Land for the hotel was purchased by the company from other private owners between 2004 and 2010 through willing buyer-willing seller transactions.  No person or economic activity was displaced as a result of these transactions and therefore, Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) is not applicable. The proposed hotel is located in an urban area in Dhaka city and the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) do not apply.

  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 which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.  

Key E&S risks and issues associated with this project include: development and implementation of E&S management systems at the proposed hotel; engagement with local communities in accordance with local requirements and IFC’s Performance Standards (PSs); assurance of fair, safe and healthy working conditions in compliance with local regulatory requirements and relevant PSs during construction and operation; adequate pollution prevention measures; life and fire safety (L&FS) management for proposed hotel in accordance with World Bank Group  (WBG) EHS guidelines for public access buildings; resource efficiency and impacts of construction and transport on nearby communities.

  Environmental and Social Impact Assessment (ESIA): As per applicable legal requirements, the company will complete an environment impact assessment (EIA) for the hotel and obtain the required approval from Department of Environment (DoE) prior to start of construction of the hotel. Based on the EIA and approval, the company will implement all required mitigation and monitoring measures. As per the ESAP, the company will develop an EHSmanual for construction activities. The company will also obtain permits from other authorities, as required before operation of the hotel. 

Policy, Management Systems and Programs:  Currently the company does not have any E&S policy or management systems. However, the hotel will be operated by Swissotel which has well defined sustainability principles, disclosed publicly in their sustainability report. The hotel will be designed and operated in compliance with Swisotel’s/Accor’s environmental principles, human rights and supply chain principles which are consistent with IFC PSs requirements. Swissotel’s procedures and programs under the above mentioned principles are therefore expected to ensure development and operation of the hotel with respect to applicable legal requirements and IFC PSs.

Organization: The PMC will have safety team responsible for management of construction activities and monitoring of construction contractors. The PMC has a detailed EHS manual in place (which will be amended as per IFC’s inputs) and has experience of performing similar role for a number of other projects globally. Contractually, the PMC will be required to ensure implementation of EHS manual at the site including by all contractors. During operation stage, hotel operations will be monitored by Swissotel’s team  in full compliance with its social and environmental requirements.

Monitoring and Reporting: Typically, the E&S performance of the hotel is monitored and reported by Swissotel to assess progress against its E&S commitments. The results are incorporated in its annual sustainability report. In addition, as per the ESAP, the company will develop an EHS monitoring procedure which will specify minimum KPIs/parameters to be monitored, monitoring frequencies and type and the definition of thresholds that signal the need for corrective actions. The EHS monitoring procedure shall be aligned with the requirements of the approved EIA, applicable legal requirements and World Bank Group (WBG) EHS guidelines. The monitoring results will be reported to IFC as part of the Annual Monitoring Report (AMR). 

Emergency Preparedness and Response: The L&FS systems of the hotel are discussed under PS4. Swissotel/Accor has requirements to document crisis management/emergency response plans for the hotel and training of the hotel staff on these plans and thus will be ensured during operation of the hotel.

  When operational, the hotel will employ about 150 employees and at the peak of the construction, 400 workers are expected on site. 

As the hotel will be operated by Swissotel, which has been acquired by AccorHotels in December 2015, the employees will be covered under Accor’s HR policies and procedures. As per public data available, Accor has an Ethics and Corporate Social Responsibility (CSR) Charter, through which it commits to follow principles contained in the United Nations Global Compact and International Labor Organization’s fundamental conventions. The charter therefore covers compliance with applicable laws, prevention of child labor, elimination of forced and bonded labor, non-discrimination, freedom of association and collective bargaining, providing a safe and healthy work environment. Therefore, HR policies at the hotel will meet the PS2 requirements. 

Third Party Workers: The hotel is expected to hire third party service providers mainly for housekeeping and security. Accor has a Procurement Charter 21 for its suppliers through which the suppliers commit to basic principles in line with the social and environmental commitment of Accor. As per these principles, Accor expects and encourages its suppliers (among other requirements) to comply with applicable legal requirements, protection of health and safety of their employees, prevention of child labor and operating in an environmentally sustainable manner. Therefore, during operation, the third party workforce management is expected to be in line with PS2 requirements.  

Occupational Health and Safety (OHS): The PMC will be responsible for management of various contractors on-site and ensuring their compliance with basic OHS and welfare requirements. As set forth in the ESAP, the company will develop an environmental, health and safety (EHS) manual for construction activities as well as a monitoring procedure and check-list which will include: 

(i)   clear EHS and working conditions requirements (in line with IFC PSs and legal requirements) to be implemented at the site; 

(ii)   clear roles and responsibilities of company, PMC and contractors’ personnel for implementation and monitoring on-site;  

(iii)   consequences of non-compliance for the contractors and their method of implementation;  

(iv)   requirements on labor law compliance including prevention of child labor;

(v)   labor camp guidelines in line with the IFC guidance note on workers’ accommodation (though considering the location of the site, no labor camp is expected on-site); and 

(vi)   construction management practices to minimize the impact on neighboring communities.

The manual will also describe specific processes on dust control and waste management. The clauses related to the EHS manual will be included in the contracts signed with the contractors and PMC to ensure that the contractors act in a manner consistent with the requirements of the PS2.IFC will review the implementation of the construction safety manual on-site through a site visit and documents review.

For the operation phase, in line with its requirements (as available in the public data), Swissotel will identify, assess and minimise risks as per recognized OHS management systems (e.g OHSAS 18001) requirements and implement required management procedures, aligned with the EHS monitoring procedure.

  Resource Efficiency: The company has committed to design the hotel in order to obtain IFC Green Excellence in Design for Greater Efficiencies (EDGE) certification therefore, the hotel is expected to be at least 20% more efficient in energy, water and materials usage.

During the operation stage, the hotel will monitor key parameters on energy and water efficiency as mandated by the Swissotel’s requirements. It was noted (though public data) that Swissotel and Accor Group have sustainability programs which include goals on energy and water efficiency. The company will also monitor and compile data on energy and water consumption as part of the monitoring framework discussed under PS1.

Water and energy supply: Water for the hotel will be sourced on-site borewell or water supply authority’s pipeline. The raw water will be further treated (through media filtration, activated carbon filtration and disinfection) and the treated water quality will be monitored to confirm that it meets the national potable water quality and Swissotel standards for various uses.

The electricity will be sourced from the grid. However, based on preliminary designs, it is estimated that considering the power situation in Dhaka, two diesel generators (DG) (of 2000 KVA capacity each) will be provided as back-up for the grid power cuts. The diesel generators will be provided with acoustic enclosure and stack of adequate height.

Pollution Prevention: The hotel will have an activated sludge process based sewage treatment plant (STP) on-site to ensure treatment of the wastewater as per local standards and WBG EHS Guidelines. The treated wastewater will be discharged into the municipal sewerage system.

As regards waste management, the construction waste and waste generated from the operations will be managed according to applicable legal requirements as well as mitigation measures identified in the EIA report. The required waste management processes will be defined in the EHS Manual for construction period. 

During operation, the non-recyclable waste will be disposed of through the municipal waste disposal systems. The other recyclable solid waste (paper waste, packaging materials, plastics etc.) will be sorted and sold to local agencies that in turn recycle these waste. Food waste will be disposed of either through municipal waste disposal system or provided as animal feed to local pig farms. Used oil (from the back-up diesel generator maintenance) and batteries will be disposed of through authorized recyclers.

Emissions are primarily from backup diesel generators (DG) The DG set emissions will be monitored and managed in accordance with environmental permit conditions and as part of the monitoring framework discussed under PS1 .

GHG emissions: Based on the available information on fuel and electricity consumption, the GHG emissions for the Project are estimated to be 3000 tonnes CO ₂  equivalent/year.

  Regarding Life and Fire Safety (L&FS), the hotel’s systems are being designed with respect to Bangladesh national building code (BNBC) requirements and Swissotel’s Design and Construction Standards which are based on Unites States’ National Fire Protection Association (NFPA) standards. Therefore, the hotel’s L&FS systems are expected to meet the WBG EHS guideline requirements of compliance with an internationally accepted L&FS code (NFPA in this case). 

As set forth in per the ESAP, once  the design is completed, the company will commission a L&FS consultant (acceptable to IFC), to review the site specific architectural brief and confirm that all the L&FS-related aspects of design are consistent with an internationally recognized L&FS code (US NFPA), as required under the L&FS section of the WBG General EHS Guidelines. Following construction, the L&FS consultant will inspect the newly constructed building and submit to IFC, a professional certification that the hotel is constructed in full compliance with previously approved engineering design, and that all L&FS systems were installed as designed and tested in accordance with international requirements. Any remedial measures needed to bring the building into compliance with IFC guidelines will be completed within a timeframe agreed with IFC.

The hotel’s kitchens will be operated to meet international food safety standards as per Swissotel requirements. Potable water for all domestic needs such as drinking, food preparation and personal hygiene (washing or bathing) will be supplied through onsite water treatment plant which will treat the raw water to meet the local potable water quality standards as well as operator requirements. Domestic hot water will be maintained at sufficiently high temperature to prevent growth of legionella bacteria, and the hotel operation team will test to confirm the effectiveness.

During both construction and operation of the hotel, unarmed private security guard will be hired through external agency.

In terms of external communications, disclosure of this ESRS and ESAP will be company’s first disclosure of the E&S information. As set forth in the ESAP, the company will develop a community engagement and grievance mechanism including a process to engage with the neighboring communities, receiving and responding to their grievances (e.g. through a grievance box).

  The Company will disclose this ESRS and the ESAP locally at the following address:

Bengal Hotels and Resorts Limited 

Bengal House

75 Gulshan Avenue

Gulshan 1

Dhaka 1212

Enquiries and/or comments about the Project may be directed to:

Mr. Humayun Kabir

Managing Director

Bengal Hotels and Resorts Limited 

Bengal House

75 Gulshan Avenue

Gulshan 1

Dhaka 1212