Land for all the developments under the project are/being purchased through willing buyer-willing seller transactions and no expropriation of land or physical or economic displacement is expected to be caused by the project. The housing projects are all located in developed urban or peri-urban areas around Jakarta in a modified habitat. As such, no impacts for this project are expected which must be managed in accordance with IFC PS 5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage).

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). Key environmental and social (E&S) issues associated with this project include: corporate E&S management systems and E&S assessment procedures; E&S management during the project construction and operation; fair and safe working conditions including management of Occupational, Health and Safety (OHS) for own employees as well as contractors; life and fire safety and emergency response measures; resource efficiency; waste management; community health and safety; stakeholder engagement and grievance redress.

Environmental and Social Assessment and Management System: The company has a group level Code of Conduct including EHS, fair employment etc. The company identifies and manages E&S risks and impacts associated with the construction and operations of its developments through compliance with applicable national standards and E&S regulatory permit requirements.

As per national legislation, the construction and operations of the Samanea Hill project is subject to Environment Management Efforts and Environment Monitoring Efforts (UKL/UPL) study. The study has been conducted by qualified consultants and approved by the Environmental Service Department of Bogor District Government on 9 July 2018 and is disclosed together with this Environmental and Social Review Summary (ESRS). The company will complete the required EIA studies and obtain the required permits for the future projects.

The company implements the UKL/UPL describing actions required to manage the impacts and risks related to the project including: risk assessment and control; environmental baseline study; waste and wastewater management; monitoring and reporting etc. Construction contractors are required to prepare customized documents to manage EHS during construction in a manner consistent with Indonesian regulatory requirements. As per ESAP 1, the company will develop and implement a land acquisition screening mechanism and the standard operating procedure for conducting E&S due diligence of potential investments to ensure that land acquired by a third party is conducted either on a willing buyer-willing seller basis or meets national laws and the requirements of PS5.

Organizational Capacity and Competency: Farpoint has assigned a construction supervisor at the housing projects. Farpoint also hires contractor management consultants responsible for construction management and monitoring at each site including accidents record, compliance with legal requirements etc. In addition, the appointed construction contractors have their own site managers to oversee the project sites including EHS aspects of their own workers. During the operations phase, an in-house estate management team will manage the developments and will oversee the development and compliance with all safety requirements in accordance with local government regulations.

As part of ESAP 2, the company will formalize the EHS organization structure for construction and operations phases, by assigning its own staff as E&S Management Representative with responsibility for the implementation of EHS management at each housing project with clear lines of responsibility and authority. This E&S function will coordinate with the site supervisors, contractors and the construction management consultants as well as the company’s corporate teams and senior management.

Emergency Preparedness and Response: The company has developed an emergency response plan (ERP) to manage emergency scenarios during the construction and operations of high-rise buildings. However, the ERP needs to be revised to suit the needs of the housing projects (with landed houses). As part of ESAP 3, the company will establish ERP applicable to the construction and operations of housing projects covering all foreseeable emergency scenarios including the roles and responsibilities, emergency evacuation, rescue, firefighting, first-aid etc.

COVID-19 Response: In response to the COVID-19 pandemic, the company has prepared COVID-19 infection prevention and control procedures. During the COVID-19 pandemic, the company did not conduct nor plans to lay-off any workers, and there have been no salary cuts or no-pay-leave arrangements. The company has implemented several COVID-19 response measures for its operations including: testing Covid-19 every two weeks, temperature checks, regular cleaning and disinfection etc., and published COVID 19 Protocol for Employee Conduct applicable to all employees and construction workers.

Monitoring and Reporting: The contractor management consultants are responsible for monthly monitoring during construction including key performance indicators (KPIs), such as: accidents and near misses; training and toolbox talks; risk assessments; and violations. Any issues arising from performance matters or safety are highlighted for discussion during weekly meetings with the construction supervisor, construction management consultants and contractors. The project teams accordingly analyse the root causes and implement corrective actions. However, no documented monitoring procedures are available. As per ESAP 4 the company will establish a documented E&S monitoring procedures including necessary KPIs for construction and operations as per regulatory requirements and World Bank Group (WBG) EHS Guidelines.

As of November 2020, Farpoint employs around 300 workers including those involved in construction management at its project sites, estate management, sales and other corporate functions at its headquarters comprising about 70% male and 30% females. All the employees are directly employed by the company except small number of security workers cleaners and gardeners etc. on site. At the time of appraisal, there were around 400 workers mobilized at Samanea Hill project construction sites through construction contractors. It is expected that at its peak the total construction workforce on the site of housing projects will be about 800 workers.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment: The company has a set of corporate HR policies and procedures in place which are consistent with the local labor law and apply to all its employees. These include requirements and provisions on working conditions (working hours, overtime payment, leave, separation etc.); description of performance evaluation; social security and health insurance etc. Each worker receives a written contract that describes the working conditions and terms of employment.

Non-discrimination, anti-sexual harassment and equal opportunity are described in the corporate code of conduct. Child and forced labor practices are strictly prohibited in line with Indonesian labor law. The company ensures that the contractor complies with local government regulation on minimum age for employment by confirming with workers’ national identity cards.

Freedom of Association and Grievance Mechanism: The company does not restrict freedom of association (FoA) of its employees and the company’s HR policies cover FoA following the local regulation. There is currently no employee/labor union at any of the operational units of the company.

The company has a documented grievance handling procedure as part of HR policies. As per the procedure, all employees are expected to first direct their grievances to their supervisor, a person assigned to each department or HR department. Anonymous grievance mechanism is available through hotline accessible to all employees and contracted workers managed by corporate compliance department. There are no significant grievances, disputes, court cases were reported to date.

Occupational, Health and Safety: The company has a group level Code of Conduct that includes OHS management. The contractors ensure their own OHS performance based on local regulatory requirements and as per general guidelines provided in the construction contract. OHS supervision is conducted by the construction management consultants and reported on monthly basis. The company has reported zero fatalities for Samanea Hill project in the past two years. However, there is no documented OHS risk assessment and management procedure developed for housing projects. As per ESAP 5, Farpoint will develop an OHS management program for housing projects including: (i) procedures to systematically assess OHS risks and hazards at housing project sites; (ii) define supervisory personnel roles and responsibilities; (iii) define OHS requirements and operational standards aligned with international good practices and the WBG EHS Guidelines, such as work at heights, scaffolding, lifting, hot work, etc.; iv) training requirements for these high risk activities as well as a general OHS training as part of site induction for all staff including contractors; and (v) define monitoring, incident investigating and reporting protocols.

Workers Engaged by Third Parties: The company requires that its contractors to follow the group’s code of conduct including EHS policies and compliance with labor law through contractual requirements. There is no migrant labor employed. Apart from the construction workers, a small number of third-party contract workers are employed at the project sites mainly for gardening and security who are not armed. The company’s compliance department reviews and monitors the qualifications of all subcontractors in accordance with national regulations and labor law. The COVID-19 response measures are also applied to construction sites. The company did not suspend or cancel contracts due to COVID-19 pandemic

Workers Accommodation: Worker’s accommodation is provided by construction contractors for their workers on-site. To ensure all workers accommodation will meet the health and safety standards including the provision of basic services, the company will develop a worker’s accommodation standard in reference with PS2 requirements on workers accommodation and “Workers’ accommodation: processes and standards - A guidance note by IFC and the EBRD”. Necessary clauses will be included in construction contracts and which will be monitored by the company as part of its E&S monitoring program (ESAP 6).

Resource Efficiency: The company is considering to design, construct and operate its housing projects following the internationally accepted green building standards and aspiring to receive the IFC’s EDGE certification, for which at least 20% savings in the energy and water consumption compared with the base case is expected. Measures to reduce the energy consumption are incorporated in the housing design such as provision of LED lighting, open spaces to reduce the electricity usage for lighting. The estimated greenhouse gas emissions from the project are estimated to be much less than 25,000 tons CO2eq/annum.

Energy Supply and Air Emissions: Electricity is sourced from the national public grid and the company will not install diesel generator sets for housing projects. The project is thus not expected to produce significant air emissions.

Water and Wastewater: Water for the Samanea Hill project will be sourced from local public water supply system supported by truck water supply when needed and will be used mainly for non-potable use of housing operations. The portable water for all housing consumption is sourced from local bottled water suppliers or homeowners will install filtration system for their houses. Each house has an on-site bio septic tank and further treated at wastewater treatment pond before discharging to public drainage. Similar systems will be installed for future housing projects.

Waste and Hazardous Material Management: Management of hazardous and non-hazardous waste during construction and operations is governed by permitting conditions that details out the procedures for handling, storage, transport and disposal of wastes. The company will also align with the green building certification to segregate and manage its wastes during operations phase. From the storage area, all the hazardous and non-hazardous waste will be collected for disposal by authorized external third parties (government and private sector) specialized in each type of waste handling. Housing projects are not expected to store hazardous materials including explosives or hazardous chemicals/materials.

Community Health and Safety: Farpoint housing project development cycle includes conceptual design, construction and management. Company has retained well experienced engineering consultants firm to design and construct the project through bidding process. Design and development are done in accordance with Indonesian legal requirements and seismic zone, including the specifications outlined in the regional and city master plans. The company takes measures to protect the community during construction, including clear demarcation of construction areas with fencing, restricted access to construction sites.

Security Personnel: A small number of unarmed security personnel are employed by the company at the Samanea Hill project site. There have been no known security incidents at company facilities and they will coordinate with local police offices for intervention if needed.