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
Environmental and Social Management System
Cogna’s commitment to good Environmental Social and Governance (ESG) practices are reflected on its various corporate policies which, among others, include sustainability, environment and climate change, and diversity and inclusion. Given the nature of the sector, Brazilian regulatory agencies do not usually require an environmental impact assessment (EIA). The Group does not currently have a formal procedure to systematically identify E&S risks and impacts associated with its operations. As per ESAP #1, Cogna will develop a corporate procedure for the identification and management of E&S aspects and impacts.
Organizational capacity
Cogna’s E&S organizational structure includes an ESG and People Committee reporting directly to the Board of Directors and an ESG Executive Committee who responds to the Corporate Executive Officer. The Sustainability team is led by the Director of Institutional Relations and Sustainability who is supported by the Sustainability and Social Impact Manager and a team of social and sustainability coordinators. Waste management and energy efficiency aspects are managed by the operations department and the OHS team is composed of safety engineers and technicians, medical doctors and nurses led by the OHS manager.
Emergency preparedness and response
Cogna has documented emergency preparedness and response plans (EPRPs) for each individual university campus that includes two main parts: contingency plans and evacuation procedures, particularly for assembly areas. These plans have specific emergency response procedures covering different scenarios, such as firefighting and response, workers’ accidental exposure to biological or chemical hazards, and other risk scenarios. The buildings include accessibility provisions for the mobilization of people with disabilities.
Emergency plans are supported, for all campuses, by a volunteer emergency brigade, that receives training based on the level of risk. The EPRPs describe the required roles and responsibilities of various brigade teams, and coordination with municipal fire department. EPRP training is provided for all types of emergencies in most campuses based on Brazilian regulations, however the EPRPs need additional information to make it suitable for the risks present on each facility. As per ESAP #2, Cogna will update the EPRPs considering the following: (i) natural hazard risk scenarios (e.g., flooding, excessive heat, etc.) and other feasible scenarios, like civil unrest and national security threats; (ii) complete program of emergency exercises and evacuations for all campuses; (iii) specific training and contingency procedures for the campus security services; and (iv) adding operative risks maps of fire safety systems and the evacuation routes, specific for each campus or building. EPRPs will also include gender and diversity considerations such as evacuation procedures for students/staff with disabilities, pregnant women, and women’s safety.
Monitoring and review
Cogna monitors key performance indicators (KPIs) such as energy and water consumption, OHS performance, labor, and social investment activities. The Group publicly discloses its KPIs which are updated quarterly (https://esg.cogna.com.br/indicadores-esg-2024/). Further, Cogna yearly discloses its Sustainability Report following the Global Reporting Initiative Standard (GRI) (https://esg.cogna.com.br/wp-content/uploads/2024/08/Cogna_Relato_Integrado_2023-PT_v2.pdf).
PS2: Labor and Working Conditions
Human Resources Policies and Procedures
At the end of 2023, Cogna had nearly 23,000 workers with over 60% of them being women; 49% of managers are women, as well as 36% of directors. The Group’s Human Resources policies cover a wide range of topics including working hours and payment of overtime, freedom of association and right to collective bargaining, diversity, equity, and inclusion, etc. As per the Code of Conduct (CoC), the Group is committed to have zero tolerance to forced or child labor and to sexual exploitation of children and adolescents, and to promote a work environment free of harassment. In 2023, Cogna’s leadership team participated in a Compliance Workshop to learn how to handle harassment and discrimination cases within their teams. Cogna’s policies and procedures are generally in line with PS2 requirements.
The CoC provides a publicly available Reporting Channel (https://canalconfidencial.com.br/cognaedu/), both for internal (including third party workers) and external interested parties, through which any breaches can be reported, including harassment, sexual harassment, and discrimination, and includes corrective and disciplinary actions. The channel is managed by a third-party and allows anonymous grievances. Further, Cogna has an Ombudsman Channel (Ouvidoria) that allows the submission of complaints, suggestions, and compliments. As part of ESAP #3, Cogna will (i) adapt the grievance handling process to be accessible to children who may access Cogna training programs or services that serve or involve children (e.g., the dental training clinic and psychology training clinics) and/or participate in research; (ii) disseminate the Reporting Channel to third-party workers, including cleaning staff and security guards. The adapted grievance process shall be responsive to a child’s age, life stage and gender, with attention to disabilities.
Further, as per ESAP #4, Cogna will assess the current perception of students with regards to technology-facilitated GBVSH through a survey and focus group discussion and implement adequate mitigation measures based on its findings.
Occupational health and safety
Cogna has an Occupational Health and Safety Policy establishing the Group’s commitment to promote a safe and healthy working environment that prevents the occurrence of accidents and occupational diseases. The management of OHS risks follows legal requirements and is based on the Risk Prevention Program (Programa de Gerenciamento de Riscos) and the occupational health medical control program (Programa de Controle Médico de Saúde Ocupacional) that describe main occupational risks per type of job and associated medical exams. Based on the risks, the Group has developed standard operating procedures, covering work at heights, use of personal protective equipment and working instructions for its operations including laboratories, clinics, and hospitals.
All incidents are investigated to identify corrective measures and the lost time injury frequency rate (number of lost time injury cases per million hours worked) is around 1.18 in 2023 which is below the 2.5 industry benchmark for universities and professional schools (www.bls.gov). Main accidents are related to falls and sprains.
Third-party workers
Cogna relies on third-party contractors for cleaning, canteen, and security services as well as for maintenance activities. The Group has a procedure, defining the control mechanism to be followed by Cogna’s team as well as OHS requirements for third parties to be followed.
PS3: Resource Efficiency and Pollution Prevention
Resource consumption
Cogna monitors and reports electricity and water consumption from its operations. Cogna piloted several environmental initiatives to reduce its environmental footprint, including changing lamps for more efficient models with lower consumption and installation of rainwater collection systems in several campuses.
Pollution prevention
The Group does not produce industrial effluents and air emissions are limited to back up diesel generators that are used at campuses where surgeries are performed. Solid, medical and hazardous waste is segregated in line with local regulations and handled following Cogna’s Waste Management Plan The hazardous waste management process is centralized in the corporate unit Cogna, which is responsible for contracting suppliers for waste collection and disposal. In the educational units, waste is discarded separately and stored in cabins classified according to the destination class until collected by the waste collection company for final disposal. All campuses have covered temporary storage areas, domestic waste is collected by relevant municipal entities whereas medical and hazardous waste is collected and disposed by outsourced licensed companies. Cogna tracks transportation of waste from its generation source to its final disposal through manifest of transport that are logged into the National Information System for Solid Waste Management.
Main hazardous materials used by Cogna include diesel for emergency generators and chemical products used in laboratories and medical clinics. As per ESAP #5 mentioned under PS4, Cogna will develop an EHS checklist to ensure standardization of the EHS provisions, including secondary containment for the storage of liquid hazardous materials and under-sink particle and grease separators.
Green House Gas (GHG) emissions
Cogna estimates and discloses its GHG in 2022, as around 27,600 tons carbon dioxide emission equivalent per year (tpa).
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety / Life and Fire Safety
Cogna has a set of fire safety procedures describing the actions to be taken in the event of fire, mechanisms for fire detection and prevention, evacuation procedures, roles, and responsibilities of the various staff, and are reviewed regularly through pro-active measures.
The campuses have the required L&FS infrastructure, and the buildings are normally designed with open architecture (naturally ventilated corridors and exit stairs) with exterior balconies and accessibility features. The buildings have several exits at the ground floor, with a minimum of two independent and separate emergency exit stairs, as a minimum on upper levels. Also, all newer facilities are accessible and Cogna is updating the older facilities with the necessary accessibility features (ramps, elevators, floor lines for the visual impaired, etc.), based on Brazilian regulations.
The width of the means of egress (i.e., main corridors, doors, stairs) have been designed to allow for egress based on occupancy load. The fire safety equipment includes different types of portable fire extinguishers, smoke detectors, manual call points, sprinkler systems, water tanks and fire pump systems, hydrants, fire hoses/reels at every floor, firefighting capabilities, fire alarm control panels and public address systems for notification of personnel, students, and visitors. However, this hasn't been standardized in all campuses in different areas/states of the country. For this and as per ESAP #5, Cogna will commission a L&FS professional to develop a corporate standard “L&FS Design Manual (Master Plan)” focusing on the most restrictive requirements of the local state laws and international good practice for university campus and associated facilities.
The Company engages L&FS professionals who certify that the buildings are designed and constructed in a manner compliant with the local fire codes and take appropriate account of site-specific conditions. This practice will be maintained and extended by applying the future L&FS Design Manual. In addition, the new L&FS Master Plan will incorporate an EHS checklist with the requirements for i) laboratories and kitchens (cooking classrooms) to ensure standardization of the EHS provisions, including under-sink particle and grease separators, specialized portable fire extinguishers, protection of hazardous materials, means of egress and ventilation requirements; ii) all emergency generators, diesel tanks, electrical rooms, chemical storage rooms, and other risky areas to ensure they have the required safety and risk awareness signage, spill, and secondary containment (e.g., dikes, trenches), electrical grounding, and any additional standard safety practices.
As part of ESAP #6, Cogna will update the maintenance service contracts of L&FS systems (fire alarm and fire pump systems in particular) for all campuses and regions by adding clauses to obtain urgent maintenance service in less than 24 hours, when required, and by developing relevant KPIs for operation & maintenance activities of L&FS systems.
Community Health and Safety
Over 70% of students have between 18- and 35-year-old; 60% of students are male and 60% are enrolled in online or hybrid classes. Through Cogna’s digital platform, students can participate in virtual classes, and interact with tutors. As per ESAP #7, Cogna will start monitoring interactions of its digital platform to prevent and address risks of technology-facilitated harassment, sexual harassment, and discrimination. Further, as mentioned under PS2 (ref. ESAP #2), Cogna will assess the current perception of students and teachers with regards to technology-facilitated GBVSH through a survey and focus discussion groups and implement adequate mitigation measures based on its findings.
Cogna’s impacts to community health and safety are not considered to be significant as the institution does not provide student accommodations and student presence is limited to business hours and evenings. Nonetheless, to minimize disturbances and impacts on surrounding communities, as part of ESAP #8, Cogna will develop a Road Safety Instructive for students and teachers.
As part of its student training programs, Cogna provides psychological and dental services to surrounding communities, including children, at a reduced cost. The Group publicizes services through social media and local authorities. As per ESAP #9, Cogna will develop and make public a policy outlining its commitment to providing a safe and secure environment for children accessing services via its training programs. The Policy will include handling any known or suspected abuse or neglect of a child under Brazilian law. It will also set forth screening, training, and conduct requirements for any of its training programs or activities, on or off campus, that serve or involve children. Any outside entities/contractors that conduct or provide programs or services that serve or involve children on behalf of Cogna will be required by contract to comply with this Policy, and to demonstrate that the appropriate screening and training of contractors have been conducted prior to commencing services. The Policy will require all workers, students and other persons participating in or serving such programs to participate in mandatory training on the appropriate conduct around children, protecting children from abuse and neglect, and reporting of known or suspected child abuse and neglect and adhere to conduct requirements. The Policy will include enforcement and how Cogna will investigate suspected violations. Such Policy will also link to the reporting channel. In addition, Cogna will utilize media good practices for the protection of children when promoting its services. This includes informed consent from parents/guardians or older children for use of images or stories and respect to privacy; obscuring the visual identity of any child if the image could make the child vulnerable to stigma, discrimination, abuse, violence, or exploitation; storing all content and data securely; prohibiting exchange of contact information directly with children, and limiting sharing of information on social media or otherwise that could expose or endanger children and families.
Security Services
Cogna relies on unarmed external security guards, except for Espírito Santos State where unarmed guards are direct employees. As per ESAP # 10, Cogna will develop and implement a Security Management Procedure including vetting of security guards, respect for human rights, provisions to prevent GBVSH, training and monitoring, among others. The procedure will follow the provisions of IFC’s Good Practice Handbook on Use of Security Forces and Cogna will implement a dissemination and training campaign among security guards working on its premises.
