The key issue associated with this project relates to SIR’s corporate capacity and management systems in managing environmental and social risks in the following areas: life and fire safety; efficiency water and energy use in hotel operations; waste management and disposal; and labor and working conditions.  The Project has a limited number of potentially adverse E&S impacts, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines, or design criteria. On this basis, this project is therefore classified as Category B as per IFC’s Policy on Environmental and Social Sustainability.

In accordance with local regulatory requirements applicable at the time of construction, the company commissioned external consultants to undertake an initial environmental examination (IEE) for the project during 2014 and 2015. SIR operates in accordance with mitigation measures and environmental management and monitoring plans articulated in the IEE report.

During IFC’s site visit, E&S and safety practices (e.g. those related to human resources (HR), fire safety, housekeeping, and waste management) were found to be well implemented. SIR has basic policies and procedures in relation to the above, and will refine these to include more details (i.e. a policy statement; a list of standard E&S KPIs, and enhanced standard operating procedures on life and fire safety management – refer to PS4 below, emergency preparedness and response, and waste management) in such a way that is adequate and appropriate to the nature and scale of its operations.

The Chief Engineer, who possesses relevant prior experience in the hospitality industry, is responsible for day-to-day oversight and management of environmental health and safety performance (i.e. in relation to waste management; energy and water use efficiency; incoming and outgoing water quality; life and fire safety; equipment operation and maintenance; administering technical training to staff; and site security), and reports to the General Manager of SIR. Appointed personnel under the chief engineer have clearly defined responsibilities to manage EHS operational aspects.

The hotel currently employs a total of 137 persons, of which 40% are women.  All staff are full time direct hires, and 95% are hired from within Shan State. Turnover has been at 1-2% since start of operations. SIR has a detailed employee manual, consistent with national labor requirements, which describe aspects such as its HR policy and procedures, hotel organizational setup, remuneration and overtime, benefits, training and development, leave arrangements, performance evaluation, disciplinary procedures, reporting, and safety and emergency scenarios. Terms of employment as well as rights and responsibilities of employees are formalized into employment contracts and communicated to all employees through the employee manual. Remuneration is competitively determined by referencing market rates and complies with minimum wage laws.

Hiring and employment practices recognize the principles of non-discrimination and equal opportunity. There is no evidence of child or forced labor in the workforce. The decision to join or initiate a worker union is entirely voluntary and the hotel does not oppose this in any way. Discussions with SIR staff and a tour of the hotel confirmed working conditions to be reasonable, safe and clean. Employees can raise grievances through their supervisors or by speaking with the HR team or the General Manager of SIR or during regular staff meetings. There have been no instances of labor disputes or litigation since SIR started operating, or any notable work injuries or lost time accidents. To ensure adherence to day to day work safety requirements, the hotel conducts regular staff training and provides personal protective equipment.

Out of its 137 staff, about 90 persons reside on site at dormitories (separate for male and female) provided by SIR. During the site visit, employee accommodation was found to be well-appointed with basic services and amenities (such as minimum living space per employee, natural and artificial lighting and ventilation, supply of water, adequate sanitary and washing facilities, storage facilities and, adequate sewage and garbage disposal system). The accommodation services are provided in a manner consistent with the principles of non-discrimination and equal opportunity, and do not restrict workers’ freedom of movement or of association.

Greenhouse gases and resource efficiency:

The annual total greenhouse emission from the hotel, mainly attributable to the operation of refrigeration equipment and electricity, is estimated at 1,800 tCO2e. In reference to benchmark values listed in the World Bank Group (WBG) Environmental health and safety (EHS) Guidelines for Tourism and hospitality development, both the electricity and total energy consumption index values (kWh/cubic meter serviced space) calculated based on data provided by the company, are within the “excellent” benchmark range (<190 and <270) for luxury serviced hotels in a tropical environment. Energy conservation measures incorporated into the hotel’s design and operation include selection of energy efficient equipment in the kitchens and laundry, close monitoring of energy meter readings, turning off air conditioners and lights when not in use, etc.

The hotel sources its water supply from two deep wells within its premises, which is treated to potable level through a 3-stage (sand filter; carbon filter; and reverse osmosis) system to provide water for the guest rooms, kitchens, laundry, and spa. Treated water is regularly tested to ensure its conformance with WHO drinking water quality standards. The water consumption index value (cubic meters per guest per night) for SIR in the year 2016 falls into the excessive category for luxury serviced hotels in a tropical climate (i.e. >1.4) and is slightly above the benchmark value of 1.4. The company will engage a qualified specialist to undertake a water efficiency audit in order to identify major water-consumption areas/sections within SIR, and based on audit results, develop and implement technically and financially feasible actions to reduce the hotel’s water consumption footprint. Refer to the ESAP.

 Pollution Prevention:

 The hotel is equipped with an operating septic tank system whereby sanitary wastewater, greywater, and waste water from the kitchens (after going through grease traps) enter a 3-stage bio-tank system consisting of an equalization, aeration, and sedimentation tank, with application of micro-organisms to further treatment of sewage. Based on design specifications, treated values of the septic system conform to the WBG General EHS Guideline values and discharge levels are monitored regularly. All treated waste water is completely reused for gardening and land application within the premises with no discharge to the external environment, and accumulated sludge is collected regularly by an external licensed waste collector. As such, impacts of treated sewage disposal on the Inle Lake water environment and its ecological carrying capacity are expected to be very limited. There are no boilers installed on-site exceeding a rated heat input capacity of 3 MWth, and air emissions from the use of diesel-powered backup generators are expected to be limited. The company practices reduction, segregation, recycling, and reuse of solid wastes (e.g. plastic bottles) most of which are sold to third party recyclers. Fuel canisters are stored in access-controlled areas and there are no notable concerns with hazardous materials or wastes.

SIR employs unarmed security guards to secure its premises, and there have been no security or fire incidents since the start of operations. The hotel’s food and beverage operations follow principles and requirements of Hazard Analysis and Critical Control Point (HACCP) and kitchen staff has been trained on HACCP requirements. This includes monitoring the source of local and non-local food ingredient supplies. Swimming pool water quality is tested daily using pH and chlorine test kits. LPG canisters are supplied to the hotel by a licensed vendor, as cooking fuel for the restaurant and staff canteen kitchens, with canisters stored in access-controlled areas.

 The hotel’s life and fire safety (L&FS) design and provisions include: smoke/heat detectors, fire alarms, emergency lighting, exit lights, hydrants, pumps, hose reel, fire extinguishers and a central control panel. Also installed is a water tank of 20,000 cubic meter capacity dedicated to fire fighting. As part of the hotel’s emergency preparedness arrangements, it has obtained approval from the local fire department, and has installed required pumping equipment to extract additional water from the lake should more water than what is provided by the on-site tank be required in the case of a fire. Regular training and fire and evacuation drills are conducted in concert with the local fire department to maintain the system.

Building on the above, the company will refine its L&FS manual and operating procedures, to include: (i) detailed management measures to minimize L&FS risks; (ii) documentation of L&FS system and equipment testing and maintenance records; (iii) training content and schedules; and (iv) conformance to IFC PS requirements for any potential future expansion involving new buildings. This is to ensure continuous monitoring of a functional L&FS system during the lifespan of the hotel. Refer to the ESAP.                                                   

The company commissioned external consultants to undertake an initial environmental examination (IEE) for the project during 2014 and 2015. As part of the IEE, in March 2015, public consultations were conducted with about 70 local residents, and with representatives of Government, NGO’s, other hotel companies operating in the Inle Lake area, and with media. During community sessions, the SIR project and its developmental plans including the process and content of the IEE were presented, and feedback from participants was sought and documented in the IEE. SIR supports a number of community outreach activities at Maing Thauk and other nearby village, and has also hired and trained a number of residents from these villages as hotel staff. Day to day interactions with these villages materialize during community program implementation, and through feedback from staff who live in those villages. The hotel’s F&B operations also source some of its food ingredients from local areas which support local development. Taking into account the limited adverse impact from the hotel’s operations on local residents, stakeholder engagement activities to date have been adequate and effective.

Contact Person: Mr. Philippe Arnaud

Company Name: Sanctum Inle Resort Hotel

Address: Maing Thauk Village, Inle Lake, Nyaung Shwe Township, Shan State, Myanmar

Email: gm@sanctum-inle-resort.com

Phone: +959 252 818800-5