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
Five over six operational divisions under Steamships, including PPP, have established and implemented Environmental Management Systems (EMS) and Occupational Health and Safety Management Systems (OHSMS), and have obtained certification for ISO 14001:2015 for EMS and ISO 45001:2018 for OHSMS, as well as ISO 9001:2015 for quality management system. The remaining division is aiming to achieve certification by 2024. To comply with the requirements of PS1, an Environmental and Social Management System (ESMS) will be developed to manage the environmental, health and social (EHS) aspects as follows: (i) an EHS Manual to be developed by Steamships will serve as the construction-phase ESMS and will be applied by construction contractors; and (ii) an operation-phase ESMS to be adopted and implemented by PPP to cover the operations of the shopping mall.
The project site was selected through an alternative site analysis, considering factors such as site access and the availability of infrastructure including road transport, drainage, water, and electricity supply. The company has engaged an external design firm based in Australia for all design-related work, and the project facilities will be designed to comply with national building codes, while also integrating internationally recognized standards, including relevant life and fire safety requirements.
In accordance with the legislation of Papua New Guinea, an Environmental Impact Assessment (EIA) is not required for the Dobel project due to its minimal environmental and social risks. Nevertheless, the company is required to integrate standard environmental control and resource efficiency measures into the project design to comply with the IFC’s PSs and applicable sections of the World Bank Group (WBG) General Environmental, Health, and Safety (EHS) Guidelines.
As outlined in ESAP, Steamships shall develop an EHS Manual for construction activities to ensure compliance with the WBG Guidelines. Steamships, along with construction contractors and sub-contractors, are required to adhere to the stipulations defined in the EHS manual, which will be incorporated into contracts as appropriate. Steamships will assign one Project Manager and other positions on site to supervise construction works, including EHS issues. Contractor’s site manager is responsible for managing EHS risks during construction and will have an EHS team. The manual will include requirements related to EHS monitoring and both internal and external reporting.
E&S risks and impacts during the project construction are anticipated to be limited and typical of a small construction site, such as the generation of dust, noise, and solid waste and OHS. Upon completion, the Dobel development will be managed by PPP, a company under Steamships. Accordingly, Steamships should incorporate relevant operational EHS requirements, as well as L&FS control measures of the shopping mall into the scope of work of PPP. Steamships will also adopt or update the ESMS of PPP to cover the operations of the shopping mall accordingly. Moreover, Steamship will also develop an external grievance mechanism which will allow external stakeholders, including local community, to raise any concerns during the project’s construction and operation, including related to security personnel.
PS 2 – Labor and Working Conditions
The construction works will be executed by a contractor selected through a competitive bidding process. It is anticipated that the contractor will employ 160 professionals and workers for the construction of the Dobel shopping mall. Approximately 30 of these professionals will be foreign nationals, while about 130 construction workers will be hired locally. If accommodation is provided for the workers, the company will require the selected construction contractor to develop a workers’ camp management plan that complies with paragraph 12 of IFC PS2 and is aligned with the IFC-EBRD Guidance Note: Workers’ accommodation: processes and standards.
Employment will be conducted in accordance with relevant national and Western Highlands Province regulations. The company will ensure that wages comply with national minimum wage requirements. Child labor or forced labor, whether directly employed or through subcontractors, is strictly prohibited. Subcontractors will be required to adhere to all local labor regulations as well as Performance Standard 2 as specified in their contractual agreements. The company must ensure that all workers involved in the construction of Dobel have written contracts clearly detailing the employment relationship with the company. These contracts should include, but are not limited to, terms and duration of employment, wage calculation, working hours, overtime, deductions, rest days and breaks, and grievance procedures.
The construction contractor’s site manager is responsible for overseeing environmental, health, and safety protocols during construction. The construction contractor will be obligated to provide personal protective equipment to its employees and conduct training and regular safety toolbox talks and inspections at the construction sites. All work-related incidents will be investigated in a timely manner in accordance with incident investigation procedures which will be detailed in the EHS Manual. Incident records are maintained, and compensation is provided in accordance with national requirements. As previously described, the EHS manual for construction will include provisions to ensure safe working conditions for both workers and contractors. In line with the ESAP, Steamships must ensure that labor practices of subcontractors comply with relevant regulations and that subcontracted workers have access to the grievance mechanism.
It is confirmed that Steamships has a Respectful Workplaces Policy or Anti-bullying and Sexual Harassment (SH) policy, Family and Sexual Violence (FSV) policy, as well as a robust Code of Conduct (CoC) which addresses discrimination based on gender, and mechanisms that promote employees’ well-being and protect them from workplace gender-based violence (GBV). These measures demonstrate Steamships’ proactive approach to creating a supportive workplace culture. For further strengthening, expanding and extending Steamships’ efforts to address GBV risks and other complaints or concerns raised by direct and contract workers, including construction workers and workers associated with leased spaces, an internal Grievance Redress Mechanism will be developed, and the Company will introduce and implement contractual clauses for direct and contract workers, including construction workers and workers associated with leased spaces with the objective of ensuring that these workers are aligned with the anti-GBV policies and commitments.
PS 3 – Resource Efficiency and Pollution Prevention
The construction works will involve road works, pilling, excavation and earthworks for services and basement construction, stormwater and runoff management, water supply infrastructure, drainage works, sewerage infrastructure, new landscaping, demolishing the temporary supermarket and clearing existing vegetation for access prior and during construction all within the site. Building work will involve site benching and construction of ground services to enable the construction of a shopping mall. The company will implement environmental mitigation measures aligned with the best international industry practices to minimize the impacts of construction noise, dust, wastewater and waste.
When the Dobel shopping mall comes into operation, it will be connected to electricity and municipal water supply. In addition, the complex will be equipped with diesel generators to generate electricity in case of grid failure. The shopping mall will be designed with green features and is expected to be EDGE certified.
Wastewater generated during operations is expected to be primarily domestic, originating from restrooms. In accordance with the World Bank Group's General EHS Guidelines, the company will incorporate a wastewater treatment unit in the design of the Dobel facilities to meet the indicative guideline values for sanitary sewage discharges and general guidelines on wastewater discharge into surface water. Furthermore, oil-water separators will be installed and regularly maintained in the parking area.
Solid waste produced during operation will primarily consist of domestic waste from commercial, retail, and residential tenants. The company will make efforts to minimize, reduce and reuse the wastes through segregation and recycling. Unrecyclable waste will be transported by a local contractor to the municipal disposal site operated by the local government.
The company will ensure that ozone-depleting refrigerants will not be used, and regular maintenance is performed to reduce the likelihood of, and quickly remediate, refrigerant leaks.
The development of new facilities under this IFC funded project will not result in more than 25,000 tonnes of carbon dioxide-equivalent emissions per year from these operations.
PS 4 – Community Health, Safety and Security
In accordance with IFC’s requirements, all new buildings accessible to the public should be designed, constructed, and operated in full compliance with local building codes, local fire department regulations, local legal/insurance requirements, and in accordance with an internationally accepted L&FS standard. Therefore, the Dobel shopping mall will be designed, constructed, and operated based on these standards. The company will adhere to national building codes while integrating internationally recognized standards, including relevant L&FS and structural safety requirements. Planned L&FS measures include emergency exits, fire alarms, and firefighting equipment.
To confirm compliance of the Project with IFC’s requirements, certification by suitably qualified professionals shall be conducted at the design stage of the project and after construction conforming compliance of retail buildings with the WBG General EHS Guidelines for Life and Fire safety requirements.
Given the proximity of the project site to the Highlands Highway, a major road with significant traffic volume, a Traffic Management Plan will be developed to mitigate potential impacts such as accidents and congestion during the construction and operation of the proposed shopping mall.
The company will either directly employ or engage a third-party contractor to provide security services for the Project during the construction and operation of the shopping mall, these forces are expected to be unarmed. The company will develop clear rules of conduct (including the use of force) for security personnel and require them to act within the applicable law. The Company will additionally provide trainings on rules of conduct for security personnel.
