This is a category B project according to IFC’s 2012 Policy on Environmental and Social Sustainability. Key E&S issues and risks are expected to include: (i) company’s capability to implement an environment, health, safety, and social management system (ESMS), in line with IFC PS requirements, at corporate and campus level, for construction / expansion and maintenance works, (ii) labor and working conditions and workers’ grievance management, (iii) occupational health and safety (OHS) management during construction and operations, including contractors’ management, (iv) gender-based violence and harassment (GBVH) for during construction and university operation, (v) life and fire safety (L&FS), (vi) waste and effluent management, (vii) resource efficiency, (viii) effective engagement with neighbouring communities, particularly during construction phase due to potential impacts including increase of traffic, ambient noise, construction waste management and dust, and (ix) effective engagement with neighbouring communities, and external grievance mechanism.

Environmental and Social Management System and E&S policy

Santo Tomás has an integrated management system, mainly limited to an occupational health, safety and environment plan which is developed in line with local legislation requirements.  Santo Tomás has an E&S Policy on a corporate level applicable to all their facilities, which sets out the commitments to comply with Chilean regulatory requirements and to continuously improve the E&S performance across the campuses. The policy is communicated to all employees at induction and annually updated by senior management.

The company will be required to enhance its Environmental and Social Management System (ESMS) in line with IFC’s PS requirements, to include reference to its existing E&S policy in addition to systems for E&S risks and impacts assessment, land/building acquisition, labor management, contractors E&S risks management, detail reporting on OHS indicators, safety training, air and water effluent management and monitoring, waste management, food safety, and the implementation of emergency response plans, security management plan, as discussed in the sections below, as per ESAP #1.

Santo Tomás acquired the lands for existing and new campuses from private owners on a willing seller-willing buyer basis and has adopted a checklist that details the technical and administrative process of land acquisition. As per the ESAP#3, the company will enhance the land acquisition procedure and ensure that projects financed by IFC requiring land/building acquisition will be implemented in accordance with PS5 requirements, including risks related to biodiversity, indigenous peoples, and cultural heritage. The procedure will include the following aspects: (i) requirement of site visit and consultations with land owners and users, (ii) requirement of a census and socio-economic surveys, (iii) establishment of cut-off dates for eligibility of compensation, (iv) valuation methodologies, (v) entitlement matrix, (vi) requirements of resettlement action plan / livelihood restoration plan, where needed, (vii) dissemination and management of external grievance mechanism related to the land acquisition, and (viii) aspects related to PS6-8 including biodiversity, indigenous peoples (IPs), cultural heritage and chance finds procedure.

Environmental & Social Risk Identification

The company is not required to conduct an Environmental and Social Impact Assessment (ESIA) for the construction and refurbishment of campuses as per the local legislation. Santo Tomás have documented procedures to identify key E&S risks and impacts for the construction and operation of campuses and administrative offices. Key risks and impacts include general and hazardous waste, air emissions, effluents, resource consumption, L&FS management, OHS, and management of chemicals and hazardous materials. The company’s risk assessment does not cover social risks and impacts to adjacent communities derived from construction activities such as noise, air quality, GBVH, and security arrangement.  As per ESAP #1, Santo Tomás will be required to enhance its documented procedures to identify all E&S risks and impacts that relate to the construction and operation, including the potential social risks for neighboring communities.

Furthermore, for construction of buildings, the company has a checklist for contractors to reduce impacts of construction on neighboring areas, and checklist will be updated to include contractual obligations for E&S standards for child and forced labor, as well as appropriate contractor management practices in line with IFC’s requirements, as per ESAP #2.

Management Programs

Santo Tomás has management programs to control resource efficiency, general and hazardous waste management, liquid effluents, chemical materials handling, and to provide E&S trainings. OHS management programs include risk and hazard evaluation, prevention programs tailored to each job function, and L&FS. As per ESAP#1 and ESAP#2, the company will enhance its ESMS to include further procedures and programs such as for contractor management and security management, as further discussed below.

 Organizational Capacity and Competency

Santo Tomás has a corporate structure to manage E&S risks in existing campuses. At corporate level, there are three qualified directors for (i) EHS and OHS, (ii) Human Resources (HR), and (iii) Physical Infrastructure which oversees construction of campuses. These three directors report to the Vice Rector, who then reports directly to the Rector. Additionally, there is one EHS officer at each of the cities and campuses (22 persons), and two OHS officers at the corporate level, making it 24 EHS and OHS persons reporting to the EHS Director.

At campus level, HR, Environmental and OHS coordinators are assigned at each campus. There is also an EHS and OHS committee, that is composed of the campus Rector, operations and administration director of the campus, HSE engineer, and three workers’ representatives, at each campus. The committee reports to the corporate EHS and OHS director monthly on accidents, trainings, emergency situations, safety and security. They conduct physical inspection, trainings, work on the emergency plan, as well as look at accidents within the campus. Complaints and grievances from students and external communities are overseen and managed by the Student Affairs Director, supported by leaders assigned per campus. GBVH grievance management of employees and students is conducted by trained resources of the HR Department.

Emergency Preparedness and Response

Santo Tomás has developed an emergency preparedness and response plans (ERP) for each campus and associated facilities and follows country regulations enforced by the Ministry of National Defense and Civil Defense. The emergency scenarios included in the ERPs are fire, earthquake, incidents caused by a violent person/intruder, spills, terrorism, civil unrest, accidents, flooding (Tsunamis) and other natural disasters. The manual describes processes on assessment of emergencies, patient categorization (based on their vulnerability and mobility) and basic evacuation procedures. Roles and responsibilities of various brigade teams and security personnel are described in the plans.

ERP training is provided for all emergencies at least twice a year with a mock drill each time. The ERPs are updated each time a campus is modified or provided with new additions or changes in general.

Monitoring and Review.

Santo Tomás has an established monitoring program to track and report Key Performance Indicators (KPIs) against the corporate E&S targets and benchmarks. The monitoring program covers the topics of resource efficiency, general and hazardous wastes, effluents, HR, OHS, emergency response, and external grievance mechanism.  The annual monitoring plans define the parameters, frequency, and responsible personnel. Monitoring results are reported to senior management team, which is responsible to review and propose corrective actions as needed, ensuring the effectiveness of the programs. The company also conducts internal annual audits of all campuses.

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

Santo Tomás currently employs approximately 11,797 employees of which approximately 70% are in academic positions, 25% are in administrative positions, 5% are in management positions, where 54% are women and 46% are men. The 51% of the employees have either a permanent or term contract; and the rest of workers are contracted for the provision of services per each academic period (denominated as “honorarios” in Spanish).

Santo Tomás adopted a corporate Human Resources Management System, which includes policies and procedures as well as employment contracts, covering: (i) selection and recruitment, (ii) compensation. working hours and benefits, (iii) induction, training, and professional development, (iv) dismissal and disciplinary processes, (v) performance evaluation, and (vi) occupational health and safety (OHS). Santo Tomás has a code of conduct and internal work regulation which align with the Chilean labor code and PS2 requirements. Multiple inspections are carried out by the Labor Department to verify compliance with the labor code.

Workers’ Organizations

Santo Tomás’s internal work regulation recognizes the freedom of association and collective bargaining (CBA). There are three main unions (National Union of Inter-company, Union of University Santo Tomás, and Union of University Santo Tomás – Puerto Montt) representing approximately 30% of the employees. The company confirmed that periodic meetings with these unions were held to discuss the implementation of CBAs and address workers’ interests and concerns.

Non-discrimination and equal opportunities

The company’s internal work regulations stipulate non-discrimination and equal opportunities, which are consistent with Chilean labor code and PS2 requirements, detailing equal opportunities for hiring process and compensation as well as non-discrimination based on race, disability, social conditions, ethnicity, age, gender, sexual orientation, marital status, health status, religion, membership to unions, and political positions, guiding actions of employees through continuous trainings.

Retrenchment

There has not been retrenchment in the past three years, and Santo Tomás reports that no retrenchment is anticipated for the proposed project. During the outbreak of COVID-19, Santo Tomás kept employees, offering paid leave and job relocation to protect employees from the risk of layoff. As per ESAP #4, the company will develop a corporate retrenchment policy and procedure aligned with the national legislation and PS2.

Worker Grievance Mechanism

Santo Tomás has a grievance channel in place to provide employees to raise concerns and grievances. According to the company and the HR policies (e.g., Internal Work Regulation), the channel of communication is currently limited to speaking directly to the line supervisors, unions, and/or HR department, specifying their names and signatures, as per the labor code. As specified in the ESAP #5, Santo Tomás will update its grievance mechanism. Supervisors are responsible for addressing and responding to workers’ concerns and grievances at each campus level in coordination with the Director of Administrations and Operations. In case the resolution is not achieved in an effective and timely manner, the case could be escalated to Vice-Rectory of People and handled at the corporate level.   

Gender-based violence and harassment (GBVH)

As per the national legislation established in 2021 (i.e., Law No 21.369 Gender-based violence and harassment in superior educational institutions), Santo Tomás has established a separate confidential channel to report concerns and grievances related to sexual and other forms of harassment and discrimination occurred within the educational environment. The channel does not provide an anonymous option to file grievances. For grievances or concerns expressed by workers and students, they could express using the online format (https://www.santotomas.cl/formulario-de-denuncia-ley-21-369/). In addition to the online platform, workers can file grievances and concerns also to the Dean through emails, where Dean channels grievances to the corporate HR function.

Deans, employees, and representative students in charge of the investigation are required to go through a specialized training to properly handle cases following an established protocol and approach. There is a professional team to provide psychological and emotional support to students and workers in a confidential way. The company also undertakes prevention of sexual harassment via communications (posters, information) and awareness-raising sessions.

As per ESAP#5, Santo Tomás will update the workers grievance mechanism as well as the GBVH specific grievance mechanism in university communities, to handle anonymous grievances. The updated grievance mechanisms will include (i) all the available channels (email, website, suggestion box), (ii) allowance to file anonymous grievances and treat confidentially, (iii) records of corrective actions taken, (v) tracking and analysis of all kinds of grievances for continuous improvement, and (vi) training materials for updated procedures. For the GBVH and workers grievance mechanism, the company will conduct regular trainings to the employees, third-party contractors, and students.

Occupational Health and Safety (OHS)

The company’s OHS Committee meets monthly to discuss health and safety issues in the campuses as well as to develop, implement and monitor the OHS annual plans, which include monitoring, training, inspection, and internal audits. There are two internal audits a year for each campus conducted by corporate EHS and OHS teams.

Santo Tomás has comprehensive OHS policies and procedures to mitigate the risks and impacts identified by OHS risk and hazard evaluation matrix at corporate and campus levels.  Employees are provided with written information on the risks associated with the job position and adequate control measures such as trainings, Personal Protective Equipment (PPEs), and engineering controls.  There are health control programs for the management levels of the organization, together with annual health controls to verify compatibility with the responsibilities of certain positions. The company has a system to investigate, and record incidents and accidents. An incident investigation report includes details, root cause analysis, and corrective actions, which is reviewed and discussed during monthly OHS committee meetings. OHS data and statistics are recorded at campus level and consolidated at the corporate level, which is reported to and reviewed by senior management on a regular basis.

The lost-time incident frequency rate (LTIFR, number of lost time injuries per million work hours) has been 2.5 in 2021 and 8.1 in 2020. These figures are generally aligned with the good international industrial practices (U.S. Bureau of Labor Statistics, College, universities, and professional schools benchmark in 2013, 2.5 LTIFR, www.bls.gov). There have not been serious incidents or fatalities in the past 3 years.

Regarding construction safety, OHS management of contractors includes specific programs and procedures for high-risk activities such as work at height, hot work, crane and lifting works, confined space entry, people/construction vehicle interference, excavation safety and electrical safety. Contractors performing construction and maintenance are required to maintain OHS plans, train employees, and provide them with necessary safety equipment, as well as to comply with their labor conditions obligations according to local laws. To enhance the monitoring of the contractors in charge of undertaking civil works, as per the ESAP#2 specified in PS1, the company will establish KPIs (e.g., leading and lagging OHS indicators) related to the contractors OHS management programs as part of the contractor management plan (CMAP), including regular meeting, inspections and audits of construction works.

Workers engaged by Third Parties

Third-party contractors currently engaged by Santo Tomás include security service providers, cleaning, and gardening, among others. Santo Tomás has established and implemented a procedure, covering its requirements that relate to the labor conditions and OHS aspects of third-party workers, as per the ESAP#2, the company will refer to the implementation of Santo Tomás’ HR policies and procedures in addition to contractor’s labor management procedures as part of the contractor’s ESMS requirements, including trainings, monitoring and controls.

Resource Efficiency

Electricity is sourced from the public grid for all campuses. Some of their campuses (San Joaquín) have small scale – 100 kW roof top solar panels supplying two-thirds of the energy of the campus. The company is looking into integrating solar PV panels in several other campuses. There are no on-site diesel generators except in one campus in Ejército as a backup in case of power outages. Liquid natural gas (LNG) is used in the campuses in the labs for hospital/infirmary labs. LNG comes from the grid in three cities (Santiago, Concepción, and Temuco), while the rest have onsite storage tanks.

The company’s resource efficiency initiatives included: (i) conversion of all lighting to LEDs (most of the campuses); (ii) design of the educational and administrative buildings with natural ventilation, which represent an energy saving feature in air conditioning; and (iii) installation of Solar PV panels in some campuses. As per ESAP#1, Santo Tomás is monitoring consumption at campus level and will update its ESMS to monitor energy and water consumption at the corporate level.

Greenhouse Gases (GHG) Emissions and Climate Risk Assessment

The annual greenhouse gas (GHG) emission is estimated at 2,560 tons of CO2 equivalent (Scope 1: 586 and Scope 2: 1,974) based on their annual energy consumption.

Water and Wastewater

Water and sanitation for all campuses is sourced from the public systems. 

Solid Waste Management

Solid waste includes food waste, plastic bottles, cans, paper/cardboard, light bulbs, and small amounts of medical waste from campus infirmaries. Each facility has a waste segregation and storage room. 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.

Hazardous materials

Santo Tomás has procedures and instructions for the handling, consumption, transportation and disposal of hazardous materials, considering their classification, and their material safety data sheet (MSDS). Chemicals are utilized in controlled quantities only in teaching laboratories and are kept in approved fire rated cabinets. Most of the hospitals/infirmaries are simulation based, thus no actual chemicals or hazardous waste are used within labs. Any hazardous waste is stored and collected by third party contractors according to internal procedure in line with local legislation. Santo Tomás has an established pest management plan and selection of pesticides is controlled by EHS Director.  Santo Tomás does not perform audits or visits to third-party contractors. As per ESAP #2, Santo Tomás will develop contractor management procedures describing the controls to be implemented by Santo Tomás to ensure compliance with their E&S requirements (e.g., inspections, audits, walkdowns, E&S meetings).

Community Health and Safety

Santo Tomás 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, which are reviewed regularly. Each facility undertakes fire drills at its premises as defined in Chilean regulations, followed by an assessment of observed gaps, with corrective actions to be taken.

All designs, engineering and architectural projects have been developed and carried out by collegiate engineers and companies with recognized experience in educational facilities. All construction projects are managed and deployed internally by Santo Tomás, that engages with certified contractor companies in Chile with proven experience. For new campuses, the design includes location, access roads and public transportation, water and basic energy efficiency measures (e.g., minimal utilization of air conditioning systems, with open and well-ventilated spaces), materials and resources analysis and interior ambient quality.

The campuses have basic L&FS infrastructure with fire alarm devices, security system keypads, portable extinguishers and hose reels in all areas. The buildings are normally designed with open architecture (naturally ventilated corridors and exit stairs) with exterior balconies. As part of ESAP# 6, Santo Tomás will commission a qualified L&FS professional to develop L&FS “master plan” (or design manual) applicable to new buildings and those programmed for extensive renovation, considering the elements described in the L&FS section of the WBG General EHS Guidelines and must be aligned with the national regulations and with an international fire safety code. Also, The L&FS Master Plan will include features of accessibility requirements to be applied in new and existing buildings. and a checklist for the selection and evaluation of future facilities following the new corporate L&FS design manual.

Also, upon completion of the future projects, a suitably qualified L&FS professional acceptable to IFC will certify that the systems were built/installed in accordance with the approved design documents.

To assess current L&FS conditions of operating campuses, per ESAP #7, the qualified L&FS professional will conduct a risk-based review of an agreed sample of the largest facilities. Findings of the review will be used to (i) introduce a systematic and gradual improvement program on L&FS management at the company level; (ii) update L&FS maintenance and operation process across all campuses and regions by developing relevant L&FS KPIs for operation & maintenance activities. Also, the company, under this task, will develop and implement a formal procedure for the “Management of Change” or “MOC” and implement corresponding controls before the change is implemented.

Security Personnel

Santo Tomás has developed and implemented corporate security policy and procedures and measures, including CCTV, visitors’ access control, regular patrol, incident monitoring by third-party contractors. All security staff and third-party contractors are unarmed. The security contractor is accredited under Chilean rules for the provision of private security services regulated by Decree 3607 and OS-10 (national authority responsible for private security). The company coordinates with public security forces (municipal security and firefighters) in emergency situations such as emergency drills and security incidents as well as the delivery of training on crime prevention.

There are approximately 2-3 security personnel per campus with three 8-hour shifts each, with a total of 183 security personnel throughout Santo Tomás’s campuses (of which 154 are third party contractors and 29 are direct employees). Santo Tomás verifies that security contractors are properly vetted with background check and documentation. Security contractors are required to participate mandatory trainings which includes code of conduct, human rights, and principles of proportionality, HR policy and procedures, first aid, prevention of sexual harassment and GBVH. According to the company, there have not been any incidents or grievances related to its security arrangements.

As specified in ESAP#1 (management programs), Santo Tomás will update and/or develop the security management plan for new campuses based on the security risk assessment and community consultation aligned with PS4 requirements that (i) evaluates safety and security risks posed by its security arrangements, and (ii) examine students’ safety risks on and nearby campuses. The security management plan will discuss: (i) security management objectives and targeted stakeholders, (ii) internal and external risks identified in the security risk assessment, (iii) security arrangement employed within and outside campuses, (iv) details of coordination with municipal police, (v) incident reporting, and (vi) KPIs for security management.

Stakeholder Engagement and Grievance Mechanism for Affected Communities

Santo Tomás has a dedicated team to plan and implement stakeholder engagement program, led by Vice-Rectory. The company identified stakeholders that include student, prospective students, employees, alumni, government authorities, churches, and Non-Governmental Organizations (NGOs) and developed a corporate stakeholder engagement policy and framework and adapted it as stakeholder engagement plan per campus. For external communications, the university has its websites (https://www.santotomas.cl), social network, WhatsApp, and contact center (virtual and in-person) to inform university communities on the activities implemented by Santo Tomás.  

As part of ESAP#8 the company will update the corporate stakeholder engagement framework to continuously report on the risks, impacts, and opportunities derived from the Project. It will outline: (i) the criteria and mechanisms of identification and analysis, (ii) methods of consultation and engagement with communities, and (iii) methods and frequency of reporting on the risks, impacts, and opportunities derived from the Project.

Grievance Mechanism for Affected Communities

Santo Tomás has channels to receive concerns and suggestions from external stakeholders (students, their parents, and general public) through email, WhatsApp, and website (https://www.santotomas.cl/sugerencias-y-reclamos). However, these channels do not provide an anonymous reporting option. During 2022, the company received approximately 600 requests. The most common requests were related to system/technical issues, financial inquiries, and academic topics. The company confirms that there have not been grievances or disagreement related to the land acquisition and lease expressed to Santo Tomás or involved a legal process.

As per ESAP#9, the company will (i) update the external grievance mechanism and implement it through the updated corporate stakeholder engagement framework and (ii) allow anonymous options to file general and sexual harassment- related grievances. The grievance mechanism will (i) specify and allow anonymous channels (e.g., suggestion boxes, website), (ii) disseminate communication channels to communities, (iii) receive, register, and handle all inquiries and grievances in timely manner in coordination with contractors, (vi) provide a resolution and feedback to communities, and (v) analyze its trends and take corrective actions, including KPIs to measure its effectiveness.

Contact Person: Eduardo Iturrate

Company Name: Santo Tomás

Address: Avda. Andrés Bello 2777, Las Condes.

Email: eiturrate@santotmas.cl

Phone: +56 2 23763497