This is a Category B project, according to IFC’s Policy on Environmental and Social Sustainability (2012). Based on information reviewed during the appraisal, it is expected to have limited adverse environmental and social risks and impacts that are few in number, 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 sections further below.

The key E&S issues applicable for this project include: effective implementation of environmental, health and safety (EHS) management procedures during the refurbishment and operation phases; effective implementation of asbestos management plan; and grievance management for both third party workers and communities; and stakeholder engagement.

Environmental and Social Assessment and Management Systems:

The Sponsor has a group level sustainability policy and a framework, which commits shareholders, directors, and management, to ensure and maintain a safe work environment and mitigate risks to employees and all other stakeholders.  The policy is approved by the Social and Ethics Committee of the Board and is monitored by the Social & Ethics and Sustainability committee against the set key performance indicators (KPIs). The policy has four pillars: managing assets responsibly, uplifting communities, developing employees; designing and delivering environmentally conscious and efficient spaces and its scope covers all employees, contractors, clients, suppliers, and regulators during their interaction with the company.

Identification of Risks and Impacts:

GREIG has a hazard identification and risk assessment policy, which includes E&S risk identification, assessment & evaluation, response, reporting and monitoring & review.  The group has also acquired an on-line evaluation system, where risks from individual assets are uploaded and evaluated.

Considering the applicable legal requirements, no E&S impact assessment (ESIA) will be required for the proposed refurbishment and expansion. However, as part of the Asbestos Management Plan (discussed under PS3), an EIA will require to be completed for the safe removal, transportation, and suitability of the disposal landfills.

Management Programs:

GREIG has developed an OHS management system in line with the requirements of ISO 45001 and is in the process of obtaining a certification. The system includes OHS policy; OHS performance evaluation policy; incident, nonconformity & corrective action policy; OHS performance evaluation policy; procurement, contractor management & outsourcing policy. GREIG’s development manager will adopt these policies during the refurbishment and expansion.  GREIG requires all its tenants to implement procedures on waste management and security and their implementation is monitored by the facilities manager. The same will be expected for the property.

Organizational Capacity and Competency:

The overall responsibility for implementation of EHS policies and procedures for each facility lies with the Facility Manager reporting to the Risk Committee. The Facility Manager coordinates the implementation of EHS-related procedures and ensure all staff undertake on-line compliance training. The training topics are informed by risk assessments, changes in law, findings of external audits, and company policy timelines.

For the refurbishment, the Sponsor has commissioned a Development Manager (Hodari Africa) with EHS responsibility and chairs monthly progress meetings, and ensures requisite corrective measures agreed upon are implemented in compliance with the refurbishment EHS plans.

Emergency Preparedness and Response:

GREIG has a corporate level Emergency Preparedness and Response policy and include emergencies like fire, medical, natural disasters, shooting, armed robbery and terrorist attacks.  The policy provides for a mechanism for monitoring and reporting. The policy is translated into standard operating procedures at the facility level, which are to be implemented by the tenants with oversight by the Facility Manager.

The Sponsor aspires to meet international fire safety codes in all its properties. The property has life and fire safety systems including a fire suppression system, trained emergency response team consisted of a team leader, firefighters and auxiliary firefighting team available 24 hours per day and conducts periodic emergency response drills. The group has commissioned a consultant to conduct an audit to inform the design of the refurbishment and the expansion phases.

Fire drills are conducted at the facilities once a year to test emergency preparedness and response, equipment, and personnel capacity. During the fire drills, the Facility Manager coordinates with the respective city fire department, and tenants who have trained fire marshals, who are also designated evacuation coordinators.

Monitoring and Review:

Monitoring and review plan is embedded in both the sustainability and the risk management frameworks. For the building refurbishments, GREIG will use the weekly and monthly meetings with the development manager, as well as findings from EHS teams, and the consultants, to appraise effectiveness of the EHS measures in the refurbishment plans, which are updated as required.

During the operational phase, KPIs such as, energy and water use, fire safety and solid waste quantity will be monitored by the tenant, however GREIG will have an oversight as the data will be shared with GREIG and included in the sustainability KPIs reported in GREIG annual report.

 Human Resources Policies, Procedures and Terms of Employment:

GREIG has 92 employees across all departments and spread across different countries of operation, of which nearly half are women.  The assets in Kenya will be managed from the head office in Mauritius, however, about 150 third party contract workers will be hired during refurbishment phase and will be managed by Hodari Africa.

GREIG has a human resources (HR) policy. The policy is operationalized through an Employee Guidelines, which specifies the terms of employment and working conditions in accordance to the Mauritius’ Workers’ Rights 2019 – Act No. 20 of 2019 which is generally aligned with the International Labor Organization (ILO) and IFC’s Performance Standard 2 requirements.

Grievance Mechanism:

As indicated above, the employment guidelines are compliant to the corporate governance code of Mauritius which provide for employment relationship, for example, employees are entitled to associate freely with Trade Unions, however, the guidelines are not explicit as such the company will therefore (ESAP #1) update the employment guidelines to explicitly articulate that there are no restrictions on freedom of association and for workers to join trade unions/organizations.

The company has a worker’s grievance procedure and guidelines policy, which provide steps for complaints and reporting. The formal workers grievance mechanism is supported by an anonymous whistle blowing policy which provides for employees to raise grievances anonymously, without the risk of reprisals, and is in line with to other requirements of IFC’s Performance Standard 2.

Occupational Health and Safety (OHS):

As mentioned above under PS1, the Sponsor has an OHS policy and has developed an OHS management systemin preparation of obtaining the ISO 45001 certification. The scope of the policy includes all of GREIG’s income generating assets and applies to all employees, majority-controlled partnerships, and mandated third party property managers.  In addition, the Group has an OHS Committee in line with national OHS legislation and as well as ISO 45001 requirements. As part of the OHS management plan, the Sponsor has developed and maintained a number of policies and standard operating procedures. Contractors and third-party workers are managed under the Sponsor’s Procurement, Contractor Management & Outsourcing Policy, which defines the processes and procedures for the appointment and management of contractors as well as defining the outsourcing arrangements to be in line with legal requirements. These policies will guide the development of SOP and guidelines by the Development Manager during refurbishment. The implementation of these policies will be ensured for the proposed refurbishment and expansion.

COVID Response:

The Sponsor has developed a COVID-19 pandemic response procedure as part of the business continuity plan which is distributed to each asset and managed by a steering committee.  The response procedure provides guidelines to implement preventive measures, ensure effective business continuity planning and update emergency measures.

There are no staff retrenchments due to COVID-19, however senior management agreed to reduce their salaries by 20% for a period of three months starting from April 2020, reverting to a 10% reduction of certain senior management for a further twelve months thereafter (this also applied to board fees for all board members).  Furthermore, no salary increases were awarded across the company for the financial year beginning 1st July 2020 and no bonuses were awarded for the financial year-ending 30th June 2020.

 Resource Efficiency:

The Sponsor has a Sustainability Framework which has set KPIs on water and energy use efficiency in all its assets and is elaborate on waste management. As part of contractor management, the tender documents include provision for resources efficiency and waste management.  Monitoring of compliance is enforced by the Facilities Manager.  For example, the Manager requires documentation from the landfill where the service provider has disposed waste. In addition, the Facility Manager conducts education sessions with tenants on recycling. The framework has also set commitment in reduction in greenhouse gases by 25% across the group by 2025.

The property being procured does not have any green certification, however, as part of the appraisal, IFC presented EDGE certification requirements for the facility and the Sponsor is in consideration to obtain EDGE certification.

Asbestos Management Plan:

The facility to be acquired has asbestos roofing installed in 1990 and covers 11 expansive warehouse units and a sulphonation plant. GREIG commissioned a due diligence on the existing status and has developed an asbestos disposal management plan, which includes safe removal and disposal of the existing asbestos as part of the refurbishment of the facilities as per the local regulatory requirements and best practice international standards. The plan includes: an environmental impact assessment for the removal of asbestos including a comprehensive risk assessment, an elaborate evacuation process which will include a permit to work system as provided by OSHA 2007, identification of a licensed hazardous waste handler with appropriate licenses to transport and dispose of the material, evacuation of workers during the removal, decontamination of materials, and confirmation through air quality measurements of safe working conditions before resumption of normal services. The Sponsor and the Development Manager are implementing the asbestos management plan through the qualified licensed specialized contractors who shall be appointed in due course.

 Community Safety:

The hazardous materials handled / used by the tenant include hydrochloric acid, caustic soda, nitric acid, and diesel among others. The hazardous chemicals are stored in dedicated and secure locations. All containers and vessels of hazardous liquids are bonded and grounded during transportation and operations. However, as an ESAP #2, GREIG will enforce upon the tenant to ensure that all containers of hazardous chemicals have adequate (110%) secondary containment. All hazardous storage areas have external and internal signs indicating the class and classification of the substances stored. As part of this project, and in accordance with its EHS policies and SOPs, GREIG will contractually require continuity of the safe management of hazardous materials and specify clear requirements on storage and handling of hazardous chemicals.

Security Personnel:

The tenant is responsible for the management of security personnel during operations. Currently the tenant employs private security personnel who are not armed, from specialized firms in the sector. Security personnel are screened for criminal backgrounds and are provided with training in the use of force. The tenant will implement security policies and procedures and provide security personnel codes of conduct and training to ensure appropriate conduct with neighboring communities.

The company operations do not rely on Kenyan public armed forces for any services or support. The tenant implements security policies and procedures commensurate to the operations’ risks and provides security personnel codes of conduct and training to ensure appropriate conduct with neighbouring communities.