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
GNDI owns or leases 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, PS7: Indigenous Peoples and PS8: Cultural Heritage, are not applicable.

IFC’s proposed investment will support acquisition of health care facilities but, as yet, for the undefined projects; therefore, it is possible that other PSs apply. The company will develop an E&S management system, as will be further discussed in the next sections, in line with IFC’s Performance Standard, which will be implemented in all of its existing and future projects and, as needed, applicability of other PSs will be assessed by GNDI.

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 GNDI’s capacity to expand its environmental, health, safety and social management system in line with IFC’s PS requirements to its existing and new facilities; occupational health and safety during operational and construction/renovation phase, implementation of an internal grievance mechanism in line with IFC’s PSs, management life and fire safety elements; resource efficient design and implementation of an external communication mechanism where interested parties can register their concern for the new projects.

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 and Policy: Other than a corporate level waste management policy, GNDI does not have a corporate level E&S management system in place. Hospitals and clinics are relatively decentralized and each has its own management systems. The systems in place included documented responsibilities for waste management, control of medicines, emergency plans for fire/evacuation, safe working instructions that relate to disease control and personal protection. Almost all hospitals are certified according to Organização Nacional de Acreditação (ONA, a Brazilian standard, which focus on physical resources, materials, equipment, financial resources, organizational, human, safety management in health care service providers). One of the hospitals, Santa Cecilia, certified its management system according to ISO 14001, international environmental management system standard, which is generally in line with IFC’s PSs. GNDI has a plan to achieve adherence to the basic policies of Joint Commission International (JCI) and ISO 14001 in all of its hospitals by 2018, however the plan does not include clinics. As per ESAP item # 1, GNDI shall develop and implement a corporate level E&S management system, in line with IFC’s PS requirement in all of its existing and future facilities, including hospitals, medical centers (clinics), in company services (ambulatories and units) and warehouse operations. E&S management system shall include (but not be limited to); (i) a corporate level E&S policy, (ii) procedures for identification of risks and impacts; (iii) management programs to mitigate the risks and impacts (both for existing and future projects for their renovation and operational phases); (iv) corporate and site level E&S teams with adequate capacity and competency; (v) corporate level emergency preparedness and response plan (master plan); (vi) E&S performance monitoring and review procedures for all of its sites with reporting requirements to senior management; and (vii) adequate mechanisms for stakeholder engagement and external communication and grievance mechanisms.



Identification of Risks and Impacts and Management Programs: According to Brazilian laws, environmental impact assessment is not mandatory for new hospital development or expansion of existing units. New facilities must obtain a series of construction and operation licenses applicable to hospitals; which typically involve an analysis of basic environmental considerations, impacts from noise and traffic, and effects on local property valuations. GNDI has developed a license matrix to monitor the status of its construction and operational licenses status and progress. GNDI technical and engineering departments review the matrix on a monthly basis and update its senior management. GNDI also prepared waste management plans (known by its Portuguese acronym, PGRSS) for its facilities which are approved by relevant authorities. As part of its investment/ac
quisition decision making process, the company conducts financial and legal due diligence including that related to operational and environmental permits/licenses/authorization checks. However, there is no documented system in place to ensure that the potential projects will be screened against IFC’s PS requirements and if needed, actions plans to bridge identified gaps to be developed and implemented. As per ESAP item 1, referred above, GNDI will develop and implement an E&S management system, which will include procedures for identification of risks and impacts and management programs to mitigate the risks and impacts, both for existing and future projects for their renovation and operational phases.



Organizational Capacity and Competency: GNDI has an E&S organization where responsibilities are shared by three main departments. The corporate level HR director is responsible for labor/employee relations and occupational health and safety issues. The Infrastructuredirector is responsible for environmental management, including effluent monitoring and waste management, the executive director of infrastructure is responsible for efforts to improve resource efficiency, life and fire safety requirements, construction / renovation contractors’ management in terms of E&S, including day to day monitoring of their compliance versus contractual E&S requirements. Those responsibilities are delegated to directors, technicians, admin staff and nurses at site level. The senior managers and mid-level staff whom the IFC met in these functions are all well-trained, well-seasoned professionals, often with years of experience in their areas. However, senior-level oversight of E&S functions, are dispersed across different departments. Thus, as per ESAP item 2, GNDI shall nominate an E&S coordinator, reporting to senior management directly, who will oversee the overall implementation of the E&S management system in line with IFC’s PS requirements.



Intermedica has a structured training program to manage its employees’ learning needs, which includes training sessions during the first month of employment for all workers, covering aspects associated with the company’s values and strategies, Code of Conduct, use of personal protective equipment, and technical knowledge according to the specific functions. In addition, ongoing trainings are provided according to workers’ needs and career development plans, including leadership development programs for coordinators, managers, and directors.



Emergency Preparedness and Response: GNDI has a documented emergency preparedness and response plan that includes evacuation, firefighting and first aid procedures for each individual facility. Evacuation plans are in place on each floor of existing facilities. Portable fire extinguishers, fire hydrants, and alarms were observed in the facilities visited. Emergency exits are clearly marked and evacuation exercises and fire drills are conducted annually. The fire drills generall
y do not include patients’ evacuation, however GNDI tests its capacity to move patients incapable of self-preservation. For the new facilities, to ensure similar procedures will be developed and equipment will be provided, as per ESAP item 1, GNDI shall develop a corporate level emergency preparedness and response plan (master plan) which each of its site to adapt at the local level. These plans shall contain an evacuation plan, a communications plan, training program, drills, fire response plan, and a response plan in the event of a catastrophe or disaster with multiple victims.



Monitoring and Review: The company’s monitoring system includes bacteriological monitoring on the floors and walls, waste water effluent quality, exposure to radiation, incident rates and at the hospitals water and energy consumption. Though E&S performance is reviewed at site level, and mitigation/improvement plans are developed and implemented in case the performance is not in compliance with the internal targets and/or legislation, it is not reported to senior management periodically. In line with ESAP item 1, GNDI’s E&S management system will include E&S performance monitoring and review procedures for all of its sites with reporting requirements to senior management.

As of October 2016, Intermedica had approximately 8,700 direct employees, 1,400 third-party workers, and approximately 2,000 doctors who also work for Intermedica on the basis of third-party workers. Of the total staff, approximately 78 percent are women. During the appraisal, Intermedica reported that there were several labor lawsuits pending against the company, most of them related to claims for overtime, social security payment, and third-party workers claiming the same labor rights that direct workers are entitled to under Brazilian labor regulations. These lawsuits are being managed by the company’s legal department in accordance with Brazilian legislation.



Human Resources (HR) Policies and Procedures, Working Conditions and Terms of Employment: Intermedica has human resources procedures applicable to all employees, the procedures are aligned with the Brazilian labor code (known as the Consolidação das Leis de Trabalho, or “CLT”). The company offers its workers all the basic benefits guaranteed by Brazilian law, which is prescriptive and consistent with PS2; the compensation package as agreed in the collective agreements with the labor unions, and additional benefits in order to attract and retain high-performing staff, including performance-based salary bonuses for directors. The Code of Conduct, which is communicated to all new employees during the induction process, has well-defined statements regarding non-discrimination, equal opportunities, ethical behavior, child and forced labor, and relations with various stakeholders. A Code of Conduct Monitoring Committee (known as Comitê de Acompanhamento do Cumprimento do Código de Conduta Ética) has the overall responsibility for the implementation of the code and reports directly to the presidency of the company.



Protecting the Workforce: Intermedica abides by all legal prohibitions against under-age employment and forced labor. Minimum age of employment in Intermedica is 18 years old, except for apprentices, which can range from 14 to 24 years of age according to Federal Decree 5.598/2005. Intermedica has currently 450 people with disabilities amongst its workforce complying with Federal Law 8.213/91.



Workers’ Organization: As per the CLT and as determined in the company’s Code of Conduct, employees have the right to freedom of association, and there is no restriction to collective bargaining. Under Brazilian legislation all employees are registered with a union, and in the case of Intermedica, its employees are represented by seven different unions. The company abides by the collective agreements in terms of salaries and benefits negotiated through collective bargaining. Almost 97 % of its employees are unionized and according to Intermedica, there is no difference between unionized and unionized employees in terms of benefits.



Retrenchment: When hospitals are acquired Intermedica conducts an organizational restructuring in order to improve the efficiency of the existing proc
esses. This process, as confirmed by the HR department, is conducted according the Brazilian legislation. The company is not planning any retrenchment in the short or medium term. However, in the event of retrenchment, Intermedica will follow the requirements of PS2 in addition to Brazilian legislation and requirements under its agreements with the unions.



Grievance Mechanism: Workers’ grievances, concerns, and/or any misconduct associated with the Code of Conduct can be raised through email, directly with the human resources department, and through the employees’ satisfaction survey. As per the ESAP item 3, GNDI shall develop and implement a grievance mechanism to ensure there is a clear procedure to receive, register, and address grievances, and that the mechanism is communicated throughout the company at the administrative and operational levels. The mechanism will allow for anonymous complaints to be raised and addressed and will include contractor’s workers.



Occupational Health and Safety: Intermedica is committed to ensure a safe and healthy work environment for all of its employees in line with the Brazilian regulatory standards related to occupational health and safety (known as Normas Regulamentadoras de Segurança e Saúde no Trabalho, or NRs). The company has a specific team dedicated to the health of workers in the workplace (known as Serviços Especializados em Engenharia de Segurança e em Medicina do Trabalho, or SESMT), which consists of 45 dedicated staff members, including occupational health and safety (”OHS”) coordinators, occupational doctors and nurses, safety engineers, and safety technicians. During the appraisal it was reported by Intermedica that in order to achieve full compliance with the Brazilian regulations the company is hiring additional 20 workers to join the OHS team, which will ensure all OHS programs are implemented and reviewed as required by the national legislation.



The company has in place the required plans, processes, and worker safety committees to comply with Brazilian regulations. Hospitals, medical clinics, and supporting facilities have Workplace Risks Prevention Programs (known as Programa de Prevenção e Riscos Ambientais, or PPRA), which identify occupational risks and determine appropriate control measures. Personal protective equipment (namely surgical gloves, masks, glasses, etc.) is provided at the hospitals and clinics, and staff are trained in its use. In addition, there are Medical Control Programs for Occupational Health (known as Programa de Controle Médico de Saúde Ocupacional, or PCMSO) to monitor the occupational health of all employees. Examples of these programs, which are updated every year, were reviewed during the appraisal. The company has workplace accident prevention committees known as CIPA (Comissão Interna de Prevenção de Acidentes), which conduct various training and awareness efforts on workplace safety.



In 2015, Intermedica registered 147 accidents among its s
taff, which resulted in 358 lost workdays primarily from needle-related injuries (cuts or punctures). All OHS accidents are investigated by the OHS team, and legally-required Workplace Accident Communication Forms (known as Comunicação de Acidente de Trabalho, or CAT) are sent to the Ministry of Social Security. In 2015, the lost time injury frequency rate (“LTIFR”) was 9.58 injuries per million hours, which is above good international industrial practices data for hospitals (http://www.bls.gov benchmark data of 7 for health care and social assistance sector and/or 8 for hospitals). As of October 2016, Intermedica had registered 68 accidents, which resulted in 216 lost workdays and 5.66 LTIFR. As per the ESAP item 4, GNDI shall review its OHS management program to improve OHS performance and will develop an action plan in line with the Brazilian regulatory standards and the WBG’s EHS Guidelines for Health Care Facilities, including the enhancement of periodic inspections, monitoring, and review of OHS performance.



Workers Engaged by Third Parties: Intermedica outsources some services to third parties, such as catering services, cleaning activities, safety services, transportation, and maintenance. The company’s contracts with these contractors require full compliance with Brazilian regulations and also requires contractors to acknowledge and comply with GNDI´s Code of Conduct by signing the Code of Conduct as an appendix of the contract.



During the renovation works of new assets acquired within the scope of the project, contractors will be employed for civil, mechanical and electrical works in order to improve the facilities to GNDI’s standards. All construction contractor companies are required to have E&S coordinators and E&S experts to monitor and report their performance to GNDI. According to construction contract’s standard E&S covenants, contractors are required to conduct risk assessments, coordinate with GNDI for mitigation plans, and conduct daily and weekly E&S meetings with the Engineering Manager. GNDI has a system in place to effectively monitor contractors E&S implementations versus requirements. This includes daily site tours by the Engineering Manager and technical staff reporting to him. The E&S management system, which will be developed in line with the ESAP item 1, shall include contractor management system to ensure contractor’s E&S performance, such as incident rates will be monitored and will be considered to award new contracts.



Supply Chain: Intermedica purchases medical supplies and drugs from licensed manufacturers and suppliers. It sources office supplies from commercial vendors. None of these supplies are considered to be high-risk from a labor or biodiversity standpoint. All supplies are delivered either directly to Intermedica’s hospitals and medical clinics or to existing warehouses.

Resource Efficiency, Water and Energy and Material Efficiency Projects: Electricity is provided from the national grid for all facilities. Electricity consumption of the hospitals are around 230 kWh/m2, which is lower than the sectorial average consumption figure of 296 kWh/m2 (reference http://www.hercenter.org/facilitiesandgrounds/energy.cfm). It is estimated that the electricity consumption is lower as GNDI hospitals implemented several resource efficiency programs as mentioned in the paragraphs below in its existing facilities. As per the ESAP item 5, GNDI shall develop a corporate level resource efficiency design specification that will be implemented in the new facilities. GNDI’s resource and material efficiency program includes use of variable speed drives for pumps; use of energy saving lamps and use of occupancy sensors. The program can be enhanced in line with good international industry practices including insulation of roof surfaces and external walls; variable refrigerant volume cooling system; air conditioning with air and water cooled chillers; lightening controls for corridors, low flow showerheads and faucets in all bathrooms, dual flush for water closets and water efficient urinals in all bathrooms, which can be incorporated into design specifications per the ESAP item 5.



Generally electrical heaters are used to provide hot water, whereas a few hospital installed natural gas boilers. Heaters/boilers are used for hot water supply only as the hospitals are located at relatively a warm region. Natural gas is also used in the cafeteria for cooking purposes at the hospitals.



There are standby generators in every facility. The generators generally have internal fuel systems. Where the stand alone fuel tanks are present, secondary containers are installed.



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 and measures are taken in line with the existing infection control mechanisms. Water quality is in line with Brazilian legislative requirements. Overall water consumption is around 115.000 m3 per year. Drinking water is generally supplied by third party companies and drinking water quality monitoring is performed by an external service provider on a periodical basis.



GHG Emissions: Emissions are generated from; (i) standby generators; (ii) natural gas heaters / boilers; (iii) its electricity usage (including air conditioning as well); and (iv) fuel consumption of the ambulances. There are no incinerators for waste management and hygenization of the equipment is done by electrical autoclaves. Carbon dioxide (CO2) equivalent emission (including hospitals, clinics and refrigerants) upon project completion is estimated to be increased from 8.300 tons per annual to around 12.500 tons per annual. The company is therefore not consi
dered to be a significant emitter of GHGs.



Wastewater Treatment: All domestic waste water from cafeteria, 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.), chemicals from laboratories and/or from chemotherapy units are collected separately and disposed by certified third party waste companies.



Solid Waste Management and Hazardous Materials: GNDI has developed and implemented a hospital waste management plan (known by its Portuguese acronym, PGRSS) in accordance with the Brazilian regulation No. 306 of ANVISA (National Agency for Sanitary Vigilance), issued in 2004, and CONAMA Resolution No. 358 (2005) at all of its sites.



Medical wastes, chemical wastes, domestic wastes and packaging wastes are segregated, stored and recycled/disposed by third party waste contractors. Medical waste, at hospitals and clinics, 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, and wastes from oncology and chemotherapy, where the radioactive wastes are transferred and disposed by authorized companies, there are no other sources of radioactive wastes. . In case future operations include such treatments, GNDI will revise its E&S management system accordingly and develop specific procedures and standards for the appropriate handling and disposal of relevant wastes and effluents.



The sites for temporary storage of waste – whether domestic waste, chemical waste, or hazardous waste – were observed by the IFC to be clean, well-organized and with appropriate access restrictions, thereby preventing contact with or handling by unauthorized people.



According to its management, GNDI has implemented hazardous materials and waste minimization programs and hazardous chemicals have been replaced with relatively less hazardous alternatives, such as limiting the consumption of x-ray chemicals by moving imaging diagnostics into digital solutions. Application of the E&S systems in line with ESAP item 1, will ensure that the hazardous materials and waste minimization programs will be in place at the existing and new facilities.

Community Health and Safety: Medical equipment is strictly controlled in accordance with Brazilian laws to eliminate the risk to community. 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. GNDI 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.



ANVISA (the National Agency for Sanitary Vigilance), reviews and approves hospital engineering designs, issues operating licenses, and regularly inspects hospitals for compliance with patient health and safety requirements. In all of its facilities GNDI implements clinical and non-clinical risk management committees to prevent hospital infections (known by its Portuguese acronym, CCIH). These committees analyze infection risks and monitor the effectiveness of prevention and control measures, including waste collection, access control, and facility cleaning; and they are also involved in investigating cases of hospital-related infections to understand and address their causes.



At the hospitals, where catering service is provided to patients, raw materials are stored in cold rooms and/or dry rooms with temperature monitoring in the kitchens, separated from other materials. Good hygenization practices are followed and there is a pest control system in place.



During the renovation of the acquired or existing facilities, construction 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, lighting of the area (if needed) will be implemented in line with the E&S management system, which will be developed and implemented per ESAP item 1. During the site visit, the project locations, where renovation is ongoing was clearly fenced, and relevant warning sign, including unauthorized access, were in place.



Infrastructure and Equipment Design and Safety and Emergency Preparedness and Response: Existing facilities are 1 to 7 floors high. Life and fire safety (“L&FS”) 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 spr
inklers if the building is 20 m or lower. Evacuation and fire drills are performed at the facilities annually. There are nominated staff for guiding the patients to the exits and according to documented plans, immobilized patient will be evacuated by the nominated staff. As per the ESAP item 6, GNDI shall engage with professional services of a qualified L&FS consultant acceptable to IFC to: (i) conduct a review of the existing facilities (a representative sample of hospitals, clinics, warehouse, head office, with a specific focus on the ones that are programmed for renovation -(or under renovation/construction-, including Grupo Santamalia, Hospital Guarulhos and Unimed ABC) to evaluate the emergency preparedness and response capabilities, including existing L&FS systems (such as detection and alarm systems; fire prevention; means of egress, in particular for patients; fire suppression systems such as sprinklers and extinguishers; emergency response plan; and operation and maintenance); (ii) prepare, if necessary, a Corrective Action Plan (“CAP”) for individual properties with proposed completion dates. The E&S management system, which will be developed per the ESAP item 1 shall ensure that; (i) a suitably qualified professional conducts a complete life and fire safety review of existing buildings slated for renovation. The findings and recommendations of the review are used as the basis to establish the scope of work of a Corrective Action Plan and a time frame for implementing the changes; and (ii) if it becomes apparent that life and fire safety conditions are deficient in an existing building that is not part of the project or that has not been programmed for renovation, a life and fire safety review of the building may be conducted by a suitably qualified professional. The findings and recommendations of the review are used as the basis to establish the scope of work of a Corrective Action Plan and a time frame for implementing the changes.



In addition, as per the ESAP item 7, GNDI shall develop standard requirements (master plan), applicable to the new facilities and those buildings programmed for renovation, 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 health care facilities, senior residences and site specific risks associated with each facility to be identified by a qualified professional). Furthermore, at the design phase, GNDI shall engage with 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 gu
idelines, as required under the life and fire safety section of the WBG EHS General Guidelines. 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.



Seismic / structural safety of the renovation works are reviewed by GNDI’s engineering department, either by its internal sources or by use of external consultants and are approved by local authorities before its implementation. Existing and future project locations are not on known earthquake zones, however, GNDI should identify and manage potential seismic and structural safety risks in future projects as part of its risk identification process as per ESAP 1.



Hazardous Materials Management and Safety and Community Exposure to Disease: As already discussed above under PS3 Resource Efficiency and Pollution Prevention and also under subsection on PS4 Community Health and Safety GNDI developed and implemented documented procedures for infection prevention and control in order to eliminate risk of community exposure to disease and as an output of implementation of the E&S systems in line with ESAP item 1, will ensure that the hazardous materials and waste minimization programs will be in place at the existing and new facilities. The company also contracted service providers to perform periodic testing and cleaning of internal air ducts to safeguard the health of employees and patients and prevent transmission of infectious agents through the internal ventilation system.



Security Personnel: For the hospitals and clinics, unarmed security personnel are employed, whereas there are armed security guards at the warehouse and head office. Security personal is provided through private contractors and they 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.



Under the ESAP item 8, the company will conduct a security risk assessment as per the requirements of PS4 to ascertain the risks posed by its security arrangements to those within and outside its facilities and to determine whether such private security personnel are being hired, equipped, and trained adequately in light of PS4, including on human rights issues, proper use of force, and appropriate conduct toward workers and other stakeholders who might come into contact with them. In addition, as per the ESAP item 9, the company will develop a clear policy and appropriate procedures and guidelines (e.g. a security management plan) for how to manage its armed guard force to avoid potential harm to employees and other stakeholders.

Intermedica is committed to promoting a healthy environment for its patients and clients. Based on that premise, the company has a health calendar to promote several activities throughout the year focused on prevention of diabetes and heart diseases, elderly well-being and quality of life, women (Pink October) and men’s health (Blue November), communicable diseases prevention such as zika and dengue, among others.

The company has multiple mechanisms for patients/clients to raise issues associated with the company''s management regarding quality of service (namely Ouvidoria), such as an online communication channel on the company’s website (http://www.gndi.com.br/web/guest/ouvidoria), call centers, customer service units, and satisfaction surveys, which are sent online to customers after the health service is provided.
However, the company does not currently have specific measures in place to engage with stakeholders and neighbors regarding construction projects and the disruptions from noise, dust, and traffic that might accompany them. As per the ESAP item 10, the company shall ensure an external grievance mechanism is available for stakeholders and neighbors of Intermedica’s construction/renovation projects.

Contact Person: Glauco Desiderio
Company Name: Grupo NotreDome Intermedica
Address: Av.Paulista, 867, 7 Andar - Bela Vista – Sao Paulo - Brazil
Email: mailto:Glauco.desiderio@intermedica.com.br
Phone: +55 11 3155-9276

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
ESAP 1 - GNDI shall develop and implement a corporate level E&S management system, in line with IFC’s PS requirement in all of its existing and future facilities, including hospitals, medical centers (clinics), in company services (ambulatories and units) and warehouse operations	06/30/2017
ESAP 2 -GNDI shall nominate an E&S coordinator, reporting to senior management directly, who will oversee the overall implementation of the E&S management system in line with IFC’s PS requirements.	01/31/2017
ESAP 3 - GNDI shall develop and implement a grievance mechanism to ensure there is a clear procedure to receive, register, and address grievances, and that the mechanism is communicated throughout the company at the administrative and operational levels. The mechanism will allow for anonymous complaints to be raised and addressed and will include contractor’s workers.	01/31/2017
ESAP 4 - GNDI shall review its OHS management program to improve OHS performance and will develop an action plan in line with the Brazilian regulatory standards and the WBG’s EHS Guidelines for Health Care Facilities, including the enhancement of periodic inspections, monitoring, and review of OHS performance.	03/31/2017
ESAP 5 - GNDI shall develop a corporate level resource efficiency design specification that will be implemented in the new facilities.	06/30/2017
ESAP 6 - GNDI shall engage the professional services of a qualified L&FS consultant acceptable to IFC to: (i) conduct a review of the existing facilities (a representative sample of hospitals, clinics, warehouse with a specific focus on the ones that are programmed for renovation -(or under renovation/construction-, including Grupo Santamalia, Hospital Guarulhos and Unimed ABC) to evaluate the emergency preparedness and response capabilities, including existing L&FSsystems (such as detection and alarm systems; fire prevention; means of egress, in particular for patients; fire suppression systems such as sprinklers and extinguishers; emergency response plan; and operation and maintenance); (ii) prepare, if necessary, a Corrective Action Plan (“CAP”) for individual properties with proposed completion dates.	03/31/2017
ESAP 7 - GNDI shall develop standard requirements (master plan), applicable to the new facilities and those buildings programmed for renovation, 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 health care facilities, senior residences and site specific risks associated with each facility to be identified by a qualified professional).	04/30/3017
ESAP 8 - The company will conduct a security risk assessment as per the requirements of PS4 to ascertain the risks posed by its security arrangements to those within and outside its facilities and to determine whether such private security personnel are being hired, equipped, and trained adequately in light of PS4, including on human rights issues, proper use of force, and appropriate conduct toward workers and other stakeholders who might come into contact with them.	04/30/2017
ESAP 9 - The company will develop a clear policy and appropriate procedures and guidelines (e.g. a security management plan) for how to manage its armed guard force to avoid potential harm to employees and other stakeholders.	06/30/2017
ESAP 10 - The company shall ensure an external grievance mechanism is available for stakeholders and neighbors of Intermedica’s construction/renovation projects.	01/31/2017