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 Policy and Management Systems
IFC has previously appraised ALI and MDC’s E&S management systems and policies as part of the SLL1 investment and made specific requirements as outlined within the ESAP for that investment. ALI is currently developing a PS compliant Environment and Social Management System (ESMS) and updating the existing Emergency Preparedness and Response Plan (EPRP) and Community Health and Safety Plan (CHSP) for the SLL1 Project. The ESMS, updated EPRP and CHSP will be applied by MDC and AMG for the construction and operation of the Greenbelt and EvoCity malls.
Identification of E&S Risks and Impacts and Management Programs
The mall construction is currently being undertaken of both sites by MDC and will be operated by AMG once completed. The Project was subject to local regulatory requirements, including Environmental Compliance Certificates (ECC) issued by the Philippine Department of Environment and Natural Resources in 2024. The ECCs have provisions consistent with IFC PS1 in connection with the management of construction-related environmental and social (E&S) risks. An E&S impact assessment is not required for the mall construction under local regulations in the Philippines. To manage site specific E&S risks, site-specific construction E&S management plans (ESMPs) have been prepared by MDC for the two construction sites respectively, which will be checked for adequacy by IFC [ESAP #1]. The Plans will manage specific risks identified and associated with each construction sites.
The climate data for the Project indicates high risks from cyclones, medium risks from tropical storms, urban floods, and extreme heat for the period from 2020 to 2049. Cyclones may cause severe damage and disruptions. Managing risks associated with extreme heat for the workforce and storms impacting the project will be required and included in relevant HR, OHS and construction ESMPs. ALI Group are currently preparing an ESMS that addresses these risks as part of the SLL1 investment.
Organizational E&S Capacity:
ALI coordinates E&S management at a corporate level, including focusing on the implementation of corporate sustainability policies that also include MDC’s and AMG’s operations. The Project will be monitored by ALI’s corporate sustainability team that has dedicated staff to implement and monitor E&S policies. MDC supervises all construction activities undertaken by contractors. Each contractor has its own E&S team that monitors construction activities. For operation of the two malls, AMG’s property management team has dedicated Pollution Control Officers assigned. The property management team will be responsible for engaging tenants and service providers, property and utility management, health, safety, and security.
Emergency Preparedness and Response:
ALI has a dedicated plan that identifies corporate risks, including E&S risks and emergency responses that is being updated and incorporated into the ESMS under the SLL1 investment. This plan applies to AMG and MDC and is implemented through both the corporate E&S team and property management teams. The focus includes social and security risks, natural disasters (earthquakes, volcanic eruptions, and hurricanes) and health and safety risks. MDC has emergency preparedness and response plans in place for construction work applied to its employees, subcontractors, and visitors. AMG has its own dedicated Emergency Response Plan/Evacuation Plan that is being applied to each construction site.
Monitoring and Review:
ALI, AMG, and MDC have stated that they conduct internal audits, which cover E&S aspects, on a regular basis, by both corporate, building construction and management teams. The ALI corporate team collects performance data and key performance indicators (such as energy and resource consumption, waste generating and waste recycling rate, greenhouse gases emissions, health and safety data etc.), aggregating them in dedicated platforms and in internal/external reports. Reporting performance occurs to ALI and the Board of Directors.
PS2: Labor and Working Conditions
MDC will oversee the construction phase of the two (2) new malls with a team of 30-50 staff deployed to the construction sites. During construction, EvoCity is expected to have a peak workforce of 1,800 workers in quarter 4 of 2025. The Greenbelt Mall construction site is expected to have a peak workforce of 4,000 workers in the first quarter of 2026. AMG will manage operations once the malls are completed with a team of 20 for each mall. AMG contracts third party service providers for housekeeping, security, and maintenance, during operations which consist of 400 to 500 staff per mall. Contractors perform most activities during both phases, under the supervision of MDC and AMG.
HR policies and procedures
ALI group’s HR procedures address terms of employment, working hours, training, leave, employee welfare, wages and benefits, minimum age, training, the principle of equal opportunity, fair treatment, and non-discrimination as per the Philippines Labor Code. HR policies and procedures are being upgraded to align with IFC PS 2 requirements as part of the SLL1 project in areas such as retrenchment, freedom of association, Gender-Based Violence and harassment (GBVH), grievance mechanisms, and worker accommodation standards.
Grievance mechanism
ALI has a company-wide whistle-blowing policy and a workers grievance mechanism that consists of online exchanges and face-to-face meetings for raising concerns. Grievance including anonymous grievances once received, will be recorded, and assessed by a team of 5 panellists for resolution. ALI also supports workers filing disputes with the Philippine Department of Labor and Employment directly. These requirements are extended to MDC and their contractors. ALI is preparing a grievance redress mechanisms for workers, for both construction and operation in accordance with IFC PS requirements.
Workers union
No unions represent employees at AMG or MDC and its subsidiaries. The HR Manual does not restrict any form of association or collective bargaining throughout the company.
Protection of workforce
ALI has a HR policy that is applicable to AMG and MDC and prohibits the employment and engagement of forced labor and child labor, including by third-party suppliers. The MDC team plans and schedules periodic workforce needs. All workers have formal employment contracts that prevent the use of child and forced labor in construction and operations. No risks of child or forced labor were identified during appraisal.
Occupational Health and Safety
MDC has dedicated OHS requirements in contracts for contractors who undertake the mall construction. These measures include requirements for job hazard assessment, permit to work and risk assessments, daily inspections, the use of PPE, as well as managing occupational noise and dust risks. These requirements were discussed during the site appraisal, and it was noted that both mall construction sites comply with IFC requirements based on these observations. Additionally, the site-specific construction ESMPs will include OHS Management Plans [ESAP #1]. During operation, the property management teams of the malls will have responsibility for OHS matters, including vendors’ contractor management such as pest control, cleaning services, security, and gardening. Both MDC’s and AMG’s property management teams, are responsible for providing staff training for their employees, sub-contractors, and third-party suppliers. MDC are responsible for monitoring all contractors and contracted labor’s compliance with relevant OHS policies and procedures. There have been no significant or reportable events identified during the construction of the two malls.
Third-Party Employees
Workers from labor contractors perform most activities during both phases, under the supervision of MDC and AMG. ALI has a procurement policy in place with provisions that restrict the engagement of labor contractors. MDC and AMG maintain pre-qualified databases for construction contractors and labor agents. Adherence to labor code requirements is mandatory for all contractors, with HR oversight managed by mall management. Contractors are currently managed through the procurement policy with AMG’s and MDC’s requirements stipulated in contracts. AMG and MDC have controls in place to check contracted labor to ensure compliance with their policies and procedures.
Worker’s accommodation
MDC and construction contractors provide temporary accommodation to workers, but they are not obligated to do so. ALI is developing a Workers Accommodation standard to ensure that any accommodations provided to workers comply with the requirements of PS2 and the “Workers’ accommodation: processes and standards - A guidance note by IFC and the EBRD” as part of the SLL1 Project.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
ALI has policies on reducing energy, water, and materials like steel and cement used in construction. For the malls, the Project will install high efficiency lighting, heat recover ventilation and high efficiency air conditioning systems. The Project will also separate all recyclable materials for reuse, including concrete.
Water and Wastewater
The two malls will discharge storm water during construction to the stormwater drainage system. This includes water that accumulates in the construction site during major storm events. Water will be supplied from the local municipal supply. All wastewater during operation will be discharged to the sewerage system and will be subject to testing and permits issued by local regulatory authorities.
Solid waste and hazardous material management
During the construction, MDC and their contractors will separate and manage all building and construction waste generated. All non-recyclable waste will be tracked and disposed at regulated landfills. Hazardous waste will be managed by accredited waste management companies. All hazardous materials will be stored onsite using appropriate cabinets with emergency equipment available to manage any spills. The site-specific construction Environment and Social Management Plans (ESMP) will specify management plans for wastes and hazardous materials [ESAP #1]. Waste generated during the operation will be separated at source and managed through licensed contractors.
Air emissions
Air emissions during construction will be primarily from excavators and trucks operating at the construction sites. These vehicles are subject to local regulatory requirements and testing by local authorities.
Noise
Noise impacts are likely to occur during construction and may impact residents. Hours of operation are from 6am to 9pm Monday to Saturday with the potential for operations at the EvoCity Mall that may include Sundays. Residents are in close vicinity to the Greenbelt construction site. A grievance mechanism is currently in place to respond to noise complaints from the site that has been socialised with the community. There were two noise complaints at this site that have been satisfactorily resolved. No grievances related to noise have been received by the EvoCity site related to the fact that there are no current residents within the housing estate.
GHG Emissions
The estimated GHG emissions for the Project are expected to be Scope 1: 1,264 tCO2e/year; Scope 2: 12,091 tCO2e/year, leading to a total of total: 13,354 tCO2e/year. These results have been simulated based on existing AMG mall assets for the two mall’s operational emissions.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design, Life and Fire Safety
The two malls have been designed and are being constructed in compliance with local building codes, local fire department regulations and local legal/insurance requirements. Site access is currently managed through fencing adjacent to the construction site; however, there are no other access restrictions along adjacent roads or other areas during construction. The design of Life and Fire Safety (LFS) Management Systems are consistent with Philippine standards which are based on the United States National Fire Protection Agency requirements. The systems will include the provision of sprinklers, fire hydrants, alarms, mobile fire extinguishers, emergency exits and emergency lighting. An internal LFS compliance assessment has been prepared by MDC. To comply with IFC requirements, the building design will be subject to an independent assessment against World Bank Group EHS Guidelines requirements related to life and fire safety [ESAP #2] and are assessed for compliance once commissioned [ESAP #3]. The buildings are compliant with local regulations related to earthquakes, typhoons, and other natural disasters which are prevalent in the Philippines. The design of the new malls incorporates universal access principles providing accessibility and egress for Persons with Disabilities (PWD).
Traffic Impacts and Transportation Safety
Construction traffic will consist of an average 58 truck movements per day for the Greenbelt 1 site and 20 movements for EvoCity between the hours of 10am and 7pm six days per week which has been required by the ECC to reduce impacts on traffic. Excavators and other construction vehicles will be used on site. Other smaller vehicles for workers including motorbikes and cars are used and parked on site or nearby. Entrance to the sites is controlled by gates and security to limit impacts to pedestrians and other vehicles.
Community Health and Safety
ALI is currently preparing a Community Health and Safety Plan (CHSP) as part of the ESAP for the SLL1 Project. The CHSP will include policies and procedures for the construction and operation including evacuation plan and exit layout of the malls, and access for people with disabilities during construction and operation to satisfy the requirements of IFC PS. For this project, a site-specific Stakeholder Engagement Plan will be prepared for each of the two malls being constructed [ESAP #4].
Security Personnel:
ALI hires armed security personnel through licensed security service providers. These providers have been trained to comply with Philippine law. ALI has security procedures and manuals in place and provides mandatory training for all personnel and conducts safety inspections of critical and hazardous activities before commencing work at operating properties and construction sites. ALI are currently updating existing policies to include how the use of firearms respects human rights including how security personnel do not infringe on the rights of shoppers, vendors, and other stakeholders.
