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 Management System and Policy
NSIA has an environment, social and governance (ESG) policy within its ESG framework, which includes the company’s commitment to safeguarding the environment and the safety of its personnel with references to the Nigerian local laws and IFC Performance Standards (PSs).
NSIA is in the process of developing an environmental and social management system (ESMS) for Medserve. NSIA will develop the E&S Policy and ESMS for Medserve in alignment with the applicable national regulatory requirements and IFC PSs, as further discussed in the following sections of this ESRS. The Medserve ESMS will include standard operating procedures (SOPs), key performance indicators (KPIs) and GHG emissions tracking for its projects (ESAP #1).
Identification of Risks and Impacts and Management Program
NSIA’s rollout plan is to co-locate in teaching hospitals and also have standalone facilities. While none of the centers as part of Phase-1 exceed 0.3 Ha in size and there are no national requirements for environmental and social impact assessment submission, NSIA still runs its own screening using an existing ESG Assessment Checklist. The checklist follows the IFC PSs and sector specific EHS guidelines and covers risks such as management of medical waste, employee safety, fire safety, hygiene, infection control, patient safety and impact on the public visiting the labs and cancer centers.
NSIA will develop an E&S Assessment and Management Procedure aligned with IFC PS and local requirements for Medserve. This procedure will be used by Medserve to identify and manage E&S risks associated with land acquisition, the development of greenfield and brownfield centers (ESAP #2).
Organizational Capacity and Competency
NSIA has an ESG department that manages the E&S performance of the planned centers under the project, with a dedicated sustainability and ESG head as well as a dedicated team, consisting of two ESG officers. NSIA’s ESG department is responsible for the development and management of E&S at the project level during construction and operational phases. NSIA’s ESG systems and policies are cascaded down to its subsidiaries, including Medserve. Medserve does not currently have its own ESG department. NSIA will assign a qualified person to coordinate the implementation of the ESMS for each center, under construction and operation (ESAP #3).
Currently, E&S trainings are provided to NSIA staff during the induction program for new hires. Similarly, NSIA will develop a comprehensive E&S refreshers and induction training plan, for all the direct employees and contracted workers across all Medserve operations, as a part of ESMS under development (ESAP #1).
Emergency Preparedness and Response
NSIA has a general emergency response plan which is cascaded down to Medserve. However, there are currently no emergency preparedness and response plans (EPRP) in place for the Medserve sites under construction. Per the agreements in place, contractors will develop and implement EPRPs for the construction period (ESAP #4). As per ESAP item 4, these plans will include detailed action strategies and drill protocols to address potential climate-related hazards such as heavy rains, storms, and flooding events. For the operational phase, each center will adapt NSIA/Medserve’s EPRP into its operations (ESAP #1).
Supply Chain
For all new centers, NSIA will use international suppliers for equipment and local vendors for disposables and other services. The supplier selection process begins with a prequalification stage where vendors complete an existing NSIA qualifying checklist. Feedback from this process is used to conduct a background compliance check, and only vendors who pass this check become prequalified. Requests for proposals and requests for quotations are then issued, and evaluation metrics are established to assess and select the top vendor.
Currently, revisions are underway to integrate ESG considerations into the supplier screening process that includes PS requirements such as GBVH measures.
PS 2 – Labor and Working Conditions
As a company, NSIA employs 210 employees in total on this project (55% males and 45% females).
Human Resources (HR) Management, Policies and Procedures
The NSIA HR organizational structure, also applicable for the company and project, includes an ESG Director and an HR Manager who report directly to the managing director and CEO of NSIA. NSIA will provide HR oversight until the appointment of a Medserve HR manager. Once Medserve appoints an HR manager, the level of oversight from NSIA to the centers will be handed over to the Medserve HR manager. Each center currently has an HR lead who will eventually report to Medserve HR manager once on-board (ESAP #5).
NSIA has HR policies and procedures to be cascaded down to Medserve, that are developed considering the national labor law and ILO standards requirements. There is a specific policy on Gender Equality and Inclusion. This policy covers non-discrimination including fair, competency-based recruitment processes without any discrimination as well as creating a gender-sensitive respectful workplace. The NSIA code of conduct emphasizes integrity and objectivity and professionalism at work. The anti-sexual harassment policy included the disciplinary processes against the harassment and abuse at the workplace procedure. There is also a staff handbook in place that covers recruitment, remuneration, overtime, leave system, whistle blowing and termination. NSIA will update its HR policies and procedures to cover its specific commitments for freedom of association, child labor, and forced labor (ESAP #5).
Employee Grievance Mechanism
At NSIA, and for the Project, employees can raise concerns through a variety of channels. There is an anonymous whistle blowing channel available on the NSIA website (https://tip-offs.deloittemanagedsolutions.com.ng/). There is also an employee grievance mechanism within the ESG framework. It allows for appealing disciplinary decisions and reporting grievances without retaliation and all grievances are dealt with by the HR department. NSIA will update the employee grievance redress mechanism (GRM) that will be cascaded to Medserve to align it with IFC PS2, including allowing anonymous grievances, a separate route for gender-based violence and harassment (GBVH) claims and assign and train personnel on the implementation of the mechanism (ESAP #5).
Occupational Health and Safety (OHS)
NSIA does not currently have documented OHS procedures for its operations. However, workplace health and safety measures are implemented at operational centers at Medserve including dosimeter monitoring for all staff that access to the bunkers, use of personal protective equipment (PPE) like gloves, protective gown, safety boots etc. NSIA also has key performance indicators (KPIs) to monitor number of workplace incidents and offsite incidents such as vehicle collisions. There is an incident reporting application available for all staff. Observed risk or incidents are reviewed by the Medserve clinic safety committee and preventive measures are planned and implemented by managers and supervisors responsible for workplace health and safety on ad-hoc basis.
For the project, Medserve will develop and implement an OHS management system, integrated into Medserve’s ESMS (ESAP #1). OHS management system will include (but not be limited to) documented OHS policy, safe working procedures and instructions, an incident investigation mechanism, near miss and hazard reporting, OHS KPIs (such as number of near misses, incidents, lost time injury frequency rates (number of lost time injury cases per million worked hour)), inspections, testing and internal audits and process for reporting the E&S performance to management.
Workers Engaged by Third Parties
There are almost 150 third-party contractor workers providing services such as transportation, cleaning and security currently for the Project. NSIA has a procurement team that follows a qualifying selection process. This process does not currently include E&S requirements. NSIA selects its contractors based on their expertise, certification, and fulfilment of contractual requirements. NSIA will develop a contractor management procedure, the E&S requirements will be integrated into its tender documents and into the contracts with contractors (ESAP #4). Additionally, contractors will be required to develop environmental, health and safety management plans (ESMPs) for projects under construction and NSIA will implement monitoring to ensure such requirements are being respected (ESAP#4). In addition, as part of their ESMP contractors will be required to ensure the implementation of alternative work schedules during periods of high temperatures and ensure the availability of water and shaded break areasfor their workers. (ESAP#4).
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas (GHG) Emissions
For operation centers under the Project, environmentally friendly refrigerants are used for the freezers, air conditioners and refrigerators. NSIA’s GHG emissions sources include fuel and electricity consumption for refrigeration, cooling and lighting, etc. at the centers as well as indirect emissions such as incineration of medical waste from the laboratories by the waste handlers. GHG emissions are estimated to be below 25,000 tons carbon dioxide gas equivalent per year, upon completion of the project.
Pollution Prevention
Health care centers operations will have limited impacts to air quality, noise, water and wastewater. However, Medserve will develop an E&S monitoring procedure (under ESAP#1) including provisions to monitor impacts to air quality, wastewater, resource efficiency and waste generation.
As mentioned earlier, for the existing centers, wastewater is managed by the host institutions (teaching hospitals). New sites located in host institutions will be managed in the same manner and wastewater management will be part of the project ESMS. The ESMS will have a wastewater management plan for new standalone centers (ESAP item 1).
At the centers generate non-hazardous, hazardous and biohazardous waste. Solid wastes such as packaging material, glass, paper, cardboard, plastic are segregated, stored and disposed/recycled per the NSIA existing waste management plan. Hazardous chemical waste includes solvents and paints which are returned to their original containers and labeled for storage in designated areas until disposal. For centers where cytotoxic liquids may be generated, it will be disposed of in line with the Waste Management Plan in the ESMS. Waste generated from patients (such as used needles, wound dressing, disposable bedsheets, gowns and gloves) are segregated into biohazard bags and containers which are stored in designated areas until disposal. A licensed waste disposal contractor is responsible for collection of all waste types from the teaching hospital and final disposal and recycling of the waste generated from the centers. A similar process will be followed for the new centers. Where applicable, the host institution waste disposal mechanism is used for disposal of all types of waste. The project waste management plan under the ESMS, under ESAP item 1, will include agreement and monitoring of implementation of the process described here.For stand-alone centers, Medserve will have a waste management plan under the ESMS (ESAP item 1).
Hazardous materials onsite include cleaning chemicals which are stored in access restricted areas and handled by trained cleaning staff who are provided with PPEs such as masks and gloves. Maintenance chemicals are not stored on site and are brought on site by the maintenance technician to handle the maintenance job on the spot. Any such chemicals are handled according to their material safety data sheets, with PPEs, by trained personnel.
PS 4 – Community Health, Safety and Security
Under the Project, NSIA does not own or operate the transportation vehicles used for staff and the transport service provider has in place adequate transportation safety management systems. This includes approaches to passenger safety, and driver management under the Project.
For the existing centers under the Project, NSIA is responsible for the life and fire safety design and management and follow national codes. At the time of an emergency, the NSIA centers under the Project are supported by the host institutions. The structural design and LFS measures planned for new centers under the project will be reviewed against the national fire code and one international fire code by an external life and fires safety expert and if needed, an improvement plan, with additional measures to full fill the gap (if any) will be developed prior to start of construction (ESAP#6).
Security Risk Management
Medserve contracts a private security provider to protect its facilities. The guards are not armed and are externally trained on access control, emergency evacuation and responsibility during emergency situations such as theft or property damage by the security service provider.
