PS1: Assessment and Management of Environmental and Social Risks and Impacts

Policy, E&S Management System and Assessment of Risks and Impacts

Each subsidiary of Man Holding (MAN) has its own integrated occupational health, safety & environmental management system (IOHSEMS). The IOHSEMS are aligned with host country legal requirements and applicable international management system standards like ISO 14001 environmental and ISO 45001 OHS. Each subsidiary has developed a health, safety, security, and environment policy statement which have been disclosed to the workforce. Where local regulations require an environmental and social impact assessment, MAN’s client(s) are required to complete the studies and seek relevant local approvals and licenses prior to project commencement. When contractual agreement with client stipulates that MAN undertakes the ESIA for the project, MAN hires a specialised consultancy firm to fulfil the specific requirement. The subsidiaries maintain project specific OHS risk registers to manage construction activities and operations. An overarching environment, health, and safety (EHS) policy is yet to be developed as part of MAN’s corporate level environmental and social management system (ESMS). Based on this corporate level ESMS, project teams develop a new country screening checklist, and IOHSEMS for each new project. MAN will document an overarching corporate E&S policy in compliance with applicable domestic legislations and sector-specific requirements and regulations and will enhance country screening checklists to screen projects versus all IFC Performance Standards (including PS5 to 8 as well) and relevant international standards (ESAP #1).

Organizational Capacity 

At corporate level, there is a function responsible for coordination with subsidiaries/project teams on environmental and social aspects. The corporate health and safety director oversees the role of the health and safety manager of each project and has overall responsibility for E&S on all construction projects. For each construction project MAN has offsite and on-site EHS manager. The EHS manager is responsible for the safety and environmental protection of the construction operations on site, elimination of health and safety risks and environmental impacts of the project. There is also a lead EHS manager and a EHS training coordinator responsible for delivery of the OHS training. The training coordinator reports directly to the lead EHS manager. In addition, there is a EHS supervisor at the ratio of 1:200 workers on site, a EHS officer for every 50 workers and a fire protection coordinator. Usually, a medical doctor, a nurse and a first aider are available to every 50 workers on site. On the visited project, the client arranged for paramedical staff in place of a full-time doctor to be on site. An environmental officer is also available on site as well as security supervisor overseeing the security guards of the private security provider and reporting directly to the site EHS manager.

Management programs

Man Holding has multiple management plans and programs to mitigate and manage the risks and impacts of its projects and activities. In line with IOHSEMS, a construction management plan (CMP) as well as an environmental and social management plan (ESMP) is developed for each project, considering the ESIA requirements as provided by MAN’s clients, country specific screening of OHS legal requirements, required permits, availability of resources including local labor, transportation, and E&S risks in the host country. The plans and management programs address OHS hazards and risks, environmental aspects such as use of materials, resource efficiency, air emissions, solid waste, wastewater, hazardous materials, and pest control, and include details such as where and how local licensed handlers will be selected, where the nearest government approved land fill is located, as well as methods to reduce the waste generated on site. Targets and key performance indicators (KPIs) are then placed to measure actual performance and implementation of these management programs against.  

Monitoring and Review

MAN conducts both internal and external audits of the EHS aspects of its activities.  There is an annual management review meeting where all audit results, OHS and environmental reports are shared with MAN’s board for assessment and budget decisions.

Emergency response plan

MAN project teams have documented site-specific emergency preparedness and response plans (EPRP) and procedures for every construction project. The procedures describe emergency scenarios and specifies responsibilities, measures and required resources. The EPRP is based on the crisis management plan, local regulatory requirements, and site conditions. EPRPs are reviewed and approved by MAN’s clients and the relevant authority of the host country, where required. Every project has trained emergency response teams and perform routine emergency drills. There is a schedule for inspection and maintenance of fire detection and fighting equipment used on construction projects.

PS2: Labor and Working Conditions

 Human Resource Policies & Procedures

As of end of December 2022, MAN group employed 625 full time employees and 2,250 construction workers with limited term contracts for the duration of the construction projects. MAN has an employee handbook which includes a human resources policy, recruitment procedure, code of conduct, training options for learning and career development, performance management and employee relations. MAN is committed to equal opportunity and non-discrimination. There are disciplinary actions in place in case of violation of MAN’s code of conduct or policies and procedures.

Working Conditions and Terms of Employment

MAN’s letter of appointment, which is used for new hires, has references to the host country labor law. The HR policy and procedures, including leave system, promotions and grievance mechanism are detailed in the employee handbook. To align with PS 2 requirements, the existing letter of appointment will be updated to include references to the employee handbook in addition to the host country regulations (ESAP item 2a).

Workers organizations

The laws in the countries of Lebanon, Qatar and KSA provide workers from these respective countries the right to form and join unions and to bargain collectively.  At the same time, these country laws do not cover migrant workers’ access to labor unions or worker organizations.  As per IFC PS2, MAN will facilitate the establishment of workers committees within the company composed of workers representatives (local and migrant) to discuss and address with management labor topics and issues (ESAP item 2b).

Grievance mechanism

There is a grievance mechanism where the concerns are raised to direct supervisors. The process entails the formation of a committee to investigate and resolve the grievance/concern and provide a response to the grievance raiser. There is a grievances log, and no grievances were received in the past year. The employee grievance mechanism will be enhanced to include applicability to contractor workers, anonymity, and a timeframe for providing a response to grievance raiser (ESAP item 2c). This update will be communicated to the workforce including applicability to contractor workers (ESAP item 2d)

Child Labor and forced labor

The minimum age for employment in the countries of operation is 18 years. Labour Law in the host countries prohibits employment of child labour (young persons between 18 and 21 in hazardous work environments) or forced labour. The company’s employment screening includes verification of birth certificates and national identity cards, to check the age requirements.

Occupational Health and Safety

The occupational health and safety management on MAN projects is undertaken by project OHS managers and site OHS advisors with overall accountability assigned to project directors/general managers. Every subsidiary has specific OHS management plans and project risk registers covering construction activities and support operations. In addition, method statements and associated risk assessments have been developed for high-risk activities (e.g., excavation, trenching, working at height, lifting operations, electrical, scaffolding, hot works) and communicated to workers. The projects have implemented permit to work system to control and manage high risk construction activities. MAN subsidiaries have an internal training program on health and safety for all supervisors and skilled/craft workers as well as external specialized trainings for specific personnel. 

Every subsidiary collects incident statistics on monthly basis which are analysed by the OHS team and trends reviewed by project management leadership teams. In the last three (3) years, there has been no fatal accidents or lost work time due to recordable injuries on ongoing/completed projects since 2020.  MAN provides personal protective equipment (PPE), safety instructions, toolbox talks and safety trainings to its contractors. MAN will implement a corporate incident investigation and root cause analysis guidance to ensure consistent practice in the investigation and root cause analysis of OHS incidents across projects (ESAP #3). 

Workers engaged by Third Parties

Third party contractors include sub-contractors undertaking civil and electro-mechanical works at MAN construction sites and security and cleaning services at MAN offices. The company screens sub-contractors against EHS and technical capability assessment criteria prior to signing the services agreement. Any external contractor is required to follow the national regulations related to environment, occupational safety, and fire safety as well as the company’s ESMS policy and procedures while working on MAN’s project sites or company premises. MAN will incorporate into agreements with contractors, in line with PS2 requirements, a requirement to follow MAN’s policies on occupational health and safety; grievance mechanism; and worker accommodation, etc. (ESAP#1). MAN has a safety evaluation for monitoring the safety performance of its subcontractors. MAN will add to its current contractor screening documents a checklist on IFC PS requirements for workers engaged by third parties (ESAP #1).

PS3: Resource Efficiency and Pollution Prevention

Air pollution and GHG emissions

Due to the nature of the sector, MAN’s projects and activities are not expected to have more than 25,000 tons of carbon dioxide (CO2) equivalent emissions per year. In 2022, scope 1 emissions were 1,087 tons CO2 equivalent and scope 2 were 643 tons CO2 equivalent for all subsidiaries including the headquarters in Lebanon, Tecman facility and worker camps.

In total, MAN owns 210 vehicles ranging from cars and buses to various types of trucks. Company owned vehicles regularly undergo preventive maintenance and are checked for emissions, brakes integrity among other aspects on annual basis. In addition, the company maintenance is conducted as needed every two to eight months.

All diesel generators are fitted with air filters and air emissions tests are conducted as required by local regulatory requirements. No fuel is stored on site.

Resource efficiency 

In line with its commitment to reducing impacts of its business activities on the environment, MAN employs several resource efficiency initiatives such as installation of LED lights at its headquarters in Lebanon and at subsidiaries, solar panels installation at Tecman. In addition, there is a study for establishing a micro-grid as a joint effort with other companies to provide energy to each other. The study is expected to feed into a business plan.

Water and Wastewater

Water for MAN construction sites is supplied from the public utility companies of each country of operation. Alternatively, water is hauled to site from licensed water contractors. Only sealed mineral water containers are purchased for drinking purposes. The main sources of wastewater are sanitary wastewater. Worker accommodation and construction site are generally connected to existing sewers which is connected to the municipal sewer.

Solid and hazardous waste management

Solid waste is segregated into glass, plastic, metal, cardboard, paper, and wood on each site. Construction waste is segregated and sold to local contractors. Excavation waste is transported to authorized landfills and/or waste areas in host countries. MAN recently launched the segregation of organic food waste at the labor camp in Lebanon in November 2022. MAN enterprise Qatar’s team use mesh fibre instead of paper cement bags. This initiative has resulted in the reduction of solid waste generated from the use of half empty cement paper bags that did not hold the cement for long. 

In terms of hazardous waste such as empty paint and thinners canisters, MAN follows the hazardous waste management plan in the CMP of each project. Hazardous waste is kept in a container under lock and key with restricted access to trained personnel. Each container is provided with a fire extinguisher and danger signs outside. These materials are stored and disposed of by licensed waste handlers contracted at each host country.

PS4: Community Health, Safety and Security

  Infrastructure and Equipment Design, Life and Fire Safety

For the projects, MAN and its vendor integrate the infrastructure and equipment design, as well as life and fire safety (LFS) requirements as per approved building designs, in line with host country building requirements and applicable international codes and standard. A competent third-party consultant is responsible for performance testing, commissioning and certification prior to client handover/ occupation of buildings.  Smoke detectors, sprinklers and fire alarms are installed at the company premises as per the local regulatory requirements for each country. For those, a third-party reviews planned and implemented LFS measures to validate the permits issued by the authorities in Lebanon.

Road Transportation

At the subsidiary level, MAN has in place a specific Road Transport and Journey Management Plan. The plan adequately addresses road transportation safety hazards and risks and has established principles for journey management, fleet management and driver management, which includes traffic management of the heavy construction vehicles at construction sites.

Security personnel

MAN employs security measures such as use of CCTV cameras, access restriction and security staff. The company employs unarmed security guards to manage access control and emergency response. In addition, the company customarily contracts private security firms or implements what is required by its client in terms of security management plan. Training for security guards from a private security provider is conducted by external agencies.