If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the PSs.                                                                                     

This is a category B project, according to IFC’s Policy on Environmental and Social Sustainability. Based on information reviewed by IFC, the proposed business activities are considered to involve potentially limited adverse environmental or social risks and impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures.

Policy

BlaBlaCar’s has developed and implemented six corporate principles for its operations, that include the company’s objectives and the means to achieve them, but the company does not have a corporate E&S policy. As per ESAP item #1, the company will develop: i) a corporate E&S policy defining the environmental and social objectives, including GHG targets, and specifying that the business activities will comply with the applicable laws and regulations of the countries where BBC operates; and ii) a risk assessment policy outlining the main E&S risks related to BBC’s operations as well as the measures to mitigate them. 

Identification of Risks and Impacts

The company has been implementing different risk identification and mitigation processes for the services it provides.

Carpool drivers use BlaBlaCar to share the costs of their ride with passengers. and the company does not allow drivers to make a profit. The terms and conditions (T&C) include a specific section on “non-commercial and non-business purpose” stating that drivers must agree not to request a cost contribution higher than the actual incurred costs. In addition to provisions included in the T&C, BlaBlaCar caps the maximum price that drivers can request. The platform offers several features to promote trust and safety among its users, such as identity checks of the members (drivers and users), and ratings. For more details, please refer to section PS 4: Community Health, Safety & Security below.

For the bus marketplace, BlaBlaCar partners with different bus operators to sell their tickets on the platform. The company does not operate any buses and works only with licensed bus companies in Brazil. Regulations for bus operators in Brazil include complying with i) annual inspection conducted by the regulatory agency, ii) preventive maintenance, iii) updated defensive driving course, iv) availability of accommodation and cafeteria for drivers, among others. BlaBlaCar verifies bus operators’ operating licenses before engaging with them.  As described in ESAP item #2, BlaBlaCar will establish a selective review procedure of bus operators in Brazil to ensure that the bus operator companies comply with local Brazilian regulations regarding road safety and labor conditions. Based on the findings, BBC will propose recommendations to the bus operator through an audit report including proposed corrective actions and timelines. The bus marketplace lead in Brazil will oversee the development and implementation of the audit plan.

BlaBlaCar’s due diligence for merges and acquisitions (M&A) of other platforms (APPs) includes the review of financial, compliance, legal and human resources issues, among others. In addition, the company prepares a post-merger integration plan to make sure there is a proper integration of processes and culture among the new workforce. Going forward, as stated in ESAP item #3 BBC will develop a documented M&A procedure to include E&S aspects (e.g., safety records, GBV, harassment, child protection, labor and working conditions) in the due diligence process, in line with the IFC’s PSs requirements. The head of strategy and corporate development will be responsible for the development and implementation of the procedure.

Organizational Capacity and Competency

BlaBlaCar has an environmental, social and governance steering committee composed by six members, including the CEO and the sustainability manager. The committee meets every quarter and decides the company’s ESG strategy and objectives as well as the actions needed to achieve them. The head of facilities is responsible for ensuring workplace conditions comply with local regulations and the vice-president of talent management is responsible for Occupational Health and Safety (OHS) issues, including employees’ training on OHS aspects and the performance and implementation of the workplace risk assessment and associated mitigation measures. At the country level and depending on the size of the workforce, there are one or two people responsible of aspects related to human resources and facilities as well as people overseeing issues related to the bus marketplace business unit. The company’s organizational capacity and competency is commeasured to the project’s level of risk.

Emergency Preparedness and Response

The company has a corporate crisis management handbook that outlines the procedure to manage catastrophic situations or incidents (e.g., road/traffic accidents, severe weather, social unrest), that may have escalated. The handbook includes roles and responsibilities of the crisis management team as well as a roadmap to develop an action plan and a communication plan. In addition, BlaBlaCar performs an average of four large scale crisis simulations per year and trainings on the content of the handbooks are held on an annual basis. The company’s emergency response is generally consistent with PS1 provisions.

BlaBlaCar employs approximately 732 employees worldwide out of which 22 are located in Brazil (50% of the workforce in the country are women).

Drivers using BBC’s platform are private, non-professionals (e.g., do not earn profits, do not work for the platform). Therefore, labor law is not currently applicable to BBC’s relationship with car owners/drivers nor are BBC’s HR policies and procedures. There is currently a draft regulation being examined in Brazil that excludes carpooling from the scope of transport law.

For the bus marketplace, BlaBlaCar only sells bus tickets and does not operate buses nor directly employs any drivers.

Human Resources Policies and Procedures

Human resources (HR) policies as well as other procedures are based on French labor regulations and applied at the corporate level with most of them are being adapted to the specificities of each country. HR documents cover areas such as recruitment, contracts management, payroll, compensation, performance management, internal rules and remote policy, among others and are generally in line with IFC PS2 requirements.

Working Conditions and Terms of Employment

BlaBlaCar’s employees in Brazil work 40 hours per week. In addition, the company provides life and health insurance, meal and transportations vouchers, and free travel via the BlaBlaCar app, among others. In addition, the company provides a 22-day parental leave for secondary care givers across all offices independently of local regulations and a corporate remote policy that outlines the principles for remote working. The company’s terms of employment are consistent with PS2 requirements.

Workers’ Organizations

In alignment with Brazilian regulations and PS2 provisions, according to the company’s management, BBC does not discourage workers from joining unions or prevent workers from forming organizations. The law provides for freedom of association for all workers, the right to bargain collectively and the right to strike. BlaBlaCar’s latest Collective Bargaining Agreement (CBA) in Brazil was signed on January 1st, 2022, with two unions. The CBA covers all workers except for interns.

Non-discrimination and equal opportunities

BlaBlaCar’s Code of Conduct includes provisions on non-discrimination and equal opportunities as well as against slavery, human trafficking, and harassment. The code is applicable to all levels within BlaBlaCar and is approved by the CEO. Besides the Code of Conduct, the company has a diversity and inclusion policy and a diversity, equity and inclusion strategy that was launched in 2021 and includes hiring objectives for underrepresented groups, inclusive job descriptions, training programs and working groups.  In addition, there is a diversity and inclusion policy in Brazil that outlines regulatory requirements related to freedom of belief and the inclusion and non-discrimination of people with disabilities and the lesbian, gay, bisexual, transgender/transsexual, queer/questioning, intersex, and allied/asexual/aromantic/agender (LBTQIA+) community. Provisions for non-discrimination and equal opportunities are aligned with PS2.

Labor Grievance Mechanism

BlaBlaCar has a harassment and discrimination alert procedure that outlines the channels to submit grievances as well as the procedure to treat them. Per ESAP item #4, BBC will update its harassment and discrimination alert procedure, to document the processes on: i) how to access reporting channels; ii) who is responsible for managing what aspects of the grievance handling process; iii) support services affected workers can access (e.g., medical services, counseling, legal assistance, job reassignment, etc.); iv) timelines for responding to reports and completing investigations; v) how decisions are made and reported, and how they can be appealed. The procedure will allow anonymous complaints to be raised and addressed, while keeping anonymity throughout the process. Staff involved in managing internal grievances will receive specialized training.

Occupational Health and Safety

The company has a process to identify and mitigate occupational risks in line with French regulations and consistent with good international practices. Identified risks are mainly associated with ergonomics, remote work, impacts of COVID-19 and psychosociology. Mitigation measures include the use of personal protective equipment and social distancing (COVID-19), provision of adequate use of working equipment (ergonomic risks) such as proper chairs and training. 

In 2020, the company’s greenhouse gas emissions, related to its internal operations, offices and data centers, were estimated to be around 1,685-ton carbon dioxide equivalent per annum. Purchases (e.g., consulting fees, telecommunications, offices supplies) made up 65% of total emissions, followed by travel (13%), buildings (12%) and IT facilities (10%). There was an 18% reduction in emissions compared to 2019, mainly due to reduced activities resulting from the COVID-19 pandemic. Other environmental initiatives include recycling and composting practices across offices. The company’s new headquarters in Paris will be powered by renewable energy.

The company is currently working on estimating the carbon footprint of all trips booked through the app, including carpooling, bus marketplace and operated buses. An internationally accepted methodology, in line with GHG Protocol and/or World Resource Institute (WRI), is expected to be used for the carbon footprint calculations. 

Traffic and user safety is expected to be the principal interface between the project and communities around which the company operates. BBC has implemented a number of mitigants to reduce risks that may impact communities. For instance, BlaBlaCar’s website hosts a help center that includes different tools to promote road safety such as a printable checklist to be filled by drivers when preparing for a ride, road safety tips, information on insurance and traveling abroad, identification verification of users, analysis of comments and grievances made on the platform, among others. 

In addition, the BlaBlaCar’s platform has different safety features to promote trust among its users. All members need to provide and verify their mobile phones before publishing/booking a ride or messaging other members; members may also verify their e-mail addresses and identification documents. Verification of identity is optional, and details of the passports and national identity cards are kept strictly confidential. Going forward and as mentioned in ESAP item #5, BBC will agree with IFC on any actions (e.g., if relevant, by adding yes/no questions, or as part of the super driver initiative, or checking expiry dates of insurances/licenses, etc.)  to improve the carpool drivers’ license and their insurance controls.

Based on their carpooling experiences, members can provide ratings to each other. A passenger can also rate the drivers’ driving skills in an anonymous way. An average evaluation will be displayed on the user’s profile based on the ratings.

Profile and car pictures, ratings, biographies, rides and ride comments are reviewed automatically (algorithmic within the App) and/or manually by BlaBlaCar’s agents. If T&C are violated, agents can take different actions such as performing a follow-up call to verify information or suspending a member. In addition, users can report suspicious or inappropriate messages, rides or profiles, as further discussed in the external grievance mechanism section below).

BlaBlaCar has also a “ladies only” feature that allows members to plan a trip where the driver and all passengers are women. The feature is rarely used and only 0.6% of rides are performed under the “ladies only” option. As per ESAP item # 6, the company will mitigate potential GBV risks that might be related to its operations and will implement GBV actions (e.g., dissemination campaigns of the “ladies only” option and the BlaBlaCar’s commitment against gender-based violence and harassment).

The company’s child carpool travel policy for Brazil, states that children up to 16 years old must always be accompanied by a legal guardian and children above 16 years of age can travel alone as long as they have parental authorization. The legal guardian must contract the driver and check if she/he agrees to drive the minor. These provisions are aligned with the country’s legal regulations.

As for the bus marketplace, BlaBlaCar engages only with licensed buses that comply with local regulations. For additional information please refer to ESAP item #2.

External Grievance Mechanism

BlaBlaCar’s website help center includes several articles containing relevant information for carpool and bus users such as instructions to report bad behavior or requirements to travel abroad. In addition, the help center allows users to submit requests for further information or complaints. Users can also reach out to BBC through social media such as Facebook and Twitter.

The company has a team of 350 people working to answer questions, complaints and manage incidents.  There are 10 people working for the Community Relations team in Brazil, that are available to provide support 7 days a week. Moreover, the team has a keyword alert system to handle safety reports in priority.

Bus operators selling tickets through BBC’s platform have a 24-hour Customer Service telephone available. In case a complaint is addressed to BlaBlaCar by the customer, BlaBlaCar transfers the grievance to the Transport Operator’s Customer Support Representative. According to the distribution contract, the transport operator is responsible of handling any customer complaints related to the transportation services.

Overall, BlaBlaCar’s external grievance mechanism is consistent with provisions established under PS1. However, to further promote safety among users, as established under ESAP item # 7 enable BlaBlaCar to improve its emergency communication procedure (e.g., if relevant, by enabling an emergency button on its app that will automatically contact the user with the Community Relations team to handle the issue).