IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Policy & Management Systems: Balwin has a Safety, Health, Environment, and Quality (SHEQ) policy statement and developed an integrated management system (IMS) which incorporates corporate and project level policies, procedures and management programs. The Balwin IMS is certified according to international standards for management system, ISO 9001:2015 (quality); ISO 14001:2015 (environment) and ISO 45001:2015 (OHS). The IMS procedures cover key E&S risks and impacts including OHS, waste management, land transport, security, environmental spills, hazardous materials management, contractor management and emergency response.
Identification of Risks and Impacts: Balwin has a corporate level Land Acquisition and Environmental Authority Permitting (EAP) procedure that requires, E&S screening as a decision-making tool as well as necessary environmental and social impact assessment (ESIA) studies. Balwin undertook an environmental assessment for Mooikloof City in 2003, in accordance with local environmental laws. Balwin keeps track of valid EAPs for the phased housing project and commissions additional environmental assessments / ESIAs for additional works such as road construction and junction enhancement, wastewater treatment, storm water management, water supply and storage. Balwin will (i) update the 2003 environmental assessment incorporating PS requirements and develop an ESIA report for submission to IFC and (ii) enhance its project level IMS procedures by developing an environmental permits and licenses register specifically for the Mooikloof project aligned with the various city development phases and related enabling infrastructure works. The register will also integrate an inventory of the latest environmental assessment reports as well and where applicable, the timeline for internal review and update of these studies (ESAP #1).
Management Plans and Programs. The company has integrated its E&S risk management programs, plans and procedures into the corporate level IMS. These plans and procedures cover E&S risk assessment, OHS programs, solid waste and wastewater management, hazardous chemical management, change control, contractor management, large spill management, change management, EHS training and internal communication on SHEQ management. The plans and programs are also cascaded to project level.
Organizational Capacity and Competency. Regional EHS Managers are responsible for EHS management at project level. They report to Regional Managers, who in turn report to the Balwin MD. The bulk of the project construction activities are undertaken by contractors. Contractor and sub-contractor E&S responsibilities are cascaded through contract clauses and managed through the Contractor Management Procedures. HR and Administration officers at corporate level manage HR issues for direct staff while the Balwin Project Management teams at project level, manage third-party labour risks. The Balwin Energy-Managing Director handles sustainability reporting on energy use and greenhouse gas emissions.
E&S risks at Mooikloof City development are managed by the Gauteng Region EHS team consisting of the Regional EHS Manager and 2 EHS Officers based in Johannesburg as well as an EHS Officer and a Community Liaison Officer (CLO) based at the Mooikloof Balwin Site-Office. Oversight, monitoring and audit functions for Mooikloof are undertaken by the Gauteng EHS team with support from outsourced E&S consultants. The Balwin Managing Director will be responsible for the implementation of the project ESAP.
Emergency Preparedness and Response: The company has developed an Emergency Preparedness and Response Plan (EPRP) for the residential complex. The EPRP include emergency plans for scenarios such as fire, medical emergency, spills, and weather events, civil unrest, other feasible events. The emergency evacuation plan has delegated responsibilities for its implementation to the on-site SHEQ officer with the support of the Site Manager. Key emergencies identified under this plan include environmental spills, natural disasters, health emergencies, fire, gas leaks, security threats and structural collapses. The EPRPs also include arrangements for emergency equipment, inspections, signage, training, drills, and exercises. The company is in the process of establishing early warning system to identify inclement weather and prevent such weather from posing negative implications on the safety of employees. The Mooikloof City EPRP has also incorporated emergency preparedness protocols for heat waves and flooding events.
EHS Monitoring and Review. The company schedules quarterly audits to all active project sites. The audits cover performance of EHS programs including (but not be limited to) management of contractors and sub-contractors, adherence to environmental permitting and water use licenses (where applicable), environmental incidences, accident and incident reports, tracking of inspections by regulators and close-out of corrective orders as issued by regulatory agencies. Reports are submitted to the Social and Ethics Committee at corporate level. The company also engages independent auditors to undertake audits at project level, covering local environmental, health and safety laws compliance. Corrective action plans are recorded through an online platform managed at corporate level and progress is tracked to inform management reviews on EHS performance.
PS 2 – Labor and Working Conditions
As of May 2024, Balwin properties had almost 350 direct staff, of which 36% are women. Mooikloof City has a workforce of around 310, of which 300 (97%) are subcontractors’ workers, which is typically representative of peak employee numbers. Workers typically work for sub-contractors engaged for specific project construction works / tasks.
Human Resource Policy and working terms and conditions. Balwin has documented its HR policies and procedures based on local employment laws, that broadly comply with PS 2 requirements. All employees are provided with written contracts indicating dates of employment. HR officers conduct visits to project sites, and update staff on new HR policies twice a year. Balwin will update its HR documents, in line with local law and PS2 requirements, as discussed in the following sections (ESAP #2). The updated documents will address (but not be limited to): (i) payment of wages and benefits, deductions (statutory and voluntary), hours of work and shift systems; overtime arrangements and overtime compensation, breaks, rest days, leave (annual, maternity, sick, statutory deductions, pay systems), (ii) commitment for anti-harassment and prevention of retaliation.
Non-discrimination and Equal Opportunity. Balwin has an Employment Equity Committee, which oversees working conditions and employee well-being as well as promotes equal opportunity. As part of ESAP #2, the company will update its equal opportunity policy to include terminology and commitments on non-discrimination per local law and PS 2.
Workers Organization. While Balwin does not have any unionized workers, per ESAP #2, the company will update its HR policies to explicitly document its commitments to freedom of association in accordance with local law and PS 2 requirements. The company will also sensitize staff and third-party workers of its updated HR Policy on this right.
Protecting the Workforce. Balwin only hires persons above 18 years and requires ID cards at recruitment. Minors are explicitly prohibited from entering Balwin’s construction sites. As part of ESAP #2, the company will document its commitment on prohibition of forced labour and sensitize staff, contractors and suppliers about this commitment.
Worker’s Grievance Redress Mechanism (GRM). Balwin has a Disciplinary and Grievance Policy, which is accessible to staff through the intranet and communicated during staff training. The company also has a Whistleblowing policy, which allows for reporting unethical behavior by email or phone call (including anonymously), with grievances investigated by an external HR consultant. The company's anti-sexual harassment policy definitions include gender-based violence (GBV) in the workplace, and covers employees, third-party workers, and visitors, with instances reported confidentially to a HR representative. Staff can also report grievances to the staff employment equity committee, while contractors and suppliers are allowed access to the company whistleblowing portal. The company will enhance its grievance and disciplinary policy to provide a clear segregation between GRM procedures and disciplinary procedures and include PS aligned measures for responding to grievances related to sexual harassment and GBV (ESAP #3).
Retrenchment. The company has not experienced retrenchment in the recent past as employees are normally assigned to subsequent phases of the same project or to other Balwin projects. Balwin will as part of ESAP #2, document a retrenchment policy in accordance with local law and PS 2 requirements including: (i) Consideration of alternatives to retrenchment, (ii) timely payment of final dues, (iv) meaningful workers engagement, (v) psychosocial support to staff, and (vi) commitments to a retrenchment plan.
Occupational Health and Safety. Balwin has a corporate level OHS management system where the OHS procedures have been cascaded to the project level through the Mooikloof City OHS Plan. The plan covers specific risks or issues related to falls, working in confined spaces, lock-out tag-out procedures, electrical installations, hazardous and flammable materials, lifting equipment, working in inclement weather as well as requirements for training, awareness, competency and internal communications. As part of ESAP #1, the Company will (i) update the OHS plan; that relate to heat-stress management protocols, to include alternative schedules during high temperatures and shaded/cooled breaks, (ii) review and update the EPRP to incorporate an early warning system for severe weather.
Hazard identification and assessment is undertaken for contracted works per project specifications and the corporate IMS requirements. The company has appointed/designated corporate level management staff as well as EHS committees (including fire marshals, first aiders and nurses), and hires external experts (where needed) for the implementation of the OHS program. The Gauteng Region EHS team also provides annual and periodic training and drills to ensure effective implementation of the program.
The Mooikloof site maintains a task-based risk assessment register, an incident/accident reporting procedure involving a root cause analysis and copies of OHS regulatory compliance certificates (“letters of good standing”) for each contractor. The results of OHS and environmental compliance audits are communicated to the company’s Social, Ethics and Transformation board committee. The company impact reporting (https://balwin.co.za/investor-relations ) includes disclosure of OHS performance at regional level, as informed by data collated from each project. The company undertakes internal training, covering topics such as first aid, fire emergency prevention and response, and competency training for members of the workplace EHS Committees. EHS induction includes contractors and sub-contractors’ staff.
Third Party Workers and Supply Chain. Balwin has contractor management procedures covering both due diligence and post-engagement oversight / management. The company also reviews minimum wage compliance and statutory deductions by potential contractors. Similar E&S procedures are applied to suppliers, with Balwin undertaking vendor E&S assessments and monitoring of implementation of applicable commitments on environmental management, OHS and labour conditions. Suppliers and Contractors are also bound by Balwin’s Code of Ethics. At site level, the Balwin CLO is actively involved in the hiring of contractor workers for the housing development and helps in prevention of gate hires. As part of ESAP #1, Balwin will enhance the contractor management procedures by expanding the scope to cover E&S oversight for contractors providing O&M services for utilities in commissioned housing phases that are still under Balwin management.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency. Power for the project is sourced from the national grid with back-up power supplied by diesel powered generators, while water is sourced from municipal sources. The company tracks energy use, water use at project and corporate level. The Balwin building designs incorporate re-use of wastewater, rainwater harvesting systems and adoption of green energy solutions such as solar power. The company has a project level water and energy use management procedure developed from the project Environmental Management Plan (EMP).
Green House Gas (GHG) Emissions: Baldwin reviews and estimates its GHG emissions as well as resource use at corporate level and disclosed through the company’s integrated reporting. GHG emissions for Mooikloof project during its construction and upon project completion is expected to be below 25,000 ton carbon dioxide gas emission equivalent per year.
Air and Noise Emissions. Air quality management procedures cover vehicle maintenance (emission control) and dust control measures such as dampening of dusty areas, vehicle coverage to control, fugitive dust and on-site vehicle speed control. Noise emission management is mainly through regulation of working hours to maintain OHS exposure thresholds. As part of ESAP #1, the company will document the project level air and noise monitoring and management practices and enhance the current monitoring and reporting procedure in accordance with PS 3 requirements and WBG General EHS Guidelines.
Solid Waste Management. Project waste mainly consists of construction waste including excavated soil, packaging materials, left over construction materials (e.g. plaster, concrete, glass). Hazardous Waste, such as used lubricant, grease, petroleum product, medical waste from first aid and other hazardous materials are in smaller quantities. A project level waste management plan was developed. Contractors are tasked with managing their own waste while the company audits contractor and sub-contractor activities. Waste quantities are captured by type of waste stream and in tons disposed of, then incorporated into corporate level monthly HSE reports.
Wastewater Management. Project level wastewater from the sanitation facilities provided to construction workers is disposed of in existing chemical toilets or wastewater systems. Wastewater management procedures are guided by the project EMP and specifications in the OHS Plan. Volumes are tracked and reports integrated into the corporate level monthly HSE reports.
Balwin has constructed a wastewater treatment plant (WWTP) and the supporting sewage collection network. Treated effluent will also be stored and used for irrigating lawns and the city landscaping while, the excess treated effluent will be disposed into the Swawelpoortspruit River. The WWTP is operated and maintained by a contractor engaged through a Service Level Agreement initially signed with Balwin Properties, and eventually handed over to the Mooikloof City after completion of the entire development. Monitoring of the performance of the WWTP is undertaken in accordance with the local license requirements that broadly align with WBG-EHS guidelines. Balwin will review and update the WWTP management manuals and the requisite wastewater management and monitoring plan to include all the parameters per WBG-EHS Guidelines (ESAP #4).
Hazardous Materials. The main hazardous material on site is diesel stored in small quantities for use by back-up generators. Site clearance activities prior to construction did not result in any contamination and/or presence of asbestos. Balwin has a corporate level hazardous chemical management procedure that outlines the company requirements in handling of hazardous materials.
PS 4 – Community Health, Safety and Security
Infrastructure Design and Safety. Balwin designs are approved in accordance with local legislation and permitting requirements. During construction, Balwin conducts regular building quality inspections to identify any construction defects and implement corrective measures. The company is also responsible for building maintenance activities for one year after the hand-over.
Life and Fire Safety. The Mooikloof development will consist of 4-floor residential blocks, lifestyle centers, and sport facilities. Balwin follows South African fire safety standards and possesses relevant certificates for each building. The company contracts an independent engineer with expertise in fire safety to develop a building specific fire protection plan at the design stage, with yearly audits conducted thereafter by relevant authorities. The building design includes i) fire protection systems (fire hydrant, fire hose reel, portable extinguishers, site water supply and a pump); ii) manual fire alarm; iii) structural fire safety provisions (e.g., fire resistance of building materials and fire separations); and (iv) adequate firefighting access to the complex.
After the facilities are completed, Balwin is normally involved in the Operation and Maintenance (O&M) phase of the projects during occupancy stage. The company will develop a detailed “Facility O&M Handbook” to be used by the administrator or building manager with the relevant operative instructions and expected quality of service specified by the Balwin brand (ESAP #5).
Road Safety. Balwin has traffic related E&S specifications for the principal contractor, which require conducting a detailed risk assessment of traffic risks and impacts. Balwin OHS programs also outline procedures for traffic management, vehicle inspections, driver training and competency, incident and accident reporting and investigations as well as emergency preparedness and response. Balwin regularly monitors and audits the implementation of this plan and incorporates road incident and accident investigations into its OHS performance monitoring activities.
Security Personnel. The hiring of un-armed security guards to prevent unauthorized access on site is the responsibility of contractors. Balwin requires the principal contractor to develop project security rules and procedures. As part of ESAP #1, The company will develop a corporate level security management procedure, in accordance with PS4 requirements, which will require (i) assessment of social risks posed by the security arrangements, (ii) background checks on past human rights abuses before engaging security staff, (iii) training security personnel on the appropriate and proportionate use of force, (iv) security personnel code of conduct requirements to also cover contracted security staff, (v) reference to mechanisms for management of community grievances related to security personnel.
