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, Identification of Risks and Impacts, Management Programs
BHub uses only leased offices in commercial buildings located in urbanized areas. Its activities are limited to office work and rely on the use of displayed screens. BHub does not have an E&S policy and/or a management system to identify and mitigate its potential E&S impacts and risks. The company is not required by local regulations to have an environmental license and/or to conduct an E&S impact assessment. The company has adopted due diligence procedures to assess its clients, contractors, and suppliers, which include the verification of some E&S aspects such as licenses and presence of court cases on labor.
The company will develop an E&S Management System (ESMS) at the corporate level, commensurate to its risks, mainly related to office operations and ergonomics. The ESMS will incorporate (but not be limited to): (i) an E&S policy; (ii) process to identify the E&S risks and impacts of its operations; (iii) management programs to mitigate the risks and impacts; (iv) organizational capacity with defined roles and responsibilities for the implementation of the ESMS; and (v) process to monitor the implementation of the ESMS and E&S performance and process to report the E&S performance to senior management for its review. (ESAP #1).
The ESMS should also include a risk tool to assess the accounting firms’ policies and procedures regarding dismissals of employees resulting from BHub partnership to ensure they are aligned with national legislation requirements.
Organizational Capacity and Competency
The company’s E&S responsibilities are delegated to multiple departments, including the departments of Human Resources (HR), Facilities and Legal and by the Compliance Committee. HR is accountable for the management of labor conditions, recruitment, suppliers, and social communications. Facilities department manages Occupational Health and Safety (OHS), Life and Fire Safety (L&FS), contractors and security. Legal team is responsible for the due diligence of contractors and suppliers. The Compliance Committee manages the grievance mechanism.
The company will assign a dedicated E&S Officer, with documented roles and responsibilities, to oversee the implementation of the ESMS at corporate level. (ESAP #2).
Monitoring and Review
As part of ESMS that will be developed per ESAP #1, the company will implement monitoring programs to measure the effectiveness of the E&S management system as well as compliance with IFC PSs and regulatory requirements.
Emergency Preparedness and Response
BHub has developed an Emergency Response Plan (ERP or PAE in Portuguese) for the offices and keeps records and copies of permits related to the fire protection systems per local legal requirements.
PS2: Labor and Working Conditions
Human Resources Policies, Working Conditions and Terms of Employment
As of March 2024, BHub employed around 320 direct employees of which 43% are men and 57% are women. Employees are hired full-time, under permanent employment contracts. Additionally, the company employed four contracted workers for cleaning duties.
The company’s human resources (HR) policies, procedures, and code of conduct cover terms of employment, compensation and benefits, code of conduct, workers’ grievance mechanism, training, professional development, career path, non-discrimination and equal opportunity, freedom of association, data protection, and prohibition of child or forced labor and are communicated to employees through induction and training programs. HR policy and procedures, as well as the corporate level code of conduct, are applicable to employees and contractors. The employment contracts define working hours, working days, holidays, duties, salary and benefits, and information security requirements. The company has implemented apprentice and internship programs. These programs are implemented in line with national regulations and trainees are not involved in any hazardous work. As of March 2024, BHub employed three apprentices and 15 interns.
The company’s Diversity, Equality and Inclusion Policy and Code of Conduct stipulate non-discrimination, equal opportunities aspects and the prohibition of gender-based violence and harassment (GBVH). The company also promotes diversity and inclusion aspects in the organization through HR trainings and apprentice programs targeted for black women.
Transfer of Workers
BHub establishes partnerships with accounting firms (the partners) that retain an intermediary role with the final clients. The partnership involves the process of directly hiring accounting firms’ professionals. The firms or partners retain the relationship with the final client, but they reduce their workforce to the minimum as result of this partnerships. BHub’s HR team conducts interviews with the partner’s workers and selects the ones that will be hired by BHub.
Those employees that are not hired by BHub are likely to be dismissed BHub will oversee the partners HR procedures in this regard as part of their ESMS and described under PS1.
The company will develop, implement and disseminate to the workers an Operational Staff “Transfer Procedure”, in line with PS2 requirements, to ensure a fair, non-biased, transparent selection and hiring process. The Transfer Procedure will include: (i) a description of the steps of the workforce transfer process; (ii) a description of the selection process; (iii) a grievance mechanism, to receive workers’ claims and feedbacks on the process; and (iv) provision of a system for record keeping of the whole process. The Transfer Procedure will include a Performance Evaluation Procedure, which will encompass: (i) the description of the evaluation criteria, measuring methods and expected targets, so the workers understand the performance indicators they will be evaluated against; and (ii) the provision of timely feedback to the workers, so they have clarity throughout the process of how their performance is being evaluated by the company. (ESAP #3).
Retrenchment
Although the company is not anticipating a retrenchment in its workforce, it will establish a retrenchment policy, consistent with IFC PS2 and the applicable laws and regulations, including the description of the steps to develop a retrenchment plan. Through its partnership agreements, the company will require its partners to implement the Retrenchment Policy as needed. (ESAP #4).
Worker Grievance Mechanism
The company implemented a workers’ grievance mechanism allowing for anonymous and confidential complaints and is accessible via online platform (https://canal.aliant.com.br/canalbhub/). It allows employees, apprentices, interns, contractors, suppliers, customers, and external public to raise concerns, grievances, and suggestions related to the company’s operations such as non-conformities to the Code of Conduct and working conditions, without risk of retaliation. The flow of grievance resolution and roles and responsibilities are formalized as a worker’s grievance mechanism procedure. The Compliance Committee is responsible for addressing the grievances received, in accordance with the procedure described in the Code of Conduct.
As per ESAP #3, the company will upgrade the existing internal grievance mechanism, to include the possibility for workers to report claims and feedback on the migration process to BHub.
Occupational Health and Safety
The company doesn’t have an OHS management system at corporate level. As a part of the ESMS, to be developed per ESAP #1, the company will perform an OHS risk assessment and develop the required OHS management programs. OHS risk assessment will include workers on hybrid and remote work regimes.
Workers engaged by Third Parties
BHub engaged with third-party contractors for cleaning. BHub’s contracts include labor conditions requirements for the contractors as per the national legislation. As per ESAP #1, the company will review and update its contractor’s E&S management procedures, to ensure the respect for labor rights of contracted workers.
