Environmental and Social Policies and Management System

Gozem is a relatively new company, and, while its business operations have limited E&S risks and impacts, at present, it does not have documented E&S policy or procedures. Going forward, as part of the E&S management system (ESMS) set forth in ESAP #1, Gozem will develop and implement corporate E&S policies and procedures on risk assessment of new product/service, fire safety, emergency response, occupational health and safety, road safety, passenger safety, genderbased violence (GBV), environmental management and external communication and grievance mechanism.

As part of ESAP #1, the company will formalize an ESMS in compliance with PS1, appropriate to the nature and scale of the project and commensurate with the level of its E&S risks and impacts. Key elements of the ESMS will include: (i) occupational health and safety of direct and contracted workers, (ii) road safety program commensurate with the exposure risk for drivers, passengers and third parties, and (iii) contractor management integrating an assurance mechanism to monitor compliance amongst the contractors and fleet managers with Gozem’s safety requirements including applicable national laws. As part of the ESMS, Gozem will implement policies and procedures specific to fleet managers screening and monitoring, incorporating measures to identify and address risk of child labor and forced labor, and measures to identify risks relevant to compliance with company’s policies on health and safety, induction, driver’s engagement with supervisors and managers, disciplinary measures, and termination of services.

Organizational Capacity and Competency

As a young company, Gozem is yet to develop a formal E&S management structure. At the time of the appraisal, several key positions such as the Chief Operations Officer, Chief Human Resource Officer, Country Marketing Officer were being recruited. Gozem has a small team that tracks driver metrics such as distance covered, speed of the drivers, passenger efficiency (number of passengers per day), and ensures drivers are within speed limit and within the driving zone to avoid bike theft.

An E&S Manager at the corporate level will be appointed (ESAP #2) to review and align company’s policies and procedures with IFC Performance Standards, to oversee the development and implementation of the ESMS, and to monitor E&S performance across subsidiaries including awareness and training of staff and, as applicable, to the drivers and other contractors, and corporate reporting.

Emergency Preparedness and Response

Gozem will develop and implement a corporate level Emergency Preparedness and Response Plan as part of ESAP #3, which will be adopted by the company and its subsidiaries, covering emergency scenarios and relevant responses, in line with IFC PS 1 requirements. The plan will include emergency response training program for drivers extending topics to, for example, defensive driving and fatigue management and will define the requirements in terms of relevant emergency response organization, roles and responsibilities of staff and road safety response teams which will be established in operating cities and countries. The organization will be staffed and structured accordingly.

Monitoring and Review

Gozem will develop procedures for internal monitoring, auditing, recording, performance review, identification and implementation of corrective actions and related periodic review as part of the ESMS developed under ESAP#1.

Further, Gozem will, as part of the ESMS under ESAP #1, develop a corporate risk review procedure to ensure consistent implementation and reporting from country subsidiaries to corporate. The company will implement a periodic external review program of its E&S procedures, including labor policies, and their implementation and will engage an external expert for review on compliance of company policy with legal and regulatory conditions of operating jurisdictions in relation to labor and working conditions of drivers on a periodic basis, as well as monitoring evolving labor practices.

Gozem employs 341 direct employees (33 percent female employees), 97 percent operating out of its subsidiaries in West Africa. Staff carry out the following roles: administration, human resources, financing, coaching, marketing, ride monitoring, driver contracting, and onboarding, data analyst and ecommerce.

Human Resources Policies and Procedures

Gozem has a dedicated human resources (HR) department at the corporate level and at the country level in both Togo and Benin. Terms and conditions of employment are elaborated in the Employee contracts and the Employee Handbook, including hours of work, overtime, annual leave, pay and benefits (social security), sick leave, termination and dispute settlement, among others. The Employee Handbook also outlines Gozem’s principles in relation to harassment, discrimination, and respectful workplace conduct. Gozem will review and update its Employee Handbook in relation to non-discrimination due to religious and political activities and freedom of association as per ESAP #4.

Gozem has multiple avenues for engaging with employees, including through town halls and regular team meetings where employees may bring up concerns, submit feedback to their direct manager or to HR. Complaints from drivers can be received through the app or through the Ambassadors and during routine street checks by the coaching team. Gozem will develop a workers grievance redress mechanism that formalizes the existing channels of communications and establishes procedures in accordance with IFC’s PS2 requirements, including grievance logging or recording mechanisms and provisions to raise and address anonymous complaints, as per ESAP #4. The grievance procedure will be communicated and will apply to employees, drivers, including drivers operating vehicles owned by fleet operators, and any contracted workers.

Occupational Health and Safety (OHS)

The Employee Handbook indicates that all accidents, including during employee’s commute, are to be notified immediately to the employee’s supervisor, and includes procedures to be followed in the event of an accident. Gozem partners with insurance companies to provide access to insurance to all drivers (civil liability insurance and accident insurance). Gozem drivers access insurance through Gozem financing. All drivers are insured from the moment they start providing services through Gozem App. Gozem also provides drivers with access to health insurance.

Gozem provides training on safety during onboarding of drivers, including road safety and training on use of personal protective equipment (PPE) by the driver and the passenger, hygiene, and road safety. CPR training is also offered. Gozem requires a follow up training of the driver if a complaint is filed by a passenger regarding such driver. Gozem has a team of 24 “Ambassadors” in Benin and Togo who are salaried employees liaising between the company and drivers on safety issues and who are collecting driver’s feedback and/or complaints to the Gozem.

Gozem requires drivers to use safety equipment, which is either provided upfront and paid by the drivers in installments as part of the lease-to-own package the cost of helmets and safety jackets are included in the lease. Gozem also requires fleet managers to provide drivers with helmets. Gozem conducts on-site random checks to ensure drivers are using helmets/equipment; passengers and fellow drivers can also report if a driver is not following safety practices. Gozem provides for accident support such as medical support based on insurance and monitors speed and working hours of drivers.

Such procedures will be formalized through an OHS policy and procedures covering direct staff, drivers and contractors as per ESAP #5, including measures to manage risk associated with public health and COVID-19 pandemic. The policy and procedures will also cover for route risk assessment, job safety analyses and risk assessments, including risks of GBV and harassment for female drivers, and the appropriate risk mitigations.

Independent Contractors (Drivers)

In Togo and Benin, Gozem currently has around 3,500 active drivers, with 2,000 drivers in vehicles leased by Gozem. The majority of drivers is engaged as an independent contractor. The drivers can use their own vehicles (if they meet company’s standards), Gozem’s leased vehicles or vehicles belonging to the fleet management companies and decide their own working hours and schedule.

All drivers (including those under fleet management) have to sign up to the Champion App Contract which outlines the relationship between the driver and Gozem and grants the license to the driver to use the platform. The App contract includes a disclaimer that the driver is not an employee of the company. Drivers are overseen and managed by the relevant Gozem Country office. For the lease-to-own product, the driver has a contractual relationship with the relevant Gozem Country office to lease vehicle and equipment under the Leasing Agreement.

Workers Engaged by Third Parties

As indicated, drivers can also operate under fleet managers. The relation between the company and fleet managers is governed by a Partnership contract. Gozem maintains a close engagement with fleet managers to ensure that the Gozem app is being used appropriately and drivers are trained and meet the required safety standards. Gozem currently does not set minimum requirements on labor in its agreements with fleet managers and does not have processes for monitoring compliance with national labor requirements. Gozem also engages contractors for functions such as IT, cleaners and security services. Labor-related requirements are not incorporated into contracts, and labor audits are not currently conducted.

Gozem will develop mechanisms for screening fleet managers and will define labor-related provisions to be included in the partnership agreements and other contractor contracts in compliance with PS2. The company will also develop and implement a procedure to monitor contractors’ labor performance, including labor audits as per ESAP # 1.

The company operates from leased offices, with minimal or no environmental impacts. Gozem conducts mandatory periodic safety checks and maintenance for all bikes that use the Gozem platform. Maintenance inspections of bikes leased to drivers are done monthly by the supplier of the bikes, who is responsible for management of wastes and materials.

Gozem is currently rolling out the use of a small number of e-motor bikes. The proposed investment will include expansion of this roll out. E motor bikes undergo weekly checks by the suppliers.

The Charter of Driver Good Conduct includes provisions to limit the risk that drivers hand over a vehicle to another driver for more than 24 hours without permission, carry out significant repairs without notifying Gozem, or drive an unsafe vehicles by enforcing monthly inspections. All personnel at Gozem have a duty to report if a driver is seen not wearing helmet, not having a helmet for the passenger, not wearing appropriate footwear, or having more than one passenger on the bike.

Driving under the influence of opioids is a known risk in the countries of operation. The Charter of Driver Good Conduct explicitly states that driving under the influence of drugs and alcohol is a violation which is not tolerated. While the company does not carry out any drug or alcohol tests, it monitors driver’s behaviour through customer feedback and any violation can lead to immediate termination of the contract with the driver. The company implements a disciplinary procedure which includes a system of fines, temporary suspension and termination of the contract with the drivers according to the violation. Going forward, as part of its ESMS, Gozem will formalize and implement a Road Safety Policy ESAP #1), including, among others, a mechanism for monitoring drug and alcohol use in a non-discriminatory way. Gozem will also regularly communicate its zero tolerance to the drivers, though its Ambassadors and other appropriate mechanisms.

As indicated, Gozem carries out road safety training during driver’s onboarding and, in case of violation of the code of conduct, a follow up training is mandated. Gozem is capable to track speed, location (ensuring vehicles stay within the limits allowed for leased motorbikes) and driving patterns (e.g. the system provides alerts to the tracking team if a driver is driving too fast or too slow). Driver’s driving hours are not regulated. Going forward, Gozem will develop and adopt a policy on driving hours, send push notifications to drivers when they have been driving for long hours without a break or have exceeded a threshold as defined in the policy, and implement a fatigue management program and training (ESAP#1).

Currently, Gozem requires a driving license in its policies and procedures but does not enforce it due to difficulties drivers face in obtaining a license. Going forward, Gozem under its Road Safety Policy as stated in ESAP #1 will require and ensure that all drivers meet the requirement of driver’s licenses per national law.

The company is capable to collect details on and categorize accidents through its platform, including whether there was a passenger, accident location and coordinates, whether assistance was provided by Gozem, whether insurance covers the costs and the severity of the accident in terms of injuries for the driver and the passenger and damages to the vehicle. However, the process is not formalized yet. Going forward, as part of the Road Safety Policy, Gozem will formalize the process, and include requirements for drivers on accident reporting. The Road Safety Policy and procedures will define company’s and driver’s responsibilities including: (i) minimum requirements for drivers (driver’s license); (ii) minimum requirements for vehicle conditions and maintenance; (iii) passenger’s safety; (iv) standards for and monitoring driver working hours, driving behaviour and speed; (v) response to incidents and accidents; (vi) non-discriminatory monitoring of drug and alcohol use; (vii) regular training on road safety, defensive driving and fatigue management; (viii) risk assessment (including GBV and harassment, including risks for female drivers) and (ix) periodic review and evaluation (ESAP #1).