If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with these Performance Standards.  PS5-PS8 are not applicable to the project because the proposed facility is built on commercial land and was acquired through a willing buyer/willing seller transaction, no one is living on, or making a living from the land at this time. Therefore, no involuntary resettlement and conversion of natural/critical habitats will take place. There are no indigenous people and the presence of cultural artifacts are unlikely.

This is a Category B project according to IFC’s Environmental and Social Sustainability Policy because, on the basis of information reviewed by IFC, this investment will have limited adverse social and environmental and social impacts that are few in number and specific impacts and risks are expected primarily to occur on site, with construction impacts mainly being short term and not significant. Operational impacts are expected to be generally site specific and can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Fulfillment of the action items included in the attached E&S Action Plan (ESAP), adherence to the national laws and regulations, internationally recognized standards, the WBG/IFC EHS Guidelines for Tourism and Hospitality Development applicable to the Project will facilitate the project implementation in a sustainable manner.

Environmental and Social Assessment and Management Systems: WWE, which controls the construction of the Project aparthotel, does not have an Environmental and Social Management System (ESMS).  WWE in collaboration with the Operator will develop and implement as (ESAP Item # 1) an Environmental and Social Management System (ESMS) aligned with Performance Standard 1, Tourism and Hospitality Development guidelines, the World Bank Group’s (WBG) Environmental, Health, and Safety (EHS) Guidelines and national requirements. Specifically, the ESMS is to include: An overarching policy statement, objectives & targets; and an Organization capacity including roles and responsibilities.  Environmental and Social Management Plans to be developed and implemented as part of the ESMS include; (i) Labor and Human Resources (LHR) Plan; (ii) Environmental Health and Safety (EHS) Management plan; (iii) Waste Management (WM) Plan; (iv) Emergency Preparedness and Response Plan (EPRP); (v) Stakeholder Engagement Plan (SEP); (vi) Traffic management Plan (TMP); (vii) Security Management Plan (SMP), and (viii) an external communication and a grievance mechanism.

The Project design aims to achieve international standards on general safety including life and fire safety, environmental protection and, and to adhere to Leadership in Energy and Environmental Design (LEED) principles, and program EDGE of IFC among other standards. Although the project is 45% completed, as part of the appraisal, IFC EDGE specialist visited the project and provided expert advice for the project to realize EDGE certification.  Other design changes were provided by the Operator.

Identification of Risks and Impacts: As required by Environmental Protection Agency (EPA) in Ghana, the Sponsor commissioned a registered environmental consultant to undertake an Environmental Impact Assessment (EIA) for the project. The main findings from the EIA include; increase in traffic flow along the Oxford Street, solid waste management, dust and noise from machinery during the construction phase.  At appraisal, all proposed mitigation measures were being implemented, except enforcement of Occupational Health and Safety procedures which was observed to be weak.

Management Programs and Organization: Environmental and social impacts of the apartments, during its operational phase will be managed and aligned with the policies of the Operator, which have a well-established and operational management system for hotel facilities.  Each of the potential operators currently considered by the Company has management programs relate to matters of life and fire safety, occupational health and safety, human resources management and food safety, which are reviewed and audited periodically.

Organizational capacity and Competency: The WWE is part of the Kwarleyz Group which has a defined governance structure with clearly delineated roles and responsibilities.  Environmental, Health and Safety issues are managed and enforced by a competent Head of Operations, who is in charge of ensuring implementation, enforcement and review of E&S compliance within the current structure.  The Head of Operations reports directly to the CEO.  As part of the ESMS, WWE will develop an EHS management plan for construction phase and assign a responsible supervisor to verify that environmental and OHS measures are addressed as described in the EHS Plan and to ensure compliance with contract requirements.

During operations phase, WWE will work with the Operator to ensure that the Project will have a management structure for EHS issues, with committees on occupational health and safety, emergency preparedness, security and external grievance mechanism. The Company will guarantee EHS competency of the employees by hiring qualified individuals and/or providing additional training to the employees.

Emergency Preparedness and Response: The building designs has elements of emergency plans incorporated; wide corridors, disabled persons’ ramp and fire hydrant system.  Under the Ghanaian law, the building has already been inspected for fire safety as part of certification process by Ghana National Fire Service. In addition to checking structural aspects related to life and fire safety and emergency preparedness. The Operator, as part of ESMS develop an emergency preparedness plan and response operational procedures for the Project. The plan shall include a training program for all employees and in particular for the internal emergency fire marshals, evacuation exercises and semi-annual fire drill programs as per the WBG General EHS Guidelines on emergency preparedness and response. The procedure should also include mechanisms to inform affected communities.  The Operator will work with Accra Metropolitan Area emergency response department to ensure that the response is effective.

Monitoring and Review: WWE does not have a monitoring and reviewing system. During the apartments operations phase, the Operator will develop a Standard Operating Procedure (SOP) for monitoring of EHS performance by defining Key Performance Indicators (KPIs) (such as, energy and water use, fire safety and solid waste quantity) to be monitored and the frequency with which these will be monitored. Ideally, this system will link to and build upon the Operator’s existing internal reporting and quality control systems in line with applicable regulatory and requirements and targets identified. 

Human Resources Policies, Procedures and Terms of Employment: At appraisal, WWE had a total of 17 full-time employees and 17 temporary employees. The group has a human resources policy, implemented, enforced and monitored by the Human Resources and Administration Manager.

All WWE employees are issued with contracts, which specify the terms of employment and employee working conditions (e.g., rights of the employees, training, remuneration, termination, working hours, compensation scheme, etc.) and benefits (e.g. salary advances and loans, medical and life insurance etc.).  The contracts are consistent with the provisions of Ghana’s labor laws aligned in general with the International Labor Organization (ILO). WWE does not make use of child labor and/or forced labor in its operations.  For new recruits, the company has also developed an internal onboarding manual and an Employee’s handbook and guidelines of conduct.

During operations, the Operator will be in-charge of staff recruitment and management.  WWE will ensure that the Operator as part of ESMS implementation will review and utilize the current Labor and Human Resources (LHR) Plan to include a mechanism for employees to send grievances anonymously and apply similar policies and procedures in compliance with local regulation and the requirements of IFC’s Performance Standard 2 regarding labor and working conditions.

Workers Organizations: For WWE employees, joining a workers’ union is voluntary.  At appraisal, only seven employees belong to a union, the company expressed they do not restrict workers from joining worker’s organization.

Non-Discrimination and Equal Opportunity: WWE’s HR manual, policies and handbooks have explicit reference to principles of non-discrimination based on sex, skin color, nationality, political affiliation, etc. which are highly valued by the company.

Grievance Mechanism: WWE has a documented grievance mechanism. As stipulated in the Employees handbook, employees raise their grievances to their immediate head of unit, then escalated the Human Resources managers if not resolved.  The current grievance mechanism does not have a mechanism for sending grievances anonymously. As part of the Labor and Human Resources (LHR) Plan the sponsor will develop and implement a formal system for employees to raise grievances anonymously, for example through a dedicated email address to file confidential grievances, without the risk of reprisals, and according to other requirements of IFC’s Performance Standard 2. The grievance procedure will also articulate how the grievances will be handled and resolved; and outcomes communicated to all employees. This procedure will be made available to all existing and new employees, third-party staff, as part of its Human Resource Policy and other relevant documents.

Occupational Health and Safety: At appraisal, WWE did not have an Occupational Health and Safety (OHS) program.  WWE will support New Africa Construction (Contractor) to develop, implement and monitor as (ESAP Item #2) an Occupational Health and Safety (OHS) management plan which will be effective during the construction phase. The OHS MP will be in line with Ghana’s OHS laws, WBG General Guidelines and IFC Performance standard 2.  The OHS MP will include, among environmental and social tasks, an objective of protecting workers from injury, illness, workers training, mechanism for documenting and reporting of occupational injuries, illnesses and fatalities; provision of safe and healthy work environment to contracted workers. WWE will also ensure that contractor does not hire child labor.

Resource Efficiency

The apartments are being designed using international standards. IFC EDGE specialist has reviewed the design as part of the appraisal to achieve green building certification. The specialist provided benchmarks and information on equipment to make the buildings more resource efficient in line with the WBG Tourism and Hospitality EH&S Guidelines and LEED (Leadership in Energy and Environmental Design) principles in the selection of equipment to be used in the apartments.

Energy: The apartments will obtain electricity supply from the national grid provided by Electricity Company of Ghanaand a 200 KWH stand-by diesel powered generator to be used only during power outages.  The electricity consumptionwill be mainly for lighting, heating, ventilation, and air conditioning (HVAC) systems and will be closely monitored and reported annually.

Greenhouse Gas Emissions: Greenhouse gas (GHG) emissions resulting from operation of the apartments, spa and shops are estimated based upon actual resource consumption, mainly due to energy consumption.  For the 108 apartments the company’s direct and indirect emissions of greenhouse gases (GHGs) from its general electricity consumption are expected to be less than 600 tonnes of CO2 equivalent/year. Actual records will be used to review amounts of tonnes CO2 equivalent per year that will be emitted from the new hospital once it is operational.

Water:  The apartments will be connected to the main water system managed by Ghana Water Company Ltd.  A borehole is also proposed to ensure adequate supply of water.  The borehole will be metered to record the amount of water used every month. Water will be treated via a multistage treatment facility, which includes filtration, reverse osmosis and ultraviolet purification. Water quality tests will be conducted periodically and results reviewed to meet the WHO drinking water quality standards.

Pollution Prevention:

Liquid effluent Management: All waste water effluents from the apartments will be treated on site since there is no centralized sewer system.  WWE will build a waste water treatment plant (WWTP) and provide documented evidence that the design meet WBG/IFC EHS general Guidelines or Ghana regulations whichever is stringent as spelled in the (ESAP Item #3), in order to comply with limits for discharge to surface water.

Solid Waste Management.  Significant amount of solid waste is expected from the apartments during the construction and operation phases.  WWE, aligned with the ESMS, will develop a solid waste management plan that ensure solid waste are handled in accordance with acceptable practices.  WWE will also ensure disposal of solid waste is handled by a reputable contractor who is licensed by relevant regulatory agencies as stipulated in Ghana’s Environmental Protection Agency Act 490 of 1994.

Pesticides:WWE, will ensure pesticides and or fumigants used in all operations comply with the more stringent of national law and IFC’s requirements.  The client will ensure no WHO Class 1a and 1b pesticides are used and only allow use of class II pesticides under specific conditions (i.e. that Class II pesticides are not in use if Ghana lacks restrictions on their distribution and use, or if they are likely to be accessible to personnel without proper training, equipment, and facilities to handle, store, apply, and dispose of these products properly).

Life and Fire Safety: As mentioned under PS1, WWE will ensure that the Operator will comply with local regulations regarding life and fire safety design and installations in the apartments. WWE is currently working with Ghana National Fire Service to review the design as part of certification process.  In addition, WWE will contract (ESAP Item #4) an expert in international L&FS standards to review the engineering design for the project, and upon physical completion of the building, to verify that the systems were installed as designed in accordance to the L&FS section of the WBG General EHS Guidelines. Under (ESAP Item#5) the L&FS professional will provide the certification, affirming that the L&FS systems were installed as designed and are properly tested.  If the certification is not issued, then a corrective Action Plan with proposed completion dates and expected metrics shall be submitted to IFC. The design should meet both local Ghana requirements and those of an international L&FS code (such as NFPA 101 of the National Fire Protection Association).  The standard specifications will include operational and maintenance guidance, such as the preparing of schedules for mandatory regular maintenance and testing of life and fire safety systems and regular fire drills.

Traffic: The EIA indicated a projected increase in traffic along Oxford Street created by the Project.  The sponsor as part of the ESMS will develop a traffic management plan to ensure smooth floor of traffic in and out of the facility.

Security Personnel: WWE employs unarmed security guards, for access control and emergency response purposes in all its current facilities.  As at appraisal, it was not clear whether a similar model will be used for the management of 1 Oxford Street apartments.  As part of the ESMS the company will develop a Security Management Plan (SMP), including a training module for management and security personnel. This SMP shall be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of Performance Standard 4 (paragraphs 12, 13 & 14).

HACCP Program. As (ESAP Item #6), WWE will design and ensure implementation of a HACCP-based food safety program for the restaurant and formalize Standard Operational Procedures, on (i) sanitation; (ii) good manufacturing practice; (iii) pest control by ensuring ensure no WHO Class 1a and 1b pesticides are used; (iv) chemical control; (v) staff hygiene and training; (vi) customer complaints mechanism; and (vii) traceability.

Swimming pool water quality management: WWE will regularly test swimming pool water quality, and maintain hot water at sufficiently high temperature to prevent growth of Legionella bacteria, and will test to confirm the effectiveness of these treatments. Operation of the swimming pool will ensure proper management of chemicals.

External Communications and Grievance Mechanisms: At appraisal, the sponsor’s procedure for external communication with stakeholders was via a website (www.petroniacity.com).  The mechanism does not include; procedures to receive and register any complaint(s)/query lodged to the company by affected stakeholders/individuals. As part of the ESMS, the company will, develop an external communication and a community Grievance Mechanism for the operation phase which will include identification of stakeholders; develop communication channels and a grievance mechanism and publicize its availability.

Contact Person: Nana Kwame Bediako

Company Name: KWARLEYZ Group

Address:  15 Osu Avenue Ridge, Accra, Ghana

Email: nkbediako@petroniacity.com

Phone: +233 244 684 848