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 Policy on Environmental and Social Sustainability because potential adverse environmental and social risks are limited, reversible and may be readily mitigated.

Key issues associated with the project include: i) the building standards applied to schools, including those related to life and fire safety; ii) labor and working conditions for employees and contract staff, including occupational health and safety during the construction phase; iii) safety and health of student boarders, particularly due to the number to be accommodated; iv) provision of potable water of an adequate quality ; iv) security measures implemented at the schools to ensure the safety of students; and v) food safety and quality.

Merryland acquired the land for the project based upon a willing-buyer willing-seller arrangement, by direct negotiation (no Agents were involved). Kigungu has four (4) different titles, purchased from 4 different entities. Part of it was public land used primarily for grazing and negotiated from the government. The rest was purchased from individual owners that were farming on the land. Katabi has three (3) different titles, purchased from 3 different entities. One was from an individual that had started construction for a primary school, the other was from a company that was using the land for farming, and the third was land from an individual that had initially planned to build a school. The land owners did not know eachother; a fair value for each parcel of land was individually negotiated, and owners vacated of their own accord, with no requirement for resettlement, claims or compensation for loss of livelihood. Thus, PS 5: Land Acquisition and Involuntary Resettlement is not applicable to this project. The new school is sited within a residential area where the land was previously cleared, highly degraded and converted. As such, PS 6: Biodiversity Conservation and Sustainable Management of Living Resources does not apply. Finally, given the areas occupied by the schools, PS 7 Indigenous peoples and PS:8 Cultural Heritage also do not apply.

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 management and compliance

Merryland is typical of many family owned businesses, where growth necessitated rapid organizational expansion without the development of a full range of formal policies and procedures. The school management has been careful to ensure compliance with national legislative requirements and both campuses are operated and managed very well with significant parental involvement;however, formal environmental and social policies and procedures are largely absent, other than a Human Resource (HR) Policy Manual that, among other thingsincorporates health and safetyprocedures to be applied at both campuses.



Kigungu was established first (2001), and an annual environmental audit has been undertaken since then for the facility, following an agreement that was signed between MHS and the National Environmental Management Agency (NEMA) for compliance with the requirements of local legislation, and international standards governing similar facilities. The terms of reference are currently being prepared by the environmental consultant for submission to NEMA, the approval of which is required for conducting an audit for Katabi. All of the necessary permits have been granted for Katabi, which has already been partly constructed. A construction permit has been obtained from Wakiso District Local Government (Entebbe), and the NEMA has issued a permit for the Environmental Impact Assessment (EIA) and wetlands use. Similarly, the Ministry of Education has issued a school license.



Plans are underway to develop an MHS environmental policy. The schools would benefit from the design of a basic Environmental and Social Management System (ESMS), which the Sponsor has agreed to implement, to integrate various environmental and social aspects associated with MHS activities. The ESMS shall cover all operations on both campuses, as defined in the project ESAP. IFC also requires that the ESMS, which is aligned with the requirements of this Performance Standard, must contain an overall policy, management procedures and plans, clear and adequate organizational capacity and competency, and processes for monitoring and review. At both campuses, limited monitoring is presently undertaken in the following areas: a) energy consumption; b) water consumption; c) waste generation (segregation for biodegradable waste, which is used on a farm owned by the school shareholders); d) onsite waste water disposal (septic tanks); and e) use of the lakeshore area (restricted activities to prevent accidental drowning, and dumping of waste at the shoreline). This monitoring program will be formalised as part of the ESMS.



Environmental, Health and Safety (HSE) capacity

The school has a dedicated occupational health, safety and environment (HSE) officer responsible for the management of environmental, health and work safety issues, who doubles as the Examinations Master (subordinated to the School Director).The HSE Officer will need further (formal)
training in order to put more comprehensive policies and procedures in place to comply with IFC’s Performance Standards.The School Director is committed to the formation of an Occupational Safety Health and Environment (SHE) committee for both campuses, to comprise of 2 student representatives from each campus, in addition to the members of the Health Committee. Formal reporting on environmental or health and safety performance will be undertaken by the HSE officer through the various committee members. Though limited, this will ensure transparency of environmental and OHS issues.MHS management intends to report to the Board and stakeholders on HSE on a quarterly basis to improve communication with external parties about current performance and future developments, with reports made publicly available via the internet.



Health & Safety and Emergency Preparedness

Merryland implements a basic emergency response that is practised via drills which are held every term (three times a year). This consists of the sounding of an alarm and evacuation at two assembly points per school. The Life and Fire Safety procedures are rudimentary, and require some elaboration. All fire procedures detailing actions and responsibilities at each stage of an emergency, and some general evacuation response guidelines, must be formulated and implemented as part of the ESRS, and have been agreed as per the ESAP. In addition, a list of emergency numbers relevant to each campus, including the Head Master, police, medical professionals, and closest hospital will be displayed; emergency infrastructure, assembly points, information posters and responsibilities will also be established and communicated.



Merryland has a contract with a Ugandan construction and engineering company, Mabrase Construction Limited, who are responsible for building the schools, along with SM Design (architects) and engineering consultants, who make up the Technical team. The company generally recruits people directly from the community and applies their own Occupational Health and Safety (OHS) requirement during construction, as articulated in a manual, and are conveyed during construction meetings and at induction. This ensures that both new and existing construction employees are trained with OHS skills. Personal Protective Equipment (PPE) will be provided to construction workers and visitors to the site, as appropriate. Merryland will ensure, via its HSE committee that the OHS policies and procedures are integrated into the construction agreements. The committee will monitor the measures implemented by the contractor, and confirm that they are consistent with IFCs Performance Standards, as specified in the ESAP.

Human Resources

Merryland has a Human Resources (HR) function consisting of a manager and two support personnel. The policies, procedures, practices, benefits, and programs under HR are contained within an HR Policy Manual, applicable to all employees working at the schools. These were compiled to meet Ugandan legislative requirements. The HR Policy Manual provides a Human Resource Policy Framework upon which the day-to-day management of staff in the institution is based. The manual provides guidelines and procedures relevant to administrators and supervisors, for performance management of the staff under their authority. The document also clearly stipulates the job performance and behavioral expectations from them by the school administration, and includesa code of conduct. It defines benefits such as annual leave, and explains the terms of conditions of employment; but, an overall HR Policy specifying equal opportunities, non-discrimination, the prohibition of sexual harassment and child labor is absent, although these are inherently part of the statutory requirement. Merryland intends to incorporate this into the HR Policy Manual, as specified in the ESAP.



All employees are issued with contracts which set out the details of their working conditions and terms of employment. There are two types of contract: those for permanent employees on indefinite terms, and others for a fixed term. MHS employs 68 permanent teachers (49 male, 19 female) and 92 contract teachers (50 male, 42 female) at the Kigungu campus; as well as 7 permanent (4 male, 3 female) and 25 contract teachers (13 male, 12 female) at the Katabi campus. Contract teachers are employed for specific subject matter and are short-term appointees; the period of the contract is individually determined and reviewed annually. Merryland does not restrict staff from joining workers’ unions; most MHS employees belong to the Uganda National Teachers Organisation. For recruitment of staff for the schools, applicants are assessed in terms of ability to perform the job and tasks required, and this process is free from discrimination. Where applicable (for example, for food handlers and the nurse), employees are required to undergo a medical examination by a recommended doctor to determine his/her fitness for the appointment. All those recruited for operations are trained in Merryland’s approach, materials and requirements for teaching, and running the school, depending on the position being recruited for. In addition to each employee’s basic salary, the remuneration system provides for allowances, fringe benefits, individualized and group incentives for performance achievement at various levels. These may include: bursaries (for the employee, with obligations to serve for up to 3 years thereafter); educational assistance equivalent to 40% of the tuition fees of one biological child of his/her own choice; medical assistance (50% of medical costs approved for the employee); rental/housing as
sistance if the employee is not accommodated at the school; staff meals; vehicle depreciation allowances for employees with specific duties requiring a vehicle; funeral/wedding assistance, and an entertainment allowance. Thirty days of annual leave are granted to non-teaching staff (teaching staff are on holiday at the same time as student holidays). Other forms of leave are approved as appropriate: study leave, sick leave, maternity leave (2 months paid leave), paternity leave (4 days), and compassionate leave (3 days). Only regular full time employees qualify for retirement benefits from the institution (60% of the basic salary times the years an individual has worked).



Merryland operates an open-door policy, whereby staff can consult with the Director or management at any time. If an employee (or student) has a grievance, they are encouraged to speak with their immediate supervisor, Headmaster and HR, or the school Director. The HR Policy Manual incorporates a grievance procedure, and the grievance form is attached as an Annex within the manual. The form is forwarded to the immediate supervisor and then goes through the administrative hierarchy of the relevant attendant stakeholders. The same methodology is followed once a grievance is received externally (from parents or community members). They are encouraged to report problems / omissions / issues arising from school activities, which are forwarded to the head teachers’ attention and subsequently to the top management / board for action.



The HR Policy Manual and the School Rules describe various offences and associated disciplinary procedures for employees and students, respectively. Issues are referred to a Disciplinary Committee, and procedures are followed in accordance with the labour laws of Uganda.



HIV/Aids Policy

MHS has a particular approach to HIV/Aids, and will support and treat individual employees who are known to have HIV/AIDS with compassion and not differentiate from those who have any other chronic and life threatening diseases. As articulated in the HR Policy Manual, no person shall be dismissed from school employment purely on the grounds of their HIV/AIDS status if they are still productive and capable of making their contribution as any other staff member. The school does not discriminate against qualified individuals with regards to advancement, promotion, training, compensation, discharge or any other terms, conditions, or privileges of employment because they are or are thought to be HIV positive, whether symptomatic or not, and encourages voluntary, informed and confidential counselling and testing (VCT). Employees who are incapacitated from the performance of their duties due to HIV/AIDS or any other chronic diseases shall be granted sick leave to regain their health and to allow recuperation. Normal rules concerning sickness and absence will continue to operate even for those who are HIV positive. The school recognizes that each employee and student has
a right to privacy and commits to ensure that: a) all laws and regulations relating to confidentiality are rigorously adhered to, and b) confidentiality is ensured for all employees'' or student’s medical information, including their HIV status. This policy is communicated to all those who handle staff or student medical information, and provide education in the workplace. Merryland, via its school policies, considers harassment or victimization of an employee (who is, or thought to be, HIV positive) as unacceptable.



In general, besides the requirement for an HR Policy, Merryland meets the requirements of PS2 on working conditions and management of worker relationships.



Occupational Health and Safety

Merryland has a formal but brief Occupational Health and Safety (OHS) Plan in place for the management of OHS during operations. During construction, OHS implementation and training of construction workers is the responsibility of the construction supervisors. However, as the campus will be functioning while construction is underway, it is important to put additional safeguards in place to protect the learners from injury or accidents. The OHS Plan implemented by the construction company must therefore be integrated with an OHS Plan for the school operations and be implemented in cooperation with the school Director.



The OHS plan should take into account all relevant Ugandan regulatory guidelines, as well as the WBG General EHS Guidelines. The OHS Plan which needs to be designed and implemented must include in broad terms; a) identification of potential hazards and protection in general facility design and operation for school staff and construction workers; b) communication and training of construction workers and school staff; c) physical hazards; d) personal protective equipment (PPE) requirements; e) special hazard environments; f) monitoring, documentation and reporting of occupational accidents, diseases and incidents; and e) emergency prevention, preparedness and response arrangements. The latter also refers to the Life and Fire Safety Management Plan. This requirement is defined in the ESAP.



There have been no major injuries or fatalities at either campus since commencement, however from time to time there are some minor injuries resulting from falls, slips, cuts, strains, electric shocks etc. within the student and staff communities that are handled at the school dispensary. Records are kept only for major injuries, and parents are kept informed of their child’s health, should there be an incident that requires medical intervention. The policy is to refer all major injuries to the nearest health facility (Entebbe Grade A & B hospitals), under the guidance of the parents.

Student and staff accommodation

The school has five dormitories in Kigungu (3 boys, 2 girls with a total space of 8000m2) which accommodate 3000 students currently; and two in Katabi (one each for boys and girls, with a total space of 2830m2), accommodati
ng 580 students currently; two further dormitories are planned at the Katabi campus, which will bring the number of students to 3100 and 1500 respectively. The school separates boys sleeping and sanitary areas from the girls’, and these are also segregated with respect to age groups. Each student is accommodated in a bunk bed (double bunks are supplied by the school), with the requirement for each student to store his/her belongings in a metal trunk under the bed. Parents supply bedding, consisting of foam mattresses and sheets as well as mosquito nets. When compared with the space recommended in the IFC’s Worker Accommodation Guidelines, the school dormitories at Kigungu are currently 18-20% under compliance (i.e each student has an average of 2.4-2.9 m2 compared with 3-3.5m2, which is recommended in the South African “Guidelines for the Provision of Boarding Facilities in Public Ordinary Schools”), which will be adjusted as far as possible towards 3m2 per student at Kigungu and, once Katabi is complete it will adhere to a minimum of 3m2 per student, as specified in the ESAP. The school is advised, and has agreed, to outlaw the use of triple bunks, and to arrange the beds so that there is at much space between bunk beds as possible. This is for both health and hygiene reasons, as well as Life and Fire Safety (LFS) reasons.



The above principles should be applied to the 4 teachers and their families who are currently accommodated on the Project site (Katabi campus) and any other teachers and families who will be accommodated there in future.

Potential pollution issues during the construction phase are generally minimal due to the nature of the facilities being built, although provision of water, solid and liquid waste management and storm-water management are issues requiring attention. To address these issues Merryland will develop an appropriate, standard Environmental Management Plan (EMP) covering these issues (as per the EIA and NEMA permit conditions), to be applied during construction for application across all sites. This action is defined in the ESAP.



Energy management

In terms of resource use and management, both schools have minimal electricity requirements as all shower facilities are cold water only, there are no refrigeration facilities (except a small fridge in the dispensary), nor are cooling or heating of buildings required. Cooking is done using open fires. Lighting (provided by energy efficient bulbs across both campuses), mobile phone charging and some computer and administration facilities are the only activities requiring energy; plans are however underway to install a photovoltaic solar system for security lighting. Electricity is provided by the Uganda Electricity Transmission Company Limited (UETCL), and this is supplemented with a 150KVA generator at Kigungu and a 75 KVA generator at Katabi campus. Electricity consumption is calculated as 3,239,360 KWh at Kigungu campus, and 800,000 KWh for Katabi (4,039,360 kWh per annum for both campuses). Diesel is not stored on either of the campuses; a contractor delivers diesel on order. The average usage varies between 150-200L per month, depending upon the stability of the national supply. Finally, Kigungu campus has a 1000L boiler, utilizing approximately 3 tons of wood per week (locally bought), while the Katabi campus utilizes 50% of the same (approximately 240t wood per annum). It was not possible to confirm that the wood was harvested from a sustainable forest/source. Although this is the local practice, it is important for MHS to explore the use of other biomass (such as corn cobs) for fuel, or explore the use of gas for cooking purposes. Collectively, the energy and fuel consumption, upon the project completion will result in an 2,130 tCO2e emissions per annum.



Water management

Water is provided from rainwater harvesting (both campuses) and the balance is procured from the National Water and Sewerage Corporation (NWSC) via the local municipality, and complies with the national drinking water standards. As a further safeguard, Merryland ensures that water for drinking and cooking is from water stored in 750 litre tanks which is electronically fed through 2 filters and UV treatment. These are serviced three times a year. Unfiltered water from the municipality is used in the sanitary facilities (showers and toilets) and for hand washing and cleaning. The consumption at the Kigungu campus is approximately 144m3/day (45,000 m3 per annum) and at the Katabi campus approximately 100m3 /day (32,000 m3 per annu
m), while the school supplies 2m3(unfiltered) municipal water a day to the community (730m3 per annum). The school intends, in the long term, to sink boreholes at both campuses and also to increase rain water harvesting at all existing and planned structures, to reduce dependence on the NWSC. If this is achieved, chemical and radiological monitoring will need to be introduced.



Waste Water and Sanitation

All dormitories are fully equipped with toilets, showers and basins. A ratio of 15-20 students per latrine is typically used to determine how many should be provided at each school. Currently, the ratios are 57 girls per latrine and 33 boys; the school has already agreed to provide more facilities to comply with the ratio of 15-20 students per latrine, and 20-30 students per shower cubicle and basin. Improvements at the Kigungu campus, to add sanitary facilities as well as upgrade existing facilities to this standard, are already underway.

Merryland uses a standard design for the sanitary facilities, which are connected to very large below-ground septic tanks (5 in Kigungu and 1 in Katabi), depending on the siting requirements e.g. high ground water requirements, and Ugandan Environmental Management Authority guidelines. Municipal Health and Environment Officers conduct random inspections of all facilities (usually each term). In future, Merryland will ensure that they have the appropriate number, design, and sitting of latrines as per the WHO document “Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009). This requirement is included in the ESAP. Permanent teachers and groundsmen are also housed in family accommodation on the school site, and the same standards above will apply.



Grey water generated from washing of laundry, showers and the laboratory is currently disposed in a soakaway pit. This practice is not encouraged for the new campus (as per the WHO standards referred to above) however; it could be allowed if equipped with grease traps, is sited 1.5 m from the groundwater table and 30 m from any groundwater source. If the WHO standards cannot be adhered to, the school management have agreed that in the longer term a better solution must be proposed.



Waste water quality and volumes (approximately 3m3 a day, or 1000m3 per annum for both campuses) must be monitored. Water recycling of grey water from the basins and showers to the toilets could be an option for future consideration. Sewage is removed from the septic tanks by contractors certified by the National Water and Sewerage Corporation, as is common in the communities in which the Merryland schools are located (the total daily volume of sewage generated by 1650 persons is estimated at approximately 105,600L). Merryland will be required in future to ensure that contractors produce a waste manifest and are licensed to dispose of this waste in designated sewage disposal areas. This is defined as a requirement in the ESAP.



Waste management

T
he amount of solid waste produced at the schools is insignificant. Food is dry (beans, flour etc) and is ordered as it is consumed, however any waste arising from food preparation is segregated on site into organic and inorganic; organic wastes are taken to a compost pit for use as manure for cultivation of vegetables or landscaping. Occasionally organic waste may go to community members to be used as animal feed. Inorganic waste is often burned or collected by a licensed waste handler for disposal at municipal landfill. Burning is not encouraged, and in future all inorganic waste must be collected for appropriate disposal. Hazardous materials currently stored on site include chemicals (used in laboratories), and medical waste from the dispensary. Chemicals are kept in store rooms that are not accessible to students, and are only accessed by trained personnel (laboratory technicians and subject teachers). The laboratory technicians are trained in hazard and risk handling and have material safety data sheets for use in case of spills, leakages, workplace exposure limits and remediation in case of accidents. Pest management is undertaken by an external contractor; the pesticides are not stored on site. The grounds are sprayed for mosquitos once a term.



Used sanitary towels and medical waste are disposed of by incineration/burning. There are two existing incineration points (i.e one at each campus located within the female halls of residence). This practice is not safe as emissions can be harmful, and monitoring is expensive. If burning does take place, plastic waste should be separated (and not incinerated), and burning should only take place in a separate location from the school children. It is proposed, as above, that all waste streams are handled by a certified external waste contractor. This is a requirement in the ESAP.

Structural integrity of infrastructure

Facilities at Merryland Schools are designed and built to meet the Ugandan Building Codes and Regulations. This commits to ensuring that all buildings are safe, provide appropriate protection against the climate, have level floors, and meet the required ventilation and noise conditions. All buildings are designed by an architect and submitted for approval to the relevant authorities. The site selection process takes into account issues such as storm water management and elevation in relation to flood risks. The building plan is approved internally by the Construction/Technical Team and Merryland management and then certified by the local planning office. Furthermore, the Technical Team has supervisors and managers on site who ensure that all standards are met. To ensure the structural integrity of the buildings after construction, Merryland will develop and implement an audit function to review this aspect. Equally, an approach will be defined for on-going review of the structural integrity of the schools.



Food Safety

All boarders on both campuses are provided with three meals a day in the form of cooked beans, cow peas, and maize meal, with occasional meat on weekends. This is cooked on an open fire (as is the traditional practice) which is in a basic building set apart from the school buildings. The school catering officer carries out regular inspections to monitor food storage, handling and disposal practices at the school. In addition, the Municipal Health Inspection Team examines all catering staff to ensure proper hygiene for the food handling practices at the school. According to management, no issues with food provision have arisen to date. Nonetheless, in order to manage any risks associated with food hygiene, Merryland has agreed to upgrade its kitchen and dining facilities to include the following: smoke extraction; the food storage area is to be cool, dry and secure; storage, preparation, cooking, cleaning and waste areas are to be separated; pest management and moisture management in food storage areas; an approach to undertaking spot checks of food hygiene through random sampling and testing and evaluation of results; hygienic cleaning and storage area for utensils. All water used for food preparation and washing utensils should be of drinking-water quality. This is included in the ESAP. Water and soap (or waterless hand cleaner) for hand washing before handling food must be provided in all kitchen and preparation areas.



Life and Fire Safety

As mentioned in PS1, Life and Fire Safety (LFS) procedures are rudimentary (section 9 of the HR Policy Manual) and require further formalisation. In the event of an emergency, the head teachers for each campus have key information in folders with emergency telephone numbers, student and staff lists, lists of special needs students and staff, and the school’s chemical inventory. In the case of a fire/accident, the fire alarm is manually activa
ted, an announcement is made to students and staff who then assemble at designated fire points, and if the need arises, arrange for evacuation. A response team, made up of teachers trained in LFS, coordinates the appropriate response.



Student accommodation contains bunk beds with highly flammable foam mattresses and bedding. At the current density (2.4-2.9 m2 per student), a fire could be very serious if not rapidly detected and extinguished, therefore Life and Fire Safety measures will receive priority attention so that the appropriate safeguards are in place. Parents, who supply bedding, will be encouraged to provide 100% cotton bedding in future, which, in the event of a fire would reduce the probability for rapid heat generation and rapid spread of a fire, as well as reducing the probability of serious burns or toxic emissions. Doors are not locked during the night (as the campus itself is patrolled by security personnel), and windows on dormitories do not have burglar proofing; these are features which are designed to be used as escape routes in the event of an emergency. Four supervisory levels are always present in and around the dormitories, in the form of room leaders, prefects, 4 teachers that stay on site, and a Matron/Warden. All students and teachers are briefed about emergencies and security measures.



A minor fire was experienced at the Kigungu campus in 2012, which was the result of an electrical fault. The fire was arrested quickly with the assistance of the local fire brigade. Actions taken to prevent recurrence included: improvements in the lighting around the facility, especially within the compound; a 24-hour surveillance team was put in place; more rigorous security procedures were instituted at the entry / exit points into the campuses; and training was given to all students and employees on the danger of fires, and the need to conduct fire drills for the safety of both the school and surrounding community members.



A preliminary review of LFS design features of the two campuses against minimum international life and fire safety requirements was conducted by a qualified LFS specialist, and revealed a need for improvements; feedback was given to MHS. Recommendations included the addition of an automatic smoke detection and alarm system which must be monitored 24/7 via the school security control room, and which will automatically trigger an alarm; additional fire exits which open outwards; additional fire extinguishers, and access to water under pressure. The positioning of electrical sockets should be beyond the reach of young students in order to avoid tampering. Plans are subsequently underway to update the plans for all existing structures.



Going forward, the company will engage professional services of a qualified Life and Fire Safety Consultant acceptable to IFC to review existing buildings (Kigungu) and designs (for buildings under construction at Katabi) against an internationally accepted Life and Fire S
afety Code, including number of occupants, provision of escape routes, exits and means of escape, travel distances and compartmentation. Based on the outcomes of the review, an LFS Action Plan containing required remedial measures, tasks and activates with proposed completion dates will be agreed. Once construction is complete, an independent LFS Engineer will conduct an audit to ensure that all safety and design features have been adhered to and conform to IFC’s Performance Standards. The above requirements appear in the ESAP.



Medical

Merryland has an on-site dispensary at each campus. This consists of a small area for testing, which contains a microscope and refrigerator for blood samples/reagents/medicine and a locked cupboard for medical supplies; a nurse’s office and two quarantine rooms. One doctor and one qualified nurse are on site and on call at any time. Parents are contacted immediately in the event of illness or injury, and if a student must be admitted to hospital, the parents take responsibility thereafter.Records are kept of incidents, cause and treatment.



Vehicle safety

Merryland School has a lorry for supplies, a 62-seater bus and a 14-seater van which transports teachers and students to events. MHS ensures that the vehicles are driven by four full-time drivers with valid driving permits (which are re-tested every 3 years for renewal) to manage the vehicles. The School plans to train them in defensive and emergency driving in 2015. All drivers and staff passengers in school vehicles must wear seat belts. Failure to observe the traffic safety rules is considered negligence, and will attract the appropriate disciplinary measures. All vehicles are insured and are serviced regularly.



Security Personnel

Security personnel are hired at both the schools. These unarmed personnel, who must have a Ugandan Certificate in Security Guardship, 2 years’ experience and valid references, before being employed at the school, report to the school security officer, and at Katabi are backed up by 16 patrolling officers (armed) from the Police Department. The Police conduct inspections especially at the entrance / exit points at the campuses and surveillance at night. They work in four 6-hour shifts. Merryland management also builds strong relationships with the local community so that if any security issues arise, they can work together with the Security Committee to address the problem. As part of the Emergency Response Plan requirements as set out in the ESMS, parents/guardians will be made aware of these procedures, and at the beginning of each year, the School Director will arrange a meeting with them, and the surrounding community, to go over emergency preparedness, including those in relation to security issues.

Merryland has strong mechanisms and procedures for community engagement, and this is built into their business model and operational strategy. Students (through a Red Cross-Merryland link) offer a wide array of community services (e.g cleaning homesteads, creation of awareness on sanitation, donations to the needy, etc). The school provides water to members of the surrounding communities. Employment opportunities are provided by the school for both teaching and non-teaching staff. Bursaries are offered to disadvantaged but academically gifted children from within the local area, but also from other parts of the country. Parent meetings for all parents of students at the school are held at minimum every four months.
In terms of an on-going grievance mechanism, the MHS has a website where information is disclosed to stakeholders and there are large, clear signs posted at each campus, with a central number where community members can call with any issues. The company has a dedicated person (see PS2) who is responsible for EHS issues, and this person’s responsibility will be extended to address EHS related concerns/grievances during construction and operation (also those that could arise from disclosure of environmental audits). Issues will be documented, analyzed and responded to within specific timeline. This is an extension of the current system, where issues raised are monitored, and resolved by the School Director through the Head Masters, and recurring challenges and risks are discussed with the Board.

Company: MERRYLAND HIGHSCHOOL COMPANY LTD
Director: Dr Ssegawa
Address: MERRYLAND HIGH SCHOOL
(KATABI CAMPUS) ON PLOT M.99, 20,
12- 18 and 119-127 BUSAMBAGA ENTEBBE,
BUSIRO-WAKISO DISTRICT
UGANDA
Postal: P. O. Box 844, Entebbe, Uganda
Telephone: +256 772 401086
Email: mailto:merrylandhighschool@hotmail.com

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	Establish an overarching policy defining the environmental and social objectives and principles to guide the project to achieve sound environmental and social performance. The policy shall be consistent with the principles of the requirements of the IFC Performance Standards	03/30/2015	Completed
2	Design and implement a basic Environmental and Social Management System (ESMS), which will be aligned with the requirements of this Performance Standard, and must contain an overall policy, management procedures and plans, clear and adequate organizational capacity and competency, as well as processes for monitoring and review. Ensure that the OHS policies and procedures to safeguard teachers and students are integrated into the ESMS	09/30/2015	Completed
3	Plan and Implement Emergency Preparedness and Response: Institutionalize Procedures and Staff Training: Supplement the ESMS to achieve establishment and maintenance of an emergency preparedness and response system. Collaborate with affected communities, teachers, parents and students, local government agencies and other third parties to facilitate response to accidental and emergency situations and to prevent and mitigate harm to people and the environment	03/30/2015	Completed
4	Establish an overarching HR policy which specifies equal opportunities, non-discrimination, the prohibition of sexual harassment and child labor. The policy shall be consistent with the principles of the requirements of the IFC Performance Standard 2.	06/30/2015	Completed
5	Establish and implement and OHS Plan procedures for managing and monitoring the OHS requirements addressed in the ESMS. The OHS Plan must include in broad terms: a) identification of potential hazards and protection in general facility design and operation for school staff, students and construction workers; b) communication and training of construction workers and school staff; c) physical hazards; d) personal protective equipment (PPE) requirements; e) special hazard environments; f) monitoring, documentation and reporting of occupational accidents, diseases and incidents; and e) emergency prevention, preparedness and response arrangements. The latter also refers to the Life and Fire Safety Management Plan.	04/30/2015	Completed
6	Establish and fully implement policies and procedures for managing and monitoring the performance of third party employers and non-employees in relation to OHS requirements addressed in the ESMS. Incorporate these into contractual agreements with third party employers. This is particularly important for the construction phase of the project (Katabi).	03/30/2015	Completed
7	Design and implement policies and procedures to address the quality and management of student and teacher accommodation, layout, and provision of basic services such as sanitary facilities. Accommodation will be provided in a manner which safeguards occupants in the event of illness or emergency, with a final accommodation space per person of no less than 3m2 , as informed by the South African “Guidelines for the Provision of Boarding Facilities in Public Ordinary Schools”	03/30/2015	Completed
8	Merryland will ensure that they have the appropriate number, design, sitting and hygiene standards of latrines as per the WHO document “Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009), to a final ratio of no less than 1 latrine per 20 female students and 1 per 50 male students, and no less than 1 shower cubicle per 30 students.	03/30/2015	Completed
9	Design a basic waste management plan (the policies and procedures of which must be integrated into the ESMS) for avoidance of litter and for segregation of any waste generated at the schools.	06/30/2015	Completed
10	Seek appropriate certified third parties to collect and dispose of the waste, particularly any hazardous waste derived from laboratories, dispensary and sanitary facilities. Burning or incineration of any wastes must be phased out. Merryland will be required to ensure that contractors are licensed and dispose of this waste in designated disposal areas.	09/30/2015	Completed
11	Merryland will upgrade its kitchen and dining facilities to include the following: smoke extraction; the food storage area is to be cool, dry and secure; for separation of storage, preparation, cooking, cleaning and waste areas; pest management and moisture management in food storage areas; an approach to undertaking spot checks of food hygiene through random sampling and testing; hygienic cleaning and storage area for utensils.	04/30/2015	Completed
12	Develop and implement Food Safety Policies and Procedures (to be integrated with the ESMS), guided by the WHO document “Water, Sanitation and Hygiene Standards for Schools in Low-cost Settings” (2009)	07/30/2015	Completed
13	Appoint a qualified external LFS expert	12/01/2014	Completed
14	Conduct a life and fire safety audit of existing school buildings and design of buildings under construction, against the South African or British LFS standard. Define deficiencies and agree on the Action Plan to meet minimum international requirements applicable to this type of occupancy, for both existing and future buildings.	01/01/2015	Completed
15	Post construction, conduct an independent audit by a qualified external expert to confirm that the LFS Action Plan has been implemented and the WBG General EHS Guideline’s LFS requirements has been met	12/30/2016	Completed