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 SPV will target acquisitions of strategically located businesses with facilities situated in cities 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 the project. However, prior to any land or asset acquisition, the SPV will conduct an environmental and social due diligence (ESDD) to ensure that risks and impacts, if any, will be adequately identified and managed in a manner compliant with local regulations and consistent with the IFC’s Performance Standard 5: Land acquisition and Voluntary Resettlement.

The project 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 potential environmental, health and safety issues associated with the healthcare sector include: i) adequacy of environmental and social assessment and management systems; 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.

Identification of Risks and Impacts

Prior to the acquisition or establishment of any business, the SPV will undertake an Environmental and Social Due Diligence (ESDD) to adequately identify EHS risks and impacts and support the design of reasonable measures directed at addressing such EHS risks and impacts, assess operations against local and IFC’s requirements, and develop an action plan to ensure compliance if necessary. These actions are defined in the attached ESAP (ESAP #1).

Organizational Capacity

The SPV will have no employees but will have a permanent board of directors (“SPV Board”) with representatives from Falck, IFC and IFU. The SPV Board will be the decision-making body responsible for assessing the risks and recommendations derived from the ESDD process. The SPV Board will instruct Falck under a management services agreement (“Falck MSA”) to manage and operate the SPV as well as to manage, operate and/or monitor the businesses that the SPV acquires or establishes. Under the Falck MSA, Falck will be responsible for appointing an appropriately qualified employee or consultant (“EHS Manager”) to monitor and report on matters relating to Environment, Health & Safety (EHS), labor and community relations during acquisition and operations, in all major acquisitions and greenfields. This person will also be responsible for recommending to the SPV Board for decision, the steps or actions regarding EHS aspects of the businesses acquired or established by the SPV as well as implementing the conditions of the ESAP (ESAP #3). The technical team working for the project will be initially based in the Falck Head Office (Copenhagen). Other positions in the organization will be filled as the project evolves.

Environmental and Social Management Policies and Systems

Falck has a corporate risk management approach, which is reported and monitored at Board level. Falck has also developed and demonstrated its expertise in managing clinics over the years and is recognized for its experience. Falck has quality management systems (“QMS”) that comply with international certifications such as ISO 9001, and which are integrated into the operations of all the clinics that are under their management. All current clinic facilities meet local legislative requirements and utilize detailed operational manuals, 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.

Falck’s Environmental Policy states that Falck aims to (i) reduce power, water and heating consumption; (ii) reduce fuel consumption as well as air pollution and wastewater discharge; (iii) use environmentally friendly technologies, work processes, substances and materials in connection with new purchases and when restructuring existing work processes; and (iv) aim for a high rate of recycling and the lowest possible environm
ental impact in connection with waste handling.

Falck’s approach, QMS and Environmental Policy, together with other Falck corporate policies, form a broad policy framework that impact all its activities. Falck will play a specific role to ensure that such an approach will apply to the businesses that the SPV will acquire.

Falck Medycyna (a Polish subsidiary), which was visited to evaluate the implementation of Falck’s corporate policy and procedures on a country-level, consists of a network of 22 medical centers, 12 on site (corporate) clinics, 63 ambulance stations, 4 dispatch centers and 7 regional offices, and employs approximately 2,700 people. The subsidiary has its own Board of Directors, a Medical Director in addition to an Operational Director of Healthcare who both report to the Board.

During the site visit to Falck Medycyna, it was clear that the clinics were well run, clean and modern, with very strict administrative and clinical procedures in place, which are monitored by Falck. Falck Medycyna has a Quality Management System (QMS) which is certified to ISO 9001. The application and effectiveness of the Falck policies and practices within the Falck Medycyna network of clinics may be demonstrated through their high levels of patient subscriptions, low OHS incident rate, energy efficiency, water and wastewater discharge quality and life and fire safety (LFS) management systems which are in place.

The SPV will develop a policy directing the businesses it acquires or establishes, to design and implement a Management System to address environmental and social aspects, in accordance with the relevant IFC Performance Standards and the WBG EHS Guidelines. The program of implementation will be determined by the SPV Board as part of their long term strategy, and be accompanied by the allocation of appropriate resources and training. This is articulated in the ESAP (ESAP #2). The SPV will monitor environmental matters at the acquisition stage (through the ESDD process) and during operation. These may include adopting measures to minimize environmental impacts, specifying requirements for contractors on EHS, conducting public consultation and providing information to project affected communities.

Emergency Preparedness and Response

Falck applies quality procedures for facility fire prevention, emergency response and evacuation, tailored to the particular environment in which the company operates. As Falck has proven experience in providing customized services in these areas, the SPV will ensure that, as part of the Falck MSA, Falck will also provide support for applying its quality procedures as well as training to employees of each acquired business on such areas.

Monitoring and Review

The SPV Board will, at the intervals that it decides, order quality assurance audits (taking into account applicable local requirements and other relevant standards and objectives as already explained), and design (with the assistance of Falck, via th
e MSA) the appropriate plans to correct any performance issues. During construction/renovation of projects, contractors will be required to provide regular Environmental, Health and Safety (EHS) monitoring reports to the EHS Manager, who will ensure adherence to local regulations and the policies of the SPV. Any material non-compliances, serious social or environmental incidents and/or accidents that may impact upon the businesses’ reputation or productivity will be reported to the SPV Board and the IFC, IFU and Falck.

Human Resources Policy

Falck has a Labor Standards Policy, Business Ethics Policy and a Code of Conduct that guide the organization’s management of employees and contractors. It covers areas as human rights, labor standards, the environment, and the fight against corruption. Falck takes into account local legal requirements concerning minimum wages, overtime compensation, sick leave etc. and ensures that the working week is in accordance with the local regulations. Typically, employees are entitled to, at least, one day off per week, are given reasonable breaks while working and have sufficient rest periods between shifts, while overtime is voluntary, infrequent, and paid in accordance with local norms and standards. The use of child labor is not tolerated in Falck. Similarly, Falck does not engage in or support the use of forced labor. Falck does not prevent employees and other workers from associating freely with any lawful worker’s association or collective bargaining association of their choice, and does not discriminate on the base of sex, race or religion. Finally, Falck does not tolerate any form of corruption including extortion, fraud or bribery.

The SPV will prepare a generic Employee Handbook in accordance with Performance Standard 2, as the tool to communicate and implement relevant policies governing HR. The handbook will include a grievance mechanism for all employees and contractors. All acquired and established businesses will customize the Handbook to comply with local human resource regulations within their jurisdictions, and the SPV will monitor whether the above practices are communicated, performed and followed by such businesses. This appears as a requirement in the ESAP (ESAP #4).

Occupational Health and Safety:

Falck has an Occupational Health and Safety Policy that states its commitment to supporting health and safety management system on site. As previously mentioned, it is envisaged that, within reasonable time the SPV will establish a Management System, which will include occupational health and safety policies and practices, with the intention of rolling it out into the businesses acquired or established and controlled by the SPV. Significant emphasis will be placed on the prevention of injuries and safety incidents within acquired businesses and their contractors by motivating, educating and involving employees in occupational health and safety at work.

HIV/Aids program:

As the SPV will be operating in the healthcare sector, in a region which has a high incidence rate for HIV/Aids and other communicable diseases, the SPV will formulate and implement an HIV/Aids Policy, utilizing the IFC’s Good Practice Note “HIV-AIDS in the Workplace” (ESAP #5). The Policy is expected to incorporate an awareness raising program for employees and patients, which, for example, could include educating all staff in acquired businesses on prevention, treatment and management of HIV and associated diseases.

Potential issues during the operational phase of any 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.

For each business acquisition or establishment by the SPV, the learnings from the ESDD process are expected to drive the potential need for an EHS action plan encompassing potential risks, mitigation measures, monitoring parameters and implementation responsibilities.

The local businesses will have operational responsibility to procure water and electricity from municipalities as well as clinical equipment and other items such as diesel generators, which generally act as the back-up system in Africa. All infrastructure and equipment relating to on-site energy generation, waste water treatment, and water purification is expected to be aligned with the requirements outlined in the WBG EHS Guidelines.

Falck typically implements a waste management plan at all of its facilities, to include all forms of waste generation, storage, handling and disposal. The plan typically 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. This approach will also be followed by the SPV with respect to its acquisitions and appropriate to the findings of the ESDD process. This is specified in the ESAP.

As part of the SPV’s monitoring of the businesses that the SPV acquires or establishes, it will ensure, to the extent that is possible, that natural resources are utilized and conserved. The Management System that will be implemented will therefore include monitoring parameters for water quality, water consumption, energy consumption, waste and waste-water volumes and quality, waste-water treatment and discharge, which will be reported annually via the SPV to the IFC, IFU and Falck, as part of the Annual Monitoring Report (AMR).

Emergency Preparedness and Life and Fire Safety

As part of the ESDD in connection with each new acquisition by the SPV, the SPV will perform a review of the Life and Fire status of all facilities of the target business. To perform this review, the SPV could draw from a pool of fire safety professionals in Falck (as it is a company leader in the implementation of fire safety services). The ESDD process will try to assess the level of compliance by the target business with local building fire, and legal/insurance requirements, as well as with internationally accepted LFS standards. Depending on the findings, the SPV may draw up an LFS plan to implement relevant corrective measures on the facilities. This is articulated in the ESAP (ESAP #1).

Emergency preparedness plans are usual practice for facilities operated by Falck, and these plans include LFS plans. The SPV intends to promote and facilitate training by the acquired or established businesses for security personnel in emergency and LFS procedures, including the safe evacuation of patients in case of fire.

Community Exposure to Disease

The SPV expects to allocate responsibility to its local subsidiaries to report on communicable diseases and follow exposure control procedures to minimize the risk of transmission to health care workers, patients and others. A Policy and associated procedure will be formulated by the SPV to guide its subsidiaries on how to respond to any epidemic or suspected bioterrorism event.

Security Personnel

The businesses acquired or established by the SPV will likely outsource security services to a professional security services company, with the appropriate accreditations and training.

As part of the ESDD for each acquisition or greenfield establishment, the SPV will assess the specific needs for security measures, which could include developing and implementing a Security Management Plan (SMP), secure training provision for security staff, security access control for clinical staff etc. (ESAP #6)

Vehicle/Driver safety

Falck has a long history with ambulance and emergency services, training of drivers, maintenance of vehicles and performance monitoring.

To the extent that this becomes relevant for the businesses acquired or established by the SPV, the SPV will be able to draw from Falck’s experience to establish vehicle safety management procedures.

Falck is a value-based organization, whose values are embedded in its corporate promise, “Here to help”. Falck employees are encouraged to volunteer their time and resources for community work, search and rescue work, and donations of goods or services. At times, they also perform activities to raise awareness of medical emergency intervention. Falck prioritises collaboration with local authorities, professionals, business partners and other stakeholders wherever it operates, to improve quality and efficiency and invest in training and development of employees. The SPV will ensure that affected local communities, if identified, are engaged via a communication process and grievance procedure.

Falck Danmark A/S
​​Polititorvet
DK-1780 Copenhagen VTel.: +45 70 33 33 11
Fax.: +45 33 15 29 57 
mailto:contact@falck.com
 
 CBR: 16271241
​​

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
The SPV will conduct an environmental and social due diligence (ESDD) of all new healthcare businesses before acquisition or greenfield establishment, with the purpose of adequately identifying EHS risks and impacts. Where the ESDD identifies gaps with reference to the relevant IFC Performance Standards and the WBG EHS Guidelines, the SPV will develop an action plan in agreement with IFC to work towards a reasonable implementation of the specific agreed measures directed at addressing such EHS risks and impacts.	01/30/2017
The SPV will develop a policy which will require all the businesses it acquires or establishes to develop a Management System to address environmental and social aspects in accordance with IFC’s Performance Standard 1 and the WBG EHS Guidelines, with the appropriate allocation of resources and training. The SPV Board will determine the implementation program as part of each business’s long term strategy, and report annually on progress.	09/30/2016
The SPV will appoint a qualified person (employee or consultant) to manage matters relating to Environment, Health & Safety (EHS), labor and community relations during acquisition and operation of acquired businesses, where the SPV will exercise management control. This person will either be appointed by the SPV or by Falck (as a member of the Falck MSA team). This person will monitor compliance with statutory requirements and pursue the incorporation, over time, of the relevant IFC’s Performance Standards and the WBG EHS Guidelines. This person will also coordinate reporting on such efforts to the SPV Board.	09/30/2016
The SPV will prepare a Human Resources handbook, consistent with local requirements and IFC’s Performance Standard 2, to be implemented by the businesses it acquires or establishes. The handbook will include a grievance mechanism for all employees and contractors.	09/30/2016
The SPV will prepare an HIV-AIDS Policy, incorporating an awareness and prevention program to be implemented by the businesses it acquires or establishes, in line with the IFC’s Good Practice Note “HIV-AIDS in the Workplace”. •	01/30/2017
The SPV will develop and implement a Security Policy and, where appropriate, ensure the development of a Security Management Plan (SMP) for project site operations, consistent with the requirements of IFC’s Performance Standard 4.	01/30/2017