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
Polmed’s current E&S policies include OHS, anti-mobbing, non- discrimination, sexual harassment, and child safeguarding policies. However, currently, there is no overarching E&S policy, or a comprehensive documented ESMS.
As per ESAP#1, Polmed will develop and implement a corporate ESMS in line with IFC PS1, national and applicable EU laws’ requirements. Once established, the corporate ESMS will comprise the following policies and procedures: (i) an overarching E&S policy to reflect the adoption of the Company’s values and principles in compliance with IFC PSs provisions and enhancement of the existing policies, applicable to all facilities of Polmed and its subsidiaries; (ii) corporate oversight for E&S and OHS related regulatory compliance; (iii) identifying and prioritizing key E&S risks (including climate risks to its facilities), development of E&S management plans and operational procedures, roles and responsibilities; (iv) E&S due diligence process for new developments and M&A; (v) development of training programs; (vi) internal E&S and OHS monitoring and reporting systems, for all facilities; (vii) HR policy and procedures including GBVH prevention and remediation and recruitment policy; (viii) waste management, (ix) OHS management; (x) contractor management; (xi) LFS and EPRP; (xii) security management, (xiii) Stakeholder Engagement Framework (SEF) including external grievance mechanism, and (xiv) supply chain management. The corporate ESMS will be cascaded down to all Polmed’s subsidiaries.
Polmed and Target identify and manage E&S risks and impacts associated with their operations through compliance with applicable national standards and E&S regulatory permits and requirements (e.g., handling biomedical waste, operation of medical diagnostics X-ray equipment, fire permits). For the planned expansion projects, which are in the early planning phase, if required, Environmental Impact Assessment will be prepared in accordance with the Polish regulations. Additionally, the Company (or the construction contractor on behalf of the Company) is required to develop and implement Construction Phase E&S Management Plan (CESMP) to address environmental, labor and OHS issues (ESAP#2).
For new acquisitions, the Company will develop and implement, as part of the corporate ESMS (ESAP#1), an E&S due diligence process, aligned with IFC PSs requirements, particularly with respect to identifying and managing impacts/risks related to OHS, labor, land acquisition, historical contamination as well as biodiversity, in line with IFC PS requirements.
In Polmed, E&S function is typically managed by general managers at the subsidiary level where some facilities are supported by outsourced OHS company. Moreover, Target has an E&S team, responsible for day-to-day management of E&S risks and impacts. As per ESAP#3, Polmed will hire/appoint an Environmental, Social, Health and Safety Coordinator at corporate level, with relevant expertise and experience, to monitor the development and implementation of the ESMS and review the E&S performance. If needed, Polmed will retain services of at third-party contractor/s that are subject matter experts during the development and implementation of the ESMS and review E&S performance.
Environmental and OHS trainings (refresher) are provided every five years as per the national regulatory requirement. As per ESAP#1, Polmed will develop and implement an E&S training program for its workforce including annual refresher E&S and OHS related trainings.
Polmed and Target have documented EPRP for each individual facility, that include two main parts: i. contingency plans and ii. basic evacuation procedures. Contingency plans have specific emergency response procedures covering different scenarios, such as firefighting and response, workers accidents, exposure to biological or chemical hazards, flooding, and other risk scenarios. As part of the corporate ESMS (ESAP#1), the Company will undertake climate related risk assessment and address the relevant risks in the respective EPRPs, accordingly. Emergency evacuation exercises and fire drills are conducted annually in coordination and involvement of the local fire department and in line with national regulations.
The existing EPRPs do not adequately cover patient safety and shelter in place procedures. Thus, Polmed will update its EPRPs with a specific section focusing on patient safety, to define the responsibilities for evacuation, improve communications, the use of patient evacuation means (e.g., special chairs and sheets), and develop a training program for fire alarm operators and other responsible staff (ESAP#4). Facility management and safety manuals including guidance on regular checks of all equipment and systems are available for each facility.
The facilities, have their monitoring programs, mainly related to quality and safety indicators. Under ESAP#1, Polmed will develop E&S related key performance indicators (KPIs) such as energy and water use, and management, OHS (such as needle stick injuries, X-ray exposure level), trainings hours, number of management inspection rounds planned/executed, among other indicators. Summary periodical reports will be shared with senior management to guide improvements and recommendations.
Primary suppliers of both companies are medicine wholesalers, pharmaceutical companies, and cleaning agent wholesalers. Additionally, Polmed and Target have service agreements with maintenance and medical laundry companies. Polmed’s purchasing department defines the general terms and conditions for their suppliers (and service providers). Polmed and Target’s existing supply chain screening or monitoring does not comprise of forced labor or child labor aspects. As per ESAP#1, Polmed’s procurement processes will be updated in line with IFC PSs to incorporate basic labor risk screening involving, at a minimum, child and forced labor and OHS aspects.
PS 2 – Labor and Working Conditions
As of July 2024, Polmed employs around 1,000 employees (direct employees as well as employees through contracts). The employees are mainly health care providers (i.e., physiotherapists, nurses, and doctors), administrative, cleaning staff, and management, of which majority are women. Additionally, Target employs approximately 550 employees (health care providers, administrative, cleaning staff and management) of which 450 are women. Third-party workers are employed for security support.
Currently, Polmed’s subsidiaries have its own internal rules and regulations document which describes the working terms, conditions, and benefits (i.e., recruitment, remuneration, working hours) in line with the national labor law. All information related to the labor and working conditions are provided during the on-boarding procedure of all new staff.
As per ESAP#5, Polmed will develop and implement corporate HR policies and procedures including a Code of Conduct consistent with IFC PS2, and applicable EU and Polish labor laws. HR policies will define Polmed’s commitments concerning labor and working conditions, recruitment, freedom of association and collective bargaining agreement, retrenchment, health and safety, equal opportunities, and non-discrimination, GVBH, prohibition of child and forced labor, and workers’ grievance mechanism. These HR policies and procedures will be applicable and accessible to the entire workforce and all employees will receive induction training on the HR policies.
According to both companies’ management, workers have the right to form and join workers organizations, although currently there are no workers organization representing the employees. The current policies encourage non-discrimination and equal opportunity which include statements such as prohibition of any discrimination based on nationality, gender or ethnic origin and characteristics non-related to the jobs. There were no reported complaints in relation to discrimination, including GBVH in both companies. Company has a system to verify and record employee’s age during the recruitment process to prevent employment under the age of 18 years.
Polmed does not anticipate any retrenchment of existing workforce in Target or its own companies. Polmed will include in its HR policies and procedures statements about its retrenchment policy and commitment to prepare a plan when necessary applicable to all its subsidiaries, in line with PS2 requirements and Polish law (ESAP#5).
Currently, Polmed does not have a documented worker's grievance mechanism (WGM). Employees raise grievances or concerns verbally to their supervisor or facility manager. Polmed will develop and implement a WGM allowing for anonymous and confidential complaints, in accordance with IFC's PS2 and Polish labor law. The mechanism will be made available to all workers, including contractors/sub-contractors with a specific route for GBVH-related grievances, for which an adequately trained grievance officer will be assigned on corporate and facility level (ESAP#6).
Polmed has a policy against mobbing, discrimination, and sexual harassment and established a committee which addresses complaints, reviews evidence, and communicates decisions. Additionally, both Polmed and Target have a child safeguarding policy that includes guidelines for screening during staff recruitment, appropriate interactions between staff and pediatric patients. As per ESAP#7, Polmed will develop and implement a GBVH focused training program for all employees including managers and the HR personnel at all Polmed facilities.
Per ESAP#1, Polmed will define in the CESMP, the Company’s labor-related requirements for contractors and subcontractors, aligned with Polish Law and the Company’s HR policies and procedures.
The key OHS risks in Polmed and Target facilities typically include falls, needle stick injuries, radiation exposure and chemical management. The Company has an OHS policy as well as a risk assessment management procedure for different job functions. OHS related trainings are provided during onboarding and repeated every five years as per the national law. Staff are provided with necessary personal protection equipment (PPE) including gloves, mask, goggles, aprons and radiation detection devices and hygiene and spill kits are present. Each incident is registered by the heads of units (e.g., chief nurse) and reported to general manager. As part of ESAP#1, Polmed will integrate OHS related procedures in its corporate ESMS including risk assessment, training, and incidence recording (e.g., near-misses), reviewing, monitoring and reporting procedures in compliance with IFC PS2 requirements. The annual refresher trainings will be provided to all workers.
PS 3 – Resource Efficiency and Pollution Prevention
At Polmed and Target Company facilities, electricity and water are sourced from the public network. Polmed implements resource efficiency initiatives, such as use of energy efficient LED lighting, regular maintenance of electrical appliances, use of digital method to save films and chemicals for X-ray apparatus, and others. Jantar and Target use LNG boilers for heating. In Jantar facilities, the Company generates electricity through rooftop solar panels and there are standby diesel generators at their facilities. Tap water is tested periodically by the Company.
There is no greenhouse gas (GHG) emissions monitoring at corporate or facility level. The current GHG emission of Polmed is expected to be around 400 tons carbon dioxide gas equivalent per year. Polmed electricity consumption, energy efficiency indicators and GHG emission will be monitored as part of corporate ESMS.
All domestic wastewater from toilets and showers, together with other liquid effluents ( urea and chemicals from laboratories) are discharged to the municipal sewage as per the environmental permit conditions at all facilities.
Target provides radiotherapy, chemotherapy and nuclear therapy. The equipment used in nuclear therapy has settling tanks for potentially radioactive water and disposed by an authorized third-party in compliance with the national regulatory requirements.
Hazardous materials include chemicals used in the clinical laboratory dealing with sample assessments (e.g., blood sample test) and material data safety sheets are maintained to handle such chemicals. Wastes typically include domestic wastes, e-wastes, hazardous wastes, and biomedical wastes. As part of ESAP#1, Polmed will develop hazardous materials management procedure for handling the hazardous chemicals including storage of chemicals in designated storage shed with ventilation, with leak detection systems and sprinkler systems as well as provision of secondary containment to contain the material in case of any spill occurrence.
Biomedical waste is segregated at source depending on type of wastes and method of disposal (e.g., plastic contaminated with blood for autoclave, general wastes for municipal collections, sharp waste such as syringe). Biomedical waste quantity is kept in record using checklist and collected by authorized contractors for disposal or incineration at designated places. Waste transportation within the clinics and hospitals is handled by authorized personnel. At Target, all solid waste from departments using radioactive or nuclear treatments is collected separately in led containers. As part of ESAP#1, Polmed will develop waste management plan and procedures including monitoring of waste and the treatment methods used by their contracted collectors which will be cascaded down to its subsidiaries.
PS 4 – Community Health, Safety and Security
Polmed complies with Polish structural, seismic and fire safety codes for the design of new facilities and for the improvement of existing facilities. The facilities are designed to provide universal accessibility measures and to facilitate the mobilization of patients, including ramps and elevators for easy access. For the construction or renovation of facilities, the Company engages specialized architecture and engineering design companies with recognized experience in healthcare and local regulations.
L&FS infrastructure and systems are based on local regulations and included required fire extinguishers, fire detection and alarm system with centralized control panel, fire hydrants, fire hose reels at every floor, water storage tanks with fire pumps and smoke evacuation systems and sprinklers are installed as needed. For the existing rehabilitation hospitals in Jantar, the fire safety conditions will be improved per the recent requirements set by the fire safety authorities of Poland, including the installation of additional emergency exit staircases and fire compartmentation walls in patient wards/dormitories of the rehabilitation hospital.
Polmed will commission an L&FS professional to develop a corporate standard “L&FS Design Manual (or Master Plan)” focusing on the applicable requirements of the local laws, fire safety requirements and international good practice for hospitals, ambulatories, and clinics. This Design Manual will be adopted into all new construction and substantial renovations, and screening of target assets during M&A (ESAP#8). The Company engages L&FS professionals (third-party experts assigned by the local municipalities), 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 corporate L&FS Design Manual.
For all operating facilities, as a part of ESAP#9, Polmed will develop a plan to reinforce the current inspection, testing, and maintenance program of L&FS systems and housekeeping practices, consistently across all regions and facility types specifically by developing relevant L&FS-related KPIs for operation and maintenance activities, as well as systems that are used to support life of patients.
Polmed and Target has a program for patient safety and has in place comprehensive engineering and administrative controls such as proper ventilation systems, architectural segregation and controls on water quality, food, and waste, among other preventive and corrective measures. Potable water for the existing operation is provided by the municipality. Both companies monitor periodically the potable water to confirm physical and microbiological parameters under Polish regulations that are aligned with the WBG EHS Guidelines for Healthcare facilities guidance values. Additionally, the Company has a monitoring program for community and/or patient health and safety, including bacteriological monitoring, physiotherapy equipment and systems (e.g., pools, hot tubs), water quality, and radiation exposure. Periodic testing and cleaning of air ducts are conducted per local regulations and by certified third-party providers. At Jantar facilities, where catering service is provided to patients, raw produces are adequately stored and/or dry rooms with temperature monitoring in the kitchens, separated from other materials. A pest control system in place.
Security personnel are outsourced by a licensed company. All security personnel are unarmed. Their main role is to regulate access to the facilities.
