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 Policies and Management Systems. Azalai Group has corporate policy statements demonstrating its commitment to E&S management, which include amongst others: i) an environmental policy, ii) a code of conduct (CoC), iii) a health and safety policy, iv) a quality policy statement, and v) a human resources masterplan. Following previous IFC investment, Azalai developed an E&S management system (ESMS) that comprises an ESMS manual which includes principles for business conduct, the procedures for identifying and managing E&S risks and impacts and the organizational structure, in accordance with IFC's Performance Standards. As part of this IFC investment, Azalai will update its ESMS to include specific E&S procedures for the following elements: (i) identification and assessment of E&S risks and impacts, considering contractor’s activities; (ii) E&S management plans and procedures on energy, water, waste and pollution management, (iii) E&S organizational capacity; (iv) emergency preparedness and response, including life and fire safety (L&FS) provisions, (v) stakeholder engagement and community grievance mechanism; (vi) a legal register / permitting plan to track all licenses and permits; (vii) road traffic and security management plan; (viii) supplier code of conduct and supply chain due diligence; (ix) occupational health and safety management procedures; (x) Pest control procedures; and (xi) E&S monitoring/reporting procedures, including Key Performance Indicators (KPIs) (ESAP #1).
Identification of E&S Risks and Impacts. Azalai has completed E&S assessments for the greenfield construction of the Azalai Hotel Dakar and the renovation of AHI in Ouagadougou in fulfilment of the respective legal requirements which identify the risks and impacts associated with demolition, construction, operation and decommissioning phases of the project. The E&S assessements and associated E&S management plans (ESMPs) were approved by the relevant national authorities. However, the E&S risk assessment of proposed renovation activities at the AGH in Bamako, Mali has not been completed. Going forward Azalai will conduct the E&S risk assessment for the AGH proportionate to the scope of renovations, and obtain an environmental certificate of conformance for its Bamako assets (ESAP#2).
Management Programs. The E&S assessments include framework plans implemented by main Engineering, Procurement and Construction (EPC) contractors and tracked as part of construction phase monitoring. For its operations phase, Azalai has developed a preventive maintenance plan for equipment and installations which is implemented in each hotel and monitored at corporate level. As per ESAP #1, Azalai will develop the management plans, procedures and programs for the hotels under the proposed investment pertaining to matters of labor and working conditions and occupational health and safety, resource efficiency and pollution prevention, community, health, safety and security, food safety, traffic management, and security management.
Organizational Capacity and Competency. Azalai Group has appointed a food safety director and a Quality, Environment, Health and Safety (QHSE) committee at corporate level. Hotel management and operations are thematically and departmentally structured, however no formal E&S functions are defined at corporate or hotel level. Both hotels in Dakar and Ouagadougou have contracted an E&S consultant to oversee the management of the E&S aspects during construction phase. Azalai Group will appoint an Environmental, Health, Safety and Security (EHSS) manager who will have the responsibility of overseeing the corporate ESMS and its implementation, conducting monitoring of E&S performance and reporting to respective management teams (ESAP #3).
Monitoring and Review. Apart from quarterly regulatory audits conducted at hotel level during the construction phase by external consultants as part of the E&Srisk assessments regulatory approval terms and conditions, there is no formalized E&S monitoring and reporting of the performance to senior management. As part of its ESMS (ESAP #1), Azalai will develop an E&S monitoring procedure which will specify Key Performance Indicators (KPIs), including occupational health and safety (OHS) indicators (incident performance, workplace monitoring data, near miss and hazard reporting), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management) and food safety KPIs.
Emergency Preparedness and Response. Azalai has drafted an internal operations plan for its Dakar asset which includes assessment and modelling of emergency risks and scenarios. There is no formalized emergency preparedness and response plan (EPRP) at hotel level, to mitigate specific risks including climate risks. Going forward, Azalai will develop and implement hotel-specific EPRPs which will set out principles and approaches to planning and managing emergency response, for different scenarios, like fire, injuries, evacuation, flood, accidental release of chemicals, including: (i) roles and responsibilities; (ii) structure of emergency response organization; (iii) legal and company requirements; (iv) emergency equipment; (v) emergency procedures; (vi) resources required; and (vii) drills, monitoring, maintenance and inspection of the emergency equipment, reporting and performance assessment (ESAP #4).
PS2: Labor and Working Conditions
At the start of operations, the workforce is expected to be around 140 employees in AHD, 160 in AHI and 80 in AGH. An estimated 35 contract workers in AHD, 70 in AHI and 30 in AGH will be hired through third-party service providers, such as for cleaning of common spaces.
Human Resources Policies and Procedures. Azalai Group has developed a corporate HR manual which includes procedures related to recruitment and onboarding, salary payment, work organization (working hours, management of interns, disciplinary sanctions), training and progression/promotion. Azalai’s Code of Conduct includes provisions on non-discrimination and harassment, management relationship, safety and security in the workplace, human rights, disciplinary measures. Azalai will tailor its corporate HR manual and procedures specific to the national laws and PS2 requirements and will include provisions on: (i) freedom of association and collective bargaining, (ii) sexual harassment policy, (iii) internal grievance mechanism, and (iv) retrenchment (ESAP #5).
Workers Organization. The Code of Conduct addresses collaboration with labor unions and associations. As per ESAP #5, Azalai Group will clearly state, in its HR policies and procedures, the employees’ rights to freedom of association and collective bargaining. The hotels in Dakar, Ouagadougou, and Bamako will support the election of employees’ representatives as mandated by respective national laws.
Retrenchment. In 2014 due to country wide riots, civil unrest and its economic impacts, AHI in Ouagadougou shut down its operations. At that time, the hotel had around 150 employees and 130 employees were dismissed with their rights calculated and paid. The hotel has reported taking steps to inform the employees, including the organization of a collective meeting to explain the situation in the presence of the workers’ representatives and the labor inspectorate. Also, AGH shut down its operations during COVID 19 and has not re-opened since then. At shutdown the AGH reassigned it staff to two other Azalai operating hotels in Bamako and plans to redeploy most of these staff to the AGH upon completion of this renovation.
Worker Grievance Mechanism. Azalai Group has not implemented a formal grievance mechanism for workers. The company will formalize a grievance mechanism accessible to all workers, including third-party workers, indicating (i) available channels to submit grievances (including separate channels for grievances related to gender-based violence and sexual harassment, and for confidential and anonymous complaints); (ii) roles and responsibilities for treating and responding to grievances; (iii) timelines for taking action; and (iv) system to log, track and report grievances and their status in accordance with IFC PS2 requirements (ESAP#6). The mechanism will include a differentiated procedure and management of GBV and sexual harassment related grievances. Azalai will sensitize its workforce and disseminate information on online platforms and notice boards with additional specialised training provided to staff managing GBV and sexual harassment grievances.
Occupational Health and Safety. Azalai has a central Quality, Hygiene, Safety and Environment (QHSE) committee chaired by the Group’s COO. An employee safety and hygiene committee is also set up within each hotel. A similar committee is expected to be set up for the new/re-opened hotels in Ouagadougou,Dakar and Bamako. Hotels have an infirmary within the premises, with a full-time nurse assigned or to be assigned. As part of the ESMS (per ESAP #1), Azalai will develop and implement an OHS management system which will include procedures for hazard identification, risk management, incident investigation and prevention, and performance measurement.
Workers Engaged by Third Parties. The hotels will hire a hundred of third-party workers through service providers for cleaning, security and garden maintenance. These third-party service providers are required to comply with all Azalai policies and standards, including Azalai’s HR manual, as well as local legislative requirements. Azalai will develop and implement a procedure to monitor the labor and working conditions of third-party workers as per ESAP #1. The AHI in Ouagadougou and AGH in Bamako have functional training schools for hotel management annexed to both facilities. As per ESAP #5, Azalai will engage and monitor that the teachers sign up to the code of conduct and perform as per its HR requirements.
Supply Chain. Azalai Group’s Code of Conduct encompasses responsible sourcing provisions, mandating suppliers not to have child labor and forced labor in their supply chains. The ESMS will be updated to incorporate a corporate due diligence procedure for the procurement of critical materials and services. This approach will focus on assessing any potential labor issues in the supply chain, particularly related to child and/or forced labor (ref. ESAP #1).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. Azalai’s environmental policy reiterates the Group’s position and provides guidelines on energy efficiency, water conservation, waste management, and pollution prevention. The hotels are connected to their respective national electricity grid and national water network. Back-up diesel generators are present for use during grid electricity outage. The hotels also have centralized chiller cooling systems for the air-conditioning. The heat from the chiller is used for heating water in the hotels. Water consumption is tracked daily and the hotels have put in place some resource efficiency measures, such as installation of double flush toilets and taps with automatic shut-off; re-use of treated effluents for drip irrigation system in Dakar; installation of sandbags into flushes to reduce volume in Ouagadougou.
Greenhouse Gas (GHG) Emissions. The greenhouse gas (GHG) emissions to be produced will primarily stem from electricity consumption, vehicle fuel consumption and diesel for back-up generators. As per the corporate environmental guidelines, all hotels are required to keep accurate and documented records and daily measurements of all energy consumption. Upon project completion, total emissions in each of the hotels in Dakar, Ouagadougou and Bamako are expected to be less than 25,000 tons of carbon dioxide equivalent per year.
Wastewater. The hotel in Dakar has installed a wastewater treatment plant for the biological treatment of all domestic wastewater generated. The treated effluents are discharged into the municipal sewer system. A portion of the treated water is currently used for garden irrigation. The AHI in Ouagadougou is connected to municipal sewage treatment system due to proximity to the networks. The AGH in Bamako has a sewage treatment plant which treats wastewater from the hotel prior to discharge with some of the treated water recovered and used for irrigation of green spaces.
Hazardous Materials and Waste Management. Hazardous materials are expected to be limited to chemicals used for cleaning, hygiene and pool treatment. They are handled and stored according to their respective material safety data sheets. Within the hotels, domestic waste is segregated and adequately stored, pending collection by licensed contractors for disposal in municipal landfills. Used oil and grease from the kitchen operation are collected via the drainage system into a holding tank which are recycled by a third-party contractor. As part of its ESMS (per ESAP #1), Azalai will develop and implement in each of the hotels a comprehensive solid waste management program which will focus on reduction of waste generated and will aim to segregate at source, reuse and recycle the generated waste with adequate storage and disposal practices.
Pest Management. Pesticides will be applied in the hotels by a licensed third-party contractor monthly and will be used in limited quantities. A procedure on pest control management will be included in the ESMS (per. ESAP #1).
PS4: Community Health, Safety and Security
Food Safety. Azalai has appointed a food safety director at corporate level. A Quality officer is recruited in each of the hotels, responsible for the implementation of the food safety management plan as part of the ESMS (cf. ESAP #1).
Water Safety: Water analysis are conducted twice a year to monitor any potential for Legionellosis. The pools are treated with algaecides and chlorine and monitored for pH and chlorine daily. The pool maintenance procedure will be included in the ESMS (per. ESAP #1).
Life and Fire Safety. Azalai incorporates life and fire safety (L&FS) requirements in the designs of the hotels and complement it with hazard studies mandated as requested by the respective national regulation. The regulatory requirement includes the development of an internal operations plan which models L&FS incidents including fires and explosion from sensitive areas like butane gas tanks, diesel storage, electrical transformer station and fires within the hotel building, focusing the design of the hotel on protection and safe evacuation of the occupants.
The design of the hotels considered the fire resistance rating of the structure and façade, smoke control systems and internal L&FS systems. At a minimum, each hotel will be provided with water-based fire protection systems (sprinklers, hose reels, etc.), kitchen hood system, two separate and independent exits, fire detection and alarm system (using smoke detection in all guest rooms with sounder to alert the people sleeping), and considerations to cover accessibility requirements. Each room has an evacuation plan as well as automatic smoke detectors, fire alarms and public address system for notification are installed in common areas, as well as emergency lighting and exit signage in all floors. The L&FS equipment installed are included in the corporate operations and maintenance program implemented at corporate level for all hotels within the chain.
Emergency Preparedness and Response. Azalai has implemented a corporate template for emergency preparedness and response plans (EPRP) for all hotels. The EPRP covers the probable emergency scenarios based on a risk analysis. The manual describes processes on assessment of emergencies, decisions on evacuation, and detail procedures, as well as the roles and responsibilities of various employees and teams. An annual calendar is prepared for training on different emergency drills. Also, the plan of the hotel in Dakar maps out national incident response facilities (fire brigade, hospitals, incident support structure) as well as identify the community within the area of influence and mechanism to communicate in the event of an incident. As per ESAP #7, Azalai will develop, implement L&FS measures and communicate emergency response protocols with community within the area of influence prior to commencement of operations at its AHI and AGH facilities.
Traffic Safety. The hotels in Bamako, Dakar and Ouagadougou are in urban areas with relatively high traffic volumes. The company will implement as part of its ESMS (per ESAP #1) a traffic management plan applicable to its guests, own transport fleet and its suppliers and distributors. The plan will address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards.
Security Personnel. There are security personnel, unarmed in Dakar and armed in Ouagadougou and Bamako. Existing measures include background checks, psychological screening of the staff, screening of all vehicles at the gates, CCTV cameras at corridors, main gate and isolated areas along the perimeter fence, defensive use of force / communication trainings. Azalai will undertake a hotel level security risk assessment for AHIOuagadougou and AGH Bamako to determine the content of the hotel level security management plan for operations and will include training requirements for security personnel (ESAP #8).
