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
DLG has a Sustainability and Environmental Policy and a Risk Management Policy in place but does not yet have an ESMS that aligns with the requirements of IFC PS1. Although certain E&S risks are addressed through existing operational practices, E&S risks identified at hotel level are not consistently codified into formal Group wide standards, documented procedures, management programs, monitoring indicators, and corrective action tracking systems. This is particularly the case as regards labor and working conditions, contractor management, and life and fire safety (LFS).
A global hospitality group manages two of DLG’s four hotels and implements its own standard operating procedures (SOPs), including undertaking regular audits on E&S topics. DLG has started to build on these SOPs and audit findings to enhance its E&S risk management practices across the Group.
DLG will strengthen its Group-wide ESMS to align with applicable national regulatory requirements, IFC PS1, and relevant WBG EHS Guidelines. The enhanced ESMS will apply across all hotels in the DLG portfolio, including those operated under third-party management arrangements and will establish Group-wide policies, procedures, and monitoring requirements to be implemented at hotel level.
The ESMS will include a PS1-aligned process for the identification and assessment of E&S risks and impacts including as regards labor and working conditions, LFS, contractor management, gender-based violence, sexual exploitation and harassment (GBVH/SEAH), road safety, community health and safety including child safety, and supply chain risks. It will include a Group-wide E&S monitoring and reporting framework applicable to all hotels. The ESMS will be implemented on an ongoing basis and will be periodically reviewed and updated to ensure continuous improvement. (ESAP #1)
DLG does not have an E&S Manager or dedicated E&S role responsible for E&S risk identification and management. A Group Finance & Administration (F&A) Manager maintains oversight of site-based health safety environment quality (HSEQ) and HR functions. Day-to-day management of E&S risks is undertaken at site level by operations managers that report to the General Managers, in conjunction with one full-time site-based HSEQ Manager responsible for quality and OHS across the four hotels.
Commensurate to the nature of the anticipated project risks and impacts, the company will establish, maintain, and strengthen an organizational structure that defines roles, responsibilities, and authority to monitor and ensure implementation of the ESMS throughout the construction and operational phases. DLG will recruit a Group-level E&S Manager reporting to the joint Chief Executives who will be responsible for strengthening and implementing the Group-level ESMS including ongoing monitoring and corrective action tracking. In the interim, DLG will engage a qualified external E&S Consultant or E&S consulting firm to support the development and implementation of the Group-wide ESMS. The Group-level E&S Manager will recruit any additional E&S and HSEQ personnel required to support effective ESMS implementation. (ESAP #1)
Permits for fire safety and food safety handling for the four hotels are current. One of the four hotels (TUI Blue Tamala) received an Environmental Approval (EA) from the National Environment Agency (NEA) in 2018 in relation to construction works undertaken by DLG at that time. EAs are not available for the other three hotels that were acquired by DLG. Environmental screening has not yet been undertaken regarding the planned and/or ongoing works across the four hotels.
DLG will regularize its environmental compliance status by submitting operational and development plans for its four hotels to the NEA for environmental screening. DLG will subsequently implement all environmental conditions associated with NEA environmental approvals (EAs). E&S assessment processes will be carried out in alignment with national regulatory requirements, IFC Performance Standards, and relevant WBG EHS Guidelines (both General and sector-specific). This will include management and treatment of wastewater and assessment of water sourcing and use across all sites including groundwater abstraction through on-site boreholes. (ESAP #3)
All four hotels manage their activities in general alignment with the requirements of the Gambia Tourism Inspection Board and Gambia Fire and Rescue. A documented emergency response procedure covering foreseeable emergency scenarios is in place for two of the four hotels. Fire detection and alarm systems are present across the four hotels however gaps were identified in: the consistency of coverage across all areas; functionality and maintenance; emergency signage; staff training including emergency drills; conduct of regular internal audits; inspection, testing and maintenance (ITM) records; and systematic follow up of corrective actions.
DLG will develop and implement a Group-wide Emergency Preparedness and Response Policy and site-specific plans aligned with IFC PS1 and GIIP on LFS, covering coordination with first responders and emergency services, including all foreseeable scenarios (i.e., fire, earthquake, tsunami warning, flooding, traffic accidents, civil unrest, water rescue, weather and climate change related events, other), defined roles, drills and training, schedule, incident reporting, corrective action tracking. Site-specific plans will be proportionate to each hotel’s risk profile and planned works. (ref. ESAP #1) (refer to PS4- LFS section)
DLG’s supply chain includes construction contractors and refurbishment suppliers; technical consultants such as the Owner’s Engineer; solar PV suppliers and equipment manufacturers; fuel and liquefied petroleum gas (LPG) suppliers; food suppliers including local produce and off-site meal preparation; laundry service providers; pest control service providers; and waste management contractors. Supplier contracts and invoices do not currently include E&S clauses, supplier codes of conduct, or right-to-audit provisions. DLG will develop a risk-based supply chain management system (SCMS) inclusive of a supplier code of conduct; risk-based supplier screening and onboarding; and targeted monitoring of labor standards. For hospitality operations, supplier screening and monitoring will also cover food safety and hygiene standards for key food and beverage suppliers, consistent with public health requirements and IFC PS4. (ref. ESAP #1)
PS2: Labor and Working Conditions
DLG employs a diverse workforce across its hotel operations comprising direct employees engaged on fixed-term employment contracts and a limited number of contractors. As at 31 December 2025, the four hotels employed 812 personnel, of whom 241 (30 per cent) were women, comprising 798 direct employees (239 women) and 14 contractors (2 women). The majority of personnel are Gambian and employed on fixed term contracts of six months’ duration, reflecting the seasonal nature of tourism operations in The Gambia. Depending on workforce requirements and operational demand, fixed term contracts may be renewed following review at the end of the contract period. DLG also operates a traineeship program that, at the time of appraisal, involved 87 trainees (51 women). Some workforce growth is anticipated in connection with the planned works.
A workers’ union, the Kombo Beach Hotel Workers Union, was established under Kombo Beach Resort’s previous ownership. A Department of Labour–recorded memorandum of agreement (settlement), concluded in 2019, exists between the Kombo Beach Hotel Workers Union and hotel management, covering communication on seasonal employment arrangements and retrenchment related matters. This agreement, brokered with previous hotel ownership, applies to employees of EON Company Ltd, the owner of Kombo Beach Resort, and remains valid. A number of these employees now work outside Kombo Beach Resort; at other DLG hotels. Measures related to workers’ rights to organize and bargain collectively, in line with national law and international labor standards, as required under IFC PS2, will be included in the labor assessment. (ref. ESAP #4)
The Group currently employs three full-time site-based HR representatives, who are based within the hotels. A first-aid clinic staffed by a registered nurse/midwife is located at Kombo Beach Resort, serving as the central first aid and basic medical facility for the four DLG hotels.
DLG has a Group-wide HR Policy and Staff Rules applicable to all staff, full-time, part-time, temporary, and contract employees across all four hotels. These include commitments to non-discrimination, equal opportunity, and fair treatment in recruitment, employment, and promotion, and prohibit harassment and inappropriate workplace behavior. The HR Policy also includes a zero-tolerance position on child and forced labor. DLG has procedures for conducting OHS risk assessments and maintains a multi-departmental risk register covering workplace safety risks. However, it does not yet have a comprehensive framework to prevent, identify, and respond to gender-based violence and harassment (GBVH) or sexual exploitation and abuse (SEAH), nor address child safeguarding risks relevant to hospitality operations.
Based on initial findings, DLG will commission an in-depth independent third-party labor assessment covering all categories of workers and focusing on labor and working conditions, including policies and procedures, wages and benefits, worker organizations, non-discrimination, grievance mechanism, OHS and contracted workers. In addition to implementing recommendations included in the labor assessment, DLG will implement baseline labor management controls, including strengthening of payroll systems, working time management, and minimum labor safeguards for contractors and trainees. (ESAP #4)
Review of clinic records, near miss reports, and labor inspection findings, indicates minor injuries and high potential near miss events, particularly in kitchens, maintenance areas, and workshops. While incident reporting is occurring, root cause analysis and legally required preventive measures are not implemented consistently across all facilities. A Group-wide OHS Management Procedure will be developed as part of the ESMS, incorporating risk assessments, standardized incident investigations, corrective action plans and training. The 2026 annual Health, Safety, Environment and Quality (HSEQ) Workplan will be implemented, and similarly detailed workplans will be prepared and implemented on an annual basis. (ref. ESAP #1)
Where hotels are operated under third-party management arrangements, DLG remains responsible for ensuring that corrective actions required under the ESAP are implemented. Corrective measures relating to HR policies and procedures, labor management practices, and OHS will be embedded in Group-wide ESMS procedures and policies and implemented operationally by the hotel manager as part of day-to-day management responsibilities. DLG will oversee implementation through its contractual oversight and reporting arrangements, ESMS monitoring, and periodic audits.
PS3: Resource Efficiency and Pollution Prevention
Hotel operations are currently supplied primarily by grid electricity, with diesel generators used during outages. Energy consumption is driven mainly by cooling, lighting, and electrical equipment. Solar PV systems are planned to be installed at three of the four hotels to reduce reliance on grid electricity and improve energy efficiency. Water is sourced from national utilities and onsite boreholes.
Sanitary wastewater is collected by licensed operators and transported to offsite treatment facilities. Air emissions are limited to diesel generators and vehicle use. Waste minimization is a Group objective and some initiatives are in place across the four hotels to recycle plastic bottles and fuel containers. Waste generation data collection and tracking systems are not yet in place. Hazardous and non-domestic waste streams include used oils, batteries, electronic waste, mercury containing lamps, empty chemical containers. These wastes are temporarily stored on site prior to collection by licensed contractors.
DLG has adopted a Sustainability and Environmental Policy applicable across its operations, committing to resource efficiency, greenhouse gas (GHG) reduction, pollution prevention, and sustainable hospitality practices, consistent with IFC PS3. While the Policy provides a strategic framework, it does not yet define clear roles, responsibilities, implementation procedures, or monitoring arrangements. DLG will establish a Group-wide Energy and GHG monitoring and reporting framework aligned with internationally recognized methodologies (e.g. GHG Protocol), including systematic monitoring of electricity and fuel use, annual estimation of Scope 1 and Scope 2 emissions, annual internal disclosure, consistent with PS requirements. It will also collect and report on its water extraction from boreholes at each site and will implement remedial actions as required, in alignment with IFC PS3 and relevant WBG EHS Guidelines. (ref. ESAP #1)
PS4: Community Health, Safety and Security
DLG’s hotels are located within a designated Tourism Development Area and operate publicly accessible hospitality facilities with high guest occupancy during The Gambia’s peak tourism season, from November to April/May, and low occupancy during the off-season of June to October. During the peak tourism season, the majority of guests are international, and mainly adults other than at Kombo Beach Resort, which is a family resort. DLG is focused on expanding its local tourism business, including through measures such as increasing its weekend brunch offerings and offering day passes for hotel facility use; particularly swimming pools. The Group maintains directly employed, site-based, unarmed security personnel at the four hotels.
Community health, safety and security (CHSS) risks are managed through general risk assessments and safety risk registers (e.g., noise, dust, traffic, emergency events, security, workforce conduct, and GBV/SEAH). Existing controls include pool attendants/lifeguards at all four hotels, with more than 14 first-aid trained staff, two on-call doctors, and first-aid kits at each site; however, site CHSS management plans and security management plans/policies are not yet in place.
Material CHSS risks (hotels): audits/inspections identify life and fire safety, emergency preparedness and response, water quality and Legionella control, pool/open-sea and recreational safety, food safety, and traffic safety as the primary material risks.
Life and fire safety (LFS): LFS risk is material due to high occupancy, seasonal staff turnover, public access, and third-party managed operations. The hotels have been designed with guest buildings of only two or three stories high, with open common areas and architecture, easy access to the egress staircases, and fire equipment in place. Available facility-level information indicates that a range of LFS systems are present across the hotels, however, there are important gaps in the completeness, consistency, and adequacy of these systems, and some elements are absent or not fully aligned with internationally recognized standards and GIIP. Based on information available at the time of appraisal, areas to be strengthened include consistency of fire coverage across all areas; the presence, functionality, and maintenance of key systems (including smoke detection, alarm, and fire suppression equipment); completeness of inspection, testing and maintenance (ITM) records; emergency lighting and signage; egress arrangements; fire separation and compartmentation; regularity of drills; and robust corrective action tracking .
DLG will engage a qualified LFS professional to undertake a comprehensive independent assessment and validation of systems across all four hotels, including identification of any missing or non-compliant elements and preparation of a corrective action plan. The LFS professional will develop a portfolio-wide LFS Master Plan that will establish Group-wide LFS requirements aligned with local authority requirements, IFC PS4, relevant WBG EHS Guidelines and IFC LFS GIIP for Hotels. This will cover fire suppression, detection and alarm systems, evacuation, ITM plan, training and drills, incident reporting, and corrective action tracking. Requirements will apply to all hotels, including third-party managed operations. (ESAP #5) The LFS will be integrated into the ESMS. (ref. ESAP #1)
GBV/SEAH and child safeguarding: hotel operations can create risks of harassment, exploitation or abuse Children may be present as guests/visitors and may face heightened safeguarding risks without clear prevention and response measures. DLG will integrate GBV/SEAH risk mitigation and child safeguarding into the Group-wide ESMS, consistent with IFC PS1, PS2, PS4 and GIIP, including: (i) dedicated GBV/SEAH and Child Safeguarding policies; (ii) survivor-centered grievance and response procedures for workers, guests and community members; (iii) mandatory training for staff, management, contractors and security; (iv) trained focal points; (v) referral pathways to local health, psychosocial, legal and child protection services. (ref. ESAP #1)
Water quality and Legionella: hotels use municipal supply and onsite groundwater abstraction. Testing indicates general compliance for treated/point-of-use supplies with World Health Organization (WHO) drinking-water standards, noting low pH typical of local groundwater and the need to treat raw borehole water. Audits identified gaps including no documented Water Safety Plan or Legionella risk assessment, inconsistent monitoring/records, and limited formal designation/training of responsible personnel. DLG will develop and implement a Group-wide Water Safety and Legionella Management Framework aligned with WHO guidance and the WBG EHS Guidelines, defining risk assessment, monitoring/treatment protocols, roles and responsibilities, escalation and oversight within the ESMS. (ref. ESAP #1)
Pool/beachfront and recreational safety: audits identified control weaknesses including inadequate signage/depth markings, insufficient rescue equipment, inconsistent records of lifeguard competence, variable pool chemistry control, and hazards in plant rooms. DLG will implement a Group-wide Recreational Water Safety Program, applicable to both pools and the ocean, setting minimum physical standards, lifeguard/pool attendant competence requirements, water quality monitoring, emergency response, routine inspections, and corrective action tracking, including improved warning signage and coordination protocols with local authorities. (ref. ESAP #1)
Food safety: audits identified deficiencies in hygiene, cold chain management, chemical handling, food preparation practices, and record-keeping. While no major food-borne illness incidents have been reported, weaknesses in oversight/documentation increase guest health and compliance risks. DLG will implement a Group-wide Food Safety Management System integrated into the ESMS and aligned with HACCP, Codex Alimentarius guidance, and GIIP, standardizing controls, training, monitoring, incident management, and corrective and preventive actions across all four hotels. (ref. ESAP #1)
Traffic and transportation safety: no road traffic accidents involving Group vehicles were recorded in the last three years; however, DLG will finalize its Transportation Safety Policy for the vehicle fleet and integrate it into the ESMS. (ref. ESAP #1)
