PS6-PS8 are not applicable to the project.  SGH Cairo is an existing facility that is to be acquired by Humania.  Humania’s proposed greenfield developments in Cairo, Alexandria and Casablanca will be built on land that has been subject to human occupation and commercial development for generations.  As such, no conversion of natural/critical habitat will result from the development of these greenfield projects. Nor have indigenous peoples been identified in relation to any of the greenfield sites.  Humania will include a Chance Finds Procedure in its ESMS that is consistent with the strict policies and procedures of both the Egyptian and Moroccan governments related to the protection of antiquities.

 Environmental and Social Management System (ESMS):  Humania currently does not have ESMS at the platform level. EHS polices, objectives and procedures are incorporated at the asset level for operations (e.g. SGH Cairo) and during construction (e.g. SGH Alexandria hospital). An overarching function with cross platform strategy and policies will be appointed at platform level once Humania Holding Company is incorporated with centralized functions (ESAP1). As per ESAP 1, Humania shall develop and implement an environmental and social management system at platform level to cover: i) E&S due diligence for acquisitions; ii) management plans for waste and effluents iii) identification of impacts, including land acquisition, biodiversity and chance finds, for greenfield projects and iv) EHS management plans and procedures for the new hospitals, inpatient healthcare facilities and outpatient healthcare facilities. This ESMS must be endorsed by senior management and communicated to all levels within its organization and subsidiaries. The Humania organizational structure will include the essential functions EHS, Supply Chain, HR, IT, Finance, Analysis and Reporting that will oversee and coordinate all related activities at each individual hospital SGH Cairo, Casablanca and Alexandria via the respective hospital based operational management and EHS teams.

As for asset level, the EHS plan for SGH Cairo is fully functional and adequately staffed with experienced professionals in quality, resource efficiency, infectious control, occupational and health safety, life and fire safety and security management. Its quality management system, the environmental management system and the occupational health and safety management system have been developed consistent with the current scope of outpatient healthcare services and are regularly monitored by SGH’s Environmental, Health and Safety Committee. The management systems include the following manuals, policies and procedures; i) Health, Safety and Environmental Plan with relevant policies and procedures, ii) Standard Operating Procedures, iii) Fire policy, program including procedures and measures for fire prevention, detection, abatement, fire fighting and emergency measures, fire drills, continuous education, iv) Infection Control Guidelines, and v) a Security Management Plan.

SGH Alexandria construction related activities are managed by the BAB owned related EPC party IHCC, a specialized turn key provider of design and construction for health care facilities. IHCC possess adequate EHS construction related management policies and plans, that incorporate sustainable principles into project delivery. IHCC is certified with ISO 9001:2015, ISO  14001:2015 and ISO 45001:2018. IHCC HSE plan describes requirements for safety and health measures to be implemented by contractor and sub-contractors at the work at Saudi Germen Hospital – Alexandria project during the construction phase of the project. The requirements are applicable to all IHCC employees, workers, sub-contractors and visitors along with temporary workers and daily wedges.

The SGH Cairo currently has ISO 22000 Food Safety Management system and have passed accreditations for Joint Commissioning International Accreditation for hospitals (JCIA), Trust Effective Medicine Optimized Services (TEMOS) (i.e. certification in quality in medical treatment and non-clinical services for international patients) and Canadian Accreditation Qmentum International accreditation requirements. SGH Cairo has officially become the first hospital in Egypt and Africa to receive the Canadian International accreditation with the highest Diamond accreditation level.

Similar approach in development of adequate EHS management system in SGH Alexandria, SGH Medical Tower and Casablanca SGH hospitals is being/will be applied for construction and operational phases.

Identification of Risks and Impacts: SGH Cairo Humania has commissioned Qmentum International to assess the SGH’s leadership, governance, clinical program and services against Accreditation Canada requirement for quality and safety, including emergency and disaster preparedness.

SGH Alexandria hospital is being constructed by IHCC with a prior obtained construction permit, which specifies EHS requirements during construction. The detailed construction related EHS requirements are specified in a separate plan “Health, Safety and Environment Requirements – SGH project Alexandria” drafted by IHCC. 

Construction of new hospital in Zenata, a suburb of Casablanca, will start by Autumn and will be developed on land that has been already acquired and provided by the Moroccan state authorities and according to the Zenata Eco-city Master Plan. The Master Plan was developed following principles of sustainable development integrating socio economic responsibilities, management of environmental impact and with stakeholders’ engagement. All related infrastructure and utility for the SGH hospital will be provided by the Zenata Eco-city Management.  As per (ESAP2) SGH Casablanca will complete the ESIA in accordance with good international practices and in line with the requirements of IFC Performance Standards. The ESIA will include the Construction Environmental Health and Safety Plan (CEHSP).

As per ESAP 1 and the EHS capacity that will be established, Humania will be able to assess construction and operational EHS risks for its future expansions in Casablanca, Medical Tower Cairo and any future developments in accordance with good international practices and IFC Performance Standards.

For operations of the existing and to-be-operational facilities, Humania is/will use good practice established by its Cairo SGH hospital and its EHS management systems, procedures, plans, SOPs and manuals. As part of the regular reaccreditation / certification in JCI, ISO 22000, and others and its internal and external monitoring the SGH Cairo is identifying corrective measures, developing improvements plans and disseminating throughout the facilities. The same approach will be utilized in other facilities once they become operational.

Management Programs: The management programs in the Cairo SGH healthcare facility identifies annual quality improvement plans from their quality management system gap analysis reports, environmental safety and quality improvement plans. The annual quality improvement plan contains objectives and programs that provide a framework for a systematic, integrated and organization-wide approach to monitor, assess and improve patient care, health and safety, waste management and organizational performance at the healthcare facilities. 

Management programs as related to construction phase in SGH Alexandria are determined by IHCC own ESMS, which we found adequate. 

Organizational Capacity and Competency: The EHS function at the Humania platform level is yet to be established, it will have full time EHS manager (ESAP 3) appointed at a corporate level with the experience required to assess and manage the EHS risks and impacts of its operations including construction related activities performed by EPC.  The EHS manager will be fully qualified to be able to perform complex corporate EHS function, be responsible for enhancing and implementing at the corporate level the ESMS and ensure that the new hospitals and acquired healthcare facilities develop and implement their site specific ESMS in line with corporate EHS policy requirements, conduct monitoring of EHS performance and report to Humania management team on E&S performance and challenges.

Emergency Preparedness and Response: The SGH hospital has a comprehensive Disaster Preparedness Plan and Evacuation Plan with policies and procedures that cover emergency response and protect life of staff and patients in case of fire, smoke, flooding or potential exposure to hazardous material, terrorist attacks, and structural damages. DPP deals with all eventualities related to various emergencies. The plan represents a comprehensive engineering, architectural and administrative controls such as proper design, selection of  the location of the structure, architectural segregation, selection of adequate material and its functionality, utility systems, ventilation, electric power system, communication, water supply systems, medical gas system, fire suppression system, emergency exit, medical equipment, safety and security of people, equipment and supplies, control of food and waste, decontamination practices and prescribes procedures and assigns responsibility for each responsible staff. The DPP also prescribes means and procedures how to inform local communities for emergencies and disasters. Separate plans exist for emergencies like HAZMAT spill i.e. chemical spill / leakage “Code Orange” and in case of mass casualty incidents like severe traffic incidents, explosions, fires, etc that would overtake the routine capabilities of Emergency Departments and other ancillary services e.g. Diagnostic Imaging.

As part of ESAP 1, Humania will develop and implement a corporate emergency preparedness and response plan including all probable emergency scenarios (fire, earthquake, terror attack, civil unrest, violent patient/family, etc) in line with IFC PS1 requirements which will be adopted by the new hospitals and the healthcare facilities.

Monitoring and Review: SGH Cairo carries out internal quality assurance audits against its Standard Operating Procedures (SOPs) and legislative requirements. Results of these audits are assessed by the Quality Assurance department and reported to the CEO of the hospital, who is ultimately responsible for correcting any performance issues. As part of the regular reaccreditation / certification in JCI, ISO 22000, and others international certification programs and its internal and external monitoring the SGH Cairo is identifying corrective measures, developing improvements plans and disseminating throughout the facilities. These corrective actions include for example improvement in waste management systems to meet best practice standards; ensuring best practice in hand hygiene and infection control at all healthcare facilities; fire safety, energy savings, water usage and conservation; reduction of losses at the pharmacies and laboratory and improvement in internal and external communication. The same approach will be utilized in other facilities once they become operational. As part of the corporate ESMS, Humania will formalize the platform level monitoring and reporting so that they could benchmark performance and share experience across hospitals.

 Human Resources Policies, Procedures and Terms of Employment: As a recently formed platform, at appraisal, Humania had 5 staff. The proposed acquisition of SGH Cairo healthcare facilities is likely to increase the numbers to approximately 1,400 including 250 doctors and approx. 400 nursing and support nursing staff. The gender split of staff is 60% female including 26% female doctors and more than 90% female in nursing. An additional 50 staff members are outsourced mainly in Cafeteria and external security. Retrenchment is not expected as part of the acquisition of SGH Cairo but if that occurs Humania will follow related requirements as per IFC PS2.

HR Policy of SGH Cairo is largely consistent with IFC PS2. HR policy, Code of Ethical Conduct Policy, Ethical Framework and other relevant information packages are delivered to staff upon hiring and important terms are incorporated in employment contracts. The HR policy and procedures specifies the terms of employment and employee 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.). HR policy prohibits use of child labor and/or forced labor in its operations and follows applicable labor law in Egypt whereby the minimum working age is 18 years old. Salary/compensation is defined and applied by type and seniority of job regardless of nationality, age or gender of the staff members. To ensure consistency across all current and future operations, Humania will develop a corporate Human Resources policy and procedures manual in compliance with IFC PS 2 (ESAP 4). The company will ensure that the HR policies and procedures manual are adopted by the new hospitals and the targeted healthcare acquisitions.

Workers Organizations: As per the Egyptian Labor Law, organization of the workforce into unions and professional syndicates is allowed. Both are organized on country level whereby employees can start a chapter of the union inside a facility after total number of staffs exceeding a certain size. All professional workers in medical sector join professional syndicates directly in a personal capacity. While the SGH’s HR policy and labor contracts refers to the national relevant law which allows workers to join workers’ organization the HR policy does not specifically state the employees right to form and join workers’ organizations of their choosing without any interference or employment consequences and to bargain collectively with the employer. Humania has agreed to amend SGH’s HR policy to include an additional clause stating that SGH Cairo and Humania in general does not prohibit or bar such right from all staff members (ESAP 4).

Workers Grievance Mechanism:  Workers grievance mechanism in SGH is formalized through a work of the Grievance/Appeal committee which functions independently of the HR committee. Humania will ensure that the grievance mechanism allows for anonymous complaints to be raised and addressed. The mechanism shall not impede access to other judicial or administrative remedies that might be available under the law. The update grievance mechanism will be made available to IFC for review as per ESAP 4.

Occupational Health and Safety: Occupational Health and Safety (OHS) program is part of the Cairo SGH’s EHS Plan.  It includes safety of biological hazards (e.g. nosocomial infections, needle stick injuries), practices for handling hazardous drugs (e.g. chemotherapeutic drugs), radiation protection, preventive medicine, workplace monitoring and medical examination of employees. The SGH Cairo conducts periodic EHS / OHS assessment of its current operations as related to its entire operations including (i) civil works, electromechanically, civil defense / emergency preparedness and response, fire and safety, (ii) its department units like ER, OR, CCU, Laboratory, hemodialysis, laundry, ICU, ETC and (iii) functional units/activities like infectious control. As part of the annual HSE training plan a number of trainings in managing fire and general hazard, hazardous material, emergency situation and sustainability are conducted every month. Also, there are periodic audits and checks covering all hospital premises and are followed by non-conformity report (NCR) assigned by top management where findings and recommended corrective actions and further preventive measures are shared regularly with concerned departments. Personal protective equipment is provided to staff appropriate for the work they do (for example in relation to exposure to infectious diseases, or the use of radioactive materials). This is also reviewed, and replacements are provided regularly or on as-needed basis. At the Oncology units, as a preventive measure to manage radiation risk to works and a risk from oncology drugs (high concentrations), a detailed policy is developed and followed in line with local atomic energy authority directives along with tracing of exposure levels / allowance limits and ongoing follow up. SGH Cairo has in place the Occurrence Variance Report policy that describes the process for OHS and EHS incident / accident reporting i.e. near miss, incidents (adverse event), a sentinel event (serious injury or deaths), critical incidents and non-critical incidents in all the hospitals operational units.

For any reconstruction / refurbishment work that SGH Cairo may conduct in its current premises it has developed a policy covering the dealing with demolition, construction or renovation in terms of infection control as well as environmental & safety precautions to ensure that the impact of construction is not affecting the patients inside the hospital and to minimize exposure of high-risk patients, visitors, staff, facilities, and environment with infectious agents during periods of maintenance, remodeling, renovation, demolition, or construction.

For the construction of SGH Alexandria hospital, a detailed contractual obligation is developed between the owner and the EPC contractor for oversight and applying financial penalties in case of OHS deviations or non-compliance of site works. The estimated number of EPC workers including sub-contractors during the construction phase of the hospital project will reach around 750 workers while during the site visit less than 200 works were onsite. So far, no fatalities occurred, however 2 near-miss incidents were reported/recorded since project commencement to date and adequate corrective measure has been taken.

During the visit of the construction site few non-compliances were observe namely related to arrangement for the above-the-round fuel tank (10,000 liters of fuel), which is mounted on concrete support walls without the containment bund to prevent soil pollution in case of spill. In addition, there is no facility for refueling and signs of soil pollution by fuel is observed adjacent to the tank where the refueling is conducted for the construction machinery. Housekeeping at the site should be improved, trip hazard adequately reduced and adequate protection measures should be in place for now open electric power switchgear panels. Humania and its EPC will address these shortcomings as per ESAP 5.

For construction of the new hospital in Casablanca Humania will commission a contractor and will support the contractor’s efforts to develop and implement the CEHSP (ESAP 2).  The CEHSP will include, environmental and social tasks, protection of workers from injury, workers training, mechanism for documenting and reporting of occupational injuries, illnesses and fatalities; provision of safe and healthy work environment to contracted workers. Humania will also ensure that the contractor does not hire child labor.

Workers engaged by third parties: The company will ensure that third-party workers for the new hospital and any acquired facilities will observe the corporate HR policies and procedures including health, safety and environmental policy and the workers’ grievance mechanism by incorporating these requirements in contractual agreements with the third-party employers. Construction workers will be engaged during the construction of the new hospital as described in the previous section.

 The project will be developed following IFC’s EDGE (Excellence in Design for Greater Efficiencies) criteria, a green building standard and a certification system.

Resource Efficiency: The SGH hospital has fully dedicated specialists in charge of quality and resource management including energy efficiency. To reduce energy consumption, SGH is planning to change all normal lighting bulbs to LED bulbs. They have installed power saving electric panels and managed to reduce electricity bills between October 2018 and Feb 2019 by 36% (panels were installed to 3 transformers out of 5 and the remaining 2 will be installed during Q2 of 2019). To reduce water consumption, SGH started to use faucets with photo cells (in kitchen); the same will be applied all over the hospital along with a water regulator to be installed on the faucets to reduce the consumption of water.

According to the measurement Jan 2018 to Jan 2019, the existing usage of electricity is 250 kWh/m2/year for the SGH hospital. The existing usage of water is 0.8 m3/patient/day (calculation done for 300 bed). Hospital is equipped with water heaters (2 water heaters with capacity 1000 liters each). All HVAC system is monitored and controlled through BMS system (building management system), a computer-based control system installed in buildings that controls and monitors the building's mechanical and electrical equipment such as ventilation, lighting, power systems, fire systems, and security systems even the F.C.U (a fan coil unit, a heating and/or cooling heat exchanger) in patients’ rooms. Air Conditioning is the biggest consumer of energy, followed by the lightings and hot water production, central sterile service departments.

Water and Wastewater Management:  Water: SGH Cairo Hospital water is coming from the city water authority source and is stored in the underground water tanks (hospital has 2 underground water tanks with capacity 635 m3 each, one for raw water and the other is for treated water).

Other SGH hospitals to be developed will source its potable water for public supply network and use it for purposes of sanitation, cleaning and laundry services. Potable water for patient and staff consumption will be sourced either via on-site water treatment plant or from local bottled water supplies.

Waste Water Management: Wastewater is segregated based on the source. Biological waste (cooking oil) is repackaged in containers and returned to a vendor for recycling. Medical hazardous waste is adequately packaged and returned to an agency authorized by Ministry of Health for proper final handling. Sanitary waste water / grey water (toilets and kitchens) is discharged to the sewer system with below max allowable pollutants load subject to semi – annual testing conducted by SGH. As per EASP 6, SGH Cairo will ensure that the its effluent meets the required load parameters for the receiving public sewage system and design criteria of the central Cairo WWTP. As needed remedial measures should be implemented, including installation of a wastewater treatment plant to achieve compliance with IFC requirements.

For the new greenfield hospital and any future acquisition of hospitals, Humania will ensure that the on-site waste water treatment plants (WWTP), when required, are designed to meet the WBG/IFC’s EHS Guidelines or the local regulations, whichever is more stringent (ESAP 7).  In case these hospitals will have arrangement with the central waste water treatment plants of cities they will be built in, the waste water pollution load at the entry point to the municipal sewage will respect national requirement for discharge of waste water to public sewers.

Hazardous Materials Management:  All hazardous materials entering the SGH Cairo premises are subject to product evaluation form signed by EHS and infection control department and MSDS list made available. Hospital departments like Main storage, CSSD (the central sterile services department), the laboratory demonstrate list of available HAZMAT used within the department according to MSDS and labelled with NFPA (National Fire protection Association) signage and monitored by the SGH Safety Department. The process is managed under the HAZMAT Program for material receipt, storage, handling and disposal. Disposal of such waste is approved by MoEnv / office of environmental affairs and MOH.

Waste / equipment, materials which contain radioactive materials is collected in 3 secondary tanks, stored in a secured premise on site. This is usual practice for the medical facilities that produce radioactive waste as the radiation levels declines over time. Decision for eventual final disposal will be made by an authorized agency licensed by the Egyptian atomic energy authority.

As part of ESAP1 Humania will develop a procedure for chain of custody for handling hazardous and medical waste and a Waste Management Plan at corporate level as part of the ESMS.

Air emissions

The level of emission of generator or diesel pump is less that 3MWth as per the environmental measures. No incineration facilities in the hospital. New hospitals will not have significant air emissions.

 Community Exposure to Disease: As required by host country legislation, Humania, via the existing SGH’s Infection Control program and procedures, is managing community exposure to communicable diseases in accordance with relevant norms and regulations. In addition to the engineering and administrative controls such as proper ventilation systems with independent air handling units for critical care rooms and architectural segregation, the company has documented procedures on various aspects related to infection control including cleaning, hand hygiene, disinfection and sterilization, access control, kitchen, sanitation and food management, etc. The hospital has an infection control specialist as well as a number of other nurses to monitor implementation of the program and procedures.

Life and Fire Safety:  As part of JCI accreditation, a survey was conducted in 2018 for the healthcare facility SGH Cairo; since then, internal audits are undertaken regularly by designated fire marshals in all the facilities in accordance with national legislation.

Fire safety policy and procedures that elaborate actions to be taken in the event of fire, fire detection and prevention, evacuation procedures, roles and responsibilities of the various staff and fire marshals is presented as a set of documents such as Fire management program, Fire control measures, Surgical fires management program Laser Safety Program, No-Smoking policy, Code Red (fire emergency) Mock-Drill, and are reviewed regularly through pro-active measures like physical  inspections for all fire prevention, detection, fire-fighting and structural measures preparations, permit to work, KPIs, preventive maintenance for all fire preparation related systems i.e. SGH Cairo is conducting regular inspections and testing in accordance with  applicable NFPA standards, which includes fire exits, emergency lighting, proper storage, portable fire extinguishers; also, regular checks for all fire alarm & fighting system e.g. sprinklers and standpipe systems, clean agent systems (FM200) and kitchen hood fire protection system (Wet-chem). SGH Cairo facilities undertakes about 27 fire drills over-all hospital premises per year (1 wide drill + 26 departmental drills). Each drill is followed by an assessment of any observed gaps with corrective actions to be sent to concerned department heads and discussed in SGH’s EHS committee, which is held each month as illustrated in annexure.

Humania will comply with local regulations and IFC requirements regarding life and fire safety design and installations in the new greenfield hospital and the healthcare facilities to be acquired. Any new building or those undergoing significant renovation will follow the requirements of the L&FS section of the WBG General EHS Guidelines. Prior to the construction of the new hospital Humania will contract an expert in international L&FS standards to prepare (ESAP 9) a L&FS Master Plan for the project, and upon physical completion of the building, to verify that the systems were installed as designed in accordance to the L&FS section of the WBG General EHS Guidelines, i.e. under (ESAP 10) the L&FS professional will 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 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.

As per ESAP 8 Humania will develop O&M plan for SGH Cairo L&FS systems, including emergency power, that will provide details of the (i) operation, testing of maintenance of the LFS systems; (ii) reliability of electrical system and use of emergency power.

Security Personnel: SGH Cairo hospital is guarded with unarmed security guards from private security agencies. Humania will employ unarmed security guards managed via a third party, for access control and emergency response purposes at the new greenfield hospitals and healthcare facilities. Humania will review the security policy and provide training and monitor the conduct of security personnel.

 Humania will develop a formal Stakeholder Engagement Plan (ESAP 12), which will include identification of all stakeholders; develop communication channels and a grievance mechanism and publicize its availability. The engagement plan will be in place before commencement of the main construction phase for any new development. At corporate and operational level, internal and external customer complaints - received through the media, dropped in suggestion boxes, anonymous or named – will be addressed based on the Complaints and Grievances policies of the healthcare facilities.

  Contact Person: Ahmed El Bakry

Company Name: Humania

Address:  11th floor, 3 Abu El Feda st. Zamalek, 11211 Cairo P. O. Box 41766 – 00100.

Email: md.africa@humaniacap.com

Phone: +202 27369471