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
PS5: Andela currently leases all space for campuses and staff accommodation in buildings located in urban areas. Current plans for expansion do not include purchase of land.

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not relevant as the project sites are located in modified urban or sub-urban neighborhoods or agricultural areas and there is no impact on biodiversity.

PS7: Indigenous Peoples does not apply as Indigenous Peoples are not present at project sites.

PS8: Cultural Heritage is not expected to apply as there are no known cultural heritage sites or issues associated with existing premises and are not expected for future developments.

The project has been categorized as Category B according to IFC’s Environmental and Social Review Procedure. The nature of the company’s operations, which involve the provision of educational and IT services, is such that adverse environment and social (E&S) risks and impacts are limited, site specific and may be readily mitigated. Key environmental, social, health and safety issues associated with the project during include: the sponsor’s system to manage E&S issues during site selection, design, construction and operation of schools, land acquisition issues if they become relevant; labor and working conditions; life and fire safety design and provisions; resource efficiency; and community engagement.

The project may result in a limited number of specific adverse environmental and social impacts that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The company will manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC’s Sustainability Framework and World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines.

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:

Andela has many of the components of an ESMS in terms of its policies and procedures relating to energy efficiency, water efficiency, equal employment, which it communicates through email and/or posted on campus. Andela takes care to comply with all national, state, and local government regulations across all aspects of its business. As outlined in ESAP Action 1, Andela will develop a documented ESMS to assess, manage, and monitor key E&S risk, commensurate with the scale and focus of its business operations, including formalizing its existing efforts to address and mitigate key E&S risks. As the company looks to expand its operations to new locations, the ESMS will also incorporate policies and procedures to identify E&S risks around site selection, building standards and fire safety design, construction management, and if relevant, land acquisition.



Management Programs:

The company has an energy conservation plan which is posted in common areas which highlights optimal times when certain appliances can be used. It also has a fully budgeted maintenance plan that focuses on weekly, monthly, quarterly and bi-annual E&S management issues including maintenance of the fire safety infrastructure and fire drills.



Organizational Capacity and Competency:

The Andela management team consists of entrepreneurs, and education and technology professionals who have successfully built the business in Nigeria. The team and its staff manage the E&S issues at its facilities in Nigeria. From this platform, the management team will recruit appropriately qualified local staff to replicate this model as the company grows across Africa. The local and corporate teams will be responsible for ensuring that the ESMS is implemented and local teams will be required to report regularly to management.



Emergency Preparedness and Response:

Andela has an informal emergency response policy and communicates with its Fellows and employees by email regarding specific situations, such as the recent Nigerian presidential election and the recent Ebola outbreak. Staff talked extensively with Fellows outlining the company’s policy on handling and treating Ebola. As outlined in ESAP Action 1, the emergency preparedness and response policy will be formalized in the ESMS.



Monitoring and Review:

Currently, the company is small and monitoring and review of compliance issues is handled informally. With the expansion of the company, the ESMS (ESAP Action 1) will adopt procedures to ensure that key E&S indicators are monitored and reported internally.

Andela has 110 full-time employees and 10 part-time employees. The full-time employees consist of 14 staff in its New York office, 16 staff in its Lagos facilities, and 80 full-time Fellows. Andela’s part-time employees include cleaning staff, a driver, and cooks. Andela has also employed 15 consultants who serve as mentors and peer programmers for its Fellows—of which 10 mentors work remotely and are located internationally and 5 mentor/peer-programmers are located in Lagos.



Working Conditions and Management of Workers Relationship:



For its New York-based employees, Andela outsources its HR function to cloud based professional employer organization for small and medium sized businesses to manage all aspects of HR including healthcare, employee handbook policies, etc. For Fellows in Lagos, Andela has a Fellows Handbook that outlines details of their employment such as time-off, weekly recurring meetings, housing policies, “Equality, Non-discrimination, Drug-free Workspace”, “Code of Conduct” and leave. The Handbook can be readily accessed through Andela’s intranet. As outlined in ESAP Action 2, Andela will extend its HR policies and procedures to all staff working across Africa, reflecting the requirements of PS2 and national law and will provide an employee handbook to all staff indicating their working conditions and terms of employment.



Currently, while approximately 10% of applicants are female, 20% of the Fellows Andela has employed are female. Management tracks and actively tries to move toward 50% female Fellows by running all-female cohorts of its Boot Camp and Fellow training. Andela’s first all-female Boot Camp received 1,137 applications from young women around Nigeria, it accepted 25 women to attend, and asked 8 women to join as Fellows. Furthermore, Andela is currently devising a budget to dedicate resources for recruiting and increasing the number of women in its Fellows program.



Andela has an unwritten internal policy to only hire adults as employees and accept only adults as Fellows as defined by Nigerian law, which lists adults at 18-years of age. Currently its youngest Fellow was 21-years old at acceptance. As outlined in ESAP Action 2, this policy will be formalized in the HR policies of all staff.



Andela allows employees and Fellows to freely associate and Fellows have formed a Student Council at the Amity campus which raises issues with staff, organizes social events, and negotiates policies on residential life at Amity. Fellows have clear avenues and procedures to raise grievances, which the company outlines during the onboarding process and are available for reference in the Fellows Handbook. This includes set times every month when Fellows can raise issues with the management team in Lagos and in New York (“Ask the Directors” meetings). In addition, Fellows can anonymously submit questions to staff through a question bank. All Fellows have direct access to senior management.



The company w
ill upgrade its HR procedures to enable employees to anonymously raise issues, as outlined in the ESAP Action 2.



Occupational Health and Safety (OHS):

If Andela’s expansion plans include construction of new campuses, the company will ensure that all contractors are required to comply with the national OHS requirements and those outlined in the WBG General EHS Guidelines (ESAP Action 1).



Workers Engaged by Third Parties:

Aside from security guards, the company does not employ workers through third parties.

Andela has procedures relating to energy efficiency, particularly given the lack of reliable public electricity. The company has both a diesel generator and an inverter with back-up battery. Its energy conservation plan is posted in common areas, such as kitchens, and highlights optimal times when certain appliances can be used.



The company emphasizes water conservation, educating staff and students about resource conservation, particularly as the Amity campus relies on its own pumped well with accompanying storage tank. Potable water is provided through filtered water dispensers. As outlined in ESAP Action 1, water will be monitored monthly and Andela will only provide potable water to employees and students that meets the standards of WBG General EHS Guidelines.



Effluent is discharged into the public sewer.



The company contracts with a waste management collection company that is approved by the Lagos State Waste Management Authority. The company also has a recycling program.

Andela’s facilities meet all national and local building codes and regulations. The company management aims to select locations for its campuses to be safe and in a physical condition in-line with international standards. Andela also takes substantial precautions for fire safety, and it has certificates from the local authority, verifying that it has met the local fire safety standards. Andela is responsible for maintenance of the fire safety system. There are smoke detectors in every room that are checked monthly and readily accessible fire extinguishers throughout its facilities. Each fire extinguisher has been labeled with its last date of inspection and the next expected date of inspection. The company holds fire drills twice a year, has appointed an internal Fire Marshal for each floor, and has a clearly designated muster point in case of an emergency. In case of any greenfield construction in future they shall comply with the life and fire safety section of General EHS Guidelines as outlined in ESAP Action 1.



The company has a contract with a professional security company to provide security and guards at both its Amity and HM building. Guards go through a two-week training process taught by instructors from the Nigerian Police, Nigerian Army, fire service professionals, and medical professionals. The training covers: ethics & company code of professional conduct, communication, fundamental human rights and concept of democracy, professional image, basic first aid, firefighting techniques, and other security related fields (arrest, investigation and detention, access control, etc.). None of the guards are armed.

Andela’s main stakeholders are Boot Camp participants and local communities. The company solicits constant feedback from participants to improve the quality of the Boot Camp experience. Should any grievances arise from local communities, they will be handled by company management in Lagos.

The ESRS and ESAP will be made available on the Andela website: http://www.andela.co
Enquiries can be made to:
Jeremy Johnson
79 Madison Ave New York, NY 10016, New York, USA
(888) 472-5913
mailto:jeremy@andela.co

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Andela will develop an E&S management system that formalizes existing practices and procedures to assess, manage and monitor E&S risk related to current operations, including emergency preparedness and response; and for expansion, including site selection and building standards. The company will include policies and procedures to ensure that all contractors are required to comply with the national OHS requirements and those outlined in the WBG General EHS Guidelines; potable water will be tested monthly and the company will only provide drinking water that meets the WBG General EHS Guidelines; and in case of any greenfiled construction in future they shall comply with the land acquisition reqirements of PS5 as well as the life and fire safety section of WBG General EHS Guidelines.	12/31/2015
Extend the HR policies and procedures reflecting national law and including a formal policy to hire only adults and an anonymous grievance procedure. Provide an employee handbook to all staff in all locations, including their working conditions and terms of emplyment.	09/30/2015