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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The land has been acquired by Actis on a willing-buyer willing-seller basis from individuals resident in Ghana. No involuntary resettlement or economic displacement was caused as a result of the acquisition. Subsistence farmers were using the site to grow vegetables for a period of time and were given six months’ notice to vacate. They complied, with no objection Thus, PS 5: Land Acquisition and Involuntary Resettlement does not apply. The site is situated within the urban area of Accra and has been previously cleared of indigenous vegetation and is largely barren, grassed or inhabited with alien shrubs. As such, PS 6: Biodiversity Conservation and Sustainable Management of Living Resources does not apply. Neither does PS7: Indigenous Peoples as there are no such individuals classified as Indigenous in Ghana. Based on the site visit it appeared unlikely that any issues related to PS8: Cultural Heritage would apply, and this was confirmed during the Environmental Impact Assessment (EIA) process.

The proposed investment is expected to have limited environmental and social impacts which will be site-specific with none anticipated to be significant. Further, the impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. Following implementation of the attached Environmental and Social Action Plan (“ESAP”), the Project will be in compliance with applicable IFC’s Performance Standards and the World Bank Group (“WBG”) General and sector-specific (Tourism and Hospitality Developments) Environmental, Health and Safety (“EHS”) Guidelines.

Key environmental and social issues applicable for this investment are; i) design and construction of the Project in accordance with accepted building codes and standards, notably that related to life and fire safety; ii) effective implementation of an environmental management plan for the construction phase; iii) labor and working conditions for construction staff and those associated with the Project’s operational phases, inclusive of occupational health and safety; and iv) Energy-and resource efficiency features in the design and operation of buildings.

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 Exchange has presented plans to address the potential environmental and social impacts to ensure that the Project will, upon implementation of the specific agreed mitigation measures outlined in the ESAP, comply with policies and standards operating procedures internal to the company, applicable Ghanaian laws and regulations, IFC’s Performance Standards and the applicable WBG EHS Guidelines. The information about how these potential impacts will be addressed by the Project is summarized in the paragraphs that follow, and in the attached ESAP which is disclosed with this document.

Assessment and Management of Environmental and Social Risks and Impacts

In accordance with the Ghana Environmental Assessment Regulations (1999) and for purposes of obtaining a building permit for the Project as issued by the municipal Town and Country Planning Department, an Environmental Impact Assessment (EIA) is required. An EIA has been completed and has been approved by the Ghana Environmental Protection Agency (GEPA).



Aside from the EIA and building permit, the other key approvals that need to be obtained relate to planning approval (zoning rights), allowable density and on-site parking requirements, as well as a fire certificate. Planning approval has been granted, while the remaining permits are in the process of being obtained. The plans have taken into consideration the guidelines for construction as provided in the Building Regulations 1999, LI 1630, and the La Dadekotopon Municipal Assembly By-Laws on Noise, Public Health and safety and Sanitation.



Actis has a comprehensive environmental and social management system (ESMS) which is aligned with IFC’s Performance Standards that is being applied to the Project. The approach to environmental and social management is defined in the Actis Guidebook; “Responsible Investment – Integration of Environmental, Social and Governance Factors”. The Guidebook includes an Environmental Policy, Climate Change Policy, Health and Safety Policy, Business Integrity Policy and Social Policy with the latter including issues related to the management of labor and working conditions. The Guideline also defines the approach to address environmental, social and governance (ESG) issues when; i) a project is initially being considered for investment with screening of ESG issues being undertaken; ii) the formal ESG due diligence procedure prior to investment; iii) the approach to management of ESG issues during the life of the investment and; iv) how to address ESG issues when exiting an investment. As Laurus and The Exchange are owned by Actis, these companies also are committed to complying with Actis’s approach to ESG; this similarly applies to Actis’s policy related human resources and occupational health and safety (OHS).



To ensure effective implementation of the Actis ESMS, there is a dedicated environmental department staffed with two full-time individuals, one of which is dedicated to this specific Project. An Environmental Committee, headed by the appointed Development Team’s (DT) Resident Engineer, will be responsible for all environmental aspects of the Project, and will comprise the General Manager for Operations, and the Operations Manager.



Aside from potential emergency situations during operations, the primary project risks and impacts associated with Actis’s investments are related to the construction phase. So as to manage OHS, Actis has a detailed documented safety management system that is applied to all projects; further information on this is provided in the following secti
on.



The Project design team from Dar Al-Handasah, are experienced international consultants and this will similarly apply to other key disciplines such as structural, mechanical, electrical and fire safety engineering, and these will be paired with local consultants. During construction, the Laurus personnel such as the Project Development and Construction Directors, will provide oversight and will be supported by an on-site engineer. This approach is being applied to the construction of One Airport Square, and equally there are monthly meetings with representatives from all the key disciplines as referenced above. In this manner Laurus acting on behalf of Actis ensure that construction is undertaken in accordance with the original design and engineering specifications.



During construction, GEPA requires annual audits of projects and in accordance with the Environmental Management Plan (EMP) agreed as part of the EIA, there will also be a need for independent regular auditing to ensure compliance with the plan. The EMP includes a grievance procedure for addressing public complaints and concerns raised during the construction phase.



Information to be captured and reported on in the operational phase will relate to aspects such as resource consumption and potable and waste water quality and, for purposes of this specific investment, this information will be reported to IFC via the Annual Monitoring Report.



The approach to management of the Project during the operational phase has not yet been finalized, however it is likely that management of all aspects, or specific components of the Project will be outsourced, such as hotel management, cleaning, pest management, waste management and security.

Actis employs 260 individuals of whom 101 are female. The majority of these are professional staff and all staff members are employed on the basis of a detailed set of employment rules, policies and procedures. In accordance with these, employees are free to join unions though none have done so to date, there is a grievance and complaints policy and procedure, rules governing discrimination and non-harassment, and a policy in respect of equal opportunities. There are clearly defined leave procedures inclusive of that related to maternity, parental and dependants leave. Overall the approach to human resources by Actis is considered aligned with this Performance Standard. Laurus employs 15 individuals with the majority also being professional staff and similarly apply the Actis approach to human resources. All staff employed by The Exchange will also need to comply with Actis’s approach to human resources.



The contractor for the Project is yet to be appointed. At the stage when the Project is made available for tender, The Exchange will ensure that the documentation includes the requirement for compliance with this Performance Standard and national legislative requirements; this is defined as a requirement in the ESAP.



Management of the hotel will be outsourced to Rezidor and The Exchange will require their approach to human resources to comply with this Performance Standard. Equally, where there are service providers that will provide regular ongoing support to the Project such as security and cleaning, these contractors will also be required to comply with this Performance Standard. Finally, The Exchange will include a condition in contracts with all tenants renting office or retail space, requiring compliance with national labor legislation; Ghana is a member of the International Labor Organization (ILO) and has ratified 46 Conventions including those related to minimum wage, weekly rest, child labor and discrimination. The requirements defined above are included in the ESAP.



Actis’s in-house activities including those associated with Laurus are typically of an administrative nature, though Actis does have a health and safety policy. Actis has an OHS specification that is included with all tender documentation for projects that defines the minimum managerial requirements for OHS on a construction project by the principal contractor. In accordance with the principal contractor, other contractors or sub-contractors need to also comply with the specification and may only commence work on-site following approval of their health and safety plan in writing.



The OHS specification is comprehensive and in line with best international practice. Key components included therein relate to: i) the need for a full-time health and safety representative, regular health safety committee meetings and monthly auditing of OHS performance by the contractor; ii) regular training including that related to induction and on the job training e.g., too
lbox talks with attendance recorded, and competence assessments for all workers relative to the task to which they are assigned, iii) requirements relative personal protective equipment (PPE), first aid and emergency response procedures; iv) requirements for various types of equipment that may be used on-site such as scaffolding, heavy machinery, vessels under pressure, lifting equipment etc.; v) the need for documented risk assessments prior to tasks being undertaken; vi) physical requirements for specific types of works such as earthworks, blasting, traffic diversion etc. and; vii) the approach to work related stresses (e.g., noise and heat). The OHS specification is underpinned by three separate safety files which provide documentation to support implementation of the specification. This includes, for example, the actual risk assessment form for various tasks (civil work, bricklaying, electrical work, formwork etc.), manuals and procedures related to activities such as toolbox talks and inspections, and checklists to be applied prior to various types of work being undertaken such roofing, electrical work, working at heights etc.



A brief site visit in 2013 and discussions with the contractor’s OHS representative at the One Airport Square project indicated that the OHS specification, as outlined above, is applied to that project. The OHS specification will also be applied at this Project.



For purposes of operations, as applicable, The Exchange will require their own staff or those contracted for overall management, or specific tasks, to also comply with the Actis approach to OHS management.

Potential pollution issues during the construction phase are those typically associated with construction sites and will include, amongst others, the discharge of contaminated (high silt loads / oil and grease) storm-water and diesel and oil spills. In addition, there is the potential for nuisance impacts (e.g., noise and dust) on those occupying adjacent buildings, and traffic congestion. A study on the ambient air quality showed levels of particulates (PM10) in the project area to be higher than the standard defined in the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines. Thus, it is important for the project developer to suppress dust and particulates during construction using nets and water sprays. These impacts will be managed with the effective implementation of the EMP for the construction phase.



During the construction phase, a waste disposal contractor will be engaged to collect separated waste and general waste from the site at the end of every week. During the operational phase, the primary waste streams from the development will be domestic solid waste (e.g. paper, plastic, glass bottles) and liquid waste, which includes sewage and storm-water runoff. Solid waste will be collected by the municipality and disposed of at the municipal landfill site.



Sewerage will be generated by all the individual aspects of the Project and The Exchange will install their own sewerage (waste water) treatment plant (WWTP). The collected wastewater from all facilities/buildings will be conveyed to the proposed domestic wastewater treatment plant (WWTP). To avoid nuisance to the residents and for aesthetic reasons the WWTP shall be installed in a basement or in an enclosed building equipped with an odor control unit. The treated effluent from the WWTP will be of a suitable quality for irrigation and/ or for discharge into the environment through the surface drainage network. Domestic wastewater flows will be calculated, based on 85% of the total water demand, and is estimated at 472 m3/day. This facility will be designed such that it is able to accommodate the potential flows and treat waste water such that the discharge complies with the WBG General EHS Guidelines; these requirements are defined in the ESAP.



Storm-water will be collected where feasible, and opportunities for rainwater harvesting and reuse of storm-water are being assessed. Storm water management will need to be incorporated into the structural design of the complex, as the existing situation (a drain that deposits run-of onto the project site) will result in flooding. The project engineer will ensure that the appropriate storm water management plans are in place.



The Exchange will install a potable water treatment plant for water to be supplied to the hotel, restaurants and other activities such as the residential units if applicable. A water quality management plan will be developed and submitted to the IFC, which will include the monitoring of th
e hot water systems, cooling systems and the pool water; the latter will include monitoring for legionella bacteria where applicable. The water quality should comply with national acceptability standards or in their absence the current edition of with WHO Drinking Water Guidelines. This is defined in the ESAP. The estimated water consumption for the Project is 76,650 m3 per annum.



Potable water will be supplied by the municipality and The Exchange will install a potable water treatment plant for water to be supplied to the hotel and restaurants. Monitoring of this water will be undertaken, and the results submitted to IFC to confirm compliance with the WBG General EHS Guidelines. Where the project includes the delivery of water to the community or to users of facility infrastructure (such as hotel guests), where water may be used for drinking, cooking, washing, and bathing, water quality should comply with national acceptability standards, or in their absence the current edition of with WHO Drinking Water Guidelines. This is defined in the ESAP. The estimated water consumption for the Project is 76650 m3 per annum.



The approach to cooking in the kitchens is to be defined, however in the event that this is by means of liquefied petroleum gas, The Exchange will confirm the building codes to be applied to the installation of the storage tanks and this aspect will be incorporated into the independent LFS audit, as previously prescribed.



The projected electricity consumption for the Project is estimated at 16,328,079 KWh, and fuel consumption of 19,309L per annum, resulting in (estimated) emissions of 6,873tCO2 equivalents per annum. Electricity will be supplied via the national grid. Given that national demand currently exceeds supply in Ghana, standby generators will be installed to accommodate full supply requirements at the Project. Prior to installation, The Exchange will confirm the emissions from the generators will comply with the WBG EHS Guidelines and the approach to secondary containment for the fuel storage tanks, whether they are above or underground tanks. These requirements are defined in the ESAP.



Actis is a leader in the design and construction of energy efficient real estate projects and have been actively working with IFC’s Green Building Specialist to identify opportunities to enhance their existing approach to energy efficiency. For this Project, Actis is committed to energy savings of 25% when compared with similar developments, and will certify the Project against LEED (Leadership in Energy and Environmental Design), an internationally recognized voluntary program that provides third-party verification of green buildings.



Maintenance of the Project gardens will require the use of pesticides on occasion and the hotel will also be fumigated according to a predefined schedule. As defined in the ESAP, The Exchange will comply with the WBG General EHS Guidelines in this regard.

A preliminary traffic impact assessment has been completed as part of the EIA so as to ensure public safety is addressed, allied to ensuring the free flow of traffic in the Project environs particularly during construction.



Aside from that related to life and fire safety (LFS) as detailed below, the building standards / codes to be applied to the Project have not been confirmed, though as with One Airport Square these will be internationally accepted standards / codes. Prior to construction The Exchange will confirm the code as applied to seismic design and access for disabled persons.



One Airport Square has been designed according the British Standards for LFS with some adaptation for local conditions. For example, the lead time for response from vehicles providing firefighting support will be somewhat longer in Accra than that envisaged in the United Kingdom, thus the design has been amended to accommodate this. Similarly, the Project will be constructing to such standards. To ensure compliance with IFC’s Life and Fire Safety requirements, The Exchange will undertake a review of the LFS design prior to construction by a suitably qualified specialist to confirm alignment with the design standard. Further, once construction is complete, The Exchange will similarly commission a qualified specialist to confirm the Project has been constructed in accordance with the original design standard. In addition to these requirements, the Ghana Fire Brigade also need to sign off on the Project’s LFS design and will undertake annual inspections of the Project.



The Exchange will also confirm the approach to the hotel’s hot water system and the approach to treatment of the hotel’s pool water and the development’s evaporative cooling systems (if any), such that this does not allow for the potential of legionella bacteria developing. A water quality plan which includes monitoring in respect of the latter three components will also be required, with this information submitted to IFC.



In respect of food hygiene at the hotel will be managed via implementation of food safety program which complies with national standards and the requirements of this Performance Standard.



During the construction and operational phase The Exchange will use unarmed guards who are able to call on the national police if required. The Airport Police Station is located 300 m from the proposed development

Stakeholder engagement was undertaken as part of the EIA and this included relevant authorities, the public and the community residing in the general vicinity of the Project. The EMP includes the requirement for a community grievance mechanism for the Project’s construction phase.

The ESRS and the attached ESAP will be made available via the World Bank Group’s InfoShop and. the ESRS and ESAP will be made available for review at the following addresses:

Name: Carlo Matta
Company: Laurus Development Partners
Address: First Floor, One Airport Square,
Airport City / PO Box CT 8434, Cantonments
Accra, Ghana
Tel: +233 (0)302 744077
Email: mailto:carlo.matta@laurusdp.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Include relevant clauses in tender documentation for the Project construction requiring compliance with Performance Standard 2.	09/30/2015
Following appointment of the preferred contractor, submit documentation to IFC confirming compliance of the contractors approach to human resources with Performance Standard 2.	10/30/2015
Submit documentation to IFC confirming compliance of contractors involved in the day to day management i.e., overall facilities management or ongoing regular services, confirming compliance with Performance Standard 2.	11/30/2016
Submit documentation confirming hotel operator compliance with Performance Standard 2: Labour and Working Conditions.	12/30/2016
Submit documentation to IFC confirming the requirement for all tenants associated with the retail Project to comply with national labor law.	12/30/2016
Submit confirmation that all plants, programmes and works will comply with Performance Standard 3 Resource Efficiency and Pollution Prevention and the World Bank Environmental, Health and Safety Guidelines and specifically in respect of ;i) sewerage treatment and disposal; ii) water supply and treatment; iii) emissions from stationary power sources; and iv) pesticide management.	12/30/2016
Commission a suitably qualified specialist agreed upon by IFC to audit the Project’s life and fire safety (LFS) design to confirm compliance with IFC’s Life and Fire Safety requirements.	11/30/2015
Commission a suitably qualified specialist agreed upon by IFC to confirm the Project has been constructed in accordance with design as confirmed in above.	04/30/2017
In the event of the use of liquefied petroleum gas in the Project, confirm the design standards applied to the storage of and use of LPG (this component is to be included in the independent LFS audit defined above if necessary).	11/30/2015
Submit documentation confirming hotel operator compliance with Performance Standard 4: Community Health and Safety.	12/30/2016
Confirm the code to be applied to the seismic design and access for disabled person; such codes are to be aligned with internally accepted practice.	11/30/2015