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 Management System
Hospital Metropolitano has a unified risk policy and management system, accredited by the Joint Commission International (JCI). The hospital also has Planetree Person-Centered Care Certification, which addresses the welfare of patients, staff, and the community. The hospital’s management systems are generally in compliance with IFC PS requirements. As per ESAP item #1, Conclina will develop an E&S Policy for the construction and operation of Hospital Metropolitano de San Patricio, in line with IFC PS1, defining the E&S objectives and principles that guide the Group to achieve sound performance in all areas of E&S across all its business units.
The Group is required per regulations to prepare an ESIA for the operation of Hospital Metropolitano de San Patricio. For the new building at Hospital Metropolitano, the Group will prepare an addendum to the site’s existing ESIA to obtain authorization for construction and operation. The building works will be delivered by specialist contractors, (see “Workers Engaged by Third Parties” under PS2). As per ESAP #2, the Group will carry out ESIAs for Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano in line with Good International Industry Practice (GIIP) and the requirements of IFC PS. This will include the identification of any E&S impacts or risks to surrounding communities, and the establishment of corresponding mitigation measures.
Organizational Capacity and Competency
At Hospital Metropolitano, E&S matters are overseen by the Operations and Quality Director who reports directly to the General Manager. The team includes a Risk Manager (covering regulatory compliance, environment, health, safety, and security), as well as an analyst and several auditors. Labor matters at all sites are managed centrally by the Group HR team. From an E&S perspective, the construction and commissioning of Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano will be overseen by Hospital Metropolitano's Risk Manager.
Emergency Response Planning
Hospital Metropolitano has emergency preparedness and response procedures (EPRP) and its emergency response plan has been approved by the local fire department. Per local regulation and JCI requirements, the new hospital buildings will prepare emergency preparedness and response procedures equivalent to those of Hospital Metropolitano.
Monitoring and Review
Hospital Metropolitano reports its environmental aspects quarterly to the Ecuadorian Secretary of Environment. E&S key performance indicators (KPIs) are discussed with the General Manager at the weekly quality and risk meeting. Every six months the KPIs are presented to the board.
PS2: Labor and Working Conditions
As of the end of 2022, the Group registered around 1,500 direct employees, of which 65% were female. The new hospital is expected to increase the number of employees by around 260 in year one, growing to around 400 by year 10. Hospital Metropolitano also utilizes contractors as security guards and food preparation services. The majority of doctors working at the Group’s facilities are self-employed. Employees are free to associate in unions in line with local legislation but have not chosen to do so.
Human Resources (HR) Policies and Procedures
The Group has an HR policy and relevant procedures (the Internal Work Regulations) that align with Ecuadorian regulations and are in material compliance with IFC PS2 requirements. The HR policy, the policy on the prevention of discrimination, harassment and violence, and the Code of Ethics, are distributed to employees upon hiring.
Worker Grievance Mechanism
In accordance with Planetree and JCI requirements, the Group has a mechanism to receive grievances from workers, patients, and stakeholders in general. Grievance can be reported anonymously by means of a phone number, website, or email address (https://www.hospitalmetropolitano.org/es/canal-de-reporte-confidencial). Workers also have the option to report grievances directly to supervisors or HR. Grievance handling is overseen by an independent controller. KPI’s for grievance management are tracked. This same system will be used by the construction projects.
Gender-based Violence and Harassment (GBVH)
The Group’s policy on the prevention of discrimination, harassment and violence commits to a zero-tolerance standard with respect to harassment and violence. It includes the confidential complaints channel and HR professionals are specifically trained in how to respond to cases of sexual harassment.
Occupational Health and Safety
Hospital Metropolitano’s OHS management system is aligned with the JCI requirements and generally complies with IFC PS2 requirements. The Hospital performs regular assessments of biohazard contamination risks, noise in key hospital areas, gas system monitoring, radiation dose monitoring, ergonomics, psychosocial risks, among others. There is an occupational health doctor on site that assesses fitness for work and treats occupational diseases and injuries.
Workers Engaged by Third Parties
The Group will utilize contractors for the design and construction of Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano. For each project, the construction contractor will develop a detailed construction plan that considers E&S risks and mitigations in line with local and national regulatory requirements and permits as well as JCI requirements, including emergency preparedness and response procedures. The Group will contract an independent specialist auditor to oversee the construction contractor. As per ESAP item #3, the Group will develop a Construction Contractor Management Plan for Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
At Hospital Metropolitano, resource efficiency is part of the hospital’s strategic planning process, (e.g., the initiative to reduce plastic water bottle use). The new hospital will be designed to achieve EDGE green building certification. Lighting at the San Patricio Smart Living complex is provided by energy efficient LED streetlamps and rainwater is collected for irrigation of native low water-demand plant species.
As per ESAP item #1, the E&S Policy for the construction and operation of Hospital Metropolitano de San Patricio will include a Resource Efficiency Policy, detailing a systematic approach to identifying efficiency opportunities and demonstrating continuous improvement over time.
Pollution Prevention
Potable water for the Group’s facilities is provided by the municipal system. Most wastewater is discharged directly to the municipal sewage system, except for water from the hospital’s kitchen, laundry and laboratory which is pre-treated prior to entering the sewage system, as required by the environmental management plan. The same requirements are expected for the new hospital.
The existing hospital has diesel generators for emergency power and has four boilers which are tested once a quarter to verify compliance with local regulations. Planetree Certification requirements include mitigation and monitoring of noise sources. As per ESAP #2, the ESIAs for Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano will include identification of pollution risks and associated mitigation measures.
Wastes, Hazardous Materials Management
The Group tracks its conventional, hazardous, and recyclable wastes. There are special rooms to store hazardous chemicals and hazardous wastes in the hospital (including medical and radiological wastes), according to local regulations and JCI requirements. Disposal is carried out by a licensed third party as per Ecuadorian requirements and GIIP. Duty of care audits of third-party waste facilities are periodically conducted. Waste management will feature as one of the components of each construction contractor’s detailed construction plan.
PS4: Community Health, Safety and Security
Community Health and Safety Management
Hospital Metropolitano has implemented measures to avoid intra-hospital infections as part of the requirements to obtain the JCI certification, that includes a management of change procedure. The hospital has engineering and administrative controls including ventilation systems, architectural segregation, decontamination practices, and controls on water, food, and waste, among other preventive and corrective measures.
For each new hospital building, the construction contractor develops a detailed construction plan which considers community safety risks, including risks related to vehicle movements. As per ESAP item #3, the Group will develop contractor management procedures for the planned construction projects that will include community health and safety management.
Life and Fire Safety
All Group facilities are required to comply with Ecuadorian life and fire safety (L&FS) and accessibility related building codes, which reference the NFPA standards for healthcare facilities. Hospital Metropolitano also complies with JCI L&FS and accessibility requirements, as will the new hospital buildings.
For Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano, as per ESAP item #4, the Group will: (a) at the design stage, obtain from the design team’s professional members a letter of certification that the L&FS and accessibility design documents (i.e. a L&FS Master Plan and detailed engineering of each system) comply with the specifics of the WBG General EHS Guidelines, and local construction code (i.e., NEC-HS-CI and NFPA); and (b) upon completion of each building (post-construction) at the time of the L&FS systems testing and commissioning, the company will obtain from the construction supervision team’s L&FS professional a letter of certification confirming that the construction of these systems has been carried out in accordance with the approved design documents (i.e. the L&FS Master Plan) and overall design concept.
Security Management
Hospital Metropolitano arrangements for its security personnel are generally in compliance with IFC PS4 requirements. Security services are subcontracted to an external company and the contract is monitored by the Manager of Security. The security company performs background checks on new employees and periodically provides training to its employees. There are 17 security positions at the hospital, (all unarmed), and they are trained to assist in case of an emergency. Similar arrangements will be in place for the operation of the new hospital. The San Patricio Smart Living site is currently patrolled by armed uniformed security on motorbikes. As per ESAP item #3 the Construction Contractor Management Plans for Hospital Metropolitano de San Patricio and the new building at Hospital Metropolitano will include a specific plan addressing the public safety and security risks posed by the construction site security arrangements.
