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
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The company’s campus is located in a developed urban area therefore issues related to biodiversity conservation (PS6), indigenous peoples (PS7) or cultural heritage (PS8) are not relevant.

Eurasia’s proposed project is classified as a Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability. The project is expected to have limited and manageable environmental and social impacts, with none expected to be 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.

Key environmental and social issues and risks associated with new building construction and existing building refurbishment, and university activities in general, include: (i) labor practices and working conditions; (ii) resource efficiency improvements (mainly energy and water use); (iii) pollution control and waste management; and (iv) life and fire safety (LFS) management, including emergency preparedness and response to ensure alignment with good practice.

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

Eurasia has most components of an Environmental and Social Management System (ESMS) in place that takes the form of a government-approved University Masterplan that includes the Green Campus Project setting out campus resource efficiency and LFS policy objectives, the Management System Collection of Eurasia University, Eurasia Occupational Health and Safety (OHS) Manual supported by a separate “task menu” of OHS procedures, a Fire Fighting and Emergency Evacuation Plan, and assigned environmental and social (E&S) management roles of staff. The University follows government procedures for building planning and approval as well as environmental management. Notably, the Green Campus Project contains specific resource efficiency targets and actions for energy and water conservation, as well as specifying the specific regulatory requirements and related activities for LFS. An environmental impact assessment (EIA) is required to be prepared by Eurasia for the project i.e., for the new building approval, and Eurasia is commissioning an independent specialist firm to do this.



The current (ESMS) can be strengthened by preparing and adopting a Stakeholder Engagement Plan incorporating a grievance redress mechanism for external stakeholders and additional LFS requirements. These additional measures are described in the follow paragraphs.



Identification of Risks and Impacts

In accordance with national legislation, a campus Masterplan was prepared by the University to plan the expansion of facilities over the medium to long term. The Masterplan sets out the layout of facilities and addresses LFS, and was approved by the Planning Bureau of Chang’An District, in 2000. The University is currently updating the Masterplan, incorporating the proposed project works, and will seek government approval in 2016/17. In addition, the proposed new research and academic building under the project is required to gain approval from various municipal government agencies (Environmental Protection Bureau, Safety Bureau, Fire Safety Bureau and Construction Bureau), including for LFS aspects. This requires an environmental evaluation to be undertaken by the Xi''an Environmental Protection Agency as per the Xi''an Environmental Protection Agency (EPA) Document, (EPA issue (2010) 232), and an environment assessment report prepared by the Xi''an Environmental Engineering Assessment Center (evaluation report of the city (Yanta District), 2010). The environmental evaluation and assessment referenced will be supported via the EIA that is being completed by the University for the new building. The project refurbishment works do not require further approvals as the original permits prevail.



Building refurbishment commences with the assessment of each building for renovation suitability by an independent specialist company to ensure that the design of refurbishment works will meet the appropriate standards. The independent
specialised company reviews the building design against the applicable building codes and check on the quality of work under construction and completed works against the approved design.



Organizational Capacity and Competency

Out of Eurasia’s 11 Departments two are responsible for E&S management and the HR Department is responsible for managing associated issues. The Logistics Department manages procurement, university assets and teaching equipment, medical facilities, vehicles, and all contractor staff (dining, cleaning, landscaping, security, medical and dormitory management services). The Infrastructure Department is responsible for overseeing the Green Campus Project, which involves land acquisition, building and works design, and management of construction contractors. External experts are contracted for the development of design documentation (e.g., building design, LFS provisions, water supply and sewage connection), while a specialist firm is hired to prepare the EIAs for new buildings.



Eurasia has been implementing campus energy and water efficiency measures over the past nine years which have been formalised into the Green Campus Project (Phases 1 and 2). In addition, Eurasia implements a range of standard environmental management measures for such aspects as primary sewage treatment prior to discharge, and waste handling, recycling and disposal. Within the logistics department, two dedicated supervisors are responsible for monitoring environmental, health and safety compliance.



Management and Monitoring Program

Eurasia’s environmental and social (E&S) performance is primarily guided by applicable national regulations. In accordance with these requirements, Eurasia has developed operational procedures for OHS, resource use efficiency, waste management and disposal, LFS and security. In addition there are procedures applicable to human resources. As described earlier, Eurasia’s main program to implement E&S management measures comes under the Green Campus Project. In addition, the Management System Collection of Eurasia University includes operational procedures for environmental and related management (national regulations, environment and facilities/property management, management process, Union responsibilities) which are implemented on campus.



Monitoring of the E&S management measures is undertaken internally by staff and externally by consultants hired by the University and government agencies as part of the approval and certification process. Examples of this are: internal monitoring of E&S measures by two supervisors; internal monthly monitoring electricity and water usage; and requirement to have construction supervision staff by the municipal government for each University building development over the length of construction to monitor quality and safety.



Emergency Preparedness and Response

Eurasia has a formal Fire Fighting and Emergency Evacuation Plan that covers actions in the event of fire, earthquakes an
d water shortages; this is generally in accordance with PS1 requirements. This plan covers personnel and property safety, rapid response actions to a fire alarm, fire rescue and safe evacuation, and extinguishing fires to safely minimize damage. The Plan is based on the Peoples Republic of China Fire Service Law, Shaanxi Fire Regulations and the Enterprises Fire Act. University staff are assigned to dedicated teams to manage emergency actions, extinguish fires, evacuate people, and provide emergency communications, medical assistance, traffic management and security.

Eurasia directly employs 1,394 staff, consisting of 754 faculty staff (450 full-time teachers and 300 part-time teachers), 380 administration (accounting and human resources) and teaching assistant staff, and 260 logistics staff. In addition, 244 contractor staff are employed for positions that include catering, landscaping and maintenance. Staff numbers are expected to remain stable over the next five years as Eurasia consolidates and improves the learning experience, while student numbers may reduce.



The company’s HR policy is contained in the four-volume Management System Collection of Eurasia University, supported by detailed HR procedures for covering such aspects as recruitment, pay and conditions, training, union representation, etc. These procedures are in accordance with the Labor Law of the Peoples Republic of China (PRC) which guarantees the core labor rights of workers (minimum wages/salaries, overtime, social benefits such as insurance, leave provisions, worker safety) and are generally consistent with PS2 requirements. The procedures include a hiring procedure, working procedures, career development, training, performance evaluation and grievance procedures. The grievance procedures allow all employees to raise issues of concern via several avenues other than their immediate supervisor, including WeChat, directly with the President and anonymously by letter. Direct feedback and suggestions can be provided to the President of the University via the “you are invited by the president” campaign. Each grievance is investigated by someone outside the subject Department, through recorded interviews. If a grievance is verified as being a valid issue, then appropriate action is undertaken. A workers representative conference is convened annually to hear recommendations and adopt appropriate work conditions.



Hiring is conducted in accordance with the national Labor Law through campuses, external job websites and internal recommendations from University staff. Discrimination in employment and occupation is prohibited in China and regulated by national law that the University complies with. Eurasia’s HR policy includes provisions relating to equal pay and benefits for the same position and recruitment and promotion based entirely on merit/ability. Staff undergo a pre-employment health check and at least one annual health check-up. Individual employment contracts are provided to new staff prior to commencement of employment, specifying employment terms and conditions, while a duties description is provided specifying responsibilities.



Every direct Eurasia employee (full-time and part-time staff) is a member of a trade union (Xi’an Eurasia Union Committee). Eurasia does not specify a minimum employment age but instead follows the national Labor Law that stipulates the minimum age of 16 years. As the majority of faulty staff have a Masters degree, most teachers are 23 years or older. Eurasia does not use child labor or forced labor, eithe
r directly or indirectly through subcontractors. Contracted staff are required to comply with all Eurasia labor requirements as specified in the contract conditions, but these staff do not have access to the University’s grievance procedures. As defined in the ESAP contracted staff will be given access to a grievance procedure.



Eurasia is in compliance with national regulatory requirements, and has not been the subject of any violations of applicable labor laws. No labor strikes have occurred, with only one recent minor labor dispute relating to a termination payment being raised by an individual in 2013. This dispute was dropped once independent arbitration advice was provided to the employee. Contract workers receive at least minimum pay as required by Government as a condition of their contracts. Implementation of the project will not result in job losses, however Eurasia will prepare a HR procedure for retrenchment aligned with PS2, ready in the event that retrenchment is required (see ESAP item). Eurasia has 120 employees residing in dormitories on campus, employed in operations and logistics (security guards, maintenance staff and cafeteria staff). Staff accommodation consists of a one-storey dormitory of 35 rooms with four staff per room. Dormitory facilities include air conditioning, ventilation, bathrooms and laundries, similar to student accommodation. Each room is equipped with a dry powder fire extinguisher, and the dormitory building has four security cameras. There is no planned upgrade of this dormitory.



The OHS risks associated with day-to-day work activities are relatively low, consisting of electrical safety, fire, traffic and physical injury from work activities such as lifting. The Eurasia OHS Manual sets out overarching requirements and is supported by separate activity procedures designed to avoid or protect against work activity-related hazards. Some of the key OHS procedures cover maintenance, food preparation, medical clinic activities and security. Eurasia has two designated supervisors within the Logistics Department overseeing and monitoring OHS practice on campus.



All direct employees have to undergo a full induction training program and subsequent worker health and safety training relevant to their job activities. A 7-8 day induction training course is run for all new employees that incorporates OHS training, and the Book of New Staff and New Staff Training Book are provided for University familiarization. The HR department maintains permanent records of training participation to ensure compliance. The University has been in compliance with regulatory OHS requirements and has recorded no significant lost time incidents or fatalities in its operational history. The only recent incident was a student receiving an electric shock from a faulty light switch that did not result in an injury or lost time, and this fault was immediately rectified.



EHS management during construction is the responsibility of the
construction contractor, with oversight provided by Eurasia. The University checks that all contract workers are OHS certified, with some specialists required to have skill-based certification (e.g. electricians) under the law. For strategic partners Eurasia provides OHS training and regularly reviews contractor performance. Approach agreements provided by the University are required to be signed and adhered to by construction contractors, specifying controls that include fencing, noise limits, dust controls, vehicle management and acceptable worker behavior. Each main construction contractor is required to prepare a Construction Implementation Plan that describes the E&S controls to be implemented, and to submit this to Eurasia for approval. Eurasia monitors contractor compliance on a weekly basis against the contractual responsibilities and local regulations. For large construction projects Eurasia hires a third party to monitor the performance of the construction contractor.

Eurasia has implemented major resource efficiency measures over the past decade under Phase 1 of its Green Campus Project to reduce the University’s environmental footprint. Phase 1, which is now complete, included: (i) decommissioning the University’s coal-fired boilers used for heating and replacing these with coal-fired Municipal heating (with regulated emissions) in 2013; (ii) switching from on-site borehole water supply to municipal supply in 2014 to protect groundwater for emergency use by the Municipality; and (iii) retrofitting selected buildings with energy and water saving devices. Energy saving initiatives have included intelligent electricity control in apartments, installation of LED lighting, glazing replacement with low emissivity glass, installation of wall insulation in various buildings including lecture and administration buildings, installation of skylights and electric controlled roof shutters, and curtains over doorways to retain building heat in winter. The University removed all coal-fired hot water boilers by 2014 in response to calls for city haze reduction. The University currently consumes 12.7 million kWh of electricity per annum from the grid and has a petrol generator for back-up power supply which is used 1-2 times a year during grid. The University plans to convert the electric kitchen ovens to gas in mid 2016 which will save an estimated 2 million kWh per annum.



The campus is connected to municipal mains water supply and uses 10,170 m3 (101.7 million L) of water per annum. Water conservation measures have been implemented at the University over the past nine years including reconstruction of the water supply system, a water saving systems installed in the restrooms of student apartment and select lecture buildings and the bathing center, and use of permeable paving in car parks to allow rainwater infiltration. These measures deliver a combined water saving of almost 1 million L annually. Under Phase 2 of the Green Campus Project similar energy and water saving measures will be installed in the new and renovated buildings.



The overall efficiency targets of the Green Campus Project are: (i) building heat loss reduction by up to 40%; (ii) lighting consumption reduction by up to 10%; (iii) energy saving of up to 30% from the installation of a new air conditioning system; and (iv) water saving of up to 20%. Energy savings from the Phase 2 works are expected to amount to 25% of current energy usage of the facilities to be improved, while water savings are estimated at 20% of current usage.



Certification of the design and construction of new green buildings and major building refurbishment works is progressively sought by the University under the China Green Building Label and the US Green Building Council LEED program, based on the efficiency measures incorporated into these works. LEED certification of the new Learning Centre is almost complete, awaiting the issuing of the certificate. Eurasia will also app
ly for LEED certification for the new campus building.



Eurasia monitors campus electricity and water consumption on a monthly basis. The electricity usage of each Department is assessed annually by the Performance Evaluation Committee, with each building fitted with a dedicated electricity meter. Greenhouse gas emissions from the generation of Eurasia’s consumed electricity emits around 1,045 mtpa CO2-equivalent. CO2-e emissions from heating supplied by the Municipality have not been ascertained.



The campus is connected to the Municipal sewage system, with the Municipal norm for wastewater quality discharged into the system being met through double filtration treatment. Kitchen wastewater and sewage are discharged through grease traps before being discharged to the Municipal sewage system. Wastewater quality is monitored quarterly by a local agency, with no significant violations against national standards identified during the previous 12 months.



Other University wastes consist of general waste (paper, cardboard, food wastes, metals), e-waste (computers, printers, etc), medical waste from the first aid treatment of students and staff, and construction waste. Handling and disposal of campus wastes is carried out in compliance with local regulatory requirements. Wastes are partially segregated on site in waste depots, with recyclable materials sold to recyclers, including e-waste that is taken by a specialist recycler. General non-recyclable waste and non-infectious medical waste is collected by the Municipal waste collection service and disposed of at an approved site. Infectious medical waste is stored in designated bins and bags in a central depot and disposed of by a specialist company in strict accordance with regulatory requirements to prevent infection.



The only notable hazardous material used on campus is bottled oxygen, used in the medical clinic for diagnosis and treatment purposes. The safe handling and use of oxygen is undertaken in accordance with the University’s procedures that include purchasing supplies from a qualified company, having the pressure gauges on bottles periodically tested by the Xi’an Institute of Measurement and Testing, daily inspection of oxygen supply by the on-duty doctor and nurse, and reporting if an issue is identified.



The quality of potable water provided by the Municipality is ensured by the Municipal government and in compliance with the World Health Organization’s Guidelines for Drinking Water Quality as prescribed in the national regulations. Borehole water quality is regularly sampled by the Municipal administration to ensure it meets the required water quality standard.



Campus stormwater is managed in with an on-site stormwater system that discharges into the Municipal stormwater system. The established, near level campus consists of hard surfaces (buildings, roads, paved areas) and landscaped areas, with the only erosion hazard being from relatively small sites cleared for develo
pment from time to time. The erosion and sedimentation hazard on these sites is low due to ground slope, and managed with standard controls. Petrol (up to 30 L) for the back-up generator is stored in a warehouse away from public buildings

The University houses 20,000 students in campus dormitories and has classrooms for 21,300 students, a large library, 88-room hotel (primarily for visiting parents), several very large kitchens and dining rooms, and a range of sporting and other facilities available to students and faculty staff. Campus buildings have been progressively built from 1999 onwards, with the older buildings being of a lower standard than recently constructed buildings in terms of LFS and resource efficiency.



Eurasia follows national fire safety standards and local fire safety regulations across the campus, with external fire prevention specialists used to design and integrate the required measures. The Logistics Department implements the campus fire prevention plan, with fire safety facilities established strictly in accordance with the national standard. Campus fire safety is provided by a central control room manned 24 hours a day, smoke detectors and automatic alarm system, water storage tanks and automatic sprinklers, fire extinguishers, fire curtains, hydrants and hoses, and clear emergency exit signage. The University’s fire alarm system is not connected to the Municipal Fire Service and this will be addressed by University management in accordance with internal plans. The University conducts weekly and monthly safety checks of the fire system, as well as routine training and regular fire-fighting drills for part-time and full-time fire fighters on campus. A specialized company is stationed on campus to maintain firefighting equipment. No fire accidents have occurred on campus since the University opened.



Building refurbishment to date has included fire system upgrades (e.g. automatic sprinklers fitted to the hotel). The proposed new research and academic building and buildings to be significantly renovated under the project will be designed, constructed and operated in full compliance with local building codes, local fire department regulations, insurance requirements and in accordance with the national and locally applicable LFS requirements, as well as the WBG General EHS Guidelines (Section 3.3 Life and Fire Safety).



The project’s new and significantly renovated buildings will be fully equipped with all required fire safety features, including smoke detectors, automatic sprinklers, and fire hoses. Building refurbishment will strictly meet the requirements of the Fire Protection Law and Code of Design on Building Fire Protection and Prevention, while some building upgrades will include strengthening with additional reinforced pillars.



To assess LFS risks associated with existing facilities the University will commission a suitably qualified LFS specialist to conduct a risk-based LFS review of selected facilities, involving expert judgment based on good international engineering and operational LFS practices. Based on the findings thereof, if necessary IFC and the University will agree on a time-based Corrective Action Plan (CAP) to address any out
standing issues. These requirements are defined in the ESAP.



The LFS aspects of the new building design building will be reviewed and approved by the municipal government, including the Fire Safety Bureau. For the refurbishment works that do not involve significant structural changes, the municipal government does not review LFS aspects. However, for purposes of the new building design and the design of works associated with significant renovation of existing buildings, the University will undertake an audit of pre-construction design by a suitably qualified LFS specialist to confirm compliance with local requirements and those contained in the WBG EHS Guidelines. Should it be necessary the designs will be amended to ensure compliance with local standards and the WBG EHS Guidelines. Once the buildings have been constructed/significantly renovated, a post-construction audit to confirm compliance with the original design will be undertaken by a qualified professional acceptable to IFC. Where the audit identifies non-compliances relative to the original design, corrective actions will be formulated indicating the actions and timeframe for implementing changes. Once the actions have been implemented, the qualified professional will then review the project activities to ensure the associated measures have been fully implemented.



Campus security personnel employed provide security in accordance with the University’s security plan. The security system consists of a central control room and over 800 cameras across the campus, with people and vehicles having to pass through manned gates. Eurasia’s Emergency Response Plan cover actions in the event of fire, earthquakes and water shortage, with an evacuation drill is conducted twice a year. As part of the LFS review, the Emergency Response Plan will be reviewed and necessary amendments made to improve it as necessary (see ESAP item).



Traffic is managed within the campus with clear signs and road markings indicating the road rules. The University requires drivers to be licensed, have more than five years driving experience and a safe driving record. The University provides safety training to drivers, and vehicles are regularly maintained. Disabled access is provided to new buildings and has been fitted to refurbished buildings. Food safety in campus catering facilities is managed in accordance with the Food Safety Law of the Peoples Republic of China and Eurasia’s food safety procedure. The University holds a Food and Beverage Services permit, Employment Permit for cafeteria chefs and Health Permit for cafeteria serving staff.

Eurasia does not have a formal corporate-level stakeholder engagement policy or a project stakeholder engagement plan, nor does it have an external grievance mechanism at corporate or project level. Despite this the University provides a good level of information to parents and students on the institution’s education and green initiatives. Although there are no communities directly affected by the project, residential apartment buildings are being constructed close to the campus. Eurasia will develop a formal external stakeholder engagement plan incorporating an external grievance redress mechanism (see ESAP item).

Eurasia supports a range of corporate social responsibility (CSR) initiatives that include scholarships for poor students, job opportunities for unemployed technicians, mutual funds for impoverished employees, and donated clothes, school supplies, tables and chairs for students who live in impoverished mountainous areas.

Contact Person: Ms. Chunni Lei
Company Name: Xi’an Eurasia University
Address: Eurasia Road #1, Dian Zi Cheng, Xi’an, Shaanxi, China
Email: mailto:leichunni@eurasia.edu
Phone: +86-029-88298750
Facsimile: +86-029-88298771

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
L&FS: Commission a suitably qualified LFS specialist to conduct a risk-based LFS review of sample existing facilities (including but not limited to dormitories for students and employees), involving expert judgment based on good international engineering and operational LFS practices. Based on the review findings, if necessary the University and IFC will agree on a time-based Corrective Action Plan (CAP) to address any outstanding issues.	05/30/2016
Undertake an audit of pre-construction design of the project works (new building and buildings to be significantly renovated) by a suitably qualified LFS specialist to confirm compliance with local and WBG EHS Guidelines LFS provisions. Should it be necessary the designs will be amended to ensure compliance with local standards and the WBG EHS Guidelines.	01/01/2018
Conduct a post-construction audit of the new buildings and buildings to be significantly renovated to confirm compliance with the original design by a qualified professional acceptable to IFC. Where the audit identifies non-compliances relative to the original design, formulate a corrective action plan (CAP) indicating the actions and timeframe for implementing changes. Once the CAP has been implemented the qualified professional will then review the project activities to ensure the CAP measures have been fully implemented.	01/01/2019
Build/strengthen internal capacity to monitor engineering and fire safety aspects of operations, and undertake regular periodic monitoring and internal audits of LFS to assess compliance.	01/01/2017
Land acquisition: develop and implement a land acquisition procedure consistent with IFC Performance Standard 5 (PS5), to be applied in the event of future land acquisitions. Said procedure will describe the process by which Eurasia will review and document the government led process to determine whether it meets PS5 requirements.	01/01/2018
Internal grievance redress procedure: Allow the existing University staff grievance redress procedure to be formally available to contract staff.	08/01/2016
Retrenchment procedure: Develop a retrenchment procedure aligned with PS2, ready in the event that retrenchment is required. Implement this procedure when applicable.	10/01/2016
Stakeholder Engagement Plan: Develop and implement a Stakeholder Engagement Plan (“SEP”) aligned with PS1 requirements. The SEP shall include a grievance redress mechanism for external parties.	11/01/2016