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
IFC Performance Standards 5, 6, and 7 are not applicable to the project. USAL has signed a 30-year antichresis contract (lease) with the Archbishopric of the City of Buenos Aires to use their land for the construction of the new USAL campus. There is no economic or physical displacement resulting from the antichresis agreement of the property. USAL operates primarily in urban areas, where exchange of ownership or leasing of land through standard land titles, contracts and transparent real estate transactions are the norm. Any future land acquisition / leasing by USAL will be through a willing buyer-willing seller relationship specified in a legal contract. There are no protected, sensitive or critical areas of biological importance where the new USAL building will be located. The clients operations will not involve modification, conversion, or degradation of any habitats, rather it has successfully cleaned and remediated the land where the building will be built, which used to be an old gas station. There are no indigenous peoples or cultural heritage in the area where the new building will be constructed.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

The proposed investment is expected to have a limited number of environmental and social impacts, all of which will be site-specific and of a temporary nature. All impacts can be avoided or mitigated by adhering to generally recognized good industry practices, in alignment with IFC’s Performance Standards (PS), the World Bank Group’s (WBG) General EHS Guidelines, and design criteria as described in the following sections. For this reason, the project has been categorized as B, in accordance to IFC’s Environmental and Social Sustainability Policy.

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. The following are the key environmental and social issues / measures identified for the project: (i) development and implementation of a corporate environmental, OHS and social management system, or key components thereof; (ii) adherence to IFC’s PS 2 requirements on labor and working conditions; (iii) OHS risk prevention and management during operations (employees, teachers, students, contractors, nearby communities); (iv) optimization of water and energy use through project design and resource conservation measures, waste management, treatment and discharge of effluent, safety procedures in laboratories, pest control; (v) engagement with local communities regarding environmental, OHS and social performance during the construction and operations phases; and (vi) ensuring adequate Life and Fire Safety (L&FS) provisions and emergency preparedness and response measures for new and existing facilities.

Universidad del Salvador is leasing land from the Archbishop of Buenos Aires for the construction of their new campus. The land agreement negotiated with the Archbishopric allows the University to use (lease) and make improvements to the land for a period of 30 years, after which the lease can either be extended or the land, along with any improvements made to it, returned back to the Archbishopric.



Environmental and Social Assessment and Management System – The project is classified by the environmental authorities (APRA) of the City of Buenos Aires as low risk, of ‘no environmental significance’. Given that the project site had previously been used as a gas station, prior to obtaining the environmental license clearing the project, APRA required USAL to commission an environmental impact assessment (EIA) for the remediation of the land, ensuring there are no remnants of toxic or hazardous substances on either soil or groundwater and that the land is apt for public use as is destined.



Lihue Engineers undertook the remediation work which, among other things, involved the removal of 9 underground storage tanks located within the lot and groundwater and soil quality testing over a two year period. APRA declared the site as fully remediated on 03 September, 2015 through Resolution–2013–326–APRA and granted USAL the environmental license on 02 October, 2015. These documents will be disclosed publicly on IFC’s website.



Policy – USAL does not have an environmental policy. As part of the project, USAL will prepare an overarching environmental policy outlining the environmental and social objectives and principles for the institution in respect to management of its direct environmental and social impacts, in addition to those of new projects. The policy will indicate who, within the client’s organization, will ensure conformance with the policy and be responsible for its execution. The client will ensure to communicate the policy to all levels of its organization and on its website. (ESAP Condition 1)



Identification of Risks and Impacts – Environmental authorities required the project to identify the main environmental and social risks associated with construction activities of the new campus, prior to its commencement. Management and mitigation measures involve: (i) transport management plans to control the ingress and egress of construction vehicles and materials into the construction site, (ii) cordoning off the construction zone, making it safe for pedestrians and vehicle traffic flow, (iii) limiting and controlling noise levels and vibration during daytime hours, (iv) minimizing and controlling dust and emission levels, and (v) ensuring the safety of workers at all times.



At the operations level, USAL identifies equipment or facilities that require upgrading, maintenance or improvement in the near to medium term. Observations are itemized and costed out in a maintenance budget and plan for the institution to implement in the upcom
ing fiscal year. In future, USAL will identify, rate and prioritize E&S risks and impacts in accordance to a risk mitigation hierarchy per IFC PS 1 requirements. (ESAP Condition 2)



Management Programs – Resolution DI-2015-1628-DGET identifies the management programs and measures the new campus is required to adopt and implement against specific milestones. The Resolution is disclosed on IFC’s website along with this report. In addition to measures identified above, under ‘Identification of Risks and Impacts’, the project was required to have the following programs (among others): (i) an Emergency and Contingency Plan signed by a certified professional, to implement in the event of a fire, explosion, hazardous spill or any other eventuality; (ii) an OHS Plan during the construction phase; (iii) a Pest Management Plan to keep the area clear of vectors; (iv) engagement and coordination with local neighbors and utility companies when shutting down power or water supply; (v) a Waste Management Plan for solid and hazardous wastes; and (vi) a grievance log book at the project site in order to address any complaints during construction.



Institutionally, USAL does not have a formal environmental management system or elements thereof. Though USAL is fully compliant with environmental requirements as established by the law, it lacks a structured system that allows for integrated and strategic management and monitoring of environmental and social issues relevant to the institution. As part of this project, USAL will seek advice from an external party to establish a management system that is commensurate with the risks and impacts of the institution and a long-term sustainability strategy to work towards. In doing so a gap analysis between local regulatory requirements and relevant IFC PS’s, including the WBG EHS Guidelines, will be defined along with a plan of action with implementation milestones to address these gaps. (ESAP Condition 3)



USAL will implement an appropriate management system, commensurate with the risks and impacts of the sector that will include a set of policies, programs, plans and / or procedures facilitating a process of plan, check, do and act, moving towards continuous improvement. A basic level ESMS will include at a minimum: (a) - policies covering environment, health and safety and human resources, (b) - planning tools to identify how the organization affects the environment and in context with its legal obligations and sector specific good practices; (c) - setting of objectives, targets and programs for teams and the institution; (d) - defining resources, roles, responsibilities, lines of communication for managing environmental and social issues; and (f) - metrics, targets and indicators for monitoring, measuring and evaluating E&S performance.



Organizational Capacity and Competency - USAL headquarters are located in Buenos Aires. Its operations, both academic and administrative, are spread across twenty building
s, all within a short walking distance of one another, except for (i) "Nuestra Señora del Pilar Campus" (Pilar Campus), located in the Province of Buenos Aires and (ii) "Campus San Roque Gonzalez de Santa Cruz" located in the town of Gobernador Virasoro (“Virasoro”), in the Province of Corrientes. Each campus has its own management team. The Pilar and Virasoro campuses are located in rural areas and occupy expansive areas. In addition to degrees in social sciences, these campuses cater to agricultural (agricultural and veterinary) sciences, with specialized laboratories and services to meet the needs of these degrees.



The lead contractor on the new Cordoba campus has a project management team directing the construction process, ensuring it is built to specification and overseeing the health, safety and security of workers while on the job. Aseguradora de Riesgos de Trabajo (ART) is a national association that oversees the safety of all workers while employed. ART requires that all contractors have a designated health and safety manager on site and a Safety and Security Management Plan for the construction phase. Safety and Security is supervised at two levels: (i) first, by the OHS Manager in the lead contractor’s team, (ii) secondly, by a Safety and Security Delegate nominated by the national syndicate group relevant to the activity (UOCRA in this case), that represents the rights of Argentine workers across that activity/sector.



At the institutional level, USAL is governed by a Rectorate and four Vice Rectorates, representing the economic, academic, development and research and development areas of the institution respectively. Environmental and social matters at USAL are managed by the Infrastructure, Development and Security Team (referred to as “Infrastructure Team” herein) and the Human Resources Teams respectively, both under the umbrella of the Economic Vice Rectorate. The Infrastructure Team handles all matters associated with the management and maintenance of all USAL facilities. The team is comprised of a Manager and supporting staff with competencies in engineering, occupational health and safety, and security. In order to address environmental matters more strategically, USAL will hire an Environmental Specialist to fulfill this role. (ESAP Condition 4)



Emergency Contingency Plan: Please refer to the section on Life and Fire Safety under PS 4.



Reporting and Monitoring: USAL does not currently have a practice for carrying out internal audits or monitoring, measuring, analyzing or evaluating its performance on environmental and social matters. USAL will adopt and implement methods and processes that will allow auto-evaluation and periodic reporting to senior management. (ESAP Condition 5)

Working Conditions and Management of Worker Relationship –The Personnel Department at USAL manages the administrative, employment, accounting (payroll) functions for the institution, including ensuring compliance with local labor laws and management of collective agreements with two local unions who represent less than a quarter of USAL’s workforce. The Secretary of Human Resources (HR) was first established in 2010. HR is responsible for overseeing recruitment and supervises and implements training across the institution. Induction training is offered to all new hires upon commencement, while other training is done as required. For example, in September 2015, the Secretary of HR delivered training to all workers on practices relating to the new law passed in the City of Buenos Aires on separation and recycling of wastes, a new program being implemented across all facilities run by the institution.



USAL’s HR practices are compliant with local labor laws. USAL has an HR Policy obtained through an internal resolution and a grievance mechanism, these are used instructionally and have yet to form the basis of a systematic and formally implemented and communicated process as part of a proper management system. As part of this investment, USAL will prepare an HR Policy and Manual integrating the most important elements of PS 2 covering workers conditions and terms of employment, collective agreements and workers organizations, non-discrimination and equal opportunity, provisions on retrenchment, contracts and contractual requirements for workers engaged by third parties and suppliers. The HR Management System will include provisions to manage potential sexual harassment, codes of conduct for engaging in institutional social media and a grievance mechanism procedure for workers. (ESAP Condition 6)



Occupational Health and Safety – The project is required by law to have an OHS Plan. The plan identifies all safety and security risks, their mitigation and management measures, including protective personal equipment (PPE) for workers while on the job. The OHS Plan is implemented by the main construction contractor, with oversight from governmental authorities and an OHS coordinator on behalf of each supporting contractor.



Oversight of OHS at the University’s existing buildings is managed by the Infrastructure Team, in coordination with the Department of Personnel in respect to training on OHS matters twice a year. USAL does not have an internal OHS Plan as part of a formal management system. OHS risks are periodically evaluated to ensure conformance and compliance with local labor laws. In 2015, USAL logged a total of 25 incidents, all of minor significance. Of these, 7 occurred inside USAL managed premises, while 18 occurred while traveling to / from the workplace. With a total staff of 650, the LTIR rate is 0.03% per hours worked, with an average of 15 days downtime. In alignment with PS 2 and the WBG General EHS Guidelines, USAL will prepare an
OHS Policy and basic OHS Plan identifying and addressing the inherent risks and hazards at its facilities. The Plan will be communicated across the organization and will include a process for training, monitoring, measuring, analyzing and evaluating performance commensurate with the scale and significance of impacts. (ESAP Condition 7)



Workers Engaged by Third Parties – USAL will establish policies and procedures for managing and monitoring the performance of third party employers, ensuring their reputation, legitimacy and commitment to complying with local laws, their own and USAL’s environmental and social policies and guidelines, which in turn will be aligned with relevant IFC PS2 requirements. (ESAP Condition 8)

Resource Efficiency - The new Cordoba campus has been designed applying elements of the LEED Green Building rating system, contributing to a more sustainable and energy efficient build. Once built, the campus will have energy savings of approximately 30% over the baseline/benchmark. Building design integrates specific features enabling the efficient use of natural solar radiation in the classrooms, reducing electricity consumption requirements. This includes evaluating (among other things) the height and size of rooms, materials used in its construction, paint colors applied on walls, surfacing, flooring, etc. A solar rooftop system will be installed for hot water circulation to certain floors and space will be reserved for future installation of solar panels to support energy needs. Solar panels were not considered to be feasible at the time of designing and planning the project, due to the high initial capital and operating costs and lack of available skilled maintenance. The use of solar panels will be assessed in the future, as costs are expected to lower.



USAL began studying alternatives for reducing energy and water consumption at its existing operations in 2011. This resulted in the adoption of some water and energy efficient measures at some of its facilities. USAL tracks its monthly electricity consumption but not water, because not all buildings have meters. Electricity costs in Argentina are generally marginal (low), as they are heavily subsidized by the Government. Given a lack of data, IFC was unable to get a clear approximation of water and energy consumption per user, or equivalent greenhouse gas emissions (GHG) generated.



Given the ad hoc nature of monitoring resource consumption and implementing measures to gain efficiencies, and given the newly elected Governments intent to raise both water and energy costs in the coming year (up to 450% in academic facilities), USAL will undertake a resource efficiency study to evaluate the best methods, targets and approaches to strategically reducing its footprint, in alignment with industry specific standards, PS 3, and the WBG General EHS Guidelines on all new and existing facilities. The study will establish a resource efficiency policy, awareness building among students and workers, establish targets, key performance indicators, improvement and monitoring measures to report against. (ESAP Condition 9)



Wastewater Treatment - Liquid effluents from all USAL buildings in Buenos Aires are discharged into the municipal sewage system. At Pilar and Virasoro, part of the effluent is sent to the public sewage system, and a portion is treated through aerobic biological treatment prior to discharge to surface waters. Effluent quality complies with local water quality parameters and will be assessed against WBG General EHS Guidelines prior to release as part of USAL’s annual performance monitoring.



Waste Management – In late 2005 the City of Buenos Aires passed a law setting gradual a
nd phased waste reduction targets until achieving a complete ban of landfilling of recyclable and compostable waste by 2020. This motivated USAL to implement a recycling program at all its facilities. Solid waste generated at facilities in the City of Buenos Aires are collected by the municipal service of waste collectors, with final disposal at government operated landfills (CEAMSE). Solid waste at the Pilar Campus is managed by an authorized contractor; whereas hazardous waste is collected, temporarily accumulated in a suitable place in compliance with local regulations, and eventually removed by an authorized contractor for final treatment and / or disposal.



Biological and/or pathogenic wastes are collected, transported, treated and disposed of by SOMA S.A., in accordance to local laws and requirements. The contractor submits a certificate to USAL recording the type, amount and dates of collection and treatment, and the location of final disposal. CEAMSE verifies and monitors compliance with the law. USAL provides specialized training and appropriate personal protective equipment (PPE) for employees handling hazardous waste at the Medical and Veterinary Schools.



Pest and Rodent Management System - Pest control (rodents, insects) is carried out by registered and licensed companies at each facility on a monthly basis. USAL will ensure to eliminate the use of WHO class 1a and 1b pesticides like Bromodiolone (currently a class 1a agent) used at the Pilar campus, and replace these with less hazardous agents, excluded from this classification. In future, USAL will require all licensed contractors to eliminate the use of these agents from their use.

Infrastructure and Equipment Design and Safety – The University’s facilities are used for educational and administrative activities only. The most significant community health and safety issue associated with USAL’s activities is the need to prevent fires or other hazards at the facilities and allow for the safe evacuation of building occupants in the event of an emergency. USAL facilities are on average relatively old (50+ years) and refurbished buildings, located in the city center of Buenos Aires, except for its two Province level campuses, considered relatively new in comparison. All buildings have incorporated modern design features to allow for open and comfortable floor space and amenities, making the space apt for classrooms and offices. The City of Buenos Aires is located in an area of low seismic risk.



Life and Fire Safety – Presently, USAL applies local and national building safety standards to the design and construction of new facilities. The fire safety review of existing structures is performed by the Fire Authorities of the City or Region in the Country, which prescribes the necessary building modifications and fire protection features based on a performance-based analysis made to close gaps with today’s local code. For existing operational buildings, USAL has reviewed the status of fire safety systems during recent renovations and upgrades, including aspects related to fire prevention, means of egress, fire detection and alarm systems, smoke control, and others to ensure compliance with local standards.



For future buildings, the company will provide evidence that the design meets IFC’s requirements as defined in the WBG General Environmental Health and Safety Guidelines. A fire safety professional acceptable to IFC will provide a formal written opinion that new buildings meet IFC’s requirements or provide identified revisions to building design that, when implemented, will cause the building to meet IFC’s requirements based on an international life and fire safety code to be agreed with the IFC. (ESAP Action Item 10)



USAL has developed and implemented emergency preparedness and response plans (ERP’s) for all of its facilities. Emergency planning responds to the needs of life and fire safety requirements and include training on emergency evacuation, use of fire equipment, and other applicable aspects identified by local experienced emergency planning specialists. Where Emergency Plans lack drawings showing evacuation routes, safety exterior meeting points, fire protection equipment location and all other important information, USAL will update these to ensure they are adequate and compliant with IFC requirements. (ESAP Action Item 11)



USAL has developed and implemented an effective training plan for all schools ensuring that all students and employees are informed of existing emergency procedures and emergency contingency plans, including evacuation routes. The company will continue performing fire drills in all ope
rating campuses at the frequency required by Argentinian laws.



Principles of Global Access - All USAL facilities are handicap accessible at all main entry points / exits, hallways, bathrooms, and classrooms. Buildings are equipped with elevators, and doors and emergency stairwells have been retrofitted with wider than average width spans allowing for easy accessibility. USAL will continue to ensure that all future buildings, including the Cordoba campus are accessible to peoples with disabilities.



Security Personnel – USAL retains security personnel from a number of third parties to safeguard its personnel and property. Facilities are monitored by security personnel year round. Security arrangements include daily patrolling and vigilance inside and outside of the buildings. Security personnel are not armed, undergo background checks, are equipped with necessary tools and equipment and receive relevant training before and during their employment. USAL will ensure that in retaining new security providers, it will establish contractual provisions that ensure that practices are aligned with PS 4 requirements and the principles of proportionality and good international practice. (ESAP Condition 12)

USAL manages relationships directly with each of its neighbors on matters that have the potential to adversely affect the health, safety and security of other residents. This practice is a function of the Infrastructure and Maintenance Teams and is also practiced at the new construction site. USAL will prepare a procedure for engaging and managing grievances from neighbors and communities in compliance with IFC PS 1. (ESAP Condition 13)

The Government of the City of Buenos Aires does not require urban infrastructure projects to undergo a traditional open public consultation prior to commencement of construction works. Rather, the project is required to ensure that the perimeter of the construction site is adequately fenced off from the public, and that this includes signage with details on the name of the architect, builder and other contractors, information on the construction license and details of who to contact in the event of a complaint, concern or comment. The lead contractor is also required to engage directly with all neighbors prior to commencement of construction, ensuring that these are aware of construction milestones and who to contact and what to do in the event of an eventuality. If an eventuality where to occur, the contractor is required by law to document the complaint in writing with photographic evidence, until resolution. The lead contractor also has to keep a grievance log book inside the construction site. Resolution of grievances involve the relevant authorities where and as necessary.

Sr Ramiro Rico,
Jefe, Departamento Infraestructura, Obras y Seguridad
(Vicerrectorado Económico)
Universidad del Salvador
Rodriguez Pena 752, 1020 Buenos Aires, Argentina

Email: mailto:rrico@usal.edu.ar
Phone: +54-(11)-4814-5025 / 26

Broad Community Support is not applicable for this project

USAL Exp(37778) Supervision Disclosure Snapshot – Version 5
Description	Anticipated Completion Date	Status	Comments	Completion Date
Environmental Policy - USAL will prepare an overarching environmental policy outlining the environmental and social objectives and principles for the institution in respect to management of its direct environmental and social impacts, in addition to those of new projects.	01-Jul-2016	Completed	Completed	12/5/2016
Risk and Impact Identification - USAL will identify, rate and prioritize E&S risks and impacts in accordance to a risk mitigation hierarchy per IFC PS 1 requirements	01-Aug-2016	Completed	Completed	12/5/2016
Management System - USAL will seek advice from an external party to establish a management system that is commensurate with the risks and impacts of the institution and a long-term sustainability strategy to work towards. The consultancy will result in a gap analysis between local regulatory requirements and relevant IFC PS’s and will outline a plan of action with implementation milestones.	01-Feb-2017	Completed	Completed	12/5/2016
Organizational Capacity - USAL will hire an Environmental Specialist to address environmental matters consistently with IFC’s PS, more strategically.	01-Jun-2016	Completed	Completed	8/16/2016
Monitoring and Evaluation - USAL will adopt and implement methods and processes that allow for auto-evaluation of environmental and social performance and periodic reporting to senior management.	01-Feb-2017	Completed	Completed	3/15/2021
Human Resources Management - USAL will prepare an HR Policy and Manual, aligning with the requirements of PS 2, including a formal grievance mechanism procedure for workers and students.	01-Feb-2017	Completed	Completed	3/15/2017
In alignment with PS 2 and the WBG General EHS Guidelines, USAL will prepare an OHS Plan or Manual that identifies and addresses the inherent risks and hazards at facilities and how these are or should be avoided, minimized, and managed, including risks specific to contractors, staff, students, communities and the public.	01-Nov-2016	Completed	Completed	2/3/2020
Third Party Contractors - USAL will establish policies and procedures for managing and monitoring the performance of third party employers and suppliers in alignment with IFC PS 2 requirements.	01-Jun-2016	Completed	Completed	8/16/2016
Resource Efficiency Assessment and Strategy - USAL will undertake a resource efficiency study to evaluate the best methods, targets and approaches to strategically reducing its footprint, in alignment with industry specific standards, PS 3, and the WBG General EHS Guidelines.	01-Nov-2016	Completed	Completed	12/1/2020
Life and Fire Safety - For future buildings, the company will provide evidence that the design meets IFC’s requirements as defined in the WBG General Environmental Health and Safety Guidelines. A fire safety professional acceptable to IFC will provide a formal written opinion that new building meet IFC’s requirements or provide identified revisions to building design that, when implemented, will cause the building to meet IFC’s requirements based on an international life and fire safety code to be agreed with the IFC.	05-Feb-2018	Completed	Completed	12/1/2020
Revision to Emergency and Contingency Plans - Where Emergency Plans lack drawings showing evacuation routes, safety exterior meeting points, fire protection equipment location and all other important information, USAL will update these to ensure they are adequate and compliant with IFC requirements.	31-Oct-2017	Completed	Completed	12/5/2016
Security Forces - In retaining new security providers, USAL will establish contractual provisions (third party contractors) that ensure that practices are aligned with PS 4 requirements.	01-Jul-2016	Completed	Completed	8/16/2016
Community Grievance Mechanism - USAL will prepare a procedure for engaging and managing grievances from neighbors and communities in compliance with IFC PS 1.	01-Nov-2016	Completed	Completed	12/30/2016