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 project does not trigger PS5: Land Acquisition and Involuntary Resettlement; PS6 on Biodiversity Conservation and Sustainable Management of Living Natural Resource, PS7: Indigenous People or PS 8: Cultural Heritage because the proposed hospital will be developed in a leased premises in the new central business district (CBD) area of the Guangzhou City.

The land and building (shell structure) are owned by Guangdong Provincial China Traditional Medicine Hospital (“TCM”), which is one of the top three public hospitals in Guangzhou, and the local joint-venture partner in the project company. Chindex will be responsible for interior fitting, equipment purchase and hospital operation.

The project thus does not involve any new land acquisition or involuntary resettlement, harvesting of natural resources or impacts on natural habitat, and it does not impact on either Indigenous Peoples or known Cultural Heritage.

Key risks and issues related to this project include: adequate E&S assessment of the impacts of the project; the company’s capacity to manage its social, and EHS performance, and engage with local communities in accordance with local requirements and IFC Performance Standards and EHS Guidelines; assurance of fair, safe and healthy working conditions; management of wastes (particularly biomedical waste) and emissions; impacts of transport infrastructure on nearby communities; and life and fire safety management for the proposed facility in accordance with local and international fire safety codes.

The project may result in a limited number of potentially adverse E&S impacts, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. On this basis, this project is therefore classified as a Category B project according to IFC’s Policy on Environmental and Social Sustainability and Performance Standards.

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



In the establishment of its existing and planned facilities, UFH conducts E&S assessments in compliance with Chinese regulatory requirements. The company has a team working on development of new facility according to the corporate standards for the site selection, design and construction, including interior design and finishes. This team is working with architects and contractors with proven experience of designing and constructing international standard facilities.



For the proposed Guangzhou hospital an environmental and social impact assessment (ESIA) was conducted as per the local regulatory requirement. The process also involved extensive public disclosure and stakeholder engagement, as described below under the Stakeholder Engagement section.



Accordingly, the environmental permit was issued for the project, with several conditions to mitigate the identified environmental impacts. These include for example: provision of on-site wastewater treatment, measures to control noise, flue gas emissions and other air emissions as per the local regulations and biomedical waste management. The project design by licensed professionals incorporates these recommendations.



Management System



Chindex’s “Corporate Ethics and Code of Conduct” as well as the “Commitment Values” (beijing.ufh.com.cn/patient-visitor-info/about-us) articulate its corporate values and policies; such as: compliance with laws, rules and regulations; respect for people; health and safety; excellence in service quality in a respectful, culturally-sensitive manner and a commitment to provide a physical environment that supports its mission.



All UFH facilities have adopted and implemented management systems in line with international best practices. UFH facilities are certified to standards developed by the Joint Commission International Accreditation (JCIA), a division of the Joint Commission on Accreditation of Healthcare Organizations (JCAHO), which is the largest accrediting body for healthcare organizations in the USA. The JCIA Standards for medical and service quality are amongst the highest standards presently achievable for a hospital and are recognized internationally by the industry and the World Health Organization (WHO).



In compliance with the standard, UFH develops policies, systems and procedures to manage EHS and social issues and generally for hospital management. These areas are addressed under the following standards of JCIA: patient care; safety; rights and education; prevention and control of infection; facility management and safety; staff qualifications and education; governance and leadership; and management of information.



JCIA certification is renewed every three years and UFH rigorously checks and reviews the ongoing implementation of its system.



All UFH hospitals and clinics are JCIA certified as of date and have received ‘Gold Seal of Approval’. UFH plans for proposed Guangzhou hospital t
o be certified by end-2017.



Organizational Capacity and Competency



As part of the JCIA management system, all UFH facilities assign responsibility for EHS, fire safety, disease prevention and outbreak control to relevant staff.



UFH employs a full-time training department that provides induction and on-going training for medical and non-medical staff. Training includes but is not limited to: service excellence; infection control; risk management; patient rights; English and Chinese language training; and life support. Life and fire safety is an important element of the training program. Supervisors conduct regular meetings with staff to discuss and review performance.



Extensive training is provided to all of UFH’s nurses, who are locally-hired, to ensure they meet international JCIA standards. 80% of the company’s nurses also have overseas experience. UFH is the only facility to provide midwifery training and services in China.



In line with these corporate training requirements from the sponsor, the company will implement its own training program for the staff of Guangzhou hospital, as it becomes operational.



Monitoring and Review



All UFH’s facilities are required to conduct regular monitoring of wastewater discharges and the disposal of medical and other wastes. Results are reported to management and local environmental authorities who also conduct their own inspection of UFH’s electricity safety, sewage and water, fire protection and lighting systems, elevators, boilers, pressure containers and measuring devices. Internal monitoring of performance is also conducted regularly in line with JCIA requirements.



Staff are encouraged to submit occurrence reports anytime there is a nonconformance with required procedures or an incident. The occurrence reports are reviewed at regular meetings of the Risk Management Committee and corrective actions are identified and implemented as needed. The Committee reviews trends over time and improves procedures and training as needed. Departmental meetings and both internal and external Peer Reviews are conducted to assess performance and identify areas for improvement. Each department has quality indicators based on the 20 performance areas designated by JCIA.



Such a monitoring and review mechanism will be implemented at the proposed Guangzhou hospital being developed under the project, in line with the sponsor’s corporate and JCAI requirement.

Currently UFH has around 2774 staff, including some part-time staff. Women constitute about 76% of the total workforce across all levels. It outsources catering, security maintenance and operation of the boilers. Once the proposed project in Gungzhou is fully operational, the company expects to recruit 346 employees in the 1st year of operation (comprising of medical and non-medical).



HR Policy and Terms of Employment



The UFH has a comprehensive human resources (HR) policy and documented procedures for managing HR issues, ranging from working hours, to maternity and paternity leave, to training and staff development. The Company’s HR policies, management system, conditions of employment and working conditions are in compliance with national law and PS2.



Workers’ Organizations



As in its existing facilities, the proposed project will establish staff union in compliance with local Chinese and IFC requirements. Meetings are held throughout the year, and UFH pays a Union Fee of 2% of the salaries of all Chinese-national employees. Hospitals also set up a mandatory separate bank account to hold funds to be used specifically for “employee recreation” purposes.



Grievance Mechanism



An annual survey of staff is conducted to assess satisfaction levels and identify areas for improvement. The company’s internal grievance mechanism encourages staff to raise issues through direct discussions with immediate supervisors or managers and by e-mail directly to management. Workers’ organization is another channel available for employees to raise their grievances to the managements.



Protecting the Work Force



The company does not engage children or forced labor and it complies with local labor laws and related PS2 requirements to protect the workforce. All employees are over the age of 21, which is above the minimum required age of 18.



Occupational Health and Safety



UFH’s JCIA-compliant management system includes policies and procedures for managing occupational health and safety issues within its facilities.



A number of initiatives are undertaken by UFH to safeguard the health of employees and patients, which will be implemented in Guangzhou hospital once it becomes operational. These include:

An Infection Control Plan to prevent, identify and control healthcare associated infections;

Education of all employees on the importance of “standard precautions” in the hospital to reduce the risk of work-related exposures (e.g. hand hygiene, personal protective equipment, handling sharps, emergency eye washers and showers, appropriate cleaning procedures);

Provision of an employee health program that screens new employees to prevent, monitor, investigate potentially harmful infectious exposures and outbreaks among personnel and provides care for personnel for work-related illnesses or exposures;

A JCI-compliant radiation exposure control plan, which outlines measures to control and monitor exposure of staff to radiati
on sources;

Implementation of a policy to manage healthcare workers exposed to blood and body fluids.

UFH has a zero accident and fatality rate for its operations till date.



Workers Engaged by Third Parties



UFH has policies and procedures in place to manage the workers engaged by third parties. Accordingly, it requires the evidence from the contractors that appropriate payments are made to the government for contract workers and verifies that their living accommodation is satisfactory. The EHS practices of construction and maintenance contractors’ workers are monitored regularly and the company has rented and renovated accommodation for security staff and provides them with appropriate training.

Resource Efficiency



As noted above, UFH has a template which is used for the design, construction and operation of all of its new healthcare facilities. The template consolidates the Company’s existing operational practices, standards and expectations into a common framework, including but not limited to: sustainable materials in the construction process; design requirements for fire safety, disease prevention and isolation; energy-efficient utilities and systems; and segregation of medical and other wastes.



The renovation of the New Hope Oncology Centre was undertaken to LEED silver standard and although the company does not intend to achieve this standard for all its hospitals in the future, it has taken some of the lessons learnt and incorporated them into the company’s design template.



With the current design specifications, the electricity consumption for the proposed project in Guangzhou is estimated at 286 kWh/m2 of built-up area – well below the global benchmark of 400 kWh/m2.



Chindex is planning to be a pilot to demonstrate the benefit of green building design and achieve IFC''s EDGE certificate (http://www.ifc.org/EDGE) - Excellence in Design for Greater Efficiencies) for its pipeline projects.



Utilities (Electricity, Water, Wastewater)



For the company’s existing facilities, electricity is provided from the grid. Bottled water is used for drinking or medical purposes, while municipal water is used for other general purposes. Same will be the practice for the proposed project.



Wastewater discharges are compliant with applicable local requirements at UFH’s existing facilities. For the proposed project in Guangzhou a two-stage bioprocess treatment plant will be installed to treat the wastewater prior to discharge to municipally-operated sewage and water treatment plants.



Waste Management



Clinical and hazardous wastes are collected in specially identified containers within UFH’s premises and removed multiple times daily by the housekeeping staff and placed inside bins in a locked temporary storage area. Housekeeping staff wear appropriate protective equipment and follow UFH’s infection control policy when disposing of clinical waste. The management of hazardous, clinical and radioactive wastes are controlled through UFH’s JCI-compliant management system.



All wastes, including solid waste, are removed daily from the storage area by a government-approved contractor. The contractor is responsible for the offsite incineration of all clinical and hazardous waste. Radioactive wastes, comprising waste film developing solution, are appropriately stored for collection and disposal by an authorized contractor. No incineration is conducted on-site.



Green House Gas Emissions



Primary energy requirement for the project will be electricity which will be procured from the national grid, and small quantity of natural gas (for cooking). Domestic hot water will be heated by using heating pump. Very small quantity of di
esel will be required for testing of small capacity backup diesel generators, for use in the rare case of power failure.



The GHG emissions from the proposed project during the operational stage have been estimated as 15,500 tons CO2 equivalent per year. Actual records will be used to review amounts of tons CO2 equivalent per year that will be once the project becomes operational.

Vehicular Traffic



For any healthcare facility, significant volume of vehicular traffic is expected during construction and operational phases. At the time of site selection and hospital design UFH assesses the accessibility and the availability of parking space. UFH’s security team facilitates the vehicular movement and parking for the doctors, staff, patients and visitors to ensure minimum inconvenience to the neighboring residents. For the proposed hospital in Guangzhou adequate parking provision has been made in the design, covering over 24,000 m2 area over 3 floors, which will accommodate around 550 cars.



Community Exposure to Disease



UFH has both facilities and management procedures to prevent and manage patients with infectious diseases and to handle outbreaks that have the potential to impact on community health and safety. Temperature checks of patients are routine and patients with fevers are isolated in negative pressure rooms.



At the entry to each of its hospital facilities, a separate building is established to register and check patients for fever.



UFH has procedures, equipment and isolation facilities/systems, and has provided training to staff, to respond to potential emergencies that could result in potential internal or external impacts.



Life and Fire Safety



As part of its accredited JCIA system, policies and procedures are in place to specifically address life and fire safety issues. Mandatory fire safety training is provided for all new and existing hospital employees and drills are carried out regularly in accordance with the plan. UFH has duty engineers available on-site 24 hours per day who are in charge of monitoring fire safety equipment. UFH’s operations and facilities are in compliance with all local fire safety laws and regulations and the local government monitors compliance annually.



For the proposed hospital being developed under the project, the company will commission a fire safety professional, acceptable to IFC, to review the site specific Architectural Brief and design drawings and certify that all the fire safety related aspects of design are consistent with an internationally recognized fire and life safety code guidelines, as required under the life and fire safety section of the WBG EHS General Guidelines.



Following construction, the fire safety professional shall inspect the newly constructed building. The company will submit to IFC certifications from this professional that the project facility is designed, constructed, and operated in full compliance with local building codes, local fire department regulations, and all LFS aspects of the previously approved Architectural Brief.



Emergency Preparedness and Response



An emergency preparedness and response plan covers potential incidents associated with UFH’s operations. It is tested twice a year and prepares the staff for internal emergencies such as flooding and power failures, as well as external emergencies such
as earthquake or plane crash.



A monitoring and reporting system is in place to engage local government as needed in the event of an emergency and arrangements exist to engage assistance from the public, fire brigade and the local health and environmental authorities as needed.



UFH operates a color-coded system to respond to emergencies in all of its facilities and staff are regularly trained on emergency and fire response procedures. The system covers a red alert for fire, yellow for violent patients, green for general security and pink for child abductions (security staff guard entrances to maternity/pediatric units and staff must enter specified codes to enter these rooms).



Security Personnel



Professionally managed and trained security personnel are hired to guard UFH’s facilities 24 hours a day, 7 days a week. Contracts include requirements to meet national laws and to provide appropriate training. Guards implement a visitor registration system and, as noted above, security staff guard entrances to maternity/pediatric units to ensure the safety of patients. The guards do not carry firearms; and are trained to be the first response team in case of any emergency such as fire (including evacuation of the patients).

According to the interim regulations on Public Participation in Environmental Impact Assessment (UNCED [2006] Article 28) public disclosure and consultations are conducted in two phases:
Early in the environmental assessment of the project, by posting the project information bulletin and project construction notices to inform the public about the project; and
Once the first draft of the ESIA report is completed, public announcement is posted regarding the availability of project ESIA information, public consultation activities (including questionnaire survey) and communication channels for public to register any grievances.
Accordingly, the first local public disclosure of Project Information Bulletin was disclosed during March 24, - April 2 , 2009 at the public display on Mo Die Sha street in West Bank district, and other public posting sites. The second public disclosure for the proposed project was conducted during August 11 - August 20, 2009, targeting residents around the project site and nearby corporates, and institutions. The announcement and ESIA report was posted in Regal Riviera Court in the project vicinity, as well as was available for download on the Canton provincial Hospital network website http://www.gdhtcm.com/News/newsdetail.aspx?articleid=2547).

As a part of public consultation process, a Public opinion survey was conducted, targeted to more than 70 project affected families and vulnerable social groups within the project area. Public participation survey results show that local residents near the peripheral units believe that this project is a beneficial project, and support the construction of this project (support rate as high as 94%).

In line with its corporate commitment, at all UFH hospitals a patient services representative and administrator are on call to respond to any compliments, concerns, or complaints from the patients or their families. UFH’s CEO further confirms that “sharing concerns or complaints will not compromise their access to care, treatment, or services”. Several communication channels including a 24X7 call center and various social media platforms are available for this purpose. (shanghai.ufh.com.cn/patient-visitor-info/about-us).

UFH’s stakeholder engagement and corporate social responsibility activities are implemented through the United Foundation for China''s Health (UFCH), which develops model programs to provide access to innovative, multidisciplinary healthcare to vulnerable populations in China (http://www.unitedfoundation.org).

As a principal partner UFH donates 1% of its gross annual revenue to support in-kind medical and surgical services at UFH Hospitals and covers the administrative overhead costs for UFCH.

Working through partner organizations which provide care to orphans, the disabled, the abused, migrant workers and the elderly, both public and private, UFCH offers these organizations access to the best medical care China has to offer. This medical care is predominately free, or at a much reduced cost.

Its “Healthcare for All” initiative provides healthcare access to vulnerable underserved adult populations while “Children’s Medical Care Program” provides orphans and children of underprivileged families with access to surgical, medical and inpatient care.

UFCH provides nearly 50 partner organizations throughout China with medical services and with the launch of its Wheels for Life Community Health Van, UFCH will be able to grow its ability to service an even greater number of people in need.

Company will disclose this ESRS and a copy of ESIA report (in Chinese) locally at the following address:
#2 Jiangtai Road, Chaoyang District, Beijing
And on its website: ufh.com.cn
 All inquiries and comments may be directed to:
Name: Wang Fei
Tel: 8610-5927 7277
Email: mailto:wang.fei@ufh.com.cn

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Provide to IFC a third-party certification from the competent professional that the design of the proposed hospital in Guangzhou is in material compliance with local as well as internationally accepted life and fire safety standard(s).	12/31/2015
Provide to IFC a third-party certification from the competent professional that the new hospital in Guangzhou has been constructed in full compliance with international life and fire safety code (as referred in the ESAP #1 above) local building codes, local fire department regulations and local legal requirements	09/30/2016