The project will be developed on land acquired by the sponsor on a willing buyer-seller basis and no involuntary physical or economic displacement occurred. The land was previously used as a warehouse.  The site is in the urban area of East Legon in Accra, in a well-developed commercial and residential neighborhood; therefore, impacts related to PS6: Biodiversity and Natural Resource Management, PS7: Indigenous Peoples and PS 8: Cultural Heritage are not expected. 

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012) because of the limited number of possible adverse impacts, the site-specific nature of these possible impacts, and that these potential impacts can be avoided or mitigated by adhering to generally recognized performance standards, procedures, guidelines or design criteria.

Key potential environmental and social impacts during construction and operation of the project analyzed include; (i) site location in an urban setting; (ii) identification of environmental and social impacts; (iii) management systems in place to address environmental and social issues; (iv) labor and working conditions, including occupational health and safety of employees and construction contractors; (v) solid and liquid waste management and disposal; (vi) tenants and visitors health and safety issues such as potable water and emergency response; and (vii) life and fire safety aspects of project design and operation.

Fulfilment of the action items included in the attached E&S Action Plan (ESAP), adherence to the national laws and regulations, internationally recognized standards, the WBG/IFC EHS general Guidelines applicable to the project will facilitate the project implementation in a sustainable manner

Environmental and Social Assessment and Management Systems and Management Programs:

A&C Development is yet to develop and implement an Environmental and Social Management System (ESMS). Given the proposed expansion, A&C Development will as ESAP Item # 1 develop a corporate level ESMS for all its facilities.  The ESMS will define management programs to be adopted to mitigate environmental and social impacts throughout the project cycle (i) design standards (life and fire safety) (ii) construction (for example, mitigation measures can be related to access, excavation, noise, materials storage, construction safety); (iii) post-construction (for example landscaping, traffic plan); (iv) routine operations (for example, waste management, monitoring of potable water, monitoring of utilities use); and (v) emergency response. The ESMS will consist of documented operational procedures, practices, plans, and related supporting documents managed in a systematic manner.

The project has been designed to achieve international standards on general safety including life and fire safety, environmental protection and, operations savings to adhere to program EDGE of IFC among other standards. IFC EDGE specialist reviewed the project design and provided expert advice for the project to realize EDGE certification.  Accra Metropolitan Assembly has provided the building permits, while Ghana National Fire Services, approved the life and fire safety designs and Ghana Aviation Authority provided approval for the height of the building, since the facility will be along the defined flight path.

Identification of Risks and Impacts:

As required by Environmental Protection Agency (EPA) in Ghana, the Sponsor commissioned a registered environmental consultant to undertake an Environmental Impact Assessment (EIA) for the project. A preliminary environmental report has been submitted to EPA for approval.  The report includes an environmental and social management plan (ESMP) with the main impacts listed as increase in traffic flow along the Otele Avenue, solid waste management for both construction and operation phases, dust and noise from machinery during the construction phase and security and public safety management.  Other studies for the project include (i) Geotechnical report of July 2018, and (ii) Traffic Impact Assessment of August 2018.  As required by EPA, the company will conduct environmental assessment an develop management programs every three years as part of risk assessment. Actions defined in the ESMP will be implemented and monitored during construction and operations.

Organizational capacity and Competency:

The construction of the project will be undertaken by A&C Development under the coordination of a project manager, following the approach implemented in the construction of the existing facilities of the A&C Square. The approach embraces sub-contracting well established firms and having a strong coordination by A&C Development to program the construction and manage procurement of key materials as well as implementation of the ESMP. A&C Development has commissioned an architectural firm and sub-contractors for the structural, mechanical and electrical design and construction of the project. The project will comply with Ghanaian building regulations related to architecture, structural and civil works, access to disabled persons and life and fire and safety.

During operation phase, the facilities will be managed by an external professional property management company Broll Ghana Ltd. Broll is a well-recognized and experienced operator in Europe and Africa. Broll will be responsible for procurement, maintenance, customer service (including tenants) and ensure implementation of environmental, labor, occupational health and life & fire safety management systems which will be part of environmental and social management plan.

Emergency Preparedness and Response:

The building designs has elements of emergency plans incorporated; wide corridors, disabled persons’ ramp and fire hydrant system.  Under the Ghanaian law, the design has already been reviewed for fire safety as part of certification process by Ghana National Fire Service.  The sponsor has also developed an emergency guide including an emergency evacuation plan. A&C Development as ESAP Item # 2 will update the existing plans and develop an emergency preparedness plan and response operational procedures for the project. The plan shall include a training program for all employees and tenants, in particular for the internal emergency fire marshals, evacuation exercises and semi-annual fire drill programs as per the WBG General EHS Guidelines on emergency preparedness and response.  The procedure should also include mechanisms to inform affected communities.  A&C Development will work with Accra Metropolitan Area emergency response department to ensure that the response is effective.

Monitoring and Review:

The Ghana Environmental Assessment Regulations 1999, LI 1652 requires EPA certification after every three years of a project, in which a new environmental social management plan will be developed and submitted for approval. A&C development will monitor EHS implementation during the construction phase. In addition, the company will develop a Standard Operating Procedure (SOP) for monitoring of environmental health and safety (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 with which these will be monitored. The results will be presented to the management and form part of the annual monitoring report.

 Human Resources Policies, Procedures and Terms of Employment:

The new development will employ approximately 200 people mostly during the construction phase and Broll (the property management company) will maintain the current structure with 8 permanent staff assigned to manage the current operations of A&C Square. Activities such as housekeeping, security, gardening and maintenance are outsourced.

Both A&C Development and Broll have extensive and well detailed Human Resources (HR) policies. Topics covered in the HR policies include non-discrimination and equal opportunity, provisions for no child labor and no forced labor, avoidance of harassment at work and grievance mechanisms. Broll’s human resources policies are in accordance with South African labor legislation, while the A&C HR policy is aligned to Ghana labor laws which are consistent with the requirements of this Performance Standard.

Working conditions are communicated through formal contracts and the employee handbook that is handed out to all employees upon taking up of employment. The employee handbook includes provisions on schedules, leave benefits (vacation, sick and maternity leave), access to medical care, salary increases, disciplinary procedures, and the company’s approach to training and development of employees.

Existing services contracts with maintenance providers and the management company requires compliance with Ghanaian labor laws in its contracts. A&C Development will include clauses in the contracts with construction contractors for the new development and key subcontractors directly engaged with A&C Square to manage labor, environmental, and occupational health and safety issues in a professional manner compliant with Ghanaian law and IFC’s Performance Standards requirements.

Workers Organizations and Grievance Mechanism:

The Ghana labor law provides freedom of workers to join workers’ associations and the company does not discourage workers to form such organizations; nevertheless, as at appraisal, none of A&C Development employees were unionised. The management team of A&C Development confirmed that they would not prevent employees to organize or participate in workers’ organizations. Employees’ grievances are managed through the direct supervisor who addresses the concern and might refer the grievance within 48 hours to the executive chairman. In addition, the executive chairman has open door policy, so any employee can address concerns directly to him.

Occupational Health and Safety:

A&C Development utilizes an Occupational Health and Safety (OHS) manual developed by the property manager, Broll.  The manual has procedures and systems for checking compliance and is in line with Occupational Safety and Health Policy for Ghana (draft 2004), aligned to ILO Convections 115 and 161. However, during the construction phase, A&C Development will formalize the OHS requirements to sub-contractors by including OHS clauses in the contracts and by implementing safety training and inspections. A formal safety plan will be submitted to IFC before construction starts and it will be implemented during the construction phase (ESAP Item #3). As part of the implementation of the E&S Management System A&C Development will address OHS elements during operations including management of electrical hazards, falls and trips and safety during maintenance operations.

 Resource Efficiency

Energy: The design of the project prioritizes the use of natural light, natural ventilation and the use of solar energy.  A hybrid system is designed for the facility with solar photovoltaic system as the main source, with a back-up system from the national grid and a small standby diesel generator.

Greenhouse Gas Emissions:

Total annual diesel consumption for 2018 for A&C Square was approximately 79,350 liters, which amounts to emissions of about 218 tonnes CO2 equivalent per annum. Energy usage of the current mall is 247 kWh/m². which compares favorably with global benchmarks for office and retail facilities, which range between 200 and 300 kWh/m². A&C Corner’s GHG emissions will be relatively insignificant and associated almost entirely with fuel consumption by a standby diesel generator given that the facility will be on solar energy. The size of the generator will be below the threshold at which IFC or local regulators require emissions monitoring.

Water: Water for the facility will be sourced from Ghana water as the main supply.  Ghana water has a water treatment plant. The project design includes (i) an underground water storage tank which will be serviced by bowsers when necessary, (ii) use of dual flush systems for the toilets, (iii) use of storm water to flush toilets and for irrigation of the gardens.

Pollution Prevention:

A waste management plan for both the construction and operation phases of the project has been developed.

Effluent Management: Effluents from the new project will be limited to domestic effluents from common areas and offices’ sanitary facilities.  The project plans to install a two-stage septic tank system with sufficient capacity and the sewerage will be disposed of via the Accra sewerage works which are operated by the ACA Metro Sewerage Unit, which will be in compliance with Ghana’s national waste water requirements. The project design includes grease traps for the food court/restaurants area.

Solid Waste Management. The main solid wastes will include paper and cardboards, food waste, and plastic bottles.  The design includes a central waste collection area which is enclosed and ventilated to avoid generation of odors and proliferation of pests. Waste will be collected daily and disposed of at the municipal waste disposal site. Recyclable waste will be made available to recycling contractors depending on demand for these materials.  Solid waste during construction operations especially debris will be collected in dedicated containers and will be disposed through an authorized vendor.

Pesticides: As require by national laws, A&C corner will be fumigated periodically.  A&C Development will ensure the chemicals are approved by WHO and are neither from the restricted category 1a or 1b, fumigation is carried by designated personnel who are properly trained, use correct equipment, and can handle, store, apply, and dispose of these products properly

 Life and Fire Safety:

A&C Development is following Ghana National Fire Service Regulations on Fire Precaution (Premises) regulations of 2003 LI 1724 regarding life and fire safety (L&FS) design and installations for the proposed facilities. The company commissioned a local expert with international L&FS standards to review the design for A&C Corner facility. The designs are in compliance with the requirements of the L&FS section of the WBG General EHS Guidelines and have been approved in principle pending fire installation proposal by Ghana National Fire Services.  After construction, A&C Development will ESAP Item # 4 hire an expert with international L&FS standards to verify that the L&FS systems are installed in accordance to the L&FS section of the WBG General EHS Guidelines provide the certification, affirming that the L&FS systems were installed as designed 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 Ghana 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.

Traffic management:

The sponsor has commissioned a traffic impact assessment as part of the project approval process.  The assessment identified potential impacts on immediate access roads (Oteke Avenue) and the project access points.  The developed traffic management plan mitigation measure includes construction of a slip road on Otele Avenue to create quick access to the development, separate IN and OUT driveways, creation of pedestrian walkways and movement of construction equipment and materials during off peak hours. The proposed development will have 107 parking spaces 16 surface car park at the frontage of the development and 91 at the basement.

Security Personnel:

A&C Development will employ unarmed security guards from a vetted third-party contractor, for access control and emergency response purposes in the proposed facility.  The company will include clauses in the contract to ensure the hiring process, rules of conduct, training and equipping are within the requirements of Performance Standard 4 (paragraphs 12, 13 & 14). A&C Development will also develop a Standard Operating Procedure (SOP) for monitoring of security personnel.

  External Communications and Grievance Mechanisms:

During the development of the Preliminary Environmental Report, the consultant engaged with key stakeholders like Environmental Protection Agency, Ayawaso West Municipal Assembly, Ghana national Fire Services who have been informed on the proposed development.  However, A&C Development will develop a stakeholder engagement plan (SEP) as ESAP Item # 5 for both construction and operation phases and will include identification of stakeholders; development of communication channels and a community grievance mechanism and publicize its availability.

 Contact Person: Andrew Asamoah

Company Name: A&C Development Company Limited,

Address: A&C Square 14 Jungle Road, Christian Center, East Legon, Accra.

P.O. Box 17506Accra, Ghana

Phone: 0244644810

E-mail: asamoaha@aandcdevelopment.com

A&C Development will make adequate public disclosure of this transaction in the Ghanaian business and trade press.