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
In terms of asset acquisition, Ciel Healthcare Limited (CHL) intends acquiring and operating existing healthcare facilities, and only on a willing-buyer, willing-seller basis. CHL will target busy and strategically located facilities, situated in city or residential areas within Sub-Saharan Africa and, as such, impacts related to PS6: Biodiversity Conservation and Sustainable Natural Resource Management; PS7: Indigenous Peoples; and PS8: Cultural Heritage are not expected in this investment. However, prior to any land or asset acquisition, CHL will conduct a social and environmental due diligence to ensure that risks and impacts, if any, will be adequately identified and managed in a manner compliant with local regulations and all applicable IFC’s 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.
The key potential environmental, health and safety issues associated with this investment include: i) adequacy of environmental and social assessment and management systems of CHL, CHA and Fortis, particularly in relation to the acquisition of hospitals and future implementation of good hospital management practices; ii) labor relations, human resources policy and practices; iii) worker health and safety, including training and housekeeping; disinfection, sterilization, hygiene; iv) life and fire safety, including adequacy of emergency preparedness and response programs; v) solid and liquid waste management, particularly clinical waste management; vi) opportunities for energy conservation and efficiency as well as waste minimization; and vii) community health, safety and security.

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 and social assessment and management system, organizational capacity

Ciel Healthcare Limited (CHL): Ciel Ltd has a corporate risk approach which is applied to all of their historical operations (sugar, textiles etc.), and this is governed by the Risk and Audit Committees of the holding company and the subsidiary Boards. Proparco (a DFI that applies the IFC performance Standards) conducted an appraisal in May 2014 at Ciel Ltd, for which there is an agreed (and very comprehensive) Environmental and Social Action Plan. The ESAP, which includes the requirement for Ciel Ltd to develop environmental and social (E&S) policies, set up an E&S Committee, appoint staff dedicated to E&S implementation, and ensure the development and (among other things) of a corporate Environmental and Social Management system (ESMS), which would be applied at subsidiary level. The Proparco ESAP is on schedule. An Environmental and Social Committee has been newly constituted, with defined Terms of Reference, by the Board of Directors of Ciel Ltd, and a dedicated Corporate Sustainability Officer has just been appointed (November 2014), to oversee the development of corporate policies and procedures across all Ciel subsidiaries. The Committee will oversee the design and implementation of a corporate ESMS.



As Ciel Healthcare Limited is newly constituted, its policy frameworks for the management of Environmental and Social (E&S) issues are still in process. CHL (and its subsidiary, CHA) does not have an overarching policy on environmental and social objectives to guide performance, nor does it yet have an Environmental and Social Management system in place (ESMS), however the implementation of the corporate ESMS at holding company level (as described above) will be implemented at subsidiary level.



Fortis Healthcare: Fortis has developed and demonstrated its expertise in managing hospitals over the years and is recognized for its best practices in India, which are in line with international standards. This group has quality management systems that comply with international certifications such as Joint Commission International (JCI) accreditation, and which are integrated into the operations of all the hospitals which are under their management. Fortis meets all local legislative requirements and manages facilities utilizing detailed operational manuals containing more than 300 Standard Operating Procedures (SOPs), which conform to international best practice for the health sector. Record keeping and reporting is thorough, and feedback is given at various levels of the organization in order to continually review issues, and improve service. As an existing client, Fortis has implemented all of its ESAP requirements and has shown good performance.

MSCL (operating under the name “Fortis Clinique Darné”), is a subsidiary of CHL, partially owned and operated by Fortis. It is the largest private hospital in Mauritius with 110 beds, 4 operating theatres, and 25
specialties including: cardiology, general surgery, orthopedics, obstetrics and gynecology, endocrinology, psychiatry, plastic and reconstructive surgery, internal medicine and gastroenterology; radiology (X-Ray, ultrasound); medical laboratory; non-interventional cardiology (stress test and echography); preventive health check-ups; and endoscopy (gastroscopy & colonoscopy). Post-acquisition, Fortis was given operational control of MSCL under a 10 year ‘Operations and Management’ (O&M) contract. The Chief Operating Officer (who is appointed by Fortis) is accountable to the Board and is responsible for the success of the O&M contract.



Policies and accreditation: Corporate level policies which Fortis has implemented to support the O&M responsibilities, and to offer services at an internationally acceptable level, are numerous and include: occupational health and safety policies; construction safety management; facility management policies; emergency evacuation plans; safe handling of chemicals and hazardous spills; environmental sampling; policy on water intrusion; Life and Fire Safety policies; visitor policies; food handling and storage policies; housekeeping, cleaning and hygiene policies; waste management and maintenance policies; drug and medicine storage, handling and disposal; patient admission policies; patient and visitor rights; medical bylaws and ethics; infection control; laboratory safety guidelines and radiation safety.



A Safety Committee communicates all regulatory initiatives and facilitates new program requirements, recommends training, performs internal self-audits and monitors workplace hazards to ensure compliance. Program compliance is assessed through safety rounds, mock surveys, review of injury and illness reports, observation of staff knowledge during actual incidents and planned drills. Environmental health initiatives include: i) conducting indoor air quality surveys in critical areas, including sampling, identifying and developing appropriate remedial actions to eliminate potential sources of airborne contaminants; ii) employee health and safety training, on such topics as handling hazardous materials and other specialized health and safety orientations; Iii) emergency response training and hazardous materials clean up; iv) implementation of the hospital''s Lab Safety Program, including conducting lab inspections and performing fume hood inspections.



LIBA, also situated in Mauritius, which specializes in food, environmental (water, effluent, waste, air conditioning, soil, pesticides and hydrocarbon contamination), and animal health testing, has received various diagnostics industry accreditations including ISO 17026 and ISO 9001; 46 parameters are accredited by MAURITAS (Mauritian Bureau of Standards), and more are added each year. The laboratory is newly established, with well-defined processes and data management systems, and is of an international standard.



Identification of Risks and Impacts: CHL’s futur
e clinics, hospitals or diagnostic centers may be leased within existing buildings and in existing properties; thus, there will likely be no need to conduct an environmental impact assessment. Equally, hospitals to be acquired will already be established. Where the status at the time of acquisition reflects clearances required, pending or requiring revision, the company is committed to approaching the environmental authorities and initiating appropriate action, under permissible rules, for obtaining the same. In addition, prior to and post-acquisition of a hospital, CHL will undertake an Environmental and Social Due Diligence (ESDD), as part of its corporate ESMS, to assess operations against the Performance Standards, and agree with IFC on an action plan to ensure compliance if necessary. These actions are defined in the attached ESAP.



Emergency Preparedness and Response: Fortis applies standard procedures for facility fire prevention, emergency response and evacuation, tailored to the particular environment. These are articulated in its policies, and employees of each facility are trained to implement the plans.



During the site visit, it was evident that the CHL Head Office must still establish a formal Emergency Preparedness Plan, including a Life and Fire Safety Plan. This is discussed in more detail under PS4.



Monitoring and Review: Internal Quality Assurance audits against the Fortis Standard Operating Procedures (SOPs) and legislative requirements are carried out twice a year. Results of these audits are assessed by the COO, who is responsible for correcting any performance issues.



Grievance Mechanism: Ciel is currently drafting a Code of Business and Ethics which will include a comprehensive grievance mechanism. Throughout the Fortis Clinique Darné facilities, suggestion boxes invite anonymous complaints or suggestions from patients, employees or visitors. Clinic managers are responsible for collecting these and dealing with the issues that are raised. All patient or visitor complaints, written or verbal (including telephone complaints), and regardless of point or origin, are forwarded to the Patient Welfare Officer/Manager. Any supervisor, who receives a complaint, must document it and give it a reference number. The record is forwarded - for non-medical complaints, to the concerned Head of Department (HOD) - and for medical complaints, to the office of Medical Superintendent. The HOD investigates the non-medical complaint and the response is forwarded back to the manager, who mails the response to the complainant, and files a copy. The Medical Superintendent investigates, and is obliged to report, any medical complaint to the Chief Operations Officer (COO); and medico-legal complaints are reported to the Legal Officer. The Medical Superintendent is responsible for mailing the response to the complainant, and retains a copy for filing.



CHL has developed a corporate sustainability policy, and have agreed to develop an E
SMS framework (linked to the Ciel Ltd policies and ESRS practices) which must be applicable, within the limitations of local regulatory and cultural norms, to all existing and subsequent subsidiaries, and which would be compatible with the Fortis quality management system. This would include Emergency Response and LFS Plans. The company has committed to a framework which will be aligned with JCI standards, as this is typically the standard that Fortis applies. This is included in the environmental and social action plan (ESAP).

Working Conditions and Management of Worker Relationships



HR Policies: CHL implements the Ciel Ltd HR Policies and procedures, and as it is a new entity, it will adapt these to conform with the requirements specific to the health sector. Fortis has formal and documented HR policies and practices in place, which are employed at the facilities which they manage. They are essentially in line with the IFC’s PS2 requirements and is consistent with the national labour laws. These cover: terms of employment and working conditions, including procedures for hiring, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and dismissal, leave and vacation, and retirement. These are not contained within a formal HR Handbook, but all policies are part of induction training, and are accessible to employees. Separate policies specify equal opportunities and non-discrimination, while specific policies on the prohibition of sexual harassment and child labor are not articulated; however these are inherently part of the statutory requirement. An overall HR Policy will be formulated as part of the requirements of the ESAP. All expatriate contracts are reviewed and approved by the Mauritian Ministry of Labour.



Freedom of association and grievances: Fortis and CHL respect employee Freedom of Association, and do not prevent employee union membership (approximately 20% of the 517 employees are unionised at MSCL). As part of its HR policies, a documented grievance mechanism is available for all the employees to raise any of their concerns. An employee who has a grievance is entitled to raise the matter, in the first instance, with his immediate superior or with the section heads or supervisor. The employee can do so with the help of his union delegate, if necessary.



Confidentiality and ethics: As mentioned above, Ciel is drafting a Code of Business and Ethics, which will cover all aspects of business conduct. Fortis has an established a Code of Conduct for all employees at MSCL and this is applicable to any individual who is seen as representing or being associated with the company to maintain confidence in the company’s integrity; the practices necessary to take into account their legal obligations from time to time and the reasonable expectations of the shareholders, and the responsibility and accountability of individuals for reporting and investigating reports of unethical practices. Employees are encouraged to report any concerns regarding serious misbehaviour including theft, fraud, and breach of policies, dishonesty, harassment, unethical or negligent behavior, workplace safety hazards and medical negligence through the COO’s office.



Occupational Health and Safety: Fortis establishes a Safety Committee within all of its facilities that it manages, and Fortis Clinique Darné is no exception. The Committee’s responsibility is to ensure implementation of the Safety Program, communicate and facilitate
all new program requirements and regulatory initiatives, recommend training, perform internal self-audits and monitor workplace hazards to ensure compliance. Program compliance is assessed through safety rounds, mock surveys, review of injury and illness reports, observation of staff knowledge during actual incidents and planned drills. The Safety Committee develops various training programs in compliance with environmental and safety standards. The Departmental Head is responsible for scheduling training. Training on SOPs, occupational health and safety, infection control, emergency management and response, and handling of liquid and solid waste is provided to all staff as part of induction training as well as through regular refresher training.



OHS incidents are monitored by the Health and Safety Officer at MSCL. For any incident occurring on the premises, the employee is referred to the clinic’s casualty for primary treatment. In case of needle sticks, the, employee is referred to the government hospital and follow-up is done over a period of 3 months to ensure there is no infection (particularly for HIV/Aids). Records are kept both with the Health and Safety officer and Human Resources. In the last quarter (June-Oct 2014) 11 minor injuries were recorded at Fortis Clinique Darné.



Workforce safety and hygiene practices cover, among others, biological hazard safety (e.g. nosocomial infections, needle stick injuries), practices for handling hazardous drugs (e.g. chemotherapeutic drugs), radiation protection, preventive medicine, workplace monitoring and medical examination of employees. As indicated in PS1, there is a set of Standard Operating Procedures that are applied for all medical activities, including: sharps injuries, treatment of the wound, medical follow up and testing as well as counselling. Fortis hospitals undertake worker health and safety risk assessments plus safety audits of all operations and areas for potential occupational hazards and risks to employees, hazardous chemical substances risk assessments, and chemical exposure monitoring; medical surveillance (as required by the local legislation) has also been conducted, and all employees working with radiological equipment are monitored for radiation exposure. Work place monitoring systems are extensive and appropriate to the nature and scale of operations, to ensure compliance with safety requirements. PPE is supplied to all hospital personnel, is strictly enforced, and (depending upon the job description) includes eye, face, hand, body and head protection.



CHL has no formal Occupational Health and Safety (OHS) Plan in place yet, and defers to the Fortis SOPs and quality management system for operational phases, while the ESMS is being developed. Nonetheless, if the group decides to build or expand assets an OHS Plan must be in place for the management of health and safety during construction. If applicable, OHS requirements will be included in bidding documentatio
n for the technical/financial proposal of the construction contractors. This will require the contractor to include in their technical proposal a detailed OHS practice handbook that it will implement during construction, and must take into account all relevant regulatory guidelines as well as the WBG General EHS Guidelines. The contractor will effectively ensure implementation of the obligatory practices (as per the above practice handbook) through a full-time OHS officer who will be employed during the construction phase. Weekly reports from the contractors to the client will be expected as part of the contractual arrangements. This also applies to a Fire Safety construction phase plan, and is included in the ESAP.



CHL (in cooperation with Fortis) will compile a corporate HR policy, and, together with the various policies governing HR, will be compiled into an Employee/HR Handbook. This will be applicable to all existing and future acquisitions, and amended to align with local legislative requirements and jurisdiction. In addition, a corporate OHS Policy and Plan will be compiled which will integrate with the ESRS, as described in PS1. This appears as a requirement in the ESAP.

Potential issues during the operational phase of healthcare facilities include: the provision of high quality water for use in clinical facilities, management (handling, storage and disposal) of solid and liquid waste, particularly healthcare (biomedical and pharmaceutical) waste, handling of compressed gases and laboratory chemicals, electricity provision and backup systems, and temperature and ventilation management.



Water and energy management: Electricity is sourced from the grid for all facilities located in Mauritius, and water is obtained from the Central Water Authority, which is of a high quality and complies not only with local standards but also the WHO Drinking Water Guidelines. The local authority samples and tests the water quality monthly. As an additional safeguard, however, water utilized for drinking or medical uses is passed through chemical filters.



Fortis emphasizes energy and water conservation. This is demonstrated in the implementation of the following initiatives at MSCL: optimization of heating, ventilation and air conditioning (HVAC); energy efficient air compressors; UPS (electricity back-up systems) with high efficiency motors for conservation of energy; leakages plugged and water pipe lines insulated; hermetically sealed stainless steel doors for operation theatres to prevent wastage of conditioned air. In addition, replacement of iridescent bulbs with compact fluorescent light bulbs (CFLs) for external lighting; use of light-emitting diodes (LEDs) for internal lighting, and monitoring meters carefully to manage consumption. A technology replacement and maintenance plan is followed closely. Water electricity, fuel and gases consumption; wastewater and waste generation are monitored monthly and reported to management. The HVAC systems are serviced twice a year.



Electricity consumption over the past year at Fortis Clinique Darné was 917,755 kWh, gas was 26,625L and water consumption was just short of 17,000 m3. Fortis Clinique Darné has a 500 kVA diesel generator for major electrical disruptions, however it is rarely used. Diesel consumption was 2,770 L for the past year, primarily for generator testing, and use in three of the Fortis Clinique Darné vehicles (two Ambulances, and the staff van). The CHL office has a 250 kVA backup generator. There is reliable electricity generation in Mauritius; UPS units are used for emergencies as they provide immediate back-up. The diesel generator is provided with an acoustic enclosure, and although not bunded, is on a concrete floor with drainage and a sump. Total emissions for the hospital are calculated at 465 tons of CO2e per annum.



Hazardous and biomedical waste management: Fortis has a documented SOP for biomedical waste management in place which provides guidelines to ensure correct sorting, labeling, handling, storage, transporting and disposal of solid and liquid waste and, thus, prevention of infection and contamination of personnel and equipment. All wa
ste is double bagged in case of leakage. The waste is separately stored in the respective color coded bags. At shift end, waste from every floor is transported to the central collection room in the basement, where it is sorted, either for collection or thermal destruction. Fortis Clinique Darné has an old incinerator which is utilized for health/clinical waste. The University of Mauritius monitors the emissions annually (stack monitoring reports must be sent to the authorities) and has certified that the emissions are within WHO limits. The incinerator is serviced 3 times a year.



Hazardous waste, such as mercury and laboratory waste (from LIBA), is generated in very small amounts and stored until such time as Mauritius has a hazardous waste disposal site or treatment facility (this is in development, along with a planned centralized government incinerator). Medications at Fortis Clinique Darné to be destroyed are kept in a designated yellow waste bag labeled as cytotoxic waste, and are either returned to the manufacturer or incinerated in the current incinerator. Dialysis wastes are sent to another privately owned incinerator for disposal. Fortis updates its SOP to include a requirement of verification of the chain of custody documentation for the authorized waste management contractors from time to time, depending upon the individual hospital requirements. Bottles and plastic bags are kept in a bin and collected by Polypet (plastic recycling company) every week.



Fortis implements a waste management plan at all of its facilities, to include all forms of waste generation, storage, handling and disposal. The plan focuses on avoiding the generation of hazardous and non-hazardous waste materials in the first instance; and where technically feasible, recover and/or reuse waste in a manner that is safe for human health and the environment. When hazardous waste disposal is conducted by third parties, contractors are appointed through contracts with explicit scopes of work that require them to demonstrate they are reputable and legitimate enterprises licensed by the relevant government agencies. Contractors must produce chain of custody documentation to the final destination, and where possible, the company must ascertain if licensed disposal sites are being operated to acceptable standards. Where this is not the case the company will undertake a process to choose alternative disposal options, including the possibility of developing recovery or disposal facilities at the project site. Effluent management: At Fortis Clinique Darné, effluent is discharged to the municipal works in Mauritius, at a rate of 16,831 m3 per annum. A grease trap at the kitchen effluent outlet is cleaned daily. Sewage from offices and hospital is connected directly to the municipal sewer and is treated at the waste water treatment works. If, during the ESDD process of new acquisitions (as described in PS1), the waste water discharge is reviewed against the requirements of
the WBG EHS Guidelines and there is found to be non-compliance, the E&S action plan arising from the ESDD must define requirements to ensure compliance, including (if necessary) the installation of a wastewater management plant.



Pest Management: Government health authorities spray the Fortis Clinique Darné premises monthly in winter or twice a month in summer for mosquitoes. An external contractor handles rodent control. Measures include glue traps, which are monitored weekly.

Emergency Preparedness and Life and Fire Safety (LFS): Emergency preparedness plans are in place at the hospital, and these include life and fire safety (LFS) plans. Security personnel are trained in emergency and LFS procedures, and coordinate any (non-medical) emergency. Fortis Clinique Darné is housed in an old building and therefore cannot comply with the JCI requirements for fire zoning; however safeguards are in place in the form of smoke detectors, alarms, access to fire extinguishers and hoses at regular intervals throughout the building. The building was inspected and cleared for Fire Safety by the Govt Fire Services in 2002 and an approval certificate issued for the same. Subsequently, the same authority does an inspection every year and authorizes the renewal of the original certificate. Sixty to seventy percent of employees are trained in life support; nevertheless every employee undergoes health and safety, emergency preparedness and LFS training as part of their induction. There are regular inspections of facilities, life safety surveys and surveys for compliance with applicable regulations and standards. These include regular inspections of fire extinguishers and annual maintenance and hydrostatic testing. Fire drills are held at least twice a year. A SOP has been developed for safe evacuation of patients in case of fire. Signage and information in public areas about what to do in an emergency, as well as phone numbers, are visible throughout the facility.



CHL will commission a fire safety professional, acceptable to IFC, to review the facilities at Fortis Clinique Darné against internationally recognized fire and life safety codes, and, if needed, to develop an upgrade programme to further improve LFS conditions at the hospital. To meet IFC’s LFS requirements for future properties, CHL and IFC will agree on a corporate LFS Manual, which will define (a) high-level design and technical requirements for the company’s typical building and occupancy categories; and (b) operational requirements. These requirements will be then translated into design and operation of individual properties, and CHL will confirm their compliance with IFC’s LFS requirements through professional certification on design and construction. This is specified in the ESAP.



Structural Safety: Every Fortis facility typically undergoes an Infrastructure Safety and Security audit every quarter. The audit is conducted by a team of fire officers, biomedical engineer and chief engineer from another hospital belonging to the Fortis Group so as to ensure objectivity during the audit process. The company has developed audit checklists for this purpose. For instance, the fire safety audit checklist covers 106 points from National Building Code and JCI requirements which are audited quarterly. The audit team conducts an exit meeting with facility director and facility heads to share their observations. All newly acquired CHL facilities will be evaluated by a structur
al engineer and certified to be in compliance with national Building Codes and Regulations. This requirement is defined in the ESAP.



Food safety: Fortis-operated hospitals include a kitchen for the supply of patient meals. Fortis implements a stringent quality management system.. This ensures that supplies of frozen goods must be delivered in a refrigerated vehicle and at temperature of 0-4⁰C; expiry dates are closely monitored. No goods are allowed to be stored on the floor and no carton boxes are allowed. Any frozen goods that have defrosted are rejected; storage of frozen goods is at a temperature of -20⁰C . A separate chill room for preparation of raw food is kept at a temperature of 0-6⁰C, and the kitchen has separate preparation rooms for meat, vegetables, baking and cooked/raw foods. Dirty materials (crockery, raw materials) have one delivery entrance, and clean materials exit via another door (the ‘dirty and clean corridor’ principle). Refrigerators and storage areas are monitored daily; areas are disinfected after each food service. All (40) food handlers are referred to the sanitary department of the Ministry of Health for training and certification and are monitored regularly by the hospital, as per the national statutes on food safety, and must have certificates of health. PPE, such as gloves, hair nets, aprons, and closed shoes are compulsory.



Community Exposure to Disease: Fortis has a strong program relating to patient safety, aligned with the requirements of the JCI, which includes control of nosocomial infections. Any new hospitals will be designed and operated under these criteria. Hospital staff report communicable diseases to the Infection Control Committee (ICC), a multidisciplinary advisory body, chaired by a Senior Pathologist/Microbiologist. The ICC follows exposure control procedures to minimize the risk of transmission to health care workers, patients and others, and advises on the following subjects: safety measures to prevent infection to the patients; efficient and standardized use of antiseptics, disinfectants and products used for washing and disinfecting the hand; quality control of the techniques used to sterilize equipment in the hospital; regular bacteriological monitoring of sterilization cycle (autoclaves); recommending antibiotic policy and guidelines; policies and procedures for surveillance, prevention and control of infection for patients, staff and visitors. All of the above measures are communicated in an Infection Control Manual, which was developed from the guidelines of the Centre for Disease Control (CDC) and state regulations.



Should an epidemic or bioterrorism event be suspected, a network of communication is activated by the Emergency Department to involve the Infection Control Team, healthcare administration including the Medical Superintendent, Facility Director, local government health departments, and NICD (National Institute of Communicable Diseases) or any other agency as deeme
d fit by the Infection Control Team.



Security Personnel: Fourteen unarmed security personnel/watchmen are employed by the hospital facilities, and are stationed at all entrances/exits. Security SOPs govern their responsibilities and are responsible to the Head of Section. Security personnel are trained in-house on security and LFS. 40 CCTV cameras are positioned around the facilities, and are monitored by security personnel in a central control room. Footage is taped and stored for 15 days. Management is considering outsourcing this service to a professional security service company, with the preference to transfer and train the existing employees to the new contractor. The hospital utilises biometric access control for clinical staff, which is able to electronically record entry/exits.



Vehicle/Driver safety: Fortis Clinique Darné has 12 vehicles (staff van, delivery vehicles and 2 ambulances), and six general drivers and seven ambulance drivers. All drivers are licenced and their performance is closely monitored by their supervisors. Spot checks ensure that vehicles are kept clean and orderly.

Fortis has an SOP in place for receiving and registering external communications from the public, in order to respond and assess the issues raised. During the construction phase, this SOP will be extended by the CHL, CHA and Fortis Projects team to include grievances received from external stakeholders

The ESRS and attached ESAP will be made available via the World Bank Group’s InfoShop. In addition, an advertisement will be lodged in a Mauritian national newspaper informing the public that the ESRS and ESAP are available for review. For information, please contact:

Alvin Peerthy
Corporate Sustainability Officer
CIEL Corporate Services Ltd
5th Floor, Ebène Skies, Rue de l''Institut, Ebène 80817, Mauritius.
Tel: (230) 404 2200 | Direct line: (230) 404 2102 | Fax: (230) 404 2201

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Institutionalize Human Resources Policies and Procedures: Adopt and implement a corporate human resources policy and related procedures, appropriate to the workforce that sets out an approach consistent with the requirements of Performance Standard 2 and applicable national law. Provide employees with clear and understandable, documented information within a corporate Employee Handbook; this should include policies and practices on HIV/Aids, collective agreements, non-discrimination, sexual harassment, forced or child labour, dangerous/hazardous work, hours of work, wages, overtime, compensation, grievance mechanisms, and benefits.	09/30/2015
Develop a corporate OHS policy and system to ensure alignment with Performance Standard 2 and OHSAS 18001. This is to be integrated with the corporate ESMS, and include procedures applicable to all operations (existing and to be developed / acquired).	12/31/2015
The OHS system is to include the management of OHS during construction phases, if any premises are expanded or undergo significant renovations. OHS requirements will be included in bidding documentation for the technical/financial proposal of any construction contractors, and will require the contractor to include in their technical proposal a detailed OHS practice handbook that it will implement during construction. The OHS Manual must take into account all relevant regulatory guidelines as well as the WBG General EHS Guidelines. The above also applies to a Life and Fire Safety Management Plan for construction phases.	12/31/2015
Conduct an environmental and social review/due diligence (ESDD) of all new health facilities before acquisition (as part of the integrated ESMS, described above), against the requirements of the IFC Performance Standards and WBG EHS Guidelines (General and for Healthcare Facilities). Where gaps in performance are identified, develop an action plan in agreement with IFC to address these	03/31/2016
In respect of waste-water, this is to be reviewed against the requirements of the WBG EHS Guidelines and where there is no compliance in terms of discharge requirements, the action plan is to define requirements to ensure compliance, including installation of a wastewater management plant if necessary.	03/31/2016
Where there is ongoing provision of contracted workers for purposes of fulfilling specific tasks e.g., security or cleaning, require such contractors via the associated contract documentation to comply with the requirements of Performance Standard 2.	03/31/2016
Engage with professional services of a qualified Life and Fire Safety consultant acceptable to IFC to conduct a review of the existing Fortis Clinique Darné facility against internationally accepted L&FS code and if necessary, prepare an improvement LFS program with proposed completion dates.	06/30/2015
Engage with professional services of a qualified Life and Fire Safety consultant to develop a corporate LFS Manual, which will define (i) high-level design and technical requirements for the company’s typical building and occupancy categories; and (ii) operational requirements to meet IFC General EHS Guidelines.	06/30/2015
Submit design and post-construction certification for any individual project to be designed and constructed/renovated as part of IFC project	12/31/2016