Based on IFC’s review of the project, no impacts are expected that might trigger the following Performance Standards:

PS5 is not applicable because the land for the hospital expansion already belongs to AMC, while the two properties for the office expansion and the new clinic at Takoradi were acquired through a willing buyer/willing seller transaction. There are no residents in both sites.

PS6-PS8 are not applicable to the project as all the sites are located within urban areas with no known presence of indigenous peoples, natural/critical habitats and where the presence of cultural artefacts is unlikely.   

  This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. Key E&S risks and impacts associated with project are expected to include: (i) company systems for E&S management of its operations in compliance with legal requirements as well as IFC PSs; (ii) assurance of fair, safe and healthy working conditions during construction and operation including infection control and COVID-19 management; (iii) energy use and resources consumption; (iv) management of hazardous health care waste; (v) life and fire safety; and (vi) security.      

  Environmental and Social Management System (ESMS)

The company does not have an overarching E&S policy nor an ESMS per IFC PS requirements. AMC will develop an ESMS, in line with IFC PS requirements, that will include (i) E&S Policy statement outlining AMC’s commitments in management of E&S risks and impacts arising from the business; (ii) methodology for E&S risk assessments; (iii) management plans and procedures to mitigate the identified risks and impacts including water and energy use, safe management of solid waste, effluent and hazardous materials, management of spread of infectious diseases, ethical management of sensitive medical data, OHS risks including radiation exposure, life and fire safety; (iv) implementation of an internal and external audits for (but not limited to) management of biomedical waste, energy and water (ESAP #1). The ESMS requirements will be trickled down to other clinics and sites operated by the company.

Identification of Risks and Impacts

An ESIA study was undertaken for the existing HQ building, approved by the local authorities. For the establishment of the maternity wing, the company will undertake an internal E&S risk assessment covering both construction and operational phases. A Construction Environmental Health and Safety Plan (CEHSP) will also be developed following this E&S risk assessment and will be submitted to IFC for review prior to construction of the maternity wing (ESAP #2a). CEHSP compliance reports from the contractor, will also be presented to the project management team as part of construction progress reports.

AMC will appoint a suitably qualified and experienced consultant to undertake a site-specific E&S risk assessment of the Takoradi clinic. The E&S risk assessment will be conducted in line with Good International Industry Practice (GIIP) and the requirements of IFC Performance Standards. The assessment will cover (i) identification and mitigation of any pre-existing E&S risks, (ii) identification and management of E&S risks for the remodeling/refurbishment and operation phases of the facility; and (iii) the requisite mitigation/management and monitoring plans. The ESIA report along with the site specific CEHSP will be submitted to IFC for review prior to commencement of renovation and re-modelling activities (ESAP #2b).

Management Programs

AMC will establish management programs consistent with the E&S policies to cover all identified E&S risks. Areas of focus are expected to include management of labour issues, health and safety, waste, fire safety, water and utilities use as envisaged in ESAP #1. The management programs will also integrate mechanisms for management of contractor’s E&S performance for construction or renovation activities at AMC facilities.

Organizational Capacity and Competency

The contractor will be responsible for implementation of the CEHSP with oversight from the company’s project management team. The AMC Medical Director is currently charged with hospital operations’ risks and impacts that relate to occupational health and safety, fire safety and spread of infections as well as waste management, with support from the COO on regulatory compliance including EHS permitting. The HR Manager is charged with labour management. As per ESAP #3, the company shall appoint an Environmental, Health and Safety (EHS) manager from the existing management staff, who will have the responsibility of developing and implementing the ESMS, conduct monitoring of E&S performance and report to AMC management team on E&S performance and challenges. The EHS manager will be supported by external consultants on specific E&S risks such as life and fire safety, waste management and hazardous materials management. The HR manager and other operational managers shall also support the EHS Manager on management of specific E&S risks and impacts under their purview.

Emergency Preparedness and Response

The company’s existing health and safety policy requires compliance with local fire safety requirements to enable safe evacuation of occupants at AMC premises in the event of fire. It also requires provision of means of egress in the event of blocked paths or spillages at the premises and outlines management and staff responsibilities in such events. The Medical Emergency Evacuation Plan also covers first aid and evacuation of construction workers at AMC premises in the event of an incident or accident, while allowing for engagement of third-party ambulatory services and medical facilities when the circumstances are beyond AMC capacity. These policy commits the extension of these procedures to contractor staff working on AMC premises.

As part of ESAP #2, the renovation and remodeling phase, emergency preparedness and response plans (EPRP) will be integrated into the CEHSP for implementation by the contractor with oversight from the company’s project management team.

As part of ESAP #1, AMC will also develop and implement an emergency preparedness and response plan in line with IFC PS1 requirements for adoption at the Accra hospital, office annex and Takoradi clinic including all actions to cover the foreseeable risk scenarios, safety training program for all employees such as medical personnel, health and safety staff, fire marshals and first aiders, mechanisms for coordination with first responders and other relevant third parties, as well as means to inform affected communities during emergencies, aligned with the company’s stakeholder engagement plan.

The proposed Takoradi Clinic and Accra Maternity Wing designs allow for life and fire safety (L&FS) provisions including alarm and detection systems, means of egress and fire suppression and control measures. As part of ESAP #1, AMC will develop fire safety policy and procedures that will provide the requirements and actions to prevent fires and respond to fire risks which will include provisions for periodic inspections, management of changes to the facility, training, fire drills, awareness programs and related communications materials, allocation of roles and responsibilities to relevant staff.

Monitoring and Review

AMC will establish monitoring and review procedures to monitor and measure the effectiveness of the ESMS. The ESMS will integrate mechanisms for reporting to the hospital senior management and the hospital board. In accordance with ESAP #1, the hospital management team will also ensure that adequate records are kept for ESMS elements that are monitored by government or other third-party agencies and authorities.     

  AMC currently has 85 direct workers of which about 59% are women. The company has also contracted 32 staff, mainly locals, as medical specialist (mainly doctors), sanitation and security personals, where 50% of them being women. An additional eight direct staff will be hired for the operational phase of the project, while 20 contracted staff will be engaged specifically on the maternity wing and the new clinic at Takoradi.

Human Resources Policies, Procedures and Terms of Employment

Documented company HR policies and procedures are provided to staff at induction in the form of the AMC employee handbook. The handbook is generally in line with IFC PS2 provisions and for the identified gaps, ESAP items are agreed as referred in the following sections. The handbook outlines the hours of work, mechanisms and timelines for payment of wages, approvals for overtime work and payment terms for overtime work, authorized claims and related mechanisms for reimbursements of such expenses. Information on health cover for staff and their families is provided in a stand-alone medical policy that covers both regular and temporary employees.

The employment contracts also provide information on probation period, salaries, allowances, annual leave, sick leave, maternity and paternity leave, termination on resignation and redundancy as well as compensation for termination on grounds of disability due to both occupational and non-occupational illness. The contracts also indicate the relevant local laws related to the terms provided in the contract. The company will integrate oversight and reporting on labour and working conditions for direct and contracted workers in accordance with IFC PS 1 and 2, as part of the social component of the ESMS under ESAP #1.

Non-Discrimination and Equal Opportunity

The company has an equal opportunity and anti-bullying policy provided in the HR handbook with clear definitions of discrimination, with references to the measures provided by local law and it includes anti-harassment/discrimination measures covering pregnancy, breastfeeding, disability, age, sex, sexual orientation, gender identity, race, physical features, political beliefs, marital status, parental status or persons associated with anyone with these characteristics. The handbook outlines specific response mechanisms referring to confidentiality, with measures and corrective actions at individual and company level. A stand-alone Worker’s Code of Conduct provides further details on expected behavior in the workplace. The company’s disciplinary principles and procedures, as defined in detail within the AMC Code of Conduct, require managers to undertake a full investigation before instituting disciplinary measures that include a hearing, verbal warnings, dismissal with or without notice and mechanisms for appeal.

Worker Organisations

The HR policy is silent on workers’ rights to form and join workers organizations of their choosing. AMC will review the HR handbook to include policy statements that recognize the workers’ rights to freedom of association and will not restrict the workers’ rights to develop alternative mechanisms for expressing their grievances and protect their rights on working conditions and terms of employment. AMC will not seek to influence or control these mechanisms (ESAP #4).

Retrenchment

In 2021, the company ended its operations at Tarkwa Mine Hospital. AMC’s management confirmed that the new hospital operators absorbed all the former AMC staff, and no complaint was raised and/or no case was filed against AMC. Although no further retrenchment is anticipated, the company does not have a documented retrenchment policy in place. AMC will review and update the employee handbook and will outline termination policies and procedures, including termination in the event of retrenchment. The policies and procedures shall include clear statements on incorporation of mechanisms to ensure non-discrimination through-out this process. The update will also incorporate the requirement for development of a retrenchment plan prior to implementation of a termination process (ESAP #4).

Grievance Mechanism

The HR handbook provides a grievance policy and procedure, for employees to raise grievances with their manager both formally and informally, which allows escalation of grievances to higher management levels as needed. The company will review and update the grievance policy and procedure to (i) allow workers, including contractors, to raise grievance with independent managers such as the HR office, (ii) provide mechanisms for raising and addressing anonymous complaints, (iii) provide templates for record keeping on hearings, investigations and resolution of complaints. The revisions in the grievance policies and procedures should not impede access to judicial or administrative remedies provided for in local law (ESAP #4).

The AMC Code of Conduct indicates that bullying, physical violence and assault as actions that would result in disciplinary action. To facilitate alignment with PS 2, the company will(i) revise their sexual harassment policies to include gender-based violence (GBV) in the workplace, (ii) update the incident investigation procedures and management responsibilities in the grievance redress procedures to facilitate survivor-centric mechanisms for dealing with GBV related complaints and (iii) provide sensitization and necessary training to staff and management on these adjustments to the grievance mechanism. (ESAP #4).

Child and Forced Labour

AMC has a stand-alone policy on child and forced labour that prohibits use of child and forced labour, including strategies for the identification and verification of the age of workers and procedures to be extended to clients and suppliers. For forced labour, the policy also requires self-assessment and periodic audits including suppliers, especially those in the fabric and trimming sector. AMC shall integrate these policies and procedures into the company ESMS as part of ESAP #1.

Occupational Health and Safety

The AMC Health and Safety Policy requires all managers and departments to carry out risk assessments for the employees and other persons accessing AMC premises. Contractors are also required to undertake specific risk assessment for their activities. The health and safety policy and AMC employment contracts outlines management and staff responsibilities. The company also conducts internal health and safety audits and develop and implements corrective actions in line with the findings.

AMC will develop and implement a formal Occupational Health and Safety (OHS) program as part of ESAP #1. Procedures and documentation under the OHS program will cover, department / activity specific risk registers, mechanisms for identification OHS risks; operational manuals and procedures; incident reporting and investigation; permits to work and related controls; emergency prevention preparedness and response; staff training; performance measurement and monitoring; mechanisms for preventive and corrective action; organization, roles and responsibilities; and internal and external reporting mechanisms. The safety measures will include (but not limited to) practices to facilitate safe handling of hazardous materials, drugs or equipment (e.g., X-ray devices), hazardous waste management, road safety in use of ambulances, life and fire safety, infection control and medical examination of employees. The OHS Program will be cascaded to all AMC sites and facilities.

AMC will monitor and report on OHS performance and will support the formation of an OHS Committee in line with the local legislation. The committee will conduct meetings and facility inspections as part of its task to identify potential risks, address worker’s concerns regarding OHS and ensure proper implementation of the OHS program.

For the construction phase, AMC will require from its contractor to develop and implement OHS measures under the Accra and Takoradi sites CEHSPs (ESAP #2).

Third Party Workers

The company requires its suppliers and clients to inform their employees of their rights and obligation under applicable domestic law. The suppliers and clients are also required to designate a company representative to oversee compliance with the requirements contained in the AMC Social Standards. The AMC Human Resource and Compliance Manager is the point of contact with clients and suppliers on these issues.

As part of ESAP #1 AMC will also develop contractor and supplier EHS performance review and reporting mechanisms with clear indicators for the procurement, operation and exit phases of engagement with contractors and suppliers.   

  Resource Efficiency and Green House Gas (GHG) emissions

Water is supplied to Accra site through an on-site borehole and by the municipal water supply network. Water consumption is estimated to be around 7,300m3 per annum. The site is connected to the national grid and electricity consumption is estimated to be around 665,000 kWh per annum. AMC has undertaken an independent study on its current power consumption and into the near future and is exploring the possibility of switching to solar energy either partially during the day to switch back to the national grid in the evenings and/or completely switching off the national grid to depend solely on solar energy. The site is also served by back-up diesel generators in the event of power outage. Water supply for Takoradi Clinic will be from an on-site borehole and from municipal sources as back up.

As part of ESAP #1, AMC will establish a procedure to analyze annual electricity and water usage records, develop improvement plans as needed, and report on performance.

GHG emissions of the project is estimated to be significantly low and upon project completion, it is expected to be well below 25,000-ton carbon dioxide equivalent per annum.

Waste Management

The company has a solid waste management policy and procedure that requires waste segregation prior to collection by a contracted party. Hazardous wastes are collected by a municipal approved hazardous waste collector and disposed off-site. These policies will apply to the Takoradi site as well.

The two sites are served by the municipal sewerage system. Wastewater contaminated with infectious liquids, effluent with chemicals and laboratory samples, and grease from kitchen wastewater undergo specific pre-treatment on site, prior to connection to the sewer system. The same processes will apply to the Takoradi site.

As part of ESAP #1 AMC will fully integrate the solid and waste water management policy and procedures and ensure alignment with IFC EHS Guidelines for general and hazardous wastes into the project ESMS. AMC will also develop a procedure for handling, storing and disposing hazardous and medical waste and a Waste Management Plan at corporate level as part of the ESMS (ESAP #1).

Hazardous Materials Management

AMC handles and store small amounts of hazardous substances to serve its laboratories, radiology rooms and operating rooms. Laboratory chemicals include xylene, ethanol, toluene, methanol, nitrous oxide and hydrogen peroxide. These are bought in small bottles, stored in their original packages and in well ventilated, controlled areas at the AMC facilities. As part of the OHS program under ESAP #1, the company will provide the Material Safety Data Sheets for these substances and will use the information for its ESMS and training programs.    

 Community Exposure to Disease

The company has an Infection Control Policy and Procedure covering use of appropriate PPE, sanitation, management of diseases transmitted through blood, air and contact, risks involving sharps, hand hygiene, cleaning protocols and handling of contaminated materials.

The company instituted additional infection control measures at the beginning of the COVID-19 pandemic. These measures included provision of face masks to staff, additional sanitizers and hand-washing stations, provision of uber services to staff during the city lock-down period to minimize exposure in public transport and coordination with local authorities to provide vaccination to staff.

As part of ESAP #1, AMC will review existing procedures and practices to prevent the spread of infectious disease to patients and the community at large and integrate them within the company OHS Program and ESMS. A comprehensive infection control management, monitoring and evaluation program with relevant norms, regulations and GIIP will also be integrated into the company ESMS and cascaded to all AMC premises. The hospital will also review, document and integrate existing COVID 19 management protocols into the ESMS. These protocols are expected to include but not be restricted to vaccination of new staff, disinfection protocols, screening, testing and segregation of infected patients.

Life and Fire Safety

The company has evacuation procedures at the HQ building with appropriate signage to exit routes and the fire assembly points. An automatic Fire alarm system that identifies and locates source of fire, a number of water hose reels on each floor and potable fire extinguishers are also provided. The company also undertakes periodic fire drills for staff at the HQ building. As per ESAP #5a, AMC will appoint an L&FS expert to review the existing (HQ and Takoradi) facilities and suggest improvement plans (if gaps identified) per local requirements and internationally accepted L&FS codes (such as NFPA 101 of the National Fire Protection Association).

Upon physical completion of the renovations, the L&FS Expert will then verify that the systems and will provide the certification, affirming that the L&FS systems were installed as designed and are properly tested. If the certification is not issued, then an additional Corrective Action Plan with proposed completion dates and expected metrics shall be submitted to IFC (ESAP #5b).

Security Personnel

Both sites will be served by contracted unarmed security personnel. As part of ESAP #1, AMC will incorporate mechanisms to review all potential security service providers at procurement stage to check for past human rights violations. AMC will review contract templates for security service providers to include (i) codes of conduct for the security personnel; (ii) periodic training of security personnel and (iii) allowance for periodic audit of security service providers by AMC. (ESAP #6).