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
FIBRA MQ has an E&S Management Policy, a WHSE Policy, Environmental Guidelines, Sustainability Guidelines, and a Health and Safety (H&S) Framework, the scopes of which apply to industrial property management and/or construction. As per ESAP item #1, FIBRA MQ will build on its existing policies and procedures to further develop its integrated E&S management system (ESMS), commensurate to the scale and impacts of its activities, and consistent with the IFC PS and relevant World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines. The ESMS will apply to (but not limited to) site selection, design, construction, and operations and maintenance (O&M) of existing and new assets, including work executed by contractors.
For prospective sites and for new projects, the Company uses a checklist to identify E&S risks and impacts, then carries out Phase I environmental site assessment, and also conducts an environmental impact assessment (EIA) as required by local regulations. As part of ESAP item #2, FIBRA MQ will build on existing processes to further develop its due diligence procedure for prospective land acquisition &/or undeveloped sites to screen for potential E&S risks and impacts in line with IFC PS1-8 requirements.
Organizational Capacity and Competency
The Company WHSE Committee is led by the WHSE Manager, while the Sustainability Committee is led by the Sustainability Manager. Both committees report E&S performance to the FIBRA MQ Manager Board on a quarterly basis. In turn, the Manager reports performance to a Technical Committee composed primarily of independent members. MAM ESG specialists sit on the Sustainability Committee and the global safety lead of MAM Real Estate sit on the WHSE Committee. MPA’s engineering team includes architects and engineers responsible for designing new industrial parks, as well as the preparations of EIAs, (in collaboration with specialist permitting consultants). Going forward, as per ESAP item #3, FIBRA MQ will designate an ESMS Manager, responsible for the continued development and maintenance of the integrated ESMS.
Emergency Response Planning
The H&S Framework includes a section dedicated to emergency preparedness and response plans (EPRP) detailing the EPRP requirements for offices, construction sites, and properties under the control of FIBRA MQ. Emergency drills are held during the year. FIBRA MQ’s industrial buildings are required to comply with national and local structural and fire safety codes. Contracts with tenants generally require the tenant to perform inspection, testing and maintenance (ITM) of Life and Fire Safety (L&FS) systems, including emergency power generation systems, in accordance with Mexican regulatory requirements.
Monitoring and Review
FIBRA MQ E&S personnel, property management, and senior management visit properties and construction sites periodically to conduct E&S inspections. Furthermore, the Company carries out an annual third-party audit of its activities, including E&S. E&S key performance indicators (KPIs) are reported to the Manager Board on a quarterly basis, including injury frequency, injury severity, environmental incidents, compliance indicators, among others. Performance is also reported publicly in the annual ESG report, (https://www.fibramacquarie.com/assets/fibra/docs/events-and-presentations/2023/fibra-mq-mx-2022-esg-report.pdf). As part of ESAP item #1 FIBRA MQ will develop procedures to monitor compliance with the whole ESMS, including KPIs and performance targets for all aspects of E&S, as defined by IFC PS, as well as an audit program to verify compliance with applicable legal requirements, IFC PS and relevant parameters of the WBG EHS guidelines.
PS2: Labor and Working Conditions
As per the 2022 ESG report, the Company reported 90 members of staff, of which 46.7% are female. The percentage of females in management positions is 34.7%.
Human Resources (HR) Policies and Procedures
FIBRA MQ has HR policies, a model employment contract, and a Code of Conduct. These are complemented at MAM’s global level by the Macquarie Code of Conduct (https://www.macquarie.com/assets/macq/impact/esg/policies/Code%20of%20conduct.pdf) and Workforce Diversity Policy (https://www.macquarie.com/assets/macq/about/diversity/macquarie-commitment-to-diversity.pdf). These policies are aligned with local regulations and cover labor and working conditions, including non-discrimination, promoting equal opportunity. The employment contract defines compensation, work hours, leave and medical benefits, disciplinary procedures. As per ESAP item #4 FIBRA MQ via MPA will update its HR policies and model contract in accordance with IFC PS 2, including clear provisions for minimum age, overtime payment, hours of work, as well as a hiring policy to promote diversity in its workforce, including within management positions.
Gender-based Violence and Harassment (GBVH)
The Macquarie Code of Conduct has zero tolerance for any form of inappropriate workplace behavior including sexual harassment, harassment of any other kind, discrimination, bullying or victimization. This stance is reiterated in FIBRA MQ’s Appropriate Workplace Behavior Policy and Equal Employment Opportunity Policy. All Company staff have free access to the Emotional Support Program, which includes support for employees who have experienced a traumatic event, including incidents of GBVH.
Workers Grievance Mechanism
At MAM’s global level, the Macquarie Code of Conduct allows any stakeholder to report a grievance to the Integrity Office (integrityoffice@macquarie.com), which is responsible for implementing the Whistleblower Program (https://www.macquarie.com/assets/macq/about/disclosures/whistleblower-policy.pdf). Alternatively, staff can contact the global Macquarie Staff Hotline anonymously. As part of ESAP item #4, FIBRA MQ will develop a local grievance mechanism procedure, defining how it addresses concerns and grievances promptly, using an understandable and transparent process that provides timely feedback to those concerned. The mechanism will allow for anonymous complaints to be raised and addressed.
Supply Chain
FIBRA MQ’s Code of Conduct for Service Providers requires all service providers to be familiar with the laws against forced labor and child labor. The procurement process includes a human rights questionnaire in each request for a proposal, which prospective suppliers must complete. An assessment of supplier risk then determines if FIBRA MQ will work with that supplier.
Occupational Health and Safety
The Company’s WHSE Policy and H&S Framework establish OHS requirements for construction and O&M activities in line with legislation and Macquarie requirements, including a permit to work process for high-risk activities. As part of ESAP item #1, the ESMS will include OHS management, with OHS practices that comply with the IFC PS and relevant WBG EHS Guidelines, applicable to FIBRA MQ’s construction and O&M activities.
Workers Engaged by Third Parties
FIBRA MQ utilizes contractors for the construction and O&M of all its industrial parks. Contractors are required to comply with a set of minimum E&S requirements, including compliance with the WHSE Policy, H&S Framework, and the Principles for Suppliers. Proposals from construction contractors are screened against E&S criteria, and once selected, they are supervised on site by a FIBRA MQ engineer. The WHSE Manager and a Sustainability Manager periodically visit construction sites to verify compliance and contractor workshops are conduct periodically to inform contractors on the Company’s requirements.
As per ESAP item #5, FIBRA MQ will (i) update its minimum E&S requirements for contractors to align with the IFC PS and relevant WBG EHS Guidelines, detailing the environmental, OHS, labor (including Company grievance mechanism), and social requirements; (ii) develop a contractor management and assurance plan (CMAP) codifying the controls to be implemented by FIBRA MQ (e.g. inspections, audits, walk-downs, E&S meetings, and periodic labor law due diligence) to verify compliance with the E&S minimum requirements; (iii) an E&S corrective and preventive actions management procedure to record and track the E&S performance of contractors, including monitoring KPIs.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
Developments within the scope of the Project will be 40% certified under LEED, EDGE or equivalent by 2026. FIBRA MQ has developed a LEED compatible prototype for the design and construction of industrial buildings, which is applied when requested by a client. For expansion projects, FIBRA MQ has a set of minimum E&S standards within their remodeling guidelines, including resource efficiency considerations. To encourage resource efficiency by tenants, FIBRA MQ has begun to include sustainability requirements in new leases per the “Green Lease Leader” requirements. FIBRA MQ’s Sustainability Guidelines guide clients on how to implement minor capex projects in a sustainable way.
FIBRA MQ’s estimated greenhouse gas emissions in 2022 were 2,094 metric tons of carbon dioxide equivalent (MTCO2e). The Company recently committed to Scope 1 and 2 emissions net-zero by 2040 through (i) a green building certification program; (ii) reducing resource consumption; (iii) maximizing on-site renewable generation (e.g., rooftop solar panels); and (iv) a green leasing strategy.
Water is primarily supplied by the municipal network or by truck, but the prototype design for new industrial parks also includes the collection and use of storm water, where legally permitted. Projects to improve water use efficiency in 2022 included low water landscaping and high efficiency fixtures.
Electricity for industrial buildings is provided by the Federal Electricity Commission, supported in some cases by rooftop solar panels. Energy efficiency was improved in 2022 through installation of high-efficiency equipment, improved wall/roof insulation and increased use of natural light.
Pollution Prevention
The Company has carried out a review of its industrial properties to verify the absence of polychlorinated biphenyls and asbestos. Equipment containing R-22 gas (an ozone depleting substance) at industrial properties have been identified and a plan has been established to phase out R-22.
FIBRA MQ has a construction works policy that contemplates noise, dust, and waste disposal among other items. Wastewater at construction sites is stored and removed by tanker by an authorized third party. During the operations phase, wastewater (from washrooms, kitchens, and cleaning activities) is typically reused for onsite irrigation, after treatment in accordance with applicable local and national legislation. Any residual wastewater is sent to the municipal sewage system.
When considering a new tenant, the Company conducts a risk screening to identify activities that present a risk of soil contamination. In such cases, specific control measures are included in the lease, and at the end of the lease, tenants are required to return the property free from any environmental damage.
Wastes, Hazardous Materials Management
Waste generated from offices includes food waste, plastic bottles, cans, paper/cardboard, light bulbs, and small amounts of batteries. Construction and O&M sites also generate wood, metal, plastic, and general construction waste, as well as waste oil, oil filters, oily rag, used paint, spent PPE, and small amounts of medical waste from first aid etc. Waste management is carried out by the construction and O&M contractors on site and their procedures are determined by local and national legislation. Waste is collected and disposed of by authorized third parties. Construction and O&M sites manage and store hazardous materials as per their classification in accordance with applicable legislation and manufacturer recommendations.
Lease agreements require tenants to be responsible for adequate disposal of waste and specific rules for hazardous materials handling and storage are included. When considering a new tenant, the Company’s risk screening rules out the use of certain types of hazardous materials. As part of ESAP item #1 FIBRA MQ will update its procedures for the handling and managing hazardous materials in line with the IFC PSs and the WBG EHS Guidelines.
PS4: Community Health, Safety and Security
Community Health and Safety Management
In the pre-planning meeting for a construction project, FIBRA MQ and the construction contractor discuss community health and safety risks and impacts, including traffic related matters. The contractor then develops a management plan which FIBRA MQ approves. Signs and personnel are placed at the entrances and exits to control the flow of vehicles and avoid accidents. As part of ESAP item #5 FIBRA MQ will update the E&S minimum requirements for contractors, requiring a traffic management plan for all construction projects, including driver and traffic safety programs according to the principles described in the General EHS Guidelines (Section 3.4 Traffic Safety).
Life and Fire Safety
FIBRA MQ builds private industrial parks, and the buildings are generally not accessible to the public. The Company complies with national and local structural and fire safety codes for the design of all facilities. When FIBRA MQ designs an industrial park, it includes; (i) access to the fire department and first responders; (ii) the main/campus fire protection systems (i.e. water tanks and fire pump system, hydrant mains, and interconnection with each tenant and internal protection of buildings), unless tenants request specific enhancements that are provided by FIBRA MQ under separate arrangements based on the risk; and (iii) fire alarm centralized reporting system for the park.
The Company also contracts a specialist third party to carry out an annual L&FS audit of a sample of properties selected on a risk basis. Furthermore, every property is visited at least once a year by FIBRA MQ’s Property Manager, which includes a review of L&FS. As part of commissioning new buildings or industrial parks, the Company obtains third-party certification of building’s materials, structure, and L&FS systems.
As per ESAP item #6, FIBRA MQ will commission a qualified L&FS professional acceptable to IFC to perform a risk-based evaluation of L&FS and accessibility of any industrial real estate locations which have buildings accessible to the public. Findings of the review will be used to set a time-bound action plan to be implemented and to introduce systematic improvements on L&FS management at such sites. The Company will also commission a qualified L&FS professional (acceptable to IFC) to develop a standard L&FS and accessibility Master Plan for industrial real estate where buildings accessible to the public are included in the design.
Security Management
At industrial parks which are wholly owned and operated by FIBRA MQ, third party security services are contracted by FIBRA MQ. The guards control access to the park and do not carry firearms. Individual tenants may also have their own security to control access to their respective buildings. At construction sites, third party security services are contracted by the principle construction contractor. As per ESAP item #7 FIBRA MQ will develop a security policy aligned with PS4 requiring that security personnel are guided by the principles of proportionality and good international practice, including requirements for training on the use of force. Contracts with constructions contractor and tenants will require those parties to align their own security policies / contracts with FIBRA MQ’s policy.
