Clinics have a small footprint and occupy only rented spaces in established commercial areas in urban centers, PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), and PS8 (Cultural Heritage) are therefore not applicable to the project. PS7 (Indigenous Peoples) does not apply because the project will not cause impacts to Indigenous Peoples.                                                

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social (E&S) impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards and guidelines.

Key E&S risks and issues associated with this project include the adequate management of human resources elements, biomedical waste, occupational health and safety, and the safe design of clinics and evacuation procedures in case of an emergency.                                                  

Identification of Risks and Impacts: As clinics are smaller than 400 m2 (largest facility is 250 m2), they are only required to present a “notice of operation” to the Mexican Federal Commission for the Protection against Sanitary Risk (COFEPRIS), and do not need to obtain sanitary licenses and be inspected by Protección Civil (Civil Protection) prior to start operations.  Ex-post inspections of facilities by COFEPRIS and Protección Civil have not identified any major non-compliance.  All clinics are located in rented spaces and no new-construction in involved in the expansion plans. If internal walls have to be demolished as part of the remodeling, a civil engineer inspects the site before commencement of works to ensure the structural integrity of the building is maintained.

Management Programs and Organizational Capacity and Competency: Documented procedures are available for (i) all services provided in the clinics, (ii) inventory management, (iii) calibration of equipment, and (iv) management of medical waste. In addition to a half-day induction training in the company’s headquarters, all new employees are trained through job-shadowing for one month, and existing employees regularly receive refreshment and progressive training with external providers.

Monitoring: Clínicas del Azucar monitors customer satisfaction and maintains records of complaints. While the company does not monitor energy consumption, it is aware of the average monthly cost paid for electricity and has taken steps to reduce it (i.e. installation of LED lights, replacement of air conditioning systems).                                                

At the time of IFC appraisal, Clínicas de Azúcar had 170 employees. Eighty-one percent of the company’s workforce are women (50% at managerial level). Monthly employee turnover in 2017 was only 1.3%.

Human Resources Policies and Procedures: All employees receive written contracts, which include information on hours of work, wages, benefits, and paid-holidays. Employees also receive a written code of conduct and clear information on progressive disciplinary procedures.

Working Conditions and Terms of Employment:  All wages are above the established minimum wage and hours of work comply with Mexican Labor Law (48 hours per week). All workers are enrolled in the social security system (i.e. IMSS, AFORE, FONAVIT). After a three-month probationary period, workers are hired on a permanent basis.

Non-discrimination and Equal Opportunity: Clínicas de Azúcar does not have a documented non-discrimination and equal opportunity policy, but no evidence of discrimination was noted in the company’s hiring practices.

Retrenchment: The proposed investment will not trigger any collective dismissal. On the contrary, the company’s five-year expansion plan will require the hiring of up to 3,000 new employees.

Grievance Mechanism: Clínicas del Azúcar has established an email address to receive anonymous grievances from employees, but no formal procedure has been developed for the investigation and resolution of complaints. Clínicas del Azúcar will document and communicate a complaint management and resolution procedure in line with the requirements of this Performance Standard (ESAP action item #1).

Protecting the Work Force: Clínicas del Azúcar does not employ workers under the age of 18.

Occupational Health and Safety: Potential OHS risks are limited to exposure to bloodborne pathogens through needle stick injuries, and exposure to pathogens through contaminated items and surfaces.  The company has basic health and safety protocols including the use of personal protective equipment (i.e. gloves), dedicated hand washing sinks, and safe needle handling practices.   No lost-time accidents have been recorded in the last three years, except for one “accident in itinere” (i.e. on the way to or from work). 

Workers Engaged by Third Parties: The expansion plan will require the hiring of construction contractors for the remodeling of medical facilities. Clínicas del Azúcar relies only on legally established companies and contractually requires that all workers are affiliated to the social security system. In addition, Clínicas del Azúcar collects the social security numbers of workers on site to control that their social security payments are up to date, and verifies that workers wear construction personal protective equipment (PPE).                                              

Pollution Prevention: Clínicas del Azúcar produces about 2 Kg of biomedical waste per clinic every month; it retains the services of authorized service providers for the collection, treatment and final disposal of biomedical waste. Biomedical waste is stored on site in properly labelled containers and is collected by the service provider once a month. Hazardous waste manifests reviewed by IFC included information of the generator, transporter and final disposal facility.

There are no additional impacts regarding pollution as there is no air emissions and liquid effluents are limited to sanitary services disposed via sewage systems.

Resource Efficiency – Energy and Water Use: Use of water in the clinics is limited. Energy is used mainly for illumination and air-conditioning systems. Clínicas del Azúcar has installed LED-lighting in all clinics and is gradually installing high efficiency air conditioners.                                                   

Infrastructure and Equipment Design and Safety: Clínicas del Azúcar started operations in 2011 and currently has 13 clinics in the Northeast of Mexico.  Most clinics are in strip malls with direct access to the exterior, and while some clinics have two floors, all services are provided in the first level only.  In addition, patients are not immobilized and therefore capable of evacuating on their own in the event of an emergency. Inspections carried out by Protección Civil have not identified any major non-compliance.

The company has an ambitious expansion plan for the next five years.  To ensure that clinics continue to provide a safe environment for workers and patients, and occupants can safely evacuate in case of an emergency, Clínicas del Azúcar will develop a Life and Fire Safety procedure (including checklists) for the selection, remodeling, and maintenance of its clinics, and will include emergency planning and response. The procedure will consider the local legal requirements of Protección Civil and applicable Mexican Official Norms, and will include aspects such as occupancy levels, means of egress, and systems for fire prevention, detection, and suppression (ESAP item nr. 2).

Security Personnel: Clínicas del Azúcar retains no direct or contracted workers to provide security to safeguard its personnel and property.                                                   

 Point of Contact (Name):  Miguel Garza

Title: Chief Operating Officer

Telephone Number: +52 81 2314 5000

Email:  mgarza@clinicasdelazucar.com               

Mailing Address: Los Rosales 365, Santa Engracia, 66267 San Pedro Garza Garcia, Nuevo Leon, Mexico

Website:  http://www.clinicasdelazucar.com/