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.
Identified Applicable Performance Standards
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards.
PS1-Assessment and Management of Environmental and Social Risks and Impacts
PS2- Labor and working conditions
PS3-Resource Efficiency and Pollution Prevention
PS4-Community Health, Safety and Security
Comments
There is no material risks related to significant conversion of natural and/or critical habitats or expected impacts on Indigenous Peoples and cultural heritage, as the Project sites are within established urban areas. Hence, PS5 (Land acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not considered applicable.
Environmental & Social Categorization and Rationale
This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012), with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures. Key environmental and social risks and impacts associated with this Category-B project will include: (a) potential non-compliance with national requirements, including (ESIA approval and environmental permitting) ; (b) the adequacy of Group and SPV E&S capacity, management systems and organizational structure to manage construction and operations of the proposed centers in line with the IFC Performance Standards (PSs); (c) fair, safe and healthy working conditions for employees and contracted workers; (d) efficient use and conservation of energy, water and process materials including the integration of green building design principles; (e) management of emissions, effluents and waste during both construction and operation in line with WBG EHS Guidelines and WBG Sector Guideline for Health Care Facilities ; (f) life and fire safety design of the proposed centers and emergency preparedness and response in line with WBG EHS Guidelines; g) potential impacts on nearby communities due to construction activities, traffic and security, worker influx including GBV; and (h) community grievance management. Within the healthcare clinic context, sexual exploitation, abuse, and harassment (SEAH) as well as child protection are key risks to be considered.
Environmental & Social Mitigation Measures
(Observations that are not to be disclosed must be recorded in ESG360)
IFC’s appraisal considered the environmental and social management planning process and documentation for the proposed Project and the gaps, if any, between these and the 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 in an Environmental and Social Action Plan (ESAP), to be agreed with the Group. Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
Applicable PSs summary
PS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S Policy and Management Systems
The Group has a quality policy and operates a Quality Management System (QMS) certified to ISO 9001 across its facilities, with the exception of medical devices, IT, communication and marketing, and canteen services. The QMS includes overarching management procedures covering risk and opportunity identification, internal audit, and management of non conformities, as well as procedures for specific clinical and operational areas including infection control, waste management, injection safety, and use of safety equipment. Fourteen departmental Standard Operating Procedures (SOPs) have been updated since 2023 related to heath care practices such as procedure related to patient identification, procedure related to the communication of a critical diagnostics, procedure to high-risk medication, etc. Procedures for operating theatres, emergency rooms, and resuscitation have also been developed while radiation safety and fire prevention procedures are pending internal approval and implementation.
The QMS does not address key occupational health and safety (OHS) aspects, including overall OHS management, laboratory and food safety. The QMS also lacks procedures covering key environmental management areas such as energy efficiency, hazardous materials management, and wastewater management. In line with ESAP (#1), the Group will enhance its QMS to align with PS1, the WBG General EHS Guidelines, and the WBG Health Care Facilities Guidelines. The enhanced system will include:
(i) an E&S policy incorporating environment, OHS, gender and social inclusion, SEAH and child protection, stakeholder engagement, grievance redress, and contractor management;
(ii) E&S risk and impact identification procedures for new operations and asset management;
(iii) E&S management and monitoring plans including water testing against national requirements and WBG EHS Guidelines for healthcare facilities;
(iv) an Emergency Preparedness and Response Plan;
(v) defined E&S roles and responsibilities for both new centers.
E&S Organization
The Quality Control Department oversees QMS implementation, supported by infection control and safety committees chaired by the Medical Director and Head of Surgery. A hygienist oversees infection control, a facility Manager manages life and fire safety systems, and a security Manager oversees security operations. A similar structure will be adopted for the new centers. Under ESAP (#2), Farah Polyclinique will appoint a qualified E&S Manager to implement the ESMS across the two IFC financed sites, covering OHS (including laboratory and food safety), environmental management, fire safety and emergency response, stakeholder engagement, and grievance management. To support ESMP implementation, an OHS Specialist will be engaged for the construction phase ESAP (#3).
Identification of E&S Risks and Impacts
At appraisal, the client had hired a private firm to develop the ESIA for the ophthalmology center. The national environmental entity has reviewed the ESIA, and the E&S permit is pending issuance. The ToRs for this ESIA have been reviewed and are aligned with IFC PS’s. In alignment with national legal requirements, the IFC Performance Standards, and WBG EHS Guidelines (General and sector-specific), Farah Polyclinique will commission site specific Environmental and Social Impact Assessments (ESIAs) for the oncology center through a consultant accredited by the Agence National de l’Environnement (ANDE) and secure the required environmental permits for the IFC financed project sites prior the commencement of any construction related works.
Informal activities have been observed on the land for the proposed oncology center. As part of the ESIA, the Group will conduct a land access assessment to determine PS5 applicability due to informal use of the Oncology Centre site. If PS5 is triggered, site specific mitigation measures will be implemented before development. The Term of Reference for the ESIA reports, and the draft ESIA reports, will be shared with the IFC for review ESAP (#4), and mitigation and monitoring measures identified in the E&S Management Plans (ESMPs) and applied during construction and operations.
An operations phase E&S risk assessment will also be undertaken. As the current QMS risk assessment does not address key facilities management risks (life and fire safety), employee and laboratory safety, or radiation risks, the Group will enhance the risk assessment to cover all potential key risks for the two project sites. Any mitigation measures identified based on the risk assessment will be implemented ESAP (#1).
Emergency Response Plan
Polyclinique Farah has multiple emergency exits, enclosed staircases with fire doors, emergency lighting, and evacuation plans displayed on each floor. About 60 employees have been trained in the use of fire extinguishers. However, the hospital does not have a documented Emergency Response Plan (ERP). In line with their ESMS, an ERP will be prepared for both new centers, covering total building evacuation and specific procedures for patients with mobility restrictions. Regular drills and awareness sessions will be conducted for employees.
Monitoring and Review
The QMS includes monthly monitoring of over 39 quality and HR indicators and periodic audits on hygiene, QMS document management, and HR practices. However, key risks, including facilities management (life and fire safety), staff safety, laboratory safety, radiation safety, environmental risk such as emissions, wastewater quality, and resource efficiency, are not monitored.
Under ESAP (#1), the Group will establish a corporate monitoring and review procedure specifying minimum KPIs, including environmental, social, and safety indicators. The procedure will define monitoring frequencies, methods, and thresholds for corrective action. Thresholds will adhere to applicable national legal requirements and relevant values from WBG EHS Guidelines (General and sector–specific). Performance data will be integrated based on the appropriate management system for regular management and executive reviews consistent with SPVs governance structures.
PS2: Labor and Working Conditions
Farah Polyclinique’s Human Resources department comprises a 12-person team, reinforced in early 2025 with new hires, including the HR Director. The Group employs approximately 1,000 staff across its facilities, of whom about 800 are at the Polyclinique. The workforce comprises permanent employees (~75%), needs-based/temporary staff (~20%) and interns (~5%). The majority of the Group’s employees are female (more than 65%). Staffing estimates for the new centers will be determined.
HR policy, working conditions and terms of employment: The Group has a documented HR procedures manual which includes procedures on recruitment, training, attendance, payroll, disciplinary sanction, annual medical check-up, document management. The HR Department conducts induction for all new employees. The procedures are readily available to managers, and employees may contact either their manager or the HR Department to obtain access to these procedures. All employees have written contracts (either fixed term or permanent) in line with national requirements. The needs- based/temporary staff are either government servants who also work in the private sector or staff with specific expertise, having documented contracts with the Group.
Farah Polyclinique employs interns who are either students or professional interns. Each intern is engaged through contracts that are specifically tailored to the healthcare sector in Ivory Coast. These contracts ensure that the internship experience aligns with the requirements and standards of the medical field, providing appropriate structure and guidance for interns working within the Group's facilities.
As per ESAP (#5), the HR procedures will be updated to include policies on non-discrimination, prevention of gender-based violence and harassment (GBVH), prevention of child and forced labor, grievance mechanism with specific process on investigation of GBVH complaints, commitment to respect freedom of association and the right to collective bargaining and retrenchment. Project SPVs will communicate the updated HR procedures to all of their workforce in appropriate languages and will develop a mechanism for the employees to access the updated HR manual (e.g. through intranet, app/s, bulletin board displays).
Freedom of association: As per applicable national legal requirements, there is an internal employees’ association (Mutelle), comprised of a President and six members who are elected by employees. The association provides support to the employees to raise concern related to overtime and working conditions. Similarly, as per the labor laws, 16 employee delegates have been elected from various departments. The delegates hold regular discussions with the HR Department on various HR matters including wages, working conditions, insurance, and planning. As mentioned above, as per ESAP (#5), a specific policy and procedure on respect of freedom of association and the right to collective bargaining will be developed and implemented at the new centers.
Grievance mechanism and GBVH: There is currently no procedure dedicated to the receipt and investigation of employee grievances. Instead, the QMS includes a procedure for customer grievances that also covers grievances raised by employees. The existing procedure also does not allow filing of anonymous complaints. Under the current process, employees may raise grievances directly with their supervisor and, if the issue remains unresolved, submit a written complaint to the HR Department. Should the grievance remain unresolved, it may be further escalated to the Director of the HR Department. The Group also conducts an annual employee satisfaction survey which is anonymous and allows employees to provide comments on a confidential basis.
The Group does not currently have a separate process of receiving and investigating GBVH complaints. As per the ESAP(#5), the Project SPVs will develop and implement a documented grievance mechanism for the workforce, consistent with PS2 requirements and Good International Industry Practice (GIIP), including: (a) written procedures and a transparent process for timely grievance resolution and response, with appropriate methods to handle grievances or concerns related to GBVH in a survivor-centric manner as well as being child-sensitive for complaints involving minors; (b) clearly defined key performance indicators (KPIs) to monitor grievance resolutions and report internally as well as provide feedback to those affected; (c) training to staff for consistent implementation and dissemination of the workers’ grievance mechanism; (d) specific training for managers/supervisor to handle grievances or concerns. The grievance mechanism shall include processes for reporting sexual exploitation and abuse of patients and hospitals users (including children) perpetrated by employees or contractors. The mechanism will allow for the receipt and resolution of anonymous complaints and shield complainants from retribution.
Occupational health and safety (OHS): Key OHS risks include falls, needlestick injuries, infectious diseases, radiation exposure, and chemical handling. All staff undergo medical checks at recruitment and on an annual basis thereafter As per ESAP(#1), Project SPVs will (a) enhance the risk assessment to cover all OHS risks; (b) enhance QMS further by development of additional procedures on OHS management (including laboratory safety), food safety (c) implement the enhanced QMS at the new centers within reasonable timelines; and (d) include relevant training sessions in the training and capacity building plan for the new centers. To comply with national requirements for new projects, a health and safety committee will be formed and at least four meetings will be conducted annually as mandated by law.
Third party workers: For construction projects, the Group hires a general contractor and a project management company (PMC) to oversee work and ensure national compliance.
For construction of new centers, the Group will appoint an OHS Specialist/Coordinator to supervise the construction contractors in alignment with the QMS requirements. For the construction of the new centers, as per the ESAP (#6), the project SPVs will develop a documented EHS manual for construction activities, to be adhered to during bidding process, as well as a monitoring procedure and checklist which will include: (i) clear EHS/labor and working conditions including Code of Conduct to be implemented at the site; (ii) clear roles and responsibilities of the project SPV, PMC and contractors’ personnel for implementation and regular EHS monitoring on-site; (iii) incentives and measures for the contractors non-compliance, including the modalities for their implementation; (iv) requirements related to compliance with applicable labor laws including prevention of child labor; and (v) specific processes for dust control and waste management. Relevant clauses derived from the EHS manual will be included in contracts signed by contractors, and the implementation will be monitored through regular site inspections and audits.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: The Group is planning to design the buildings to meet the requirements of IFC’s EDGE (Excellence in Design for Greater Efficiencies) standard to achieve energy, water and material efficiency. As the sites for the new centers are located in urban areas, the main source for power supply will be the national power supply. Back-up diesel generators will be provided
Water Supply and Wastewater Treatment: Similar to the power supply, the new centers will depend on the municipal water supply system. As per ESAP (#7), the relevant Project SPV will install a wastewater treatment plant at the oncology center to ensure that treated effluent meets all relevant national standards and the requirements specified in the WBG EHS Guidelines and WBG Sector Guideline on Health Facilities. Also, the wastewater treatment system will incorporate appropriate measures, such as delay tanks, to ensure sufficient storage of radioactive wastewater based on the half-life of the materials used. The quality of the wastewater treated will be tested during commissioning to verify compliance with applicable standards and guidelines.
Hazardous materials management: Hazardous materials used in laboratories, laundry, water treatment, and generator operations will be managed in line with enhanced QMS procedures. Radiation related materials at the oncology center will be governed through updated procedures under ESAP (#1).
Biomedical waste management: As part of the QMS requirements, a bio-medical waste (BMW) management procedure has been developed which describes the system of appropriate sorting, labeling, handling, storage and disposal of BMW from the facilities. A segregated BMW storage area is provided in the facilities where waste is stored in color coded bags and waste is collected by an authorized external agency for disposal. Similar procedures will be implemented at the proposed centers. For any radioactive waste expected to be generated at the Oncology center, the procedure for radioactive waste management will be included in the radiation safety procedure (described under ESAP#1).
Greenhouse Gas (GHG) Emissions: Based on expected electricity and diesel consumption for the proposed centers, the estimated GHG emissions for the project are expected to be less than 25,000 tons CO2 equivalent per annum (tpa CO2 equivalent).
PS4: Community Health and Safety
Life and fire safety (LFS) systems: Polyclinique Farah has fire extinguishers, fire hose reels, fire pumps, fire alarm system with smoke detection and manual call points. The other clinics managed by the Group have fire extinguishers and manual call points. The Group has a contract with an agency to maintain the fire safety equipment.
The Oncology Center will have 60 beds for overnight patient hospitalization. The Ophthalmology Center is expected to be a day-care center and will not have overnight patient stays but the building will have two floors to accommodate 16 studios for rent. As per the ESAP (#8), the Project SPV for the oncology center will design a life and fire safety (LFS) specification to be compliant with the national code as well as internationally recognized LFS codes as required under the LFS section of the WBG General EHS Guidelines At the design stage, the Project SPV will commission a suitably qualified LFS consultant to review and confirm that all the LFS-related aspects of design are consistent with an internationally recognized LFS code.
Since construction of the ophthalmology center is already underway, the LFS consultant will inspect the new building after completion to ensure it meets the agreed design. Certification at both design and post-construction stage will be shared with the IFC. Any remedial measures identified to bring the building into compliance with WBG EHS Guidelines will be completed within a timeframe agreed with IFC.
Community exposure to disease: As per the current QMS requirements, an infection control procedure has been developed for control of nosocomial infections. The company has put in place engineering and administrative controls such as proper ventilation systems. Segregated Air Handling Units (AHU) have been provided in various areas for improving infection control in operation theatres and with use of Variable Refrigerant Volume (VRV) based air conditioning systems in individual patient care rooms. Other preventive measures in place include decontamination practices, access restrictions and controls on water and waste. Each facility has an infection control committee to monitor implementation of the program and procedures.
Security Personnel: The company has a security manager who is overseeing security operations. All operating facilities have security guards who are either company employees or the services are outsourced to private security agencies. All guards are unarmed. Similar security arrangements will be implemented at the new centers. The agreement signed with the security agencies needs improvements as it does not include any guidelines on background search, engagement with staff and visitors or use of force. As per ESAP (#9), Project SPVs will develop a security code of conduct and include clauses on background search, engagement with staff and visitors, and use of force in the agreement signed with any security agencies. All security guards will receive training in these guidelines.
