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
Environmental and Social Management System and Policies. Vision One's has established corporate E&S Management System (ESMS) in line with IFC PSs requirements. It includes an Environmental Management Policy, supported by other corporate policies, such as (i) Quality Policy, (ii) the Company's Code of Ethics and Conduct, (iii) Anticorruption Policy, (iv) Policy on Conflict of Interest, (v) Third-Party Hiring Policy, (vi) and Policy on the Management of the Whistleblower Channel. Additional operational procedures and manuals are in place, including waste management plans, risk management programs related to physical, chemical, and biological agent exposure, a health and safety policy, and a risk assessment management procedure. All units have in place an Environmental Management Policy that includes waste management and resource efficiency guidelines, among other topics.
Vision One ensures compliance with healthcare-specific standards through regulatory alignment with ANVISA (Agência Nacional de Vigilância Sanitária) and the Ministry of Health, clinical and operational accreditation from organizations such as ONA (Organização Nacional de Acreditação) and QMENTUM (an international accreditation program for healthcare organizations developed by Accreditation Canada), the implementation of internal Standard Operating Procedures (SOPs) and audits. The Company conducts training and continuous improvement initiatives, supported by technology-enabled compliance monitoring through a proprietary app.
Vision One will augment its corporate Environmental and Social Management System (ESMS) to include: (i) a corporate Stakeholder Engagement Plan (SEP) per PS1 requirements (ESAP #1) i, that will be cascaded down to hospitals and clinics in the network; and (iii) reinforce its EHS organizational structure with the inclusion of a social specialist in the ESG unit under the HR Department, responsible for social matters and overseeing the development and implementation of the SEP (ESAP #2).
Identification of Risks and Impacts: The Company 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. According to Brazilian laws, an Environmental Impact Assessment (EIA) is not mandatory for renovation or expansion of existing hospitals and clinics. However, Vision One as part of its ESMS has in place a risk assessment & management procedure called EPA (Estratégia para Ação) which serves as a facilitating tool for the identification, analysis, monitoring and control of EHS risks related to health care center management, renovation or expansion, including environmental risks, patient safety, health & safety, compliance with regulations, ethics and behavior, reputational risks, etc. The Company has also adopted a due diligence procedure for M&As, which details steps taken to assess E&S aspects of companies and facilities to be acquired. The procedure includes verifying operational licenses and monitoring reports, such as water resources and intakes, waste and wastewater management, pollution prevention, and legal cases on labor, civil, and environmental aspects, including land tenure and environmental fines. As part of ESAP#3, the Company will update the existing E&S due diligence procedure for M&A to include additional aspects: grievance mechanism, labor conditions, OHS performance, contractor management, GBV/SEAH resource efficiency and community health and safety, in line with national requirements and IFC Performance Standards.
Organizational Capacity. Vision One’s HR Department is responsible for E&S management, including waste management, effluent monitoring, resource efficiency (energy and water), environmental audits, climate strategy and GHG emissions. HR is also responsible for labor and working conditions, including OHS issues and L&FS requirements, stakeholder engagement, diversity and inclusion strategy, raising gender and inclusion awareness across the Company, conducting training, and supporting corporate areas in the different needs regarding Diversity and Inclusion (D&I).
Within the HR department, there is an ESG unit with an environmental specialist, who works in coordination with the E&S managers of each hospital or clinic. At hospitals and clinics, day-to-day monitoring and supervision are conducted by local technical staff with environmental and OHS training. As per ESAP#2, the Company will increase the number of staff responsible for E&S functions at the corporate level through the hiring of a social specialist within its ESG unit under the HR department, who will have the responsibility, among others, of coordinating the implementation of the Stakeholder Engagement Plan (SEP) at corporate level in coordination with the E&S staff from hospitals and clinics.
The Legal & Compliance Department is responsible for the management of the workers and community grievance mechanisms, due diligence of contractors and suppliers and the follow-up of the legally required licenses including environmental permits.
Management and Monitoring Programs. Vision One maintains all required environmental licenses and permits, including operations and sanitary licenses, LFS-related permits, and all the regulatory permits for the business activities of the Company. Due diligence of environmental and social aspects is conducted for all expansions and acquisitions to ensure compliance with regulatory requirements. Vision One monitoring system is mainly related to the EHS country regulation requirements, including waste and wastewater effluent, exposure to radiation, water and energy consumption, and incidents and accidents in its hospitals and clinics. As per ESAP#4, the Company will improve its current KPIs and monitoring procedures to adhere to IFC PSs and WBG EHS Guidelines. Improved KPIs and monitoring procedures will include resource efficiency and greenhouse gases, as well as waste management, as further discussed under PS3 below.
Emergency Preparedness and Response Plan. Vision One has documented emergency preparedness and response plans (“EPRPs”) for each individual facility per national law, that includes two main parts: contingency plans and evacuation procedures. Contingency plans have specific emergency response procedures covering different scenarios, such as firefighting and response, workers’ accidental exposure to biological or chemical hazards, flooding and other risk scenarios. The facilities have emergency brigades and professional firefighters as required by law for ambulatory services and doctors’ offices. The Company keeps records of fire permits for all hospitals and clinics, which follow regional building codes and fire protection regulations. Emergency exits are clearly marked, and evacuation exercises and fire drills are conducted annually in coordination and involvement of the local Fire Service Department. Staff members receive regular training and participate in emergency drills.
Under ESAP #5, Vision One will enhance its EPRPs in line with medical procedures and to: (i) address civil unrest risk; (ii) include safe evacuation procedures for patients with limited mobility or immobilized after medical procedures; and (iii) improve the training program.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures: The corporate HR team is led by an HR director and includes units in charge of change management, ESG, talent acquisition, culture & leadership development, performance management, diversity & inclusion, OHS and patient safety. The Company has in place a Code of Ethics and Conduct applicable to all employees, suppliers and service providers covering several topics such as child and forced labor, non-discrimination and equal opportunities, diversity and inclusion, workplace harassment, gender-based violence, sexual harassment, conflict of interest, data protection, respect for human rights and other topics. Vision One has also established a Medical Code of Conduct which includes the rights and duties of doctors and patients, information security and data protection, sexual and workplace harassment and discrimination, relationship of doctors with the health industry, conflict of interest, clinical protocols and other issues.
Vision One’s HR policies, procedures and practices are aligned with national law and PS2 requirements. As part of ESAP#6, the Company will develop a corporate HR Policy, that integrates all existing human resources practices such as recruitment, onboarding, compensation, including overtime, employee development, performance management and employee relations. The HR Policy will cover all direct and indirect employees, contractors, apprentices and temporary workers, if any, across the Company's operations, will serve as the basis for all human resources activities and will include monitoring procedures to ensure its correct implementation.
Working Conditions and Terms of Employment. As of October 2025, Vision One had approximately 4,700 employees with two types of contracts: i) 3,472 direct employees (75% female and 25% male), 98% of them hired full-time under permanent employment contracts covered by the Brazilian labor code or CLT (Consolidação das Leis do Trabalho), these employees work in different areas: Administration & Finance, Shared Services, Healthcare, Human Resources, Business, Operations and Technology; ii) 1,300 Autonomous Professionals or independent healthcare professionals (52% female, 48% male) in different areas: Administration & Finance, Clinical staff (including nurses and doctors, 86% women and 14% men), Business, Operations and Technology. Direct employees receive benefits such as health, dental and life insurance, meal allowance, maternity leave, childcare assistance, etc.
The Company has a set of HR policies and procedures including terms of employment, compensation and benefits, OHS, workers’ grievance mechanism, training, professional development, non-discrimination and equal opportunity, freedom of association, and prohibition of gender-based violence and (GBV) including sexual exploitation, abuse and harassment (SEAH), child or forced labor. The employment contracts define working hours, working days, holidays, duties, salary and benefits, and safety requirements. HR policies and documents are communicated to employees through inductions and training.
Workforce statistics are available, broken down by job function, gender and contract type. All direct employees are members of local unions, except for 20 executives employed at the holding company. Indirect employees are free to join unions if they choose to do so.
The Company provides induction training for new employees and contractors, including mandatory modules on EHS aspects, data protection, patient safety and sexual harassment prevention. For the healthcare teams, training is also carried out on the management of sharp objects and patient safety practices. For the clinical staff, training is carried out on accident prevention, patient safety practices, and life support. Continuous education programs are available for employees and independent healthcare professional contractors. Vision One applies a talent retention strategy in all its facilities; turnover reached 2.4% on average in 2024.
Workers Grievance Mechanism. Vision One has implemented a grievance mechanism called Ethics Channel using the "Contato Seguro" external platform for workers, patients and third-party grievance resolution, as well as a dedicated telephone line. The platform allows for anonymous reporting, and the claims are managed by an Ethics and Conduct Committee, composed of the CEO, the heads of HR and Legal & Compliance Departments, the Medical Director and a representative of the private equity fund that supports the Company. The time for responding to grievances is 7 business days, with immediate action taken in the event of serious issues, such as SEAH. After analysis of the reports, if the veracity of the facts is confirmed, disciplinary measures may be applied, including removal, suspension or dismissal of the employee, depending on the severity of the case.
Occupational Health and Safety. The Company has a Risk Management Program (RMP) in place in all its units, that deals with the identification, assessment and control of risks, and a Medical Control and Occupational Health Program designed to protect and preserve the health of its workers in relation to occupational risks, according to the risk assessment performed through the RMP. All facility managers, assisted by HR personnel, perform an occupational risk assessment to identify key risks. Employees are provided training and written information on the risks associated with the job position and related measures such as use of personal protective equipment (“PPEs”), as well as handling of biological materials and ophthalmic medications.
Vision One has a formal Standard Operating Procedure (SOP) for incident and accident investigation, which outlines the steps for reporting, root-cause analysis and implementation of corrective and preventive actions in case of lost-time injuries or safety-related events. The Company maintains records of safety measures, with KPIs, including incidents and accidents. All incidents and accidents are investigated and documented in the system. Until September 2025, Vision One registered 48 work related accidents among its staff, the most critical of them related to commuting to the workplace (especially motorcycle accidents) and sharp injuries. There was one recorded fire incident in 2025 related to a fire in a UPS at the Molinari unit in São Paulo with no personal injuries, only direct damage to the equipment. Vision One does not use equipment containing radioactive material in any of its locations.
The Company performs training and awareness campaigns to prevent such incidents and has in place an Internal Commission for Accident and Harassment Prevention, a joint committee of employer and employee representatives, primarily focused on preventing workplace injuries and occupational illnesses, promoting health and preventing workplace harassment. Vision One manages the risk of exposure to infectious diseases through mandatory vaccination for professionals, on-site vaccination programs and the implementation of a Biosafety, Sterilization and Infection Control Protocol and a Biosafety Risk Assessment for all activities. The Company undertakes Ergonomic Risk Assessments in its units and plans to start conducting workplace monitoring (noise, light, thermal stress) in all its facilities in 2026.
Workers Engaged by Third Parties and Supply Chain: Vision One requires its third-party suppliers and contractors to comply with national laws through specific contract clauses, such as labor and OHS obligations, prohibition of child and forced labor and environmental aspects. The Company’s Code of Ethics and Conduct (CoEC) applies to contractors and suppliers; standard contracts with suppliers and contractors require them to comply with the company's CoEC, which is an integral part of those contracts. The existing contracts and the current Code of Ethics and Conduct do not include monitoring labor and working conditions or EHS audits for third parties. As part of ESAP #7, Vision One will establish a monitoring procedure for its primary suppliers and partners (e.g., partner hospitals, laboratories and contractors) to manage PS2 requirements, including labor and OHS aspects, GBV, SEAH and child safeguarding.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. Electricity for all facilities is supplied from the national grid and sourced from renewable energy by bilateral power purchase agreements (PPA) acquired from the Brazilian energy market (Mercado Livre or ACL). Diesel fuel is used for the operation of backup generators. Currently, Vision One is still working to monitor water and energy consumption in all its units. The Company has installed solar energy plants using photovoltaic cells at 3 of its facilities and plans to expand this initiative to other cities, and at the same time is implementing projects targeting the reduction of single use plastic.
Water is generally supplied from the municipal networks, only 3 facilities carry out groundwater abstraction with the corresponding licenses. The Company undertakes some initiatives for reduction of water consumption and some cases of water reuse such as capturing condensed water from the air conditioning for garden irrigation at one facility and rainwater harvesting at one hospital for use in outdoor areas and gardens.
As per ESAP #4, Vision One will (i) develop periodic energy and water consumption monitoring reports, (ii) establish performance targets for energy and water reduction, and (iii) regularly review the performance targets to confirm whether they are set at appropriate levels and identify where action should be taken to reduce energy use.
GHG Emissions: Vision One has started in 2025, as a pilot project, the mapping of GHG Emissions in two of its largest facilities (the HOPE hospital in the city of Recife, State of Pernambuco in Northeast Brazil, and the H. OLHOS hospital in São Paulo). The Company will gradually quantify the GHG emissions for all its units and operations to publicly disclose the GHG data annually in its Sustainability Report (ESAP#4).
Pollution Prevention and Waste Management: Vision One has developed a Health Service Waste Management Plan for all facilities. The plan covers aspects related to generation, segregation, packaging, collection, storage, transportation, treatment and final disposal, as well as actions to protect public health and the environment. Waste is segregated and storage according to several categories: infectious (biological agents with risk of infection), chemical (hazardous chemicals and medications), common waste (household waste), recyclable (paper, plastic, metal, and glass), sharps (needles, blades, and sharp materials) and special waste (electronics, lamps, batteries, etc.). These categories are separated and handled separately according to their physical, chemical, and biological characteristics, physical state and the risks involved. They are stored separately in special dedicated containers with restricted access and transported by licensed service suppliers in vehicles equipped according to the category of each type of waste. Domestic and organic wastes are disposed of at licensed sanitary landfills, while chemical, infectious, and skin-piercing wastes are incinerated by accredited companies. Vision One does not use equipment containing radioactive material in any of its locations. All units discharge their wastewater to municipal/state networks in compliance with local municipal regulatory requirements.
Pesticide Use and Management: The Company conducts urban pest control at all its facilities every six months, targeting rodents and insects through certified contractors in compliance with national EHS laws and regulations; no WHO Class Ia and Ib pesticides are used for this purpose.
PS4: Community Health, Safety and Security
Community Health and Safety: Vision One hospitals and clinics are regulated by the National Agency for Sanitary Vigilance (ANVISA), which reviews and approves healthcare facilities design, issues operating licenses and regularly inspects all facilities. The Company implements clinical and non-clinical risk measures to prevent hospital infections. OHS procedures are followed, including the necessary biosafety protocols, audits and emergency drills. All transportation used by Vision One units is outsourced to licensed companies.
Community Exposure to Disease: There are documented infection prevention and control procedures in place to eliminate the risk of community exposure to disease. Local authorities conduct audits to inspect sanitation practices and other community health, safety and security-related issues. The Company has a monitoring program for community and/or patient health and safety, including bacteriological monitoring of floors and walls and water quality. Periodic testing and cleaning of air ducts are conducted per local regulations and by certified third-party providers.
Strict infection control protocols are applied in surgical procedures to ensure patient safety and reduce the risk of healthcare-associated infections. In general, patients who undergo surgery in hospitals only stay there for a couple of hours without overnight admission, except in some extraordinary circumstances. The Company has a protocol in place to respond to potential clinical emergencies involving patients, in such cases certified partners carry out the transfer of the patient to a general hospital facility, if advanced care is required.
Infrastructure and Equipment Design and Safety and Emergency Preparedness and Response: Each hospital develops and maintains site-specific emergency response plans, adapted to the local infrastructure and risks. These plans include designated fire brigades, emergency teams, evacuation routes, signage and medical emergency protocols. Life and Fire Safety (L&FS) infrastructure and systems are based on the requirements of the national building and fire safety codes and include fire extinguishers, fire detection and alarm systems with centralized control panels, sprinkler systems, fire hose reels at every floor, water storage tanks with fire pumps and smoke control systems. Emergency equipment, such as alarms, extinguishers, and generators are regularly inspected and tested.
In all its facilities, the Company has adopted an Emergency Evacuation Plan that prioritizes the evacuation of patients according to criteria such as mobility and criticality. As per ESAP #8, Vision One will engage a suitably qualified professional acceptable to IFC that will prepare a L&FS Design Manual (i.e., L&FS Master Plan) in line with the requirements of the L&FS Section of the WBG General EHS Guidelines, focusing on the most restrictive requirements of the local laws (regional fire codes) and international good practice for hospitals and clinics, as well as other facilities (e.g., optical stores and storage facilities). This manual will include, as a minimum, the following topics: fire prevention, means of egress, detection and alarm systems, compartmentation, fire suppression and control, emergency response plan and operation & maintenance, and will be used as a tool for the screening of sites during M&A process, and to provide company managers with information for decision making and identifying required modifications to correct safety non-compliances, accessibility aspects and structural issues of current buildings.
Security: Vision One employs unarmed security personnel for its hospitals and clinics, mostly directly hired with adequate training. Only one of the Company’s facilities has a Security Management Procedure (Procedimento Operacional Padrão - Controle de Segurança), which sets forth procedures for the installation and use of alarms, panic bottoms, construction and maintenance works, etc. As per ESAP #9, the Company will prepare a corporate Security Management Procedure in line with PS4 to regulate the use of security personnel, the access control for users, service providers, employees, medical staff, entry and exit of materials for use and consumption, and storage points for materials as well as circulation of equipment in all units.