The land for the greenfield hospital has been acquired on a 99-year lease from the Rajdhani Unnayan Kartripakkha, the Capital Development Authority of Government of Bangladesh. The site is free of any encumbrances, secured with a boundary wall on all sides and has been in the possession of the Company for the last 5 years. No physical or economic displacement has been caused by the Company’s activities and there is no litigation and/or grievances associated with the land, as reported by the Company; consequently, IFC Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) is not applicable. Further, the selected land is in an urban area and, therefore, the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), is not applicable. There are no known indigenous people and/or cultural heritage within the vicinity of the project, thus PS7 and PS8 is not considered to be applicable at this stage)

This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability. Key E&S risks associated with the project include: the company’s capacity and systems to identify and manage environmental, social, health and safety aspects of its proposed operations in compliance with legal requirements as well as IFC Performance Standards (PSs) and the World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines; assurance of fair, safe and healthy working conditions during both construction and operation; management of wastes (particularly biomedical and hazardous waste), emissions and effluents; life and fire safety (LFS) management for the proposed hospital building in accordance with WBG EHS guidelines; and resource efficiency (water and energy efficiency)

Two of the Group hospitals, the Labaid Cardiac Hospital, and the Labaid Specialized Hospital, are National Accreditation Board for Hospitals & Healthcare Providers (NABH) accredited hospitals and the Labaid diagnostic chain is accredited by Bangladesh Accreditation Board as well as by College of American Pathologists. Labaid is also planning to pursue Joint Commission International Accreditation for the other two hospitals i.e., Labaid Cancer Hospital, Dhaka, and the Labaid Hospital, Chattogram. The greenfield facility at Uttara i.e., the Labaid Cardiac and General Hospital (LCGH), is in an initial stage of planning and aligning with the Group’s overall vision, will pursue relevant quality accreditations within the first two years of operation.

Policy: The Labaid Cardiac and Specialized hospitals have adopted a policy under the CARE Environment (CE) Program. The policy specifies Labaid's commitment to prevent and control environmental risks including accidents and injuries and to ensure the safety for all. As per ESAP#1, the Company will formulate an E&S Policy and E&S Management System (ESMS) based on its existing CARE program, incorporating IFC PS requirements.

Environmental and Social Assessment and Management System: The operational hospitals have not conducted any Environmental Impact Assessment (EIA) Study or developed any Environment Management Plan (EMP). The Group has initiated a process of assessing and monitoring facility level E&S risks/impacts of its operational hospital assets and does undertakes periodic audits through its Quality Assurance (QA) Team. LCH and LSH have obtained Environmental Clearance Certificate (ECC) from the Department of Environment (DOE) – the ECCs are presently under a process of renewal.

The existing systems for E&S management relies on the certified quality management systems (that embed E&S aspects) and national legislation requirements, The existing system will be duly updated as part of ESAP#1 to develop an ESMS for the new hospital, aligned with IFC PS 1 requirement,

As per ESAP#2, the Company will engage with a qualified consultant and commission an Environment and Social Impact Assessment Study (ESIA) for the greenfield hospital in accordance with Bangladesh Environment Conservation Rules (BECR) 2023 and IFC PS1 requirements, prior to seeking permits from the concerned regulators. The greenfield hospital will be required to obtain necessary environmental approvals from the DOE and other E&S approvals as may be applicable, prior to initiating construction works at site. As per ESAP#3, the Company will develop a legal and commitment register to identify and document the applicability of the E&S permits and licenses for the greenfield hospital and have a clear strategy in place to ensure that the permits are received before the initiation of construction works.

Management Programs: Labaid has implemented a Quality Management System at two of its accredited hospitals (LCH and LSH) in line with NABH. As per NABH requirements, relevant policies, operational manuals, procedures, and institutional committees have been developed.  The visited hospitals, however, do not have specific E&S Management Plans and Programs in place to manage and monitor the E&S performance of the facilities. As part of the quality improvement initiative, periodic audits are being undertaken to monitor the performance of the operational facilities by using a select group of key performance indicators (KPIs) as per NABH (which also includes limited E&S indicators).

As per ESAP#2, the greenfield hospital at Uttara will be required to develop specific E&S management and monitoring plans consistent with legal/regulatory and IFC requirements. This will involve developing plans and procedures as applicable to the greenfield hospital project, including management of aspects such as, where applicable: resource utilization, air and noise emissions; effluents and discharges; hazardous materials; biomedical and hazardous wastes; occupational health and safety; contractor E&S management; labour management; transportation management; emergency preparedness and response; climate change; gender; community health and safety; stakeholder engagement and grievance redress procedure along with other aspects, where adverse social and environmental impacts are expected.

Organizational Capacity and Competency: At the Labaid Cardiac and Specialized Hospitals, a Quality Assurance (QA) team is responsible for implementation and monitoring of the Quality Management Programs. There is no dedicated EHS/E&S personnel at the corporate/facility level and EHS/E&S is managed as a shared function between multiple facility management departments such as administration, housekeeping, biomedical engineering, safety and security, operations and maintenance. As per ESAP#4, the Group will assign a corporate level E&S Manager to manage impact mitigation of the greenfield hospital in accordance with national requirements and consistent with IFC’s Performance Standards

Emergency Preparedness and Response: The facilities visited have identified six different emergency scenarios for which colour codes, response team and emergency response plans such as - fire (Code Red), security threat (Code Violet), cardiopulmonary arrest and life-threatening emergencies in hospital (Code blue), disaster or mass casualties (Code Yellow), spillage of hazardous materials (Code Orange) and missing child (Code Pink), have been formulated. The emergency response preparedness includes identification of specific teams for these codes, periodic trainings, reviews, and mock drills. Trainings on fire safety and emergency response are also organized through involvement of Bangladesh Fire Service and Civil Defence Department (BFSCD).

The Group has developed an Operational Manual for Safety Management that covers general safety, fire safety, laboratory safety, electrical safety, radiation safety, natural disasters (earthquakes), spillages of hazardous material / waste, gas leakages, etc. Labaid has also developed a fire safety procedure to specifically deal with fire related emergencies. Fire safety systems are discussed in detail under PS 4 below.

As part of the ESMS development for the greenfield hospital, the Company will develop an Emergency Response Plan (ERP), consistent with IFC PS requirements [ESAP#1]. For the operation and maintenance (O&M) phase, the Company as per ESAP#1, will put in place a process for the management of change in the new hospital, that will ensure that any change will not affect the level of LFS protection as originally designed and aligned with the infection control program of the hospital.

Monitoring & Reporting: The Group monitors indicators which includes occupational, health and safety (OHS) KPIs such as patient falls, needle stick injuries, near-misses, etc. Internal auditing is coordinated by the QA department in the hospitals and the findings are shared with head of departments (HODs).

External auditing is limited to NABH surveillance and recertification audits. NABH undertakes surveillance audits once in 18 months and a recertification audit once in 36 months. Most of the monitoring and review activities (e.g., internal audits, monitoring of KPIs) are currently focused on operations and quality, in line with NABH requirements.

As per the ESAP#2, the Company will develop an E&S monitoring plan for the greenfield hospital as an outcome of the proposed ESIA Study – the plan will specify minimum KPIs/parameters to be monitored, monitoring frequencies, type of monitoring and the definition of thresholds that signal the need for corrective actions.

As of March 2023, the Labaid Cardiac and Specialized hospitals have a total workforce of 1170 permanent employees, of whom 217 are doctors, 398 are nurses, 91 are technicians, 17 are office staff and 447 are support professional involved in patient care, laundry services, kitchen and cafeteria and other support functions; the hospitals have only two temporary workers, who are engaged as interns. In addition, the hospitals contracts 163 workers hired through third party contractors to perform supplementary jobs such as cleaning, pest control and waste management.

Human Resource (HR) Policies and Procedures, Working Conditions and Terms of Employment: Human Resources Policy and Manuals have been developed by the Group for its operational hospitals and diagnostic centres. HR Manual covers policies and procedures on various aspects including recruitment, training and development, employee code of conduct, performance management, employee separation, leave management, etc. In addition, the policy covers key aspects required under PS2 on grievance mechanisms, occupational health and safety, and non-discrimination. The policy is communicated to all employees during their induction and is available across the Group’s Local Area Network (LAN). The HR policy does not cover labour and working conditions for contractors, engaged by the Group. Though contracts require, compliance to Bangladesh labour laws, other PS2 requirements applicable to contractors are not covered in the HR policy.

Freedom of Association: Currently there are no staff unions at any of the Labaid hospitals/diagnostic centres. However, the Group does not restrict formation of employee unions, in line with Bangladesh labour legislation.

Non-discrimination and Equal Opportunity: The company’s HR policy includes equal opportunity among employees, prohibiting discrimination of any nature.

Grievance Mechanism: The Group has a documented grievance handling procedure detailed in the HR Manual and the same is communicated to the employees through induction/LAN. Grievances received are first directed to the head of department (HOD) for redress and then escalated to the HR department and the Grievance Handling Committee (GHC) that exists at the facility level. Provisions for raising grievances anonymously is currently not available at the facilities visited. Further no defined process has been established for contract workers to access the Group’s grievance redress system. In addition, for addressing sexual harassment related complaints, a separate policy (Internal Complaints Policy) has been developed and a specific committee (Internal Complaints Committee) has been formed.

Protecting the Workforce: The Group clearly indicates its commitment in respect of child labour and forced labour in the HR Manual. The Group does not employ anyone below 18 years of age. Based on observations during the appraisal, no instances of child labour or forced or bonded labour were noted.

Occupational, Health and Safety (OHS): The OHS management systems followed at the Group’s accredited hospitals are in line with the NABH requirements. The key OHS concerns covered include falls, needle stick injuries, management of infectious diseases, radiation exposure, spills, etc. and the hospitals have developed a safety manual which describes procedures on risk management and safety aspects.  The Group reports zero fatal accidents in last 3 years.

BAEC guidelines are followed with respect to workers/operators associated with radiology services and the detailed measures for workplace safety for radiation area workers are separately documented in a Radiology Service manual.

Workers engaged by third parties: Third party workers are employed at the Group hospitals mainly for cleaning and pest control. The housekeeping and HR departments monitors compliance of the contractors with respect to labour laws, basis documentary evidence submitted by the contractors. The contracts with these contractors are renewed annually based on their performance and compliance with labour laws as well as Labaid’s own management systems and procedures.

Supply Chain: The Group has developed a manual for supply chain management and has adopted screening mechanisms for selection of vendors as well as developed checklists for conducting periodic supply chain audits.

As per ESAP#5, the Company will update and adopt the Group HR policies and procedures that meet local regulatory requirements and IFC PS2, to extend relevant provisions of PS2 and grievance mechanism to contractors and contract workers and implement procedures to oversee contractor compliance with labour laws and PS2 requirements and to upgrade the grievance mechanism to include provisions for raising grievances anonymously

Resource Efficiency: The Labaid Group does not have a formal program on resource efficiency; however, they have initiated monitoring of energy consumption data of their operational assets and have also adopted energy conservation initiatives e.g., use of solar power for staircase lighting.  

Electricity at Labaid Cardiac and Specialized Hospitals is sourced from the public grid. For back-up, diesel generator (DG) sets, and uninterrupted power supply (UPS) battery back-up systems are installed. Based on data reported by the group, the average annual electricity consumption is estimated to be 10.2 million units whereas the average annual diesel consumption is estimated to be 22,715 litres.

The water requirement is sourced from ground water and the Group has acquired the necessary permit from the Water and Sanitation Authority (WASA) for extracting the ground water. The annual water requirement for the hospitals is reported to be 108,084 KL For the greenfield hospital, the company plans to supply water from ground water after acquiring the WASA approval (as per ESAP#3). The Company will adopt a formal program for improving resource efficiency in the new hospital (as per ESAP#2).

Greenhouse Gases (GHG) Emissions: Based on the electricity and diesel consumption data, the GHG emissions from Labaid’s Cardiac and Specialized Hospitals is estimated to be 6000 tons carbon dioxide emission equivalent per annum.

Air Emissions: Air emissions from Labaid’s Cardiac and Specialty hospitals is limited to the DG sets. As these are only used as back-up, the operating hours are limited. Labaid has obtained necessary approvals from DOE for the installation and operation of the DG Sets.

Wastewater Treatment: The hospitals have installed an Effluent Treatment Plant (ETP) with a capacity of 12,000 L/day for treatment of the wastewater streams from the laboratories, critical care units, operation theatres, etc. However, for areas within the hospitals, dealing with radioactive materials and nuclear medicine, there is no process is in place, to divert and hold the effluents in separate tanks before its transfer to the ETP. The Group has put in place a program for quarterly monitoring of the treated effluent from the ETP to ensure compliance with BECR discharge standards.

Sewage treatment plant (STP) has not been installed at the operating hospitals and currently the sewage is being let out into the municipal drains without any treatment. The Group informed that the design process is currently underway and the STP is likely to become functional in the next 6 months. For the greenfield hospital, as per ESAP#2, the Company will develop and implement mitigation and monitoring plans for appropriately managing project level effluents/discharges, including specific systems to manage the effluents from the radiology and nuclear medicine departments, aligned with BAEC/IFC PS requirements.

Hazardous materials management: Labaid is involved in the storage and handling of hazardous chemicals in the form of acids, alkalis, and organic solvents particularly by laboratory staff/technicians. Chemical spill control and management procedures have been defined as part of the Safety Manual. With respect to the use of radioactive materials in the radiology sections, necessary safeguards have been adopted in accordance with BAEC requirements. For the greenfield hospital, as per ESAP#2, the Company will develop and implement plans for appropriate management of hazardous materials.

Biomedical and other waste management: The visited facilities have developed a bio-medical waste (BMW) management manual, that describes the systems for appropriate sorting, labelling, handling, storage, and disposal of BMW from the hospital facilities and is consistent with the applicable legal requirements. Every facility has a segregated BMW storage area, where the waste is stored in colour coded containers. Segregated BMW is removed from the clinical areas to the BMW storage area, from where it is collected by an external agency for disposal.  The Biomedical Engineering Department of the Group supervises the work of this third-party contractor and ensures proper adherence to requirements under the BMW Manual and the appropriate use of PPEs. The radioactive wastes are managed as per BAEC guidelines while the general waste accumulated at the kitchen and other areas of the hospital, is carried by a separate agency to a municipal disposal site. For the greenfield hospital, as per ESAP#2, the Company will develop and implement plans for appropriately managing biomedical and hazardous wastes, generated from the Project.

Infrastructure and equipment design and safety: The operating hospitals have departments for radiology imaging services and biomedical engineering. All the radiology related infrastructure (civil structures, equipment, and operational staff) and management procedures are regulated by the BAEC. These facilities are approved by, periodically inspected, reviewed, and permitted for operation after BAEC safety codes are implemented.  As per the Group, to date, there have been no incidents/accidents resulting in fatalities or major injuries to the community.

Hazardous Materials Management and Safety: Spillage of hazardous materials has been identified as a specific emergency scenario (Code Orange) and specific measures around emergency preparedness and management have been detailed in the Safety Manual of the operating hospitals.  Same measures will be implemented at the new hospital.

Community Exposure to Disease: The hospitals have an infection control manual aligned with the requirements of NABH, which includes control of nosocomial infections. The Group has put in place engineering and administrative controls such as proper ventilation systems for critical care rooms, including use of HEPA filters, etc. The hospitals also have an infection control committee to monitor implementation of the program and procedures.

Security Personnel: The security personnel deployed at the hospitals do not possess arms. Security personnel are trained to manage the entry/exit gates, vehicular and pedestrian movement, and other areas within the hospital premises. They also form part of the critical emergency code response teams such as fire and security threat.

Life and fire safety (LFS) systems: The hospitals visited were provided with basic LFS infrastructure and systems including smoke detectors, fire exit signage, different types of fire extinguishers, manual call points, fire hoses/reels at every floor, sprinkler systems, emergency lights, centralized fire alarm control panel and public address system. The sprinkler systems are available for all floors of the Cardiac Hospital (except the ground floor), however for the Specialty Hospital, sprinkler systems have been provided only in the facility basements. At the visited facilities, facility the housekeeping practices were observed to be poor - miscellaneous materials (some combustible in nature) were found to be haphazardly stored next to oil/paint storages, gas cylinders, parked vehicles, etc.

The firefighting equipment are subjected to periodic inspection and regular training are provided for all concerned, regarding their use during fire emergencies. Provision of alternative staircase to ensure emergency evacuation in event of a fire is also available at both buildings. The hospitals are compliant with the requirements of BNBC (Bangladesh National Building Code) and Bangladesh Fire Service and Civil Defence Department (BFSCD). Both the hospitals were noted to have valid fire certificates from the BFSCD. Periodic audits as well as annual fire drill are conducted by the BFSCD, within the hospital premises. The fire safety function is under the direct supervision of the General Manager - Safety and Security and is supported by a designated Fire Safety Officer and his team as well as the team of security personnel, (who form a critical part of the critical emergency code response teams.

For the greenfield hospital at Uttara, LFS designs have not been initiated and presently only the floor plans for the new building have been developed. The Company will develop LFS designs for the greenfield hospital to be consistent with an internationally recognized LFS code (e.g., United States National Fire Protection Association (US NFPA) or equivalent), as required under the World Bank Group General EHS Guidelines. As per ESAP#6a, the Company at the design stage, will commission a suitably qualified LFS consultant to review the site-specific architectural brief and confirm that all the LFS-related aspects of design are consistent with an internationally recognized LFS code in addition to ensuring alignment with BNBC/BFSCD requirements. Following construction, as per ESAP#6b, the LFS consultant will inspect the newly constructed building to confirm the building has been constructed in accordance with the agreed design.

The Group considers the neighbourhood communities, statutory authorities, patients, employees, contractors, and suppliers as key stakeholders. Community stakeholders are engaged through corporate social responsibility (CSR) programs. As part of its CSR initiative, the Group arranges for free treatment facilities to the poor and deserving patients. The Group also arranges free 'Friday Clinic' every month outside Dhaka to provide free medical services including free medicines and investigation facilities.

The members of security and administration teams are trained to engage with visitors, patients, and neighbourhood communities. The hospitals maintain feedback boxes at prominent locations within the hospital premises, where any stakeholder can raise or record their concerns. Labaid publishes newsletters and annual report for its stakeholders periodically. For the greenfield hospital, the Company will develop and implement formal stakeholder engagement and grievance redress mechanisms as part of the ESMS (ESAP#1)

In terms of disclosure of E&S information, publication of the ESRS and ESAP will be group’s first disclosure of such information.

Company              Labaid Group

Point of Contact  Mr. Ahmad Dawood

Title                            CEO, Labaid Dhanmondi Hospitals

Telephone Number  +88 02 58610793-8

Email                           info@labaidgroup.com

Mailing Address  House # 01 , Road # 04 , Dhanmondi, Dhaka 1205, Bangladesh

Website              https://labaidgroup.com/