All land acquired for developments is on a willing buyer seller basis, thus PS5: Land Acquisition and Involuntary Resettlement is not applicable to the project.  In addition, all developments occur in urban areas typically on land that has been previously developed, thus PS6 is not applicable to the project.  Given the urban nature of the activities in that all developments occur within settled and populated areas, PS7: Indigenous Peoples is not applicable to the project and similarly neither is PS7: Cultural Heritage.

  The project is defined as a Category B according to IFC’s Policy of Environmental and Social (E&S) Sustainability because a limited number of specific E&S impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.  Key E&S issues relate to; i) ensuring compliance with national legislation for the development of facilities and during operations; ii) supply chain management;  iii) the systems to ensure key environmental aspects such water supply, waste storage and handling, and materials handling are adequately managed and monitored; iv) human resource management; v) energy efficiency; vi) general hygiene and food safety; vii) application of adequate design standards to the developments including that related to life and fire safety; viii) emergency preparedness and response; and viii) security control at key areas such as in the theme parks. 

   Environmental and Social Assessment and Management System

The project approval process for new developments other than those in existing shopping malls such as the stand alone retail facilities and hotels includes submission of initial schematic designs to the relevant authorities which defines the building standards and codes to be applied to the respective project.  Based on these, the authorities issue a list of relevant approvals required such as that related to planning and the environmental licenses which the company is then responsible for acquiring.  Once obtained, these are then submitted to the authorities for approval and then a formal license is issued allowing construction to commence.  The company uses DP Architects, an architectural firm in Singapore to undertake the initial schematic design and thereafter the project is submitted for tender on a detailed design and construction basis.  As part of the environmental licensing process, the company engages independent consultancy firms to undertake the Environmental and Social Impact Assessment / AMDAL as based on Government regulations approved in 2016.  Following construction, the relevant authority vets the development and issues a “Certificate of Functionality” whereupon a license to operate is issued.

For the retail operations there is a committee responsible for developing policies and procedures that apply to these activities and these focus on financial and business processes, fraud, supplier management, product handling, hygiene control and food safety, human resource management and safety management. These systems are aligned with those of the Carrefour branded stores such that there is similarity across all retail operations.   

The policy and procedures applied to the luxury hotels have been developed by Trans Entertainment and are based on similar high end branded hotels, while the Accor managed facilities apply their own policies and procedures.  The hotels have developed their own hygiene policy and control program (The Perfect Quality Program) which is aligned with HACCP and will be seeking certification of the systems in due course. Similarly, the Accor branded hotel also has clearly defined food safety system based on Accor’s standards as applied to all the hotel operations.

Management of the suppliers at the retail facilities is a via dedicated vendor management system.  There are over 6,500 suppliers on the database, though 70% of all products sold are from approximately 20 primary vendors who are large companies such an Unilever, Nestle and Coca-Cola amongst others.  Other vendors are typically national and local small and medium sized enterprises and Trans Retail has a focus on trying to support such enterprises to the extent possible.  There are contracts with all suppliers who are required to comply with national legislation and regulations and Trans Retail provide training to key suppliers such as those involved in food supply on issues such as maintaining the cold chain.

Organizational Capacity and Competency

Each store has a dedicated manager who reports to a Regional Director who then reports to the Territory Director responsible for all the stores.   Stores have dedicated head of safety, security, marketing, maintenance and store control respectively, who report to a regional focal point representative for each of the areas referenced who may then raise issues at the weekly commercial meetings if necessary. Each head is supported by a dedicated team; further information on these functions is provided in the sections that follow.   Every store has a safety committee and Safety Team (typically 6 employees) who are responsible for emergency related aspects along with hygienic control. There is also a dedicated Emergency Response Team.  The photographs and the names of the Safety Team and Emergency Response Team are prominently displayed in the back office and general access area of each store. There is also Risk Prevention Manager, Safety Manager and Safety Inspector based at headquarters where the Internal Audit Team is also based; the latter undertake regular audits at stores of various functions.  There is a dedicated engineering team for each theme park and every ride has a trained operator.   

All hotels have a General Manager, Assistant Manager and dedicated leads for key areas such as food and beverage, front office, engineering and the kitchens, while there is there is a Hygiene Manager responsible for implementing associated food safety procedures.  There is also a combined safety and emergency response team at the hotel.   There are dedicated life guards at each pool, and these individuals need to be certified.

The retail operations are headed by Human Resource Manager and there are some 40-supporting staff at headquarters and every store has a human resources administrator.  In addition, each hotel has Human Resources Manager with support from administrative staff.

Emergency Preparedness and Response

The company has well established emergency preparedness and response plans for the stores and hotels respectively and these cover all potential situations such as bomb threats, hostage situations, fire, earthquakes, food poisoning, power outages and incidents associated with lifts.   Signage detailing evacuation routes is also readily displayed throughout the facilities. As noted, there are dedicated teams for safety management and emergency response, and all facilities have staffed control centers which include surveillance systems located throughout the stores and hotels; the centers at the hotels are staffed 24 hours a day. In addition, there is an Alert Prevention Centre at headquarters staffed 24 hours a day which acts as central control post in the event of there being an incident at any facility.   Where the retail stores are in shopping malls, these operations rely on the broader facility for the firefighting infrastructure, though each store is responsible for the mobile fire-fighting equipment e.g., fire extinguishers.  All the stand alone retail facilities have dedicated fire-fighting equipment which include fire pumps with stand by generators and sprinklers throughout.  In addition, there are smoke and temperature sensors in the retail facilities and at the hotels. The hotels also have mobile firefighting equipment.  All fire extinguishers are regularly checked by the safety teams and are all flushed, refilled and checked by the fire department once a year. The safety teams undertake daily checks of the fire pumps, checks to ensure the fire exits and access routes are clear and that the emergency lighting is working.  At both the retail facilities and hotels there are fire and evacuation drills twice a year and once a year the fire departments participate in a drill.  The fire department also undertake annual inspection of facilities and check infrastructure such as the sprinklers. In addition, at the hotels every month there is a drill on differing topics e.g., pool emergency, electrical fire etc.   IFC’s observations during the site visit indicate that all fire extinguishers were serviced in accordance with the required time frame, there were teams checking on fire equipment and all fire exits were clearly demarcated, the exits could be opened as necessary and the access routes were clear.  The company reported that there was a fire at one of the stores in 2011, however there were no injuries as a result.

Monitoring and Review

There are clear reporting lines throughout the operations with the safety teams reporting to store managers and regional focal points as required.  As per the respective food safety systems there is ongoing monitoring of relevant parameters i.e., temperature, of food display areas and fridges, and this information is recorded.  Records are maintained for any incidents that may occur and these are reported to senior management.   At the hotels the pool water quality is monitored daily and the waste water quality on a quarterly basis.

 The retail facilities employee some 13,000 workers of which some 30% are women, while some 650 workers are employed by the hotels of which 35% are women.  At the stores there are some 7,000 contractors and their primary focus is on cleaning, security and sales promotion of products; approximately 20% are women.   Trans Retail is not involved in the transport of supplies and merchandise to customers and where required this function is fully outsourced to key service providers.

Working Conditions and Terms of Employment

All permanent and contract employees have a written contract which defines their position, salary, working hours, allowances, benefits and leave.  General human resource policies and procedures are defined in the “Peraturan Perusahaan” (Employee Handbook) for the retail facilities and hotels respectively.  Leave requirements are in accordance with national requirements (annual, sick and maternity), there is medical aid as per the Government regulations and the company provides a supplementary private component to this.  Pension payments are defined by the national regulations.   Prior to workers, including contractors, commencing work at the company, they undergo an induction course which includes an overview of the company’s approach to human resources.  Workers undergo a medical checkup prior to being employed and there is ongoing medical screening for staff involved in the handling of fresh produce.  There is also a training program for all workers (permanent and contract) which focuses on soft skills (e.g., customer interaction) and technical aspects of tasks as required, along with a developmental program (related to promotion).   Going forward any Accor branded hotels will be in a license arrangement between Trans Entertainment and Accor. Therefore, the human resources policies and procedures to be applied to these hotels will be similar as those of the Tran Luxury branded hotels as they will be under similar management. As to the existing Ibis hotel managed by Accor, the company will ensure the associated human resource policies and procedures are aligned with their own. These actions are defined in the ESAP.

Workers’ Organization

In accordance with national legislation workers may join unions.  However, currently only 10% of the workforce are union members.  There are signed collective bargaining agreements with the unions which include formalized channels through which workers can raise grievances such that these can be addressed without undue influence from the company.

Non-discrimination and Equal Opportunity

The retail facilities and hotels have a formal policy on nondiscrimination and equal opportunity which is communicated to staff and contractors during induction.

The retail facilities have a target of ensuring 1% of all staff employed are disabled, though the actual number employed at one time does vary.  Such staff and then provided with dedicated support to ensure they can fulfil their associated function. 

Retrenchment

Staff turnover at the retail operations and hotels is low compared to the industry average and given the expansion underway, retrenchments are not envisaged.

Grievance Mechanism

Both the retail operations and hotels have a formal grievance mechanism defining the approach to raising grievances for resolution thereof.  While Trans Retail stated that anonymous grievances may be raised via an internal hotline and email, the approach to anonymous reporting at both the retail operations and hotels will be formalized and communicated to workers. In addition, Trans Retail and Trans Entertainment will amend their future contracts with contract employees going forward such that where a contract employee does not have a formal grievance mechanism, it will be noted that the associated contract worker will have access to either Trans Retail or Trans Entertainment’s grievance mechanism as applicable. In addition, the course material for the induction program will be amended to reflect this.

Protecting the Work Force

In accordance with national law, all employees are 18 years and above and at the stores the company only employees high school graduates.  The company confirms the age of potential workers against identity documentation.

Occupational Health and Safety(OHS)

OHS at stores is managed via the Risk Prevention Department and, as outlined, there is a Safety Committee for each store / hotel and they also have a dedicated Safety Team. The stores and hotels similarly have a set of OHS procedures with the focus of these being primarily on the types of clothing and equipment to be used during specific activities, notably that associated with food preparation areas. While incidents are recorded, the company noted that there have been no significant incidents at any of the retail operations, while at the hotels, one minor incident has been recorded to date.  There are first aid kits available in both stores and the hotels and there is a full-time nurse at the hotels. Members of the safety teams and emergency responses teams are trained in the provision of first aid.

Occupational health and safety during construction is managed via the individual contracts and associated contracts require compliance with national legislation in this regard.  To ensure consistency in practice the company will develop and implement a standard OHS plan which clearly defines the management systems and associated polices, practices and procedures to ensure alignment of all construction projects (retail and hotels) with national requirements and good international industry practices for such.  This plan and the requirements for compliance will form part of the standard contractual requirements for projects. The plan will also define the approach to oversight by the company to ensure ongoing compliance by contractors with the plan. This action is defined in the project ESAP.  

Workers Engaged by Third Parties

Contracts with all contract employees stipulate the requirement to comply with national law and every month the human resource administrator at each store randomly check the salary slips of 3 contract staff to ensure they are paid the minimum wage. 

Supply Chain

At the retail stores the company has written contracts with all suppliers that define the need to comply with national legislation including specifically that related to minimum age of employees and minimum wages. Trans Retail does not have own brand products and therefore rely on independent suppliers. There is no identifiable high risk of child or forced labor in the primary supply chain of the retail or hotel operations.

  Energy & Resource Efficiency

The retail operations are implementing more efficient lighting e.g., LED’s in some of the older stores, while at the new standalone facilities the architects are starting to incorporate green building concepts into the new designs e.g., increasing the extent of natural lighting, ensuring provision of efficient equipment where such is energy intensive e.g., chillers.  The latter also applies to the hotels, though they do have a Building Management System to ensure equipment e.g., air conditioners, are operating optimally.  Trans Retail has agreed to work with IFC’s green building team to assess opportunities to incorporate energy efficient design parameters into their projects.

At the hotels, rainwater is collected and used for laundry while waste water is used by the cooling towers, as well as irrigation water for landscaping features and in the fish ponds. 

Water

Water at all the retail facilities is primarily supplied by the relevant municipality and Trans Retail does not undertake testing to confirm water quality.  At the hotels water is supplied by boreholes, treated at an-site water treatment facility which use a combination of sand and carbon filters and then chlorine.  Water used in the kitchens is further treated with ultra-violet light prior to use.  Bottled water is available for employees and guest alike for potable usage.

GHG Emissions

Total annual emissions associated with existing activities are estimated to exceed 25,000 tonnes of CO2-equivalent annually, and this similarly applies to new projects. The company will annually quantify GHG emissions from its current and future operations and report these annually to IFC.  The company has confirmed that all refrigerants used are non-ozone depleting.

Wastewater Treatment

All the retail stores are connected to the municipal sewage systems for the disposal of waste from the ablutions and waste water from the food processing areas e.g., wash down water. The hotels have dedicated waste water treatment facilities and, as noted, the water is reused to the extent possible.  All sink facilities at the respective operations are connected to grease traps prior to the waste being discharged. The waste water quality is monitored by local municipality once every quarter and the water quality results indicate the water quality is aligned with that as defined in the World Bank Group General Environmental, Health and Safety Guidelines. 

Solid Waste Management

Solid waste generated by the retail facilities is collected by the relevant municipal services and there are dedicated waste storage facilities available external to the stores with carboard and similar such packaging material separated for recycling purposes.  All expired food is disposed of. The hotels have dedicated waste storage areas with wet waste stored in bags in a chilled room prior to disposal, bins for general mixed waste for disposal and separate sections for plastic containers, cardboard and packaging material and glass which are recycled or reused.  All these areas are under cover and secured.  

Hazardous Materials

Limited quantities of paints, grease and the like are used in the day to day maintenance of buildings.  The only hazardous material the facilities utilize in any quantity is diesel for the standby generators which is stored in underground storage tanks.  Liquefied petroleum gas used in cooking is transferred directly to all facilities via the provider in the respective areas and thus there is no-storage on-site.  

Pesticide Use and Management

Pesticide management at both the retail facilities and hotels are outsourced to recognized pest control companies e.g., Ecolab and Rentokil.  These companies all used pesticides specifically accredited for use in such facilities.

  Community Health and Safety

The retail stores rigorously apply the hygiene policy and control procedures to ensure food safety and this includes use of the appropriate equipment by staff and regular checks on the temperature of areas where refrigerated goods are displayed, and the recording of such.  As noted previously, individuals working in the fresh produce areas undergo regular medical checkups for communicable diseases such as tuberculosis.   There is also a Food Expiration Policy which defines the approach to this issue central to which includes checking different sections of stores as per a predefined schedule to ensure food products at or beyond their sale by date are removed from the shelves.   Fresh produce is also tested for upon delivery.

At the food outlets in the theme parks and the food outlets in the retail stores there is a hygiene audit by associated store safety team annually, and external checks on all are undertaken once a year. These assessments include sending food for sampling to assess potential contamination. The contractual requirements with all vendors require compliance with Tans Retail’s Safety Policy. 

As noted the hotels also have a defined program and related set procedures which are aligned with HACCP for food safety which is overseen by a dedicated staff member.  In addition, there are independent audits of the approach to food safety twice a year by an independent Australian company. 

Infrastructure and Equipment Design and Safety

There are regional maintenance teams who undertake maintenance of equipment at all stores according to a planned maintenance schedule, and this similarly applies to the hotels. 

The design of facilities considers the potential for an earthquake and to ensure access for disabled persons; the latter includes having one payment point / till at each store designed specifically for access by disabled persons.

All stores are designed to ensure compliance with local life and fire safety (LFS) standards.  As it applies to the current expansion of retail activities which focus on standalone facilities, DP Architects stated that for the most part Indonesian standards are applied and then supported where necessary by applying key aspects of the NFPA or Singaporean codes.  A similar approach is applied to the hotels.  To align with IFC’s LFS requirements for public access buildings, the company will develop a standard LFS master plan to be applied to the construction of all new stores and hotels and this will also define the approach to emergency planning and response. The plan will detail the local legal requirements for projects, all applicable LFS codes to be applied which define means of evacuation and systems for fire prevention, detection and suppression amongst other requirements as necessary.  In doing so, the company will engage a suitably qualified specialist to confirm that the procedure and standards align with the requirements of per the LFS Section 3.3 of the World Bank General Environmental Health and Safety Guidelines.

Following IFC’s investment in the company, a suitably qualified specialist will undertake an audit of the first 3 stores to be opened to confirm these have been constructed as per the agreed plan.  Similarly post construction of the hotels, an audit will also be undertaken confirming these have also been constructed in accordance with plan defined.  In respect of the stores and hotels, where deficiencies relative to the agreed plan are identified, the company will implement corrective action plans accordingly.   The actions referenced above are included in the project ESAP.

Security Personnel

The individual retail and hotel facilities have a dedicated security team comprising a core of permanent staff and contractors in support.  All guards undergo training and are unarmed.  There are undercover personnel at the retail stores and at the theme parks.

 As part of the ESIA’s undertaken for the various new developments there is stakeholder engagement. 

There is hotline number available that can be used to report complaints.  However, as defined in the ESAP the company will develop and implement a formal grievance mechanism by which stakeholders at the retail facilities and hotels may raise E&S issues.  This mechanism will also formalize the approach to managing grievances raised and separately define the methodology to addressing E&S concerns, as opposed customer complaints / queries. 

The individual hotels have a Social and Development Team and Community Development Team which focus on community engagement in the area in which they operate. Examples of activities initiated in the last year include providing free access to orphanages in the area to the theme park located adjacent to the hotel, organizing blood donation and direct financial support to the community.  The retail operations also have initiatives to support the communities in which they operate, however these are ad hoc in nature and focus on providing food to orphanages and support to disabled groups amongst other aspects.

    This document and the companion ESAP will be made available on the World Bank Infoshop and at the offices of PT Trans Corpora as per below and for further information contact details are as per below.

Company:               PT Trans Corpora

Contact:               Mr. Ashish Saboo, Director, Business Development

Telephone Number: +62-21-7917 5533

Email              ashish.saboo@ctcorpora.com

Address : Menara Bank Mega, 24th Floor Jl. Kapt. P. Tendean Kav. 12-14 A, Jakarta 12790