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
E&S Management System, E&S Policy, Identification of E&S Risks and Impacts and Management Programs:
The company has developed and implemented an E&S management system (ESMS) generally in line with IFC PS requirements. ESMS includes a corporate ESG policy, risk assessment and identification procedures, emergency response plan, waste management procedures, applicable to all project assets. The company has disclosed its ESG policy on corporate website (https://nwpproperty.com/esg/). The ESG policy demonstrates company’s commitments related to E&S compliance, worker and public health and safety, resource efficiency and sustainability, continuous improvement, communication and engagement with workers and stakeholders.
The company identifies and manages E&S risks and impacts associated with its operations per applicable national standards and regulatory requirements. The existing identification of E&S risks and impacts and assessment system is generally in line with PS1 requirements. There is no major construction/rehabilitation process for the project assets and thus the company is not required to undertake an Environmental Social Impact Assessment (ESIA) per local legislations.
Organizational Capacity and Competency:
The company has a manager at company headquarter in charge of E&S management and assigned additional site managers with E&S responsibilities at each project asset. The company has several specialists and dedicated an E&S team to oversee various aspects of project assets including sustainability, environmental monitoring and safety.
Emergency Preparedness and Response:
The company has emergency response procedures (ERP) for each project asset, including responsibilities and duties defined for staff and procedures for disaster prevention and management. It consists of a standard operating procedure as well as provision of relevant trainings on how to response in case of fire, natural disaster, other emergencies and accidents.
Monitoring and Review:
The company monitors all project assets’ key performance indicators (KPIs) such as environment (energy efficiency, waste and wastewater management), OHS incidents and fire. The bi-weekly E&S performance monitoring reports are submitted to corporate management for their review.
PS2: Labor and Working Conditions
As of March 2023, NWP has around 700 employees (76% male and 24% female) in total, employed directly. In addition, NWP employs third party agencies activities as discussed in the sections below.
Human Resources Policies and Procedures:
The company’s HR documents include HR policies, an HR handbook and code of conduct, which defines the rights and obligations of the workers, working hours, overtime, annual and sick leaves, social security and health insurance, resolution of complaints, and terminations. As part of ESAP 1, the company will update its HR policies and procedures, in line with IFC PS2, to include; (i) worker grievance process applicable for its contractual workers; (ii) clear statements for freedom of association; and, (iii) measures to monitor and prevent forced and/or child labor.
Working Conditions and Terms of Employment:
All employees are provided with a contract, which includes working hours and location, wages and allowance, holidays and leaves, health insurance and termination. According to the company’s management, all employees exceed the minimum age of 18 years. however, no explicit policy on child and/or forced labor is available. As described in ESAP 1: NWP will update its employment policies and procedures to include measure to monitor and prevent child and/or forced labor.
Workers’ Organization and Retrenchment:
According to its management, NWP does not restrict workers from freedom of association, in line with local regulations. There is no labor union present at NWP, representing employees in the project assets. The company has not implemented retrenchment in the project assets and is not anticipating one. As described in ESAP 1: the company will update its HR policy and procedure to include clear statements for freedom of organization.
Non-discrimination and Equal Opportunity:
NWP implements an anti-harassment policy, covering non-discrimination and equal opportunity. The policy has a documented process for the prevention of any kind of harassment, including sexual harassment and gender-based violence, and a grievance procedure including confidentiality.
Worker Grievance Mechanism:
The company has established a workers grievance mechanisms as part of its whistleblower policy and anti-bribery compliance policy, including an option to raise anonymous grievance. NWP contractors do not have access to the grievance mechanism. As described in ESAP 1: the company will update its worker grievance mechanism procedure to be applicable for its contractual workers.
Occupational Health and Safety:
The company has developed an OHS management system, including a risk identification process. Induction and regular OHS trainings provided to all the employees. As per ESAP 2, NWP will develop an OHS management program for project assets, including: (i) procedures to systematically assess OHS risks and hazards at sites; (ii) define supervisory personnel roles and responsibilities; (iii) define OHS requirements and operational standards aligned with international good practices and the WBG General EHS Guidelines, such as work at heights, scaffolding, lifting, hot work, including appropriate use of personal protective equipment (PPE).
Workers Engaged by Third Parties:
The company employs third party agencies to perform activities including cleaning, security personnel as well as construction works. Company’s E&S requirement are embedded into contractor agreements and relevant departments, including operations, procurement, and legal, are overseeing contractor’s compliance and performance.
Supply Chain:
The company currently does not have a formal E&S screening process or a documented supplier Code of Conduct. As part of ESAP 3 the company will establish a supplier Code of Conduct articulating its commitment to prohibit forced, and/or child labor and significant occupational health and safety risks.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency, Greenhouse Gas (GHG) and Air Emissions:
Electricity is sourced from the national grid through the municipal power supply. Resource efficiency initiatives, including installation of LED lighting and wastewater recycling for the use of cooling tower and gardening, are implemented. At project assets, diesel oil for backup generators and liquefied petroleum gas by food and beverage tenants will be in use. Considering the annual consumption, significant quantities of air emissions are not expected.
Based on data from the company’s energy consumption including all project assets, total gross greenhouse gas (GHG) emissions is estimated to be around 23,600 tons of carbon dioxide gas emission equivalent per annum.
Water and Wastewater:
Most of the project assets supply water from the city network. Citimall Sampit utilizes exclusively deep well extraction, which has been authorized by the local government for its activities. Meanwhile, the Park Kendari employs a combination of city network water supply and partial deep well extraction as a precautionary measure.
For most of the project assets, wastewater is treated via sewage treatment plant (STP). The company monitors the wastewater quality which is generally in line with required standards. The effluent of the STP is utilized for gardening and/or cooling tower water and the rest is discharged to the city drainage.
Waste and Hazardous Material Management:
The company has waste management procedures including a system of separate collection, storage and disposal. All the waste is collected for disposal by an authorized third-party agency specialized in each type of waste.
Hazardous materials are limited to light bulbs, printer inks, refrigerant, as well as chemicals used for water treatment, cleaning and hygiene purposes, which are stored in small quantities, segregated and recycled/disposed by third party authorized companies. The company has hazardous material management procedure, which defines handling, storage and transportation of such materials.
PS4: Community Health, Safety and Security
Life and Fire Safety Management:
Project assets have fire safety certificates indicating that the fire protection system have been approved by local authorities and being regularly inspected. L&FS system includes fire hydrants, pumps and mobile extinguishers. NWP is responsible for L&FS inspection at project assets. As per ESAP 4, NWP will develop a comprehensive plan for the inspection and maintenance of the L&FS systems in the project assets, including fire detection and alarm, water systems, emergency lighting and power, and signage.
The project assets have been designed, considering the earthquakes, in line with applicable to local regulation in Indonesia.
Security Personnel:
Some mall assets are protected using contracted unarmed security. The company regularly undertakes internal briefings and provides training for the security personnel.
