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
Vinte has a corporate environmental and social management system (ESMS) and a suite of the E&S management plans (ESMPs) commensurate with the E&S risks and impacts of its operation and compliant with the requirements of IFC Performance Standards (PSs) with an integrated management policy that covers quality and OHS. As per ESAP #1, Vinte will review and update Javer’s ESMS and ESMP to assess and manage environmental, health and safety (EHS) risks and impacts from its operation, by cascading down its corporate ESMS. This will include (but not limited to) updating Javer’s E&S policy consistently with the principles of IFC PSs.
Javer identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. Its land selection procedure requires the development of assessment and feasibility studies, which include evaluating potential buying options on selected E&S aspects such as existing land use, proximity to natural protected areas, key biodiversity areas, contaminated land, presence of settlers and illegal activities, and presence of cultural heritage. As per ESAP #1, as part of the ESMS update, Vinte will review and update Javer’s land selection and acquisition procedure per IFC PSs' requirements.
Javer has an environmental audit program to ensure its portfolio of projects complies with local regulations and the EIA related mitigation management plan. The audit program includes conditions required at each construction site to protect biodiversity and minimize impact on vegetation and wildlife, to manage and dispose of waste in line with national law, implement pollution control measures during equipment maintenance, to dispose of removed soil in authorized landfills, to purchase soil from licensed suppliers, and to provide dust, noise, and air pollution control measures during transportation. The audit program needs to be strengthened to explicitly cover emergency preparedness and response, stakeholder engagement, archeological findings, and managing security personnel. As per ESAP #1, as part of the ESMS update, Vinte will review and update Javer’s E&S audit programs in line with the requirements in the IFC PSs and World Bank Group (WBG) General EHS Guidelines (2007).
The project development manager at each Javer’s business unit oversees compliance of its operations with EIA-related mitigation management plan and the environmental conditions at each site. The corporate legal team is responsible for document control and supervision of compliance with legal requirements, while the corporate social responsibility team provides training on E&S aspects. On the project site, the site manager and deputies oversee the project's technical, OHS, and E&S aspects. As per ESAP #2, Vinte will appoint or hire an experienced EHS manager to oversees EHS and OHS aspects of its operations in compliance with national law and IFC PSs requirements.
Javer will establish key performance indicators (KPIs) and monitoring and reporting procedures. As per ESAP #1, as part of the Javer’s ESMS, Vinte will develop a E&S monitoring program of construction sites that includes site inspections and KPIs reporting.
PS2: Labor and Working Conditions
Vinte has HR policies and procedures compliant with national law and requirements of IFC PS2.
Javer has documented HR policies and procedures that are compliant with national law and mostly aligned with the requirements of IFC PS2. HR policies and procedures apply to all employees and encompass a range of topics, including recruitment, terms of employment, internal workplace regulations, a code of conduct, freedom of association, non-discrimination, and anti-sexual harassment measures.
Javer has a workers’ grievance mechanism that aligns with its HR policy and IFC PS2 requirements, which is accessible to its staff. The mechanism is not formally available to contractors. As per ESAP #3, Vinte will review and update Javer’s worker’s grievance mechanism to include provisions for receiving grievances from contractor workers and develop a communication strategy to enhance awareness of the grievance mechanism and process across all its operations.
Javer has not documented OHS procedures as required by IFC PSs. The HR team is responsible for OHS risk management. At the same time, contractors are contractually required to create hazard identification, risk assessment, mitigations, and control measures, as well as to conduct OHS training for their employees per the requirements of national law. Although contractors report work-related incidents, investigations, and root cause analysis to Javer, they do not compile incident statistics. Over the past three years, there have been no reported occupational fatalities. As per ESAP #4, Vinte will review and update Javer’s OHS management system in line with IFC PSs and WBG General EHS Guidelines (2007), and good international industry practices (GIIP).
Javer’s contractors managing procedures have not yet been formally documented as required by IFC PS. Contracts stipulate that contractors must adhere to national law and standards and Javer’ code of conduct and prohibit engaging with child, forced, or bonded labor practices. As per ESAP #5, Vinte will cascade down to Javer its contractor management procedure to manage contractors in line with IFC PS, including providing a supervision mechanism, as well as providing an OHS evaluation protocol on the contractor performance which includes scores and penalties for labor, EHS and OHS wrongdoings.
PS3: Resource Efficiency and Pollution Prevention
Javer company monitors its carbon footprint and calculates greenhouse gas (GHG) emissions using internationally recognized methodologies. In 2023, the company reported its GHG emissions to be significantly lower than 25,000 tons of carbon dioxide equivalent per year.
Electricity for all facilities and construction sites is sourced from the national power grid. The company’s operations are not a major air, soil, or water pollution source. The local utility company handles water supply and wastewater management. During the construction phase, Javer engages authorized suppliers to provide water and establish temporary wastewater treatment plants until connections to the municipal system are completed. Local regulations mandate water storage and wastewater treatment plant development in certain areas.
Javer has documented efforts to reduce material consumption and waste from its office, but these efforts do not extend to construction activities. Currently, as part of its ESMS, Javer’s waste management procedures have not yet been formally documented as required by IFC PS for proper sorting, handling, storage, and disposal of waste at construction sites. Contractors are responsible for the collection, management, transportation, and disposal of all hazardous and non-hazardous waste, utilizing authorized service companies specializing in each type of waste. Vinte will develop a documented procedure to track and maintain records of contractor compliance in this area. As per ESAP #1, as part of the Javer’s ESMS update, Vinte will establish a procedure for waste and hazardous waste to be managed in line with IFC PSs, and WBG General EHS Guidelines (2007).
Hazardous materials, typically including paints, lubricants, cleaning agents, and other construction and maintenance chemicals, are stored and managed by contractors per local regulations, which include proper labeling and storage in the designated area. Javer’s hazardous materials management procedures have not yet been formally documented as required by IFC PS. As per ESAP #1, as part of the Javer’s ESMS update, Vinte will establish a procedure for hazardous materials to be managed per local regulations, IFC PSs and WBG General EHS Guidelines (2007).
PS4: Community Health, Safety and Security
Javer develops apartment buildings following local fire codes and technical requirements. As per ESAP #6, Vinte will develop as part of its ESMS a life and fire safety risk management (L&FS) Framework to Javer’s apartment building projects per national building and fire safety codes and WBG General EHS Guidelines (3.3 Life and Fire Safety) (2007). This framework will confirm that buildings are designed, constructed, and operated in full compliance with local building codes, local fire department regulations, local legal/insurance requirements, and per internationally accepted life and fire safety (L&FS) standards. Additionally, Vinte will develop a handover procedure to guarantee that the condominium administrator or building manager receives the relevant operative instructions and is assured of the expected quality of service.
Javer’s environmental audit program mandates that all projects implement control measures to limit traffic during peak hours and train drivers on the speed limits. However, there is currently no requirement to develop a traffic safety plan. As per ESAP #1, Vinte will develop and implement a traffic safety management plan for Javer’s operations, including traffic risk identification and assessment, evaluation of routes and access points, and emergency response.
Javer uses unarmed security services for its headquarters and construction projects. Javer does not have procedures to manage security personnel, and contractors are not obligated to adhere to Javer’s code of conduct. As per ESAP #7, Vill will develop a procedure applicable to Javer’s operation to manage construction and security contractors, which includes a code of conduct and an anti-sexual harassment policy.
