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 Policies and Management Systems: Summa identifies and manages E&S risks and impacts associated with its construction and management operations through compliance with applicable national standards and E&S regulatory permits and requirements.?In addition, Summa?implements?management systems certified as per ISO 14001 (Environment), ISO 45001 (OHS) and ISO 9001 (quality)?at corporate level, which will be extended at the sub-project level.?As part of this project, Summa will (for projects using proceeds from this investment) develop and implement site level E&S management system (ESMS)?aligned with IFC PS1.?Specifically, the ESMS will?include?the following elements:?(i) policy; (ii) identification of risks and impacts;?(iii) management programs; (iv) organizational capacity and competency; (v) emergency?preparedness and response; (vi) stakeholder engagement?community grievance mechanism; and (vii) monitoring and review.?(ESAP #1).?The E&S management procedures to be developed and implemented as part of the ESMS will include?but will not be limited to: (i) occupational health and safety (OHS)?procedure, (ii) resource efficiency (energy/water use and efficiency), (iii) effluent, ambient air quality, noise and solid/hazardous waste management and storage; (iv) managing labor and working conditions including those related to contractors and third party workers; (v) emergency preparedness and response procedure, including L&FS; (vi) stakeholder engagement procedure and community grievance mechanism; and (vii) a community health and safety procedure, including?road safety and use of security.
Identification of E&S Risks and Impacts. Summa has developed and implements?an?EHSS?risk assessment?procedure and?matrix for?its construction sites. As?per national requirement Summa has commissioned?a?PS-compliant ESIA study for hotel and is implementing the E&S management plans. Summa will, going forward, undertake a PS compliant ESIA for new facilities and implement the resultant E&S?Management?Plans. (ESAP#2). The ESIA for the shopping mall (currently greenfield) has been undertaken per the statutory requirements and will be updated (as needed).
EHS organizational structure and competency. The project manager supported by EHS officer oversees the EHS compliance assisted by separate teams for compliance managements (environment, social and compliance) at construction facility level. At the corporate level, the HSE and Sustainability manager (reporting to the Director) oversees?EHS initiatives for the construction projects. Going forward, Summa will further strengthen its corporate team with a sustainability officer, responsible for overseeing E&S / sustainability initiatives across the company operations (ESAP #3).
Emergency Preparedness and Response. Summa has a documented corporate level emergency preparedness and response plan (EPRP) for its operations and develops EPRP for each construction and operation site. The roles and responsibilities for various teams responsible for evacuation, rescue, firefighting etc. are defined and displayed at various locations across the construction?sites.?As part of ESAP#1,?Summa will prepare EPRP for?the Hotel in?Senegal and?other?construction sites?under this project, to include its?compliance team’s?internal audits to?verify the?implementation of fire safety measure, train a section of construction workers in fire safety and operation of fire safety equipment.
E&S Monitoring and Review: As part of the construction site EHS management, Summa monitors key performance indicators (KPIs) such as record of injuries, L&FS measures, usage of personal protective equipment (PPE), energy and water consumption, waste generation at construction sites. The KPIs are reported on monthly basis to the compliance management team. All incidents are summarized and discussed in the monthly management meeting and the team analyses the root causes and implements corrective action and data will be stored in a centralized database for periodic reporting.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures: Summa has a corporate level HR policy and procedure that lays down the company’s policies and procedures on HR management. In line with this and the applicable statutory requirements, the sub-projects prepare and implement project level HR policies and procedures that are compiled in an Employee Handbook. The handbook includes policies and procedures on working conditions, workers code of conduct, anti-bribery, and harassment.
IFC’s E&S appraisal assessed the hotel’s overall practices to be satisfactory. However, going forward, the hotel will consolidate the different HR/Labor management codes and procedures in one HR manual which lays down the hotel’s vision/policy and procedures to establish, maintain, and improve the worker-management relationship in compliance with Summa’ corporate procedures, local laws and PS 2 requirements. This will include (but not be limited to) clear policy/procedures on working conditions and terms of employment, leaves, worker organizations & freedom of association, non-discrimination and equal opportunity, prevention of child and forced labor, worker grievance mechanism (WGM), prohibition of sexual harassment and abuse, occupational health and safety, sub-contractor and third-party worker management, retrenchment, and supply chain. These policies will be communicated to all?staff and workers during induction, regular training, and sensitization activities such as toolbox talks and bulletin boards?(ESAP #4a).?Summa will hire competent HR managers?for Senegal and other new sub-projects/facilities.?(ESAP#4b).
Working Conditions and Terms of Employment: Working conditions and terms of employment are stipulated in?project level HR handbook and include?recruitment,?employee election,?compensation and?benefits,?labor?relation, and?managerial?relations.?As part of the?ESAP #5,?Summa?will and update its?contracts, as needed, for the?terms?to refer to the compliance?with local labor laws of the countries of operation,?consistent with the requirement of PS2?and?refer to the company’s HR policies and procedures including the available worker grievance procedure
Workers’ Organizations: There are no unionized workers at the hotel. As part of?ESAP#?4a, Summa will?develop a clear freedom of association policy and procedure to comply with statutory and IFC PS 2?requirements. These will be communicated to all workers.
Workers Grievance Mechanism: The current HR handbook does not include a well-defined grievance management procedure that is fully aligned to PS requirements.?As part of?ESAP #4a,?Summa will strengthen its Worker Grievance Mechanism (WGM) in alignment with IFC PS2 by a) increasing avenues for lodging grievance; b) incorporating systems for lodging of anonymous grievances; c) clear timelines for resolution and d) communication. The GRM will also include a clear statement on anti-retaliation. All workers (including third party workers) will have access to this grievance mechanism and be trained on this procedure through induction and regular training.
Occupational Health and Safety (OHS). Summa is currently strengthening its corporate level OHS management system and implements a project level?OHS management plan.?During construction, Summa provides for a standby ambulance,?personal protective equipment (PPE) and incidents?are recorded.?Going forward, Summa?will?formulate OHS policies and implement an OHS management system?for the hotel in Senegal and the other construction sites to address key?workplace?hazards at its operations?to improve its OHS performance. The OHS SOPs will be continuously updated based on?workplace?hazard identification and risk assessment conducted under the coordination of the EHS Officer?(ref. ESAP#3).?Summa will also develop/implement an OHS training plan which will include safe working SOPs, including emergency procedures, PPE usage, machine safety,?and?accidents reporting?(ESAP#6).
Workers Engaged by Third Parties: As part of?its HR policy and procedure review (ESAP#4a) Summa?will?require that policies and measures are in place with respect to?management of?contracted workers. Specifically, the company will contractually require its contractors to align their?labor?policies with?the?company’s policies and?PS2. This will include a) having provisions in HR policy/manual on applicable requirements for sub-contractors and third-party workers; b) having an oversight and monitoring system to ensure that the sub-contractors and third-party workers; c) extending the grievance mechanism to sub-contractors and third-party workers; d) periodic training and capacity building; and e) record keeping and conducting internal audits to verify and ascertain compliance (ref?ESAP?#9).
Workers Accommodation. Summa provides some workers and contractors with accommodation during construction. Summa will develop an accommodation management procedure which will include principles of non-discrimination and equal opportunity, freedom of movement or of association, in line with IFC/EBRD Guidance Notes for worker accommodation: processes and standards https://www.ifc.org/content/dam/ifc/doc/mgrt/workers-accomodation.pdf. (ESAP #9).
Contractor Management: Summa uses sub-contractors for specific tasks during construction. The company develops sub-contractor management plan for each construction site. Summa?will review these procedures for construction sites?to align with PS2 and the Good Practice Note for Contractor Management?and?contractually require its contractors (including third party workers) to align their?labor?policies with?the?company’s policies and?PS2?(ESAP #9).
Supply Chain: ?Summa suppliers undergo a process for registration as vendors,?however, contracts do not include E&S considerations. Summa will (i)?develop?a procurement policy and supplier code of conduct that addresses child labor, forced labor, (ii) include contractual clauses requiring suppliers’ compliance with the code of conduct, (iii) develop a verification process to?verify?new suppliers have the policies and procedures in place to meet requirements of the code of conduct, (iv) develop a communication strategy to inform suppliers about the code of conduct and (v) have a formal process for supplier engagement, remedy or disengagement in case non-compliances that are not addressed?(ESAP #10).
PS3: Resource Efficiency and Pollution Prevention
Resources Efficiency: The?company’s operations primary involve design and construction of building and other civil engineering works and operation of airports and hotels and?would not?result in significant quantities of wastes and emissions.?Electricity is sourced from the national grid during construction and operations, and there are no major air emissions / pollution from the company’s operations. The diesel standby generators are used rarely, and they are less than 3 MWh. As indicated in the designs, the company will use R406a as a refrigerant for the air condition systems and will not use R22 or other refrigerants that have been phased out.?Water for the construction and operation is?normally?obtained from the local utility supply company.
Green House Gases: GHG emissions from the construction phase of the hotel in Senegal (based on electricity and fuels consumption) have been estimated to approximately?1677?tons carbon dioxide (CO2) equivalent per year. Additional GHG emissions?are expected to be?below 25,000 tons?of?CO2e per year.?Based on the company’s GHG management plan, Summa will monitor its annual GHG?using internationally recognized methodologies.
Pollution control:
Air emissions: As part of the E&S Management System (ESAP #1) for the construction phase, Summa will develop and implement air quality management plan. The procedure will record, monitor, and report air quality during construction.
Solid waste: Summa has developed a construction waste management plan for the construction in Senegal. The waste management procedures including a system of appropriate sorting, handling, storage, and disposal which are consistent with applicable legal requirements and aligned to IFC PS3. The procedure list types and volume of wastes for the entire construction period, management of wastes including waste transfer notes for the waste disposal third party contractors. At the project site, all waste materials were noted to be properly labelled and stored in the designated area and the company has a waste register. Summa will develop and maintain similar waste management procedure for new construction sites.
Wastewater. The designs for the construction of the hotel provides for wastewater treatment plants (WWTP). Treated wastewater will be used for the irrigating the lawns. Summa will build the WWTPs and provide the frequent effluent wastewater monitoring results to IFC through annual monitoring report. (ESAP #11).
PS4: Community Health, Safety and Security
?The proposed construction sites are in planned urban areas and impacts on the health, safety and security of the local community are expected?to from?increased traffic and security personnel.
Life and Fire Safety: The building designs have?several elements of emergency plans incorporated, such as wide corridors, disabled persons’ ramp, and firefighting systems.?Summa?hires a L&FS consultant for each construction project.?Summa?submits the building designs fire safety reports to the city authorities for approval, alongside other design reports.?For the hotel in Senegal, Summa has approval from the?Societe?de gestion des infrastructures?publiques?dans les?oles?urbains?de?Diamniadio?et du lac rose (SOGIP). A similar approval process will be adhered to for?the other proposed facilities. As part of this?Project, Summa?will contract?an expert in international L&FS standards to provide the certification, affirming that the L&FS systems were designed, installed, and are properly tested?in line with?both local national requirements and those of an international L&FS code (such as NFPA 101 of the National Fire Protection Association)?or?a corrective Action Plan, to fulfill the gaps (if any),?with proposed completion dates and expected metrics?will?be submitted to IFC. The standard specifications will include operational and maintenance guidance, such as the preparing of schedules for mandatory regular maintenance and testing of?L&FS?systems and regular fire drills.? (ESAP#11).
Traffic Management: The ESIA for the hotel in Senegal recommended the development of a traffic management plan for the construction phases. Similar recommendations are expected from ESIA for new sites. Summa will therefore implement the ESMP which will include, periodic toolbox talks with drivers,?defensive driving training and?management of traffic at the construction site.
Security: During construction, Summa uses?unarmed security guards from a third-party contractor for access control and safeguarding property.?The guards?were?trained in emergency response and received?monthly training program on standard operating procedures for their job including human rights and engagement with the communities. A similar?process?will be?implemented?during operation phase of the facility in Senegal.?For other proposed sites,?Summa will develop and implement a similar process during construction.
