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.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System, Identification of Risks and Impacts and Management Programs
The Group has an Environmental and Social management system - ESMS based on ISO 14001 (international standard for environmental management system) requirements, but it is not formally certified against the referred standard. Its practices are conducted in line with local law requirements, and it has obtained the required environmental licenses and authorizations for operation, which are issued by the local environmental authority in Colombia.
The group has an Environmental Policy and an OHS Policy that defines the group’s commitment to provide the human, technical and financial resources necessary to comply with relevant local regulations, implement measures to protect the health and safety of employees, and prevent and mitigate the environmental impacts associated with its operations.
Environmental, Health and Security - EHS issues are regularly assessed across all business units to identify and evaluate the magnitude of E&S risks, including procedures for identifying, managing, and monitoring impacts and risks associated with the Group’s operations. E&S impact assessment is not required for the group’s activities per the local legislation.
Additionally, the Group has an OHS Management System covering work safety and industrial hygiene. This system applies to the entire Group.
As per ESAP action No 1 the Group will expand its ESMS to all its operations including the new developments such as the pharma manufacturing facility enhancements and the ramp-up of the new hospital in Villavicencio, in line with IFC PS requirements. Additionally, the ESMS will include an Stakeholder Engagement Plan including a proper grievance redress mechanism available for construction and operation (please further details in the stakeholder engagement section below).
Organizational Capacity and Competency:
The Group has staff responsible for overseeing the environmental, social, and occupational safety issues at the corporate/group and company level. Group’s Health, Safety and Environmental team address activities mostly related to its operation and reports directly to the Managing Director.
Specifically, for Altea (pharma facilities), the staff responsible for OHS and E&S aspects report directly to the Quality/Technical Director.
The Group will clearly define the corporate E&S roles and responsibilities and design and implement an E&S training program for their staff in line with new procedures developed. Training will include health and safety aspects, risks and impacts, management of contractors, stakeholder engagement, and new plans and procedures aligned with IFC PSs (ESAP Action No. 2).
Monitoring and Review:
The Group prepares an Annual Sustainability Report, including E&S activities and results, status and/or progress of issues related to the applicable legal obligations, stakeholder engagement aspects, among others. The Group regularly conducts environmental inspections across all business units, to verify compliance with legal requirements, waste management standards and hazardous materials management at each company.
The Group’s procedures define Key E&S Performance Indicators - KPIs, (e.g., accidentality; natural resource consumption such as water, gas and energy; and effluent and waste generation). Particularly for Altea, the Company has specific procedures for EHS monitoring called “Audits and Inspections Procedure”, which defines monitoring requirements for firefighting equipment, personal protective equipment – PPE use, that relate to waste, wastewater, and air emissions, among others.
Emergency Preparedness and Response
The Group 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 various staff and security service, which are reviewed regularly. The Group has procedures and equipment for preventing and fighting fires and safeguarding life.
For health care facilities, an Emergency Plan has been developed covering respond plan to situations that may represent a risk to the integrity of workers, patients and visitors inside the facilities or from neighboring areas.
Altea has a specific Emergency Plan which the organizational systems and applicable general procedures are defined to manage disaster or emergency situations, in their different phases. The company will develop an emergency preparation and response plan (EPRP) for the new clinic in Villavicencio, to adapt it to the conditions of the development, with the identification of potential risk scenarios with the respective new mitigation measures and response to emergencies. Particularly, the new EPRP will address patient safety, shelter in place procedures and communication with the nearby communities (ESAP 3).
PS2: Labor and Working Conditions
Human Resources Policies and Procedures, Working Conditions and Terms of Employment
The Group currently has around 1,400 direct workers, where 86% are women. Group’s Ethic Corporate Code includes its commitment to avoid conflicts of interest; non-discrimination, anti-sexual harassment, transparency and integrity, generally align with IFC PS2 requirements. In addition, the Group has a whistleblower procedure that addresses offences, violation/non-compliance of Group’s policies/corporate codes.
The Group follows national requirements related to minimum wage, benefits, working hours, shift times and overtime payment and all workers have contracts written under the terms of the Labor Code of Colombia.
The Group has a policy that includes sexual harassment issues and Gender Based Violence. In addition, the Group has mechanisms allowing anonymous complaints to be raised and addressed (which is also accessible by third party workers) and a response/ resolution procedure. Specifically, for Altea, workers can also access the Human Management and Labor Coexistence Committee.
Workers Engaged by Third Parties
For construction and maintenance activities, and for services such as security for its facilities, the Group retain specialized companies. Contracts and legal documents signed with the referred companies usually contains legally binding requirements covering EHS aspects and responsibilities.
The Group will strengthen its contractor management procedure to include (but not limited to) relevant IFC PS 2 labor provisions of their future contractor’s workers. The contractor management procedure will define and establish E&S requirements for contractors to comply with the Group’s E&S policies and procedures as well as IFC’s PSs, as relevant, oversight procedures for their E&S performance, and actions to be taken for non-compliance, and will cover (but not limited to): (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”)
As mentioned above, the Group has an OHS Management System. The Group has internal policies and plans to manage the related OHS aspects, including risks identification and control procedure, health security inspections, safety induction, OHS training programs, and an incident system that includes accident reporting, investigation, and corrective actions.
During the last three years, no significant accidents and/or fatalities were reported. In the case of Altea and BlueCare Salud lost time injury frequency rate (number of lost time injuries per one million work hour) is reported to be 1.22 and 5.37 respectively which are below compared to industry values as per the Bureau of Labor Statistics of the United States (1.5 and 6.2 www.bls.gov).
Altea provides PPE for workers. There are suspended dust extractor system and high-efficiency filters in place, to improve workplace air quality. Altea has a Labor Committee, where the purpose of this Committee is to receive, analyze and follow up on labor complaints and define action plans for the improvement.
The Group does not have a systematic approach to monitors contractors’ performance, therefore, as per ESAP Actions No. 4, the Group will develop procedures to ensure oversight of occupational health and safety performance of their contractors during construction.
Supply Chain
The Group has a specific policy to evaluate risks and opportunities associated with contracting, acquiring and supply services at a corporate and project level. As part of this commitment, the Group considers the prevention of any risk with origin in its supply chain and in the assets and services produced or supplied by the companies that form part of this chain. This policy applies to all purchases of goods and services generated by the Group. The policy covers ethical, environmental, health and safety at work criteria, including the elimination of forced labor, child labor, fair conditions and non-discrimination practices, freedom of association and equal opportunities.
For its vendors, the Group has a monitoring program, carried out according to its procedure called “Qualification and validation of providers”. The frequency of auditing and re-auditing is determined according to the results obtained in the last audit, depending on the provider's performance level (obtained annually in the evaluation).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
Electricity is sourced from the public grid for all facilities and water is supplied from the public network. As mentioned before, the group monitors and controls its consumptions, and going forward, the Group will design resource efficiency programs including relevant KPIs and goals in order to improve efficiency in its consumption and define relative level of efficiency and the required actions to achieve them (ESAP No 5).
Greenhouse Gases (GHG) Emissions
Upon project completion, GHG emissions are expected to be less than 25.000-ton carbon dioxide equivalent per annum.
Pollution Control
For CienoGroup’s facilities, the wastewater is discharged into the public sewage system and wastewater quality is periodically tested, and effluent quality is in line with local legislation requirement.
For Altea’s operation, the facility has a wastewater treatment plant (flocculators and aerobic digester). The monitoring results follow the regulatory requirements.
The Group has a waste management procedure, generally in line with good international industrial practices, which covers segregation of hazardous and nonhazardous wastes per their types and risks, temporary storage in designated places, and disposed by licensed third party contractors. The Group has a procedure to monitor and control air emissions and monitoring is also carried out annually for all the facilities. Monitoring results are in line with local regulatory requirements.
PS4: Community Health, Safety and Security
Community Health and Safety
All the buildings and facilities have obtained operation permits from the local fire department. The fire prevention devices and installations are tested annually, and the Group has trained emergency team and provided with tools and equipment to manage potential emergency scenarios. The Group will provide appropriate information to potentially Affected Community, according to ESAP No 1.
For pharma and healthcare facilities, including Villavicencio, the group will engage a suitably qualified L&FS expert, acceptable to IFC, to conduct an L&FS review of the architectural and engineering design of the “to be upgraded” and “new” facilities, to evaluate gaps with international requirements. Findings of the review will be used to set a time-bound action plan to be implemented and to introduce systematic improvements to L&FS aspects (ESAP Action No 6).
After the completion construction project, the LFS consultant will conduct a post construction audit, as part as project completion test, at the time of the L&FS systems testing and commissioning and will certify that the construction of these systems has been carried out in accordance with the accepted design and the L&FS section of the WBG General EHS Guidelines (ESAP Action No. 7).
Security Personnel
Group’s facilities are guarded with armed security guards from private security agencies and necessary training, including “defensive use of power, rules of engagement, communication” is provided twice a year according to local regulations, which is part of the local regulation requirement for this type of services. The agencies’ recruitment process covers psychological controls and criminal checks.
