The accommodation facilities will be built within a one-kilometer radius of the existing universities hence in urban areas, as either refurbished existing facilities or greenfield developments, with the lands acquired under commercial terms without any involuntary displacement. The facilities are in already modified urban environments and no priority ecosystems or natural/critical habitats are affected or directly threatened. There are no indigenous peoples or cultural artifacts or sites around the facilities.  Hence, no impacts for this project are expected which must be managed in accordance with PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples and PS8: Cultural Heritage.

This is a Category B project, according to IFC’s Policy on Environmental and Social Sustainability (2012). Based on information reviewed during the appraisal, it is expected to have limited adverse environmental and social risks and impacts that are few in number, short-term and site-specific, and can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the sections further below.

The key environmental and social (E&S) issues applicable for this project include: effective implementation of environmental, health and safety (EHS) management plans during construction and operation phases; life and fire safety and emergency response planning; grievance management for both third party workers and communities; and stakeholder engagement

Environmental and Social Assessment and Management Systems:

Eris, through MSAIF, intends to develop student accommodation on properties that are in urban, modified environments, close to Universities, and within suburbs where physical development plans (PDPs) exist. In South Africa, comprehensive environmental and social assessments are undertaken by planning authorities during the physical development plans process. As such, any commercial entity undertaking activities that fall within the scope of these PDPs is only required to develop construction environment, social health and safety plans to manage any environmental or social risks and impacts from their activities and seek approval from the city environment and occupational safety authorities before commencement of such activities. The sponsor has followed this procedure for its developments including for its pioneer student accommodation project and will continue in all their planned developments.

Eris is implementing an environmental and social management system comprising of a group health and safety policy and standard operating procedures (SOPs) covering all key risk areas (viz. labor and working conditions, life and fire safety, occupational health and safety, grievance management, violence and harassment, disaster response, risk management, procurement and medical aid). These SOPs are implemented at the student facility in Pretoria. Eris has also developed internal E&S risk audit and monitoring procedures and schedules that are also being applied. The company will implement similar policies, procedures and management systems at the future PBSA developments under the project.

Policy:

Eris has a group level sustainability policy which commits shareholders, directors and management, to ensure and maintain a safe work environment and mitigate risks to employees and all other stakeholders. The policy is aligned with SA national laws and its scope covers all employees, contractors, clients, suppliers and regulators during their interaction with the company. The management recognizes the centrality of occupational health and safety, and mitigation of impacts to the environment, to the sustainable success of the business. This policy covers all Eris subsidiaries including MSAIF.

Identification of Risks and Impacts:

Selection of land for new development is guided by proximity to universities, access to water, grid electricity, proximity to public transport infrastructure, like train and bus stations and the price. Since the facilities are typically located in already planned urban areas, as described earlier, Eris is not required to conduct ESIAs, but develops comprehensive construction and operation phases EHS plans for approval by the respective city authorities.  For the facility in Pretoria, the principal consultant developed the construction EHS plans, which was submitted to the Pretoria city authorities for approval together with project design documents. Similar will be practiced for the future developments.

Eris has developed a risk management methodology, which includes risk identification, assessment & evaluation, response, reporting and monitoring & review. The company has identified, assigned and trained safety, health and environment (SHE) committees at the accommodation facilities and the head office, primarily for continuous risk identification and monitoring. During construction, a monthly environmental checklist is completed and signed-off for each project site by the project manager and project health and safety manager and is shared with the relevant development manager who review the checklist and coordinate any mitigation actions/improvements that need to be implemented. Eris also undertakes corporate-wide E&S risk assessments annually and the findings are used to revise the SOPs where needed.

Externally, the labor, insurance and occupational safety authorities undertake annual compliance audits as well as random audits on all facilities to appraise compliance with the legal requirements and insurance conditions. The reports are shared with the management team for corrective actions when required.

Management Programs:

For each risk identified across the business, a SOP has been developed and forms the management program. This for instance includes recruitment and remuneration, grievance management, security, communication, harassment and violence, maintenance, fire safety, disaster management, housekeeping, waste management, water and energy efficiency, transport and traffic management. The facility manager and SHE committee are trained on the relevant procedures.  As indicated above, the construction EHS plans are developed by the principal consultants, adopted and implemented by the contractors. Similar site-specific management programs will be developed and implemented at each of the future PBSA developments.

Organizational Capacity and Competency:

The overall responsibility for EHS implementation within Eris group lies with the Occupational Health and Safety Manager, assisted by the Risk and Compliance Manager. For each PBSA site, there is an EHS officer, reporting to the facilities manager, who in turn report to the Operations Director. The EHS officer coordinates the implementation of EHS-related SOPs, EHS training and EHS reporting for each facility. Eris develops and implements an EHS training program for each financial year, applied across the business. The training topics are informed by risk assessments, changes in law, findings of external audits, and company policy timelines.

During construction, the Development Manager have the ultimate EHS responsibility and chairs the weekly and monthly progress meetings, and reviews EHS performance reports from the EHS supervisors and ensures requisite corrective measures agreed upon are implemented in compliance with the construction EHS plans.

Emergency Preparedness and Response:

Eris risk management methodology includes emergencies and operational risks such as fire, bomb threat, medical emergency, natural disasters, strike and riot and armed robbery. The company has drafted a standard emergency evacuation plan for each scenario and includes persons with special needs; visually impaired persons, hearing impaired persons, persons using crutches, canes or walks and persons in wheelchairs. The standard evacuation plan is filed at the pioneer facility, and students are sensitized appropriately during induction and on a regular basis. The facility manager is fully aware of the requirements in the procedures and when they can be applied. Fire drills are conducted at the facilities once a year to test emergency preparedness and response, equipment and personnel capacity. During the fire drills, Eris coordinates with the respective city fire department, and has trained fire marshals, who are also designated evacuation coordinators.

Monitoring and Review:

Eris monitoring and review plan is embedded in the risk management methodology. For new developments and building refurbishments, Eris uses the weekly and monthly meetings, as well as findings from EHS visits by the national OHS manager, the consultants and Development Manager, that are used to appraise effectiveness of the EHS measures in the construction EHS plans, which are updated as required.

During the operational phase, Eris will continue monitoring of 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 EHS KPIs will be linked to and build upon Eris’s existing internal reporting and quality control systems. The KPI results will form part of IFC’s annual monitoring report (AMR).

Human Resources Policies, Procedures and Terms of Employment:

As of September 2020, Eris had 328 employees across all departments, of which 206 are permanent and 122 are from third party contractors providing services like security, housekeeping and maintenance and approximately 54% are women.  The student accommodation is a new department and has three managers. After the project is implemented, Eris’ headcount is expected to reach up to 350, and a 30% increase on third party contractors.

Eris has a human resources (HR) policy that covers all the entities under the group, including MSAIF. The policy is operationalized through an Employee Handbook, which specifies recruitment and selection, equal opportunity, the terms of employment and working conditions and include; employees’ conduct, employment regulations, wages and benefits, disciplinary code, employees’ grievances, occupational safety and health and performance management sexual and other forms of harassment to all employees.

Each employee has a documented contract entailing type of employment, remuneration, employee roles and responsibilities, leave benefits, health and safety rights and responsibilities, study assistance and training. The workers, both direct and contracted, are provided with adequate working spaces and requisite tools to effectively perform their jobs. The duty rosters are clear, reporting lines well understood, and performance indicators are known to the general workers. Workers have signed up to a minimum of 45hrs a week. The company provides medical coverage for all workers and their registered dependents and pays performance-based bonuses. All employees are entitled to annual, sick and maternity leave. All working conditions are in accordance to the South Africa’s Basic Conditions of Employment Act which is aligned in general with the International Labor Organization (ILO) and IFC’s Performance Standard 2 requirements.

Non-discrimination and Equal Opportunity:

Eris has an Employment Equity and Anti-Discrimination policy in compliance with the South Africa’s Constitution and Employment Equity Act. The policy supports the principles of equity and diversity in employment and opposes all forms of unlawful and unfair discrimination on the grounds of color, race, ethnic or national origin, sex, marital status or disability. The policy is aimed at considering race, gender and disability in employment and promotions.

Workers Organization and Grievance Mechanism:

The Labor Relations Act (LRA) provide for employment relationship, for example, employees are entitled to associate freely with Trade Unions.  Eris HR policy is explicit on workers freedom to join workers’ associations, however, only three workers are part of the Trade Unions.

The Employee Handbook provides steps for complaints and reporting as part of the code of conduct.  The formal workers grievance mechanism is supported by an anonymous whistle blowing policy which provides for employees to raise grievances anonymously, without the risk of reprisals, and is in line with to other requirements of IFC’s Performance Standard 2.

Protecting the Workforce:

South Africa’s laws prohibit employment of child labor or forced labor. The company’s employment screening requirements for potential employees include verification of national identity cards, which are only issued to adults. Eris as part of the suppliers’ management plan will also ensure that contractors do not hire child labor and/or forced labor in its operations.

Occupational Health and Safety (OHS):

The OHS related risks in the company’s operations are limited (e.g. working from heights or confined spaces for maintenance; electrical safety etc.). Eris complies with the South Africa Occupational Health and Safety Act (OSHA), 85 of 1993 which ensures employees work in safe and healthy environment and is enforced by the labor department through inspections. The company uses a risk management methodology to identify OHS risks, conduct assessment & evaluation, provide appropriate mitigation measures, report, monitor and review.

During the construction phase, Eris reviews the construction contractors’ OHS management plans to ensure its completeness for: (i) identification of potential hazards to workers, (ii) provision of preventive and protective measures, including training of workers and provision of personal protective equipment; (iii) documentation and reporting of occupational accidents, diseases, and incidents; and (iv) emergency prevention. Eris’s own EHS team also monitors the contractors’ implementation of OHS management plans and provide corrective action plans where necessary.

During operational phase, every worker is sensitized on the health and safety policy, respective procedures and provided with appropriate protective equipment. In addition, Eris provides training to staff on risk identification and reporting, to ensure that risks are identified on time.  Where OHS risks to workers are identified, the company undertakes repairs and maintenance works promptly to prevent any form of escalation. Other OHS trainings provided to workers include; OHS Awareness safety tips, OHS Representative, First aid, Fire and Evacuation, and Hazard Identification and Risk Assessment (HIRA).

Workers Engaged by Third Parties:

During the construction of the Hatfield facility and for new developments, Eris evaluates potential contractors’ compliance with local labor laws (policies and procedures) as a condition for selection. Once selected, the contractors are required to demonstrate that the labor practices (including workers contracts and wages) comply with minimum labor law requirements and all appropriate tools and resources for safe working conditions are provided.

Eris has a SOP to guide on the supervision of short time and ensures workers engaged by third-party contractors have access to a grievance mechanism.

 Resource Efficiency:

Eris is a member of Green Building Council SA. In its policy, Eris is committed to designing all buildings to the IFC’s EDGE certification standard to ensure optimal resource use efficiency, safety and adequate waste minimization. An EDGE expert is working with the company to achieve certification for its pioneer facility.

Energy: Eris relies on grid electricity as the main source of energy for construction and operations. However, back-up generators are installed in the facilities to cover during outages. The facilities are designed to allow for as much natural lighting as possible to reduce electricity consumption. At the Hatfield facility, the company has installed centralized water heating systems to reduce energy consumption, installed automated switch sensors for the electric cookers, automatic light sensors for the bulbs and displayed series of energy saving tips across the facilities.

Water: The company relies on municipal water for consumption at the facilities. Water is provided by the city council and does not require further treatment. Water use is generally for domestic and sanitation purposes. The Hatfield facility has a water storage tank to cater for the needs during main supply shortages. The facilities have taps fitted with sensors to save on water and water-efficient laundry machines. Water use is tracked through the monthly bills and will be collated and reported as part of AMR.

Greenhouse Gas (GHG) Emissions: The student accommodation business does not use significant fuel amounts, and the emissions are largely related to the use of electricity and to the occasional use of the diesel generators and use of company vehicles, including student transport. The greenhouse gas (GHG) emissions from the company’s activities are therefore estimated to be less than 25,000 tCO2eq/annum after the project implementation.

Pollution Prevention:

Solid waste management: Main waste streams from the Hatfield facility and the head office include office waste, food waste, sanitation waste and wastes from repair and maintenance activities. Eris has waste segregation bins at the accommodation facilities and has retained a waste management company to collect and dispose of wastes in designated land fields in line with South Africa’s NEMA: Waste Act 59 of 2008.

Wastewater Management: The wastewaters and effluents from the facilities are related to facility cleaning, sanitation facilities and laundry activities. The Hatfield facility is connected to the municipal sewer system where the wastewaters and effluents are discharged as such a wastewater treatment plant (WWTP) is not required.

During major maintenance activities and new construction works, solid wastes and wastewaters are managed according to the Construction EHS Plans and disposed through the municipalities and in accordance to local requirements.

Hazardous Materials Management: Eris does not store significant quantities of hazardous materials during operations. The company stores chemical cleaning agents and equipment repair materials in small amounts. These materials are handled in line with the housekeeping and maintenance SOP and disposed of by the waste contractor where needed.

During construction or facility refurbishment activities, the nature of works, equipment and processes may involve use of various forms of hazardous materials (including stand-by generators and fuel storages). These are usually handled in line with construction EHS plans.

Pest management and control: Pest control is contracted to third-party contractors and fumigation is done periodically depending on the level of risk.  The contractor uses internationally known brands.  The composition of the brands indicates the chemicals are not WHO recommended classification of pesticides by hazard class 1a or 1b.

 Life and Fire Safety:

Eris hires a Life and Fire Safety (L&FS) consultant for each construction project. During design of new buildings or modification of existing buildings to meet student needs, Eris submits the Building Fire Safety Reports to the City Authorities for approval, alongside other design reports. The pioneer facility at Hatfield therefore comply with the South Africa’s National Building Regulations and Building Standards Act. Students in these facilities are long term users, which overall are familiar with the layout of the building. Each building has at least two exits, fire detection and suppression systems, alarm systems on each floor and each room is fitted with smoke detectors. The facilities also have adequate dedicated fire pumps in fire compartments with safe access; dedicated fire water tanks; clear fire escape methodology and protected fire safety routes; adequate and appropriate occupancy numbers; fire separation double walls in selected areas; fire muster points; and fire safety awareness posters. The students are regularly sensitized on fire risks from coking and general use of electric gadgets. There are trained fire marshals. The L&FS consultant inspects, and test firefighting equipment regularly, as required by law; and conducts fire safety test drills on a regulated basis. No fire emergency incident occurred since commencement of operations.

The current PBSA is along 1118 Park Street in Hartfield and is designed with a slip road to create quick access to the development. The facility is also designed for universal access for persons with disabilities.

Community Safety:

Eris has an incidents and accidents records at Hatfield facility, and no significant systemic trend on safety risks to the students and visitors was noted from the records reviewed. The company also implements sexual harassment, rape, aggressive behavior, suicide prevention and response procedures, primarily to protect the students against these situations. Emerging cases of theft or violence are dealt with by top company management, and mitigative measures include dismissal from the facilities.

Security Personnel:

Eris has outsourced unarmed security personnel at the Hatfield facility for access control and emergency response.  In addition, Eris has installed a comprehensive CCTV system linked to a command center to monitor security threats.  When needed, especially in case of riots or armed theft, the company calls in government security for support. The company has a security SOP that clearly lays out the rights and responsibilities of security staff and the nature of their interaction with the students, visitors and the management.

 Eris engages regularly with the regulatory agencies and communities located around the facilities. These engagements are used to address any views from these communities. At the Hatfield facility, the students have representatives that champion their rights and issues, and these representatives report to the Facility Manager. Since the student accommodation business integrates different stakeholders, including local communities, law enforcement agencies, labor and OHS authorities and the universities, Eris as per ESAP Item #1, will develop and implement a Stakeholder Engagement Plan (SEP).  The SEP will include identification of stakeholders, develop a formal stakeholder engagement strategy that details the various affected and interested stakeholders, and outlines the various levels of engagement with each category of stakeholders and also describe in detail the mechanisms to raise concerns including anonymous channels.

 Contact Person: Barend de Loor

Company Name: Eris Property Group

Address 3 Gwen Lane, Sandton, Johannesburg, 2000, South Africa

Phone: +27 11 775 1000

Email: bdeloor@eris.co.za