extensively and positively engages with a large number of urban and rural community members throughout Cambodia. The existing ATC training center activities pose limited impacts on local residents. IFC’s review finds that the general view of households near the campus site towards the project is positive with an expectation of job and small business opportunities that may arise because of it, and there are no notable concerns. At an appropriate time in the coming months leading up to construction activities, the company will hold discussions with households living near the campus site boundary to understand their perspectives towards the proposed project and any concerns they may have (e.g. construction related), and take steps to address concerns if any. Once the campus is operational, the security pouch and information counter at the front entrance will be the key local public interfaces to receive external communications including grievances if any from the public.

For more details on the project, please contact:

Mr. Chhan Ponloeu
President and CEO
ACLEDA Training Center Ltd.
Tel: +855 (0)23 999944
Fax: +855 (0)23 999979
http://www.acledabank.com.kh

ATC will place a bilingual (English and Khmer) newspaper advertisement in a major local newspaper in Phnom Penh. This will inform the public that results from IFC’s E&S due diligence are available for access. It will also post the bilingual language ESRS and ESAP at conspicuous locations outside the main entrance of its current training center and the campus site, and the same at its corporate website (http://www.acledabank.com.kh) or place a web-link to IFC’s disclosed ESRS and ESAP.

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
The company will develop an appropriately scaled E&S management system (ESMS) which will consist of: i) the company E&S policy (which can be adapted based on the sponsor’s E&S policy); ii) appropriate Key Performance Indicators (KPI) and targets; iii) standard operating procedures (SOP) on life and fire safety, emergency preparedness and response; campus safety and security; labor and working conditions; occupational health and safety; contractor E&S management including management of construction related impacts and worker age screening to ensure there is no child labor practice (with the company regularly reviewing screening results); resource efficiency; waste management; and stakeholder engagement and external communication; iv) a monitoring and reporting system whereby performance data (according to aforementioned KPI targets) will be regularly reported to senior management; and iv) assigned personnel and roles and responsibilities.	10/31/2015
Where an EIA is deemed to not be legally required by national regulations, the company will instead conduct on its own (or with help from a qualified external consultant as needed) an appropriately-scaled process of environmental and social risk and impact identification, and develop an E&S management program to address identified risks and impacts of the project.	12/31/2015
Develop a SOP on OHS performance data monitoring for the construction phase of this project, including leading indicators such as "near misses" (i.e. accidents that almost happened), and build relevant monitoring requirements into the construction contractor agreement.	10/31/2015
Verify whether boiler installation and use will be included as part of the project detailed schematic design.	10/31/2015
The company will develop a life and fire safety (LFS) Master Plan which will: (i) identify major fire risks associated with the project, applicable local and international fire codes and national regulatory requirements; (ii) address the following LFS elements i.e. fire prevention; means of egress; detection and alarm systems; compartmentation; fire suppression and control; emergency and response plan; and operation and maintenance; (iii) list a set of LFS objectives and LFS related performance indicators of the project; (iv) include a narrative document describing design and operational measures to be adopted to achieve the LFS objectives and indicators, and to address the abovementioned LFS elements and identified LFS risks; and (v) include relevant floor plans, architectural drawings, and equipment and facility specifications. Once developed, the LFS Master Plan will be reviewed by a qualified LFS engineer or entity who has demonstrated experience working with an internationally recognized fire code – to verify that its content is consistent with the requirements of local LFS regulatory requirements as well as one of the internationally recognized LFS codes (e.g. NFPA) as specified in the World Bank Group General Environmental Health & Safety Guideline.	06/30/2015
The company will commission a post-construction completion audit by similarly experienced LFS professional(s), to verify that buildings have been constructed in accordance with the LFS Master Plan.	06/30/2016
Implement an appropriate system to regularly and proactively monitor potential LFS risks at the campus, as well as to train campus users on LFS and emergency preparedness through fire drills and other relevant activities.	06/30/2016
The company will ensure that the campus and building detailed design fully incorporates the principles of universal access i.e. ensuring safe and open accessibility and egress for persons with disabilities.	10/31/2015