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 majority of land plots have been rented by SIS. Land owned by the group has been acquired through willing buyer-willing seller transactions and did not result in any physical or economic displacement. The group is planning to mainly lease land plots and, thus, PS5 was not found applicable. SIS is focused on developed urban areas, and it is therefore highly unlikely that issues related to biodiversity conservation, indigenous peoples or cultural heritage will arise. Going forward, prior to any lease and/or acquisition, the group 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 IFC’s Performance Standards 2-8.

Based on information reviewed by IFC this proposed investment is expected to have limited environmental and social impacts which are likely to be site-specific and not significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria, as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy.

Key environmental and social (E&S) issues associated with this project include: assurance of health and safety of students and staff through proper design and operation of the buildings; sound management of environmental, health and safety matters during construction; assurance of fair labor conditions for the company’s personnel and third-party workers; and on-going stakeholder engagement.

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

In accordance with the national legislation the Environmental Impact Assessment (EIA) is not required for any of planned schools. Selection of sites by SIS is based on two principal criteria: ease of access (in terms of distance, travel time and traffic conditions) and secure and healthy surroundings. Going forward, in accordance with the ESAP SIS will strengthen its current approach and develop a checklist to screen for adverse E&S impacts (for both construction and operation phases) while leasing/acquiring new land and developing design for its new schools.



In order to identify risks related to safety and security of its existing schools SIS hired Bravo One, an external consultancy firm, which reviewed all SIS facilities in 2014 and 2015. Further details are provided in PS 4 section.



Environmental and Social Assessment and Management System

Key principles in respect to management of environmental and social risks are incorporated into a group academic staff handbook. In addition, in order to further strengthen its E&S risk management framework the group has developed various procedures including but not limited to emergency response (including earthquakes), security and closed-circuit television (CCTV), cleanliness (including waste management), resource efficiency and accidents management procedures. Furthermore, health and safety program is being developed and implemented on semi-annual basis.



While the current E&S management system is sufficient for the group to manage its key operational risks posed by the existing school operations, it could be further strengthened to support due diligence and construction process of new schools as referred to above. EHS objectives have been defined by the group already and SIS should formalize these in a corporate Environmental policy.



Management and Monitoring Program

External experts are contracted for the development of design documentation (e.g. sections on life and fire safety, heating, ventilation, water supply and sewage). In accordance with the national legislation the project developer is responsible for the submission of design documentation to the state committee for review. Based on the review, a building permit is issued to the project developer. In accordance with the local requirements all facilities have mandatory permits.



Considering construction works, SIS will develop environmental, health and safety manual for construction activities to ensure compliance with World Bank Group (WBG) General EHS Guidelines for construction activities. Such manual will be included in tender documentation for construction works and implementation of the manual will be supervised by SIS.



Furthermore, SIS will ensure that standard environmental control and resource efficiency measures are introduced in schools’ design to satisfy Performance Standard 3 requirements. The group will also impose internationally recognized life and fire and seismic protecti
on requirements to new schools/facilities (more details are provided in Performance Standard 4 section).



Organizational Capacity and Competency

Operational environmental risks and impacts of the group activities are limited. To provide continuous management of the environmental and safety matters, the company has nominated responsible staff on both corporate and school level and similar approach will be followed for all schools once in operation.

HR policies and procedures

Currently, the group employs approximately 540 employees, approximately 40% of SIS staff are local. The group plans to hire 100% local staff for new schools to be operated at the Tier B schools. In addition, SIS outsources approximately 50 workers including cleaners, security staff and drivers.



SIS has developed and implemented various HR policies and procedures for its staff which are mainly aligned with Performance Standard 2 objectives. While some HR documents are applied to all staff, the majority of HR procedures have been developed separately for local and international staff as well as academic and non-teaching staff. Company Regulations which incorporate HR general policy and employment terms for all staff are cross-referenced with the national Labor Code. All local and international employees receive staff handbooks. Individual contracts are provided to SIS staff and information on staff terms and conditions is presented in contracts. The school operates five days a week, 9 hours a day (7:30 to 16:30 with one hour provided for lunch, rest and prayer and provision of an extended break for prayer on fridays). Expatriate teachers are offered a standard contract that includes salaries, benefits (including visa/employment permits, medical cover, housing, access to loans, annual return flight home and performance bonus).



The group has developed a grievance mechanism for all staff which specifies grievance management procedure, however the procedure doesn’t address submission of anonymous grievances.



Although SIS doesn’t prohibit its local employees to join trade unions, its procedures don’t specify this opportunity. National legislation doesn’t provide clear guidance regarding eligibility of expatriate workers to join national unions.



In order to meet requirements of Performance Standard 2, SIS should upgrade its existing procedures. In accordance with the ESAP, SIS will align a group level HR policy with Performance Standard 2 in respect to non-discrimination and equal opportunity, ability for the submission of anonymous grievances as well as ability to form and/or join staff association or labor union.



Occupational health and safety

Various types of chemicals are used in the laboratories in the schools. Laboratories are equipped with emergency shower and storage of chemicals was found to be satisfactory during the visit.

IEN Consultants with headquarter office in Singapore reviewed resource efficiency of SIS schools with focus on Palembang school (which will be replicated as described in the project description section above). In accordance with the review, electrical energy consumption is 4-5 kWh/person/day and water consumption is 30-50 litres per person per day. These results do not exceed publicly available benchmarking data for schools. SIS will continue regular monitoring of electricity and water consumption and results will be compared across all SIS schools on a regular basis.



Each school is equipped with back up diesel generator to provide energy in the case of blackouts associated with the grid. Air emissions are associated with the periodic use of the generators. These generators are tested periodically and maintenance is contracted to an outside party.



The development of new schools under this IFC funded project will not result in more than 25,000 tonnes of CO2-equivalent emissions per year from these operations.



Potable water for the existing schools is purchased. Similarly, the group will purchase potable water for its new schools.



Food for SIS students is supplied by outsourced companies and none of SIS schools is equipped with food processing and cooking equipment. Therefore, wastewater is limited to sewage mainly and food waste generation is minimal.



Some schools are connected to existing municipal/real estate sewerage system where wastewater from these schools is discharged into. Schools located in areas where such sewage system is unavailable are equipped with septic tanks.



Solid waste from schools is collected by the contractor for further treatment and disposal.



In accordance with the ESAP and as described in PS 1 section, SIS should ensure that minimal environmental design criteria aligned with WBG EHS General Guidelines will be incorporated in design of new SIS schools (e.g. installation of oil traps for schools where dishwashing (if any) to be conducted and usage of zero chlorofluorocarbon cooling systems).

Community Health and Safety

The group follows local fire safety regulation across its schools. Regular trainings including fire drills are planned and conducted by SIS. In 2014 SIS contracted Bravo One, an external specialized consultancy company, which conducted risk-based security and safety review (360 degree review safety program) of all SIS facilities. The scope of fire safety assessment included review of means of escape, fire detection and alarm systems, firefighting equipment, emergency lighting, signs and notices, fire action notices, evacuation assembly points, and final exit doors. Based on review’s findings a corrective action plan was developed, major part of which has been implemented already and SIS will continue its cooperation with external consultants to ensure ongoing management of life and fire safety risks.



New educational facilities, to be developed or significantly renovated/modernized as part of IFC project, shall be designed, constructed and operated in full compliance with local building codes, local fire department regulations and, as a requirement of the IFC PS, be consistent with good international industry practice in life and fire safety; structural safety; and, to the greatest extent possible, universal access.



To confirm compliance with IFC’s PS requirements, certification by suitably qualified professionals shall be conducted at the design stage of the project and after construction conforming compliance with the WBG General EHS Guidelines for Life and Fire Safety and International Building Code for seismic requirements (when situated in high-risk locations).



In compliance with regulatory requirements a Fire Preparedness and Response Plan has been developed for the existing schools. In addition, an emergency response plan should be developed for each facility funded out of IFC proceeds. The plan will address different emergencies including earthquakes, fires, disease outbreak, and other large scale emergency situations.

Some schools offer transportation services for students which are typically provided by external licensed transportation companies.



Except Palembang, Kebon Jeruk and Cilegon campuses, other SIS schools are guarded by outsourced licensed security guards. Security guards (both outsourced and direct employees) do not possess arms and there have been no incidents of conflict with community. Security personnel (both outsourced and direct employees`) are trained to manage entry and exits, parking areas, assist in emergency evacuation and overall movement of visitors inside its facilities.

In accordance with national requirements local community needs to confirm its consent regarding new facilities by means of signing of community acceptance letter. Early announcement in local media of an intended establishment of a SIS school is made and intended location is clearly mentioned to address any community concerns in respect to the proposed site. Subsequently, prior to construction the group obtains consent letters from local communities in order to ensure compliance with national requirements. According to national legislation similar process will be followed for future SIS schools.

Although there are no communities expected to be directly affected by the project, SIS will develop an external grievance redress mechanism (see ESAP item) to address any concerns from communities in which schools operate.

Contact Person: Mr. Oliver Anderson
Company Name: SIS Group of Schools
Address: Jl. Bona Vista Raya, Lebak Bulus, Jakarta Selatan – 12440, Indonesia
Email: mailto:oliver@sisschools.org
Phone: +62 21 759 14414 
Facsimile: +62 21 759 144 24

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Upgrade the environmental and social management system (ESMS) to provide consistent oversight of environmental, health and safety practices for its operations: (i) Environmental and social (E&S) Policy; (ii) Set of environmental and social minimum requirements (site selection and design preparation processes), including but not limited to, requirements on land acquisition in compliance with Performance Standard 5. Environmental and social assessment should be conducted for school sites prior to land acquisition/leasing to evaluate any potential past contamination and/or other limitations for development (e.g. potential impact on local community during construction and operation); (iii) set of environmental and social minimum requirements, stipulating standard control measures and specifications on resource efficiency to be adopted into schools design in compliance with Performance Standard 3; (iv) environmental, health and safety manual for construction activities.	10/01/2016
Develop an external grievance redress mechanism aligned with Performance Standard 1 requirements to address any concerns from communities in which schools operate.	06/01/2016
Develop a group level HR policy for all employees regardless of nationality or job role. The policy should specify principles aligned with performance standard 2 requirements in respect to non-discrimination and equal opportunity, ability for the submission of anonymous grievances as well as ability to form and/or join staff association or labor union (providing that SIS will not discourage workers from forming or joining working organizations and will not discriminate against workers who participate or seek to participate in such organizations in accordance with Performance Standard 2 requirements).	06/01/2016
Engage a suitable qualified L&FS expert acceptable to IFC to develop L&FS Master Plan in full compliance with the national and locally applicable L&FS requirements as well as IFC requirements as specified in the WBG General EHS guidelines (section 3.3), provided they do not contradict Indonesian law, to be applied to new schools/facilities developed as part of IFC project.	07/01/2016
Provide certifications from the qualified expert (contracted as per action above) that (i) new schools financed with IFC funding are designed in full compliance with national and locally applicable L&FS requirements as well as IFC requirements as specified in the WBG General EHS guidelines (section 3.3), provided they do not contradict Indonesian law; and (ii) schools (re) construction faithfully incorporates all element of the L&FS Master Plan and detailed engineering design.	07/01/2019
Engage qualified expert acceptable to IFC for schools to be located in highly active seismic zones to certify structural elements to meet the requirements of Performance Standard 4.	07/01/2019
Develop an emergency response plan for each new school financed with IFC funding. The plan will address different emergencies including earthquakes, fires, disease outbreak, and other large scale emergency situations.	07/01/2019