Food Safety
CEG outsource all the food service in canteens to independent third parties and restaurants that are regulated by a governmental system for food safety categorization. For example, the JUT has three student canteens, all classified as Grade-A, BTC also received "Grade A", and GBU received "Grade B". The rating is based on the respective “Province Food and Beverages Safety Supervision Report” index and even though, the category B is normally an acceptable level for operation of the canteens in the campus, as part of the ESAP, CEG will develop a food safety improvement plan, aligned with the student risk management system, to have all canteens and cafeterias in all existing campuses, and from future acquisitions, to be classified as category “A”. The plan will make emphasis on outsourcing management of providers under the following factors: (i) permittable environment; (ii) system and personnel management; (iii) hygienic condition, facilities and equipment; (iv) food and raw materials procurement, storage and operation; (v) processing operation; (vi) food transport; (vii) utensils cleaning and disinfection process; (viii) food logistics and transportation; (ix) food samples, waste oil and meal waste disposal in accordance with local legislation.
Campus Safety and Security
There have been no major security and safety incidents (i.e. fires; food poisoning; epidemic outbreaks; harassment incidents; vandalism; etc.) at any of the campuses in the last 10 years. All campuses employ in-house unarmed security guards, who receive training provided by a qualified external trainer on topics such as professional behavior and good conduct, and neutralizing security scenarios including the exercise of restraint where the use of force becomes inevitable. There are detailed procedures in place on the maintenance and use of security apparatus and equipment.
The company has been planning actions to reinforce life and fire safety at its campuses, and is in regular contact with local fire departments which conduct regular and irregular on-site inspections. An on-site fire brigade has been installed at the three schools (JUT, GBU and BTC), as a private fire department, staffed by 12 firemen who are employed directly by the schools, and equipped with fire engines, communication means (radios, cell phones) and other equipment (uniforms, shovels, special PPE, flash lights, first-aid kits). The use of a private fire team is a corporate rule to improve emergency response and ensure that any fire event is controlled in its early stages This team is responsible for L&FS inspections and fire-fighting at these facilities as well as at nearby residences, grocery stores, restaurants, and areas outside the campus perimeter that could affect the students or university personnel. The onsite fire brigade station kept records of daily inspections against a list of six indicators. Fire-fighting, inspection, prevention, and emergency preparedness and response procedures kept at the station can be improved. This arrangement will be maintained by CEG to be applied in future acquired schools.
CEG made a comprehensive disclosure on E&S related matters, and in particular Life and Fire Safety management in the IPO prospectus, indicating that there are some buildings, including educational, dormitories and ancillary building that don’t have a fire permit. The Company is already taking steps to correct these Fire Safety matters and has replied for permit. For the three schools, the group has disclosed that approximately 20% of the total building’s areas had not passed the local fire brigade’s control assessment for various reasons, and mainly because of the age of the buildings that were not designed at today’s L&FS regulations and standards. For example, JUT has two buildings, a maintenance building and the clinic, that have not passed the “fire control assessment” from the authorities. The school is correcting the identified L&FS issues and maintained close contact with the local fire department that has issued a letter confirming that the university is cooperating and the school hasn’t been penalized. Also, the company will implement a relocation plan utilizing the future campus at GBU that will be used to relocate some of the existing activities/users in buildings with L&FS issues, relieving some of the initial load, as the University achieves compliance with relevant local regulations and permits.
IFC’s visit to several dormitories, and other type of buildings, found the following in relation to life and fires safety (L&FS): (i) the buildings are designed with open architecture (normally well ventilated corridors and exit stairs), and each building had several additional exit doors on the ground floor and, with the exception of some old dormitory buildings, they have two flights of stairs as a minimum, the width of which had been designed to allow for egress based on occupancy load; (ii) any heating or cooking devices were strictly prohibited in dorm rooms to eliminate an important potential ignition source; (iii) in some dormitories the main entrance and exit staircase doors are provided with electronic control access systems (card readers, mag-locks, etc.), however, in other dormitories exit stair doors were pad-locked for security reasons to prevent non-building-residents from entering the building through those doors – however the company recognized that doing so posed a safety issue in terms of blocking emergency exits; (iv) dormitory corridors were generally dark with limited lighting; (v) fire-fighting equipment, signage, and emergency lighting were in place and all equipment appeared well maintained and identified; (vi) there were records of regular inspections/verification of electrical system functionality by the Logistics Department with an inspection checklist of ten aspects as part of the review; (vii) electrical wirings, systems and connections appeared to be in good conditions; (viii) housekeeping is good with no obstructions in corridors or other risky areas; (ix) fire drills are performed twice a year; (x) abundant water for fire-fighting is supplied to each building by the municipal water supply company; (xi) no fire notification alarm system is available in the dormitories and other tall buildings and the campuses rely on a not very effective personal notification made by the fire brigade (passing the voice) and utilizing whistles; (xi) sprinklers were installed in specific buildings - as per the updated national fire code, buildings constructed post-2011 would typically have sprinklers installed, especially where the combustible loading and ignition risk was considered to be substantive; (xii) some of the 10-12 story old dormitories were designed with only one exit stair (open stair, not well ventilated to dissipate smoke in case of fire) serving four rooms per floor. These buildings have not a good egress layout, not enough exit capacity and don’t have fire alarm for notification of occupants.
Fire drills by the local brigade are performed twice a year including simulated evacuations and practice with school private fire brigade and city fire department.
To address the above findings, the company will commission a qualified L&FS professional entity to undertake the following (refer to the ESAP for details) work, in concert with its planned L&FS reinforcement actions. In carrying out these tasks, the professional entity has engaged the company’s campus engineers, safety and logistics personnel, to use this as an opportunity to help them gain exposure to L&FS good international industry practice.
(i) The group will develop a time-bounded corrective action plan (CAP), to address the gaps that have been already identified by the local fire brigades, the company and those suggested by IFC. The company is expected to duly implement the CAP on a timely manner. The plan should cover the issues identified by IFC regarding locked (pad-locked) exit stairs and emergency doors, and automatic fire alarm notification in all dormitories. As part of this, the company will also reapply for permit and provide a copy of all relevant and applicable L&FS licenses to IFC.
(ii) Review the L&FS Master Plan prepared by the company for each new facility cluster (whether green field, or brownfield campus buildings to be acquired by the company and to undergo major renovations) and to verify that its design has been completed by a recognized firm, and meets the requirements of the national L&FS code/regulations and one internationally recognized L&FS code (e.g. U.S. NFPA) as defined in the World Bank Group (WBG) General Environmental Health and Safety (EHS) Guidelines 2007. Where gaps are identified, develop a CAP for the company to update the Master Plan.
(iii) Upon completion of construction of a new facility cluster (i.e. a collection of campus facilities and buildings) or substantive renovation of an existing facility cluster, undertake a completion review to verify that the buildings have been constructed/renovated in accordance with the facility's L&FS Master Plan as finalized under (ii) above, and where gaps are identified, develop a CAP to be implemented by the company.
