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:
Centum Real Estate implements an Environmental Management Plan (EMP) developed for the Two Rivers Development detailing environmental risk and mitigation plans for the construction and operational phases, as well as a Two Rivers Integrated Waste Management System. Centum Real Estate will develop an overarching Group Environmental and Social Management System aligned with IFC’s Performance Standards (PS) and national requirements (ESAP #1a) to streamline existing management plans for this project. The Group ESMS will include the following management programs to develop projects and operate in a manner consistent with IFC’s PSs:(i) Environmental, Health and Safety (EHS) management plan, (ii) Emergency Preparedness and Response Plan (EPRP), (iii) contractor management plan, (iv) Stakeholder Engagement Plan (SEP), (v) Traffic Management Plan (TMP), (vi) Security Management Plan, (vii) Monitoring and reporting procedure, and (viii) an external communication and grievance mechanism plan. In addition to this, the company will employ a reputable consultant with E&S experience to develop an ESMS manual aligned with IFC’s Performance Standards to streamline key polices, processes and procedures related to the management of E&S at Group level (ESAP #1b).
Identification of Risks and Impacts & Management Programs:
The company has completed the Environmental Impact Assessment (EIA) for Mzizi Court in 2020 (please refer to Annex1 of the ESRS) and have received the license from the National Environmental Management Authority (NEMA). As part of the ESMS (ESAP #1a), the group is required to develop management programs to mitigate and manage the risks and impacts of its projects and activities identified by the EIA. The plans and management programs will address E&S aspects such as occupational health and safety (OHS) risks, noise, resource efficiency, air emissions, wastewater, solid waste management and hazardous materials during construction and operation phases for its operations.
E&S Organization Capacity:
Centum Real Estate have in place an organizational structure for E&S management. The Board is ultimately responsible for the oversight and compliance of E&S issues. There is an ESG team led by the Head of Risk and Compliance that oversees E&S risks at Mzizi Court. E&S risks are also monitored by the third-party construction contractor, during the construction phase. In line with Performance Standard 1, the Group will hire an E&S Manager responsible for E&S coordination and implementation of the Group ESMS. Furthermore, the company will develop and define clear roles and responsibilities for the E&S organization of the Group (ESAP #2).
Emergency Preparedness and Response:
The company implements an Emergency Evacuation Action Plan developed by the third-party construction contractor describing actions to be taken in the event of different emergencies during construction. As part of the ESMS (ESAP #1), CRE will develop a Group level EPRP which will be cascaded to existing and planned facilities. The EPRP will include assessment of emergencies, decisions on evacuation, and detail procedures, as well as the roles and responsibilities of various employees, occupants and teams, communities and individuals that may be impacted, response procedures and periodic training for all employees and in particular for the internal emergency fire marshals, evacuation exercises and semi-annual fire drill programs in line with local regulation.
Monitoring and Review:
The project team at Mzizi Court oversees the monitoring of the project. The contractor provides daily and weekly reports to the project team. The team conducts site visits and inspections and tracks E&S and OHS Key Performance Indicators (KPIs). Monthly meetings are also conducted, where E&S issues related to the construction are discussed, and monitoring reports are shared with management teams.
The company will develop a monitoring and reporting procedure as part of the of the ESMS (ESAP #1a). The procedure will detail: i) identified key performance indicators (KPIs) on E&S compliance and performance, as well as objectives and targets on sustainability (resource efficiency); ii) monitoring processes (corporate audits, internal/external audits); iii) reporting requirements in specific formats, including routine reporting via a corporate risk register to the company board; and iv) the development of a corrective actions register to capture and track the closure of corrective actions.
PS2: Labour and Working Conditions
As at August 2023, CRE had a total of 30 staff members. Of these, six staff members work actively on Mzizi project. The six staff include the project mamager, assistant project manager, clerk of works and three sales executives. The main contractor has 17 direct staff working on the site, and 30 staff who are hired through a third-party agent. For phase one of Mzizi Court, there are 200 temporary staff who are working on the site. As per the resource estimation plan, a construction workforce of 2600 workers will be required over the 3 phases to complete Mzizi court. Upon completion, CRE hands over the completed project to a third party property management company.
Human Resource Policies & Procedures:
Centum Real Estate adopts the Group Human Resources (HR) Policies and Procedures Manual covering, compensation, ethical conduct, roles and responsibilities, leave, performance management, disciplinary procedures, grievance procedures, and sexual harassment and discrimination. The HR Manual (updated in August 2023) is generally aligned with IFC PS 2 requirements and incorporates explicit references to the freedom of association with worker organizations, non-discrimination, non-use of child/forced labor, retrenchment, and anonymous grievance mechanism. The updated HR policies and procedures will be communicated to workers and contractors through various channels including induction, regular training, and refreshers (ESAP #3).
Working Conditions and Terms of Employment
Centum Real Estate makes use of contractors and sub-contractors during construction. All employees and contractors have been provided with written contracts. Regulatory bodies conduct annual labor audits, covering working conditions. The company also conducts an internal HR audit from its Head Quarters.
Worker Organizations
None of CRE’s direct employees or contractors are unionized. The company includes a clause in the HR Manual and employment contract, allowing freedom of joining unions..
Grievance Mechanism:
The company has implemented an employee grievance management mechanism as a component of their internal management policies and procedures. As part of the communication of the updated HR manual (ESAP #3), the Group will train staff and contractors on the procedure for grievance submission, requirements and options, roles and responsibilities and appropriate feedback and resolution timelines for grievances.
Occupational Health and Safety:
At the Mzizi Court construction site, the main contractor has a Health and Safety (HSSE) Policy that is implemented for all contracted and sub-contracted employees. The policy describes Health, Safety, and Environment (HSE) performance and responsibilities, training, specific use of fire policy, HSE performance management, sub-contractor management, and list of personal protective equipment (PPE) to be used on site. As part of the management programs to be developed under the ESMS (ESAP #1a), the Group will develop and implement an occupational health and safety (OHS) management plan at corporate level for all its business operations, where applicable. The OHS procedures will cover both construction and operation phases of the project and include elements such as a construction safety plan, fall protection plan, PPE requirements, site safety induction procedures, incident register management procedure, site safety meeting minutes, and near misses and lost time injuries rate (LTIR) tracker amongst others. The OHS procedures will be in line with country regulation and relevant sections of the WBG General Guidelines and IFC Performance Standard 2.
Third Party Workers and Supply Chain:
Centum Real Estate implements a supplier code of conduct for its contractors. In addition to reviewing contractors’ relevant permits, licenses, authorizations and agreements, the company will develop a Contractor Management Plan as part of its ESMS, to have oversight and manage its contractors. The management plan will also include a screening procedure, require contractors and sub-contractors to comply with the company’s code of conduct, the EMP, and management programs developed as part of the ESMS (ESAP #1a).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
The company has achieved Excellence in Design for Greater Efficiencies (EDGE) Preliminary certification for Mzizi Court for the implementation of energy, water and material efficiencies in its design. Other efficiency measures at Mzizi Court include LED lights, reduced window to wall ratio, reflective paint to reduce heating, solar photovoltaics, and smart energy meters for electrical energy. The Two Rivers development sources 80% of its power from the national grid and 20% from the solar plant within the development.
Water and Wastewater
Water that will be used at the completion of Mzizi Court will be sourced from boreholes. The Two Rivers Development has a water treatment plant and laboratory that regularly monitors and controls water quality to WHO standards. Effluent wastewater monitoring data were within NEMA standards. The recycled water from the development is used for irrigation, cleaning and in the construction of Mzizi Court.
Solid and hazardous waste management
Two Rivers Development has an Integrated Waste Management Strategy that is adopted by all developers on the site. The document describes roles and responsibilities, guiding principles, requirements for developers, and non-compliance penalties. The solid waste collected from the construction site is periodically collected and recycled by a licensed third-party contractor.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design, Life and Fire Safety
Centum Real Estate has designed and begun constructing Mzizi Court in accordance with British Building Regulation (ver. 2010 with 2020 amendments for dwellings). All designs and architectural projects of residential buildings are carried out by specialized architecture and engineering design companies with recognized significant experience, in line with the local building codes, regulations and international good practice. and includes features of accessibility requirements in all buildings. The company has applied for the corresponding fire permits for the facilities and these will be as obtained as part of the occupation certificate that will be issued once the building is completed.
The residential building design plans indicate fire and safety equipment, such as two enclosed fire exit staircases per block, smoke control (i.e., pressurization system) in staircases, fire extinguishers, standpipes, hose reels, fire detection and alarm with manual pull stations in all areas. The company will engage with a suitably qualified fire safety specialist to conduct a review of the design specifications and update against the requirements of the L&FS section of the WBG General EHS Guidelines (ESAP #4a) and upon completion of the construction, test life and fire safety systems and certify that these systems comply with national, as well as international fire safety and building codes, as referred to in the L&FS section of the WBG General EHS Guidelines, for public access buildings (ESAP #4b).
As part of ESAP #1a, the company will develop a detailed program for commissioning of the buildings and the respective Operations and Maintenance (“O&M”) plan for L&FS systems that will be attached to the occupancy contracts of the condominium, after selling the units. The plan will include the method of operation of the systems, the frequency and procedure for the inspection, testing and maintenance of L&FS systems aligned with international codes, as well as the emergency preparation requirements for the respective building.
Community Health and Safety:
The main contractor implements a Transport Policy. Mitigation for road incidents include training programs for driver, compliance with safe travel standards, monitoring operating guidelines for vehicles and motorcycles. At the project level, traffic incidents are managed through the EMP. Centum Real Estate will manage the implementation of the Transport Policy through the contractor management plan and safety procedures. The company will identify specific KPIs to monitor traffic on site.
Security Personnel:
The company engages the services of an internationally certified security firm at the Two Rivers Development who has deployed over 200 private armed security personnel. Public security officers are also deployed at the development. The security firm conducts regular evacuation drills and also implements a de-escalation policy. The security firm also makes use of smart ultra-modern security systems. The company will document a corporate security management plan as part of the ESMS (ESAP #1a), defining its security management practices, policies, and procedures in line with IFC’s Performance Standard 4.
