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 for this phase, Lagoon Hospitals intends leasing existing building facilities. Hygeia will target busy and strategically located facilities, situated in city or residential areas within Victoria Island Lagos 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, Hygeia 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 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 Lagoon Hospitals particularly in relation to the acquisition of hospitals and future implementation of good hospital management practices; ii) labour relations, human resources policy and practices; iii) worker health and safety, including training and housekeeping; disinfection, sterilisation, 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 minimisation; 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 SystemLagoon Hospitals Group has a fully functional integrated Environmental and Social Management System in place to manage the safety, health, environmental and quality (SHEQ) issues of its hospital operations on an ongoing basis. The ESMS incorporates the required elements of the Performance Standards. The ESMS has an overarching policy and a process for identifying the environmental and social risks and impacts of its hospital operations. Lagoon Hospitals also complies with various international health care standards. There is a dedicated and experienced Environment, Health and Safety (EHS) Officer who is responsible for managing the E&S and quality issues of the Hospital group. The company has all the necessary permits and licenses in place to operate. JCI Standards certification to improve care quality and patient safety was obtained for the Apapa and Ikeja hospital facilities.



Policies and accreditation: Corporate level policies which Hygeia has implemented to support the Operations and Management (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; 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. Occupational 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.



Identification of Risks and Impacts: Hygeia’s future clinics or hospitals may be leased within existing buildings and in existing properties; thus, there will likely be no need to conduct an environmental impact assessment. Where the status at the time of acquisition r
eflects 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, Hygeia will undertake an Environmental and Social Due Diligence (ESDD), as part of its corporate ESMS, to assess operations against the Performance Standards and EHS guidelines 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: Hygeia 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. IFC appointed an independent specialist to assess Life and Fire Safety in all of Hygeia’s facilities and the proposed facility. Hygeia will be required to implement all the recommendations from the specialist both for the existing and proposed health care facilities.



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



Grievance Mechanism: Throughout the Lagoon Hospitals 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 Communications 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 Directors. 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 director investigates and is obliged to report, any medical complaint to the CEO; and medico-legal complaints are reported to the Legal department. The process entails responding to the complainant and the hospital retains a copy for filing.

Working Conditions and Management of Worker Relationships



HR Policies: Hygeia 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 are consistent with the national labour laws in Nigeria. 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. 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. All expatriate contracts are reviewed and approved by the Nigerian Ministry of Labour.



Freedom of association and grievances: Hygeia respects employee Freedom of Association, and does not prevent employee union membership. 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: Hygeia has established a Code of Conduct for all employees at Lagoon Hospitals, which 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 behaviour, workplace safety hazards and medical negligence through the CEO’s office.



Occupational Health and Safety: Hygeia has fully functional Occupational Health and Safety policy procedures in place which are managed by the HSE Committee. 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 HSE officer is responsib
le 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. For any incident occurring on the premises, the employee is referred to the clinic’s casualty for primary treatment. Incident records are kept both with the Health and Safety officer and Human Resources.



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. Lagoon 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. Personal protective equipment (PPE) is supplied to all hospital personnel, is strictly enforced, and (depending upon the job description) includes eye, face, hand, body and head protection.

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 Nigeria, and water is obtained from the Water Authority. Hygeia ensures that water 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 utilised for drinking or medical use is passed through chemical filters.



Hygeia aims to implement energy and water conservation principles in its operations. Energy usage is primarily associated with air-conditioning, IT infrastructure and lighting. Solar water heating and grey water systems will not be incorporated into the design of the new premises; however the orientation of the building will be optimised for energy efficiency. Energy efficient light bulbs, energy efficient air conditioners and appliances will be installed where possible, and the building will be built with sufficient insulation. Greenhouse gases emissions associated with the project are not expected to exceed 25,000 t CO2 eq/year.



Due to power crisis in Nigeria, the company has diesel generators at all its facilities for the frequent electrical disruptions. In addition, UPS units are used for emergencies as they provide immediate back-up. The diesel generators and fuel tanks are bunded on a concrete floor with drainage and a sump.



Hazardous and biomedical waste management: Hygeia 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 waste 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 designated collection area of each facility, where it is sorted and ready for collection. Hazardous waste, such as mercury and laboratory waste, is generated in very small amounts and stored until such time as the registered collection comes to collect for disposal.



Hygeia implements a waste management plan at all of its facilities. These 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 environmen
t. 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, HNL must ascertain if licensed disposal sites are being operated to acceptable standards.



Effluent management: At Hygeia, effluent is discharged to the municipal works. Sewage from offices and hospital is connected directly to the municipal sewer and is treated at the waste water treatment works.



Pest Management: Government health authorities spray the Hygeia premises for pests’ control. An external contractor handles rodent control.

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. Safety personnel are trained in emergency and LFS procedures, and coordinate any (non-medical) emergency. Hygeia has employees who 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. Safeguards are in place in the form of smoke detectors, alarms, sprinklers, access to fire extinguishers and hoses at regular intervals throughout the building and alternative escape routes.



However, some operational aspects at the company’s existing hospitals and clinics fall short of meeting the acceptable international life and fire safety standards. The company is experiencing problems with proper maintenance of smoke detection and alarm systems. IFC appointed an independent specialist to assess Life and Fire Safety in all of Hygeia’s facilities and the proposed facility. As the condition of IFC’s investment, Hygeia will implement an improvement plan to address identified deficiencies and bring the existing facilities in compliance with good international practice.



New wings and standalone hospital buildings to be built or undergo major renovation as part of IFC’s project will comply with acceptable international life and fire safety standards as specified in the section 3.3 of the WBG’s General EHS Guidelines.



Structural Safety: Every Hygeia facility typically undergoes regular Infrastructure Safety and Security audit. The audit is conducted by a team of fire officers, biomedical engineer and facility manager. The company has developed audit checklists for this purpose. For instance, the fire safety audit checklist covers 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 Hygeia facilities will be evaluated by a structural engineer and certified to be in compliance with national Building Codes and Regulations. This requirement is defined in the ESAP.



Food safety: Lagoon hospitals include a kitchen for the supply of patient meals. Hygeia 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, 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 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: Hygeia 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 team, a multidisciplinary advisory body, chaired by a Senior Pathologist/Microbiologist. The hospital 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 or any other agency as deemed fit by the Infection Control Team.



Security Personnel: Security personnel/watchmen are employed by the hospital facilities, and are stationed at all entrances/exits. Security SOPs govern their responsibilities and are reported to the Head of Section. Security personnel are trained in-house on security and LFS. CCTV cameras are positioned around the facilities, and are monitored by security personnel in a central control room.



Vehicle/Driver safety: Hygeia has vehicles such as staff van, delivery vehicles and ambulances
. Vehicle drivers are licenced and their performance is closely monitored by their supervisors. Spot checks ensure that vehicles are kept clean and orderly. Traffic in and out of the Ikeja Hospital and VI clinic is of concern with insufficient parking spaces for patients and a prevalent of traffic hazards. The company will implement appropriate traffic management plans to address the issue.

Hygeia 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 Hygeia projects team to include E&S 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 local newspaper informing the public that the ESRS and ESAP are available for review.

In Nigeria the ESRS can be reviewed at Hygeia offices at the following address:
Hygeia Nigeria Limited
8 Marine Road
Off Liverpool Road
Apapa, Lagos
Any queries and/or comments about the project may be directed to:Lanre Tunji-Sanusi
+234 1 631 3803
mailto:lsanusi@hygeiagroup.com

Broad Community Support is not applicable for this project

Hygeia 2014(36007) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Prepare a LFS program with proposed completion dates in accordance with recommendations of LFS specialist	19-Oct-2015	Completed	Completed	10/1/2015
Implement an improvement LFS program	19-Oct-2015	Completed	Completed	12/8/2015
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.	19-Oct-2015	Completed	Completed	9/30/2015
Develop a Traffic Management Plan for vehicle movements from the hospital off and onto public roads and within all facilities.	19-Oct-2015	Completed	Completed	9/15/2015