PS5: Land Acquisition and Involuntary Resettlement is not applicable as the laboratories, both existing and planned acquisitions are set up or planned to be set up in leased commercial buildings. PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply because the planned project sites will be in urban centers i.e. modified habitats with no significant biodiversity values. PS7: Indigenous Peoples and PS8: Cultural Heritage do not apply because the project will not cause any impacts on indigenous people and the presence of cultural artifacts is unlikely.  

   This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. Based on information reviewed by IFC, this investment will have limited adverse E&S risks and impacts that are few in number and site-specific, with limited renovation or 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.

Key E&S risks and impacts associated with the project include; the company’s capacity and systems to assess and manage E&S risks and issues associated with its operations and during development and acquisitions of the new laboratories; provision of fair and safe working conditions for employees and contractors; occupational health and safety (OHS) policies and practices including infection control; resource efficiency measures; medical waste and wastewater management; life and fire safety and the company’s stakeholder engagement activities.

  Environmental and Social Assessment and Management Systems:

CLA’s laboratories are accredited to ISO 15189:2012 medical laboratories standard and have integrated ISO 14001 Environmental Management System and OHSAS 18000 Occupational Health and Safety and ISO 9001 Quality Management System in the management of the network of laboratories. The company has adapted Lancet’s Manuals for Quality and Safety Health and Environment (SHE) including protocols and procedures that are applied throughout the laboratories in the network as well as site specific protocols and procedures. For each laboratory, the company maintains either South African National Accreditation System (SANAS) certificates or certificates provided by the regional accreditation bodies such as Kenya National Accreditation System (KENAS). The laboratories are audited annually by external auditors as required by the standards.

CLA has an overarching Safety, Health and Environment (SHE) policy that is consistent with the principles of the Performance Standards and is communicated to all staff and stakeholders. The policy enumerates the company’s commitment to comply with all local, national and international laws. It is reviewed annually to ensure appropriateness and enable continuous improvement. For the upcoming new laboratories and acquisitions, the same corporate policies, practices and management systems will apply as they become a part of the network.

Identification of Risks and Impacts

The company has developed a corporate risk and opportunity management policy that provides an integrated framework for effective management of risks and opportunities to optimize decision making, add value and help achieve the group’s corporate objectives. Each department manager is responsible for risk and opportunity management functions and has a risk and opportunity champion (ROC) to assist in compiling the departmental risk and opportunity registers. Each register contains risk mitigation and opportunity pursuit plans. Guidelines are provided for risk rating, impact and consequences if the risk were to be encountered, control effectiveness options, residual risk factors and possible risk mitigation strategies to guide staff on avoidance, transfer or mitigation of risk. Identified risks are documented and addressed on site, while major risks are escalated for management interventions, especially where additional resources are needed to address those. As per ESAP 1, the company will develop a documented procedure and checklist for environmental and social (E&S) screening of the new laboratories and acquisitions to identify risks and develop action plans for improvement prior to commencement of operations.

Management Programs

CLA’s corporate objectives include; advancing corporate sustainability by reducing waste and improving SHE compliance and customer relationship management. The corporate risk management program includes; the development and implementation of risk registers, development of implementation plans for the identified risks and internal audit and reporting. The SHE programs include; good laboratory practice and employee SHE rules; SHE committees; personal protective equipment (PPE); good housekeeping practices; personal hygiene; hazardous biological agents (HBA) and exposure protocols; SHE incident management; first aid; hazardous chemical substances (HCS) management, environmental management, safe working procedures and fire and other emergencies management. There are various procedures, protocols and working forms developed for the implementation and auditing of the programs. There was evidence of robust implementation of the documented procedures, plans and monitoring records on site during the visit and interviews with selected staff. There are IT systems such as collaborator for the quality and SHE management system for storage and distribution of approved and controlled documentation. Human resources management is also supported by a robust human resource information management system (HRIS).  

Organizational Capacity and Competency

CLA’s laboratories operate under the direction of the respective Country Managers, assisted by their Laboratory Managers. Each country has a designated SHE officer responsible for co-ordination and awareness training of the SHE rules and procedures, supported by a safety health and environment committee. For the smaller laboratories the Quality Manager or officer is responsible for SHE, and safety committees are not in place.

The Health and Safety Committee undertake the following functions: implementation and co-ordination of the SHE management system; support internal and external safety audits; investigation and management of workplace injuries and incidents; completion of injuries on duty documentation; health and safety training and communication with external parties such as fire service provider or waste contractors.

The Human Resource (HR) departments in each country works with the departmental heads to develop and implement a training plan annually for all employees. Training needs are identified by each department and training logs maintained for training sessions held. The company provides induction training for new staff for three months and thereafter on-the job training for one year. Refresher training sessions are organized for existing staff annually depending on the training needs assessment. Training topics for staff in various departments include health and safety manuals, fire safety, hand washing procedures, eye wash station locations and usage, first aid, emergency plan, evacuation routes, PPE, material safety data sheets (MSDS) location and content and screening and treatment for occupational exposures (hepatitis B and tuberculosis).

Emergency Preparedness and Response

The Safety, Health, Environment and Quality (SHEQ) working manual outlines detailed procedures on HCS, fire and other emergencies management. The laboratories visited were observed to have fire suppression equipment installed at strategic locations, evacuation floor plans and emergency contacts clearly displayed at strategic locations. Fire drills and fire safety audits and certification are done as per local regulatory requirements and documented.

Monitoring and Review

The company has detailed internal quality audit guidelines for its internal auditors and laboratory and depot staff to achieve consistency in the required standards within all laboratories and departments. Monitoring is done through periodic inspections and audits. The parameters used include; respective inspection checklists, internal audit checklists, SANAS audit checklists and regulatory authorities’ inspections before licenses are renewed. The company provides training and evaluates the competency of the internal auditors that evaluate the Quality and SHE Management Systems. The company has document controllers in charge of the distribution control for all the documents in each country of operation.

The main laboratories in each country are audited annually by a team of internal quality auditors from the South African offices. The smaller and peripheral laboratories are audited by in-country trained quality champions. The company schedules annual external management system audits by the national certification bodies. Findings and corrective actions of the audits are documented in internal audit reports and discussed with senior management. Management reviews and implements the corrective actions before the next audit. 

  CLA currently has 1,277 regular employees in Africa. Of these, 511 are female and 766 male. Management level staff at middle management and top management comprise 42 women and 97 men.

Human Resources Policies and Procedures

The company has detailed documented Human Resources (HR) policies and procedures manuals adapted from the South African Lancet human resources policies and procedures which are consistent with the requirements of IFC PS2. In each country, the human resources managers have aligned these corporate manuals with the respective national legislative requirements.

Employee handbooks provide a summarized version of the company’s policies, procedures and rules. They include working conditions and terms of employment, overtime, leave benefits (annual, sick, maternity, parental, etc.), medical insurance, employee wellness, retirement, termination, grievance and disciplinary procedures, training and continuous professional development and sexual harassment. The company has developed a recruitment and selection policy and procedure as well as a grievance and disciplinary procedure for staff and a performance management system.

The corporate HR procedures and manuals will be used in the development of HR procedures and manuals in the new countries of operation.

Working Conditions and Terms of Employment

All employees have formal written contracts provided upon recruitment and the terms of service are explained during staff orientation and in the employee handbook. The contracts describe details such as job title, working conditions and terms of employment, training and leave benefits. The company provides medical insurance coverage for employees and dependents. Other benefits are dependent on host country legislative requirements.

The working hours are based on the national legislation. All employees are entitled to annual leave. Female employees are entitled to maternity leave with full pay in line with host country legislation.

Workers Organizations

National legislation in the countries where laboratories are situated recognize and respect workers’ freedom of association and right to collective bargaining. Although staff are not affiliated to any recognized union, the company allowed staff to form a welfare association or staff liaison committees to negotiate salary increases for nursing staff and laboratory technicians.  

Non-discrimination and Equal Opportunity

CLA is an equal opportunity employer and the company does not discriminate on the basis of sex, ethnic background or religious and social affiliation. Sexual harassment is not tolerated by the company. The company’s recruitment and selection policy commits to providing equal opportunity by assessing all potential applicants according to their skills, knowledge, qualifications and capabilities at all levels. All recruitment and selection processes aim to be fair, efficient and effective.

Grievance Mechanism

The company has a grievance procedure that outlines the grievance management process for all staff. The grievance procedure allows for a process of escalation if the grievance is not resolved with the immediate supervisor. The procedure also provides for appeal to an internally constituted committee and ultimately an option for judicial recourse if the company is unable to resolve the staff grievance. Although not explicitly stated in the HR manuals and employee handbook, anonymous grievance mechanisms can be reported through the HR information system that provides for anonymous reporting, use of suggestion boxes located at different locations at the laboratories or through the company’s fraud hotline managed by the internal risk department.

Protecting the Workforce

The minimum age for employment in is the countries of operation is 18 years. Labour Law in the host countries prohibits employment of child labor (young persons between 18 and 21 in hazardous work environments) or forced labor. The company’s employment screening requirements for potential employees include verification of birth certificates and national identity cards, which are only issued to persons 18 and over.

Occupational Health and Safety

The company has a health and safety manual and a SHEQ manual that outline procedures for all employees and contractors on occupational health and safety and infection control. The manuals provide detailed procedures for SHE committees, types of PPEs for staff, decontamination procedures, personal hygiene procedures, HBA exposure protocols, prevention of disease and post exposure prophylaxis. 

Workers engaged by Third Parties

Third party contractors include licensed waste management contractors and contractors undertaking renovations or fit out for the laboratories. The company will engage qualified / experienced contractors for renovation or fitting out the leased premises for new laboratories. The contractors will be required to follow the national regulations related to environment, occupational safety, and fire safety as well as the company’s EHS policy and procedures while working on the company premises.

    Resource efficiency

The company relies on electricity from the national grid to run laboratory operations. The laboratories are equipped with backup generators to provide energy in the case of power outages associated with the grid; which happen on rare occasions. As per ESAP 2, the company will explore the feasibility of including energy efficient design requirements in the design template for new laboratories (e.g. energy efficient lighting, HVAC systems, water saving plumbing fixtures etc.).

Water supply is from the public utility companies supplied to the leased commercial buildings. The laboratories are connected to existing municipal sewerage system where wastewater is discharged into.

The development of new and operation of the laboratories will not result in more than 25,000 tonnes of CO2-equivalent emissions per year.

Solid and Hazardous Biomedical Wastes

The company has developed and implements a healthcare waste management plan and procedures. Color-coded bins for the different waste types were observed during appraisal visit and staff are trained on waste segregation procedures and protocols. The waste management procedure maps out the sources and categories of waste, segregation into waste types, containerization into colour coded waste bins or receptacles and storage. Used needles are handled separately as per the standard operating procedure. The company has contracted licensed and accredited waste management companies in each country to collect, transport, treat and dispose of the waste. For all waste (solid and liquid), a waste manifest from the service provider as well as the internal company waste manifest must be provided with the weight of the waste and manifest stamped by the company.

Wastewater

The main sources of wastewater are sanitary wastewater, laboratory waste and runoff. The laboratories are connected to the commercial building sewer system which is connected to the municipal sewer. Hazardous and biomedical waste is segregated as per corporate procedures and collected by licensed contractors. According to the company procedures, process waste is not permitted to enter storm water drainage systems.

Hazardous Chemical Substances

The company has developed procedures for hazardous chemical substances (HCS) waste management. HCS are disposed through recognized hazardous waste disposal procedures. Expired reagents and chemicals are placed in color coded (red) biohazard waste bins, sealed with relevant MSDS attached to the outside of the biohazardous bin. Incompatible chemicals are segregated. The SHE Officer contacts the authorized waste collector to arrange for collection.  

    Infrastructure and equipment design and safety

For the new laboratories to be set up or proposed to be acquired as part of this project, the company will ensure that renovation or fitting out of existing buildings will comply with host country building requirements, fire department regulations and other related legal requirements. The company will prepare a master L&FS checklist for the applicable life and fire safety provisions for the prospective laboratories, considering means of egress, as well as the systems for fire prevention, detection and suppression (ESAP 3). The L&FS policy and procedures for the laboratories will align with the requirements of the L&FS section of the WBG General EHS Guidelines, as needed, critical upgrades should be considered in the budget of the new sites. The company will ensure proper coordination with the buildings maintenance companies where the laboratories are located.

Security personnel

CLA has a security policy and uses a range of security measures, including the use of CCTV cameras, access restriction signs and security staff. The company employs unarmed security guards to manage access control and emergency response. In addition, the company has engaged private security firms at different locations across the network. Training for security staff is done by external agencies. The company displays out of bound signages and have access control procedures on data use.

    The company through the country offices, regularly engages with the regulatory agencies and occasionally with the communities though CSR activities. The company has its contacts on its website and communicates and responds to community concerns through their social media platforms and press releases. The customer service team and the call center team log in customer concerns and complaints and directs them to the relevant managers for response. The team prepares weekly logs, undertake trend analysis and prepare monthly reports to management for review. The marketing and client services teams collate complaints from corporate clients. Stakeholder engagement will be conducted during site selection and or review of the premises to be leased for the new laboratories. Consultations will be done with communities neighboring the identified locations, local government authorities and relevant non-government entities.   

  Contact Person: Mr. Stephane Carre

Company Name: Cerba Lancet Africa

Address: 11-13 Rue René Jacques, 92130 Issy-les-Moulineaux, France

Email: stephane.carre@cerbahealthcare.com

Phone: +33 6 45 67 34 38