Given the nature of the business activities under this proposed investment, 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 2012 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.

 Environmental and Social Assessment and Management System

The company engaged an external consultant to undertake an ESG review of its operations to provide benchmarks, against related international standards (including IFC Performance Standards), for the company’s ESG commitments and guide its future performance evaluation. The company will build on the review undertaken for the development of its ESG strategy, will adopt an ESG Risk Management Policy and will develop and implement an Environmental, Social and Governance Management System (ESGMS) in compliance with PS 1 to cover management of environmental and social risks related to its operations, including management of contractors (including drivers) and primary suppliers (ESAP#1). The ESGMS will define procedures and responsibilities for ESG risk management. The ESG Risk Management Policy and the ESGMS will include the company’s commitments and the relevant procedures to: integrate ESG risk management into each stage of its operations; ensure compliance with IFC’s PS; ensure stakeholders engagement; ensure appropriate internal capacity to handle ESG issues; ensure training to employees and drivers; implement emergency preparedness and response and road / driver safety; and ensure effective management processes for the identification, assessment, categorization, mitigation, monitoring and reporting of ESG risks and impacts.

Policy and Management Programs

The company has developed a set of policies, including a health and safety (H&S) policy, a green office policy, a climate change policy, a fire management policy and a risk assessment policy. The H&S policy covers the processes and procedures for: carrying out H&S risk assessments for employees, drivers and third party who may be exposed to company operations; accident reporting and investigation; notification of sickness or absence; H&S reporting and monitoring; workers’ health (such as medical checks, sick/medical leave and antenatal care); emergency preparedness and response; vehicle management; and prevention of pandemic/epidemics among all staff and drivers.

The Green Office Policy covers energy conservation, water use, paper use, waste management and recycling. The Climate Change Policy seeks to reduce the carbon footprint of company activities through a combination of cleaner vehicles and fuels, fuel-efficient operation and driving, reduction of greenhouse emissions and resource efficiency. The Fire Management Policy outlines the procedures and guidelines for the company to control fire safety risks in the company’s premises.

The Risk Assessment Policy outlines procedures that identify hazards, assess and control risk, record findings and review existing controls. As per policy’ requirements, the company will develop and implement a risk register. Under ESAP #1, the company will develop and implement the management programs and operational procedures required to operationalize the policies and meet the requirements of IFC’s PS.

Organizational Capacity and Competency

Moove is a young company; as indicated above, policies and procedures are still under development while key roles within the organization are still being filled. At the time of the appraisal, Moove’s E&S performance was managed by an ESG committee chaired by the Chief Strategy Officer and including the Chief People Officer, the Female Ambassador, a representative of a consulting firm hired to assist in development of ESG policies & procedures and a driver representative. The objective of the ESG Committee is to focus on material environmental, social and governance issues relevant to the company’s business activities and support the company’s ESG performance. The ESG Committee reports to the Board with respect to the development and implementation of ESG risk management policies and procedures, including labor relations and stakeholder engagement. However, the company recognizes the need to integrate the organization with qualified ESG expertise.

Moove will recruit an ESG director with knowledge, skills, and experience necessary to build the company’s capacity in ESG management and to implement the specific measures and actions required under the ESGMS, meeting IFC’s PS (ESAP#2). The ESG director’s primary responsibility will include leading the assessment and management of environmental, social and governance issues arising from Moove’s operations.

The company’s onboarding team conducts trainings on H&S and fire training during onboarding and during the monthly mandatory inspection. Key aspects covered include emergency procedures and road safety including defensive driving, pre-trip inspections, and safety limitations (e.g. braking distances, turning radius, blind spots). Additional trainings on new company policies and procedures will be rolled out to staff and drivers periodically, as part of the training program and procedures developed for the ESGMS (ESAP #1).

Emergency Preparedness and Response

Moove’s health and safety policy covers emergency situations which can have significant impacts to the environment, including occupational health & safety risk to employees, drivers and other personnel working for or on behalf of Moove. The policy establishes a system for carrying out emergency preparedness and response actions within the premises of the company and areas of its operations including remote work areas and roads where Moove drivers operate. An emergency response team is to be established to ensure the company’s readiness in the event of incidents and other emergency situations. The policy also requires documentation of possible emergencies from all potential risk areas identified in Moove activities, operations and processes for staff, drivers, visitors to office premises and the general public. Training on emergency response include fire and medical emergency drills, and sensitization to understand emergency signage in the office building.  The company will develop and implement an Emergency Preparedness and Response Procedure, including the documentation of possible emergency scenarios and relevant response, as part of the ESGMS (ESAP #1). The procedure will be made available to all staff and drivers and training will be provided.

Monitoring and Review

Monitoring and review of implementation of the ESG strategy is undertaken by the ESG Committee. Moove will build upon the ESG Strategy to develop procedures for internal monitoring, performance review, corrective action and related follow-up for management plans and programs as part of the ESGMS under ESAP#1.

Data governance tools have been developed to comply with Uber’s Information Security Risk Requirements. Moove is also working toward compliance with ISO 27001 Information Security Management, and has developed a set of policies, mechanisms, monitoring protocols, assessments, and other relevant tools on data management.

Through onboarding and training as part of the relevant program developed for the ESGMS under ESAP #1, Moove will ensure that managers (e.g. team captains) and drivers are aware of company monitoring arrangements, understand relevant privacy implications, understand the limitations on how information can be used, and ensure that drivers can raise grievances / complaints about privacy issue through the company’s grievance mechanism.

 Moove has a total of about 100 direct employees and 20 contracted / outsourced staff with the latter being security personnel and cleaning staff. Majority of the staff (about 70%) are men. The staff is expected to increase to 150 staff by June 2021.

Human Resources Policies and Procedures

Moove’s human resources policies are outlined in the company’s HR policy handbook and covers equal employment opportunity, diversity and inclusion, anti-harassment provisions, pay periods, salary deductions, bonuses, grievance redress, disciplinary measures, working hours, annual, medical, sick leave, compassionate and maternity leave, recruitment and selection, probation, performance review and termination. The company issues formal contracts that generally provide information on gross salaries, probation period, working hours, holidays, and notice periods. Moove will review its policies and procedures and update or develop its policies on retrenchment, grievance redress for both direct staff and drivers (general and specific to sexual harassment in the workplace), freedom of association and collective bargaining consistent with PS 2 (ESAP#3).

Occupational Health and Safety

The health and safety policy indicates Moove’s commitment to provide a safe work environment for the health, safety and welfare of their employees, contractors, visitors, and members of the public who may be affected by their work. An incident reporting schedule is utilized by the company to capture and record: work-related injuries, illnesses and fatalities; trends in H&S issues; serious damage occurrences to property, equipment or materials; potential damage to the environment; incidents involving contractors/visitors; and incident investigations.

Moove has trained first aiders in the workplace and provides health insurance for staff. Moove is also developing a remote work policy to cover times of civil unrest and to allow for home-based work.

As indicated above, the company’s fire management policy aims to secure the safety and wellbeing of everyone within the company, and to protect the company’s assets. It calls for a fire risk assessment to be undertaken to inform requisite fire safety management measures including: (i) conduct of quarterly fire evacuation drills; (ii) inspection of fire exits; (iii) provision of fire extinguishers; (iv) testing and inspection of firefighting equipment and fire warning systems; and (v) provision of adequate fire safety training to employees.

In response to COVID-19 related risks, the company instituted a policy and protocols to manage the spread of the virus in the workplace including: (i) screening through temperature checks; (ii) upgrading of sanitation measures through requirement of hand sanitization at entry points supported by provision of hand sanitizers and daily cleaning of desks and other frequently used surfaces; (iii) provision of masks and gloves to office staff and visitors; and (iv) allowance for physical distancing in the offices. For Moove vehicles, the company (i) introduced vehicle dividing screens; (ii) required that both drivers and passengers wear masks; (iii) fitted cars with hand sanitizers and gloves for use by passengers and drivers; and (iv) installed devices and provision of mobile based platforms to facilitate cashless payments.

Ongoing communication to staff and drivers on company expectations and policy on OHS management (including COVID-19 response) is undertaken through emails, newsletters, mobile-phone based group chats, town halls and internal meetings.

Management of Contractor (Driver) Relationship

Currently Moove has about 570 drivers under the various products. Under current arrangements, Moove’s drivers provide their services via Uber and are engaged as independent contractors. Moove’s key contractual arrangement with drivers involve: (i) Moove’s provision of products and services to drivers; (ii) drivers’ payment for these products and services through deductions from Uber earnings by Moove; and, (iii) certain level of control and exclusivity which Moove exercises over their drivers.  Moove has sought legal advice on the drivers’ status (including implications for provision of benefits, protections) in Nigeria and will continue monitoring changes in the legal and regulatory conditions of the operating jurisdictions in relation to labor and working conditions and evolving labor practices in relation to drivers as per ESAP #5. 

Each Moove driver is assigned to a team captain and drivers have direct access to their team captain via phone, email or mobile phone based individual and group chats. Team captains contact drivers on a daily basis. Subsequently, team captains also collate any issues on a daily basis and share with management for review to ensure all issues are dealt and resolved in the most appropriate manner.

Although required to complete a minimum number of trips to generate revenue to cover the rental and other relevant payments to Moove, the drivers can work longer hours to increase their earnings (within the maximum number of hours allowed by Uber). The company does not make deductions for income tax or pension and does not provide compensation for work-based injuries due to their independent contractor status. However, Moove provide comprehensive car insurance structured to cover renters in case of accidents, with premium payments made by both Moove and drivers.  Moove will develop and disseminate virtual and print information packages to raise awareness among drivers of the implications of their independent contractor status as well as any voluntary welfare programs, including access to health insurance, accessible to Moove drivers as facilitated by Moove or Uber (ESAP#4).

Moove’s commitment to drivers’ rights, responsibilities and welfare is outlined in the Driver Policy Handbook and seeks to promote fairness, labor ethics and transparency in their relationship with drivers. The Driver’s Policy Handbook communicates Moove‘s expectations and commitments to drivers through the Code of Business Ethics & Driver Code of Conduct, anti-fraud, anti-bribery, ethical marketing, antiviolence, anti-bullying, anti-harassment, anti-discrimination, diversity & inclusion, grievance redress, child-labor prohibition, whistleblowing, climate change, ESG KPI’s for drivers as contribution to Moove’s overall ESG targets, health & safety (outlining both driver’s and Moove’s responsibilities on health and safety).

As Moove drivers are not allowed to operate vehicles when sick, the sick leave policy provides guidance to drivers on steps for reporting illness and, depending on the product, when and how to facilitate return of the car to Moove during the period of illness up to a maximum of two weeks a year.  The unpaid sick leave policy is a formal reporting mechanism to protect sick drivers from being charged rental fees as they are not working at the time.

The Driver’s Policy Handbook also outlines Moove’s commitment to recognition of the driver’s freedoms of association and their right to form, join or leave any interest or pressure group of their choice, while recognizing the drivers’ prerogative to associate with others to share concerns and engage in discussions with Moove on the agreements made with the company. It also indicates the company’s commitment to complying with any law that allows its drivers’ rights to form and join interest groups and organizations for collective bargaining processes, while further elaborating that Moove will enable the means for drivers to bargain collectively and organize in the event that national law restricts these rights.

Moove engaged a female driver ambassador who escalates issues, specifically raised by female drivers, to the company’s management. Gender specific measures for the DTO or Flexi-rental products targeting women are informed by women’s focus group discussions that are also led by the female driver ambassador. The Driver’s policy handbook sensitizes victims of rider violence to report such incidents to Moove through the Grievance Redress Procedure (to be developed, see ‘Human Resources Policies and Procedures’) and the Uber channel established for this platform. Any form of violence by Moove drivers is subject to disciplinary measures including termination of the agreement with the company.

Workers Engaged by Third Parties

Moove engages contractors in some of its key and support functions. Some of Moove’s policies communicate the company’s expectations on contractor workers such OHS, child labor and business ethics. Moove will review and update its contracts with contractors and service providers (including private security contractors) to include compliance with its policies and Performance Standards, incorporated as a contractual requirement and will implement contractor E&S compliance audits according to a relevant procedure of the ESGMS (ESAP #6).

 Resource Efficiency

The company operates from leased offices. Power and water consumptions are generally minimal and used mainly for routine office administrative and sanitation purposes. As indicated, the company has adopted a Green Office policy aiming at energy conservation and reduction, water use and recycling of wastes.

Moove’s climate change policy outlines the company’s commitment to reduction of carbon emissions including commitments to act on driving techniques and trainings, use of the shortest routes to destinations, use of Moove’s approved fuel stations, vehicle maintenance and strict adherence to scheduled vehicle servicing programs.

Moove recently started tracking its GHG emissions from both its fleet of vehicles and office related energy consumption. Moove offices run on biodiesel as the only source of fuel for the back-up generators. The calculation of GHG emissions from the company’s fleet is based on the vehicle model and distances covered, estimated at about 4,800 tonnes of CO2 emission equivalent per year for the entire fleet.

The company intends to launch the use of hybrid vehicles in its fleet with an aim of reducing the CO2 emissions by 50%. With the planned increase of vehicles in the company’s fleet, Moove will establish a procedure for monitoring vehicular emissions, as part of vehicle maintenance and inspection program, to support its targets for reduction of GHG emissions (ESAP#7).

Waste Management

The ESG strategy focuses on monitoring waste generation, including waste electrical and electronic equipment (WEEE)  and car components, in addition to office waste.

Vehicle servicing is outsourced to a contractor therefore Moove does not handle any wastes contaminated with petroleum products. Moove will communicate its policy expectations to contractors on management of hazardous wastes arising from vehicle servicing and maintenance and ensure that these expectations are integrated in subsequent contracts for car servicing, repair, and maintenance. Moove will also establish procedures for waste management and periodic monitoring and auditing of the car servicing, repair and maintenance contractors, in compliance PS 3 and aligned to good practice as per relevant sections of WBG EHS Guidelines (ESAP#7).

 Road Safety

Moove’s Vehicle Safety Policy is included in the Driver’s Policy Handbook and outlines vehicle use and insurance requirements, accident reporting and investigation, vehicle inspection and maintenance, and driver safety regulations.  In addition, the Driver’s Policy Handbook prohibits use of the vehicle for personal purposes and requires that only Moove-authorized drivers can drive the cars. The driver code of conduct included in the Driver’s Policy Handbook requires that drivers comply with traffic laws in their location of work including speeding, traffic control and alcohol requirements. Rider and driver safety is promoted through provision of dashboard cameras (dash-cams) that are monitored remotely by office staff, provision of a panic button in the car, live car tracking systems and frequent driver training. Telemetric data also monitor specific driver behaviors such as speeding allowing for intervention by office teams.

The company has a driver response procedure in the event of accidents, theft and vehicle break down. It requires that all accident data be reported to the Monitoring and Fleet Team for investigation, documentation, and institution of corrective measures towards achievement of the company’s zero accident target. The team also undertakes analysis of accident data to determine trends, recurring problems, and the need for further control measures.

Primarily, the Uber app limits working hours to 12 hours per day. While working within these parameters, Moove requires its drivers to work for a minimum of 60 supply hours per week. Moove monitors its drivers working hours and current data shows that majority of the drivers work for 5.5 days a week and take 1.5 days rest with an average of 12 hours of work per day.

Moove will update its health and safety policies and develop and implement a road safety procedure which will  define the responsibilities within the organization, including the Monitoring and Fleet team, the emergency response personnel and the team captains and will define response actions regarding monitoring of driver working hours and rest breaks, collaborative actions with Uber, the local government agencies, emergency response personnel, including measures to adopt in the event that the driver or the riders or both are incapable of applying the emergency response procedures, and external communication protocol (ESAP#8).

Security Personnel

Moove security is provided by a mix of direct staff, a contracted security firm and local police. Moove will review current and potential security service providers for past cases of human rights violations and integrate requirements for conduct of security staff when undertaking their duties including application of human rights principles when responding to strikes, protests, asset recovery and security breaches. Moove will develop a Corporate Security Management Plan and will communicate this plan to its security service providers (ESAP#9). The Security Management Plan will include: (i) a security risk assessment to determine the risks associated with its security arrangements for its facilities and for vehicle recovery, (ii)procedures and plans for hiring and equipping security personnel, (iii) training of security personnel  on human rights issues, proper use of force, and appropriate conduct towards workers and other stakeholders, (iv) auditing procedures of the security service providers.