Considering the nature of business operations and project activities and based on IFC’s review during project appraisal, no significant risks and impacts associated with the requirements of PS 5 (Land Acquisition and Involuntary Resettlement), PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources); PS 7 (Indigenous Peoples) and IFC PS 8 (Cultural Heritage) were identified for this proposed project. In any case, the company will develop policies and procedures to screen for E&S risks and impacts and, when such risks and impacts are identified, mitigate them consistent with all the PSs as summarized under the PS1 section below.

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the potential adverse E&S risks and/or impacts, which are generally site-specific, are largely reversible and can readily be addressed through mitigation measures. Based on the available project information, key project-related E&S issues and risks include the company’s capacity and systems to review and manage the E&S performance associated with the operations of their assets, adequate procedures for site selection and acquisitions for pipeline projects, stakeholder engagement and community grievance mechanism, and contractor E&S management during construction.                                                  

 Environmental and Social Assessment and Management System, Identification of Risks and Impacts and Management Programs

The company has a corporate sustainability policy, which underlines the environmental and social aspects of the organization, the stakeholders mapping and its commitment to implement actions against climate change and to prevent pollution within its operations. Visum Capital is signatory of Principles for Investment Responsible – PRI, a program promoted by United nations that aims to incorporating ESG issues into investment practice. Although Visum Capital does not have a formal E&S management system (“ESMS”) in place, its practices are conducted in line with ESG requirements defined within its policies. Regarding E&S impacts and risks, Visum Capital recently conducted an E&S diagnosis for all of Visum’s assets, including waste management practices and natural resource consumption data; however, it is not a systematic practice.

At an early stage, Visum Capital engages with external consultants for identifying potential risks associated with its projects. This assessment includes E&S aspects mostly related to water management, permits required, among others.

As per ESAP action No. 1, Visum Capital will develop, implement, and maintain a corporate ESMS across all projects and operations. The ESMS will incorporate (but not limited to) the following elements: (i) E&S risks and impacts identification process; (ii) plans and specific management programs to mitigate E&S risks and impacts, including procedures for site screening and selection, as indicated below; (iii) stakeholder engagement; and (iv) monitoring and review, in line with PS requirements, described in the paragraphs below.

Visum Capital, as part of their management system, will undertake to develop a site screening and selection procedure that includes screening and assessment criteria related to: (i) land acquisition as per IFC PS5 (if applicable), (ii) potential impacts on the community surrounding, and (iii) risk and impacts to biodiversity, indigenous peoples, as cultural heritage as per IFC PS 6, 7 and 8 respectively (if applicable) (ESAP Action No 2)

Organizational Capacity and Competency:

Visum Capital 's E&S aspects mostly related to construction activities are currently managed by the property management department, and the sustainability aspects are under a third-party responsibility (VAV capital). The E&S officer is the deputy property manager. Visum Capital will clearly define the corporate E&S roles and responsibilities, including E&S management system implementation and operation, ESG performance monitoring and compliance reporting to senior management, and for overseeing community/stakeholder engagement and community grievance mechanism as discussed below. Furthermore, Visum Capital will design and implement an E&S training program for their staff. Training will include health and safety aspects, risks and impacts, management of contractors, stakeholder engagement, and ESMS plans, and procedures aligned with IFC PS1 (ESAP Action No. 3).

Monitoring and Review:

The company is implementing a number of key performance indicators (“KPIs”), which will monitored on annual basis in line with PRI recommendations, mostly oriented to energy efficiency, waste management, among others. Visum Capital oversees performance of their contractors and sub-contractors engaged in construction of its assets through a supervisor or “interventoria” which its responsibilities are defined within binding legal contracts. Other aspects such as permits, or licenses required for the operation phase of its assets are monitored by the property manager in most of its assets, “Inverlink Estructuras Inmobiliarias”. However, Visum Capital does not have a formal procedure to undertake monitoring and review of E&S performance at its operations and projects. Visum Capital will undertake to develop E&S monitoring and reporting procedures, including procedures to oversee its operations and projects construction. The procedures will define monitoring mechanisms and KPIs, including environmental, occupational health and safety and social KPIs (Please see ESAP Action No.1).

Emergency Preparedness and Response

Visum Capital has implemented a corporate template for emergency planning and emergency preparation plans (or emergency preparedness and response plan, “EPRP”) for all facilities. The EPRP covers the probable emergency scenarios based on a risk analysis, and include fire, earthquake, violent person and terrorism, civil unrest, accidents, flooding and natural disasters. The plan describes processes on assessment of emergencies, decisions on evacuation, and detail procedures, as well as the roles and responsibilities of various employees and teams. An annual calendar is prepared for training on different risks and emergency drills, at least twice a year are planned and conducted.

Emergency plans are supported by volunteer emergency brigades who are highly motivated and trained in all facilities. The company participates in the annual emergency day in Colombia, which seeks to improve planning, coordination and communication between public and private entities and the community, for an effective response during emergencies.

 Human Resources Policies and Procedures, Working Conditions and Terms of Employment

At the time of IFC’s review, Visum Capital has 11 direct employees (55% men and 45% women).

HR practices of Visum Capital include polices and detailed procedures such as workplace internal policies that provide details of hours of work, benefits, minimum age, non-discrimination, anti-sexual harassment, grievance mechanisms, and termination procedures.

Procedures provide guidance to all employees on dealing with stakeholders and communication; conflicts of interest; human rights; community and public relations, among other aspects. Visum Capital has a whistleblower procedure that addresses offences, violation/non-compliance of company’s policies/procedures; health and safety risks; and unprofessional and inappropriate actions. This mechanism is anonymous and confidential.

Visum Capital’s HR policy includes provisions relevant to prohibition of child and forced labor; meeting minimum employment age requirements, rights to freedom of association, collective bargaining, and worker grievance mechanisms in line with PS2 requirements. Visum Capital complies with national requirements related to minimum wage, benefits, working hours, shift times and overtime payment.

Workers Engaged by Third Parties

Visum’s constructions activities rely on contractors. Visum Capital delegates the E&S responsibilities to the constructor companies through binding legal contracts. Among those responsibilities, the Contractor is required to design and implement proper measures in order to prevent the pollution and comply with the E&S country law.

Visum Capital will upgrade their contractor management procedures to include relevant IFC PS 2 labor provisions of their contractor’s workers. The contractor management procedure will define and establish contractual E&S requirements for contractors to comply with the company’s E&S policies and procedures, including compliance with IFC’s PSs, as relevant and applicable to the contractor’s activities, oversight procedures for contractor E&S performance, and actions to be taken when contractors are found out of compliance. The contractor management procedure will include: (i) minimum E&S requirements for contractors in line with the IFC PSs (including mandatory competency trainings etc.), (ii) E&S pre-qualification criteria and process, (iii) communication and training, (iv) E&S audit, (v) requirements and process for E&S risk assessment prior to work commencement, (vi) E&S monitoring and reporting (including performance indicators), and (vii) requirements and provisions regarding compliance with labor host country law and PS2 (including non-discrimination, compensation, training, timely payment of salaries, freedom of association, no child/forced labor, grievance mechanism, occupational health and safety, etc.)  (ESAP Action No.4). 

Occupational Health and Safety (“OHS”)

Visum Capital, through an external consultant, monitors OHS aspects associated with its operations, including an emergency response plan, LFS measures, safety training and emergency drills, incidents management, among others.

As per ESAP Actions No. 1 and 3, Visum Capital will develop procedures to ensure oversight of occupational health and safety performance of their contractors during construction.

COVID-19 Response

As a result of the COVID-19 pandemic, Visum Capital has not laid-off workers but have made temporary adjustments to its workforce by adapting to both national and local labor laws, such as flexible shifts and mandatory requirement to attend in-person meetings only for team planning every week and commercial meetings with clients. Visum Capital is back operating at its offices since August 2021 and gradually resuming pre-pandemic conditions.                                                  

 Resource Efficiency and Greenhouse Gas (“GHG”) Emissions

The company has implemented resource efficiency initiatives, for example, conversion of all lighting to LEDs; installation of Solar PV panels; rainwater harvesting for flushing and gardening purposes; installation of aerators in the taps; installation of motion sensor for lighting systems.   Visum is committed by its Policy with adoption of sustainability criteria in the planning and architectural design of all facilities. The project’s use of energy and emissions, including future projects in the next years, are expected to exceed 25,000 tons CO2eq/year. The company will use an internationally recognized methodology, and local regulations, to estimate and report annual GHG emission levels – refer to the ESAP for details (ESAP No 5).

The next development to be constructed by Visum (large warehouse facility in the Bogota area - Colombia) is planned to obtain the LEED certification, and the design incorporates efficiency in the five: sustainable site selection, water efficiency, energy and atmosphere, materials and resources and indoor environmental quality. Additionally, Visum is in the process of evaluating the certification of existing assets with IFC’s EDGE or LEED certification. The REIT is committed to implement green certification (LEED or EDGE) for all future developments.

All the existing assets are connected to the country's aqueduct and energy network. All facilities, via the respective suppliers, monitor the electricity and water consumption and report to the asset manager. In the case of energy consumption, renewable energy providers are being contracted aligned to corporate policy.

However, Visum Capital has not established a set of KPI’s for energy and water consumption for all types of l facilities in Colombia. As per ESAP No 6, the company will develop a set of indicators to benchmark all facilities’ power and water usage (e.g kwh/m2, m3 water/m2 or m3/person). 

Water and Wastewater

Water for most facilities is sourced from the public systems. The treatment is provided through filtration, softening and disinfection, and reverse osmosis, as necessary. Water quality is tested externally as well as internally by the asset manager twice a year.

All facilities are conducting the respective effluent testing of the wastewater quality and the results are in compliance with the national standards and World Bank Group (WBG) General Environmental, Health and Safety (EHS) Guideline’s guidance values. In few cases, the facilities are not connected to the public sewage system, and for those facilities the company provides wastewater treatment plants, which have the respective permits, proper operation and tested on regular basis for certified third-party contractors. Any future facility which wastewater needs to be treated and discharged to bodies of water, will be required to comply with the guidance values defined in the WBG General EHS guidelines.

Solid Waste Management

Waste generated from the current operations include food waste, plastic bottles, cans, paper/cardboard, light bulbs, etc. Each facility has a waste segregation and storage room (recyclable, organic, ordinary, and hazardous waste), where waste is periodically collected by licensed third-party contractors. There is a corporate level waste management plan for collection, storage, handling, recycling, accounting, reuse and final disposal of waste, which are handled by contractors or government agencies who are licensed by local authorities.

During the construction process, the construction company will manage the waste generated and will be responsible for the correct disposal or subsequently usage in accordance with local regulations, which are in line with IFC PS requirements.

Hazardous materials

Hazardous materials are managed as per their classification, and per the information provided in their material safety data sheet. Visum also tracks consumption in each facility in regular basis. Chemicals are utilized in controlled quantities, for cleaning and other controlled uses such as for basic maintenance in the facilities. Also, there is ammonia in refrigeration systems and diesel fuel for emergency power generators and natural gas for cooking facilities.  The company will perform a safety audit, to further identify and mitigate potential hazardous materials (such as ammonia in refrigeration systems, combustible/flammable liquids and gases mainly for cooking) as discussed below, under PS4.

Visum has an established pest management plan and selection of pesticides is controlled by asset manager, with a preference for the selection of natural and biodegradable products or mechanical systems.

 Community Health and Safety

Visum has a set of fire safety procedures describing the actions to be taken in the event of fire, mechanisms for fire detection and prevention, evacuation procedures, roles and responsibilities of the staff, and are reviewed regularly through pro-active measures with the tenants of the facilities. Each facility undertakes fire drills at its premises as defined in Colombian government regulations. Each drill is followed by an assessment of observed gaps, with corrective actions to be sent to the asset management team and discussed for improvement.

All designs and architectural projects of facilities (all types) are carried out by specialized architecture and engineering design companies with recognized experience in the particular type of development or asset, in line with the local regulations and international good practice.

As part of the corporate sustainable approach for the operations, the design evaluates important aspects of the project, including integrated design and strategic solutions approach, location, access roads and public transportation, water and energy efficiency, materials and resources analysis and interior ambient quality, as well as other green building features.

The facilities in the company’s portfolio have adequate life and fire safety (“L&FS”) infrastructure and the systems are properly operated and maintained.

The buildings have been developed complying with the regulation of the year of construction in terms of exit doorways and emergency exit stairs. The width of the means of egress (i.e. main corridors, doors, stairs) have been designed to allow for egress based on occupancy load. The fire safety equipment includes different types of portable fire extinguishers, smoke detectors and fire alarm, manual call points; sprinkler systems, fire pump systems, hydrants, fire hoses/reels at every floor, firefighting capabilities, fire alarm control panels and public address systems for notification of tenants, own personnel and visitors.

As part of ESAP No 7, Visum shall include all the required L&FS features in a future corporate guideline (L&FS facilities guideline) applicable to new buildings, including Falabella warehouse development in Bogota, and those programmed for extensive renovation, considering the elements described in the L&FS section of the WBG General EHS Guidelines, aligned with the national regulations and one international fire safety code (e.g., NFPA 101). Also, Visum will include features of accessibility requirements to be applied in new buildings.

For the existing assets, the company has planned for improvement/upgrade of L&FS systems and architectural features (exit stairs, fire doors, etc.), that will be implemented in the Future. Also, the company has a detailed program for Operations and Maintenance (“O&M”) of L&FS systems (i.e. Technical Annex) that is attached to the tenant occupancy contracts. The plan includes the frequency and procedure for the inspection, testing and maintenance of L&FS systems aligned with international codes (e.g 72 “Fire Alarm Systems”).

Additionally, the asset manager performs three safety and fire audits per year and the implementation of the recommendations are monitored by senior management. The safety issues reported by tenants are recorded, attended and resolved in less than one week, or on immediate basis (less than 4 hours) for critical assets (e.g data centers). However, based on direct observations of the visited assets, as per ESAP No 8, the company will perform a safety audit of all assets, focusing on fire protection requirements in the main electrical rooms, emergency diesel generators, refrigeration systems utilizing ammonia, and other special risks in their facilities (e.g. cooking equipment), combustible/flammable liquids and gases, and large storage areas.  

Security Personnel

Visum has developed and implemented corporate security policy and procedures, including Closed- Circuit Television CCTV, visitors’ access control, surveillance, regular patrol, incident monitoring database, and safety escort service by security staff and third-party contractor managed by Visum. All security staff are unarmed. The security contractor is accredited under Colombian rules for the provision of these services and have the responsibility to prepare and update annually the Security Risk Assessment per facility.

The company also works with Business Security Front (Frente de Seguridad Empresarial) consisted of national police, criminal investigation department, and Interpol (The International Criminal Police Organization) whose responsibility is to support the companies with safe operations through the prevention, provision of criminal statistics information, and trainings related to the crime protection. Visum is officially incorporated as a group member of the Business Security Front. According to the company, there have not been incidents or grievances expressed by the users or communities derived from its security arrangements.

There are approximately 259 security personnel throughout Visum’s facilities, of which 40% of them are women as of January 2022. Security personnel participate in trainings on the HR policy and procedures, code of conduct, human rights, and principles of proportionality as per the Colombian legislation (i.e., Colombia has legally committed to the implementation of the Voluntary Principles on Business and Human Rights since 2009).