PS5 – Land Acquisition and Involuntary Resettlement is not considered applicable since the proposed facility will be built on previously commercial agricultural land that was acquired through a willing buyer, willing seller transaction concluded several years ago, and no new land acquisition is necessary. The project does not result in any involuntary resettlement and conversion of natural/critical habitats.  There are no indigenous people in the project area, and presence of cultural artifacts are unlikely. Therefore, PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage, are not applicable.     

  This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability (2012) because of potentially limited E&S impacts that may result from the construction or operation of the project.  Construction impacts are short term and not significant, while operational impacts are expected to be generally site specific and can be avoided or mitigated by adhering to generally recognized good practices and design criteria.

Key E&S risks and issues associated with the project include; the company's capacity and systems to assess and manage E&S risks and issues associated with its operations; provision of fair and safe working conditions for its employees and contractors embedded into the human resources (HR) and OHS policies and practices; resource efficiency measures with focus on energy and water conservation; monitoring and management wastes and emissions, and engagement with communities and stakeholders.                                                 

        Environmental and Social Assessment and Management Systems:

Since 2014, PHZ facilities are managed under a Marriott International master franchise agreement.  However, only full-serviced brands have Marriott Environmental sustainability Hub (MESH) implemented to monitor energy and water usage efficiency. As such, for the proposed hotel, PHZ will develop and implement as (ESAP Item #1) an Environmental and Social Management System (ESMS) aligned with IFC Performance Standard 1, the applicable parts of World Bank Group’s (WBG) Environmental, Health, and Safety (EHS) Guidelines, Tourism and Hospitality Development guidelines, and national requirements. Specifically, the ESMS is to include: an overarching policy statement objectives & targets; and an organization capacity including roles and responsibilities.  Environmental and Social Management Plans to be developed and implemented as part of the ESMS include; (i) Labor and Human Resources (LHR) Plan; (ii) Environmental Health and Safety (EHS) Management plan; (iii) Waste Management (WM) Plan; (iv) Emergency Preparedness and Response Plan (EPRP); and (v) an External Communication and a Grievance Mechanism.

Identification of Risks and Impacts:

PHZ’s risk and impacts identification for its operations is guided by the equipment manufactures’ specifications on energy and water efficiency, and Zambian regulatory requirements. For example, health risk assessment for restaurant workers is assessed quarterly by a third-party contractor.

The sponsor submitted an Environmental Project Brief in 2016 and Zambia Environmental Management Agency (ZEMA) approved with conditions which include: applying best available technologies, allow inspectors from ZEMA for site inspections, comply with applicable environmental standards, etc.  PHZ will comply with all conditions stipulated in ZEMA’s decision letter of March 2016 and commission a social impact assessment for the project.

Organizational capacity and Competency:

The Head of Operations is the designated person to oversee EHS implementation and review the E&S compliance across all the properties within the PHZ structure.  The Head of Operations reports directly to the CEO and is assisted by individual facility managers.

As part of this project, PHZ will develop an OHS management plan for the construction phase (as described below) and accordingly, shall assign a responsible supervisor to verify that environmental and OHS measures are addressed as per the plan and ensure compliance with contract requirements.

As per the ESMS described earlier, the sponsor will ensure that the project has a management structure for EHS issues, plus the committees on OHS, emergency preparedness, and external grievance mechanism. PHZ will guarantee EHS competency of the employees by hiring qualified individuals and/or providing additional training to the employees.

Emergency Preparedness and Response:

Currently, PHZ has a documented emergency response plan which has identified areas where accidents or emergencies may occur, and accordingly, has trained its staff on emergency response procedures.  PHZ conducts periodic emergency drill at all its facilities.  During these drills, hotel guests are informed and occasionally supervised by Lusaka Fire and Rescue Services.

Similar emergency response plan will be developed for the proposed hotel. In addition, as the proposed new hotel will be surrounded by a housing estate, PHZ will be informing this community during emergency drills. All the fire firefighting equipment (alarm, horse reels and portable fire extinguishers) will be tested annually as required by national laws.

Monitoring and Review:

During the construction of the new facility and as part of the EHS plan for the construction phase (see below), PHZ will ensure the contractor monitor, record and report injuries and other occupational, health and safety risks. During the operational phase, PHZ will develop a Standard Operating Procedure (SOP) for monitoring of EHS performance by defining Key Performance Indicators (KPIs) such as, energy and water use, fire safety and solid waste quantity, to be monitored and the frequency of monitoring. External monitoring is conducted annually by Lusaka Fire and Rescue Service for life and fire safety.                                           

  Human Resources Policies, Procedures and Terms of Employment:

PHZ has a documented HR policy and supporting operational procedures. This includes aspects related to non-discrimination and equal opportunity, recruitment, employees’ conduct, employment regulations, wages and benefits, disciplinary code, employees’ grievances, performance management and OHS.  The HR policy is implemented, enforced and monitored by the PHZ HR department, headed by a manager. However, the HR manual does not explicitly reference workers’ organizations, grievance mechanism, management of third-party workers and sexual harassment. PHZ as ESAP Item # 2 will align the existing HR manual to include provisions for workers’ organization, grievance mechanism both formal and anonymously, management of third-party workers and sexual harassment as required in with IFC’s Performance Standard 2 and Zambia labor laws. The new HR policy and procedures will be implemented for all PHZ operations and implementation reports will be submitted periodically.

At appraisal, PHZ had a about 475 full-time employees across all the current operations, comprising about 30% women and only one expatriate staff. The proposed new hotel, once fully operational, will employ 300 staff fixed term contract. Only security services are outsourced.

All PHZ employees are issued with contracts, which specify the terms of employment and working conditions (e.g., rights of the employees, training, remuneration, termination, working hours, compensation scheme, etc.) and benefits (e.g. salary advances and loans, medical and life insurance etc.). The contracts are verified by department of labor for consistency with the provisions of Zambia’s labor laws which are aligned in general with the International Labor Organization (ILO). Salaries and benefits for the different type of workers (e.g. fixed and term) are paid in accordance to local requirements. Aligned with company principles and local law, PHZ does not make use of child labor and/or forced labor in its operations.  For new recruits, the company has also developed an internal onboarding manual and an Employee’s handbook and guidelines of conduct.

Workers Organizations and Grievance Mechanism:

PHZ employees are free to join workers’ associations, aligned with local law which provides for freedom of association; at appraisal a small number of employees were unionised. The company does not discourage workers from forming or joining workers’ organizations of their choosing or from bargaining collectively and will not discriminate or retaliate against workers who participate in such organizations. Supervision activity of existing projects with PHZ has not identified any concerns regarding freedom of association. The new hotel will apply these principles for worker’s organizations. Although, the company’s HR policy allows for workers to raise their workplace concerns and has a workers committee chaired by a non-management member, a formal and documented grievance mechanism is currently not in place. PHZ will therefore, develop as ESAP Item # 3 a formal system for employees to raise grievances, including anonymously, (for example through a dedicated email address or complaint box to submit confidential grievances, without the risk of reprisals). The grievance procedure will also articulate how the grievances will be handled and resolved; and outcomes communicated to all employees. This procedure will be applicable to all existing and new employees, third-party staff, and shall form part of the HR policy and other relevant documents and shall be communicated extensively to all the beneficiaries.

Occupational Health and Safety:

PHZ is striving to provide a safe and healthy working environment to its workers. Workplace risk assessments and monitoring is performed annually in compliance with the Zambia OHS regulations. These OHS audits, like six-monthly medical check-up for kitchen staff, practicing certificates for manager are undertaken by approved safety and health advisors registered with the Directorate of Occupational Health and Safety Services, under the Ministry of Labor and Social Security. Identified hazards are presented to the Safety and Health Committee for implementation. The recent audit reports, which were submitted to IFC for review, were found to be comprehensive in their scope and did not show any material non-compliances.

PHZ conducts periodic EHS training (e.g. first aid, OHS, work place safety, basic fire preventive methods, etc.) for all workers.  This will continue in the new operations.

The company will commission a third-party contractor (Velos Enterprise Ltd.), for the construction of the proposed hotel. PHZ in collaboration with Velos will as ESAP Item #4 develop, implement and monitor an EHS management plans (EHS MPs) for the construction phase, in line with Zambia’s OHS laws, World Bank Group (WBG) General Guidelines and IFC Performance Standard 2. The plans, among other measures, will include procedures for managing and monitoring of OHS performance of the construction contractors by PHZ team and necessary OHS related clauses will be included in the contract. PHZ will also ensure that contractor does not hire child labor.            

   Resource efficiency:

Energy: PHZ sources energy from the national grid and uses standby diesel generators in each facility. A 90KVA generator is already installed at the project site and is currently used to run the irrigation pump for the golf course. Estimates from one of the existing hotels (Protea Lusaka Cairo) indicate the energy consumption kWh/m2 of serviced space, greater than 370, which is higher than the good international industry practices benchmarks for resources and energy consumption (Table 1 of the WBG EHS Guidelines for Tourism and Hospitality Development). PHZ has put in place measures to reduce energy consumption in its existing hotels, through LED lighting, installation of air conduction VEF (vacuum effects) units; using gas for cooking in all kitchens and utilizing energy efficient laundering equipment. Moreover, the proposed hotel is being designed as per the good international industry standards. The design includes, green building principles and the company aims to achieve IFC EDGE green building certification. In addition, PHZ will install solar water heaters as part of energy saving initiative.

Water: Water for the proposed hotel operations will be sourced from a borehole. In addition, PHZ is planning to connect to the municipal water supply network.  PHZ has initiatives to minimize the use of excess water in the new facility. The company plans to use treated wastewater for irrigating the adjacent golf course, thereby further reducing the fresh water consumption. In order to establish water use efficiency, PHZ will meter the borehole and collect data on annual extraction.  The data will be reported to IFC as part of Annual Monitoring Report.

Currently PHZ does not have a raw water filtrations system.  For the new project, PHZ as ESAP Item # 5 will install a multistage treatment facility, which includes filtration, reverse osmosis and ultraviolet purification. Water quality tests will be conducted periodically, and results reviewed to meet the WHO potable drinking water quality standards.

Greenhouse Gases (GHG) Emissions:

Current GHG emissions from one existing operations (based on electricity and fuels) have been estimated at approximately 40 tons CO2-equivalent per year. Additional GHG emissions due to the proposed project are not expected to be significant and will be well below 25,000 tons of CO2-equivalent per year.

Pollution Prevention:

Wastewater treatment: The PHZ hotel facilities in urban areas are connected to the municipal sewerage systems.  However, for the new project, all wastewater effluents will be treated on site since there is no central sewer system coverage in the project area.  PHZ as ESAP Item # 6 will design and build a waste water treatment plant (WWTP) and shall provide documented evidence that the treated effluents comply with the Zambian regulations and/or WBG General EHS Guidelines (Table 1.3.1). The sponsor intends to use the discharge for watering the golf course greens, hence PHZ shall ensure the treated wastewater will meet Zambian regulations for sanitary wastewater discharges or, in their absence, the indicative guideline values applicable to sanitary wastewater discharges shown in Table 1.3.1 of the WBG General EHS Guidelines

Solid Waste Management: Based on Marriott’s standard operational requirements, PHZ has implemented a waste management plan and procedures across all the hotels to ensure that, non-hazardous wastes are properly stored, transported, treated, and disposed. The main type of solid waste are cartons and food waste. These are stored in waste chambers for sorting and periodically collected by ZEMA registered vendors and finally deposited at a designated municipality landfill.  At the new facility, waste will be collected by the municipality.

Pesticides: For the current operations, the sponsor, uses Termidor, Goliath, Tenopa, Fendona for crawling insects and general fumigation. Fumigation is carried by the sponsor with close collaboration the chemical manufacturers BASF. Designated personnel are properly trained, the sponsor has equipment, and facilities to handle, store, apply, and dispose of these products properly. All the chemicals are approved by WHO and are neither from the restricted category 1a or 1b. The sponsor intends to use similar chemicals in the proposed project.           

     Life and Fire Safety:

The building designs has several elements of emergency plans incorporated; such as wide corridors, disabled persons’ ramp and firefighting systems. However, as mentioned under PS1, PHZ will comply with local regulations regarding life and fire safety (L&FS) design and installations in existing and new facilities. As such PHZ as (ESAP Item #7) will contract an expert in international L&FS standards to review the design for the new facility to verify that the L&FS systems are designed in accordance to the L&FS section of the WBG General EHS Guidelines and provide the certification, affirming that the L&FS systems were designed, installed and are properly tested.  If the certification is not issued, then a corrective Action Plan with proposed completion dates and expected metrics shall be submitted to IFC. The design should meet both local Zambian requirements and those of an international L&FS code (such as NFPA 101 of the National Fire Protection Association).  The standard specifications will include operational and maintenance guidance, such as the preparing of schedules for mandatory regular maintenance and testing of life and fire safety systems and regular fire drills.

Security Personnel:

PHZ employs unarmed security guards from a third-party contractor, for access control and emergency response purposes in all its current facilities. 

Food Safety:

PHZ is implementing food safety program based on Hazard and Critical Control Point (HACCP) for all its restaurants, and has developed Standard Operational Procedures (SOP), on hygiene and sanitation; pest control by ensuring ensure no WHO Class 1a and 1b pesticides are used; chemical control; staff hygiene and training; customer complaints mechanism; and traceability. PHZ will establish a similar program in the new hotel.                                              

 External Communications and Grievance Mechanisms:

At appraisal, the sponsor’s procedure for external communication with stakeholders was via a website (www.uniongold.co.zm). The mechanism does not include; procedures to receive and register any complaint(s)/query lodged to the company by affected stakeholders/individuals. As part of the ESAP Item #6, PHZ will, develop an external communication and a community grievance mechanism for the construction and operation phase which will include identification of stakeholders; develop communication channels and a grievance mechanism and publicize its availability.  As part of the stakeholder engagement.  

Contact Person: Christopher O’Donnell

Company Name: Union Gold (Zambia) Limited

Address:  Office Suites, 2nd Floor, Office Suites, Protea Lusaka,

Arcades Shopping Centre, Lusaka, Zambia 10101

Email: cmodonnell@uniongold.co.zm

Phone: +260 966 125 010