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.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
AODC implements a centralized Environmental and Social Management System (ESMS) for the whole Ayla area including Oasis-33. ESMS was established based on the risks and impacts identified in the Environmental Impact Assessment (EIA) report and included an Environmental Management Plan (EMP) prepared which was approved by ASEZA in 2008. The ESMS covered E&S organization; LFS and emergency response procedure; E&S monitoring and reviewing mechanism; environmental protection and biodiversity conservation; and safety and security procedures.
As per ESAP #1, for Oasis-33, AODC will revise and implement, its ESMS and standard operating procedures (SOPs) in line with IFC PSs, WBG EHS Guideline for Tourism and Hospitality, good international industrial practices (GIIPs) and local legislation requirements. These will include, but not limited to; fair and safe labor conditions, grievance mechanism and E&S monitoring and review mechanism supported with key E&S performance indicators (KPIs), etc.
AODC has a dedicated E&S management team headed by the Director of Facilities and Technical Services Environmental, Safety, & Security Supervisor and established committees as per the national regulatory requirements, with overall responsibility and authority for overseeing and managing the health, safety, security and environment (all together, referred as E&S) and energy efficiency management practices of each and every business operating in Ayla. As per ESAP item #2, AODC will assign, for Oasis-33, a dedicated E&S coordinator with relevant expertise and experience, who will have the overall responsibility and authority for overseeing and managing all E&S risks of the project assets under construction and/or operation, including implementation of the corporate ESMS, to be prepared as part of ESAP item #1.
AODC has emergency management procedures for Ayla with specific focus on fire and earthquake preparedness. It includes emergency response teams (firefighting, evacuation, first aid and rescue teams), their roles and responsibilities, the contact details and emergency alert mechanisms.
EMP includes periodic internal and external monitoring requirements, for design, construction and operations, and the results were reported to Environment Directorate of ASEZA. Oasis-33, as per the ESAP item #1, will develop, as part of its ESMS, monitoring procedures for Hyatt, Cloud7 and operation period of The Pulse Hotel Ayla, with key performance indicators for water, electricity, fuel and LPG consumptions, hazardous and non-hazardous wastes, community complaints, LTIFR (Lost Time Injury Frequency Rate, number of lost time injuries per million worked hour) and record of near misses and injuries.
PS 2 – Labor and Working Conditions
AODC has about 341 employees as of July 2023, comprising 308 males and 33 (9.7 percent) females, including 12 staff assigned to Oasis-33. Hyatt and Cloud7 employ 292 males and 57 (16 percent) females; and 41 males and 8 (16 percent) females, respectively. All employees are full-time and have fixed-term contracts with a three-month probationary period.
Human Resources Policies and Procedures:
AODC, Hyatt and Kerten have their own Code of Business Conduct and Ethics and employee handbooks outlining company’s HR policy provisions including employment terms and conditions (employment contract, probationary period, shift schedule, salary payment, time recording, overtime work and open door policy); compensation and benefits (medical insurance, social security, leaves and trainings); rules and regulations including anti-sexual harassment policy; disciplinary procedure; and performance management. As per the ESAP item #3 AODC will develop HR policies and procedures for Oasis-33 in line with IFC PS2 requirements to cover non-discrimination and equal opportunity, gender-based violence and sexual harassment, freedom of association and collective bargaining, child and forced labor, retrenchment, accommodation, and grievance mechanism. In addition, HR policies and procedures of Oasis-33 will be adopted and implemented throughout the hotels under the project by Hyatt, Kerten and the operator of The Pulse Hotel Ayla. These policies will be adequately reflected in their employee handbooks, employee contracts and induction trainings; with relevant measures to supervise the implementation and compliance.
Worker Grievance Mechanism:
AODC has an open-door policy requiring employees to direct their grievances either to their supervisor or HR department. There is no formal grievance mechanism procedure that allows redressal of anonymous grievances. As a part of ESAP item #3, AODC will develop for Oasis-33 a structured grievance mechanism to be followed at the project hotels, that allows employees to raise all workplace related concerns with provisions for anonymous grievances including a route for gender-based violence related grievances. Grievance mechanism will be disclosed and communicated to both the employees of Oasis-33, Hyatt, Cloud7 and the operator of The Pulse Hotel Ayla.
Worker’s organization
Employees of AODC, Hyatt and Kerten are not unionized. As per ESAP item#3, AODC will include provisions for freedom of association in HR policies and procedures to be developed for Oasis-33 to underline the workers right to form and to join workers’ organizations of their choosing without interference and to bargain collectively. HR policies and procedures will indicate that there will be no discrimination or retaliation against workers who participate, or seek to participate, in organization or collective bargaining.
Gender:
AODC will further improve the implementation of HR policies of Oasis-33 by integration of GBV and sexual harassment policy, procedures and grievance mechanism into the staff induction training. A training program will be developed to ensure that once a year refresher training will be provided covering GBV and sexual harassment policy procedures, code of conduct and grievance mechanism for all existing staff of Hyatt and Kerten and mandatory onboarding training for any newly recruited staff will be conducted. The management team shall be trained separately from other employees (ESAP item #3).
Retrenchment:
The code of business conduct and ethics of AODC explicitly addresses dismissal and termination procedures in compliance with the national labor law, as outlined in the disciplinary policy. AODC will develop HR policy and procedures for Oasis-33 with provisions for collective dismissals (retrenchment) in line with IFC’s PS2.
Accommodation:
Non-local employees were provided with accommodation either in hotel premises within Ayla or in the apartments rented in Aqaba town center by Hyatt and Kerten. No on-site worker accommodation is envisaged for the construction workers of The Pulse Hotel Ayla.
Occupational, Health and Safety (OHS):
AODC has an HSE policy aiming to provide and maintain a safe environment for employees, visitors, and guests. Several SOPs are in place for OHS management during construction and operations, including hazard and risk assessment, permit to work, working in confined spaces, identification and use of personal protective equipment (PPE) and incidence reporting. Employee handbooks refer to safety related topics such as hygiene, PPE use and following the other OHS rules and requirements identified for their work areas. The HSE committee was formed to reduce injuries and maintain safety rules in the workplace. Each asset in Ayla Oasis under construction or operation is regularly checked and controlled by the respective departmental teams to identify OHS related non-compliances. Findings of these controls, together with OHS statistics (incident records) trainings and drills conducted are compiled in monthly HSE reports for the review of an HSE committee and Ayla Oasis management. No fatalities or major incidents have been reported over the past two years.
Workers engaged by third parties:
The security and safety instructions of AODC includes procedures for contractors engaged in Ayla projects, including retaining necessary firefighting equipment and dedicated specialized OHS personnel at the site, and commitments to comply with the OHS, traffic, environmental, public safety national regulations, legislations and instructions. The construction of The Pulse Hotel is expected to be resumed in the first half of 2024. AODC identified HSE and OHS requirements for the construction contractors in the Site Regulation and Guidelines document which is annexed to the construction contract.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency and Green House Gas Emissions:
The seawater replenishment pump station, golf course and cooling system are fed by the solar PV plants with 5.8 MW total installed capacity. The remaining electricity is sourced from the national public grid.
Drinking water at Ayla is provided through the Aqaba Water Company (AWC) (some 3000 cubic meters per day). For irrigation, Ayla utilizes treated wastewater supplied by AWC and the underground water extracted (from 19 wells) and treated through a reverse osmosis system.
AODC established an energy efficiency committee, focusing on energy efficiency and resource conservation.
The main source of greenhouse gas (“GHG”) emissions is from the LPG and electricity usage of the project facilities. Project’s overall GHG emissions are estimated to be 4,190 tCO2e.
Wastewater
Ayla's wastewater is discharged into the sewage network of AWC where AWC returns some quantity of the treated wastewater (3000 cubic meters per day) back to Ayla to be used for irrigation purposes.
Waste Management
The waste generated in Ayla is collected and disposed by Aqaba municipality. AODC has waste management operating procedures including handling, storage and disposal.
Hazardous Materials Management
AODC has SOPs for safe handling of various chemicals such as chlorine and acids, maintaining an up-to-date chemical inventory, identifying potential hazards, conducting training sessions, ensuring proper storage practices, promoting safe handling procedures, establishing emergency response protocols, defining disposal procedures, implementing ventilation and engineering controls, conducting routine inspections, and maintaining a robust documentation system for chemical purchases, usage, disposal, and incidents, as well as performing continuous risk assessments.
SOP for controlling flies and mosquitoes within Ayla area is in place. Fly and mosquito control is conducted by a contracted expert service provider in line with the SOP.
PS 4 – Community Health, Safety and Security
The project is within proximity to residential areas that may be affected by increases in traffic associated with vehicle movements during construction and operations. AODC has a traffic management plan and transportation safety procedures in place for prevention of road accidents and providing safe transportation for the employees, materials, wastes and travelling guests to Ayla Marina Village. Hyatt is certified in the Food Safety Program, incorporating the principles of HACCP. The ESMS of Oasis-33 will include a food safety program incorporating the good international industry practices and standards, to be implemented by the operator of The Pulse Hotel Ayla.
Life and Fire Safety (LFS) Management:
AODC, in 2013, hired a competent consultant to provide concept guidance criteria for the design of Hyatt as per the international standards (NFPA) and national regulatory LFS requirements. LFS manual and set of SOPs are in place for the entire Ayla development area, explaining firefighting protection and safety measures such as fire alarm system, fire extinguishers, fire hose reel, smoke detectors, assembly points, fire drills, firefighting, evacuation, first aid and rescue teams. Periodic briefings and evacuation drills are conducted as per legal requirements organized by the AODC security department team.
As per the ESAP item #4a, Oasis-33 will engage a competent LFS professional acceptable to IFC to conduct a design review of The Pulse Hotel to identify LFS design criteria for this asset as per the GIIP and upon completion of the construction, to undertake a construction review to confirm that the asset was constructed in accordance with the identified design criteria (ESAP item #4b).
Security Personnel:
All assets including hotels are patrolled by 40 unarmed security guards deployed by AODC. Regular training programs and on-the-job trainings are conducted for security workers on standard operating procedures for their job including life and fire safety emergency trainings.
PS 6 – Biodiversity Conversation and Sustainable Management of Living Natural Resources
Ayla Oasis is located in Aqaba on the coast of the Red Sea, which falls within the Red Sea Nubo-Sindian tropical desert and semi-desert ecoregion of the deserts and xeric shrublands biome in Jordan (as designated by the World Wildlife Fund). Initial construction of the existing hotel complex started in 2008 and added 17 km to the coastline through establishing artificial lagoons within the complex.
The area also falls within the Aqaba Coast and Mountains Key Biodiversity Areas (KBA)/Important Bird and Biodiversity Area (IBA), which is a migratory bottleneck site that also holds breeding bird communities. The activities under the project will be confined to the completion of the Pulse Hotel construction. Impacts on biodiversity values associated with Aqaba Coast and KBA/IBA are therefore not anticipated. AODC has been working in cooperation with a local biodiversity NGO to identify and monitor bird species since 2012 and ongoing monitoring studies by them suggest that artificial lagoons and surrounding areas established in Ayla provide suitable habitats as resting points for migratory bird species, which have increased in number and density over the past decade. AODC is also engaged with marine researchers studying ecological conditions within the artificial lagoons and monitoring fish species. The lagoons host coral nurseries, the first of which was established in 2015, and AODC has a team of experts monitoring the coral growth at the nurseries, and conducting transplantation as new suitable areas are identified for coral growth. AODC will continue monitoring birds, fish and corals and take measures to address any impacts in collaboration with relevant stakeholders and in line with the ESMS to be developed for Oasis-33 (ESAP item #1).
