38740 - VUS Training

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Environmental & Social Review Summary

Project Number

38740

Company Name

EAGLE HOLDINGS PTE LTD

Date ESRS Disclosed

Oct 18, 2016

Country

Viet Nam

Region

East Asia and the Pacific

Last Updated Date

Sep 25, 2022

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Sep 1, 2016
Signed : Sep 16, 2016
Invested : Sep 20, 2016

Sector

Other Training

Industry

Health, Education and Life Sciences

Department

Regional Industry - MAS Asia & Pac

Project Description

Vietnam US Society English International Joint Stock Company (“VUS” or “the company”) currently operates 15 training centers in Ho Chi Minh City, Vietnam serving about 38,000 students. The company offers English language training programs for each category of students including juniors, teens and adults as well as other premium and supplementary programs (http://www.vus.edu.vn/).

VUS typically rents rooms/ buildings in commercial and residential areas for purposes of training centers and the company doesn’t plan any construction of new buildings. Usually, prior to commencement of new centers operation the company refurbishes rented space so as to equip for training purposes.

The company intends to continue expanding its operations in Vietnam (“the project”). The project shall encompass both optimization of programs and expansion of the company’s physical presence.

IFC is considering a co-investment, with Aureos South-East Asia Fund II L.P. (“ASEAF II” or “the Fund”), an existing IFC investee fund (#29952, disclosed in November 2011) managed by The Abraaj Group (“Abraaj”). In the transaction, ASEAF II and co-investors (including IFC) will jointly invest in the project through a special purpose vehicle which is being set up and will be managed and controlled by Abraaj.

Overview of IFC's Scope of Review

IFC’s environmental and social (E&S) review of this project included:

- A desk review of E&S due diligence as conducted by ASEAF II vis-à-vis IFC performance standards requirements;
- A review of publicly available information in respect to environmental, health, safety (EHS) and social performance of VUS.

E & S Project Categorization and Applicable Standard

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 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
Impacts related to PS:3 Resource Efficiency and Pollution Prevention, 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 expected because only minor amount of non-hazardous wastes is/will be generated during operation of training centers (solid waste from training centers is collected by the licensed contractor for further treatment and disposal), VUS doesn’t own any land plots or buildings, all training centers are/will be housed in the rented premises and centers located in well-developed urban areas.

Based on information reviewed by IFC this proposed investment is expected to have limited E&S impacts which are likely to be site-specific and not significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria, as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy.

Key E&S issues associated with this project include: company-wide management system to assess and manage limited E&S risks (especially related to screening of new premises) and life and fire safety (L&FS) of students and staff through proper operation of the premises; assurance of fair labor and working conditions for the company’s personnel and third-party workers; and any impacts on safety and security of its students and nearby residents.

Environmental and Social Mitigation Measures

Stakeholder Engagement

Broad Community Support

Environmental & Social Action Plan

Title	Anticipated completion Date
Develop and implement an environmental and social management system (ESMS) in accordance with Performance Standard 1 requirements. The ESMS should include: (i) the E&S policy and relevant standard operational requirements, ), (ii) a procedure for screening the potential training center location against the minimum corporate E&S standards prior to entering into a new lease agreement, and (iii) monitoring procedures related to implementation of L&FS directive and grievance mechanisms (for employees and external stakeholders	04/30/2017
Develop an external grievance mechanism which will allow students and local communities to raise any concerns.	04/30/2017
Revise / update key employment contracts	01/31/2017
Update the HR policy (provisions in respect to non-discrimination, avoidance of child and forced labor should be incorporated).	04/30/2017
Enhance / strengthen existing background checks on security personnel and will provide training to security personnel on interaction with students / parents.	04/30/2017

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Environmental and Social Mitigation Measures

Stakeholder Engagement

Broad Community Support

Environmental & Social Action Plan

Similar Projects

Projects

Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Identified Applicable Performance Standards

Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

Environmental and Social Mitigation Measures

PS 1: Assessment and Management of Environmental and Social Risks and Impacts

PS 2: Labor and Working Conditions

PS 4: Community Health, Safety and Security

Stakeholder Engagement

Stakeholder Engagement

Local Access of Project Documentation

Broad Community Support

IFC's Determination of BCS

Environmental & Social Action Plan

Environmental & Social Action Plan

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