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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS5 does not apply because all the new houses will be developed on land already owned by the company which has been acquired on a willing-buyer willing-seller basis; this approach will similarly apply to new land going forward. PS6 does not apply because the houses are being developed in urban areas on modified habitat with no significant biodiversity value. PS7 does not apply because the project will not cause adverse impacts to indigenous peoples. Finally, PS8 does not apply as there is no known cultural heritage issues in the project area. Vinte does however have a chance find procedure as part of the overall company management system.

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result from project activities that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria as is described in the following sections. The main potential environmental, social, health and safety issues of the proposed project are related to: (i) effective application of environmental and social management systems during construction, including occupational health and safety; (ii) energy use and energy efficiency measures; (iii) water resource efficiency; (iv) solid waste management, including disposal; (v) stakeholder engagement; and (vi) wastewater treatment and disposal. As an existing IFC client Vinte has demonstrated the ability and commitment to address the issues identified above.

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 Systems (ESMS)

The company’s internal procedures and management programs related to environmental and social (E&S) matters incorporate the basic elements of an ESM and require enhancement. Thus as part of the ESAP the ESMS will be improved to ensure full alignment with IFC’s requirements; detailed in this regard are provided below and in the sections that follow. Vinte relies on regional-level (Strategic Business Units) management to address all issues related to E&S risks arising in each specific region where projects are developed such as that related to: environmental permitting, waste management, occupational health and safety (OHS), land acquisition and management of wastewater. For each project Vinte hires third party firms to develop an environmental impact assessment (Manifestación de Impacto Ambiental, MIA) following the requirements established by the state environmental authority. The authority then review the assessment and provide a decision on the project; assuming approval, an environmental license (Resolutivo Ambiental) is issued which includes recommendations and mitigation measures. These recommendations are presented in the environmental license.



When an area is designated for urban development, areas under communal ownership (ejidos) formerly used for limited agricultural production are legally subdivided and sold to developers under a willing buyer-willing seller arrangement. Vinte only purchases land in areas zoned for urban development and which is fully titled. The company already owns the land on which housing associated with the project are being developed and in any event, Vinte follows a policy for land acquisition (Política de Adquisición de Tierras) that is consistent with PS5 requirements and local laws on this matter. The procedure relies on consultation and engagement with potential affected parties throughout the whole negotiation process.



Policy

The company has a commitment to develop projects that minimize impacts to the environment and presents this as a selling point and differentiator when compared to competitors. There is though no environmental policy defined as part of the ESMS and thus as part of the ESAP the company will develop and implement an overarching policy defining the environmental and social objectives and principles that guide Vinte activities to achieve sound environmental and social performance, and this will include reference to IFC’s requirements. Once developed, the policy will be communicated to all individuals within the organization.



Identification of Risks and Impacts

The company develops and implements projects with due considerations to environmental and social risks. All projects undertake an EIA as required by local laws and ensure that mitigation measures are implemented during construction and by the time the projects are handed over to the administration organization that will manage the housing projects.



Management Programs

Vinte has some E&S procedures to manage issues related to: human resources, environmental, health and safety training, client communications and land acquisition amongst others. Construction managers are responsible for ensuring that construction activities are undertaken in accordance with the requirements specified in the EIAs. As part of the ESAP, Vinte will complement its existing procedures by developing additional procedures to manage environmental aspects related to construction activities i.e., solid waste management (hazardous and non-hazardous), dust control, noise, water use and on-site sanitation.



Organizational Capacity and Competency

For each region or business unit there is a person in charge of ensuring that all the necessary environmental permits and requirements for each state are fulfilled. These employees have relevant experience on housing projects and are acquainted with state regulations. For each construction site there is a construction site manager and an occupational health and safety (OHS) and first aid officer (paramédico y enfermero industrial) that oversees safe working practices and conditions. Construction site managers are responsible for implementing environmental requirements of the environmental license.



Emergency Preparedness and Response

The company performs annual emergency drills at its offices and active construction site for fire and earthquake emergencies. There are active fire brigades, first aid brigades, and evacuation brigades for each construction and office site. Offices and construction sites are equipped with fire extinguishers and are regularly maintained. Each construction site manager, with the support of the OHS/first aid officer are responsible to respond to medical emergencies. During 2015, Vinte provided training to personnel on first aid, evacuation, and fire response. While there are drills, there is no defined procedures for emergencies and thus as per the ESAP, Vinte will develop and implement emergency response procedures in line with PS1 requirements that will be applied to all construction sites so as to be able to respond to all potential emergencies e.g. medical, fire etc.



Monitoring and Review

Vinte systematically collects and reports OHS statistics from its operation and are compiled, analyzed and reported to the relevant authorities periodically and is then reviewed by management. Vinte’s construction site managers and industrial nurses undertake periodic supervision and monitoring visits to ensure environmental management requirements as per the environmental license are being applied.

Human Resource Policies and Procedures

Vinte has 2,181 employees of which 525 (24%) are women across its active projects between direct employees and contractors; 768 of them work in administrative functions. It is an equal opportunity employer and has clearly defined policy on non-discrimination and equal opportunity and does not discriminate when hiring new employees or when considering promotions, as required by federal law. It has a Human Resource Policy that is distributed and discussed with all employees during the induction process that defines working hours, compensation and leave benefits, no-tolerance of harassment, conflict of interests, training and development and other HR rules and procedures and benefits. However, the company’s HR procedures can be improved and thus, as part of the ESAP, Vinte will develop and implement procedures to ensure that employees are periodically trained in matters related to the grievance mechanism, compensation, social security, discrimination, and occupational health and safety; this will be tailored to office and construction employees alike.



There is a documented grievance mechanism and employees can submit grievances through their direct supervisors, human resources (HR) representatives or through the Ethics Line (Línea de Ética) available to all employees. As par the ESAP, the company will develop and implement a procedure for allowing employees to submit anonymous complaints. Employees are payed on time and salaries and benefits, as well as working schedules, comply with local regulations. All employees are registered in the social security system. They are also free to join unions and the majority belong to the state construction employees’ unions. Each site has contact information for union representatives in case employees need to reach out to them.



Occupational Health and Safety

Vinte provides construction workers with the appropriate personal protective equipment (PPE) and its contractors are contractually required to use it on Vinte projects. There are programs in place for accident prevention, health and safety, in collaboration with local health authorities. These programs provide for regular training to administrative and construction workers. Additionally, Vinte has established employee brigades for first aid, fire prevention and evacuation.



Working conditions for both contractor and Vinte employees on each construction site are supervised by the site manager and an OHS officer. The overall Lost Time Injury Frequency Rate for both Vinte and contractor employees are higher than when compared to the benchmark for the industry, however Vinte recognize this issue and have agreed to work with IFC to define effective measures so as to improve OHS performance.



Workers have access to adequate sanitation facilities on construction sites. The company coordinates with the state OHS office and facilitates the provision of health awareness and workplace safety campaigns for its employe
es. During the past year there were 23 campaigns and 2,416 employees participated. Topics included: early detection of cancer, diabetes and hypertension; vaccination and first aid; among others. No workers are accommodated on any construction sites and there are areas designated for eating.



Workers Engaged by Third-parties

As noted above, contractor employees undertake land preparation activities and associated infrastructure to these developments (schools, water tanks, roads and water pipelines). Contractors undergo induction safety trainings and are contractually required by Vinte to follow local regulations in regards to labor and environmental protection. As part of the updated OHS system to be developed by, Vinte will develop and implement a procedure to oversee contractors and ensure compliance with relevant OHS legislation. In addition, where contractors do not have a grievance mechanism, Vinte will make available their grievance mechanisms to such contractors. These requirements are defined in the ESAP.

Resource Efficiency

One of Vinte’s competitive advantages and leadership in the housing market is its emphasis on building houses that are water and energy efficient. Vinte does this by focusing on research and development of new sustainable materials that reduce construction material inputs and by incorporating water and energy efficient fixtures on its houses. As of today, Vinte has EDGE-certified 76 houses, and plans to certify 2,000 more by 2021. Vinte has also been awarded several design and architectural awards for its developments. The company also offers, through one of its division, a wide array of energy and water saving measures to home owners and educates them on these matters, so they can be acquired and installed conveniently; the latter is facilitated by Vinte. Additionally, the company has equipped some of its developments with solar powered lightning for common areas, and has several other programs that focus on energy and resource efficiency.



Water

As mentioned earlier, all Vinte developments undergo an assessment of environmental impacts, including the sourcing of water for construction activities and subsequent water supply for housing developments. Water for construction is normally transported to site via trucks or provided by on-site wells which are permitted by the relevant municipal authority. Housing complex source its water for its operation either from wells permitted by the relevant municipal authority or from municipal supply connections. On some of its developments (e.g. Real Verona, Real del Cid, Real Toscana), Vinte has been making efforts to reuse water from the housing complex’s wastewater treatment plant for irrigation purposes. In some developments, water reuse has been up to 30%.



Greenhouse Gases, Air Emissions and Ambient Air Quality

GHG emissions for Vinte operations are due to fuel consumption for construction activities, electricity from both construction and office activities where 1820 tons in 2015 (approx.). In regards to dust control during construction, the company implements adequate measures (e.g. water spraying, covering bulk material) to reduce dust, as specified on environmental permits.



Wastes & Wastewater

Vinte designs and develops its housing complexes with considerations for wastewater treatment and disposal as defined via the relevant EIA and state regulations. Depending on the local setting, Vinte’s solution in regards to wastewater treatment could be: (i) constructing a dedicated wastewater treatment plant (WWTP) exclusively for the complex; (ii) coordinate with nearby developments and share the cost and construction responsibilities for a WWTP with other developments, or (iii) coordinate with municipal WWTP plants to collect and treat the complex’s effluents in exchange for payments. In all cases Vinte arrangements comply with local pre-treatment standards for sanitary wastewater discharges.



Vinte´s general approach to stormwater management is to build infiltration pond
s on its developments, which naturally filter water to the required standard and recharge underground aquifers. The infiltration ponds water quality is periodically monitored to ensure regulatory compliance.



Hazardous Materials

Conventional construction waste is disposed appropriately in an area designated by each municipality. Maintenance of construction equipment and vehicles is done outside the project area and fuels, lubricants and other hazardous wastes is disposed appropriately. As part of the ESAP, Vinte will develop and implement a hazardous waste management plan for all its developments to ensure these wastes are disposed as per the local requirements.

Community Health and Safety

The main risks that Vinte housing developments have for the communities in the vicinity of the project area relate to traffic, noise and dust which are managed and supervised by construction supervisors. In addition going forward they will be addressed via the new procedures to be developed as defined above. Nearby communities may approach construction sites with concerns, which will be processed and responded to through Vinte’s public communication channels (See stakeholder engagement section below).



Infrastructure and Equipment Design and Safety

As part of the permitting process, the housing and future buildings have the relevant structural design safety reviews and approval by local authorities. In regards to life and fire safety, Vinte housing projects comply with Mexican fire safety codes. The new apartment building complex in Queretaro will comply with the Mexican Fire Safety code, both in design and construction materials used.

During the land acquisition change of zoning ordinances processes, Vinte undertakes public consultations as required by local laws. Public consultation is also undertaken as part of the EIA’s completion. In addition, Vinte has offices in each of its developments to address potential customers and public enquires, and they can use phone lines, suggestion boxes, email or walk-in on each of its sites to communicate with Vinte. The company has an internal procedure to process and respond to enquiries from the public.

Contact Person: Alfredo Nava Escárcega
Company Name: Vinte Viviendas Integrales SAPI de CV
Address: Paseo de la Reforma 350 Piso 11, Col. Juárez 06600, México, D.F., México
Email: mailto:alfredo.nava@vinte.com
Phone: +52 55 9171-1528
Facsimile: N/A

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Develop and communicate across the organization an overarching policy defining the environmental and social objectives and principles that guides environmental and social management which include the relevant IFC requirements.	10/04/2016
Develop and implement procedures to ensure employees are periodically trained in matters related to: the grievance mechanism, compensation, social security, discrimination, and occupational health and safety; this will be tailored to office and construction employees alike.	02/15/2017
Develop and implement procedures for the management of construction site environmental aspects related to: solid waste management (hazardous and non-hazardous), dust control, noise, water use and on-site sanitation.	01/15/2017
Develop and implement an emergency response procedure in line with PS1 requirements for each and future construction sites to respond to medical, earthquake and fire emergencies.	12/31/2017
Develop and implement a procedure to oversee contractors and ensure compliance with relevant OHS legislation.	02/15/2017
Develop and implement a procedure to ensure that contractors either have a documented functioning grievance mechanism or have access to the company’s grievance mechanism,	03/31/2017
Develop a hazardous materials risk assessment and management plan to be implemented in all project sites to ensure disposal of such materials in accordance with accepted industry practice. .	02/15/2017