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 Policy:
Cinépolis manages its E&S aspects through a structured framework of policies and procedures anchored in its Global Code of Integrity, which aligns with the UN Global Compact and emphasizes ethical conduct, legal compliance, fair labor practices, non-discrimination, and environmental stewardship. The company is currently finalizing a Double Materiality Analysis that will inform the development of a global Sustainability and Environmental, Social, and Governance (ESG) Policy. As part of ESAP # 1, Cinépolis will develop a comprehensive Global E&S Policy in line with IFC PS.
Cinepolis’ E&S risks and impacts are assessed and managed in accordance with the relevant host country’s regulations, with corporate-level guidelines adapted from Mexico—its primary operating base—to suit each jurisdiction’s legal context while maintaining consistency with core values. The Board of Directors and senior management are provided with E&S performance updates including key metrics, audit results and improvement initiatives through the Sustainability Committee. Monitoring and review of E&S performance are conducted at the country level.
As outlined in ESAP #2, Cinépolis will enhance its existing framework and develop a corporate global E&S Management System (ESMS) by developing additional E&S corporate plans and procedures in alignment with IFC PS and the World Bank Group’s General EHS Guidelines (2007). This corporate framework will consequently be implemented at country level. To support the effective implementation of these new policies, procedures, and systems, as part of ESAP #3, Cinepolis will develop a country-level environmental and social management system (ESMS) time-bound roll-out plan. This plan will ensure that the corporate policies are adequately tailored and implemented into the relevant jurisdictions where Cinepolis operates. The objective is not only to establish corporate-level safeguards but also to align country-level systems and procedures with these standards.
Organizational Capacity and Competency:
Cinépolis has established a Sustainability Committee that oversees ESG matters. The committee includes senior management from relevant areas (CEO, CFO, HR Director, Social Communication Director, Environmental Deputy Director, Architecture Director, Legal VP and Sustainability Director). The Board of Directors retains oversight of governance, audit, and compliance. A Global Director of Compliance and Sustainability leads the company’s ESG strategy and is responsible for advancing ESG performance and safeguards. As per ESAP item #4, Cinépolis will appoint a qualified Global ESMS Coordinator responsible for the development, implementation and maintenance of the ESMS and related E&S programs, plans and procedures.
Emergency Response Planning:
In line with the respective national law requirements and corporate-level guidelines, Cinépolis prepares and implements an emergency response plan for each facility. Commonly, its emergency response plans include assessment of emergency scenarios, structural safety, emergency response procedures, evacuation plans, communication protocols, training, drills, and coordination with external agencies and the main facilities (e.g., shopping malls) where the movie theatre operates. In order to systematically manage emergency preparedness and response (EPR) at the corporate level, as per ESAP #5, Cinépolis will develop and implement a corporate EPR procedure in accordance with the requirements of IFC PS and WBG General EHS Guidelines (2007), focusing on customer safety, probable risk scenarios (including climate risks), addressing the methodologies to be used for evacuation, particularly for people with disabilities, elderly and children. The procedure will define the roles and responsibilities to manage EPR across the portfolio. Each existing operating facility will update their emergency plans as necessary to align with the corporate procedure.
PS2- Labor and working conditions
Cinépolis has approximately 33,000 direct employees, of which 43% are female. 91% of Cinepolis workforce has permanent contracts and 43.8% is unionized.
Human Resources (HR) Policies and Procedures:
HR policies and procedures vary by country and are aligned with the relevant host country regulations. Cinépolis has established a range of thematic global HR policies covering areas such as training, compensation, internal communication, and talent management. The company’s Global Code of Integrity serves as the overarching ethical framework for all employees, suppliers, contractors, and business partners worldwide. This code affirms Cinépolis’ commitment to fair and non-discriminatory labor practices, the rejection of child and forced labor, respect for freedom of association, and the promotion of diversity, inclusion, and OHS. It also establishes expectations for integrity, transparency, and compliance with both internal policies and applicable laws in every country of operation. The Code is mandatory for all personnel and is supported by a global internal grievance mechanism that protects whistleblowers and ensures that concerns can be raised confidentially and without fear of retaliation. In order to systematically manage HR at the corporate level, as per ESAP item #6, Cinépolis will develop and implement a corporate-level HR policy and related procedures aligned with IFC PS2.
Cinépolis has also established a global Diversity, Gender Equality, Inclusion, Non-Discrimination, and Non-Harassment Policy, which applies to all employees, contractors, and partners. As part of ESAP #7, Cinépolis will revise its Global Policy on Diversity and Inclusion to include child safeguarding, extend protections to clients, deliver updated training to staff and contractors, and ensure visible zero-tolerance messaging.
Freedom of association:
Cinépolis formally commits to respecting the right to freedom of association for all employees across its global operations. This commitment is explicitly stated in the company’s Global Code of Integrity, which applies to all Cinépolis personnel, suppliers, contractors, and business partners in every jurisdiction.
Workers’ Grievance Mechanism:
Cinépolis has implemented a global grievance mechanism aligned with PS2 requirements. It is accessible to employees, contractors, suppliers, and stakeholders via the Lética platform, managed with help of an independent compliance (for the investigation processes) firm. Governed by the Global Protocol Complaint Line, it supports anonymous reporting through web and app across all countries of operation. Beyond addressing non-compliance, it serves as a tool for risk management and fostering a safe, inclusive workplace. The system includes anti-retaliation safeguards and clear investigation procedures. Employees understand how to use it, and the Global Code of Integrity prohibits all forms of harassment. SEAH-related grievances are handled with enhanced confidentiality by a joint worker-management committee.
Occupational Health and Safety:
Cinépolis manages OHS in line with the national laws and standards of each jurisdiction in which it operates, with a strong focus on the construction phase. For this, the company requires the formation of safety and hygiene committees, regular inspections, risk assessments, and the implementation of contractor safety programs. Contractors must develop and submit safety plans, ensure the use of appropriate personal protective equipment (PPE), and provide safety inductions and ongoing training for their personnel. Incident reporting, accident investigation, and emergency preparedness are systematically addressed for construction work. To systematically manage OHS at the corporate level, as part of ESAP #1, the corporate ESMS will include an OHS policy and corporate procedures in accordance with the requirements of IFC PS, and WBG General EHS Guidelines (2007). This policy and related procedures will set minimum standards for hazard identification, risk assessment, training, incident reporting, and emergency preparedness for all operations globally.
Workers Engaged by Third Parties:
Cinépolis does not generally rely on third-party workers, preferring direct employment for its corporate, administrative, and operational staff. The engagement of third-party workers is primarily limited to contractors responsible for construction of new developments, remodeling, maintenance, and security services. Contracts with suppliers and service providers include clauses requiring compliance with applicable labor laws, explicit prohibition of child labor and forced labor, and the right for Cinépolis to request proof of compliance at any time. Non-compliance with these requirements constitutes grounds for contract termination. These measures are designed to ensure that all workers engaged through third parties are protected by the same standards of ethical employment and legal compliance as Cinépolis’ direct employees. To strengthen its corporate requirements applicable to construction contractors, as part of ESAP #2, Cinépolis will develop a supplementary procedure for contractors, to include: (i) the minimum environmental, OHS, labor, community health & safety, SEAH, grievance management, and social requirements in alignment with the IFC PS and the WBG General EHS Guidelines (2007); (ii) the controls to be implemented to verify compliance with the minimum requirements (e.g. inspections, audits, and periodic labor assessment); and (iii) actions to record and track the E&S performance, including KPIs.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency:
Cinépolis has implemented a suite of resource efficiency initiatives across its international portfolio of assets. Photovoltaic panels have been installed in multiple regions, and energy audits have informed targeted improvements in Heating, Ventilation, and Air Conditioning (HVAC), lighting, and kitchen equipment. These measures have resulted in significant reductions in energy consumption and operational costs. Other resource efficiency initiatives include real-time energy monitoring and behavioral change campaigns. Potable water is provided by local public supply, and wastewater is discharged directly to the local sewage system. The IFC financing package will contribute to the implementation of these initiatives, supporting Cinépolis in achieving its resource efficiency targets and strengthening its environmental performance across operations.
Greenhouse Gases (GHG) emissions:
Cinépolis monitors and reports greenhouse gas (GHG) emissions across its operations, with practices determined primarily by local regulatory requirements and internal protocols. The company’s most robust and standardized methodology is applied in Mexico, where a dedicated GHG emissions calculation handbook, developed in accordance with national regulations, is used to measure, validate, and report Scope 1 and Scope 2 emissions from fuel combustion, electricity consumption, and refrigerants. For international operations, Cinépolis collects and reports GHG data as required by host country´s regulations and internal procedures. As part of the ESAP # 9, Cinépolis will build on its existing procedures and develop and implement a corporate GHG emissions handbook, aligned with IFC PS 3 and the WBG General EHS Guidelines (2007). In addition, Cinépolis will prepare and submit a comprehensive emissions report to IFC.
Waste Management:
Cinépolis manages waste (e.g. plastics, paper, food, oil, refrigerants) in compliance with applicable local and national regulations and is in the process of standardizing waste management practices across all countries of operation. Cinépolis implements recycling and circular economy initiatives in some cinemas, including pilot programs for waste segregation and partnerships with responsible suppliers. The company has completed the replacement of single-use plastics in Mexico City and is expanding this initiative nationally, with further rollout planned for other regions. Packaging redesign for sustainability and the deployment of waste segregation stations for recyclables, organics, and general waste are ongoing efforts to improve sorting and disposal practices. Hazardous waste relevant to Cinépolis’ operations includes refrigerants, oils, and gases used in HVAC and refrigeration systems. Waste disposal is carried out by licensed third-party contractors, and practices are aligned with local environmental regulations. Per ESAP # 2, to systematically manage waste-related aspects across its operations Cinépolis will develop a Corporate Waste Management Procedure in line with IFC PS 3 and the WBG General EHS Guidelines (2007).
PS4-Community Health, Safety and Security
Community Health and Safety:
For new developments and remodeling works, as part of the E&S Assessment and Management Procedure to be developed per ESAP #1, the Company will include minimum community health and safety requirements for construction contractors, consistent with the IFC PS and WBG General EHS Guidelines.
Cinépolis operates industrial kitchens to support its dine-in cinema services. The company follows and complies with applicable local food safety legislation in each jurisdiction where it operates. As part of ESAP item #2, Cinépolis will develop a global Food Safety Management Procedure to ensure consistent standards and practices across its international portfolio of assets, aligned with the requirements of the IFC Performance Standards and the World Bank Group’s General EHS Guidelines (2007).
Life and Fire Safety:
L&FS infrastructure at Cinépolis cinemas is designed and its is compliant with the fire safety regulations of each country in which the company operates. Key safety features include portable fire extinguishers, fire detection and alarm systems, sprinkler systems (where required), fire hydrants, fire hose reels, water storage tanks equipped with fire pumps, and smoke control systems, all installed according to site-specific needs. When developing new movie theaters, Cinépolis ensures that its L&FS systems are coordinated with those of the primary occupancy—such as shopping malls—to facilitate seamless operations and comprehensive emergency planning. Cinépolis works with qualified third-party Life and Fire Safety (L&FS) professionals to ensure that its facilities are designed, constructed, and operated in full compliance with national building and fire safety codes. This corporate approach will be further strengthened by adopting the upcoming corporate L&FS Design Manual, which will establish standardized requirements and best practices for both existing and future developments.
As per ESAP item #8, the Company will commission a qualified L&FS professional to develop a corporate L&FS Design Manual (Master Plan), including accessibility requirements. The Design Manual will include the minimum requirements for all existing cinemas and upcoming developments. For operations and maintenance activities across the portfolio, the Design Manual will include the minimum inspection, testing, and maintenance requirements of LFS systems, accessibility and change management requirements.
For the current operations in different countries, conditions and considering future growth, the company will develop under the corporate ESMS, a corporate procedure to manage the current L&FS conditions established for the protection of the users and clients, including emergency preparation (refer to ESAP item #1, in PS1 section).
Security:
Cinépolis employs unarmed security personnel to ensure safe, customer-friendly environments. Staff are trained in the Global Code of Integrity during onboarding and through regular refreshers. Their role is preventive and supportive focused on access control, crowd management, customer assistance, and emergency response. They coordinate closely with shopping center emergency services to ensure effective incident handling.
