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 Policy and Management Systems. Safari has no overarching E&S Policy, procedures, plans or risk management systems at group level. At subsidiary level, Pollman’s and Ranger Safari have policies focused on human resource management, fleet management, driver guides conduct in conservation areas, road safety management and customer feedback. The subsidiaries also have basic operational procedures and management systems developed and improved organically in management of material operational risks, or in response to health & safety incidents. The procedures mainly focus on worker health and safety, road safety, human resource management, driver guide training on conservation and defensive driving, vehicle preventive and repair maintenance and emergency response.
Safari will develop an overarching group environmental social and governance (ESG) policy and will develop and implement ESG Management System (ESGMS) to cover management of E&S risks related to all its operations. The ESG Policy and ESGMS will cover PS requirements for its operations covering labour rights and labour management systems, pollution prevention and management for its fueling facilities, vehicle refurbishment and repair workshops, occupational health and safety requirements for its facilities, road safety, emergency preparedness and response, contractor and supplier management (including outsourced vehicles & drivers and bulk fuel suppliers), sustainable tourism and conservation strategies and programs commensurate to its operations in the destination countries, stakeholder engagement, external communication protocols and community grievance redress mechanisms.
The ESGMS will enable cascading of risk management roles, responsibilities, plans and procedures to subsidiary level and requisite reporting on E&S performance to group level. The group will also ensure that its subsidiaries develop and maintain environment health and safety (EHS) permits and license registers for all their premises and operations (ESAP #1).
Identification of Risks and Impacts. The group operates from seven leased premises, three of which have office blocks and workshops which house diesel storage, fueling stations, auto body shops for refurbishing safari trucks and facilities for fleet repair and maintenance. While Pollman’s and Rangers Safari operate on leased premises, they are responsible for meeting local EHS permitting and licensing requirements for improvements specifically on installation and operational maintenance of fuel storage and filling stations, diesel generators and the workshops. Pollman’s and Ranger Safari also undertake basic maintenance and repairs on office premises. During the appraisal visit, Pollman’s was planning for the regulatory annual OHS audit for its Mombasa and Nairobi premises.
The group also has small offices located at the international airports in Nairobi, Mombasa, Diani and Kilimanjaro that are mainly used to receive tourists prior to transfer to hotels or safari tours. Pollman’s and Ranger Safari employees at these facilities rely on facilities provided and maintained by the respective airport authorities.
As part of ESAP #1, the group will undertake PS compliant supplementary EHS and fire safety audits/risk assessments for the seven premises in Tanzania and Kenya. The findings of the audits will inform the development of the ESG Policy and ESGMS.
Biodiversity Protection. Safari Group will establish a system to monitor and report on driver guides adherence to national park regulations, such as prohibiting off-road driving and maintaining safe distances from wildlife. Both Pollman’s and Ranger Safari already promote conservation-friendly practices like using glass water bottles and enforcing a “no waste left behind” policy, which will be consistently applied across all tours. Safari will also establish a program for monitoring and evaluation of the implementation and effectiveness of Driver Guide Codes of Conduct while on Safari and utilize these findings to inform driver guide training, capacity building and corrective actions on wildlife protection and responsible tourism practices.
Organizational Capacity and Competency. The group has not established its E&S risk and impact management organizational structure. EHS management responsibilities are delegated to other line managers, but this approach is not uniform throughout the group. Pollman’s has a dedicated HR manager while ARP and Ranger Safari have delegated labour management responsibilities to other functional roles.
Safari will designate an ESG Director at group level. The ESG Director will be supported by managers at company level to manage EHS and HR risks. Pollman’s and Safari managers responsible for EHS management will incorporate conservation and sustainability responsibilities, while Ranger Safari will engage a qualified HR Officer to support the Managing Director’s current responsibilities in HR management (ESAP #2).
Emergency Preparedness and Response: Safari has a standard emergency crisis management manual that is used across its companies. Pollman’s and Ranger Safaris provide supplementary materials specifically related to customer-facing operations, with a particular focus on safari activities. Though not harmonized, the various subsidiaries have documented policies and procedures on medical emergencies, violent/disruptive protests, bomb threats, hazardous materials spills, fires, earthquakes, floods and severe weather. Safari will strengthen the implementation of its emergency crisis management manual by requiring and developing site specific emergency preparedness and response plans (EPRPs) to cover all foreseeable risk scenarios, response to wildlife encounters, training programs for staff appointed as first responders, annual drills and awareness programs for all staff. Safari will also establish mechanisms to inform emergency service providers, applicable stakeholders and affected communities / customers during emergencies, and align these mechanisms with the group’s external communication procedures (ESAP #3).
EHS Training. Pollman’s and Rangers Safari undertake basic annual training for driver guides and operational staff on EHS management covering road safety and defensive driving, use of fire-fighting equipment, first aid and reporting requirements in the event of road accidents. Pollman’s also partners with wildlife management agencies and tertiary institutions to upskill drivers on ecotourism, customer management and upskilling of drivers on vehicle guiding techniques. Safari will develop a corporate EHS training plan covering staff induction, periodic and refresher training. The training program should enhance staff awareness and equip office and workshop employees with the necessary skills and knowledge relevant to their specific roles and responsibilities in managing key risks identified under ESAP #1.
EHS Management Programs. Safari will establish management programs to provide E&S risk mitigation as informed by the supplementary EHS and fire safety audits/risk assessments under ESAP #1. Key performance indicators will be developed for each key risk/issue. Performance improvement actions and measures will be integrated into the management programs to enhance E&S management outcomes. Key risks/issues to be captured by the management programs will include management of risks/issues identified under ESAP #1.
E&S Monitoring and Review. Safari will implement monitoring and review procedures under ESAP #1 to assess ESGMS, with regular reporting to group senior management and the board. Management and the board will ensure ESGMS objectives are achieved, and corrective actions are effectively carried out. The ESG Director will oversee the implementation of corrective measures and policy/procedure updates, with clear reporting lines from subsidiaries. Each subsidiary will maintain records for ESMS elements monitored by government or third parties.
PS 2 – Labor and Working Conditions
Safari employs approximately 490 people across its subsidiary companies, with 65% working at Pollman’s in Kenya, 30% at Rangers Safari in Tanzania, and 6% at ARP in the United Kingdom (UK). Contracted staff provide security and cleaning services at the company premises and Pollman’s can hire third-party vehicles with drivers when the need arises.
Human Resource Policy and Procedures and Working Terms. Safari does not have overarching HR Policies. The subsidiaries however have HR policies and procedures structured to the local employment law requirements, with some gaps on PS 2 commitments or requirements on non-discrimination and equal opportunity including specific measures on bullying and harassment, child labour, forced labour, freedom of association and collective bargaining, retrenchment and oversight on third-party workers.
Workers are engaged on term contracts, permanent contracts and on casual (trip based) work-orders for driver guides during off-peak seasons. Sometimes the subsidiaries engage casual workers on daily basis to assist in vehicle modification works at the workshops. The HR management systems across the subsidiaries are not standardized and exhibit varying levels of maturity in aligning with HR policies particularly on working hours, overtime tracking and compensation, rest periods, and leave entitlements. In several cases, these aspects are recorded manually, which limits the ability of management to systematically verify compliance.
Safari will develop a corporate level HR Policy and Procedures Manual and cascade these requirements to all subsidiaries. The subsidiaries will in-turn update their HR Policies and Procedures Manuals or HR Handbooks and establish HR management systems to meet the group standard (ESAP #4).
Safari and its subsidiaries do not have documented policies on child and forced labor. The subsidiaries also lack mechanisms in place to safeguard its HR processes from situations that could be indicative of forced labor. Nonetheless, the subsidiaries only engage adults in their workforce and enforce this by requiring applicants to submit national identity cards and other evidence as proof that they are above 18 years.
Workers Organization. Union affiliation at Safari is currently at DMC level with Pollman’s is currently affiliated with two trade unions: the Transport Workers Union in Kenya (TAWU), which is the older of the two, and the Kenya Game Hunting & Safaris Workers Union (KGHSWU). Available records show that some staff belong to both or one union only. Rangers Safari has 5 unionized staff, affiliated to the Conservation, Hotels, Domestic and Workers Union. TAWU filed a case with the Kenyan labor court, over the legality of the current CBA as negotiated with KGCTSW. This court case is still open and pertains to the right of Pollman’s staff to join a union of their choice and an objection to the legality of the resultant CBA. Safari is committed to accepting the outcome of the legal process and IFC will continue to monitor progress and ensure compliance with the outcomes of the judicial process.
Worker’s Grievance Redress Mechanism (GRM). Safari and its DMCs do not have documented and structured grievance redress mechanisms and lack specific mechanisms for handling GBV/SH related complaints. However, staff reported that they are able to submit complaints to their line managers or directly to HR, and can escalate grievances to senior management. The union representative at Pollman’s also confirmed that shop stewards are involved in GRMs and worker disciplinary cases. Key worker grievances as reported by staff were mostly on PPE, sanitation facilities, sensitisation on company processes and inadequate worker engagement. Safari will develop a PS compliant workers GRM that will include anonymous reporting systems with practical mechanisms to ensure protection from retaliation and reprisals (ESAP #5a). Safari will also extend its grievance mechanism to third party and contract/casual workers per PS 2 requirements.
Safari will undertake a risk assessment on sexual harassment, gender based violence and sexual exploitation and abuse (SH/GBV/SEA) in its operations and develop sexual harassment policy to cover: (i) a comprehensive definition of SH/GBV/SEA in the workplace; (ii) prevention of SH/GBV/SEA in the workplace with applicable extensions to the group contractors, customers and suppliers (iii) extension of this policy and related mechanisms to cover complaints involving project affected communities and Safari’s contracted workforce; (iv) engagement of an active focal point for receipt of SH/GBV/SEA related complaints at subsidiary level; (v) commitments to training of staff with responsibilities in receiving and handling complaints related to SH/GBV/SEA to specifically cover survivor-centric mechanisms, referral pathways, data protection policies and non-retaliation protections (ESAP #5b).
Safari Group will incorporate its policies on harassment and GBV as part of its Code of Conduct, clearly prohibiting all forms of harassment, abuse, and exploitation based on gender for both staff and other stakeholders, including its customers. This will include sexual harassment, physical or psychological abuse, and any coercive behavior in the workplace or during work-related activities such as safaris and transfers. The Code will document clear reporting and response mechanisms, including anonymous grievance channels, survivor support measures, and disciplinary actions for violations. Regular training on GBV awareness and prevention will be mandatory for all staff, with additional guidance for managers on handling SH/GBV/SEA cases. Safari will also track the signing of codes of conduct by all its staff (ESAP #5c).
Retrenchment. Among the Safari subsidiaries, only Pollman’s reported having undertaken a retrenchment exercise. The retrenchment was driven by COVID-19 impacts in the tourism industry whereby 36 (or 12%) of the staff were retrenched and the rest of the staff were retained on reduced salaries. The company reported that the retrenchment was undertaken in accordance with local retrenchment laws which require issuance of notices to the local labor office, engagement of staff and union representatives during the retrenchment process and payment of terminal dues. The company also reported that the decision to reduce salaries for remaining staff was a negotiated approach to maintaining jobs in lieu of retrenchment but the salaries and arrears have since been cleared. There are no pending legal cases or liabilities on retrenchment and reduced work.
Safari does not intend to undertake any retrenchment under this project. As part of ESAP #4, Safari will update the HR manual to document its commitments under local law and PS 2 requirements on retrenchment. Safari will also cascade the P2 requirements on retrenchment to its subsidiaries, including the requirements for development of retrenchment plans and maintenance of related records.
Occupational Health and Safety. Safari will build on the existing OHS policies and procedures at subsidiary level to develop and implement a formal Occupational Health and Safety (OHS) program as part of the HR procedures and programs (ESAP#6). Procedures and documentation under the OHS program will cover, mechanisms for identification of OHS risks from a gender lens where applicable and provisions for the development of site-specific risk registers; incident reporting and investigation; control of work and permits to work at the offices and workshops; emergency prevention; preparedness and response; staff training; identification and monitoring of OHS-related diseases, gender considerations in risk assessment and monitoring requirements; performance measurement and monitoring with inclusion of KPIs with leading and lagging indicators; mechanisms for preventive and corrective action; organizational roles and responsibilities for OHS management; and internal and external reporting mechanisms.
The safety measures will include practices to facilitate safe handling of hazardous materials and emissions (e.g. sprays used at the workshops) and medical examination of employees. Safari will also expand the scope of the OHS training to capture hazard identification, preventive and protective measures, emergency preparedness, and safe work practices for particular risks facing office, airport and tour guide staff.
Safari OHS program will be developed to support and improve the accident investigation procedure at subsidiary level, by incorporating an appropriate root cause analysis methodology and adequately training the EHS Committee to apply these methodologies. Safari will monitor and report on OHS performance and will support the formation of OHS Committees at subsidiary level, consistent with the requirements of the host country legislation. The committees will conduct meetings and facility inspections as part of its task to identify potential risks, address worker’s concerns regarding OHS and ensure proper implementation of the OHS program.
Road Safety. While Safari does not have corporate levels road safety policies, both Pollman’s and Rangers have policies for roadworthiness and driver qualifications. Both Pollman’s and Ranger enforce zero-tolerance substance abuse policies, conduct background checks, and require written and driving tests. Ranger also offers in-house road safety training. Both subsidiaries follow a "one driver, one vehicle" policy to ensure accountability. Pollman’s and Rangers also have journey management procedures and route plans for the longest circuits, to ensure that no driver is continuously on the road for more than 4 consecutive hours. Safari drivers must perform pre- and post-trip vehicle checks and report issues. Pollman’s uses an automated system with alerts sent to multiple managers, while Ranger review logs manually and relies on driver-submitted trip data to spot speeding or other concerns. Safari plans to review and align road safety procedures including the automation of Ranger’s tracking system for better real-time monitoring and alerts. requires all drivers to complete Toyota’s specialized vehicle training and annual defensive driving refreshers. Safari will integrate PS compliant road safety requirements into the OHS program developed under ESAP #6.
Third-party Workers and Supply Chain. Safari’s subsidiaries engage contractors to provide security personnel, waste collection and maintenance / repair services on the offices and related facilities. The main suppliers critical to business operations are diesel suppliers for the onsite fueling stations and suppliers of leased safari vehicles used during peak season.
Safari has not established contractor and supplier management policies and procedures but Pollman’s and Rangers Safari apply basic contractor/supplier screening, due diligence and performance management procedures that focus mostly on commercial interests. To meet PS requirements, Safari will establish contractor and supplier management procedures (including outsourced vehicles & drivers and bulk fuel suppliers) as indicated under ESAP # 1. Pollman and Ranger Safari will also incorporate the additional OHS requirements for fuel providers’ workers as outlined in ESAP #7b. Lastly, Safari will ensure that its workers’ grievance mechanisms established under ESAP #5a, 5b and 5c are extended to its third-party and supplier workers.
Resource and Energy Use. Both Pollman’s and Ranger Safari rely on municipal water supplies for their operational needs, which are considered minor. Ranger Safari has taken additional steps to enhance water sustainability by implementing rainwater harvesting and a basic wastewater recycling system. This proactive approach helps supplement its municipal water intake and demonstrates a commitment to resource efficiency. Pollman’s, in particular, has reported experiencing occasional water shortages in its areas of operation. Safari subsidiaries rely on electricity from the national grid, but they also maintain diesel generators for backup power during outages.
As part of ESAP # 1, Safari will establish a procedure for auditing the group’s energy savings, water re-use practices, analyze annual electricity and water usage records and report on performance.
Waste Management. Safari has no waste management plans in place and its subsidiaries have basic waste management practices. Wastewater is handled through on-site septic tanks and the systems for segregating wastes contaminated with hazardous materials (albeit in small quantities), do not meet PS or WBG EHS Guideline requirements. As part of ESAP # 1, Safari will establish a solid and wastewater management plan and procedure aligned with the PS and WBG EHS Guideline requirements. these plans/procedures will be cascaded to all facilities and premises. Safari will also ensure that all waste is collected and disposed off by qualified and licensed waste collectors.
Green House Gas Emissions. The primary source of GHGs stems from the extensive vehicle fleets operated by Pollman’s and Ranger Safaris, which include safari vehicles, transfer vans, and administrative cars. During peak tourism seasons, Ranger alone estimates diesel usage at approximately 3,000 litres per day. Based on this, the report estimates that Ranger’s fleet consumes around 1,095,000 litres of diesel annually, resulting in approximately 3,204 metric tons of CO2 equivalent emissions. Pollman’s, with a slightly larger fleet, is estimated to consume about 1,349,651 litres annually, contributing roughly 3,949 metric tons of CO2 equivalent emissions. The emissions from the project are not expected to exceed the PS 3 thresholds 25,000 metric tons of CO2 equivalent GHG emissions.
Management of Hazardous Materials. The key hazardous materials stored and used by Safari include diesel, vehicle oils and grease. Pollman’s maintains an underground diesel fuel tank with a capacity of 30,000 liters at its workshop in Mombasa while Ranger Safari operates two underground fuel tanks, each with a capacity of 13,000 liters at the workshop in Arusha. The companies engage pre-qualified fuel distributers based on commercial criteria and do not have agreed standard operating procedures for loading of fuel in their premises.
The companies also handle smaller volumes of paints and thinners for spray painting of vehicles during refurbishment, as well as hydraulic and lubricating oils and grease for vehicle maintenance and repairs.
Safari will develop and implement a hazardous materials management procedure that includes minimum requirements for storage, transportation, use and disposal of hazardous materials in line with local regulatory requirements and WBG EHS Guidelines (ESAP #7a).
To align with the World Bank Group’s Environmental, Health, and Safety (EHS) Guidelines, Pollman’s and Ranger Safaris will also implement a comprehensive fuel loading and handling plan for its premises aligned with WBG EHS Guidelines. This will include the development and enforcement of procedures for safe loading and unloading of diesel, spill prevention, and fire safety. All personnel involved in fuel management will undergo mandatory training on these procedures with annual refresher training. Secondary containment systems such as bund walls or spill trays will be installed around fuel storage and dispensing areas to contain spills and minimize pollution impacts. Both companies will enhance safety by providing appropriate PPE and installing clear signage at fueling stations. Additionally, quarterly audits will be conducted to monitor compliance with fuel handling protocols and to document corrective actions. This action plan supports safer operations, regulatory compliance, and environmental stewardship across Safari’s operations. The group will also enhance the facilities at the workshops by improving drainage, oil/water interception and containment of spills to meet minimum local regulatory requirements and WBG EHS Guidelines; and prepare and implement standard operating procedures for activities at the filling stations (ESAP #7b).
Safari tours focus on national parks and game reserves in Kenya and Tanzania with additional activities and excursions such beach hotel stays, mountain climbing, city tours, balloon rides and cultural visits to local villages and heritage sites. Pollman’s and Ranger Safaris partner with hotels, airlines and private conservancies to deliver on the packages sold by ARP. The main community health and safety risks are related to road safety in the use of company vehicles, customer safety and security during guided tours in national parks and game reserves and community/visitor interactions with Safari-CI Tour Drivers.
Road Safety. Pollman’s and Rangers Safaris as the DMCs within the groups have procedures in place for managing and responding to road and customer safety related emergencies. The customer care desks at the DMC’s also provide a platform for customer / community complaints on driver behavior. The company actions under ESAP #6 on reporting and investigation of incidents and near misses, will be extended to the company vehicles and drivers.
Security Personnel. Pollman’s and Ranger employ unarmed third-party security guards at their main sites. Both companies plan to update their Security Management Plan with increased oversight of third-party guards. As part of ESAP #1, Safari will develop a security management policy and cascade the key operational procedures to Pollman’s and Ranger Safari: (i) development of site specific security management plans (SMPs); (ii) assessment of security service providers serving the group’s facilities; (iii) requirements for training of security personnel on observance of human rights and appropriate use of force; (iv) alignment of the staff and community GRMs to capture complaints related to the contracted security personnel; (v) performance review of service providers as part of the procedures under the Contractor/Supplier Management Plan.
