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
Policy, Environmental and Social Assessment and Management System: Gozem has developed an E&S policy that encompasses all aspects of its operations across its countries of operation. The policy outlines the company’s commitment to align with IFC PSs. Additionally, an Environmental and Social Management System (ESMS) was developed as part of the upstream engagement. Key elements of the ESMS include: (i) OSH for workers and drivers, (ii) a road safety program to mitigate risks for drivers, passengers, and third parties, (iii) E&S training plans, (iv) a waste management plan, (v) a sustainable supply chain management plan, (vi) a contractor management plan, and (vii) monitoring and reporting, among others. The ESMS and policy are consistent with IFC PS requirements. Implementation of the ESMS has commenced in Lome, Togo, Gozem’s headquarters, where programs such as road safety training are already underway. Gozem has developed a roll-out plan for the ESMS to ensure its full implementation.
Identification of Risks and Management Programs: As part of its ESMS, Gozem has developed a risk identification and management procedure to ensure legal compliance with E&S requirements and alignment with Gozem’s E&S policy. A risk register has been created based on a comprehensive risk assessment conducted during the ESMS development. The register covers all aspects of Gozem’s operations, including risks associated with drivers, suppliers and maintenance partners. The risk register has been further updated to include GBVSH risks. Gozem adheres to applicable national and local regulatory requirements, which, to date, primarily focus on the management of staff and contracted workforce. Additionally, a legal compliance register has been developed as part of the ESMS to ensure ongoing compliance with national regulations. Verification of every driver, including driving skills test, is conducted by the company before they are authorized and registered to provide services through the Gozem app. As part of the verification process, key documents such as driver’s license, vehicle registration, insurance, and vehicle fitness are verified.
Gozem has established several management programs as part of its ESMS, including a waste management program and a road safety management program. Currently, most of these programs are being implemented in Togo, where Gozem’s headquarters are located. The roll-out of the road safety program, GBVSH, waste management in other countries where Gozem operates has also started including allocation of resources and training and awareness of employees and the drivers. The full roll-out is planned to be completed by the last quarter of 2026.
E&S organizational structure: Gozem has appointed an E&S Manager reporting to the director at the corporate level, who is responsible for overseeing E&S and OSH compliance, monitoring, reporting, training, resource management, and pollution control. The E&S Manager is supported by an E&S Champion in each country of operation. These E&S Champions also serve as “smiling champions”, providing wellbeing support to drivers in areas such as training, addressing grievances, and offering general assistance. The E&S champions also conduct E&S supervision of suppliers and maintenance partners. The ESMS details the role and responsibilities of the E&S champions.
E&S Training. Gozem has developed an annual training plan for its employees and drivers, which includes training on E&S policies and procedures, firefighting, first aid, general OSH, road safety, and defensive driving. The company has established training centers for drivers within its offices and has already commenced road safety training for drivers. Additionally, training on GBVSH has started in all countries where Gozem operates. As part of its ESMS, Gozem has developed a training plan to ensure that all drivers are regularly trained in road safety, labor and working conditions requirements as they pertain to local law, defensive driving, GBVSH and other policy updates as part of this investment.
Emergency Preparedness and Response: Gozem implements a documented Emergency Preparedness and Response Plan (EPRP) for its operations. The EPRP addresses key risks such as fire, medical emergencies, road accidents, riots, and protests. It outlines the necessary response actions, responsibilities, and measures to prevent or mitigate these risks. Fire protection systems have been provided at the offices, which include portable fire extinguishers, fire alarms, smoke detectors, emergency exits and marking of evacuation routes. No fire incident has been reported so far in any of the offices. Gozem has recently updated the EPRP and associated procedures to include climate-related risks such as floods and heat waves. The company has also established protocols to communicate such events in real-time to drivers as well as passengers through the platform to ensure their safety. Awareness programs will be conducted for both drivers and employees on these climate-related risks and the precautions to be taken. Additionally, the updated EPRP addresses the risk of assault, including GBVSH, for both drivers and passengers, and establish mechanisms to respond effectively to such situations. Furthermore, the company will establish protocols with emergency services and national security agencies to effectively respond to such events, reinforcing its commitment to safety and community well-being (ESAP#1).
E&S Monitoring & Review: As part of its ESMS, Gozem has developed an E&S monitoring procedure that defines Key Performance Indicators (KPIs) to track and evaluate the company’s E&S performance. These KPIs include metrics related to OSH such as leading and lagging indicators (e.g., incident records, near misses, hazard reporting, and other workplace monitoring data). Additional KPIs cover resource usage and efficiency (e.g., water and energy consumption), pollution prevention and control (e.g., effluents, solid and hazardous waste management), and the E&S performance of suppliers, including service providers. The monitoring procedure also establishes auditing protocols and specifies the frequency of audits and the KPIs are reported to the board of directors through an E&S performance dashboard on a regular basis. The monitoring procedures will be further updated to include specific procedures that need to be audited, detailing the frequency and responsibilities (ESAP#2).
Supply Chain and Maintenance Partners: Gozem’s primary suppliers are local passenger vehicle resellers who import ready-made vehicles, with most of these vehicles being manufactured in controlled and automated facilities, thereby minimizing the risk of child labor and forced labor in the supply chain. The company has developed a sustainable procurement procedure, which established the E&S requirement used by Gozem, to select suppliers and service providers, and also a policy against the use of child and forced labor. While Gozem has very limited leverage to directly engage with the original manufacturers, the company has developed E&S clauses that are systematically included in the contractual obligations of its suppliers. These clauses require suppliers to establish and implement an E&S policy, ensure compliance with national regulations, preserve human rights, uphold workers’ rights, ensure the safety of their workers, provide transparency regarding the sourcing of materials, and establish proper protocols for waste disposal. Gozem has developed a stand-alone supplier and third-party service provider code of conduct and further reinforced the auditing and monitoring process of supply chain and maintenance partners. Guidance for waste management and disposal is provided to maintenance partners.
PS2: Labor and Working Conditions
Due to the nature of its operations, Gozem engages three types of labor, which are: a) direct employees hired on fixed or permanent contracts; b) third party workers hired via third party companies; and c) independent contractors which comprise of drivers. At the time of the appraisal, Gozem had a workforce of approximately 425 direct employees across its various countries of operation, with around 32% of the workforce being female. In addition to its direct employees, the company engaged roughly 20 third party workers through a third-party contractor, primarily for security and housekeeping services. Gozem also retains the services of around 30 G-Force agents, who serve as independent marketing agents for the Gozem platform and are remunerated based on performance metrics related to driver recruitment. Gozem identifies drivers operating on its platform as independent contractors, and as of April 2025, the platform had approximately 7,000 active drivers.
Human Resource Policy, Working Conditions and Terms of Employment: Gozem has established human resources policies for its direct employees, detailed in the company’s employee handbook, which covers a wide range of topics, including equal employment opportunity, diversity and inclusion, anti-harassment provisions, pay periods, salary deductions, bonuses, grievance redress mechanisms, disciplinary measures, working hours, overtime, annual leave, medical leave, sick leave, compassionate leave, maternity leave, recruitment and selection processes, probation periods, performance reviews, and termination procedures. The company provides formal contracts to all employees, which include details on gross salaries, probation periods, working hours, overtime rates, holidays, and notice periods. The employee handbook further includes explicit reference to freedom of association and collective bargaining consistent with Gozem’s HR Policy and PS 2. The company has provided awareness on this aspect to all employees.
In terms of GBVSH, the handbook includes a code of conduct that also prohibits gender-based violence within the company operations. The company has developed a stand-alone sexual harassment policy, including description of sexual harassment, disciplinary actions, reporting channels, investigation methods, and support for survivors. The requirements of this policy are extended to drivers, G-force agents, third-party contractors and users of the Gozem platform and provision are included in all direct and third-party employees’ contract, including drivers. Awareness and training for the implementation of this GBVSH policy will be provided for all direct employees and third-party workers (ESAP#3).
Gozem requires all employees to work 40 hours per week in accordance with statutory requirements. Most employees follow standard office hours, working from 8:30 AM to 5:30 PM with a one-hour daily break, five days a week. However, support services operate 24 hours, hence staff who are responsible for assisting drivers during emergencies, work in shifts. These shifts typically last 8 hours per day, though additional overtime may occasionally be required. Gozem will develop an overtime management plan including measure to reduce overtime and provision of safe commuting means for employees during late night hours (ESAP #4) and update the employee handbook accordingly. Gozem also permits its employees to work remotely especially female employees for a certain number of days per month which is also reflected in its employee handbook through a remote and flexi work policy to ensure transparency and fairness.
Non-discrimination and Equal Opportunity and Worker’s Grievance Mechanism: Gozem’s HR policies include explicit statements to ensure non-discrimination, equal opportunity and fair treatment during recruitment and selection.
Gozem has a documented grievance mechanism in place that is accessible to all employees, including third-party workers and drivers. The mechanism provides clear channels for submitting grievances, including those related to GBVSH and accommodates confidential and anonymous complaints. To align with IFC PS2 requirements, Gozem has recently updated the grievance mechanism to include (i) a separate confidential, accessible, and optionally anonymous channel specifically for reporting GBVSH incidents, (ii) defined roles and responsibilities for addressing and responding to grievances, (iii) clear timelines for taking action, and (iv) a system to log, track, and report grievances and their resolution status. Additionally, the mechanism now incorporates differentiated procedures for managing GBVSH related grievances. To ensure effective implementation, the company will sensitize its workforce and disseminate information about the grievance mechanism through online platforms and notice boards. Specialized training will also be provided to staff responsible for handling GBVSH grievances, reinforcing Gozem’s commitment to fostering a safe and inclusive work environment (ESAP#3).
Management of Contractor (Drivers) and Third-Party Companies’ Workers: Under DTB arrangements, Gozem’s drivers operate as independent contractors, providing their services through the Gozem platform. The key contractual arrangement between Gozem and its drivers includes: (i) Gozem’s provision of products and services to drivers, (ii) drivers’ payment for these products and services through deductions from their platform earnings, and (iii) a certain level of control and exclusivity exercised by Gozem over its drivers. Gozem has sought legal advice regarding the drivers’ status, including implications for benefits and protections, across its target markets, ensuring that current practices are aligned with national legislation. The company remains committed to monitoring changes in the legal and regulatory conditions of its operating jurisdictions, as well as evolving labor practices related to drivers, to ensure continued compliance and alignment with best practices and as per ESAP# 5, Gozem will develop and establish a legal and regulatory monitoring procedure, which will also include periodic reviews of contracts and Gozem’s legal obligations.
The company has developed a Driver Code of Conduct, which details the expected behavior of the drivers while operating on the platform. Each Gozem driver is assigned to a team lead, who serves as their primary point of contact and is accessible via phone, email, or mobile-based individual and group chats. As independent contractors, drivers have access to Gozem’s anonymous grievance mechanism via direct complaint through the team leads, 24 hour online support and anonymous email. Team leads maintain regular communication with drivers, addressing their concerns and providing support. They also collate any issues raised by drivers and share them with management for review, ensuring that all matters are resolved in an appropriate and timely manner. Due to their status as independent contractors, Gozem does not deduct income tax or pension contributions on behalf of drivers, nor does it provide compensation for work-related injuries. However, as an incentive, the company covers medical expenses up to a certain amount within the first 24 hours of an incident, promoting incident reporting.
Supervision and monitoring of drivers is done under various E&S and operational procedures such as road safety management procedures and grievance mechanism. Gozem implements an E&S procedure for drivers which establishes guidelines for hiring, managing and monitoring of drivers. Gozem will further develop and communicate a Driver’s Policy Handbook to outline drivers’ rights, responsibilities, and welfare, fostering fairness, labor ethics, and transparency in its relationship with drivers. The handbook will articulate Gozem’s expectations and commitments to drivers including the existing Driver Code of Conduct, further covering areas such as legal, contractual and taxation obligations, anti-fraud, anti-bribery, ethical marketing, anti-violence, anti-bullying, anti-harassment, anti-discrimination, diversity and inclusion, grievance redress mechanisms, child labor prohibition, whistleblowing, climate change, health and safety (detailing both drivers’ and Gozem’s responsibilities), general OHS requirement, road safety, use of illicit substances, GBVSH, child safeguarding and maximum driving hours and off-days. To ensure adherence to the handbook, Gozem will establish key performance indicators and targets as needed and will further conduct regular audits of drivers to monitor compliance (ESAP#6). Additionally, the legal requirements for registration as independent contractors and taxation obligations are explicitly included in drivers’ financing contracts, reinforcing accountability and alignment with regulatory standards.
Gozem engages third party workers via service contractors, primarily for cleaning and security services. The company’s policies on OHS, child labor, and business ethics are communicated to contractor workers through induction training and are integrated into the contractual agreements with third-party service providers. Gozem has oversight of contractors through regular E&S compliance audits in accordance with its policies and procedures, including a stand-alone supplier and third-party service provider code of conduct.
Occupational Health and Safety: The E&S policy reflects the company’s commitment to providing a safe work environment that prioritizes the health, safety, and welfare of its employees, contractors, visitors, and members of the public who may be impacted by its operations. The company utilizes an incident reporting schedule to document and track work-related injuries, illnesses, and fatalities; identify trends in OHS issues; record serious damage to property, equipment, or materials; assess potential environmental damage; and address incidents involving contractors, passengers and members of the public. This schedule also facilitates incident investigations to ensure corrective actions are implemented. Gozem has trained first aiders available in the workplace and provides health insurance for its staff. Additionally, OSH risk management is incorporated into induction training for all direct employees, drivers and third-party workers, reinforcing the company’s proactive approach to workplace safety and health.
Road accidents, primarily involving drivers, have been identified as a major contextual safety risk for Gozem. To mitigate these risks, Gozem implements a road safety program as described in the section on PS4 below.
PS3: Resource Efficiency and Pollution Prevention
Energy Consumption and GHG emissions: The main energy sources at the offices are grid electricity and diesel for transportation and backup generators. The Project emissions are estimated to remain below 25,000 tons of carbon equivalent per year. Additionally, Gozem is exploring the financing of electric vehicles, which produce significantly lower emissions, as part of its commitment to reducing environmental impacts.
Pollution Prevention: Gozem’s offices use bottled drinking water and tap water from the municipal supply for other purposes, generating only sanitary wastewater, which is disposed of via on-site septic tanks. The offices do not produce significant air or noise emissions during normal operations, except for occasional emissions from backup generators during power outages. However, the vehicles operating on the Gozem platform may contribute to air and noise emissions. To mitigate this, the company requires all vehicles to undergo regular maintenance through its maintenance partners.
Solid Waste and Hazardous management: Gozem offices generate minimal solid waste, primarily from office and kitchen activities, while waste oil is produced from motorbike oil changes conducted by Gozem’s in-house maintenance services. The waste oil is stored in dedicated containers with secondary containment in a sheltered location, treated as hazardous waste, and disposed of through licensed contractors. For maintenance and oil changes of larger vehicles, drivers are directed to selected maintenance partners. At the maintenance partner level, faulty spare parts and waste oil are generated. Some maintenance partners visited demonstrated a high degree of compliance with Gozem’s E&S policy, including regular OSH monitoring and waste management practices, while others require improvements. To address this, Gozem has reinforced its monitoring and auditing processes for maintenance partners to ensure compliance with good industry practices.
PS4: Community Health, Safety and Security
Road Safety: The road safety program of Gozem includes online tracking of all Gozem vehicles, defensive driving training for all drivers, incentives for timely accident reporting, and accident investigations. To prevent fire in the vehicles, Gozem requires the drivers to ensure proper maintenance via selected maintenance partners and routine check to reduce any fire risk or collision risks. Gozem’s support services monitor all vehicles 24/7, enabling the detection of behaviors such as over speeding. Additionally, the assistance program, which covers medical costs for drivers for the first 24 hours following an accident, ensures that incidents are reported promptly. Despite these measures, road accidents remain a significant risk due to factors such as poor road conditions, unsafe driving by non-Gozem drivers, inadequate lighting, and other external challenges.
Although Gozem requires drivers to work 8 hours per day, drivers have the flexibility to work longer hours to increase their earnings, as they are required to complete a minimum number of trips to generate revenue sufficient to cover rental and other relevant payments to Gozem. Thus, some drivers may work more than 15 hours per day, which poses significant safety risks, particularly while on trips.
To further strengthen its road safety program, Gozem will recruit a suitably qualified road safety consultant to undertake an operational risk assessment for each country of operation, considering factors such as working hours, live tracking data, complaints, accident history, climate change impacts, internal capacity for monitoring vehicles, tools and resources available and security risks among others. Based on this assessment, the company will develop (i) tools to effectively address the identified risks, including alerts to drivers about high-risk areas (e.g., flood-prone zones) and operations (e.g., over speeding or deteriorating weather conditions) and (ii) fatigue management procedures including automated means to limit driving hours to reasonable safe driving hours. Gozem will also provide similar tools to riders such as panic button to alert the company of any imminent risks (ESAP#7). As part of the operational risk assessment, the company will undertake analysis of accident data to determine trends, recurring problems, and the need for further control measures.
The company has a driver response procedure in the event of accidents, theft and vehicle breakdown. It requires that all accident data be reported to the operation and support team for investigation, documentation, and institution of corrective measures towards achievement of the company’s aim for accident reduction. The procedure defines the responsibilities within the organization, including the operations team, the emergency response personnel and the team leads, and the investigation and reporting protocols. Gozem will also reinforce its accident investigation practices by ensuring the investigation teams are properly trained in root cause analysis (ESAP#7).
Gozem’s road safety policy outlines key aspects of vehicle safety, including vehicle use and insurance requirements, accident reporting and investigation procedures, vehicle inspection and maintenance protocols, and driver safety regulations. Additionally, the Driver Code of Conduct mandates that drivers adhere to traffic laws in their respective locations, covering areas such as speed limits, traffic control measures, and alcohol consumption regulations. To further enhance road safety, Gozem will update its road safety policy to include defined response actions for monitoring driver working hours and rest breaks, collaborative measures with local government agencies and emergency response personnel, protocols for situations where drivers, riders, or both are unable to implement emergency response procedures, and an external communication protocol for managing such incidents (ESAP#7). These updates aim to strengthen Gozem’s commitment to ensuring the safety of its drivers, riders, and the broader community
Community based gender-based violence: By the nature of their work, Gozem drivers frequently interact with community members, including the public utilizing the Gozem platform and individuals along transportation routes, which increases the risk of GBVSH. To address this, Gozem has established a Driver Code of Conduct that outlines unacceptable behaviors such as violence and verbal abuse. Additionally, the company will develop and communicate a sexual harassment policy to both drivers and riders, ensuring awareness and compliance. The latter policy will be integrated into the driver’s handbook. As part of its emergency response measures, Gozem will provide drivers and as well as riders with appropriate tools to monitor situations and request support during urgent incidents (ESAP#7). Gozem will also establish partnerships with service providers to offer psychosocial, medical and legal support for workers, and champions, especially after incidents of harassment, attack and GBVSH (ESAP#3).
While Gozem does not allow anyone under 18 years to register on its platform, children do make use of the platform either while sharing rides with another adult or parent requesting rides for their children. To avoid any risk of child abuse, Gozem has adopted a child safeguarding policy that will apply to all its employees and contractors. This policy includes the (i) company’s commitment towards a zero tolerance for any form of child abuse, (ii) requirement for all incidents and allegations to be treated seriously and promptly investigated, and (iii) grievance mechanism system for reporting such incidents, including anonymous means. Training and awareness will be carried out for this policy (ESAP#8)
Use of Security forces: One to two security guards are employed per shift at each Gozem office, through security service provider. For each office site and shift, one of the security guards is armed. Gozem has developed a Security Management and Monitoring Plan aligned with the requirements of PS4 and the Voluntary Principles on Security and Human Rights. Contractual requirements for guard selection, rules of engagement (including minimum force), training, equipment, facilities, working conditions, and grievance management will be included in the service provider contracts (ESAP#9).
