This is a Category B project according to IFC's Environmental and Social Sustainability Policy. Based on the information reviewed by the Company, this investment will have limited adverse E&S risks and impacts that are few and site-specific, with no renovation or construction impacts, only operational impacts are expected. These can be avoided or mitigated by adhering to recognized performance standards, procedures and guidelines as described in the following sections.

Key E&S risks and impacts associated with the project include: the company's capacity and systems to assess and manage E&S risks and issues associated with its operations; provision of fair and safe working conditions for its employees; Occupational Health and Safety (OHS) policies including COVID 19 related procedures; road safety; and life and fire safety.

Environmental and Social Assessment and Management Systems:

As per applicable regulatory requirements, no Environmental Impact Assessment (EIA/ESIA) is required for the establishment or operation of a medical distribution company. For the imported equipment stored in the warehouse, the storage system and equipment handling are expected to be compliant with the standard set by the Ethiopian Food and Drug Association (EFDA). Infinity holds a valid EFDA certificate and has a Quality Management System (QMS) certified as per ISO 9001:2015 requirements. Infinity is audited by external auditors prior to certification renewal. There are also internal audits conducted by the QMS team twice a year to monitor progress with the plans provided by the external audit report.

Identification of Risks and Impacts

The Company has developed a risk assessment plan and has undertaken a documented risk assessment, which has identified both E&S as well as business risks and prevention measures implemented by the various departmental managers. Risk consequences, rating, likelihood and assessment matrix along with required controls and mitigation procedures are in place. Major risks are escalated for management interventions where additional resources may be needed to address them. Risk management at Infinity includes the development and implementation of standard operation procedures (SOPs) to mitigate the identified risks and establish business procedures that are streamlined with the QMS; and on-going risk management training and monitoring. In addition, the Company has developed and implements OHS, sanitation and fire safety measures.

Policy

Infinity has an Environmental Health and Safety (EHS) Policy that guides E&S performance of its operations. The policy covers inherent risk areas such as OHS, safe work practices, use of personal protective equipment (PPE) and incident reporting. In addition, the policy covers waste management, electrical safety, radiation safety and fire safety. All staff are trained on the policy and related operational procedures. Infinity conducts awareness activities on the policy for newly recruited staff. As part of the partnership with General Electric (GE), Infinity requires its engineers to attend training on the safe handling of equipment during installation and testing provided by experts from GE.

Organizational Capacity and Competency

Infinity currently has a Quality manager responsible for overseeing the implementation of the QMS, including coordinating quality audits and implementing quality improvement plans. The responsibility of implementation of the EHS policy is currently shared between the managers of the various departments of Infinity. For this reason, Infinity is in the process of recruiting an EHS manager to be responsible for the mitigation of EHS risks.

Emergency Preparedness and Response

In addition to Infinity's SOP to address and respond to risks, an emergency preparedness and business continuity plan (ERP) has been developed.

As per the ERP, submersible pumps are installed at underground rooms to extract flooding water incase storage areas are accidentally flooded.

The Company operates in a leased office building that has passed the national regulatory requirements for fire safety design. The Company has its own EHS policy which entails Life and Fire Safety (L&FS) instructions and has L&FS checklists for its maintenance team to check on fire-fighting systems and other maintenance aspects such as fire prevention from electrical sources. As per ESAP item # 1, the Company will review and update its current procedures and emergency response plan to increase staff training frequency on emergency evacuation and regular fire drills.

Monitoring and Review

Currently, the quality manager monitors, reviews and tracks the implementation of issues raised in the risk assessment plan. The quality manager works closely with an external consultant to conduct internal monitoring and annual audits to ensure continuous improvement. The external consultant monitors the implementation of the improvement plans with the managers of the various departments at Infinity. Incidents are monitored and reported through the company incident reporting forms. There were no major incidents or injuries reported in 2019 and 2020. Any incidents including road safety incidents are reported immediately and are recorded in the incident reporting system. This is clearly stated in the company Fleet Management Policy.

 Infinity currently employs 138 staff (53 female and 85 male). The Company has 12 staff in management (6 female and 6 male staff). There are no contracted staff or workers. 

Human Resources Policies and Procedures

Infinity has a Human Resources (HR) policy that provides adequate detail on recruitment and appointment procedures in accordance with local regulatory requirements. The policy articulates working conditions (working hours, performance evaluation, leave, duration of probation), non-discrimination and equal opportunity, recruitment, promotion, overtime, staff development/training and employment termination. The Company has also developed an employee grievance mechanism under the appeal system. Infinity also has an Employee handbook that communicates the working conditions to newly hired staff and is distributed to each employee as part of the induction procedure. 

Working Conditions and Terms of Employment

All employees have formal written contracts provided upon recruitment and the terms of service are explained during staff orientation. The contracts describe details such as job title, working conditions, terms of employment and benefits.

Non-discrimination and Equal Opportunity

As per the HR policies, Infinity is an equal opportunity employer and the company does not discriminate on the basis of sex, ethnic background or religious and social affiliation. The Company has developed a policy on sexual harassment that is annexed to its code of conduct. To ensure that this policy and related grievance procedure are put into practice, the client will enhance the staff training to put more emphasis on gender-based violence at the workplace under ESAP item # 2.

Grievance Mechanism

Infinity has a grievance and disciplinary procedure that outlines the grievance management process for all staff, including feedback timelines. The grievance procedure allows for escalation if the grievance is not resolved with the immediate supervisor. The procedure also provides for an appeal to raise a complaint through a court of law if the company is unable to resolve the staff grievance. While the process is anonymous, and a suggestions box is provided that is out of surveillance camera coverage, the company will revise and enhance the grievance procedure SOP to clearly state that anonymous grievances are allowed in compliance with IFC Performance Standard 2. ESAP item #2.

Protecting the Workforce

The minimum age for employment is clearly defined to be 19 years in the Company’s recruitment and appointment SOP. The local labor law prohibits the employment of child labor or forced labor. The Company's employment screening requirements for potential employees include verification of birth certificates and national identity cards, which are only issued to persons 18 and over. The company shall include explicit reference to non-use of forced labor in their recruitment and appointment SOP. ESAP item #2.

Occupational Health and Safety

As already indicated, Infinity has developed an EHS Policy and a COVID 19 SOP to protect its staff and visitors from injury, illness, infections or such impacts associated with exposure to hazards encountered in the workplace. The Company is planning to have a health and safety committee to champion the implementation of the EHS policy and mitigation of risks in all company operations. The committee will undertake the training of staff and enforce safety practices by all employees.

Radiological devices are monitored weekly by the Radiation Protection authority which dictates the national standards for installing of radiological imagery equipment. In terms of X-ray Radiation protection; all engineers (12 nos.) working on X-ray machines are equipped with personal Dosimeters (TLD) with quarterly follow-up TLD readings assessment reports. All engineers are equipped with safety work gears such as: overalls, safety shoes, gloves, helmets and goggles. In addition, first aid kits are available at electrical and mechanical workshops.

In response to COVID 19 pandemic, the Company has developed a COVID19 Policy detailing procedures to be followed during the pandemic for all staff to follow. Implementation of this policy entails elevated hygiene and disinfection measures at the workplace for staff protection. COVID19 appropriate PPE is provided to all staff including masks and sanitizers while on the job. The policy also defines procedures to follow in case COVID 19 symptoms are developed.

 Security Services

The Company office building is in a populated residential and mixed-use area. The Company has a security policy and uses a range of security measures, including CCTV cameras and unarmed security staff to manage access control and assist in emergency response. An external hiring agency conducts training for security staff prior to the hiring of security staff by Infinity. The office building is located less than 1 km away from the emergency civil fire services and ambulance.

Road Safety

Distribution of medical equipment by Infinity requires significant road travel by drivers and engineers around Ethiopia. The Company's fleet management policy details safety measures taken by drivers and passengers including safety belts, mobile phone usage and other safety measures. Induction for drivers include such safety components and the drivers are responsible to inform passengers of the safety measures to be taken during travel. In case of an accident, it is stated in the policy to immediately contact the fleet manager and nearby police. The drivers are oriented on these issues.