PS5 on Land Acquisition and Involuntary Resettlement is not applicable as the company operates in leased office spaces located in commercial buildings. PS6 on Biodiversity Conservation and Sustainable Management of Living Resources; PS 7 on Indigenous Peoples and PS 8 on Cultural Heritage are not applicable as all the sites are located within urban areas with no presence of indigenous peoples, natural/critical habitats and where the presence of cultural artefacts is unlikely. The company will be required to evaluate and address any potential PS5-PS8 related risks as further discussed below, under PS1. 

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability.

Key Environmental and Social (E&S) risks and impacts are expected to include the company’s organizational capacity and systems for E&S management of the project and its operations in compliance with legal requirements as well as IFC PSs; assurance of fair, safe and healthy working conditions for its workers including management of life and fire safety risks; energy use and resources consumption; and stakeholder engagement. 

Environmental and Social Assessment and Management System

For the Uganda and Kenya operations, the company has documented (i) Crisis and Incident Management Policy and Procedures whose coverage include fire and bomb threats; (ii) HR policies provided for in the People Operation Policy and procedures; (iii) Staff Code of Conduct; (iv) Whistle Blower Policy; and (v) IT Business Continuity Plan. The company also has ISO 9001:2015 (quality management system) and ISO 27001: 2013 (information security) certification for the Kenya and Uganda Offices. However, Samasource does not have a documented overarching E&S policy or an Environmental and Social Management System (ESMS). The E&S risk assessments undertaken to-date are for occupational health and safety (OHS) for the Kampala, Uganda offices and fire safety risk assessments for the two offices in the Nairobi, Kenya. Further details are provided under PS 2.

Samasource will undertake an E&S risk assessment process that will include assessment of the company’s operations, a review of existing records and procedures provided during the appraisal process prior to developing / updating plans and procedures commensurate with the level of the identified E&S risks and impacts. The company will then develop a corporate level ESMS which will as a minimum incorporate: (i) a corporate level E&S Policy; (ii) E&S due diligence procedure for acquisition / leasing of new premises; (iii) OHS Policy, Plans and Programs, site specific Emergency Preparedness and Response Plans (EPRP); (ii) water and energy use management strategies / plans; (iii) hazardous materials management plans and procedures; (iv) waste management plans (including management of waste electronic and electrical equipment); (v) corporate level internal and external communication procedures, site specific stakeholder engagement plans with mechanisms for management of grievances from the communities near their areas of operations; (vi) mechanisms for cascading the ESMS to all its operations. (ESAP #1).

Management Programs

The company will establish management programs to provide environmental and social risk mitigation as informed by the E&S risk assessment process. Performance improvement actions and measures will be integrated into the management programs to enhance environmental and social management outcomes. Areas of focus are expected to include management of labour issues, health and safety, waste management, fire safety, water and utilities use as envisaged in ESAP #1.

Organizational Capacity and Competency

The company does not have a defined E&S Risk management structure across the organisation. The Service Delivery Director and the People Director share the responsibilities in OHS while each office has a Health and Safety (H&S) committee. The company facilitates training of the H&S Committees in accordance with local laws.

The company also has a Vice President of People and Trust as well as a Senior Impact Manager based at the headquarters, who both have roles on labour related matters. The HR Manager in Nairobi oversees labour related issues and is supported by HR Business Partners in the four offices in Kenya and Uganda.

Samasource shall appoint an Environmental, Health and Safety (EHS) Manager who will have the responsibility of developing and implementing the ESMS, conduct monitoring of E&S performance and reporting to Samasource management team on E&S performance and challenges. Samasource shall also designate EHS Officers at Office level, who shall in turn report to the EHS Manager (ESAP #2).

Emergency Preparedness and Response

The company’s System Crisis Management Procedures outlines the company’s commitments and responsibilities to business continuity related IT risks including fire risk and bomb threats in the workplace. The procedures provide for the establishment of an Emergency Response Committee and Specific Emergency Response Teams which include first aiders and fire marshals as well as a Damage Assessment Team that is empowered to declare a disaster in the workplace. It also outlines the emergency evacuation procedures, incident reporting and review procedures as well as emergency contact information. However these procedures are structured only for the Nairobi Offices.

As part of ESAP #1, the company will undertake activity and location specific risk assessments and review the existing system crisis management procedures and develop site specific Emergency Preparedness and Response Plans to cover all applicable emergencies in the workplace including fire related emergencies.

Monitoring and Review

To monitor and measure the effectiveness of the ESMS, the company will establish monitoring and review procedures with mechanisms for reporting to senior management. Senior management will in turn take steps to ensure that the objectives of the EHS policies are met and that any corrective actions to the policies and procedures are undertaken and necessary amendments made to the ESMS. Clear roles and responsibilities for implementation of corrective actions and amendments to policies and procedures will be assigned to the country level managers with delegated responsibilities in EHS and human resources management, as well as any other line managers in charge of company operations of relevance to the ESMS.

As part of ESAP #1, the country level office management team will establish and implement mechanisms for record keeping and reporting on E&S risk and impact management at facility level.

 As at the time of appraisal the company had 4,731 staff of which 49.7% were women. The highest number of staff are in Kenya (about 78%) and Uganda (about 18%). Sama’s third-party workers in Uganda and Kenya consist of cleaners, food services providers (lunch and tea breaks in the office) and unarmed security personnel. The company’s primary suppliers mainly consist of the data services providers for both software and hardware (computers and related equipment).

Human Resources Policies, Procedures and Terms of Employment

The company operations in Kenya and Uganda have HR policies and procedures structured to country specific labour laws. The policies cover working terms and conditions from recruitment to termination stages including performance reviews, working hours, staff benefits including health insurance for staff and equal opportunity policies. The company also recently developed a Global Human Rights and Working Conditions Policy which broadly complies with PS 2 requirements. The policy commitments by the company will be cascaded into country level HR handbooks and HR Manuals (ESAP #3). Workers will be sensitized on these changes to the HR policy statements and manuals.

Retrenchment

The company had established a product for smaller accounts supported by a self-serve/low touch external-facing software as a service product (Sama Go). The product was not economically viable, so the company decided to focus on the core business that serves large steady clients. The company then had to release 39 staff in Canada (13), Costa Rica (two), Germany (one), England (one) and the US (22) whose roles and positions were impacted by this decision. By the time of the appraisal, only one former staff member was not in agreement with the severance package provided by the company.

While the HR policies and procedures are aligned with local laws, the company will update its retrenchment / redundancy policy and procedures as part of ESAP #3, to provide for commitments on: (i) undertaking an analysis on alternatives to retrenchment; (ii) preparation of a retrenchment plan and (iii) procedures for worker engagement prior to and during retrenchment / redundancy. These changes will also be translated into the country level HR Handbooks.

Grievance Mechanisms

The company HR policies for the Kenyan operations cover general and sexual harassment, while the code of conduct provided in the Samasource employee handbook provides specific mechanism for managing complaints related to general and sexual harassment. Policy statements specific to protection against retaliation are also present in the HR policies for the Kenyan operations. There is no specific policy and procedures for GBV risk in the workplace. As part of ESAP #3, the company will review its HR policies and country level manuals to ensure alignment with IFC requirements and guidelines on management of sexual harassment and GBV risk in the workplace.

Occupational Health and Safety

As indicated under PS 1, the company undertook an external OHS Audit for the Kampala office. Key corrective actions raised in the OHS audit report that were closed out by the time of the appraisal visit included: documentation of the company OHS Policy within HR policies, establishment of a worker H&S Committee, establishment of systems for recording of accidents and incidents, registration of the workplace, identification and training of first aiders and posting of emergency evacuation signage. Sama also engaged with an external consultancy company to undertake a life and fire safety (L&FS) risk assessment for its Nairobi Offices. The assessment confirmed that the premises are licensed as workplaces per local occupational safety and health OSHA law. The audit found compliance on firefighting equipment, availability of means of egress in the event of a fire, adequate emergency response procedures and evacuation in the event of a fire risk. Examples of non-compliances identified during the audit included inadequate controls for electrical fire risk, low imposition of OHS requirements on third party workers, establishment of fire detection systems, maintenance of fire alarms and establishment of appropriate emergency evacuation signage.

As part ESAP #1, the company will undertake an audit of the implementation of corrective actions identified under these assessments and prepare a time bound resourced corrective action plan (CAP) to close out outstanding actions. The documented OHS Program will integrate a fire safety policy and procedures that will outline L&FS provisions including periodic inspections, training, fire drills, awareness programs and related communications materials, allocation of roles and responsibilities to relevant staff.

The nature of work at Samasource is desk based with heavy reliance on computer use. As part of its workplace risk assessment under ESAP #1, the company will pay attention to workers with special needs to inform the mechanisms for assessment of worker’s equipment needs, related procurement procedures and specific staff support programs to facilitate an equitable and healthy work environment.

Third Party Workers

The company HR policies covers all direct and contracted workers within Sama premises on data protection, security and alcohol and drug abuse. As part ESAP #3, the company will update its HR policies and procedures to include PS 2 requirements on oversight of third-party workers ESMS, especially on labour issues and third-party workers’ access to company grievance redress mechanisms.

 Resource Consumption Management

The offices in Uganda and Kenya are connected to the national grid and the company owns diesel generator sets that provide back-up power. The company records emissions from generators, furnaces and vehicles. Samasource also estimates it greenhouse gas emissions from grid electricity consumption to inform its sustainability reporting. Its emissions from current operations and after the expansion in Uganda are expected to be below 25,000-ton carbon dioxide equivalent per annum. The company stores low volumes of diesel on site to power the generators in case of power outage from the grid.

Water use in the company premises is also low and restricted to sanitation for the office workers. Conversely, wastewater from the premises is only restricted to sanitation facilities from the office environment. Solid wastes are collected and disposed by waste contractors.

The company will as part of ESAP #1, document policies and establish targets and KPIs for resource use consumption management as well as procedures for management risks connected to storage and handling of diesel fuel, air emissions, management of general wastes and wastes contaminated petroleum products in accordance with PS 3 and the World Bank Group’s relevant EHS Guidelines. The company will also develop site specific waste management plans and establish a procedure to confirm that its waste collection and disposal contractors are duly licensed by local regulatory authorities.

 Management of Communicable Diseases

The company facilitated access to internet and electricity for staff to work from home during lockdowns in Uganda and curfews in Kenya. This included internet connection through fiber optic cable for workers’ homes in informal settlements of Nairobi (Kibera). The company also made arrangements with hotels in Nairobi to provide working space for its workers. By the time of the appraisal, some staff had opted to continue working from home, or work on a hybrid model even as the office spaces transition back to post-pandemic operations.

The company facilitated vaccination drives for staff by hosting service providers at the Samasource offices and undertaking staff sensitization on the COVID-19 vaccines. At least 70% of the workers have received 2 doses of the vaccine.

Road Safety

Samasource engaged a third party to provide transport services for its workers. As part of ESAP #1, the company shall integrate mechanisms for monitoring the roadworthiness of vehicles used and licensing of third-party drivers as part of the road safety program for its site specific EPRPs.

Security Personnel

The company premises in Uganda and Kenya are guarded by unarmed contracted security staff. Samasource will integrate contractor due diligence review on all potential service providers at procurement stage to check for past human rights violations. The security staff will be issued with a code of conduct to guide their engagement with the staff and visitors while the contract will include requirements for continuous training of security personnel and allowance for periodic audit by Samasource (ESAP #4).

 The company relies on its web-based platforms for external communication with the general public. As indicated under PS 1, the company will develop a formal SEP as part of ESAP #1, commensurate with its E&S risks and impacts. The SEP will include mechanisms for site specific stakeholder identification and mapping, identification of appropriate engagement platforms, record keeping mechanisms and internal and external reporting mechanisms aligned to stakeholder engagement objectives and country specific engagement schedules.

The company will also integrate external communication procedures into the ESMS and establish community grievance redress mechanism in tandem with the company’s E&S risk exposure to cover the general public, neighbouring communities and beneficiaries of corporate social responsibility (CSR) initiatives by the company.

 Contact Person: Wendy Gonzalez

Company Name: Sama

Address: 6795 Rue Marconi, Montréal, Québec H2S 3J9, Canada

Email: wgonzalez@sama.com

Phone: +1 2067698709