Given the nature of Bolt’s business activities, no impacts are expected in the project which must be managed in a manner consistent with PS 5: Land Acquisition and Involuntary Resettlement; PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS 7: Indigenous Peoples and PS 8: Cultural Heritage.

 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, 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 following sections.

The e-platform sector is fast evolving and interpretation of applicability of contractual and legal frameworks, especially in relation to treatment of gig-economy workers, contract drivers and other service providers, is also evolving. The key E&S issues reviewed at appraisal are related to availability of an overarching system and management approach for identifying, managing, and monitoring E&S risks and performance; adequacy of the human resource policies and procedures for employees and management of the company’s partnership with the independently contracted drivers using the service platform; safety and security to both driver and customers, including management of gender-based violence risks; and response to road side emergencies.

 Bolt implements an Integrated Management System (IMS) that is aligned with ISO 9001:2015: Quality Management System and ISO 45001:2018 Occupational Safety and Health. To manage key E&S risks in the business, the company has developed a corporate Health and Safety Guideline, and a Risk Management Procedure, developed to align with ISO 31000:2018: Risk Management – Guidelines. A number of relevant management procedures, including: Incident, Near Miss and Hazard Management Procedure; Rideshare Safety Management Procedure; Emergency Management Procedure (SOS Procedure); and Consultation and Communication Management Procedure, have been developed accordingly. The Health and Safety Guideline outlines key Bolt commitments, primarily to undertake risk assessments of offices and working environment; ensure adequate and proper training of both new joiners and existing workers; emergency management and accident/incident reporting. The above procedures guide on the specifics of E&S risks assessments at market and location-specific levels, hazards evaluation and incident reporting and management; vehicle, driver and customer safety management; internal and external communication; and management of emergencies in the course of engagement with the platform. These procedures are interlinked, controlled and reviewed periodically.

For the delivery business, Bolt operates a Bolt Food platform where restaurant operators are registered and transact with their customers. The platform also extends to include non-food items. The company has designed General and Special Terms to Bolt Food Service with the Restaurant Operator – two documents that entail the policy, ethical, compliance and food safety requirements that each operator has to abide by.

The company business is primarily based on the Bolt platform as the main medium of interaction between the company and freelance drivers and clients (e.g. riders, restaurant operators, etc.) The Guideline and sets of procedures applied in risks management across the markets of operation are deemed functionally adequate for the nature of the company’s business.

Identification of Risks and Impacts; and Management Programs

The Risk Management Procedure is the main guidance document for risk identification, assessment and management. During the feasibility analysis by the company on new operations, E&S risk assessment is undertaken alongside the regulatory and legal assessments. Before entering in a new country, the company conducts risk assessments for national, sector/industry, and location-specific scenarios. In addition, risk assessments are also undertaken for all routine activities. Routine risk assessments cover vehicle safety, rider safety, and client safety. The risks and impacts identification and assessment process begins with a hazards identification process, followed by a risk assessment. Such risks are thereafter monitored over time through the corporate risk register. To manage risks, Standard Operating Procedures (SOP) are designed, and the SOP are communicated to relevant staff to ensure that they are aware of the hazards and controls. Where there is need, training is conducted to all parties involved in such an activity.

The Company has various specific procedures in place to manage health and safety incidents, near misses, hazards (events) and regulatory issues related to private hire vehicles, contract vehicles and occupational incidents. Incidents are identified, reported and investigated in a consistent and effective manner, and corrective actions implemented to mitigate future occurrence.

To adequately understand and incorporate E&S risks related to the food delivery and financial services businesses into the company’s risk management regime, Bolt will conduct specific E&S risk assessments for these new business activities and revise the existing Risk Management Procedure and the corporate risk register, or design risk management procedures specific to these two types of businesses, to accommodate the additional identified risk streams (ESAP #1).

Additional social risks, given the nature of the client’s business activities, are the safety of drivers and customers, including in relation to gender-based violence and COVID-19 among others.  They are considered in more detail under Performance Standard 2 and 4 below.

In relation to data protection and privacy, the company has systems in place which are based on the European Union GDPR standards.

Organizational Capacity and Competency:

Bolt Global Head of Safety oversees E&S management in the business and works closely with country and city managers on risk assessments, incident investigations and management, compliance enforcement and training. This team (Head of Safety, country and city managers) has a formal E&S management and reporting structure and the members have differentiated E&S risk management responsibilities and accountabilities. Bolt has environment, health and safety (EHS) Committees in the respective countries to support with continuous risk mitigation activities, including assessments, internal communication and a first level of call in employee grievance management before escalation, if need be.

The drivers on the Bolt platform receive regular training and sensitization notes through the platform, and periodically within their respective country and city structures. Such training activities include personal health and safety, client health and safety, incident management and reporting. During COVID 19 pandemic period, there has been intensified training and sensitization of the direct workers and drivers in the platform on their own health and safeguarding the clients’ health.

Emergency Preparedness and Response

The company is implementing an Emergency Management (SOS) Procedure. This procedure also guides on handling external grievances or complaints.  The procedure elaborates protocols on initiating a distress call, recording of complaints (both on emergencies or other complaints), processing of complaints, incident evaluation process and investigation of claims – known to all workers and platform drivers. The Bolt platform has an emergency (SOS) alert feature that is used to instantly report emergencies and external complaints either by the drivers or clients in many but not yet all jurisdictions, and these are escalated all the way to the group emergency teams. A press on the alert feature triggers an interaction with the emergency teams and subsequently a dispatch of an ambulance and/or security team to the exact GPS location of the trip, depending on the incident. In some jurisdictions, Bolt has contracted a dedicated private security response team to provide guarding, emergency medical services and roadside assistance in the event of any medical or security emergencies drivers encounter while operating on the Bolt platform (see below under Performance Standard 4). To adequately address such incidents, the company also has close working relationships with security and health authorities in the operating cities and countries.

Monitoring and Review:

As part of the company’s management system, relevant E&S responsibilities are included in the management procedures and evaluated as part of KPIs – especially for the management teams. The procedures are reviewed annually by management.

Due to the nature of such platform businesses, Bolt will develop a corporate risk review procedure to ensure consistent implementation and reporting from countries to corporate and will implement a periodic external review program of its E&S procedures, including labor policies, and their implementation and will engage an external expert for review on compliance with company policy, legal and regulatory conditions of operating jurisdictions in relation to labor and working conditions of drivers on a periodic basis, as well as monitoring evolving labor practices(ESAP #2).

 Human Resources Policies and Procedures:

Bolt directly employs over 1,800 people globally spread across its headquarters in Estonia and from various locations in Johannesburg, Warsaw, Bucharest, Lagos and London. Among the workforce, 57% of employees are male while 43% are female.

Human Resource (HR) policies that Bolt implements include a Diversity Policy, a whistleblowing policy, a modern slavery policy, country-specific Employee Handbooks, and Grievance Policies. Employee handbooks differ in content, but cover similar key areas including employee responsibilities, standards of conduct, and disciplinary action. The Diversity Policy sets clear standards on acceptable behavior in relation to discrimination on personal grounds and harassment at work. The company implements Human Resource (HR) policies and employee handbooks adapted to fit in-country labor requirements in the examples of South Africa and Kenya. 

Drivers (ride hailing and delivery): In relation to the drivers, the company views them as independent contractors who are responsible for the provision of transport services, including vehicles, but it acknowledges that labor law frameworks in several jurisdictions are evolving on the question of drivers’ labor status. In relation to each new market, the company takes legal advice in relation to the regulatory situation related to its platform, including an assessment of the evolving labor law issues related to the engagement of drivers.

Fewer than 5 percent of drivers globally are women and this percentage is much lower in African countries. While there are concerns related to the safety and security of female drivers and customers, the company will explore initiatives to develop a gender approach to services based on an understanding of differentiated risks (for example, women-only services) in ride hailing.

Working Conditions and Terms of Employment:

Employees are engaged on common terms and conditions where possible, but these are adjusted in different jurisdictions to reflect relevant national legislation and practices. On entry into a new market, the company engages local counsel for a review of relevant regulatory requirements, including relevant employment legislation. Based on that advice, Bolt makes adjustments to its standard terms and conditions where appropriate and necessary. Contracts address typical employment terms and conditions including working hours, leave, remuneration, and termination. Several clauses address non-competition, non-solicitation, intellectual property, and confidentiality. The review of sample terms and conditions did not identify gaps with respect to the requirements of Performance Standard 2.

Non-discrimination and Equal Opportunity:

The company has a harassment, equality and diversity policy which applies to all employees globally and sets out clear standards related to non-discrimination and harassment. It also adequately sets out the clear steps which an employee who feels she or he has been subject to discrimination or harassment should take.

Grievance Mechanism:

The grievance mechanisms which apply to employees vary based on jurisdiction. Policies in some jurisdictions addressed basic grievance aspects including submission of a complaint, investigations, hearings, timelines, and appeals. Policies in other jurisdictions provided less detail on grievance procedures. Some Employee Handbooks need improvement on grievance procedures while other are relatively streamlined. These mechanisms will need to be supported by consistent formal processes and recording systems that can provide insight into types of grievances by country, response and response time. Bolt will revise the current grievance management systems to define a formal grievance redress, reporting and escalation procedure as well as systems to manage and capture grievance information consistently across the business, and ensuring reporting from city / country level to group level (ESAP #3).

Occupational Health and Safety:

Through the Risk Management Procedures, Bolt manages occupational health and safety and carries out regular health and safety training and sensitization to direct staff and drivers. For the drivers, these are conducted via the Bolt platforms and through country and city managers. A new driver gets registered onto the platform and undergoes a mandatory induction training before being allowed to begin work. The training modules cover the full use of the Bolt platform, company policies and procedures, road safety, customer care and vehicle management, among others. As indicated above under Performance Standard 1, there is a specific emergency response program for drivers on the platform. 

The vehicles used in the Bolt platform are screened for safety. Through a formal checklist, vehicles are assessed and cleared to work on the platform.

For Bolt’s cohort of female drivers, the company reports that steps have been taken to combat gender-based violence when they are providing services on Bolt’s platform. For example, in the case of Nigeria, Bolt has carried out an information campaign aimed at raising awareness of the potential risks faced by its female drivers and also setting up dedicated response teams within the local Customer Support units that are tasked with dealing with any case of gender based violence and also a women-to-women category matching female riders with female drivers on request.

Workers Engaged by Third Parties; and Supply Chain

The company engages contractors to provide a limited number of services. Customer service is a major outsourced function, and Bolt relies on two main outsourced providers that adhere to its codes of conduct. Bolt also relies on contractors for office and operations support, as well as specific services in local markets (for instance emergency management and roadside assistance). Bolt currently does not have a group-wide procurement policy. Bolt will design and implement procurement and supplier screening procedures to ensure that contractors and suppliers comply with legal and policy requirements, consistent with IFC PS 2 requirements (ESAP #4).

 Resource Efficiency: The company operates from leased offices in the countries with physical operations. The power and water consumption are generally minimal, provided by the property owners and used mainly for routine office administrative and sanitation purposes.

Wastes and Wastewater Management: Limited volume of solid waste is generated in offices, mainly food, paper, and occasionally some electronic wastes. These are disposed of in accordance with local municipal rules. Bolt’s operations do not result in any material wastewater discharge.

 Community Health and Safety:

Driver and customer safety, especially security and gender-based violence during trips, is a significant risk area in the operations. The company has a defined protocol for both drivers and customers safety and emergency management, as indicated under PS 1. The SOS procedure and the Global Ride Hailing Event Management Procedure both outline the process which Bolt uses to manage safety and health related risks to drivers and customers. These include specific Standard Operating Procedures for managing risks including gender-based violence against female customers.

In relation to drivers, there are a range of instances where driver safety may be of particular concern, ranging from road traffic challenges through to potential car-jacking or other violence in some countries. Across all operations, COVID-19 is an ongoing risk that needs to be addressed. There are a number of reported safety initiatives across different jurisdictions, from emergency roadside assistance to COVID-19 specific cleaning procedures.

The company is aware that the development of ongoing measures to ensure driver safety is a work in progress, particularly given the impact of COVID-19. To safeguard driver and customer health during the COVID-19 pandemic, Bolt has provided masks and sanitizers to drivers in some markets, encouraged drivers to purchase appropriate PPE, facilitated frequent sterilization of cars at a central locations in some markets, provided clear guidance to both drivers and customers on appropriate safety precautions, and introduced the Bolt “Protect” ride option in several countries which involves cars with screens between drivers and customers to further ensure safety.

For the food delivery services, Bolt has developed terms of engagement for restaurant operators to ensure that the meals prepared for delivery are not harmful to health or the environment; have been properly cooked or prepared and are otherwise safe, of high quality, fit for transportation and consumption and at an appropriate temperature for consumption by the customer; and comply with all applicable requirements for the preparation and packaging of food. Bolt has reserved the right to inspect the process of the provision of services by the restaurants at any time.

To mitigate against road accidents, the company continues to provide safety training and sensitization to all drivers.  Accidents and incidents are monitored and recorded. To sustain customer and driver safety issues from long working hours, the company has a time-based tracker that ensures that when a driver hits 12 hours on the platform, they are automatically de-activated for 12 hours. The company will continue to assess and identify suitable ways to introduce self-diagnostic checks on drivers through the App to understand the total working hours (for Bolt and all other platforms) and to spread knowledge on the dangers of driving when fatigued.

The company has also introduced various measures to address the risk of gender-based violence. The procedures employed by Bolt are both proactive and reactive. Proactively, Bolt has deployed procedures in markets where the incidences of gender-based violence against female customers are acute. For example, Bolt has deployed a campaign aimed at raising awareness of the issue among its drivers and passengers and launched a separate service aimed at providing emergency escape rides for female customers who find themselves in situations of risk, with local customer service teams receiving training on how to respond - in some markets.  On the reactive front, Bolt has adopted a zero-tolerance policy when it comes to allegations of driver involvement in gender-based violence while operating on its platform.

Security Personnel: Bolt’s business premises are small sized and do not have armed security personnel. As indicated above, Bolt has contracted a dedicated private emergency response and support team to provide, through local health and security working partners, emergency medical services and roadside assistance in the event of any medical or security emergencies drivers encounter while operating on the Bolt platform. Bolt has also retained contracts with private security firms in high-risk cities to promptly handle reported security situations as appropriate. Bolt will develop a security risk assessment and management procedure, aligned to IFC PS 4, including relevant provisions on screening and management of the contracted private security firms and their personnel (ESAP #5).