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
Environmental and Social(E&S) Policy: GHM currently does not have E&S policies and procedures, however, the company has been implementing the sustainable development policy of the main sponsor, SNIM. SNIM’ sustainable development policy revolves around seven main axes: (i) stakeholders’ engagement; (ii) governance; (iii) value chain traceability; (iv) human resources, health and safety management; (v) safeguarding communities and socio-economic development; (vi) environment; and (vii) integrity. SNIM is also ISO 14001 (international standard for environmental management system) certified. As part of this investment, GHM will develop and implement an E&S framework which will include (i) an IFC PS aligned E&S policy; (ii) an E&S risk screening/assessment procedure for construction and operations in line statutory and IFC PSs requirements; (iii) detailed requirements for the Operator to develop and implement a hotel specific Environmental and Social Management System (ESMS); (iv) E&S monitoring procedures for hotel operations and activities carried out by the Operator, contractors and sub-contractors (will also include labor aspects); (v) a communication procedure including an external grievance redress mechanism (ESAP#1).
GHM and the Operator have signed a Hotel Management Agreement (HMA) that gives the Operator the exclusive control of the hotel in terms of management approaches and the determination and implementation of all policies and procedures, including the hotel’s E&S policies and procedures. The Operator’s policy includes the Operator’ commitment toward sustainable operation of its hotels, biodiversity and ecosystem protection, climate change mitigation, waste and pollution management among others and various policies on fair and ethical working environment. As a part of its E&S Framework, GHM will require the Operator to develop specific processes, plans, procedures and instruction to mitigate the E&S risks and impacts for the hotel, such as labor management procedures, OHS management procedures, covering hazard identification and risk assessment, L&FS, food safety, pool safety, crisis management, Legionella control procedure and pest control, electrical safety, air emissions monitoring and management plan, waste management procedures, hazardous material management plan, child safeguarding procedure, security management plan and other related E&S procedures, in line with local regulations and IFC PS requirements (ESAP#1)
Identification of Risks and Impacts: GHM identifies and manages E&S risks and impacts associated with its operations per applicable Mauritanian E&S regulatory requirements. In this context, GHM developed an Environmental and Social Impact Assessment which included construction and operational phase E&S management plans. During operation, the Operator will undertake regular internal E&S audits to identify new E&S risk that can occur including any forms of GBV and Child Safeguarding risks. GHM will regularly supervise and monitor the hotel E&S performance during operations.
Management Programs: The Company contractually requires from its contractors and sub-contractors to follow SNIM sustainability policy and align with ISO 14001 requirements, which is also generally aligned with IFC PS requirements. At the start of the construction, the contractors had prepared a Construction E&S Management Plan (CESMP), which included measures for reducing, mitigating and compensating environmental and social impacts such as (i) waste management, (ii) noise and air pollution, (iii) stormwater management and (iv) workers’ and community health and safety. The implementation of CESMP was supervised by GHM through regular visits and monthly meetings. The contractors also received regular visits and trainings from the labor inspectorate and were required to submit monthly reports on E&S trainings and pending actions from regular internal audits.
As per the HMA, the hotel will adopt the Operator’s corporate E&S management programs and global policies relating to environmental compliance and impact mitigation, safe food and hygiene, climate and biodiversity action, ethics and corporate social responsibility, labor rights and workforce protection, data protection and privacy, fire and life safety and security, energy and water efficiency, food management, carbon emissions, waste management, gender representation, sexual harassment, non-discrimination, employment equity and responsible sourcing. As discussed above, site specific procedures and processes will be developed to align with the existing corporate programs as per ESAP#1.
E&S Organisation and Capacity: EHS management of the construction site was under the responsibility of the project management team of GHM and was supported by the Operator. GHM will hire or assign a qualified E&S manager to oversee and manage all E&S risks of the hotels for operational phase and major maintenance and reparation works that may need to be performed by contractor and sub-contractors (ESAP#2). On the Operator side, EHS management is under the responsibility of General Manager, who has been hired with the advice of the Operator and agreed by GHM. Head of departments will also be responsible of implementation of E&S policies and procedures with respect day-to-day activities. The Operator will also assign sustainability champions among the staffs within each department of the hotel with specific E&S roles and responsibilities.
Emergency Preparedness and Response: A site-specific emergency preparedness and response plan (EPRP) for the hotel will be developed to cover the possible emergency scenarios based on a risk analysis including fire, earthquake, violent person and terrorism, accidents, and additional climate risk such as sandstorms, flooding and heat waves (ESAP #1).
Supply Chain Management: The Operator has a global Procurement Supplier Conduct Guidelines, which include commitment towards fair working conditions, freedom of association, occupational health and safety requirements, prevention of forced labor and child labor, as well as management of key environmental impacts in the supply chain. As part of the hotel specific ESMS, the hotel will adopt the global guidelines and develop its own responsible souring policy along with requirements for auditing and monitoring compliance with the responsible sourcing policy
Monitoring and Review: As part of the E&S monitoring procedure to be developed per ESAP#1, the hotel will be required to submit quarterly and monthly reports on E&S related Key Performance Indicator (KPIs) such as waste, energy, water, labor grievance and others. In its E&S monitoring procedure, GHM will define and set target for E&S KPIs aligned with GIIP as well as with WBG General EHS Guidelines (ESAP#1). Furthermore, the Operator as group annually publishes key information on its E&S performance that are operated under its brand, hence in addition to future reporting of the project specific KPIs to GHM, Operator group level KPIs will also be made publicly available.
PS 2 – Labor and Working Conditions
As of January 2026, the hotel was employing around 200 workers with 34% of female. The hotel also employs third party contractors for security and gardening services. Around 60 third party workers are employed. At full operation, the hotel is expected to recruit around 250 - 300 employees.
Human Resources Policies and Procedures: GHM is committed to respect Mauritania’s labor regulations and the applicable interprofessional collective bargaining agreement. The company has adopted Internal Rules that cover the technical organization of work; discipline; and hygiene and the health and safety measures necessary for the proper functioning of the hotel, as mandated by the law. GHM has developed an Open Door Policy, which enables every employee to have free and direct access to management in order to raise any work related concern or issue, and to benefit from fair, timely, and impartial handling without fear of retaliation.
In addition, GHM relies on Mariott’s global policies and standard operating procedures that align with IFC PS2. They include, among others, anti harassment, freedom of association, child labor, forced labor, human trafficking, and ethical recruitment. They are available on the Operator’s MGS platform and are communicated to employees during their onboarding. Furthermore, mandatory trainings are provided to all employees on key HR topics.
Finally, GHM has developed an employee handbook that includes some overview of GHM’s HR expectations and practices and could be further enhanced by including clear references to all applicable HR Policies and Procedures covering IFC PS2 topics. HR Policies and Procedures and will communicate it to all workers including labor agency workers in Arabic and French during onboarding (ESAP#3).
Working Conditions and Management of Worker Relationship: As per the HMA between the Operator and GHM, all employees are recruited and managed by the Operator, although the labor contractual agreement of the employees will be with GHM. All these employees are under ultimate responsibility of the General Manager, who was selected by the Operator. In January 2026, the employees had been recruited on short term and long-term contracts depending on the need and the Operator does not currently intend to recruit casual workers. All employees are provided with a written contract detailing the employment terms and conditions in compliance with legal and PS 2 requirements. Number of working hours and payments for working hours are aligned national labor regulations.
Worker’s organization: According to the Operator’s global policy on human rights, the Operator permits freedom of association and the right for employees to form and join unions of their own choosing. The same approach will be adopted for the hotel which is in line with Mauritanian labor codes. To further strengthen this commitment and as per ESAP#3, the company will include a clear statement/policy with respect to workers right to freedom of association and collective bargaining in its HR Policy and Employee handbook. The policy will also clearly state zero tolerance for any retaliation on account of participating in union/freedom of association related activities. Awareness training will be carried out for all employees on this aspect.
Grievance Management: The Operator has different means for employees to report for grievances, which are (i) reporting to direct supervisor or human resources via the open-door policy (GFT - garantie de traitement equitable), (ii) by calling the toll-free corporate reporting phoneline and (iii) by filing an online grievance through the Operator’s online reporting platform. The online platform and corporate phoneline is accessible to all guest and employees, including third party contractor and suppliers. The complainant can opt to file the complaint anonymously. Sexual exploitation, abuse and harassment, child abuse, safety and security grievances can also be filled via these platforms. GHM does not currently have a formal documented grievance mechanism. Going forward, the company will develop a formal, inclusive, and accessible corporate grievance mechanism that will allow employees, as well as contracted workers to file any labor related complaint including anonymous ones directly with GHM. The mechanism should provide clear processes (detailing the management of all the steps: submission, receipt, investigation, response, appeal, close out), and ensure timely, fair, and well-documented resolution of complaints logged in a grievance register. Workers must be regularly informed and trained on how to use the mechanism (ESAP#4). In its E&S monitoring procedure, GHM will require the Operator to report on grievances related to labor and working conditions.
Survivor-centred approach: In relation to sexual abuse, harassment, exploitation and child abuse, the Operator will identify front line managers who will be trained to identify and prevent such incidents and necessary tools such as alert devices and educational videos will be made available for all employees in this effort. The Operator and GHM will arrange partnerships with organizations that can provide GBV response support services to staff and guests who have experience sexual harassment and voluntarily need these services (ESAP#5).
Occupational Health Safety (OHS): Site specific OHS management procedures, covering hazard identification and risk assessment, L&FS, food safety, pool safety, crisis management, Legionella control procedure and pest control, electrical safety and others will be developed for the hotel (ESAP#1), aligned with the Operator’s corporate policies, which are currently being implemented. The Operator will institute an OHS committee which will meet regularly to discuss health and safety matters. OHS components will be included in the onboarding and refresher trainings.
Third Party Workers: GHM relies on the work provided by 3 contractors mainly in charge of the following services: gardening, landscaping, lift maintenance, security. In total, GHM employ around 60 third party workers.
The Operator has supplier conduct guidelines which are applicable to contractors as well; and includes the respect of labor right such freedom of association, anti-harassment and anti-discrimination, prevention of child and forced labor, and unethical conduct. As part of the onboarding process for new suppliers, GHM’s Human Resources department conducts basic due diligence to verify that partner companies are duly registered with the social security authorities and comply with applicable labor regulations. To this end, the department liaises with the relevant administrative authorities. In line with IFC PS2, GHM will develop a mechanism to allow the company to monitor the labor conditions provided by its partners. This mechanism should include ongoing monitoring of contractors’ labor practices, supported by adequate tools that enable GHM to conduct document reviews, test contractor’s HR systems, and conduct worker interviews to ensure that contractors’ labor practices align with the expectation of the law and PS2 (ESAP#6)
PS 3: Resources Efficiency and Pollution Prevention
Energy and resource efficiency measures were incorporated at design phase of the hotel and included installation of energy efficient equipment, HVAC, heat pumps in addition to other measures. Upon completion of the hotel, Scope 1 Greenhouse gas Emissions(GHG) emission is not expected to be above 25.000 tonnes Carbon Dioxide equivalent per annum in total. The Operator has a carbon footprint program and annually discloses its GHG emissions.
Water supply during construction and operation is provided through the municipal network. A borehole has been installed on site for emergency purposes. Potable water quality will be monitored periodically, and swimming pool water quality will be tested. A wastewater treatment plant has been installed which will be used to treat all domestic wastewater and effluent will be re-used for irrigation purposes. A water and wastewater monitoring and management plan will be developed for the hotel with the intention to monitor the quality, optimise and reduce water usage and wastewater generation (ESAP# 1).
Electricity is sourced from the public grid and back-up generators powered with diesel have been installed in case of grid power failure. A diesel fired boiler has been installed for water heating purposes. Liquid Petroleum Gas (LPG) will be used for cooking. An air emission monitoring plan will be developed for the hotel to monitor air emissions against local regulations and IFC EHS guidelines (ESAP#1).
Noise nuisances can occur during festive season due to late parties. The hotel is surrounded by businesses and administrative offices and the nearest residence from the hotel is more 400m away from the site. Noise will be managed in line with the applicable legal requirement.
Solid wastes consisting mainly of cardboard paper, plastic, and wooden packaging is expected, that will be segregated at source and handed over to the local authorized recyclers. The Operator’s aims to reduce food waste, however a certain quantity of food waste will still be produced, which will sent for composting, either on the hotel site or off-site. Within the ESMS, specific procedures for managing non-hazardous solid waste will be developed, including a system of sorting, storage, and disposal, in line with applicable legal requirements and the Operator’s global policies (ESAP#1).
Hazardous materials that are stored/used on site include chlorine, chemicals for the pool, disinfectants, and cleaning detergents for housekeeping, LPG, diesel, lubricants and others. A dedicated bulk LPG storage has been installed which has been equipped with fire detection and suppression system. Three underground tanks will be used to store diesel that will power up the boiler and backup generators. The underground tanks are double walled and have an additional concrete bund. As a part of ESMS, a hazardous material management plan, including procedures for regular inspections of LPG and diesel tanks, in addition to storage and handling of hazardous materials, will be developed (ESAP #1).
PS 4: Community Health, Safety and Security
Food Safety: The Operator implements a global policy for food safety and it is expected that the same policy will be implemented for the hotel and a relevant procedures, detailing roles and responsibilities, quality requirements, supplier management, receiving and storing of food, pest control, will be developed.
Guest Safety: Pool safety management plan will be developed for the hotel, where measures such as water quality monitoring, presence of lifeguards, proper signage and others will be implemented (ESAP#1). The Operator requires reporting and investigation of complaints of unethical behavior, harassment, and other human rights concerns both from its employees and guests. Human trafficking and child sexual abuse cases can be promptly reported via a dedicated crisis hotline. The Operator provides training to its staff on human trafficking awareness and will implement safeguarding against online child exploitation by adopting internet block for flagged websites in hotel. The hotel will develop a specific child safeguarding procedure which will comprise of safety measures for children that stay as guests (ESAP#1).
Life and Fire Safety: The hotel has the required life and fire safety (LFS) infrastructure, as the LFS systems were designed in accordance with United States National Fire Protection Association standards and the Operator’s fire protection and life safety standards, referring to good international industrial practices. The proposed LFS systems include fire and smoke compartmentation of spaces, portable fire extinguishers, fire detection and alarm system with centralized control panel, sprinkler systems, fire hydrants, fire hose reels at every floor and water storage tanks with fire pumps. Additionally, the hotel was provided with independent emergency staircases protected with fire resistance materials. Prior to operation, GHM has undertaken a post -commissioning audit for all LFS systems, including compartmentation, smoke management (e.g., stair pressurization), fire suppression systems (pumps, sprinklers, hose, hydrant, other), fire detection and alarm system, emergency power and lighting, combined testing of building systems interfacing, etc. Minor gaps identified were fully addressed.
Security: The hotel will employ its own unarmed security guards for indoor security management, while for outdoor security, unarmed security guards from licensed private security companies will be contracted. A security management plan will be developed which will be aligned with the requirements of IFC Performance Standard 4 as well as the United Nation’s Voluntary Principles on Security and Human Rights (ESAP#1).
