The retail developments under the project are in urban/peri-urban areas with minimal to no vegetation and surveys have not identified any features or species which would trigger PS6 for Biodiversity Conservation and Sustainable Management of Living Natural Resources. There are no Indigenous Peoples in the project area, and therefore PS7 on Indigenous Peoples is not applicable.  The project is being built in urban areas without any known cultural heritage, hence PS8 on Cultural Heritage is not applicable. However, the company will develop a chance finds procedure in case cultural/archeological resources are discovered during the excavations related to project construction as described under PS1.

    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 impacts that may result can be avoided or mitigated by adhering to generally recognized performance standards or design criteria as is described in the following sections. Key environmental and social (E&S) issues and risks associated with this investment include: (i) assessment and management of E&S risks and impacts related to the development and operation of the malls; (ii) labor and working conditions including for the contractors; (iii) L&FS; (iv) occupational health and safety (OHS) during construction and operations; (v) solid waste management; (vi) resource efficiency and (vii) impacts on nearby communities due to transport infrastructure.

  Identification of Risks and Impacts

Environmental and social impact assessment (ESIA) studies were completed for all the malls in accordance with Egyptian law and approved by the Egyptian Environmental Affairs Agency (EEAA). In addition to the ESIAs, the company also conducted traffic impact assessments and geotechnical impact assessments for all the projects to identify key risks and impacts due to the project for the surrounding area. The data obtained from these studies was assessed by the company’s design unit and consultants to determine the most efficient ways to improve site accessibility, pollution prevention, site development and protection, rainwater management, life safety concerns, heat island reduction, light pollution reduction and measures to reduce water and energy consumption.

Under the scope of the project, the company has also developed external infrastructure in the surrounding areas of the malls. These infrastructure activities were paid for by the company but implemented by the relevant government entities, on government-owned lands, as part of the public infrastructure development projects. There were no informal settlers on any of the government owned lands mentioned above, and hence did not result in any involuntary resettlement for any of these developments. Respective government agencies responsible for developing this infrastructure were responsible for compliance with E&S requirements applicable for such public infrastructure development.

Policy and Management Programs

The company’s Environmental policy focuses on reduction of energy and water consumption through their resource efficiency program. Accordingly, and with the objectives of continually improving the E&S performance of its activities, products and services, as well as to prevent pollution, minimize the environmental impacts and, as a minimum, ensure compliance with the applicable legislation, the company develops management programs to promote resource efficiency, to mitigate water and energy consumption, to manage waste, to improve occupational health and safety, amongst other aspects.

The company ensures that all the mall developments under the project are OHSAS 18001 certified and the requirements are applicable for all the contractors. A documented EHS Plan guides the company’s day-to-day operations in line with OSHAS 18001 and requires their contractors to be OSHAS certified and includes necessary OHS provisions covering all employees including contractor’s.

Going forward as per ESAP#1 as part of its EHS plan, the company will, develop a chance find procedure if any cultural heritage is discovered during construction phase of future developments.

Organizational Capacity and Competency

The EHS function at the company is under Quality Control (QC) department which reports directly to the CEO and CTO of the company for all the assets. EHS auditing, inspection and monitoring is covered by QC department and outlined in its EHS plan. The EHS team comprises of EHS Manager and 3 officers at corporate level; who oversee and coordinate with a large team of the EHS officers and consultants hired at each construction site by the company as well as by the construction contractors as per the EHS plan and related contractual obligations.

Monitoring and Review

The company sets targets and defines key performance indicators (KPIs) in reference to water, energy consumption and L&FS, action plans are developed to improve the indicators, and in some cases, follow up audits are conducted. The Civil Defense authority does yearly inspections at each mall. To formalize this practice and process, the company will develop a documented procedure for monitoring, review by the accountable persons and follow up corrective actions in line with ESAP #1

Emergency Preparedness and Response

The company’s EHS plan includes an Emergency Response Plan in case of fire and evacuation. The mall facility management (FM) team maintains a checklist for all L&FS features which is reviewed every month, to check whether: all the fire exit corridors are free from obstacles, fire exit doors are operating properly, fire exit signs and emergency lights are checked for proper operation etc. Assembly points are clearly marked and free, fire drills are executed every 3 months and the FM staff are trained by the Civil Defense every year. Fire extinguishers are checked for expiration date, fire alarm panel is checked for false alarms and all its interconnection with HVAC and other systems are properly functioning, fire pumps are checked as per the O&M manual. The company has a 24hrs monitoring for all life safety systems. The Emergency Response Plan also includes incidents such as earthquakes and unrest, and the company conducts emergency drills twice a year with in accordance with the designated assembly points.

   Human Resources Policies and Terms of Employment

The company has about 1,300 employees, 13.7% of whom are women. Women also represent around 30% of management positions at the Corporate level. Of the 1,300 employees, 396 are direct employees.  The rest of the employees are outsourced staff in the two malls for security and facility management.

The Human Resources department at ECRED is responsible for establishing the HR policies and procedures as well as its implementation. The HR Manager reports directly to the CEO of ECRED. The company has HR policies and procedures in place, which include: terms of employment, working hours, benefits, leave, disciplinary procedures, etc. The HR policies and procedures are shared with all employees upon joining the company as well as during induction training. The company requests medical checkups (no pregnancy tests) upon appointment and checks regularly for drug and alcohol testing. Employees of the company are trained on various task related matters, as part of the annual training calendar. The company’s HR policies and procedures are consistent with local labor laws and IFC PS2 requirements.

Freedom of Association, Non-discrimination and Equal Opportunity:

There are no unions or worker organizations at the company as there was never a request for it. While the company respects the workers’ freedom of association, the same is not formally documented in its policies. Going forward, the company will update its HR policy to document the same. Similarly, company will document its commitment about non-discrimination and equal opportunity with respect to encouraging disabled persons employment and female employment as per ESAP #2.

There is a zero-tolerance policy in the HR policy on sexual harassment and misconduct. Legal department does investigation for complaints such as harassment, or gross negligence, or court cases to ensure impartiality against any liability.

Grievance Mechanism

The company annually does a satisfaction survey to gauge the employees’ satisfaction. There is an employee grievance policy under the HR policies and procedures which entails as a first step to speak to the direct manager, then to HR, then to a committee. Types of complaints received generally include those related to allowances, salary increase, and other such matters, which are addressed appropriately.

The grievance policy does not specify maximum number of days of dealing with grievance and reporting back to the complainants. Moreover, there is no system for anonymous reporting of the grievances. The company will thus, update its grievance policy to include confidentiality provisions, channels to raise workplace concerns anonymously, as well as define response time (ESAP#3). Moreover, the company will make available the grievance mechanism to all employees, including those from the contractors and will inform widely among the workforce about the availability of the revised grievance mechanism (at the time of recruitment in the case of new hires) and make it easily accessible.

Occupational Health and Safety

The EHS Plan includes OHS provisions and safety trainings to all employees during induction and throughout construction phase during toolbox talks. As described earlier, all the contractors are required to be OHSAS certified, and assign necessary EHS staff, which are supervised by the company’s EHS officers. Accidents are documented, recorded and analyzed as per the company’s EHS Plan.

Workers Engaged by Third Parties

The company has different contractors for the construction of different malls, but always ensures that EHS requirements are included in contractual obligations with contractors, and that, all contractors, consultants, and FM service providers are ISO certified and have proper management systems in place. The company provides its EHS Plan to the contractors and asks them to adopt it based on the specific project situation. The contract between the company and the third parties includes clauses for compliance with labor laws, as well as minimum wages, minimum age, and overtime. Contractual obligations require that no one is to be employed on construction sites below 18 years as per the company’s HR policy.

During the operation phase, the malls are managed by a Facility Management FM service provider for all activities including housekeeping, landscaping, L&FS, CCTV security, water and wastewater, waste collection and maintenance and repair.

In general, the company’s contractors do not use worker accommodation camps, however in Mall of Tanta the contractor did have a small construction camp for 40 labor as a temporary site for a few months. The company will incorporate IFC’s worker accommodation guidelines in their contractual obligations with the contractor for the future malls (ESAP #4).

The company’s EHS officers regularly audit the contractors for the OHS aspects, including first-aid, personal protection equipment, tools and equipment’s condition review, safety store’s conditions review, emergency preparedness, work in heights control, and chemical products safety.

There is currently no audit being conducted by the HR or EHS offices of the company for the third parties (such as FM contractors) towards labor compliance. The company will begin doing this as per ESAP #4.  

   Resource Efficiency and Pollution Prevention

The company has been actively developing a resource efficiency plan on water and energy. During the design phase, the company’s design unit together with the consultants, study different water and energy savings options including the use of energy efficient air-conditioning and lighting systems, use of renewable energy, and the optimal use of underground water wells.

During the operations phase, the water and energy meters readings are checked and compared with the average historic readings. Changes are analyzed and corrective actions are taken where required.

In order to conserve water (in projects that have water shortages) , the company uses air cooling AC systems as opposed to water cooling AC systems in Mall of Arabia and Mall of Tanta. While projects that have no water shortages use centrifugal/gas chillers as opposed to air cooled systems to reduce 35% of the total energy consumption in the HVAC system.

For the existing malls (Mall of Arabia, Mall of Tanta), refrigerant R22 and R407 are used. For new malls (Mall of Kattameya and Mansoura) chilled water plants will be used instead of the DX units and thus no refrigerant will be used.

Some of the resource efficiency measures that the company is implementing, include the following: solar reflective roof paint, double glazing for windows, roof and wall insulation; low energy lights (CFL, LED, etc.), energy efficient heating and cooling systems, solar collectors for hot water; low energy appliances; water efficient taps, showers and dual flush toilets; reclaimed/recycled building materials; low carbon roofs and floor surfaces; and smart meters. The malls are compliant with IFC’s EDGE Green Building certification, and will aspire a certification for at least one of the malls thereby further reducing the GHG footprint.

Water and Wastewater

Water required for the construction and operation of malls is sourced from municipal sources.

There is currently no on-site sewage treatment plant, and the sewage from the malls is discharged to the public sewage network for further treatment by the municipality. Sand traps are provided on-site for all storm drainage system and grease interceptors are provided for all indirect waste.

GHG Emissions

Main source of the GHG emissions is the electricity consumed for the operation of the malls, in addition to small quantities of liquid fuel (e.g. diesel for generators). The company’s GHG emissions for all its malls are estimated to be about 27,500 tCO2/year. However, the company is currently more than offsetting these emissions, as FAS energy, a sister company of ECRED feeds 50 MW of solar power to the national grid, whereas the company’s malls are consuming little over around 40 MW in total from the national grid.

Waste Management

The company’s waste management policy and procedures are part of its EHS plan, which has an objective to reduce construction waste. To achieve this, the company adopts the following measures: 1) Re-use of excavated earthwork materials where applicable, 2) Surplus excavated materials are disposed in government approved disposal areas; 3) Scrap metals are sold to recycling facilities for melting and re-use; 4) Scrap wood is sold to recycling facilities that re-use them in fabrication of chip wood and fiberboard sheets, 5) Other surplus materials are disposed in government approved disposal areas where hazardous materials is segregated from other materials, and 6) Un-used finishing materials are moved for use in other project sites.

During the operations phase, the FM service provider for each mall handles the waste for the malls through licensed local municipal contractors. Hazardous waste including electronic waste is disposed of through licensed contractors; whereas organic food waste is mixed with all other waste and collected by the municipality.

  Infrastructure and Equipment Design and Safety

To manage the large number of footfall and associated vehicular traffic, the company conducts a traffic impact study during the design phase of the mall. The data obtained from these studies get assessed by the Design Unit and consultants to determine the most efficient ways to improve site accessibility and prevent sound and light pollution. As per the local authorities’ regulations, all commercial and retail projects must have enough parking areas to cover the entire project needs. In several cases, the company has financed the upgrade of the transportation infrastructure in the surrounding area.

All of the malls in Egypt are American Disabled Association (ADA) certified and meet the universal access requirements catering to special needs including: providing access ramps, handicapped parking areas, handicapped toilets, handicapped elevators and wheel chairs at mall entrances.

All L&FS systems including fire alarm system (designed and constructed as per NFPA 72) and fire protection system (designed and constructed as per NFPA 13), and fire exits are included in the building design. All these systems design and installations are reviewed and approved by the Egyptian Civil Defense before granting the mall its operation license.

Moreover, the company shall engage the professional services of a qualified L&FS consultant to: (i) conduct a review of the existing facilities to evaluate the emergency preparedness and response capabilities, including existing L&FS systems (such as fire detection and alarm systems; fire prevention; means of egress; fire suppression systems such as sprinklers and extinguishers; emergency response plan; and operation and maintenance); (ii) prepare, if necessary, a Corrective Action Plan (“CAP”) for individual properties with proposed completion dates as per ESAP #5. The company will also develop standard requirements (master plan), applicable to the new facilities, for fire safety systems design and operation which will build upon the requirements of local fire safety regulations and an internationally recognized L&FS code such as British, French, Canadian or US National Fire Prevention Association (“NFPA”) codes. The applicability of such requirements will take into consideration risks associated with retail facilities and site-specific risks associated with each facility to be identified by a qualified professional as per ESAP #6.

Security Personnel

Security is outsourced to two reputed and licensed service provider companies for all the malls. There is a Security Manager at the corporate level to oversees the security operations and the contractor companies for all the malls; who is supported by a team of 19 security personnel. All security guards at all the malls are unarmed and are trained by the Egyptian Ministry of Interior on the use of force. The corporate security department documents all security complaints and reports them monthly.

   The company’s vision is to transform and develop the areas in which it locates its projects to enhance the infrastructure of the area for the mall as well as for the surrounding community. The company has done this in Tanta (and is planning to do the same in Mansoura) by supporting the development of road and telecom infrastructure, as well as waste and sanitation networks. These otherwise impoverished areas were not connected to the grid for these services.

In addition, the company’s aim is to employ directly from the local communities within their malls both during the construction phase as labor, as well as the operation phase for store tenants and mall employees. With support from IFC’s Gender Advisory team the company is trying to enhance female employment in these secondary cities in Egypt for the benefit of the local communities from these projects in a multitude of ways.

External Communications and Grievance Mechanisms

The company has an external community grievance mechanism for its consumers of the mall which is divided into the Customer Service Department under Mall Management, and under the Security Department under Mall Management. Depending on the grievance, each of the various departments’ records, files and handles the grievance accordingly. For instance, grievances related to theft, sexual harassment will go the security department, whereas lost child, complaints against retail shop employees goes to Customer Service Department. This project will incorporate a Gender Based Violence (GBV) component to train the company staff on how to handle GBV cases at its malls. All grievances are documented and reported monthly to the Mall Manager and Head of Operations of the company. There have not been any community grievances filed from neighboring communities around Mall of Arabia or Mall of Tanta.

Internally, the company has not documented the criteria for grievance handling. The company shall therefore to develop a documented procedure for grievances handling including maximum number of days/hours for dealing with the grievance and reporting back, as per ESAP #7.

    Contact Person: Ashraf Farid

Company Name: Egyptian Center for Real Estate Development

Address: Juhayna square   - Mall of Arabia Gate 4

Email: afarid@marakez.net

Phone: +202 27366355

Facsimile: +202 27383473