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
MedLife owns all its existing facilities and will seek acquisition of new facilities in the open market based on a willing seller willing buyer basis. The new facilities may need only renovations works and there will be no greenfield project within the scope of IFC’s exposure through this project. Thus PS 5 Land Acquisition and Involuntary Resettlement is not considered applicable. The existing facilities and new clinics are within the cities and are not in the vicinity of sensitive environmental areas, nor within known historical and/or cultural heritage areas; this is similarly expected for any new facilities acquired. Therefore PS6: Biodiversity Conservation and Sustainable Management of Living Resources and PS8, Cultural Heritage, are not applicable. There are no indigenous people in Romania, thus PS7: Indigenous Peoples, is also not triggered.

As IFC’s proposed investment to MedLife will be used to support acquisition of health care facilities but, as yet, for the undefined projects; the principal Performance Standards to be applied to this investment are those listed above. The company is already complying with IFC’s Performance Standard and will continue to do so as part of this project.

This project has been classified as a Category B project in accordance with IFC’s Policy of Environmental and Social Sustainability as the environmental and social (E&S) risks and potential impacts are expected to be limited, generally site specific, and can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key E&S issues include MedLife’s capacity to adapt their existing environmental, health, safety and social (EHSS) management system to new facilities; contractor management during renovation of new assets acquired; labor and working conditions; management of wastes including medical wastes; patient and community health safety and security; life and fire safety; energy efficient design and 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.

Environmental and Social Assessment and Management System / Policy : MedLife has a corporate level documented EHSS policy and management system, including documented procedures for identification of EHSS risks, implementation of mitigation measures, policy and procedures, management review, emergency preparedness, external communication. The existing management system has been enhanced since IFC’s first investment in the company and is currently in line with IFC’s PS requirements. Furthermore, each facility (hospital, laboratory, clinic) is certified to international management system standards including ISO 9001 (quality assurance), ISO 14001 (environmental management), and OHSAS 18001 (occupational health and safety). The medical laboratories are accredited to the international standard of ISO 17025, covering competence of calibration and testing laboratories, and to ISO 15189 which covers medical laboratories quality and competence. These accreditations will be extended to all new hospitals, clinics and laboratories. MedLife is also certified by the National Commission for Hospital Accreditation (CONAS) that is based on over 1,850 indicators covering areas of waste management, hygenization, chemicals management, community health, safety and security, life and fire safety, patients’ safety and satisfaction.



In going forward the company intends apply its existing EHSS Management System to new operations to be acquired and equally ensure these are certified against the relevant ISO, OHSAS and CONAS standards referenced above where applicable.



Identification of Risks and Impacts and Management Programs: As a part of its investment/acquisition decision making process, the company conducts financial and legal due diligence including that related to operational and environmental permits/licenses/authorization checks and evaluation of previous and/or ongoing liabilities on employees’ relations and environmental/social legislation; this due diligence is performed in house and/or by contracted external experts.. The company conducts further technical due diligence, after the acquisition of the asset, to identify environmental and social performance and compliance versus its existing EHSS management system. If needed, actions plans to bridge identified gaps are then developed and implemented.



As a part of the existing EHSS management system the company reviews its potential environmental impacts and occupational health and safety risks for the renovation works (construction phase) and operational phases of new projects. Management plans, including documented procedures and safe working practices such as waste management, hygenization, chemical storage and training programs as well as monitoring plans, are developed and implemented. The company requires its construction contractors to review environmental impacts and occupational health and safety risks related with the renovation works/services that they will be providing to MedLife and dev
elop and implement management plans to mitigate the risks.



Operational phase environmental assessments and RA’s of the facilities, which will be acquired as a part of the project, will be conducted by MedLife, in line with the existing EHSS management system.



Organizational Capacity and Competency: MedLife’s Construction Project Manager and the Administration Director are responsible to ensure that technical due diligences are conducted for all new facilities. The Construction Project Manager is also responsible for construction / renovation contractors’ management in terms of EHSS, including day to day monitoring of their compliance versus contractual EHSS requirements, in line with the documented EHSS system’s contractor management procedure.



For the operational phase, the Management Systems Coordinator - Quality Manager has overall responsibility for EHSS implementation in MedLife. Day to day EHSS implementation at each facility (hospitals/clinics and laboratories) is managed by on-site technical and medical staff, including maintenance technician and facility nurse. A similar approach and structure will be implemented at all newly acquired facilities.



Emergency Preparedness and Response: The company has a documented emergency preparedness and response plan that includes evacuation, firefighting and first aid procedures for each individual facility. Evacuation plans in place on each floor of existing facilities. As required by the Romanian legislation and CONAS, portable fire extinguishers, fire hydrants, smoke detectors and alarms were observed in the facilities visited. Emergency exits are clearly marked and evacuation exercises and fire drills are conducted annually. For the new facilities, similar procedures will be developed and equipment will be provided.



Monitoring and Review: The company has an EHSS monitoring system in place, including bacteriological monitoring on the floors and walls, water quality, exposure to radiation, incident rates and at the hospitals water and energy consumption. However, water and energy consumption is not monitored at the clinics and laboratories. As a part of the existing EHSS, performance is reported monthly and reviewed by the senior management annually. EHSS performance is in line with Romanian legislation requirements and World Bank Group’s relevant Environmental Health and Safety Guideline values. The EHSS management system includes a documented procedure to ensure mitigation/improvement plans will be developed and implemented in case the performance is not in compliance with the internal targets and/or legislation.



As per action item # 1, MedLife shall enhance its EHSS management system including monitoring and review of the EHSS performance including water and energy consumption in all of its existing and new facilities. Thereafter the company shall provide a copy of its updated monitoring system to IFC.



Details of the EHSS performance monitoring and MedLife’s energy efficien
cy approach is further discussed under PS3 below.

Human Resources (HR) Policies and Procedures: The company has a documented HR policy and procedures including that related to recruitment, performance evaluation, company ethics, training, and career development. The HR system has been enhanced since IFC fist investment and is currently in line with IFC’s PS requirements. The same HR system will be implemented to the new operations to be acquired.



Working Conditions, Management of Worker Relationship, Terms of Employment and Workers’ Organization: The company employees over 3,000 staff of which almost 1,300 are medical professionals with 80 percent of the medical staff being directly employed, either full time or part time, and only 20 percent of employment is outsourced. Outsourced staff are generally doctors, who are working in other health service providers as well. About 40 per cent of the employees are females. All employees have to sign individual contracts. Benefits such as use of company loan and/or additional food package provided during the new year, cover both full time and part time staff. Hospitals are operational on a 24 hour basis with 3 shifts a day, seven days a week. Laboratories and clinics are operational 16 hours per day, with 2 shifts. Working conditions, vacations and freedom of association, as per Romanian Labor law, are documented in job descriptions and in the terms of employment. Company’s management stated that there is no prohibition or discouragement of freedom of association though currently there are no unionized employees and no collective bargaining agreement is in place at any of the current facilities.



Non-discrimination and Equal Opportunity and Retrenchment : The company’s HR policy and ethic codes included statements against all kinds of harassment and discrimination on the basis of personal beliefs or other characteristics unrelated to a person’s ability to perform his/her duty. MedLife does not anticipate any retrenchment in the near future; in fact, the company is currently in a growth phase. Personnel of acquired facilities are expected to continue to work for MedLife after the acquisition.



Grievance Mechanism: The company has a documented grievance mechanism, including dedicated email addresses and phone numbers where grievances can be submitted. Employees can address grievances directly to their superiors or to the HR Department. The system can be used by contractors’ employees working for MedLife. However, the existing system does not allow anonymous reporting. As per action item # 3, MedLife shall agree with IFC on a time plan to enhance its existing internal human resources grievance mechanism to allow for anonymous reporting.



Protecting the Work Force: Medlife does not employ child or forced labor, and the minimum age of employment is 18 in accordance with national law. Company’s contractors are required to implement the same policy for their work force while under contract with MedLife.



Occupational Health and Safety: All existin
g MedLife facilities have OHSAS 18001 Occupational Health and Safety Management System Standard certifications.



EHSS system includes a RA, safe working practices, onboarding and refreshment training, documented job descriptions, periodical health checks, periodical inspections of the equipment and work place monitoring. Workplace risks are regularly assessed and mitigation measures implemented within an action plan. Biosafety is a key program in all facilities. Infection control and emergency response committees conduct regular meetings, trainings and drills. All staff, including medical and non-medical, receive adequate training in accordance with the specific workplace risks. Medlife reported that personnel undergo medical checks in accordance with the Romanian labor legislation before employment and periodically while under contract. Medical checks include respiratory system control, blood tests, hepatitis, and HIV tests; vaccination for influenza and hepatitis are also provided. Additional screening is done based on employees’ specific activities (e.g., radiation exposure is monitored for all staff working with computed tomography and X-ray devices). MedLife has an incident reporting and investigation system in place, covering both its staff and contractors. No injury occurred in any of the facilities for the last five years as reported by MedLife. Personal protective equipment, including gloves, mask, goggles, and aprons are provided and widely used by staff in contact with the patient and/or performing tests.



Workers Engaged by Third Parties: Cleaning and security services are outsourced at clinics while catering and laundry services are outsourced at the hospitals. All contractors are required to implement MedLife’s EHSS system and have access to MedLife’s internal grievance mechanism.



During the renovation works of new assets acquired within the scope of the project, an estimated 20 contractors will be employed (e.g., painting, civil and mechanical works, electrical, etc.) in order to improve the facilities to MedLife’s standards. All construction contractor companies are required to have EHSS coordinators and EHSS experts to monitor and report their EHSS performance to MedLife and to local authorities. According to construction contract’s standard EHSS covenants, contractors are required to conduct risk assessments, coordinate with MedLife for mitigation plans, and conduct daily and weekly EHSS meetings with the Construction Project Manager. MedLife has a system in place to effectively monitor contractors EHSS implementations versus requirements. This includes daily site tours by the Construction Project Manager and technical staff reporting to him.

Resource Efficiency, Water and Energy and Material Efficiency Projects: Electricity is provided from the national grid for all facilities. Electricity consumption ranges from 45 to 201 kWh/m2, with an average of 105 kWh/m2 in the existing hospitals. Existing electricity consumption performance is significantly low when compared to benchmark figure of 296 kWh/m2 (reference http://www.hercenter.org/facilitiesandgrounds/energy.cfm). It is estimated that the electricity consumption will be higher in the new facilities as MedLife implemented several resource efficiency programs as mentioned in the paragraphs below in its existing facilities. Similar improvement programs will be implemented in the new facilities based on the results of technical due diligence referred from PS1 and the E&S performance monitoring system.



All existing facilities are heated by boilers that also supply hot water. Natural gas consumption in the hospitals is close to 95.000 m3/year. Future assets will be heated by natural gas in line with the general approach in Romania.



There are standby generators in every facility. The generators have internal fuel systems and no separate stand-alone fuel tanks are installed. None of the generators, as well as chemical storage areas observed at the visited sites are provided with spill control kits such as absorbent material. Per ESAP item # 4, MedLife shall provide spill kits such as absorbent material where hazardous chemicals, including generator fuels, are stored.



Domestic water is supplied from the municipal network and treated further at on-site facilities through a combination of reverse osmosis, ion exchangers, chemical and UV-disinfection systems. Water quality is monitored periodically at each facility in line with the existing EHSS management system and measures are taken in line with the existing infection control mechanisms. Water quality is in line with Romanian legislative requirements. Overall water consumption is around 60.000 m3 per year.



MedLife’s resource and material efficiency program follows good international industry practices (GIIP) including insulation of roof surfaces and external walls; variable refrigerant volume (VRV) cooling system; air conditioning with air and water cooled chillers; use of variable speed drives for pumps; use of energy saving lamps; lightening controls for corridors, occupancy sensors in bathrooms, low flow showerheads and faucets in all bathrooms, dual flush for water closets and water efficient urinals in all bathrooms. As part of the technical due diligence, referred under PS1, MedLife will identify the areas of opportunities in the new facilities and develop and implement improvement plans as needed.



GHG Emissions: Emissions are generated from; (i) standby generators; and (ii) natural gas heaters / boilers. There are no incinerators for waste and hygenization of the equipment is done by electrical autoclaves. Carbon dioxide (CO2) equivalent emission upon project compl
etion is estimated to increase from 6.000 tons per annual to around 7.500 tons per annual.



Wastewater Treatment: All domestic waste water from toilets and showers is discharged to municipal waste water collection networks in compliance with local municipal regulatory requirements. Liquid effluents, which include waste biomedical test liquids (e.g., blood, urea etc.) and chemicals from laboratories, are collected separately and treated on site by compact wastewater treatment units which include microwave disinfection. Treated sludge is disposed as medical waste and treated effluent, which is regularly monitored against Romanian legislation by certified agencies and results reported to the regulatory authorities, is discharged to the city sewerage



Solid Waste Management and Hazardous Materials: MedLife implement hazardous materials and waste minimization programs in line with IFC provisions. As a result, hazardous chemicals have been replaced with relatively less hazardous alternatives and limiting the consumption of x-ray chemicals by moving imaging diagnostics into digital solutions. Application of the existing EHSS systems to new facilities will ensure that the same hazardous material minimization programs will be in place at these.



Medical wastes, domestic wastes and packaging wastes are segregated, stored and recycled/disposed by third party waste contractors. Medical waste is stored in locked and cooled areas to prevent unauthorized access. In order to minimize contamination risk, all medical waste is collected within 48 hours by the accredited waste contractor for incineration and/or landfilled. Other than X-ray equipment, there are no other sources of radioactive wastes since MedLife does not provide nuclear therapy. In case future operations include such treatments, MedLife will revise its EHSS system accordingly and develop specific procedures and standards for the appropriate handling and disposal of relevant wastes and effluents.

Community Health and Safety: Medical equipment is strictly controlled in accordance with Romanian laws to eliminate the risk to community. As a part of the existing EHSS management system, utilities and safety equipment as well as medical and analytical equipment are subject to regular maintenance and inspection programs. Inspections are conducted by third party authorized companies including elevators, ventilation system, and pressurized vessels such as oxygen and/or carbon dioxide and/or nitrogen tubes that are used for treatment and/or for laboratory tests.



There are documented procedures for infection prevention and control in order to eliminate risk of community exposure to disease. Local authorities conduct audits to inspect hygenization practices and other community health, safety and security related issues. There have been no fines issued and/or cases filed against the company in the last 5 years. MedLife has a monitoring program for community and/or patient health and safety, including bacteriological monitoring of floors and walls, water quality, and exposure to radiation. The results are reported to senior management and necessary measures are taken if required.



There is no cafeteria within the hospitals and clinics; catering services are outsourced to an approved contractor’s with certified food safety system in line with ISO 22000 International Food Safety Management System Standard in place, which is regularly inspected as reported by the Medlife management.



Existing hospitals are 3 to 4 stories high, except the Pediatric Hospital in Bucharest, which is 7 floors, whereas clinics and laboratories are generally on one or two floors. Facilities that will be acquired are expected to have 1 to 4 floors. Life and fire safety design and installations, including clear marking of the exits, smoke detectors, alarm system, fire exits, evacuations plans posting, emergency lights, are compliant with the national standards and regulations. However, national legislation does not require installation of sprinklers if the building is 20 m or lower. Technical due diligence, which is referred from PS1 includes an assessment against compliance versus good international industrial practices (with suggested action plans if gaps identified) for the facilities that will be acquired to ensure alignment with IFC’s requirements. In the previous projects, MedLife provided documents and reports that confirms that the existing facilities are in line with IFC’s life and fire safety requirements, addressing internationally accepted codes, including emergency exists to be provided, fire retarded doors to be installed and/or smoke detectors / sprinklers are in place.



Romania and expected project locations are known earthquake zones and projects are approved and permits are provided if the design is in line with Romanian life and fire safety as well as seismic/structural safety requirements



During the renovation of the acquired facilities, construc
tion works are expected to be within the buildings. However, there might be civil works on the exterior of the buildings where general occupational health and safety measures including barricading, installation of warning signs, lightening of the area (if needed) will be implemented in line with the existing EHSS management system in place.



Security: Unarmed security personnel are employed through private contractors. Security personnel are trained in the use of force for defensive purposes only and criminal checks as well as psychological tests are included as a part of pre-employment and periodical health controls.

MedLife provide contact information on their web-site (http://www.medlife.ro/) for external grievances. A call center, open 24 hours, is also available to the public.

However, there is no established a mechanism to timely provide information about the company expansion plans and activities to the stakeholder and the public in the vicinity of their operations. Thus as per action item # 2, MedLife shall agree with IFC on a time plan to develop and implement a stakeholder engagement plan at corporate level to be implemented for each project. This plan will include an external grievance mechanism.

Contact Person: Administrative Department – Razvan Laslo or Andrei Tudorean
Company Name: Med Life S.A.
Address: Bucharest, 1st District, Calea Victoriei 222, 7th floor, room 704
Email: mailto:administrativ@medlife.ro
Phone: +40 753 535 343 or +40 742 199 744
Facsimile: -

Broad Community Support is not applicable for this project

S.no	Description	Anticipated Completion Date	Status
1	MedLife shall enhance its EHSS management system to include monitoring and review of the EHSS performance including water and energy consumption in all of its existing and new facilities. The company shall provide a copy of its updated monitoring system to IFC.	07/31/2016	Completed
2	MedLife shall agree with IFC on a time schedule to develop and implement a stakeholder engagement plan at a corporate level to be implemented for each project. This is to include an external grievance mechanism.	03/01/2018	Completed
3	MedLife shall agree with IFC on a time schedule to enhance its existing internal human resources grievance mechanism to allow for anonymous reporting.	03/31/2019	Completed
4	MedLife shall provide spill kits such as absorbent material where hazardous chemicals, including generator fuels, are stored	07/31/2016	Completed