PS 5: Land Acquisition and Involuntary Resettlement is not considered applicable, as the accommodation facilities sites are built in urban areas or refurbished existing facilities, that are acquired under commercial terms without involuntary displacement. PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not triggered since 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 PS7: Indigenous Peoples and PS8: Cultural Heritage are not triggered by the company operations.

 This is a Category B project, according to IFC’s Environmental and Social Sustainability Policy. 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 identified include; i) effective management of contractor environmental, health and safety (EHS) performance during refurbishment of acquired properties; and (ii) stakeholder engagement.

 Environmental and Social Assessment and Management System:

Respublica develops new properties or acquires and refurbishes existing properties to meet student accommodation needs. The company’s properties are in urban, modified environments, close to Universities, and within suburbs where physical development plans (PDPs) exist. As a norm in South Africa, comprehensive environmental and social assessments are undertaken by planning authorities during the drawing of physical development plans (PDPs). Any commercial entity undertaking activities that fall within the scope of these PDPs is typically then 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. Respublica has followed this process for all existing properties. For the selection of new projects, the company conducts feasibility studies on preferred locations and once a decision is made, the Development Director engages consultants to design the facility as required. These final designs are presented to Respublica management for approval. Once approved, the Development Director submits the designs to the City Authorities for approval and permits issuance. The Development Director, working with the design consultant (now principal consultant for the approve development) leads the evaluation and selection contractors for the actual works. The principal consultant directly supervises the contractor for the entire duration of project works, and reports to the Development Director.

The company is currently planning refurbishment works to increase accommodation capacity at Yale Village (phase 2 and phase 3) and Paton House and submitted their refurbishment and development design plans to the City authorities for review and approval, with all the necessary approvals having being secured. Even though the company has a select number of routine consultants and contractors they always work with in their projects, selection procedures are not documented to standardize this process. Respublica will develop a consultant and contractor selection procedures that set minimum requirements on EHS Policies, staffing and supervision capacity, labor policies. These requirements will be aligned to the country’s labor and EHS laws, and IFC PS 1 and 2 (ESAP 1). Before commencement of refurbishment work at Yale village, Respublica develops the EHS (through its appointed H&S Representative) issues the spec to the Contractor for compliance. This specification will be provided to IFC for each project. The company will also ensure that a competent EHS Supervisor is engaged as part of the principal consultant’s team to oversee the implementation of the Construction EHS Plan. This will be the standard practice for every site where material refurbishment and/or new construction are required, and Respublica will share the construction EHS Plans with IFC in every project.

Respublica is implementing an environmental and social management system comprising a corporate health and safety policy and standard operating procedures (SOPs) covering all key risk areas (labor and working conditions, life and fire safety, occupational safety and health, grievance management, violence and harassment, disaster response, communication, procurement and medical aid). These SOPs are implemented at each facility. The company also has developed internal E&S risk audit and monitoring procedures and schedules that apply to each facility.

Policy:

In the Respublica Health and Safety Policy, the management commits to ensure and maintain a safe work environment and mitigate risks to employees and all other stakeholders. The Policy scope covers all employees, contractors, clients, suppliers and regulators during their interaction with the company. The management recognizes the centrality of occupational safety and health, creation of a healthy social network for all students and workers, and mitigation of impacts to the environment, to the sustainable success of the business.

Identification of Risks and Impacts:

During feasibility studies on potential new sites or on existing facilities targeted for acquisition and refurbishment, the primary factor is the proximity to the universities. Other main factors include access to water, grid power, roads, safety of the students and costs. These factors are evaluated on a case by case basis, and no minimum standards are documented for these. Since the facilities are typically located in already planned urban areas, Respublica is required to develop comprehensive construction and operation EHS Plans for approval by the City authorities. The principal consultants develop these Construction EHS Plans and includes them in the project design documents submitted to the City authorities for approval.

The company has identified, assigned and trained safety, health and environment (SHE) teams at each accommodation facility and at the head office, primarily for continuous risk identification and monitoring. These teams comprise trained employees that undertake routine risk assessments and submit findings to Residence Managers. The site residence management teams report on all business operations, including EHS on a regular basis to the Corporate Facilities Manager, and write monthly reports, including EHS risks and impacts relating to the Operations Director for review and support where necessary. Respublica 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 selected facilities to appraise compliance with the legal requirements and insurance conditions. The reports are shared with the management team for action.

Respublica has a ResLife program, developed by the company to promote student wellbeing in the design and running of the accommodation facilities. The key idea of this program is to integrate students’ learning and living environment, as not to let them function separately. ResLife membership consists of both students and workers, and focuses on student orientation, grievance management, promotion of safe practices on mutual respect, mental and physical health and wellbeing, awareness and actions against gender-based violence, student security, proper use of the facilities, promotion of sports and social educational activities, academic support and lead community engagements within the neighborhoods. Through this program, the human-related risks and impacts to the business are identified and appropriate actions taken.

Management Programs:

The management of E&S risks in the business is hinged primarily on implementing the SOPs. For each risk identified across the business, an SOP has been developed. The main E&S risk areas covered by the SOPs include; recruitment and remuneration, grievance management, security, communication, harassment and violence, maintenance, fire safety, disaster management, housekeeping, security, medical support, waste management, water and energy efficiency, transport and procurement. The SOPs are filed at each facility and all facility managers and SHE committees are trained on the specific procedures.

The ResLife Champions at each facility hold weekly ResLife meetings and the outcome are shared with residence managers, who then address these, or escalate to the management, where necessary. The monthly reports to management include social/human risks and management actions taken during each month.

For new developments and building refurbishments, Construction EHS Plans are developed by the principal consultants, adopted and implemented by the contractors, duly supervised by the principal consultants. The Development Director chairs regular progress meetings where EHS issues are discussed and receives weekly and monthly progress reports that also account for EHS aspects. The Development Director also conducts regular site visits to appraise the project on all aspects, including EHS.

Organizational Capacity and Competency:

The overall responsibility for EHS matters in the business lies with the Operations Director. At the Head office, Respublica retains a competent EHS Officer, who engages the Residence Manager, who in turn report to the Operations Director. The EHS Officer coordinates the implementation of EHS-related SOPs, EHS training and EHS reporting across the business. She works closely with the facility-level SHE teams. At each facility, the SHE teams are trained and empowered to undertake audits and monitor EHS performance, led by the Residence Managers who are ultimately accountable at this level. The company 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.

This arrangement is clear and verifiable, and the documentation reviewed show effectiveness in the application of the SOPs.

For new developments and building refurbishments, the Development Director have the ultimate EHS responsibility. The principal consultants’ teams include EHS supervisors who undertake weekly operational monitoring of EHS aspects of the projects through supervision and reporting on the implementation the construction EHS Plans. The contractors’ teams also include EHS supervisors who ensure compliance with the Construction EHS Plans. Through the weekly and monthly progress meetings, and reports, EHS performance is evaluated and requisite corrective measures agreed upon.

Emergency Preparedness and Response:

The identified possible emergency risks at Respublica facilities include; fire, bomb threat, medical emergency, natural disasters, strike and riot and armed robbery. For each scenario, the company implements the fire and evacuation SOP, with a fire evacuation drill reporting template. These are filed at each facility, and the students are sensitized appropriately during induction and on a regular basis. The SHE committees are fully aware of the requirements in the procedures and when to trigger each. Fire drills are conducted at the facilities at least twice a year to test response level at each accommodation facility. In every facility, Respublica, working with the City fire departments, have trained fire marshals, who are also designated evacuators and assistant evacuators during the fire drills.

Monitoring and Review:

All SOPs are controlled documents with implementation lifespans. Their effectiveness is reviewed once they expire, or after a significant incident. The regular internal and external audits are also used to inform any material issue that require changes in the procedures.

For new developments and building refurbishments, the weekly and monthly meetings, as well as findings from EHS visits by the consultants and Development Director, are also used to appraise effectiveness of the EHS measures in the Construction EHS Plans. Where required, appropriate updates in the measures are effected

  Human Resources Policies and Procedures:

Respublica has retained 78 (comprising 43 male and 35 female staff) direct staff at the head office and at the supervisory level at each facility. The company has contracted Bidvest to manage operations at the facilities due to their specialty in this business. Bidvest retains a total of 172 staff (comprising 77 male and 95 female). Respublica implements an Employee Manual (equivalent of the Human Resources Policy). The Manual has provisions relating to recruitment and selection, equal opportunity, wages and benefits, occupational safety and health, working hours, performance management, sexual and other forms of harassment. These provisions have been adopted by Bidvest in their policies and contracts with their workers.

Working Conditions and Terms of Employment:

Each employee has a documented contract that details 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. 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 leave and sick leave, as well as maternity leave.

Non-discrimination and Equal Opportunity:

Respublica has developed an Employment Equity Plan in compliance with the South Africa’s Constitution and Employment Equity Act. The Plan is aimed at considering race, gender and disability in employment and promotions. In addition, the company conducts regular consultations with workers, labor department and other stakeholders in order to protect the interests of all employees across all occupational categories and writes advertisements in a non-discriminatory way to attract all applicants, especially from the targeted groups.

Retrenchment:

The Employment Manual acknowledges retrenchment as a possible employee termination scenario. However, the Manual does not provide guidance on the process to be followed during such retrenchments. Retrenchment is not expected in this project, however, prior to any future retrenchment, Respublica will develop a retrenchment plan that upholds fairness and employee participation principles, and consistent with requirements of IFC PS 2 and the local laws. The company will also ensure that Bidvest develops and implements a similar Plan prior to any future retrenchments.

Grievance Mechanism:

Respublica has an existing workers’ grievance management procedure. The procedure entails a 3-stage grievance management process, where the claimant is involved at each stage, and peaks in a formal hearing that involves an external labor consultant. The process is simple and clear, and workers are aware about it.

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. The ResLife program has developed a human-centered model of promoting mutual respect and positive values across all facilities, and sponsors events and competitions to create comradeship among facility users.

Occupational Health and Safety:

At facility level, every worker is sensitized on the health and safety policy and respective procedures. They are provided with appropriate instructions, training and safety gear to protect them. The application of routine housekeeping, SHE committee audits and ResLife programs are all in concerted efforts to improve workers safety and health. Where OHS risks to workers are identified, the company undertakes repairs and maintenance works promptly to prevent any form of escalation.

For the planned refurbishment works at the Yale village and all new developments, Respublica will ensure, through evaluation of compliance with minimum EHS requirements in contracts with consultants and contractors, the regular construction site visits by the Development Director and review of weekly and monthly construction EHS reports, that the contractors implement the construction EHS Plans to safeguard the safety of all workers and visitors on site.

Workers Engaged by Third Parties

Respublica has contracted Bidvest for all operational needs at the accommodation facilities. For new developments the company evaluates potential contractors’ compliance with local labor laws (policies and procedures) as a condition for selection. Once selected, the contractors are required to align their labor practices (including workers contracts and wages) with minimum labor law requirements and provide all appropriate tools and resources for safe work. For the planned Yale Village accommodation works, a contractor will be engaged through the principal consultant and required to observe local labor and OHS legal requirements. Bidvest has already adopted key E&S requirements from Respublica. The company has a maintenance SOP implemented by any short-term contractors.

 Resource Efficiency:

Energy: Respublica relies on grid electricity as the main source of energy for operations across the business. 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 on electricity consumption points. In all accommodation facilities, the company has installed centralized water heating systems to reduce on consumption, installed automated switch sensors for the electric cookers and wall heaters, 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 use is generally for domestic and sanitation purposes. Back up tanks are provided at the accommodation facilities to cater for the needs during main supply shortages. The facilities have taps fitted with flow restrictors to save on water and water-efficient laundry machines. Water use is tracked by monthly bills incurred by management, and water efficiency is slated as one of the discussions topics during facility-level meetings. There are series of water saving awareness posters at the facilities.

Greenhouse Gas (GHG) Emissions: The student accommodation business does not use significant fuel amounts, and 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 current greenhouse gas (GHG) emissions from Respublica activities are therefore estimated to be significantly less than 25,000tCO2eq/annum.

Wastes and wastewater management:

Main waste streams from the accommodation facilities and the head office include office waste, food waste, sanitation waste and wastes from repair and maintenance activities. Respublica has waste segregation bins at the accommodation facilities and has retained a waste management company to collect and dispose of wastes in designated sites. The wastewaters and effluents from the facilities are related to facility cleaning, food kiosk operations, sanitation facilities and laundry activities. These wastewaters and effluents are directed to the municipal sewers to which the facilities are connected.

During major maintenance activities and new construction works, the 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:

Respublica does not store significant quantities of hazardous materials. Some chemical cleaning agents and equipment repair materials would fall into this category but are few in the operations. These materials are handled in line with the housekeeping and maintenance SOP and disposed of by the waste contractor where needed. During 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.

 Community Health and Safety:

Life and Fire Safety: During design of new buildings or modification of existing buildings to meet student needs, Respublica submits the Building Fire Safety Reports to the City Authorities for approval, alongside other design reports. All existing accommodation facilities 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. Buildings are mostly low rise, with levels ranging between one and six levels with the exception of Hatfield Square which has higher rise buildings. Each building has at least two exits, fire detection and suppression systems, and where required, alarm systems on each floor or as required by the approved rational fire designs. The facilities also have adequate dedicated fire pumps in fire compartments with safe access; dedicated fire water tanks where required by the approved rational fire designs; clear fire escape methodology and protected fire safety routes; adequate and appropriate occupancy numbers; fire separation walls in selected areas; fire muster points; and fire safety awareness posters. The students are regularly sensitized on fire risks from cooking and general use of electric gadgets. Each facility has trained fire marshals. There are designated smoking areas in each facility. The company engages fire safety consultants to inspect and test fire fighting equipment regularly, as required by law; and conducts fire safety test drills at each facility on a regulated basis. No fire emergency incident occurred in the last year of operations across the business.

Community safety: Respublica keeps incidents and accidents records at each 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, sexual assault, 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.

Community Exposure to Disease: Most accommodation facilities have a food canteen. To address health risks, the vetting of applicants includes health certifications as required by law. Once operational, the SHE committees conduct regular checks on food safety and general sanitation at the kiosks and investigate any emerging food safety issues. The company is implementing food safety SOP to guide in this risk area. The swimming pools are maintained by dedicated staff and cleaned on a daily basis. The rules and safety measures are posted at the pool side. No incident of any form of contamination has been reported from any of the swimming pools.

To address risks related to student transport, the company implements the transport SOP. All drivers are vetted on legal compliance and against a code of conduct and are prohibited from use of drugs while on duty. The shuttle buses are maintained in line with the SOP requirements.

Security Personnel:

Respublica, through Bidvest, has employed unarmed security personnel at each accommodation facility. When needed, especially in case of riots or armed theft, the company calls in government or private security to support them. 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.