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
Policy, E&S Management System, and Programs
The Company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards, building codes and E&S regulatory permits and requirements. However, the company’s environmental and social management system (ESMS) and related procedures need to be established to assess and manage identified environmental, health and safety (EHS) risks and impacts from its construction, operations, and future land acquisition process.
As per ESAP #1.1, the Project will establish an E&S policy and an Environmental and Social Management System (ESMS) aligned with the requirements of IFC Performance Standards (IFC PSs), the applicable World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines and good international industry practice (GIIP). The Project will develop as part of the ESMS, a Contractor Management Plan defining their approach to managing the EHS performance of their contractors, subcontractors, and other third parties during the various phases of the Project. The contractor management approach will be consistent with the general principles addressed by the IFC’s Good Practice Note: Managing Contractors' Environmental and Social Performance (2017).
As per ESAP #1.3, Douja CIV will develop a land access and compensation procedure to guide the acquisition of assets or development of greenfield facilities in Lagoona City and Florida City, in line with the requirements of national law and IFC PS 5. The procedure should make provisions for due diligence, site screening, compensation, management of informal use, and prevention of forced eviction of land users.
Identification and Assessment of Risks and Impacts
Douja CIV follows the building codes and local legal requirements for design, development and construction of the housing developments including technical and urban specifications defined in the Master Plan of Grand Abidjan (Schema Directeur d’Urbanisme du Grand Abidjan or SDUGA 2030), and the requirements defined by the national Construction and Housing Code (Code de la Construction et de l’Habitat 2019) as well as the Ministry of Environment and Sustainable Development. Douja CIV has a construction permit for the Lagoona City site.
As per ESAP#1.2, the Project will undertake E&S risk assessment (ESIA) in line with the requirements of IFC PSs, WBG EHS Guidelines and national law for the construction of Lagoona City in Yopougon. Based on the ESIA, the Project will obtain all relevant E&S permits required for the construction and develop a suite of site-specific construction and operational E&S management plans (ESMPs). IFC and the Company will agree on the terms of reference (ToR) for ESIA and ESMPs.
Organizational Capacity
The executive director of Douja CIV has overall responsibility for EHS matters and the technical director oversees and monitors compliance of architectural and technical master and technical plans with the national building codes and standards. Monitoring and management of site -specific construction EHS risks and issues is delegated to the contractors. Hence, EHS organizational structure needs to be strengthened with the personnel with necessary knowledge, skills, and experience.
As per ESAP #1.4: the Project will appoint EHS manager with the direct responsibility for the Project E&S performance. Douja CIV will contractually also require from the Project contractors to designate adequate number of EHS professionals.
Douja CIV will hire third-party specialized consultant, acceptable for IFC to conduct bi-annual audit of EHS related compliance for the construction sites funded under the Project. The audits would focus on compliance with respect to the Project’s ESMS as well as IFC PSs requirements and any improvement areas identified will be implemented within reasonable timelines.
Emergency Response Plan
Douja CIV follows the building codes and local legal requirements for emergency preparedness and response in design, construction and building occupation. These requirements include provisions on health and safety during construction and life and fire safety requirements for building design, materials, and occupation. IFC reviewed emergency response practices at the construction sites and identified areas of improvement.
As per ESAP#1.3, the Project will develop a site-specific emergency preparedness and response plan (EPRP) in line with the national law and WBG EHS Guideline requirements.
Monitoring and Review
The Company regularly monitors technical aspects but procedures for E&S related aspects need to be established.
Hence, as per ESAP#1.3, the Project will develop as part of the ESMS, E&S monitoring and reporting procedures which will cover requirements (for both construction and workers’ accommodation camp) on dust and noise control, regular environmental monitoring (ambient noise, air quality, wastewater management and effluent quality), management of hazardous materials, waste management, implementation of the site specific ESMPs, and work-related accidents and incidents.
PS 2 – Labor and Working Conditions
Douja CIV currently has a total of 49 employees who work in management, design, commercialization, construction, and technical oversight. The Company hired about 1,600 contracted workers for implementation of its construction program. Particularly for the Lagoona City site construction, there are approximately 500 contracted workers.
Working Conditions and Management of Worker Relationship
Douja CIV has a corporate level HR policy which addresses its four HR commitments: (i) Equality and equity in recruitment, sharing of information, training and mentoring, internal promotion, renumeration, and health and safety; (ii) Promoting a transparent work environment with mutual respect in regard to advancement and work assignments; (iii) Encouraging a sense of responsibility across all sectors and work; (iv) Taking initiative and teamwork. Hence, the Company’s will apply the corporate HR policy to the Project and enhance this in line with the requirements of IFC PS2 and national law (ESAP #2.1).
Non-discrimination and Equal Opportunity
The principles of equality and non-discrimination are underpinned in the Constitution of Cote d’Ivoire (CIV) and Douja CIV corporate HR policy. While Douja CIV implicitly adheres to the principles of non-discrimination and equal opportunity, these should be clearly articulated in HR policy and procedures.
Thus, as per ESAP#2.1, the Company will address the principles of equality and non-discrimination as part of the HR policy update.
Freedom of Association
The Company supports freedom of association and recognizes the right to collective bargaining. Although this is not explicitly in a policy, currently Douja CIV has less than 50 employees so according to the law, there is no legal obligation to have a union.
Per ESAP #2.1, Douja CIV will, as part of HR policy update, include freedom of association in line with national law and requirements of IFC PS2.
Worker Grievance Mechanism:
Contracted workers at the construction sites channel their grievance through the worker delegates to the construction site directors. The Company needs to establish grievance mechanism for direct and contracted workers in line with the requirements of IFC PS2 and national law which will allow for anonymous and confidential filing of complaints. (ESAP #2.1).
Occupational Health Safety
Douja CIV has an internal health and safety committee comprised of seven workers including a company doctor to address HS concerns in their office setting in Abidjan. This committee does not address OHS oversight of their construction activities. There is no OHS risk assessment or management plan in place.
ESAP #2.2 - The Project will (or delegate to contractors) develop a site-specific Occupational Health and Safety (OHS) risk assessment and based on outcomes, an OHS risk management plan will be developed in line with the requirements of IFC PSs and WBG General EHS guidelines. The OHS management plan with corresponding procedures for (sub)/contractors will be monitored by the Project. The Project will perform regular OHS audits of contractor’s performance, hire an EHS manager who will oversee construction site EHS officers (ESAP #1.4). Bi-annual EHS audits will also be conducted by an external, accredited OHS specialized company (ESAP #1.4).
Worker Accommodation
The Company’s contractors provide accommodation for contracted workers. While at the site, the team found areas of improvement, including upgrade of dormitory, sanitary, toilet and canteen facilities amongst others. As part of the Project, the Company (or delegate to contractor) will create and maintain adequate living conditions in the worker accommodation facilities taking into consideration IFC/EBRD Guidelines for Workers’ Accommodation (2009) and national law.
As per ESAP#2.3 the Project will include a checklist for worker accommodation facilities in the ESMS aligned with IFC/EBRD Guidelines for Workers’ Accommodation (2009) including as a minimum adequate living/sleeping facilities and space per person; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities; locker/storage facilities; fire safety passive and active equipment and alarms; emergency response planning and facilities for management and disposal of garbage, sewage and other waste.
Third-party Workers
Douja CIV signs a contract with each of its contractors and requires its contractors a certification of registration. Areas of improvement noted relate to inclusion of Douja CIV’s HR and OHS requirements, including prevention of forced and child labor, worker grievance mechanism, health and safety conditions, use of employment agencies, and monitoring (e.g. contracts, minimum wage, working hours and overtime, statutory payments).
Going forward as per ESAP#1.1 the Project will develop and implement a contractor management plan aligned with the requirements of IFC PS2 for contractors and sub-contractors associated with Project’s construction activities and operations. This procedure will clearly define oversight and monitoring of the contractor’s ESMS including HR and OHS practices.
Supply Chain
The Project has not yet established supply chain management procedures. Hence, as per ESAP #2.4, the Project will develop a (i) a Supplier Code of Conduct (CoC) which prohibits the use of child labor, forced labor prevents GBV at workplace and includes relevant social and OHS requirements in suppliers’ own operations (ii) incorporate contractual clauses in agreement with its suppliers requiring from them to comply with its Supplier Code of Conduct in line with IFC’s PS 2 requirements and (iii) develop checklists to monitor supplier’s performance against agreed CoC and social contractual clauses in line with IFC’s PS2 requirements.
PS 3 – Resource Efficiency and Pollution Prevention
Pollution Prevention:
Environmental impacts from construction and operation are mainly related to land preparation, air emissions (heavy equipment, vehicles, generators), noise, sewage from domestic use and waste management.
As per ESAP #1.2, the Project, as part of the construction ESMPs, will be required to develop a site-specific environmental management plan.
Water Supply and Wastewater Treatment:
Water during construction will mainly be used for construction activities and drinking purposes. For Lagoona City, water for construction is currently obtained from the national water company (SODECI). If the Project sources water from a borehole in the future, they will be required to obtain a water abstraction license in line with national law (ESAP#1.2).
Wastewater will be generated at the construction site and worker’s accommodation. The Project will require from contractors to collect the wastewater in septic tanks and contract a licensed company to regularly empty the tanks (ESAP #1.2 – contractor site -specific EHS management plan).
The Lagoona City master plan foresees construction of sewage system and central municipal wastewater treatment plant (WWTP). As temporary measure, the Company will install a temporary WWTP until the central municipal WWTP commences with operation. Construction, operations, and maintenance of the WWTP will be done by a licensed contractor. As per ESAP #1.4, the Project (or delegate to contractor) will maintain treatment efficiency of WWTP and regularly monitor the effluent quality in line with WBG EHS Guidelines for Water and Sanitation (2007). The Lagoona City master plan also foresees construction, adequate collection, management, pre-treatment in oil and grease separators before discharge to surface waters of stormwater.
Waste Management
As part of the ESMS (ESAP #1.3), the Project will develop and implement waste management plan in line with the national law, requirements of IFC PSs and WBG General EHS Guidelines. As part of the contractor management plan (ESAP #1.1) requirements of the waste management plan contractually will be cascaded down to contractors and subcontractors, where contractors will be responsible to develop, implement and maintain site-specific waste management plans. The waste management plans will address procedures for collection, sorting, reuse, disposal for non-hazardous and hazardous wastes which will include chain of custody related documentation requirements.
PS 4 – Community Health, Safety and Security
The Project is in an urban setting (Lagoona City) and is surrounded by small businesses and other housing blocks. As Douja CIV finalizes construction on apartment blocks, a homeowner’s association is created with representatives from the current owners. In discussions with the management company of the homeowner’s association, trespassing was brought up as a security concern. It is unclear if trespassers are neighbors whose access has been disrupted due to Douja CIV’s construction.
Per ESAP #1.3 in the SEP, the Project and the homeowner’s association will engage with the trespassers to understand why they enter the apartment complex and find mutually beneficial solutions.
Life and fire safety
Buildings with the public access such as small retail/commercial spaces, schools and health care facilities are included in Douja CIV’s Lagoona City construction. Per ESAP #1.3 and in line with WBG General EHS Guidelines, the Project ensures that the design, and construction of new buildings with public access ( health care facilities, schools, shopping malls) are carried out in accordance with the relevant provisions on life and fire safety (L&FS) as set out in the WBG General EHS Guidelines, and the PSs, including, through hiring a qualified and certified L&FS professional with terms of reference and experience acceptable to the IFC, who shall, inter alia: (i) prepare a L&FS Master Plan before the design for the construction or rehabilitation of a facility and/or building; (ii) Certify that the design for the construction or rehabilitation of the respective facility and/or building meets the requirements of the said L&FS Master Plan; and (iii) Conduct a review of the L&FS systems as part of the testing and commissioning of such systems, and certify that the construction of such systems has been carried out in accordance with the accepted design. Share the design review and certification with IFC.
Site security
The Project will hire unarmed private security personnel to provide security of personal and property during construction.
As per the ESAP#1.3, the Project will develop and implement a security management plan and code of conduct for security personnel in line with the requirements of IFC PS4, principles of proportionality and good international practice and that will include requirements associated with community conduct, a code of ethics and implement clear guidelines on preventive and defensive use of force as well as processes on security background checks for the security personnel. The security management plan will be contractually binding for the private security provider and communicated to the security personnel as part of the induction, as well as refresher trainings. In addition, the community grievance mechanism (discussed under stakeholder engagement) will also allow for complaints related to security forces to be filled.
