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: Land Acquisition and Involuntary Resettlement, PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7 - Indigenous Peoples and PS8 - Cultural Heritage are not considered relevant for this project at this time as none of the parcels of land acquired for warehouses to date have impacted on the aspects covered by these Performance Standards. Where applicable, for future sites, the management of the relevant aspects of these Performance Standards will be managed under Performance Standard 1.

This project has been categorized as a category B project in accordance with IFC’s Policy on Environmental and Social Sustainability. The environmental and social risks and impacts associated with this project are limited, site-specific and can be readily addressed through generally accepted mitigation measures as described in this document and the attached Environmental and Social Action Plan (ESAP).

The main environmental and social risks for this project relate to ALP’s management of environmental and social impacts in line with applicable laws in countries of operations and IFC Performance Standards; labor and working conditions of employees and contract workers, including occupational health and safety standards during construction and operation; resource efficiency particularly in relation to the management of energy consumption during operations; and community safety, particularly in relation to the movement of vehicles during construction and operations.

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.

IFC’s assessment considered documentation of ALP’s management of its environmental, safety and health performance; compliance with applicable local laws; and stakeholder engagement and disclosure of information about the project and its operations.



Environmental and Social Assessment and Management System (ESMS): ALP is a greenfield venture and whilst ALP has some policy documents covering the environmental and safety aspects of its activities, there is no formal ESMS in place for the systematic identification, assessment and management of environmental and social risks and impacts associated with its activities. In order to manage these risks and impacts, as indicated in the ESAP action item 1, ALP shall develop an ESMS suitable to the scale of its activities (development and operation of warehouses) which meets the requirements of applicable local laws and IFC Performance Standards. The ESMS shall include policies, plans, manuals and procedures to manage the identified risks. The ESMS shall also incorporate relevant aspects (such as occupational health and safety) covered in the WBG General Environmental Health and Safety (EHS) Guidelines.



In relation to the acquisition of land, as previously indicated, three sites in Nairobi have been identified for warehouses – Tatu, Tilisi and Embakasi. Whilst these transactions have been conducted on a willing-buyer willing-seller basis, as indicated in ESAP action item 2, ALP shall develop and implement a Land Acquisition Framework, in order to ensure that the objectives of Performance Standard 5 are taken into consideration in future land acquisition processes. Where applicable, appropriate measures to mitigate impacts of involuntary resettlement or displacement will be implemented.



It is noted that for the Tatu site in Nairobi, an ESIA and an Environmental Management Plan (EMP) have been completed; the assessment is pending approval by the National Environmental Management Agency in Kenya. As indicated in ESAP action 3, ALP shall develop generic terms of reference for environmental and social impacts assessments (ESIAs) for development projects that meet the requirements of the Performance Standards and local regulations. In addition, ALP shall develop standard specifications and/or procedures for environmental and social risks and impacts related to construction to be included in invitations to tender for construction works with the intention of contractually obligating engineering, procurement and construction (EPC) contractors to manage these risks and impacts. The specifications shall cover OHS requirements; the implementation of project EMPs and appropriate project environmental, health and safety (EHS) plans including community grievance procedures where applicable; good international industry practice and WBG EHS Guidelines as well as the Performance Standards. This has been included in ESAP action item 4.



Policy: ALP currently has an Environmental and Social Policy which cover
s its commitment to carrying out its activities in an environmentally friendly and sustainable manner as well as commitment to continuous improvement of environmental and social performance in all its activities. The policy commits the company to adherence to national legislation and good international industry practice. In addition, ALP’s contractors, suppliers and partners will be required to adopt a similar level of commitment to environmental and social sustainability. ALP also has a Sustainability Framework which highlights the elements to be considered in the development of sustainable warehouses.



Management Programs: As a greenfield, ALP currently has no management programs in place for managing the environmental and social aspects of its activities. As indicated above, ALP shall develop and implement a management system; this ESMS shall cover management programs for environmental and social aspects of the company’s activities, covering both construction and operation.



Organizational Capacity: At present, ALP has designated a Health, Safety and Environmental (HSE) Officer who will oversee the implementation of the ESMS once developed. In addition, appropriate training shall be provided to all employees to ensure adequate implementation of the company’s ESMS.



Emergency Preparedness and Response: Emergency preparedness during construction shall be managed by contractors; ALP shall ensure that appropriate plans are included in the EHS plans for each project. As part of its ESMS, ALP shall develop an emergency preparedness and response plan to manage potential emergencies associated with warehouse operations. The plan shall identify emergency scenarios and the required response mechanisms for addressing these emergencies. All emergency procedures and communication protocols shall be documented in the plan.



Monitoring and Review: As covered in ESAP action item 1 for this project, ALP shall define key performance indicators (KPIs) in order to monitor E&S parameters such as lost-time incidence frequency rate and accident free days; compliance with legal and regulatory requirements; water and energy consumption; community complaints and community engagement activities. These KPIs shall be reported to senior management as part of the company’s monitoring and review process for E&S risk management.

External Communications and Grievance Mechanism: EPC contractors shall be responsible for managing any grievances during the construction phase. As indicated above, ALP shall develop E&S standards for contractors including implementation of grievance procedures. For the operations phase, as covered in the ESAP for this project, ALP shall develop an ESMS which includes a grievance mechanism which shall be applied at all sites.

IFC’s review considered ALP’s activities with regards to fair, safe and healthy working conditions and is based on an assessment of the practices in place and a review of the documents and information made available during due diligence process.



ALP currently has four employees based in Nairobi, Kenya; the recruitment process for additional employees is ongoing.



Human Resources Policies and Procedures: ALP has a Labor Policy and related policies such as disciplinary, code of conduct and grievance policies; however a full suite of HR procedures is yet to be developed. As indicated in the ESAP action item 5, ALP shall develop human resources procedures which meet the requirement of this Performance Standard as well as applicable labor laws in Kenya and other countries of operation.



Workers’ Organization: ALP employees will be permitted to form and join worker’s organizations of their choosing and to bargain collectively; there shall be no restrictions or interference where permitted under the labor laws in its countries of operation.



Non-Discrimination and Equal Opportunity: As part of the HR policies and procedures, ALP shall develop and implement a formal policy on non-discrimination and equal opportunity to cover all aspects of its operations.



Grievance Mechanism: ALP has a Grievance and Harassment Policy which describes company’s approach to managing grievances in the workplace and creating an environment free of harassment for its employees. ALP shall ensure that the HR procedures incorporate adequate worker grievance mechanism procedures as well as the procedure for managing harassment in the workplace



Occupational Health and Safety (OHS): The potential OHS risks related to the construction phase of ALP’s activities include – working at height, use of heavy equipment, use of explosives, exposure to electricity cables, exposure to dust and noise and traffic management on site. The typical OHS risks during operations include working with machinery, noise, and lifting of heavy materials. ALP has an OHS Policy however, no procedures have been developed. ALP shall develop appropriate OHS procedures for the operations of its warehouses which are consistent with the requirements of this Performance Standard and local laws in its countries of operation. This has been included as action item 6 of the ESAP for this project. KPIs for this project will include OHS indicators which will be documented as part of the project improvement process. In addition, ALP shall provide appropriate protective equipment for all its employees and provide the required training to ensure that its employees work in a safe manner. ALP shall ensure that its EPC contractors implement adequate OHS procedures and provide adequate training and protective equipment to all workers. As indicated under Performance Standard 1, OHS standards shall be included in the terms of reference for EPC contractors.



Workers Engaged by Third Parties: It is expecte
d that ALP will engage a number of third party employees during the development and operation of its warehouses. As indicated in ESAP action item 7, ALP shall develop a policy and a procedure for managing and monitoring the performance of such third party employers in relation to the requirements of this Performance Standard, including consideration for worker grievance mechanisms and fair working conditions.

IFC’s review considered ALP’s management of resource use, wastes and pollution aspects and the impacts on the surrounding human and natural environment. The review focused on available information and estimates provided by ALP.



Construction activities will include excavation, minimal blasting, drilling, and crushing of aggregates, brickwork and erection of structures. Potential pollution issues during construction will be those typically associated with construction sites including – the discharge of contaminated soils, diesel and oil spills, dust and noise emissions, water pollution etc. During operations, the issues include management of waste oil and other fluids, energy consumption and noise emissions.



Pollution Prevention: Air emissions will primarily be dust/particulates from the construction phase and fugitive emissions from equipment during construction and operations. Noise pollution is expected during construction especially during excavation, blasting and drilling. To manage emissions from generators and fugitive emissions from vehicles, ALP shall ensure that adequate maintenance programs for vehicles and equipment are implemented. ALP needs to ensure that contractors implement dust suppression measures and that appropriate measures are taken to minimize noise emission from the sites. As indicated in Performance Standard 1, ALP shall ensure that contractors implement adequate EHS plans. Noise pollution during operations will be mostly limited to vehicular movement and power houses. These impacts are expected to be localised and all employees will be provided with adequate ear protection to minimize noise impacts.





Resource Efficiency: Energy and water for construction projects are expected to be provided by on-site generators and boreholes. For operations, the warehouse designs shall incorporate resource efficiency measures such as natural ventilation, natural lighting, spatial considerations, and shatterproof construction materials. Where possible, energy will be supplied by renewable power sources such as solar power. ALP has plans to implement green building measures in line with IFC’s EDGE program. ALP shall develop appropriate benchmarks for monitoring the green building initiatives.



Greenhouse Gas (GHG) Emissions: GHG emissions associated with the construction and operations are not expected to be significant as the activities are not energy intensive. In the case of refrigerated warehouses, ALP shall ensure that refrigerating systems do not contain phased-out flourocrabons. The project will therefore not be required to quantify and report on the CO2-equivalent emissions as required under this Performance Standard for projects with emissions exceeding 25,000 tCO2eq/annum.



Solid Wastes: Construction wastes are expected to include domestic waste, inert waste (rubble, spoil) recyclables (plastics, paper, metals) and small quantities of oil and oil-contaminated materials. ALP shall ensure that the EMPs and
EHS plans for the construction projects cover the management of wastes. During operations, solid wastes are expected to be collected by the local county authorities. As part of the procedures for the ESMS, a Waste Management Procedure will be developed and implemented by ALP; this has been included in the ESAP as action item 8 for this project.



Pesticide Use and Management: Pest control measures will be required at the warehouses. It is expected that non-chemical methods such as traps and electric insectocutors will be used at the warehouses.



Hazardous Materials Management: Hazardous materials include fuels and lubricating oils. Petrol/diesel for generators will be stored in above-ground storage tanks fitted with containment bunds. Any other hazardous chemicals used during construction will be stored in small quantities on site and the measures identified in the EMPs will be implemented to minimize any impacts.

IFC’s review considered the potential impacts of ALP’s activities on the local community in the various locations. The assessment is based on the documents provided for review by ALP.



Community Health and Safety: The warehouses are expected to be located in industrial areas with limited impacts on communities. Influx of migrant workers will be limited as most of the workers are expected to be recruited from the local area. Traffic impacts during construction could constitute a nuisance to neighboring facilities. Impacts on community safety and traffic safety during construction shall be addressed through the mitigation measures identified in the project EMPs and EHS plans. For the operations, the movement of trucks may have impacts on neighboring facilities within the industrial areas. As indicated in ESAP action item 9, ALP shall establish preventive and control measures for traffic safety consistent with the section on traffic safety in the WBG General EHS Guidelines.



Security Personnel: During construction and operation, site security will be managed by private security firms which will provide trained unarmed security personnel. ALP shall ensure that the security contractors comply with local regulatory requirements as well as the requirements of this Performance Standard; as indicated in ESAP action item 10, ALP shall develop standard terms of reference for security contractors that will be used during the construction and operations for each site.

Stakeholder engagement shall be included in the ESIAs for individual projects. As indicated under Performance Standard 1, ALP shall develop terms of reference for ESIAs which meet the requirements of the Performance Standards, including adequate stakeholder engagement. As previously indicated, ALP shall develop E&S standards for contractors including implementation of grievance procedures. For the operations phase, as covered in the ESAP for this project, ALP shall develop an ESMS which includes a grievance mechanism which shall be applied at all sites.

Name: Toby Selman
Address: Blixen Court, Lower Plains Road, Karen, Nairobi
Email: mailto:toby.selman@africawarehouses.com

Broad Community Support is not applicable for this project

Maris: ALP(38583) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
ALP shall develop and implement an Environmental and Social Management System commensurate with the scale of its activities and consistent with IFC Performance Standards. The system shall define roles and responsibilities, and include operational procedures, monitoring and reporting requirements, to enable operations to comply with local laws in the countries of operation and IFC Performance Standards. Amongst other elements, the management system will include: an emergency preparedness and response plan, HSE KPIs and a grievance mechanism for affected communities.	17-Feb-2017	Completed	Completed	12/31/2017
ALP shall develop a Land Acquisition Framework to manage the acquisition of land in line with Performance Standard 5	17-Feb-2017	Completed	Completed	6/6/2018
ALP shall develop generic terms of reference for environmental and social impacts assessments of potential greenfield property development projects that meet the requirements of the Performance Standards and local regulations.	17-Feb-2017	Completed	Completed	12/31/2017
ALP shall develop standard specifications and/or procedures for environmental and social risks and impacts related to construction to be included in invitations to tender for construction works with the intention of contractually obligating contractors to manage these risks and impacts. The specifications shall cover OHS requirements, Good International Industry Practice (GIIP) and WBG EHS Guidelines as well as the Performance Standards.	17-Feb-2017	Completed	Completed	12/31/2017
ALP shall develop and implement Human Resource Policies and Procedures which meet local laws in its countries of operation and the requirements of Performance Standard 2. The documents shall include, but not be limited to a worker grievance procedure and a non-discrimination policy	20-May-2017	Completed	Completed	12/31/2017
ALP shall develop and implement Occupational Health and Safety (OHS) procedures tailored to its activities. The procedures will include identification of managers/persons responsible for OHS performance, on-going training, maintenance of OHS performance statistics and a mechanism for reviewing deviations from procedures and improving performance.	20-May-2017	Completed	Completed	12/31/2017
Develop and implement a procedure to ensure contractor’s labor and working conditions comply with Performance Standard 2.	17-Feb-2017	Completed	Completed	12/31/2017
ALP shall develop and implement a Waste Management Procedure which meets the requirements of Performance Standard 3.	20-May-2017	Completed	Completed	12/31/2017
ALP shall develop and implement a Traffic Safety Procedure which meets the requirements of the WBG General EHS Guidelines	17-May-2017	Completed	Completed	12/31/2017
ALP shall develop generic terms of reference for security contractors which meet the requirements of Performance Standard 4.	17-Feb-2017	Completed	Completed	12/31/2017