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 Impact
E&S Policies and Management Programs. SafariCo has established and implemented an ESMS, largely aligned with the requirements of IFC PS1, and underpinned by an ESMS policy statement reiterating the group’s commitment to conducting all operations in a manner that minimize E&S risks and impacts. Further corporate policies include those related to water, energy, waste management, occupational health and safety (OHS), and fire safety. The ESMS has been developed at the corporate level and is adopted and refined for each operation dependent on the context and nature of risks and impacts.
SafariCo has developed and implemented several E&S management plans and standard operating procedures based on the nature of operational risks and impacts. These include management plans relating to waste, water and energy. In addition, an ESMP specific to NXR, together with N20 extension, was developed as a component of the 2025 EIA. Further, the group, through its sustainability arm, the Land and Life Foundation (https://landandlife.foundation/), has also developed and implemented an overarching Sustainability Management Plan, defining three core program areas, namely environmental management and conservation, community development, and social enterprise support.
Identification of Risks and Impacts. SXR and NXR (together with N20 extension) are located with the Serengeti National Park and Ngorongoro Conservation Area (NCA) respectively, hence, E&S risks and impacts are identified and managed as per the requirements of both TANAPA and NCAA, in particular their respective Tourism Investment Manuals (TIM) and the related General Management Plans (GMP).
The TIMs detail the mandatory procedures for site selection, environmental protection, infrastructure standards etc. and the requirement for the completion of an Environmental Impact Assessment (EIA). Mandatory requirements include assessment of physical, ecological, land use, cultural, socio-economic, and health and safety risks among others. As SXR and NXR were developed prior to Tanzania’s Environmental Management Act, SafariCo was required to complete an Initial Environmental Audit (IEA) and was awarded an Environmental Audit Certificate in September 2017 and August 2015 respectively. Adherence with the IEA is monitored annually as detailed further below.
For N20, which is an extension of NXR, an EIA was completed in June 2025 and the associated EIA certificate granted in July 2025 by the Tanzania National Environment Council (NEMC). The EIA was prepared as per national legislative requirements and in accordance with the UNESCO Guidance and Toolkit for Impact Assessments. The document was also reviewed and approved by the Tanzania Wildlife Research Institute (TAWIRI).
In addition to the regulatory requirements, SafariCo implements further tools and methodologies to identify and manage potential E&S risks and impacts related to their operations, including annual quantitative risk assessments, maintenance of incident registers, and voluntary sustainability certification with Responsible Tourism Tanzania (RTTZ).
Organizational Capacity and Competency. SafariCo’s ESMS and general sustainability approach is overseen by the CEO of Land & Life Foundation and implemented by the Sustainability and Environmental Manager. At the lodge level, the group has a Sustainability and Compliance Manager who is supported by onsite health, safety and environment committees. General E&S management is also closely supported and monitored by the Director of Operations and respective lodge general managers. The scale and experience of the group’s E&S resources are considered commensurate to the nature of the lodge level risks and impacts.
Emergency Preparedness and Response. SafariCo has implemented an Emergency Handbook and associated Emergency Action Plan detailing the necessary lodge level emergency procedures, drills, contact details, roles, responsibilities etc. SXR conducts periodic fire and evacuation drills and has trained fire marshals and first aiders on duty at each shift. The Emergency Handbook and Emergency Action Plan will be refined and adopted at both NXR and N20 once they become operational.
Monitoring and Review. As per the requirements of Tanzania’s EIA and audit regulations, all EIAs/IEAs are required to be audited on an annual basis, and reports submitted to the NEMC. Both SXR and NXR had their last regulatory E&S audits in June 2021 prior to their closing for refurbishment. All lodges are also audited annually to ensure compliance with the OHS and life and fire safety (L&FS) permitting.
In addition to regulatory audits, SafariCo has multiple internal monitoring and reporting systems, including monthly and annual quantitative E&S audits of every lodge. These audits assess and report on energy, water, waste, facilities management, chemicals, air quality, fire safety, environmental and legal compliance. Lastly, assessments are undertaken every two years by Responsible Tourism Tanzania (RTTZ) to rate the E&S performance of each property by rewarding the property with sustainability certification.
PS2 – Labor and Working Conditions
Human Resources Policies. SafariCo employs a total of 888 workers across their Tanzanian operations of which 164 workers are employed at the SXR and NXR lodges, and 94 workers at the head office (as of 30 April 2025). The remaining workers are spread across other lodges and operations. The male to female ratio of workers is 72:28, with over 97% of the workforce consisting of local employment. The group’s Tanzania business has a centralized HR function based in Arusha, Tanzania, and further HR support staff based at each respective lodge as required. Labor and working conditions are managed under an overarching HR Manual, covering terms and conditions of employment, and various policies, including those related to human rights, grievance management, retrenchment, and health and safety.
Working Conditions and Terms of Employment. SafariCo’s labor and working conditions are driven by the requirements of the Tanzanian Employment and Labor Relations Act (ELRA), the Labor Institutions Act, and an existing Collective Bargaining Agreement (CBA), including the required provision of either term or permanent contracts detailing workers’ terms of employment and statutory rights (leave, social security etc.).
Remuneration is paid monthly and as per reviewed pay slips is above the Tanzanian private sector minimum wage of TZS 300,000 (?US$116.00). Working hours are defined by the ELRA, with a limit of 45 hours per week, and a maximum of 50 hours of overtime per month. As per the ELRA, overtime is compensated at 1.5 times the normal rate, or as time off in lieu based on agreements with workers and operational requirements. Workers are also entitled to leave, training, transport etc.
Workers’ Accommodation. Due to the isolated nature of SafariCo’s operations, worker accommodation is provided at all lodges and hence the group has implemented a Staff Accommodation Policy defining minimum standards and specifications for worker accommodation. At SXR, accommodation is provided for all on duty workers and includes a maximum of two people per room (segregated by gender), bathrooms, kitchen/canteen, and recreational facilities. These facilities were visited during the appraisal and are noted to be aligned with the requirements of IFC’s Guidance Note on Workers' Accommodation: Processes and Standards.
In relation to the construction contractor accommodation at NXR, the group has contractually defined the minimum requirements of the contractor. Currently the contractor is utilizing the existing staff accommodation which is deemed suitable for the duration of the construction period. This accommodation will be further upgraded prior to the lodge becoming operational.
Workers’ Organizations. As per the ELRA, freedom of association and collective bargaining are legally protected rights in Tanzania. At SXR, all workers, except for management and expats, are eligible to be members of the Conservation, Hotels, Domestic, Social Service and Consultant Workers Union (CHODAWU), with two elected union representatives at each lodge. In addition, each lodge has an elected Staff Committee who represent workers and, as with union representatives, engage with management on an ongoing basis. There is an existing CBA in place defining various negotiated working conditions.
Non-Discrimination and Equal Opportunity. SafariCo has defined a Human Rights policy including requirements relating to non-discrimination and equal opportunity. Further, embedded as a component of the HR Manual, the group has defined their anti-harassment approach, including sexual harassment, detailing requirements around reporting, confidentiality and sanctions. At the lodge level, management and workers are provided with training in relation to sexual harassment and gender-based violence (GBV). As per ESAP #1, the group will update the existing sexual harassment policy to: (i) include a dedicated, and adequately trained, focal point for the receipt and management of sexual harassment grievances and complaints, (ii) include specific clauses relation to anti-retaliation for reporting sexual harassment incidents, and (iii) update the grievance mechanism to reflect the defined reporting channel for sexual harassment incidents.
Protecting the Workforce. As per legal requirements, SafariCo’s Human Rights policy states that the group does not employ any person under the age of 18. Based on IFC’s appraisal, and supported by SafariCo’s procurement processes, no evidence of child labor was evident.
Grievance Mechanism. SafariCo has defined a Complaint and Grievance procedure whereby a stepwise approach is adopted for the receipt and resolution of worker grievances. As per ESAP #2, the procedure will be updated to cater for the receipt of anonymous grievances as per the requirements of PS2. The existing CBA also refers to a grievance procedure whereby workers can submit their grievances to the Staff Committee and General Manager.
Occupational Health and Safety. SafariCo has implemented an OHS Policy guided by the requirements of Tanzania’s OHS Act, including roles and responsibilities, requirements for personal protective equipment etc. As per the OHS Act, SXR has obtained a Certificate of Compliance and is subject to annual OHS audits undertaken by the Occupational Safety and Health Authority (OSHA), who oversee compliance with the relevant regulatory requirements. The group also conducts ongoing risk assessments, safety inspections, and training. NXR and N20 will be subject to the same requirements once operational.
At SXR, a full-time nurse is employed and 16 workers are trained in first aid. SafariCo also maintains a general incident register of all accidents, near misses and fatalities. Over the past two years, a total of 13 incidents were recorded, with no fatalities or serious incidents.
Workers Engaged by Third Parties: SafariCo makes limited use of third-party contractors. Where such services are required (transport, food suppliers, etc.), the group has defined a vendor/supplier vetting and registration process assessing areas such as compliance with labor law, OHS, certifications, and environmental policies and practices.
In relation to current construction contractors for NXR and N20, they are contractually required to comply with SafariCo’s Contractor Code of Conduct and Environmental Responsibilities, which detail the minimum contractual requirements in relation to standards of health, safety, welfare and environmental awareness required by the contractor while on site. SafariCo only makes use of Tier I contractors for their construction activities, as is the case at NXR and N20. Such contractors are registered with the Tanzanian Contractors Registration Board and are required to meet certain standards in relation to OHS. SafariCo also has an internal projects team that manage and oversee all construction activities and overall compliance.
PS3 – Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases: Due to the isolated location of SafariCo’s lodges, they rely on a combination of diesel generators, solar, and liquefied petroleum gas (LPG) for power generation. SXR is equipped with four generators totaling 1.5MW providing approximately 70% of the lodge’s energy requirements, with the balance supported by direct supply rooftop solar and LPG. In 2024 SXR and NXR utilized approximately 63,000 liters of diesel and 27 tonnes of LPG. It is anticipated, once operational and due to altitude and cloud cover, that NXR and N20 will predominantly utilize diesel generators for energy, supplemented by LPG for cooking.
SXR’s main water requirements emanate from laundry, kitchen and guest requirements. The lodge is equipped with a 27,000-liter water storage tank, supplied by three boreholes, which are pumped using solar power. Water consumption from January to April 2025 totaled 7,600 m3. The group has implemented a Water Management Policy defining the sustainable water management approach. In addition, TANAPA has implemented Water Use and Management Guidelines required for all lodges. SafariCo has implemented an Energy Management Policy defining the group’s approach to sustainable energy management. It is anticipated that NXR and N20 will also utilize borehole water once operational.
In relation to greenhouse gas (GHG) emissions, the group is a signatory of the Glasgow Declaration, and has defined a Climate Action Plan outlining the approach to determining, managing and reducing its overall carbon footprint. This includes a detailed data capturing process whereby each lodge records its resource consumption daily and reports these statistics each month. This data is consolidated into monthly, quarterly and annual Carbon Footprint reports. In 2024, SafariCo reported a total combined carbon footprint of 5,926 tonnes of carbon dioxide equivalent (tCO2e), a 19% reduction from its baseline year (2022) which was 7,300 tCO2e).
Waste Management. SafariCo has implemented a Waste Management Plan defining the group’s approach to waste categorization, avoidance, reduction and management, and aligned with the TANAPA GMP requirements. Key waste streams include food waste and packaging, while hazardous waste includes kitchen grease, oil rags etc. At SXR waste is currently segregated, recycled or composted where possible, or collected by an accredited service provider, with waste manifests provided. Waste quantities are reported monthly. SafariCo will adopt the same waste management approach at NXR and N20 once operational.
During the redevelopment of SXR, at least 8,800m3 of demolished materials from pre-existing infrastructure was re-cycled and re-purposed, saving approximately 844,800 km of truck haulage and consequently mitigating approximately 303,600 liters of diesel fuel.
Wastewater (grey water and sewage) is largely generated through laundry and guest activities. At SXR this is managed through a soak-away system, with the associated septic tank emptied on a periodic basis by a licensed service provider. At NXR a biological sewage treatment plant, which will treat both sewage and grey water, will be installed.
Pesticide Use and Management: The group currently makes use of an accredited service provider to provide pest management services and products. The service provider is accredited and licensed and use chemical pesticides that are low in human toxicity, that are known to be effective against the target species, and that have minimal effects on non-target species and the environment. TANAPA has also implemented guidelines for the management of alien invasive species.
PS4 – Community Health, Safety and Security
SXR and NXR (together with N20 extension) are located within the Serengeti and Ngorongoro national parks, and hence not near local communities, and health and safety risks and impacts are limited.
Infrastructure Design Safety: All SafariCo operations, including SXR, NXR and N20, are designed to the highest standard, and approved by TANAPA. All construction operations require a building permit prior to commencement and at the completion following an external inspection and approval.
SafariCo has implemented a corporate Fire Safety Policy across all operations detailing the requirements and approach for prevention, detection, and response. Key measures, from both a public/worker safety, and environmental protection perspective, include appropriate building design and construction, installation of detection systems such as smoke detectors and alarms, pressure pumps, fire extinguishers etc. In addition, every operation undertakes periodic staff training, fire drills and have dedicated fire marshals on duty across shifts. Each operation is subject to annual internal and independent fire safety audits.
As noted under PS1, SafariCo has implemented an Emergency Handbook and associated Emergency Action Plan detailing the necessary lodge level emergency procedures, drills, contact details, roles responsibilities etc.
Security. The nature of SafariCo’s SXR, NXR and N20 operations do not necessitate extensive security requirements and generally are required to manage customer / animal encounters and risks. SXR, which is currently operational, has 14 unarmed security guards across 2 shifts, as well as a dedicated control room. All security guards are employed directly by SafariCo. As per ESAP #3, SafariCo will develop and implement a Security Management Plan, commensurate to the nature of risks and impacts that will define the group’s security management approach, use of force, equipment, and training requirements as per the requirements of PS4.
PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protection and Conservation of Biodiversity. SXR is located in the Serengeti National Park and NXR/N20 is located in the Ngorongoro Conservation Area, both of which are Key Biodiversity Areas (KBA) and designated UNESCO World Heritage Sites (WHS). Both lodges are situated within the southern Acacia-Commiphora bushlands and thickets ecoregion, and a number of Critical Habitat values are common to both.
Both SXR and NXR are existing operations, with approved leases and environmental permits. SXR is currently operational while the project at NXR is limited to refurbishment of the existing lodge. N20 is an extension of NXR, for which an amended lease has been granted by TANAPA. The extension will result in the clearing of approximately 4 acres of land. In this regard, SafariCo completed an EIA in 2025 which was submitted to the NEMC, including comments from TAWIRI. The EIA was developed in alignment with UNESCO’s Guidance and Toolkit for Impact Assessments, and the terms of reference and scoping report were reviewed by the UNESCO national commission. Engagement with the UNESCO secretariat is ongoing, including their review of the final EIA and the approved environmental authorization from the NEMC.
Since the lodges are situated in protected areas, KBAs and WHS, the management and protection of Critical Habitat and outstanding natural values (OUVs) are of paramount importance. The management and mitigation of potential biodiversity risks and impacts is delegated to TANAPA and NCAA respectively. A proportion of the annual lease fees is allocated to conservation activities in the respective protected areas. As per ESAP #4, in addition to this existing commitment, SafariCo will develop and implement a Biodiversity Action Plan, in consultation with TANAPA, for the delivery of additional positive conservation outcomes in both the Serengeti National Park and Ngorongoro Conservation area, over the course of the current investment.
Invasive Alien Species. The introduction of alien invasive plant species is noted as one of the major biodiversity risks in protected areas such as Serengeti and Ngorongoro, hence, both TANAPA and NCAA have developed and implemented their own Invasive Alien Plant Species Strategic Plan. At the lodge level, SafariCo’s management of invasive alien plant species is guided by the requirements of the TANAPA and NCAA GMP’s respectively, as well as the respective EIAs that details the potential risk and management approach to avoid the introduction of invasive alien species during construction and operations.
