This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

 Assessment of the Project Impacts:

The company identifies and manages E&S risks and impacts associated with its operations and constructions through compliance with applicable national standards, E&S regulatory permits and requirements as well as application of international standards including IFC Performance Standards. Environmental and Social Impact Assessment (ESIA) and public consultations are conducted as part of all project development, including the extensions. An ESIA was recently developed for the extension of the existing hotel in Abidjan.

The 153-room Onomo Yaoundé hotel project in Cameroon has started the tendering process for the ESIA, however the process is currently on hold due to Covid-19 pandemic. The project is located in the city of Yaoundé and the impacts associated appear to be limited.

For the Djibouti project, the hotel would be constructed on a land that will be reclaimed on the sea, along the shore of the city peninsula. A presidential decree giving Onomo a temporary right on the future plot has been issued. This temporary right will be turned into a title deed once the project has been completed. The area to be backfilled is located along a portion of the shore that is urbanized and the associated ecosystems are potentially already heavily modified due to effluent discharge as well as other activities including fishing. Based on the initial screening, the potential impacts on biodiversity and marine ecosystem services are noted to be limited. As per ESAP #1, Onomo will perform a detailed and comprehensive ESIA for the project, that will include a marine biodiversity assessment, prior to the beginning of any construction or reclamation on the site. This ESIA will be performed by a skilled and reputable consultant that will be approved by IFC.

E&S Policy and Management Programs:

Onomo has a comprehensive Environmental and Social Management Framework (ESMF) in place that was developed in 2018. The ESMF includes an E&S policy which has been approved by senior management. 

The management framework also includes a series of procedures that allow the company to manage the different E&S aspects: design and construction phase due diligence; operational phase E&S management; stakeholder engagement, grievance mechanism guidelines, use of security forces and monitoring and review process.

The policies and management systems are fully functional and adequately implemented by experienced professionals across all the properties. In response to the COVID-19 pandemic, the company has prepared COVID-19 infection prevention and control policies and has received external certification of these protocols and policies from BUREAU VERITAS.

Organizational Capacity and Competency:

Onomo has an appropriate organizational structure in place to manage E&S, with an E&S committee at the corporate level, that meets bi-annually to discuss the performance of the company. The company has an E&S manager at corporate level to oversee EHS risk management across all the properties. The General Managers at each hotel are in charge of operational EHS risk management and monitoring. Project managers are responsible for overseeing the EHS plan during the construction phases.

Emergency Preparedness and Response:

The ESMF includes an emergency plan applicable for the construction of new hotels. The plan covers the following issues: chemical spills response, fires, rupture of water supply infrastructure and rupture of sewerage system. The emergency response plan assigns overall responsibility for implementation of the plan to the site manager and assigns the environment manager and EHS technicians the responsibility for coordination in the event of an emergency, training of staff and dissemination of the plan.

For its operations, Onomo has implemented an emergency preparedness and response plan, in compliance with IFC PS 1 requirements, for different emergency scenarios including fire, earthquake, flooding, pandemic situations, with clear assignment of responsibilities, processes and decision making on evacuation and response. The roles and responsibilities are well defined with teams in charge of evacuation, rescue, firefighting, first-aid etc. Regular fire drills and safety training are being conducted as per the local regulations, as well as the requirements of Onomo corporate business continuity plan.

Monitoring & Reporting:

The company’s E&S Manager is responsible for monitoring the efficiency and implementation of Onomo Group’s E&S Framework and reporting up to the CEO level. In the event that there are changes or improvements to be made, these are communicated to the E&S Committee and the Board for discussion and approval. Onomo Group recently began monitoring of key performance indicators (KPIs) such as energy, water efficiency, waste management etc. and developing management plans.

 Human Resources Policies and Working Conditions

Onomo Group employed 1,061 regular staff in 2019, across its hotels and corporate operations. During peak demand period, temporary / daily wager staff can represent up to 15% of the staff. Of the total operations workforce, 39% are women and within senior management, 32% are women. Contractors are hired mainly for the maintenance of equipment (lifts, life and fire safety, etc.) through external companies and for construction projects. Oversight of subcontractors is conducted by the Onomo hotel project manager on site.

Due to the COVID pandemic, working schedules have been adapted to the activity of each hotel. Onomo used flexible hours for employees with a stay at home policy and safety measures when possible. The Abidjan and Bamako hotels have not been closed during the pandemic. Dakar was closed between March 23rd and April 23rd and  from June to end of July.

No retrenchment plan is foreseen for the contemplated hotels due to the pandemic situation. Communication between the Onomo headquarters and the operational team has been enhanced during this crisis period. In addition, several meetings with employees’ representatives have been organized to present the situation.

Onomo has a corporate human resources (HR) manual outlining all functions of the department from recruitment to induction to promotion to ongoing training.  There is a corporate level HR Manager as well as a person responsible for HR matters at each hotel. Each Onomo hotel abides by national collective conventions of hotel industry in respective countries which outlines all labor laws as well as salary scales in the hotel industry.   

For each hotel, the HR department has an ‘employee manual’, outlining the mission and values of the Onomo Hotel Group. The employee manual provides practical information on the history of Onomo in Africa, how each employee should behave in the work environment, the organizational chart for each hotel and the induction plan. The employee manual is shared with every new employee, together with the réglement interieur. In the employee manual, there is no mention of an employee grievance mechanism.  The induction process is outlined in the employee manual and is detailed in the internal Onomo procedure.  This induction takes place when the employee is first hired and there are subsequent trainings related to every employee’s specific job. Although there is no specific HR/recruitment policy that refers to anti-child/forced labor, the “réglement interieur” makes provision of this.    

Onomo Group does not have a specific Sexual Harassment Policy although the Réglement Intérieur includes clauses on anti-sexual harassment and anti-discrimination as well as anti-prostitution clauses, especially concerning prostitution of minors and makes provisions for sanctions against employees who do not respect the interior regulations.

Per ESAP item #2, Onomo will develop a Sexual Harassment Policy together with a Code of Conduct and relevant disciplinary procedures in line with IFC guidance: “Addressing Gender-Based Violence and Harassment Emerging Good Practice for the Private Sector”.  All staff working at Onomo hotels including security guards will be required to adhere to this policy. Every employee will participate in a thorough training on the contents of policy and the Code of Conduct before signing.

As per ESAP #3 the Company shall develop and operationalize a documented grievance mechanism for the workforce, in accordance with PS2 requirements. The mechanism will allow for the receipt and resolution of anonymous complaints, protect the workers from retribution, allow for timely response and feedback and enable the appropriate receipt and resolution of gender related issues and grievances (such as sexual harassment and gender-based discrimination) with due regard for confidentiality. The grievance mechanism shall be applicable to all existing and new employees, third-party staff, and shall form part of the HR policy and other relevant documents and shall be communicated to all the workers.

Occupational, Health and Safety (OHS):

Onomo has procedures in place for the site selection and due diligence conducted as part of the risk assessment for greenfield projects, EHS plan at construction phase, and an OHS plan. The EHS plan covers contractor approval, labor and working conditions, and contractor supervision.

For the construction projects, the company uses internationally reputed companies that comply with good international industry practices for contracted services, including construction work. Onomo’s Project Managers closely monitor projects weekly and receive a monthly report from the site manager. Onomo requires its contractors to be responsible for the training of their own employees, as well as overseeing OHS issues on site. Construction reports, including OHS reporting and statistics are shared and discussed with the project team every week.

Due to Covid-19, Onomo has adapted working schedules to each hotel’s activity. The group appointed a Covid Committee that develop and implement safety standards and guidelines for the protection of employees and guests. Every hotel bought the needed PPE for the teams and protective masks for the guests. A Covid19 committee has been created to make sure that employees use their PPE and follow the standards.

 Resource Efficiency

Onomo Group has started collecting data on resource usage at each of their hotels. The company is developing a detailed policy with clear KPIs on water usage, plastic use, waste management, electricity usage at corporate level to support the management of individual properties.

Electricity will be sourced from the national public grid for all assets. Usually, Onomo hotels use standard back-up system generators for grid failure. The Abidjan, Yaoundé, and Djibouti hotels will have a centralized cooling system for the air-conditioning, which will allow the controlling temperatures according to occupation and whether windows had been open. The Abidjan and Yaoundé hotels will have heat exchangers installed to cool air, and almost all hotels are using LED bulbs. The expected GHG emissions from the project are expected to be 3.700 tons CO2 eq/annum.

Water and Wastewater

All Onomo properties concerned by the transaction are or will be equipped with an onsite sewage water treatment system. The group uses accredited contractors to remove sludge from the treatment plant. Treated wastewater is used locally to water green spaces and wash the outside areas at hotels after being filtered and treated with UV rays before use. Samples are sent to a laboratory regularly to test the quality of the treated water.

Water for the Onomo hotels is sourced from local public water supply system, used mainly for non-potable use such as cleaning, gardening and laundry services. Potable water for staff consumption is sourced from local bottled water supplies.

Wastes and Emissions

Waste (mainly general waste) is collected by local municipality in each country or locally accredited contracted utility suppliers. Onomo has a waste management procedure developed as part of their ESMF, that is consistent with the applicable legal requirements.

The only type of combustion equipment in use for each hotel are 630 kVa back-up power generators that work with diesel delivered by gas trucks. The generators are maintained regularly to guarantee their efficiency, but the air emissions are not monitored.

 Infrastructure and Equipment Design and Safety / Life and Fire Safety

Based on the review of the information available, the design of the buildings is in line with the requirements of national fire regulations for each countries of operation, as well as, in compliance with an international Life and Fire Safety (L&FS) standard such as the French Fire Code or UK Fire Code depending on the country and location of the particular hotels. Onomo obtains certification from competent professionals or specialized companies that the architecture and engineering design for the hotel is fully responsive to the L&FS section of the WBG General EHS Guidelines. Also, the company has developed an overarching architectural design guiding document for the Onomo Hotels (called O-Plan) that will be used for future hotels. The O-Plan contains the mandatory L&FS requirements for the hotel and related facilities, including accessibility and access to first responders.

The new hotels are audited by specialized and internationally recognized companies upon completion of construction, to confirm that it was constructed in accordance with the approved design, structural safety and the internationally accepted L&FS standard. For each hotel, Onomo obtains certification of the structural and fire safety aspects prior to start operations from independent third-party certifiers.

For operation and maintenance of the L&FS systems the company contracts a recognized company that coordinates the operation and maintenance (O&M) requirements and coordinates with local subcontractors for specific systems (water systems, fire alarm, portable extinguishers, etc.).

Hazardous Materials Management and Safety

Onomo has standardized the use of biodegradable products for all cleaning and laundry processes in the hotels. Onomo has an established pest management plan and selection of pesticides is controlled by Quality and EHS teams with a strong preference for natural and biodegradable products or mechanical systems. The Onomo Hotels Group has partnered with a company leader in testing, inspection and certification services (Bureau Veritas), to certify the Covid-19 safety processes implemented in its hotels in Africa to ensure the highest levels of protection for guests, employees and partners.

Traffic Management

The project site is located in urban areas with relative high traffic. The company implements a traffic management plan during construction phase for each project in line with the ESMF, coordinated with city authorities, to ensure smooth flow of traffic to the construction site with minimal disruption to the host community. Adequate provision for parking is made in the design of each hotel.

Security Services

All hotels are being guarded with unarmed security guards from licensed private security agencies. Regular training programs are conducted for the security workers on the standard operating procedures for their job including emergency response and safety trainings.

In addition, Onomo works with armed public security forces (police and gendarmes) at three of their hotels – Bamako, Abidjan and Dakar - a legal requirements in those countries. There is no specific policy, Memorandum of Understanding (MOU) in place yet or clear training for these public forces.  As part of ESAP # 4,  the company will update (1) the security risk assessment and security management plan that identify and evaluate relevant security related risks (including knowledge of likely risks and likely responses, capacity to manage these risks, ownership of these risks) to be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of Performance Standard 4 (paragraphs 12, 13 & 14).); and (2) the security management plan to include references and process to manage the public security forces in the applicable countries and finalize the MOU that will be signed with the public security forces to demonstrate efforts to engage with those public security forces.

Community Exposure to Disease

International food and water safety standards are being adopted before the opening of each new hotels. All food and beverage outlets that serve in the hotels need to comply with all the standards and Food Safety Procedures Manual and Onomo designs the kitchens accordingly. The hotel maintenance team tests the swimming pool water quality regularly as per the standard procedures and maintains hot water at sufficiently high temperature to prevent growth of Legionella bacteria, and tests regularly to confirm the effectiveness of these treatments.