PS5: Land Acquisition and Involuntary Resettlement, is not applicable because the Project is located in already constructed building being owned and occupied by the Company and there was no physical or economic displacement during Project construction. The Project site is located in a well-developed urban area, therefore, impacts related to PS6: Biodiversity and Natural Resource Management, PS7: Indigenous Peoples and PS 8: Cultural Heritage are not expected.

In addition to the above applicable Performance Standards the Project is required to comply with applicable parts of the WBG/IFC General Environmental, Health and Safety (EHS) Guidelines and EHS Guidelines for Health Care Facilities.

This is a Category B Project according to IFC’s Policy on Environmental and Social (“E&S”) Sustainability as the E&S impacts are mostly site specific and localized and can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria and adequately managed through the implementation of site specific Environmental and Social Management Plan.

All civil construction and mechanical, electrical and plumbing (MEP) works of the Project are complete along with other finishing and furnishing jobs required for a hospital. Project has commenced its first phase operations in July 2019.

Specific E&S issues identified include: i) Company’s policy and a plan for developing and monitoring Environmental, Health and Safety and Social (EHS&S) management systems at Project level, ii) Company’s HR policy and procedures and contracts with third-party services providers to comply with IFC PS 2 provisions, iii) E&S due diligence of the contractor’s facility for handling, treatment and disposal of infectious waste, and iv) adequacy of the Life and Fire Safety (LFS) systems at the constructed hospital buildings/facilities in order to comply with the WBG EHS guidelines. 

Land and natural environment:

The Hospital is in the Abdali district in the hearth of Amman city. No additional land acquisition is required for the Project. The Project has been built at the premises owned and occupied by the shareholders and there was no physical or economic displacement during the Project construction period. The Project Sponsor is familiar with the local regulation relating to Project development and have acquired necessary permits for the construction and operation of the hospital from the Jordanian Ministry of Health, municipality and civil defence (e.g. firefighting) departments.

Environmental and Social Assessment:

While completing the Project construction the Company conducted an environmental and social impact assessments (ESIA) of AMC in July 2018, by engaging an independent consultant, in order to comply with the requirement of local environmental regulatory department. The ESIA assessed the risks related to the construction and operational phases of the Project and identified appropriate mitigation measures to redress them. The ESIA identified, analysed and assessed relevant valued environmental components of the Project including public health, occupational health and safety, socioeconomic conditions, water resources, biodiversity, archaeology, and traffic and transportation.

To design and construct the AMC Project, the Company hired services of experienced professional companies. AECOM, a global leading company with a track record of hospitals design, was engaged as lead design and Project management consultants. Arab Towers Contracting Company (ATCCO) and Dar-Al-Omran, leading contractors in the Middle East, were the design and construction companies. The supervision of design, engineering and construction contractors was conducted by Consolidated Consultants Group, a leading engineering company in Jordan with experience in best practice hospital design and management. Universal Hospital Services, an international specialized firm in hospital design and medical equipment was engaged for hospital equipment planning and procurement.

Identification of Risks and Impacts:

Based on the assessment of ESIA study, an Environmental and Social Management Plan (ESMP) was developed for the Project which included mitigation measures against the identified risks and determined the responsibilities of environmental management within the Project. ESMP also included an environmental monitoring plan for implementation by the Project Company and the contractors, with main objective to ensure compliance with specifications, standards and the requirements of the relevant legal authorities. ATCOO, the contractor engaged for design and construction of the Project, developed an occupational health, safety and environment (OHSE) management plan which included hazard identification, risk assessment and management process for the construction phase.

AMC has developed a Business Continuity Plan which describes the steps that need to be taken in event of any situation that may prevent the facility from functioning normally.

The ESMP under the ESIA study required the Company to adopt appropriate methodologies to ensure management of safety and prevention of hazards and accidents for staff and patients by performing, hospital wide and department/unit specific, risk assessment and continuous process of surveillance, data/information collection, evaluation and reporting.

An Infectious Control Plan has been developed to promote safety and reduce the risk of acquiring and transmitting infections among patients, visitors, healthcare workers and supporting staff. The plan identifies the measures to be taken to prevent or minimize the risks and details the training needs for the staff for implementation of the plan.

The Company will develop and implement, as described in ESAP item #1, procedures for conducting environment, health and safety and social risk assessment, as part of the operational phase; specific Environment, Health, Safety (EHS) and Social Management Plans (EHS&S MP) will be developed for each departmental activity based on the risk assessment. The risk assessment would cover but not be limited to, safety of staff/patients/visitors, management of hazardous materials and wastes, emergency preparedness and response, fire safety, safety of medical equipment and utility system, and Project security. Such assessments and plans should be periodically updated (e.g. annually).

HSE policy and Management Programs:

AMC has no formal and documented EHS Policy in place, however, a Code of Conduct Policy has been developed to support the mission, vision and values of the hospital to ensure a positive environment and a culture to optimize patient care and safety. It summarizes legal and ethical minimum standards and practical advice to ensure that the business is conducted ethically and in compliance with all applicable laws, rules and regulations. AMC requires all staff to sign the code of conduct confirming their commitment to adhering to its terms.  Several procedures for addressing environment, occupational health, safety and security related aspects have been documented and are practiced. These procedures have been developed with a commitment to provide a safe and healthy environment to every patient, personnel or visitor who comes within the scope of activities of the hospital. AMC has developed its procedures based on the guidelines of the Jordanian Ministry of Health, standards of Joint Commission International Accreditation (JCIA), and recommendation of Center for Disease Control CDC/WHO. AMC is also in the process of implementation of the Hospital Accreditation Standards issued by the Health Care Accreditation Council (HCAC) of Jordan. AMC plans to be accredited by both local (HCAC) and international (JCIA) healthcare accreditors by 2021; and also plans to acquire OHSAS 18001 certification.

The ESMP under ESIA required the Company to develop and implement mechanism and plan of proper categorization and disposal of domestic and medical waste; have a policy for provision of safe and reliable water supply and sewerage services; have a policy to reduce emissions from heating system; and, adopt traffic management system to maintain smooth traffic flow on the access road around the hospital. As an integral part of the organization-wide strategic plan, AMC has developed a quality and performance improvement plan (Quality Plan) to guide its units/departments to provide state of the art quality and highest standards of care and adopt a cost-effective, efficient, and evidence-based strategies and tools to improve patient outcomes and decrease the safety risks on patients and staff. A key performance indicator (KPI) framework has been developed to ensure that AMC KPIs are based on the priorities set by the quality committee.

The Company will engage a qualified professional to do the EHS&S risk assessment of AMC and formulate an EHS management system specific to the operational phase of the Project. As described in ESAP item #1, the Company will develop an EHS & Social Policy to develop an Environment, Health, Safety (EHS) and Social Management Plan (EHS&S MP) to respond to the management and mitigation actions, identified by the risk assessment process, in accordance with the requirements of IFC Performance Standards, applicable WBG EHS Guidelines and applicable local legislation.

The Company will build its capacity to implement the ESMP as described in ESAP #2.  

Organizational Capacity and Competency:

AMC has engaged two Managers, one for Infection Control and another one for EHS, supported by safety officers and junior staff. These technical positions comply with the Jordanian Ministry of Labour requirements applicable on healthcare facility with less than 200 beds. A Quality Committee has been constituted under the CEO to prioritize, coordinate and oversee quality, patient safety and KPI improvement plans. Infection Control committee is responsible for implementation of Infection Prevention & Control Plan 2019. A Quality, Patient Safety and Experience Directorate (QPSED), headed by a Director, is in place to establish and supervise the organization’s systems and processes in day to day activities relating to performance improvement, accreditation and audits, risks and patient safety. The directorate collects and analyses the data and information and reports to the Quality Committee. Health and Safety Committee, comprising of workers and management representatives, has been constituted as a forum to manage health and safety issues and bring the internal responsibility system into practice. This committee is empowered to: establish procedures for investigating all HSE related incidents; ensure quarterly workplace inspections; document and recommend actions to eliminate hazards and unsafe work practices.

During the Project operational phase, the EHS section is responsible for monitoring of EHS and social performance and implementation of EHS&S management plans/programs.

As described in ESAP item #2, the Company will develop and implement a plan for establishing and capacity building of EHS unit defining organogram, roles and responsibilities, functions, etc. The Company will ensure that the EHS&S manager in charge of the implementation of the EHS&S related policy and procedures has required qualification and experience. The EHS unit will be responsible to implement Project specific EHS&S policy, management plan and procedures developed therein during Project’s operational phase in compliance with the IFC PSs, applicable WBG EHS Guidelines and local legislation.

AMC has developed training modules being mandatory to complete by all staff of renewal of contracts. These include general orientation trainings modules on quality, infection control and safety. Health and Safety committee provides trainings to its members on regulatory requirement and standards, hazard identification and accident/incident investigations. Infection Control Plan also provides for the training of housekeeping staff for waste management, cleaning and disinfection. Staff is trained on accreditation standards and quality control under quality plan. Patient Safety Plans for AMC recommends trainings, monitoring and reporting of international patient safety goals published by JCIA. The QPSED responsibilities includes reporting to senior management on status of performance and objectives.

The Company will develop a Project specific training plan, as part of EHS&S MP, for the EHS team, employees and will extend the scope of trainings to cover the important third-party service providers, such as waste management contractors, etc.

Monitoring and Review:

The EHS management plan, being developed under ESAP item #1 will include detailed procedures for routine EHS inspections, monitoring and internal audits conducted for each ward/section level and third-party external audits for overall hospital. A procedure will also be developed for reporting and review of all audits, monitoring, inspections and performance reports at senior management levels. The Company, through Board of Directors, will be responsible to develop and implement Project specific EHS&S management plans for the operational phase in compliance with the IFC PSs, and local legislation.

Company will submit E&S performance reports to IFC on quarterly basis for first year of operational phase and later on annual basis. 

Under first phase, the Company has engaged about 415 employees (45% females) including 15 expats (96% is local staff). Around 88 female and 58 male nurses are employed in nursing department. Around 82% of the total staff include technicians, supervisors and junior level positions. The hospital will employ around 1,400 employees at full operations. AMC has established an off-site hostel with capacity to accommodate 100 shift staff and nursing staff who come to work from out of city limits.

Human Resource Policies and Procedures:

AMC has a Human Resource (HR) Policies Manual which specify the terms of employment and working conditions at AMC, procedures for recruiting, salary and compensation, leave and overtime, performance based bonuses, and salary adjustments, orientation of new employees, trainings and capacity building.

Current policies although in compliance with local requirements, do not include provisions regarding freedom of association, prohibition of forced and child labor, prevention of sexual harassment, grievance mechanism, mechanism for resolution of collective and individual disputes, or provision of basic services at accommodation provided by the company. In addition, it does not present provisions for third-party staff performing services within the hospital. Therefore, under ESAP item #3, the Company will update the HR manual to be consistent with IFC PS2 to include the described aspects.

HR policy and procedures approved by the HR Committee are communicated to all employees at hiring and are available via intranet/web portal and to managers.

Employees are issued written appointment letters/contracts at the time of joining which mentions essential information related to their rights including, working hours, remuneration, probationary period, notice period, compensation & benefits, code of conduct, etc.

All new employees undergo a general (hospital wide) and a departmental (work unit specific) orientation, which include trainings on health, safety, infection control, security, firefighting, quality related matters, KPIs and performance management process.

AMC’s HR Department is adequately staffed, trained and had all necessary resources to implement the HR management system. A HR Committee, comprising of head of all departments and in charge of training, conducts bi-monthly meetings to review HR strategy, ensure robust HR practices in line with HCAC and JCIA requirements, monitor performance, recommend staffing plans, and ensure that HR policies are in line with AMC business and operational plans.

HR Capacity Building:

HR department support employees to develop skills and abilities that underpin better performance within their specific role/position and their potential for career advancement. Both, the heads of the HR department and the training department assist in the professional development of all employees in a systematic and well-planned manner. Staff training needs are assessed at the end of every year. Through onboarding program, 367 staff have undergone over 3000 days of trainings.

HR trainings are focused, in initial phase, on building foundational capabilities which include onboarding training, basic and advanced life support training by Cardio Pulmonary Resuscitation Center currently being accredited by European CPR Association, specialists-hospitalist trainings to transfer skills, specialized non-clinical trainings in IT, patient experience being strong retention tools. AMC plans to conduct in next phase clinical conferences and lectures, community awareness programs, nursing professional development, develop opportunities for fellowship/residency, etc.

Workers’ Organization:

The Company has no registered labour union for collectively bargaining for both employees or contract workers at AMC, however, does not impede employees/workers from exercising freedom of association and collective bargaining. The management engages with the employees through grievance redressal processes described in the following paragraphs.

Workers’ Grievance Mechanism:

AMC encourages staff and contract workers to contact their managers to communicate any grievance. Senior management discuss all issues in daily meetings with the managers and conduct monthly meetings with supervisors and workers. Head of HR department receives all complaints. Customers feedback forms are shared with patients. 

As per ESAP, the HR manual will include a documented procedure for grievance redressal mechanism and communicated to the employees through intranet/portal and contract agreements, including provisions to submit anonymous grievances. Complaint boxes would be placed at prominent location for receiving written grievances and a registered maintained to record redressal actions and decisions.

Non-Discrimination and Protecting the Workforce:

Company is committed to provide equal opportunities for its employees by assessing all potential candidates according to the AMC’s need and their skills, knowledge, qualifications and capabilities.  Hiring processes is carried out under the Onboarding Policy developed under HR process. The code of conduct prohibits any discrimination on the basis of factors such as age, gender, marital status, race, religion, physical impairment or political opinions.

Occupational Health and Safety:

All staff at AMC is appropriately screened and ensured for fitness to perform the work being engaged for. The new employees, under the pre-employment screening policy and onboarding procedure, complete a pre-employment medical evaluation questionnaire and provide medical clearance form to be completed by a physician on the basis of medical examination. The staff also receive regular screening necessary to ensure their own health and that of the hospital’s patients. The Occupational Health Physician conducts risk assessment regarding recruit’s exposure, and determine the recommended tests, physical exam and /or investigations required based on the policy.

AMC has a policy in place to reduce or eliminate risk of occupational exposure to blood borne pathogens. The policy requires the Health and Safety Manager to establish, maintain and administer risk assessment, written procedures, training, recordkeeping and annual review in due course of implementation. For operating and maintaining safe, clean and healthy food preparation and consumption areas procedures for personal hygiene and workplace cleanliness are in place.

Company will ensure that the AMC has an Occupational Health & Safety Management Program (OHSMP), as part of the overall management system, in place to take actions to maintain a safe and healthy environment and comply with local laws and IFC EHS Guidelines for Healthcare Facilities. The OHSMP would be applicable on entire hospital operations including all facilities, people, contractors, processes and equipment of operation. The program would include a process for identification of workplace hazards including ergonomics.

Considering the severity and exposure of certain job roles, the OHSMP would include a post medical monitoring program for examinations of workers to detect adverse health effects which could possibly be related to workplace exposures. The policy focuses on early detection of symptoms to help plan earlier treatment and prevent additional exposures that could aggravate a potentially serious medical threat to employee and patients. OHSMP would include a procedure to acquire work permits designated senior management for performing jobs involving hot works, radiation & chemical exposure, infection hazards, energy isolation, confine space, pressurised gases, toxic emissions and fumes, etc. 

Since commencement of operations at AMC under first phase no Lost Workdays (LWD) have been reported by the Company.

OHSMP would be develop as part of Project specific EHS&S management plan being developed for the operational phase under ESAP item #1.

Workers Engaged by Third Parties:

The Company engage third party to support routine operations at AMC operations including housekeeping, janitorial services, catering, security, etc. Housekeeping contractor has 100 workers and Catering contractor engaged 32 workers in routine operations.

HR manual would include a policy on third-party contracts and daily wages employment, and part-time employment. As described in ESAP item #4, the Company will ensure that the contractual terms with companies providing outsourced services comply with the Project’s HR guidelines/criteria relating to, but not limited to, minimum wages, working hours, overtime, procedure for termination, grievance mechanism, etc. 

Resource Consumption:

Water Supply: The routine operations of hospital require approximately 120 m3 of water per day and is mainly used for laundry, canteens, cleaning, washing, and in washrooms. AMC acquires water from municipality. Raw water is stored in underground water tank of 1800 m3 capacity.  About 400 m3 of water in the tank is always kept in reserve for firefighting usage. Raw water is treated through filter media and water softening units and stored in two potable water tanks of 50 m3 each. Water for use in dialysis section and central sterilization unit is treated through Reverse Osmosis units. AMC has a policy for drinking water which requires regular monitoring of water quality and establishment of procedures to prevent contamination of drinking water sources. Drinking water quality inspection checklist have been developed.

Energy: Project requires 8.5 MW of electricity per month for hospital operations which is acquired from electricity grid from the city. The Project owns a solar plan, connected to the grid, generating all electricity required by the hospital. Power generators operated on diesel fuel are installed as secondary source and backup power supply. LPG is used in kitchens for cooking. Four LPG/diesel boilers are installed (two 1000 kg/hrs; two 1600 kg/hr capacity) for hot water supply to the hospital facilities.

Pollution Prevention:

Wastewater Treatment: The wastewater generated mainly from canteen, washing, cleaning, laboratory and washrooms discharged, after proper treatment, into municipality sewerage system. AMC has acquired necessary permits from the Greater Amman Municipality for discharge of wastewater into their system. The Project has a wastewater recycling process including segregation of grey water from non-medical floors, cooling condensate and floor washing which is treated through wastewater treatment system of 150 m3 capacity for reuse in irrigation/watering of plantation and green belts. The black wastewater after treatment through septic tanks located in the basement, is lifted through a pumping station for release into the municipal drainage. Treated wastewater is tested by third-party laboratory. 

The Company will ensure that the treated wastewater quality comply with the requirements specified in IFC EHS Guidelines for Healthcare Facilities. The EHS&S Management Plans developed under ESAP #1 will define monitoring and management plan for the wastewater.

Air Emissions: Air emissions sources at the Project include stacks of four fuel (LPG/diesel) operated boilers and secondary power generators. These are small stacks and emissions will be monitored for the emission levels define in IFC EHS General Guidelines.

At all zones of the hospital, the fresh air ducts are of Stainless Steel and have a UV system and filters installed to disinfect and clean the indoor air quality. The EHS&S Management Plans developed under ESAP #1 will define monitoring and management plan for the exhaust emissions.

Solid Waste: AMC operations are expected to produce daily around 200-250 kg of hazardous/hospital waste in first phase besides the general solid waste from wards and other facilities in the hospital and food waste for kitchen operations. The general solid waste and food waste is compressed in a dedicated area inside AMC and transported via city municipality services into waste management collection and treatment area located at Ghabawi.

Hazardous Wastes: Biohazardous/infections wastes from the hospital operations are segregated at source in color coded bags and sharps containers and placed in a refrigerated room for transportation to the disposal site. AMC has a contract with the government approved Medical Waste Centre (MWC) contractor who collects and transports the infectious waste in temperature controlled vehicles to the treatment facility located outside the Amman city. The waste, after crushing, is treated through an autoclave process in a vacuum chamber operated at 142 °C at 6 bar pressure. Autoclave processed waste, being non-infectious, is collected by the municipality service for disposal at the designated solid waste landfill located outside the city. The facility has two autoclave units of 500 tons and 60 tons per month waste processing capacity. The Jordanian Ministry of Health collects sample of autoclaved waste every second week for analysis in their laboratory. MWC contractor has acquired necessary licences from the Jordanian Ministries of Health and Environment for operations of the autoclave facility.

Chemical waste and expired medicines are stored in blue bags and delivered to the chemical/industrial storage site of the Jordanian Ministry of Environment, as per the local regulation. Nuclear medicine related wastes are stored in lab for 10 times more than the require storage time, radiation levels are monitored  and the residual waste is disposed of with chemical waste.

As described in ESAP item #6, the Company will develop an infectious waste disposal procedure confirming that it will comply with the requirements specified under IFC EHS Guidelines for Healthcare Facilities and that all operations such as transportation of hazardous waste, treatment at third-party facility and disposal are properly managed in accordance to best practices.

The Company will conduct an E&S Due Diligence of the third-party facility used for treatment and disposal of hospital waste, including transportation of the hazardous waste, and obtain approval form relevant local authority for utilization of the third-party facility for disposal of hazardous/hospital waste.

Hazardous Materials Management:

Hazardous Materials:  For the boiler operations AMC uses about 30 tons of fuel on monthly basis which is stored in an underground storage tank.  Other hazardous chemicals used in AMC routine operations include scale/corrosion inhibitor, disinfectant, anti-germs, cleaner, etc. A policy on purchasing, safe usage, storage, management, transportation and disposal of chemicals is in place.

As described in the ESAP item #1, Company will develop a consolidated procedure for hazardous materials and waste management that requires maintaining an inventory and identify, handle, use, and dispose of hazardous materials and waste in a manner that protects the employees, patients, visitors and the environment. The procedure would be developed in compliance with the IFC EHS guidelines and the instructions mentioned in the Material Safety Data Sheets (MSDS) of the chemicals being handled and used. Under ESMS, the Company will also develop a Radiation Safety Program to comply with the international regulatory requirements for radiation control and include equipment and waste disposal to ensure safety.

Energy Efficiency, Resource Conservation & GHG Emissions:

The Project design included energy conservation and efficiency enhancement system such as the use of LED lights and compact florescent lights; full control system using DALI and KNX systems to facilitate the control of lighting; using power factor correction (capacitor bank) to reduce the power loss for MDBs and to improve active power; use of variable speed motors in all HVAC systems, and; use of heat recovery system in the AHU.

The Sponsors has installed and operate solar photovoltaic farm/unit of 8 WM capacity at land located about 80 km away from the Amman city. The solar energy is supplied to the local electricity grid. The Sponsor has a power network wheeling arrangement with the government on the electricity acquired for AMC operations from the Amman city electric grid.

AMC is equipped with a Building Management System (BMS) which control and monitor the Heating, Ventilation and Air-Conditioning, Lighting, Utilities, Temperature for the monitored refrigerators. Also, all maintenance activities are monitored/controlled through the “Computerized Maintenance Management System”.

As described under ESAP #1, the Company will develop a resources management plan to monitor and record the consumption patterns and initiate conservation strategies in AMC operations.

GHG Emissions: GHG emissions for the AMC would be mainly from the grid supplied electricity and fuel consumption in boilers and company owned vehicles/ambulances. The total amount of power that the Sponsor’s solar plant produce is 6,800 kWh resulting in savings of approximately 4,380 kgCO2 .  

Based on electricity consumption estimates, the net emissions will be below 25,000 tonnes of CO2-equivalent annually, therefore GHG reporting requirements does not apply to this Project.  

Community Health & Safety:

The AMC Project has been designed by reputable international firm in compliance with internationally acceptable standards such as structural safety and life and fire safety standards. The Sponsor acquired permissions from Greater Amman Municipality for use of building for hospital operations and acquired licence from Jordanian Ministry of Health for operations of hospital and the laboratories. The licencing authorities conduct routine inspection of the AMC premises to observe compliance of the operating conditions.

AMC building design include parking facility for 750 vehicles at three basements. The ingress and egress points are designed to minimize traffic disruption on the adjoining roads in the neighbourhood. 

Life and Fire Safety (L&FS):

AMC has a fire emergency action plan which defines processes to provide a safe environment protecting patients, visitors, staff and property from fire and smoke. The Project has designed and installed a firefighting system which consists of prevention, early detection, suppression, abatement, and safe exit from the facility in response to fires and non-fire emergencies.

AMC has a system of maintaining 400 m3 of reserved water in the 1800 m3 capacity of raw water tank, two 1500 gpm pumps for maintaining pressure at 21 bars, fire suppression system and facilities include sprinkler system (at sensitive locations), hose valves connected to internal standpipe system, portable fire extinguishers, automatic smoke detection and alarm installed at sensitive locations and Project has emergency voice alarm communication system. Car parking area is fitted with carbon monoxide auto detectors to operate the exhaust system at levels exceeding 20 ppm. Project has two separate ducts each for pumping fresh air and smoke exhaust in a designated zone of the hospital building. Hospital building has refuge areas at every 6th floor having fire rated doors for 3 hours of holding time.

All firefighting, detection, suppression and alarm units are connected to the centralized monitoring and control room. The pressure in the pipes, operations of the pumps, water levels in tanks are monitored regularly at the control room. Fire system has provision of starting manually or through automatic detection system.

Sponsor acquired permission to operate the hospital form the Civil Defence of Amman after their review of the installed life and fire safety measures at AMC building. AMC conducted first firefighting drill in June 2019.

The EHS&S Management System would include a plan for maintenance, operations, firefighting trainings, drills and inspections.  As s described in ESAP item #6, the company will engage a suitably qualified Life and Fire Safety professional acceptable to IFC to conduct a review of the L&FS systems to certify that the installation and operation of these systems are in compliance with the requirements of the section 3.3. of the WBG General EHS Guidelines, as needed a corrective action plan will be agreed and implemented.

Disaster Management:

The Company will develop, as part of EHS&S Management System, an Emergency Response Plan to document procedures to respond to natural and manmade disasters/emergencies in a manner that protects health and safety of its patients, visitors, staff and community around. The plan would provide a structure, with roles and responsibilities, for disaster/emergency response, identify resources needed, and reviewed on annual basis or as needed as result of drills/ real emergencies.

Security Management:

The security management at the Project includes controlling access at the gates and entrances of the hospital premises and keeping premises under CCTV surveillance 24/7 by security personnel. AMC has a full time Security Manager and 4 security personnel, as staff, placed in the CCTV control and monitoring centre, Company has also engaged a private company, Scorpion Security, who provide 24 guards (including 3 female guards) for placement at all entrances points and car parking area in three shifts. Screening of the security guards at hiring is conducted at government level, being mandatory, and at AMC level.

The Company will develop a Security Management Plan (SMP), as described in ESAP item #7, shall perform a Security Risk Assessment (SRA) with a qualified international security risks firm and will update the Security Management Plan (SMP) as per the IFC Performance Standard and aligned with the Voluntary Principles on Security and Human Rights (http://www.voluntaryprinciples.org).

The Company has engaged the key stakeholders at various stages of the Project. Community engagements are documented as part of the Environmental Impact Assessment conducted by the consultant Al-Rawabi Environment & Energy Consultancies (REEC) in July 2018.  AMC conducted consultations with the Government department including the Jordanian Ministries of Health, Environment and Labor, Greater Amman Municipality, Civil Defence, etc. through their CMO and Director of HR Department. Private Hospital Association were also consulted through the Marketing Manager and neighbouring hospitals were consulted for collaboration and transfer, etc.