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.
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 the 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
Prishtina Mall’s EHS policies demonstrate its commitment to protecting the environment and the health and safety of its employees, customers and the community. The mall is certified to ISO 9001 Quality Management System. At the time of IFC’s review PM was in the process of updating its existing EHS management procedures comprising of waste management, energy efficiency, sustainable water use, OHS, emergency response, evacuation plans, EHS training programs, and fire safety. Prishtina Mall will enhance its E&S management system by updating its existing EHS policies and procedures and developing a standalone child protection policy and relevant procedure aligned with IFC PSs, the relevant and applicable sections of the WBG EHS Guidelines, and in compliance with local regulations. The new procedures which will be developed and implemented by the Company will include E&S risk assessment, chemical spill and leakage management, hazardous materials management, periodic E&S performance monitoring, greenhouse gas accounting, contractor management, change management procedure, supply-chain management, and stakeholder engagement plan (ESAP#1).
In accordance with Kosovar regulations, PM has completed an EIA prior to the construction of the mall and acquired the necessary environmental approvals and permits from the local authorities. Additionally, PM followed applicable national legal requirements for the design and construction of the mall, including the specifications defined by the municipal authorities and the national building code and the requirements of environmental, sanitary and fire safety authorities.
PM has an ESG & Quality Manager responsible for E&S management, reporting to the CEO and COO. The operations team supports the ESG & Quality Manager, and Sonae Sierra provides support through EHS trainings and guidance. A local company certified by state authorities supports PM in fire and safety protection. All staff, including contracted workers, receive EHS trainings.
PM has an Operational Emergency and Evacuation Plan which includes defined responsibilities and procedures for different emergency scenarios (i.e., fire, natural disaster, seismic activity, other emergencies and accidents) and the relevant trainings are provided to all employees including contractors and selected anchor tenants. Multiple fire drills and emergency evacuation exercises are conducted. The mall is monitored 7/24 through closed circuit TVs which feed information to emergency response team. As part of the ESMS update (ESAP#1), Prishtina Mall will enhance its Emergency Operational and Evacuation Plan to incorporate crowd management measures to address relevant risks in an emergency situation.
PM conducts periodic monitoring activities for environmental and OHS aspects. Sonae Sierra’s corporate ESG teams’ representatives also perform periodic EHS-focused audits to support PM’s EHS risk assessment and management efforts. All these audits are summarized with time-bound corrective actions and the progress reported to senior management. Under the actions agreed to update its ESMS (ESAP#1), Prishtina Mall will formalize an EHS risk assessment and monitoring procedure, which will define relevant key performance indicators (KPIs).
Currently, PM does not have a systematic E&S screening & management process for its suppliers and service providers. While the technical specifications and E&S requirements for cleaning, maintenance, pest control, and security, are attached to contracts, they do not explicitly prohibit child and forced labor. With regard to the installation of rooftop solar panels, it will be a one-off purchase and therefore relevant PS requirements regarding primary suppliers are not applicable. PM will develop a contractor, service provider and supply chain management procedure including a code of conduct articulating its commitment to prohibit forced, and/or child labor and significant OHS risks, incorporate contractual clauses in agreements with its contractors, service providers and suppliers to comply with the code of conduct and undertake activities to monitor implementation and review their compliance (ESAP#1).
Land acquisition for PM was completed through willing buyer-seller arrangements. There is one land plot surrounded by the currently operational parking lots that is still owned by a private party. It is observed that the landowner retains full access to this plot and can use it for cultivation without any restrictions. PM maintains open communication with the landowner and ensures access remains unobstructed.
PS2: Labor and Working Conditions
As of October 2024, PM employs 53 direct employees (72% male and 28% female) and around 50 contractor employees for cleaning and security operations.
PM has an employee handbook and code of conduct that define the rights and obligations of the workers, working hours, compensation and benefits, annual and sick leaves, disciplinary procedures, equal opportunities and contract terminations. The handbook is explained to its employees during onboarding. However, currently there is no formal HR policies and procedures. At the time of the appraisal, the Company was in the process of developing of a worker code of conduct. As part of ESAP#2, Prishtina Mall will develop and implement HR policies and procedures in accordance with IFC PS2 and Kosovo labor code, which will be applicable to all workers (including contracted/sub-contracted workers). As part of its HR policies, PM will further develop a worker code of conduct and update the existing employee handbook applicable to all workers (which will specifically include measures related to GBVH). All direct and contracted workers will receive training on the company’s updated policies and procedures and code of conduct, including a GBVH prevention training (ESAP#3).
All employees are provided with a contract, which includes working hours, wages and allowance, holidays and leaves, health insurance and termination. All employees are above the age of 18 years. PM does not have an explicit policy on child and forced labor. As noted in ESAP#2 Prishtina Mall will update its HR policies and procedures which will include a measure to prevent child and forced labor, including monitoring for contractors and including relevant clauses in the tenant contract and in the tenant manual.
The Company is not a party to a collective bargaining agreement with worker’s organization, and there is no active union. PM is open to workers joining a union or forming a workers' organization. Prishtina Mall will include a clear statement in its HR policies which will affirm compliance with national law with respect to freedom of association (FoA) and therefore recognize workers’ organizations if the workers have chosen to form or join such organizations and engage in collective bargaining (ESAP#2).
The employee handbook of PM strictly prohibits any form of discrimination or harassment based on race, gender, age or religion and such behaviors are not tolerated and can lead to dismissal or other disciplinary actions. Currently, all employees who might experience discrimination, harassment or any other concerns about the work environment are encouraged to report directly to their line managers, CEO or HR Manager. Prishtina Mall will develop and implement a worker’s grievance mechanism (WGM), in accordance with IFC PS2 and local labor law. The WGM will be made available to all workers, including contractors/sub-contractors and tenant workers, irrespective of their employment status. PM will disseminate information about its use to the workforce and place grievance boxes in the mall to allow anonymous grievances. The grievance mechanism will define specific considerations for GBVH-related grievances, for which adequately trained grievance officers (men & women) will be assigned.
The company has an OHS management system, including a detailed job hazard analysis and risk mitigation measures and provide appropriate personal protective equipment (PPE) and training to its employees. These have been documented through work instructions and management procedures. Induction and refresher OHS trainings are provided. There is an incident reporting mechanism in place which records all reportable injuries, first aid cases, near misses and lost time accidents along with cause of accident, immediate action taken, and correction actions required. No fatal or serious accidents involving any employee at operational history were reported and the company reported limited lost time injuries.
PS3: Resource Efficiency and Pollution Prevention
Prishtina Mall is committed to resource efficiency and is exploring ways to optimize energy and water efficiency. The company implements a BMS to monitor and control of heating, ventilation and air conditioning (HVAC) and resource utilization. Prishtina Mall runs entirely on electricity purchased from the grid and consumed approximately 21,000 MWh in 2024. As part of this investment, the company will install a 4 MW rooftop solar park. The total greenhouse gas (GHG) emissions for the project are estimated to be approximately 22,000 CO2e tons/ year. Going forward, PM will quantify and report the total GHG emissions generated by its operations, by adhering the requirements of GIIP and identifying actions to reducing emissions.
Water is sourced from on-site wells and purified using reverse osmosis, mainly for sanitary and irrigation purposes. Separate water tanks are available for firefighting. Potable water quality is periodically monitored and tested by an external authorized laboratory.
Domestic wastewater from toilets and kitchens is discharged to the city sewage network. All food court units are installed with grease traps, with the oil separated from water via an oil separation system, waste oil is collected and disposed of by a specialized company.
The company has diesel-run back-up generators that automatically turn on when a power outage occurs. Additionally, diesel powered boilers which are used only in winter and undergo regular inspections and maintenance by a certified third party. The fuel is stored in an underground storage tank (UST) with a capacity of 5,000 liters, equipped with a proper storage and piping system (e.g., concrete vault) to prevent leaks. The tank and pipes are periodically inspected and maintained by external qualified companies and regularly monitored by the company. Prishtina Mall will formalize its UST and hazardous materials management and monitoring procedure as part of its ESMS under ESAP#1 (ESAP#1).
The primary solid wastes generated are packaging, delivery materials (e.g., cardboard and plastics) and paper wastes, which are segregated at source and handled by authorized recycling companies. Hazardous wastes, such as used fluorescent lamps and alkaline battery are stored separately and disposed by an authorized third-party. The company’s tenant manual provides clear instructions on waste management, recycling, H&S implications of poor housekeeping.
As discussed in PS1, the Company is in the process of documenting E&S management procedures. Prishtina Mall will formalize additional management procedures including but not limited to non- hazardous and hazardous waste management, hazardous materials storage and management, water and wastewater management and hazardous material loading/unloading procedures (as discussed under PS1 and included in ESAP#1).
Pest control and management are outsourced to a specialized service provider that follows local regulatory requirements when performing the activity.
PS4: Community Health, Safety and Security
Based on the review and site visit performed by IFC specialists, the fire protection measures in the mall are largely well managed, with design of facilities in line with international building codes and local fire safety regulations. PM’s L&FS protection systems include fire and seismic resistance structure, adequate means of egress capacity (i.e., staircases, corridors, and egress doors) to manage the maximum potential occupancy of the mall at a given time. The design of the mall has provided fire detection and alarms in all areas, as well as voice paging systems to communicate specific messages to tenants, clients, and own personnel during emergencies.
The fire suppression systems, including sprinkler and hose reel systems, are fed from a robust fire pump system, water reservoirs and fire water supply. The mall was provided with emergency lighting systems, emergency power and signage. The underground car park has carbon monoxide (CO) and gas detectors to activate ventilation fans in the case of fire and avoid accumulation of the CO or smoke. There are fire separation barriers and walls for the required fire separation of main egress corridors, hazardous areas, large tenant spaces and storage areas and parking areas. Vertical connection shafts and the means of egress (i.e., staircases and main evacuation corridors and pathways) are also available. The PM design included a complete set of accessibility features, including accessible elevators, ramps, visual signage and alarms, etc. The areas of the mall that are currently unoccupied (shell spaces) are protected with sprinkler system as required by fire codes and regularly inspected to avoid excessive storage of materials. The fire protection systems are supported by a security control room, using the mall’s CCTV system cameras and trained security personnel to respond to any fire alarm or emergency situation.
PM has a well-documented set of fire safety procedures to be followed in the eventuality of a fire, with trained personnel, regular inspections, and fire drills. PM also has an Operations and Maintenance program for the mall and leased stores (tenants), as a part of the tenant occupancy contracts, including information relating to fire safety equipment, frequency and procedure for inspections, testing and maintenance, and coordination activities with PM, in both normal conditions and emergency situations. Prishtina Mall will develop and implement a management-of-change procedure to follow-up any changes that might affect the current fire safety risk level in common areas or tenant spaces, including post-modification testing and commissioning procedures. The procedure will be followed in the case of new tenants, changes in architectural layout or use of space, and changes affecting the means of egress of the mall, and addition of tenants with special risks (ESAP#5).
Based on the site appraisal observations, some issues and potential risks were identified, including: (i) lack of hazard identification signs of important areas and hazardous rooms; (ii) housekeeping in back stage areas of the some tenants, (iii) wood blocks (wedges) used on exit doors to keep them open; and (iv) required specialized training on crowd management to be imparted to personnel of those tenants with children (minors) as main client base. Based on this, Prishtina Mall will develop and implement a time-bound L&FS corrective action plan. As part of the plan, Prishtina Mall will reinforce the periodic fire safety inspections of the mall’s common areas and the tenant units or other areas with risks associated with the general public (ESAP#6).
The company contracted a private security company which holds the relevant security license in accordance with the local law and have relevant trainings. Security personnel are unarmed and mainly responsible for conducting security checks at the mall and undergo thorough screening.
