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
Environmental and Social Risk Assessment and Management System. PLP is yet to develop an E&S Policy and E&S management system. As noted above, PLP will be the Operator of the Hotel and has signed a Franchise Agreement with Hampton by Hilton. As part of this investment, PLP will develop and implement a hotel-specific ESMS aligned with the Hilton Standards, statutory requirements and IFC PSs. The ESMS will include (i) an IFC PS aligned E&S policy; (ii) identification and assessment of E&S risks and impacts, considering contractor’s activities; (iii) E&S management plans and procedures such as labour, energy, water, waste and pollution management, pest management, food and water safety, a company level contractor management plan among others; (iv) E&S organizational capacity; (v) emergency preparedness and response, including life and fire safety (LFS) provisions; (vi) a legal register / permitting plan to track all licenses and permits; (vii) security management plan; (viii) supplier code of conduct and supply chain due diligence; (ix) occupational health and safety management procedures; and (x) E&S monitoring/reporting procedures for operations and activities carried out by the contractors, including Key Performance Indicators (KPIs); (xi) a stakeholder engagement plan including a communication procedure and an external grievance mechanism (ESAP#1).
Identification of E&S Risks and Impacts. PLP has developed an Environmental Impact Assessment of the hotel project (disclosed with this ESRS) as per the national regulatory requirements. For construction phase, the Company has developed a Plan for Construction Operation (PCO) which outlines key site mobilization aspects including traffic management, security arrangements, and organizational structure, among others. A Health, Safety and Environmental Protection (ESHSP) manual has also been developed by the main construction contractor and includes an ESHSP Policy, E&S organizational capacity at contractor and sub-contractor level, safety audits requirements, accident and incident management, OHS requirements including use of personal protective equipment (PPE), resource management, emergency response and training. The construction ESHSP manual briefly provides key elements on emergency preparedness and response and will be updated to include a PS-aligned emergency preparedness and response plan which will be disseminated to all groups of workers (ESAP #2).
E&S Management Programs. As per ESAP #1, PLP will develop specific plans, procedures and instructions to mitigate the E&S risks and impacts for the hotel, such as labor management procedures, OHS management procedures, hazard identification and risk assessment, LFS, food safety consistent with the principles of Hazard Analysis and Critical Control points (HACCP), pool safety, crisis management, Legionella control procedure and pest control, electrical safety, air emissions monitoring and management plan, waste management procedures, hazardous material management plan, child safeguarding procedure, security management plan and other related E&S procedures, in line with local regulations, Hilton Standards and IFC PS requirements.
E&S Organizational Capacity and Competency. The E&S aspects for the construction phase are overseen by a safety manager and a safety officer appointed by the main contractor. Subcontractors are also required to appoint an EHS officer. For the operation phase, E&S personnel are yet to be appointed. PLP will recruit a qualified E&S manager to oversee and manage all the E&S risks, and to lead the implementation of the E&S management system and associated plans, including those addressing risks that may arise during significant maintenance and renovation works (ESAP #3).
Emergency Preparedness and Response. Emergency preparedness and response considerations for construction activities have been included in the project’s environmental management plan developed as part of the EIA, the PCO and the main contractor’s ESHSP manual. As part of its ESMS (cf. ESAP #1), PLP will develop a hotel-specific EPRP consistent with IFC PS1 requirements, that will respond to the needs of the hotel’s life and fire safety requirements and include training on emergency evacuation, guest safety, use of fire equipment, and other applicable aspects identified in the planning process. The EPRP will cover all possible emergency scenarios based on a risk analysis including fire, earthquake, accidents, natural disasters, proximity to airport operations, violent person and terrorism among others. PLP will also enhance the EPRP by including all additional climate-related scenarios such as flooding, heatwaves, drought, sea-level rise, as needed, based on additional climate risk assessment and will provide a copy of the final EPRP for the hotel. The Plan will include an emergency communication protocol with surrounding stakeholders located within the airport premises. Training on emergency preparedness and fire drill program will be provided to all groups of workers. The EPRP plan will be periodically reviewed and updated as new risks are identified.
Monitoring and Review. PLP monitors overall construction activities through regular on-site meetings and will formalize a contractor management plan with adequate level of supervision (cf. ESAP #1). As part of the ESMS, PLP will also develop an E&S monitoring procedure aligned with Hilton reporting requirements, statutory obligations and IFC PSs. The procedure will define E&S key performance indicators (KPIs) including OHS indicators (incident performance, workplace monitoring data, near miss and hazard reporting), resource (water and energy) usage and efficiency, pollution prevention and control (air emissions, noise, effluents, solid/hazardous waste management), food safety and labor (grievances, strikes, court cases, etc.). The procedure will also define and set target for E&S KPIs to be regularly reviewed by senior management, with a clear escalation mechanism for key risks, performance indicators and corrective actions, in line with GIIP as well as with WBG General EHS Guidelines (cf. ESAP#1).
PS2: Labor and Working Conditions
PLP has approximatively 30 direct and 150 casual workers, for construction activities as of May 2025, recruited by the appointed Engineering, Procurement and Construction (EPC) companies. At the peak of construction, the number of employees is expected to be around 400. Around 135 permanent (direct and contracted) employees are expected during operation phase and will be recruited by PLP, with a target of 50% of female workforce.
Human Resources Policies and Procedures. PLP is yet to develop Human Resource (HR) policies and procedures for operations phase. PLP will develop a HR Manual outlining the company’s policies and procedures guiding the working conditions and terms of employment. The Manual will include adequate policies with clear provisions on compensation (including overtime, leave and benefits); equal opportunity and non-discrimination; gender-based violence and harassment; freedom of association and collective bargaining; prohibition of harmful forms of child labor and forced labor; retrenchment, disciplinary measures and worker grievance management; and labor and OHS policies and procedures applicable to all groups of workers. HR policies and employment terms and conditions will be aligned with the national labor law requirements and consistent with IFC PS2 requirements. All staff and contracted workers will receive a copy of the Manual and training on these policies at hiring. The company will maintain regular communication on these policies and procedures through training and refresher sessions (ESAP #4).
Employment Conditions and Management of Worker Relationship. For hotel operations, all employees will be provided with written contracts in accordance with the national labor laws and IFC PS2 requirements. All contracts will clearly outline key employment terms, including wages and benefits, working hours and overtime, annual leave entitlements, allowances, probation and notice periods and statutory deductions.
Worker’s Organization. As per ESAP #4, PLP HR policies and procedures will include clear provisions on workers’ right to freedom of association and collective bargaining in line with labor law and IFC PS2 requirements. The policy will also clearly state zero tolerance for any retaliation on account of participating in union and freedom of association related activities. Awareness training will be carried out for all employees on these aspects.
Grievance Mechanism. PLP will develop, prior to operations, a grievance mechanism accessible to all workers including third party staff, contractors and guests. This mechanism will outline the available channels for submitting grievances including separate channels for confidential and anonymous complaints, as well as grievances related to gender-based violence and harassment (GBVH). It will also emphasize a strict non-retaliation policy; define roles and responsibilities for treating and responding to grievances; timelines for taking action; and system to log, track and report grievances and their status in accordance with PS2 requirements. In addition, PLP will implement support services to affected workers and guests including access to medical services, counseling, legal assistance, and options for job reassignment. A dedicated committee will be appointed to monitor and resolve grievances. This procedure will be documented, and appropriate worker sensitization undertaken through in-person training sessions and dissemination of information on online platforms and notice boards. Staff members responsible for managing GBVH-related grievances will receive specialized training on a survivor-centered approach for handling and investigating such incidents. PLP will develop a GBVH referral pathway for cases of GBVH reported through the grievance mechanism (ESAP #5).
Occupational Health and Safety (OHS). OHS arrangements during the construction phase are outlined in the ESHS Manual and include adequate provision of personal protective equipment, safety induction and weekly toolbox talks, regular inspections by the EHS officer, a permit-to-work system for critical activities, accident/incident management procedure and emergency drills. For the operations phase, PLP will develop hotel-specific OHS management procedures, covering project-specific hazard identification and risk assessment, risk registers, incident/accident tracking, investigation and reporting, periodic medical surveillance program for workers, amongst others, (cf. ESAP#1). The OHS procedures will be in line with country legislation and relevant sections of the WBG EHS General and Sectoral Guidelines and IFC PS2. The company will also institute an OHS committee which will meet regularly to discuss health and safety matters and have representation from all key departments. OHS components will be included in the onboarding and refresher trainings.
Workers Engaged by Third Parties. PLP has two main contractors for the project’s construction phase. Employment terms and conditions during construction phase are set at contractor level. The two main contractors have developed key HR policies including a code of conduct, a grievance management procedure and are providing contracts as per national labor law. The end of employment of the construction workers will be managed as per statutory requirements.
For the operations phase, the following services are planned to be contracted: security, landscaping and gardening, linen laundry, and pest control. As per ESAP #1, PLP will develop contractor and labor management plans to verify the statutory compliance of all contracted workers with national labor and health and safety regulations, including for workers assigned to operations and maintenance activities. This system will include, but not be limited to, the verification of worker identification documents at the time of hiring, provision of written contracts outlining their terms of employment and benefits, wages, leave, etc., safety measures, and contractual arrangements. Furthermore, in line with ESAP #5, the hotel’s internal grievance mechanism will be extended to third party workers to raise concerns or complaints confidentially and without fear of retaliation.
Worker’s Accommodation. PLP is providing accommodation to the construction workers. The accommodation is located on a land parcel within the airport premises, leased by PLP for a period of two years maximum, non-renewable. The accommodation conditions for some groups of workers merit improvement to guide/enhance their health and hygiene, safety, security, grievances and relationship with the larger community. The civil works have been completed, and the main contractor is being demobilized. PLP will confirm the decommissioning of the worker’s accommodation by providing a letter confirming the completion of the civil works, the demobilization of the main contractor and photographs of the workers’ accommodation area (ESAP #6).
Supply Chain Management. As part of the ESMS development, PLP will develop a Supplier Code of Conduct and Procedure to explicitly prohibit any form of child and forced labor and include due diligence procedures for the procurement of critical materials and services and reporting requirements for suppliers if applicable, consequences of non-compliance with such requirements, and mechanisms through which requirements will be formalized and monitored.
PS3: Resource Efficiency and Pollution Prevention
Energy and resource efficiency measures were incorporated at design phase as per the Hilton Design and Construction Standards. It includes energy efficient equipment and a guest room management system (GRMS) to monitor and reduce the energy consumption, solar panels, dual flush toilets, amongst others.
Greenhouse Gases (GHG) Emissions. The GHG emissions will primarily stem from electricity consumption, vehicle fuel consumption and diesel for back-up generators. Upon completion of the hotel, Scopes 1 and 2 GHG emissions are not expected to be above 25,000 tonnes Carbon Dioxide (CO2) equivalent per year.
Water and Wastewater Management. Water supply is provided through the municipal network, both for construction and future operation, with concrete tanks for reserve. The average water consumption is estimated at approximately 33 cubic meters per day. Potable water quality will be monitored periodically, and swimming pool water quality will be tested. A compartmentalized water treatment plant with a capacity of 80 cubic meters per day is under installation and will be used to treat all municipal water. PLP is also installing a wastewater treatment plant, and all treated effluents are expected to be discharged into the public sewage network, and PLP will do so in line with applicable local pretreatment standards. As part of the ESMS development, a hotel-specific water and wastewater monitoring and management plan will be developed to monitor the quality including for risk of Legionella, optimize and reduce water usage and wastewater generation (cf. ESAP# 1).
Ambient Air and Noise Emissions. Ambient air and noise levels have been measured as part of the EIA. Dust and noise are expected during construction phase and management of these aspects are addressed through the project construction E&S management plans. The hotel designs include specific measures for noise cancellation, including isolation systems for rooms’ windows, generator rooms, etc., especially due to proximity to the airport. As part of the ESMS, the hotel will be required to implement adequate measures for indoor air quality (e.g. no-smoking policy) and noise monitoring plan in line with Hilton’s requirements and WBG General EHS guidelines.
Hazardous Materials and Waste Management. Construction waste is generally stored, pending collection by licensed contractors for disposal in municipal landfills. Used oil and grease from the kitchen operation will be collected via a grease interceptor to be collected by a third-party contractor. A Liquefied Petroleum Gas (LPG) storage is also planned to be installed at the rooftop of the hotel, with required fire safety detection and suppression systems which will be assessed by a suitably qualified expert prior to hotel commissioning (cf. ESAP #8). Hazardous materials are expected to include chemicals used for cleaning, hygiene and pool treatment. As part of its ESMS (cf. ESAP #1), PLP will develop and implement a comprehensive and hotel-specific solid waste management program which will focus on reduction of waste generated and will aim to segregate at source, reuse and recycle the generated waste with adequate storage and disposal practices. A hazardous waste management plan will also be developed and include adequate procedures for storing and handling hazardous materials, including procedures for regular inspections of gas and diesel tanks.
Pest Management. Pesticides will be applied in the hotel by a licensed third-party contractor monthly and as needed, and will be used in limited quantities. A hotel-specific procedure on pest control management will be included in the ESMS (cf. ESAP #1).
PS4: Community Health, Safety and Security
Life and Fire Safety (LFS). Life and fire safety systems are being designed as per Hilton requirements and in accordance with the US National Fire Protection Association (NFPA) standards amongst others. PLP has developed the hotel design and LFS Master Plan, including a set of LFS drawings and the design of life and fire safety systems, which demonstrate that the project observes the requirements of the Hilton Brands on LFS and the LFS section of the WBG General EHS Guidelines. The protection includes adequate means of egress with two independent and protected exit staircases, sprinkler system, fire detection and alarm, smoke control, fire compartmentation, emergency power and lighting, signage, as well as other LFS features. As part of the project completion test, a suitably qualified Life and Fire Safety professional acceptable to IFC will conduct a review at the time of the LFS systems testing and commissioning and will certify that the construction of these systems has been carried out in accordance with the relevant industry LFS design standards and codes, including the WBG General EHS Guidelines. As needed, a corrective Action Plan with a time frame for implementation will be submitted after the professional’s first review. Completion will not be certified until the professional has received confirmation of satisfactory completion of the Action Plan. Regular audit and maintenance interventions will be completed as per the hotel’s LFS master plan and local fire safety regulations (ESAP #7).
Food and Water Safety. For the operations phase, the hotel will develop a food and water safety management plan as part of the ESMS, with a clear procedure detailing roles and responsibilities, quality requirements, supplier management, receipt, handling and storage of food, supply of potable water and other food hygiene and water-quality standards as defined by regulatory authorities and consistent with the principles of good international industry practices of Hazard Analysis and Critical Control points (HACCP). Regular testing of potable water will be completed in accordance with World Health Organization (WHO) standards as a minimum (cf. ESAP #1).
Guest Safety. PLP will develop a grievance mechanism which will cover investigation of complaints of gender-based violence, sexual harassment, child abuse and other human rights concerns both from its employees and guests (cf. ESAP #5). Swimming pool safety management plan will be developed for the hotel, where measures such as water quality monitoring, availability of certified lifeguards, staff training on emergency response procedures, clear signage and rules, guest education and emergency evacuation and rescue plans will be implemented (cf. ESAP #1).
Security Personnel. A third-party company has been contracted for the provision of unarmed security services during construction phase. The arrangements will be similar for the operations phase. As part of the ESMS development (cf. ESAP #1), a hotel-specific security risk assessment and management plan will be developed and will be aligned with the requirements of IFC PS4 as well as the United Nations Voluntary Principles on Security and Human Rights.
