While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The corporate office and the nursing homes are/will be rented from third parties, located in residential areas with established connections to public water, sewage, and electricity utilities. It was therefore considered that PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples), and PS8 (Cultural Heritage) do not apply to this project.

This is a Category B project according to IFC’s Policy on Social and Environmental Sustainability because a limited number of specific E&S impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. Key E&S issues associated with this investment concern the following: (i) systems and organizational capacity for consistent management of environmental, labor, and occupational health and safety practices in all nursing homes, including new developments; (ii) management of safety risks associated with Senior Assist’s clients (residents); and (iii) management of solid waste and household hazardous materials and wastes.

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.

Policy and Identification of risks and impacts:



Senior Assist manages its operations in conformity with relevant national health and safety requirements established by agencies such as SEREMI (Secretaria Regional Ministerial de Salud, or the Regional Ministerial Secretariat for Health), and the Directorate of Municipal Works (Dirección de Obras Munipales). As discussed below under PS2, PS3, and PS4, the company manages environmental, labor, and safety issues in line with the national legislation.



Senior Assist has policies and procedures for addressing operational and labor risks and to mitigate them accordingly. As a company, however, it does not currently have an overarching policy with regard to sustainability issues. As per the ESAP (action #1), Senior Assist will therefore review the IFC Performance Standards and the World Bank Group''s General Environmental, Health, and Safety (EHS) Guidelines, develop an E&S policy to be approved at the board level, and communicate it widely throughout the organization and to key stakeholders.



As part of its expansion plan, the new nursing homes will be built by real estate companies as per the design specifications provided by and later leased by Senior Assist. Senior Assist’s project development director and contracted architects are responsible for designing the projects and monitoring the construction activities, which are undertaken by licensed contracted construction companies. As per the ESAP (action #2), Senior Assist will develop a screening procedure/checklist for assessing E&S risks and impacts associated with the new projects. For this purpose, the company will develop a set of criteria for site selection as well as an evaluation checklist that will be completed for each new potential residence location. Based on results of this screening the company shall make a decision on approval or rejection of each considered location.



Moreover, with the help of the checklist, the company will assess and summarize key E&S risks and impacts associated with the selected sites (typically, for instance, noise, life and fire safety, accessibility and traffic related issues, and security issues for the residents), and any specific design features will need to be adopted, in order to comply with regulatory requirements and the company’s corporate standard design specifications.



Management Programs:



Senior Assist has an established management process for labor and OHS to ensure that all its centers consistently comply with the Chilean legislation (see below under PS2 for more details). As discussed below under PS-3, the company has sought to implement a variety of resource efficiency measures across all its centers to reduce the use of water and especially electricity, which has also been incorporated into the design of new nursing homes. In addition, the company has developed an emergency preparedness and response system at corporate level that is implemented across all its centers to ensure
appropriate response in case of emergency situations (see below under Emergency Preparedness and Response for more details).



Organizational Capacity and Competency:



At the corporate level, responsibilities for labor, occupational health and safety, and residents’ safety performance are shared between the human resources and the operations departments. Personnel occupying these roles are highly-experienced professionals.



Each residence has a director with either a management or nursing degree, who has the responsibility for compliance with local legislation and corporate policies. The work of each director is supported by a head nurse who oversees all the functions of the personnel related to residents’ care (assistants and technical nurses) and a facilities manager responsible for administrative and operational issues of the centers (kitchen, cleaning and utilities). As per the ESAP (action #3), Senior Assist will strengthen the existing organizational capacity by formally designating a senior company official at the executive committee level with overall responsibility for ensuring that all E&S aspects of the company’s performance are consistently managed and executed across all centers.



Emergency Preparedness and Response:



Senior Assist has an emergency preparedness and response system to ensure appropriate response in case of emergency situations. The system consists of (i) emergency plans for all residences, which include the identification of emergency scenarios and specific emergency response procedures, evacuation procedures, roles and responsibilities, emergency contacts, and communication procedures, (ii) emergency equipment, such as fire extinguishers and wet extinguishing systems, in line with national life and fire safety decrees (namely Decretos Supremos 594 and 369) and safety requirements of the Department of Urbanism and Construction of the Ministry of Housing and Urban Development, (iii) trained emergency response teams distributed in all residences and in different shifts to ensure emergency response capacity at all times, and (iv) annual emergency drills. According to information provided to IFC during the appraisal, the company is in full compliance with all Chilean fire safety regulations. The emergency plans of two nursing homes were reviewed by IFC during the appraisal and some recommendations were discussed with Senior Assist aligned with the identified risks. As per the ESAP (action #4), Senior Assist will review the emergency plans of the nursing homes currently operational/under construction nursing homes in order to enhance and standardize the guidance for evacuation in case of emergencies, especially regarding fire and earthquake scenarios.

 

Monitoring and Reporting:



The emergency preparedness and response system is monitored on a weekly basis by an external safety specialist, who evaluates aspects associated with infrastructure and staff behavior at each residence. Aspects associated with lab
or practices are monitored by the human resources department (see below under PS2 for more details). Financial, commercial and quality key performance indicators are monitored and reported to senior management on a monthly basis. With the establishment of a sustainability policy and the designation of a senior company official as the coordinator for EHS issues, as per the ESAP (action #5), Senior Assist will include environmental, OHS, and labor key performance indicators in the senior management monthly report.

As of June 2016, Senior Assist had approximately 250 direct employees, including three part time doctors, and two third party workers providing physiotherapy and occupational therapy services at its residences. Of the total staff, approximately 85 percent are women. As part of its expansion plans it is estimated that by 2021 the company will have over 900 direct employees.



Human Resources (HR) Policies and Procedures, Working Conditions and Terms of Employment:



Terms of employment and working conditions are established in the human resources and occupational health and safety policy (Reglamento Interno de Orden, Higiene y Seguridad, or Internal Regulation on Order, Hygiene, and Safety), in line with the provisions of the Chilean Labor Code, which are communicated to all new employees during the induction process.



The human resources policy covers various aspects, including working hours, overtime, cessation of employment, equal opportunities, equal remuneration for men and women, obligations and prohibitions, workplace harassment, and OHS.



Employees’ compensation is composed of the legal requirements guaranteed by the Chilean Labor Code, which is consistent with PS2 requirements, and additional benefits such as performance-based salary bonuses, transport and food subsidies, emergency loans, birth and holiday allowances, in order to attract talented individuals in a sector which is highly competitive in Chile.



Training:



During the last two years, Senior Assist has been working on various initiatives to enhance its human resources management system in order to attract and retain high-performing staff, including the review of the recruitment process; review of staff functions, roles and responsibilities; and implementation of career development plans for all staff levels, leadership development programs, performance-based salary bonuses, and satisfaction surveys. Employment positions are published in different channels, including internet portals, recruitment sites of universities and technical institutions, newspapers, and at the company’s website. In addition, Senior Assist has partnerships with education institutions for internship programs.



Senior Assist is committed to developing effective means for managing its employees’ learning needs and training its personnel. The training program includes training sessions for all workers during induction covering aspects associated with Senior Assist’s values and strategies, safety procedures, operational procedures, and leadership, among others. In addition, specific trainings are provided according to workers’ functions. All staff are trained on life and fire safety issues by an external safety specialist. Senior Assist is currently developing a capacity building plan (known as Plan de Formación) to enhance its training programs considering the company expansion plan in the short and medium term. During the appraisal, it was reported that some staff members have started in the
company as caretakers or technicians and were promoted into positions of increasing responsibility, including senior administrative roles based on professional performance.



Protecting the Workforce and Workers’ Organizations:



Senior Assist applies Chilean legislation and regulations on labor standards, including respect for labor rights, minimum age requirements, equal opportunities and prohibitions against forced labor. Conditions of employment are defined in the contracts signed with its employees and thoroughly communicated during induction. The Chilean legislation recognizes workers’ rights to form and to join unions and to bargain collectively. Approximately 20 percent of Senior Assist’s workers are organized under a union (known as Sindicato de Trabajadores de Empresa Servicios Médicos de Enfermería SpA), while non-unionized workers negotiate their benefits collectively through negotiation groups. The company abides by the collective agreements in terms of salaries and benefits.



Grievance Mechanism:



Employment-related grievances are discussed directly with each residence director or with the human resources department. However, the company does not have a formal grievance mechanism in place through which concerns and/or any misconduct in the workplace are registered, addressed, and managed. As per the ESAP (action #6), Senior Assist will implement a workers’ grievance mechanism to ensure all grievances are registered, addressed, and managed promptly. The grievance mechanism should be readily accessible to all workers and should allow for anonymous complaints to be raised and addressed.



Occupational Health and Safety (OHS):



Senior Assist is committed to ensuring a safe and healthy work environment for all its employees in line with Chilean regulatory standards, as established in the human resources policy. In compliance with the OHS decree (namely Decreto Supremo 40 del Ministerio del Trabajo y Previsión Social) the company identifies the potential risks and hazards to workers and the corresponding preventive and protective measures.



In addition, the company has a set of operational procedures to ensure personnel and patients’ health and safety, including procedures for preventing infections among patients and staff, managing needle-stick injury, correct use of personal protective equipment (PPE) and appropriate disinfection and sterilization techniques, managing exposure to blood and body fluid substances, procedures for adequate hand washing, and appropriate cleaning, among others. Training on relevant aspects of OHS associated with the daily work are provided on a regular basis to all workers, in addition to the induction sessions to all new employees.



Senior Assist is associated to ACHS (Asociación Chilena de Seguridad, or the Chilean Safety Association), which is a Chilean nonprofit institution that manages social insurance, and is focused in risk prevention services, occupational healthcare, and long-term
disability care under Law 16.744. All Senior Assist’s occupational accidents and diseases are registered and monitored by ACHS. In 2015, Senior Assist did not register any accident at the workplace. Over the last year, Senior Assist has been working to enhance its operational protocols and training programs to ensure the safety of its clients and personnel. The nursing homes do not pose significant OHS risks and the residences have a safe working environment. There have not been any fatal accidents or major OHS incidents so far.



Workers Engaged by Third Parties:



Senior Assist contracts third-party companies to provide physiotherapy and occupational therapy services at its residences. As part of its contracts, the company requires service providers to comply with all relevant Chilean labor and OHS laws and requirements.

Resource Efficiency:



Senior Assist is committed to implement cost effective measures for improving efficiency in its consumption of energy and water. The nursing homes are designed considering several resource efficiency initiatives, such as efficient lighting (LED and compact fluorescent light bulbs), glass doors to allow natural light to flow into the common spaces, double glazing and insulated wall panels to reduce heat transfer, hydronic radiant floor heating systems, dual-flush toilet devices, among others.



Green House Gas Emissions:



Based on Senior Assist’s overall energy consumption in 2015, total annual emissions after completion of the expansion have been estimated by IFC as 2,500 tonnes of CO2 eq. per annum.



Wastewater:



Senior Assist’s nursing homes are connected to public sewage systems, and the wastewater generated by the company’s operations derives from food services and normal personal use.



Waste and Hazardous Materials:



Senior Assist generates two types of solid waste consisting of (i) general waste, i.e. domestic waste generated during administrative, housekeeping, cooking, and maintenance functions, and (ii) sharps/needles. During the appraisal, it was noted that although Senior Assist does not have a formalized waste management procedure, waste is handled, collected, temporary stored, transported, and disposed by the municipal waste management authority, or by certified waste management service providers, consistent with the Chilean legislation. The nursing homes have appropriate rooms for temporary storage of waste, thereby preventing contact with clients and unauthorized people. The fuel, such as diesel and kerosene, used by the company for back-up generators and boilers is delivered at the nursing homes by certified companies. With the establishment of a sustainability policy (see more information under PS1), as per the ESAP (action #7), Senior Assist will (i) formalize a waste management procedure to ensure all waste, in the existing and new nursing homes, is handled, collected, stored, transported, and disposed in the existing and new residences, according to local regulations and hazardous materials and waste management requirements as defined in sections 1.5 and 1.6 of the WBG’s General EHS Guidelines, (ii) assess the possibility of implementing a recycling program (for example of metals, glass, and paper) at its nursing homes, and (iii) develop a fuel discharge procedure to ensure fuel is properly discharged at the nursing homes. In order to prevent any leaks associated with the underground storage tank, Senior Assist will develop a procedure for leak detection in accordance with the US Environmental Protection Agency (EPA). For the new buildings, Senior Assist will install twin walled tanks, with leak detection between the inner and outer skins.

Infrastructure and Equipment Design and Safety:



The nursing homes are designed in accordance with Chilean regulations, ensuring accessibility for elderly and persons with disabilities, consistent with the principles of universal access, and complying with local fire department regulations, including earthquake safety standards. Senior Assist’s facilities are regulated by SEREMI and the Directorate of Municipal Works, which review and approve the design/layout of the residences, issues operating licenses, and regularly inspects the units. The nursing homes design/layout include several measures to minimize the risks of injuries and to improve comfort and safety of the residents such as anti-slip flooring, installation of handrails and grab bars, bed rails, good lighting, sliding doors in the bathrooms, alarms in the bedrooms and bathrooms to alert staff when a resident needs assistance, smoke detectors, emergency lights, fire alarms, fire extinguishers, among others.



The company has an annual maintenance program for each residence and trained personnel are responsible to ensure maintenance activities are in place.



Community Exposure to Disease:



Senior Assist has a set of operational policies and procedures to prevent infections and ensure the health and safety of the residents, including cleaning, disinfection and sterilization procedures; kitchen, sanitation and food management; hand hygiene; immunization for staff members and residents as necessary (e.g. vaccination for influenza); use of personnel protective equipment (see above under PS2 – Occupational Health and Safety for more details). As Senior Assist provides food service at its nursing homes, the company has a nutrition management program based on food safety and nutritional adequacy. All nursing homes have the necessary regulatory permit from SEREMI to provide food services, and the food is processed under regulated quality, hygiene and sanitation controls. All food items are protected from contamination and spoilage, and all cooking and food storage areas are regularly cleaned. The company provides adequate hand washing facilities throughout the food service areas. Unauthorized personnel are not allowed inside the areas where food is being prepared.



Life and Fire Safety:



As part of its expansion plan, the nursing homes will be built by real estate companies and leased by Senior Assist. The residences have standard design/layout and are developed by Senior Assist’s project development team in compliance with the Chilean regulations. The design/layout of two nursing homes were reviewed by IFC during the appraisal against L&FS requirements of the WBG’s General EHS Guidelines, and a few recommendations were discussed with Senior Assist aligned with the identified risks and international practices. As per the ESAP (action #8), Senior Assist will ensure that all nursing homes that are operational/under construction have emergency routes (exits) with direct access to a pu
blic road and fire blankets installed in the kitchen.

For the new buildings, as per the ESAP (action #9), Senior Assist shall develop standard requirements (master plan) for fire safety systems design and operation which will build upon the requirements of local fire safety regulations and an internationally recognized life and fire safety code such as British, French, Canadian or US National Fire Prevention Association (NFPA) codes. The applicability of such requirements will take into consideration risks associated with senior residences and site specific risks associated with each nursing home (which will be identified case by case by a qualified professional).



For all the new nursing homes being developed under the Project, the company will commission an independent fire safety professional, acceptable to IFC, to review the site specific architectural design specifications and confirm that all the life and fire safety related aspects of design are consistent with local and an internationally recognized fire and life safety code guidelines, as required under the life and fire safety section of the WBG EHS General Guidelines (ESAP action #10). This analysis will consider sector and site specific risks, which will be identified case by case by a qualified professional (as mentioned above), and it should be submitted to and discussed with IFC.



Lastly, as per the ESAP (action #11), following construction, the fire safety professional shall inspect the newly constructed buildings. The company will submit to IFC certifications from this professional that each facility is constructed and commissioned in full compliance with local building codes, local fire department regulations, and all life and fire safety aspects of the previously approved Architectural Brief.



Security Personnel:



Senior Assist does not employ security personnel at its corporate office or at its nursing homes.

Senior Assist''s primary communication channel with its clients is staff interaction with residents and their relatives at the nursing homes, and grievances are discussed directly with each residence director. In addition, the company has an online communication channel via its website (http://www.acalis.cl/contacto) for its key stakeholders, i.e. residents, guests and neighboring communities. However, the company does not have a formal mechanism in place to ensure all external communications are registered, addressed, and monitored. As per the ESAP (action #12), Senior Assist will formalize a communication mechanism to ensure all external communications are (i) registered, screened, addressed, documented, monitored, and reported through key performance indicators to senior management at corporate level on a regular basis.

Contact Person: Roderick Peters, CEO Latin America Acalis
Company Name: Acalis / Senior Assist International
Address: Alonso de Cordoba 5151of 90, Las Condes, Santiago, Chilehttp://www.acalis.cl/
http://www.seniorassist-international.com/

Email: mailto:roderick.peters@sa-care.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Policy and Procedure: Develop a corporate environmental and social policy articulating commitment to comply with IFC Performance Standards to be approved at the board level, and communicate it widely throughout the organization and to key stakeholders.	03/31/2017
E&S Screening Checklist: Develop a screening procedure and checklist for assessing E&S risks of new projects, as described in ESRS	03/31/2017
Organizational Capacity: Designate a senior company official at the executive committee level with overall responsibility for ensuring that all E&S aspects of the company’s performance are properly managed and executed.	10/30/2016
Emergency Plans: Review the emergency plans of the nursing homes currently operational/under construction in order to enhance and standardize the guidance for evacuation in case of emergencies, especially regarding fire and earthquake scenarios.	12/31/2016
Monitoring and Reporting: Include environmental, occupational health and safety, and labor key performance indicators in the senior management monthly report.	03/31/2017
Workers’ Grievance Mechanism: Implement a workers’ grievance mechanism to ensure all grievances are registered, addressed, and managed promptly. The grievance mechanism should be readily accessible to all workers and should allow for anonymous complaints to be raised and addressed.	03/31/2017
Waste and Hazardous Materials Management: (i) Formalize a waste management procedure to ensure all waste is handled, collected, stored, transported, and disposed in the existing and new residences, according to local regulations and hazardous materials and waste management requirements as defined in sections 1.5 and 1.6 of the WBG’s General EHS Guidelines. (ii) Assess the possibility of implementing a recycling program (for example of metals, glass, and paper) at its nursing homes. (iii) Develop a fuel discharge procedure to ensure fuel is properly discharged at the nursing homes. (iv) Develop a procedure for leak detection in order to prevent any leaks associated with the underground storage tank in accordance with the US Environmental Protection Agency (EPA). (v) Install twin walled tanks at the new buildings, with leak detection between the inner and outer skins.	06/30/2017
L&FS – Operational/Under Construction Nursing Homes: Ensure that all nursing homes that are operational/under construction have emergency routes (exits) with direct access to a public road and fire blankets installed in the kitchen	02/28/2017
L&FS Standards New Nursing Homes: Develop standard requirements (master plan), applicable to the new facilities, for fire safety systems design and operation which will build upon the requirements of local fire safety regulations and an internationally recognized life and fire safety code such as British, French, Canadian or US National Fire Prevention Association (NFPA) codes. The applicability of such requirements will take into consideration risks associated with senior residences and site specific risks associated with each nursing home (which will be identified case by case by a qualified professional).	03/31/2017
L&FS Design Review: Commission an independent fire safety professional, acceptable to IFC, to review the site specific architectural design specifications and confirm that all the life and fire safety related aspects of design are consistent with local and an internationally recognized fire and life safety code guidelines, as required under the life and fire safety section of the WBG EHS General Guidelines.	01/31/2021
L&FS Certificate: Following construction, the fire safety professional shall inspect the newly constructed buildings. The company will submit to IFC certifications from this professional that each facility is constructed and commissioned in full compliance with local building codes, local fire department regulations, and all life and fire safety aspects of the previously approved Architectural Brief.	01/31/2021
External Communications: Formalize a mechanism to ensure all external communications are (i) registered, screened, addressed, documented, monitored, and reported through key performance indicators to senior management on a regular basis.	04/30/2017