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
Policy and ESMS. ISA Lab operates under a structured management system based on the Company's quality management standards. This system integrates policies, procedures and monitoring tools covering occupational health and safety, labor practices and some environmental safeguards. The management system is overseen by ISA's quality and operations team and is based on their quality manual, which includes the procedures used in the Company's operations to ensure a consistent approach to managing their operations risks. ISA Lab ensures compliance with healthcare-specific standards through regulatory alignment with ANVISA (Agência Nacional de Vigilância Sanitária) and the Ministry of Health, clinical and operational accreditation from organizations such as ONA (Organização Nacional de Acreditação) and ACSA (Agencia de Calidad Sanitaria de Andalucía), the implementation of internal Standard Operating Procedures (SOPs) and audits. The Company conducts training and continuous improvement initiatives, supported by technology-enabled compliance monitoring through a proprietary app. Additionally, ISA Lab is in the final stages of becoming a “Certified B Corporation”
As per ESAP Item#1, ISA Lab will supplement the existing manual with an Environmental and Social Management System (ESMS) that can be integrated within their current management system and be compliant with the requirements set forth in IFC PSs. The ESMS will include: (i) an E&S Policy ; (ii) procedures for screening and assessing environmental health, safety, and social risks and impacts of ISA activities; (iii) a Stakeholder Engagement Plan (SEP) and community grievance mechanism; (iv) an ESMS organization and structure with a dedicated staff member responsible for E&S matters; (v) the monitoring of E&S performance through Key Performance Indicators (KPIs); and (vi) environmental and social criteria in the internal and external audits process and checklists.
Organizational Capacity. ISA’s Chief Peoples Officer (CPO), who reports directly to the CEO, is responsible for EHS matters, including occupational health and safety, implementation of safety protocols, labor compliance, diversity and inclusion programs, internal and external grievance mechanisms and workplace ethics and harassment prevention policies.
Management and Monitoring Programs. ISA maintains all required environmental licenses and permits, including operations and sanitary licenses, LFS-related permits, and all the regulatory permits for the business activities of the Company. The Company's expansion plans focus on scaling B2B partnerships, geographic expansion to new cities and states within Brazil, establishing operational hubs, training of healthcare professionals and pursuing selective mergers and acquisitions. No physical displacement, land expropriation or acquisition of land is envisioned. ISA offices and storage facilities are located in rented spaces, minimizing environmental and social risks. Due diligence of environmental and social aspects is conducted for all expansions and acquisitions to ensure compliance with regulatory requirements.
Emergency Preparedness and Response Plan. ISA has developed basic Emergency Preparedness and Response Plans (EPRPs) for each office and hub facility. The Company keeps records of permits related to the fire detection and suppression systems, which follow local building codes and fire protection regulations. The EPRPs include relevant emergency scenarios such as fire, floods and spill events. Each facility also has an emergency evacuation brigade and performs annual evacuation drills and training.
PS2: Labor and Working Conditions
Working conditions and management of workers relationship. ISA has established labor policies and procedures that align with national labor regulations. These policies are detailed in their Code of Ethics and Conduct and cover labor rights, non-discrimination, equal opportunities, diversity and inclusion, workplace harassment, gender-based violence, and sexual exploitation and harassment. Each employee receives an employee handbook outlining the terms of employment, including contract types, working hours, compensation, benefits, rights, responsibilities, and disciplinary procedures.
ISA's organizational structure includes a CEO and VPs for various departments (Health, Commercial, Operations, Product, HR, Finance). Workforce statistics are available, broken down by job function, gender and contract type: i) CLT - full-time employees under Brazilian labor law (82% women, 18% men), mainly administrative and logistic staff who receive benefits such as health, dental and life insurance, meal allowance, childcare assistance, etc. ii) PJ - Juridic employees (37% women, 67 % men), primarily in executive and strategic positions within the Company;these are also full-time employees and receive the same type of benefits as CLT workers, and iii) Autonomous Professionals or independent healthcare professionals (nurses and doctors, 86% women and 14% men). There are no unionized workers, but a collective bargaining agreement covers 100% of the CLT employees. Employees are free to join unions if they choose to do so.
The Company provides induction training for new employees and contractors, including mandatory modules on EHS aspects and sexual harassment prevention. Continuous education programs are available for employees and independent healthcare professional contractors. The effectiveness of training is not formally evaluated, but the training is documented. To ensure the E&S competency of the workers, ISA will, as per ESAP item#2, include methodologies for evaluating competencies as part of the training procedures and will establish minimum requirements for the evaluations.
Workers Grievance Mechanism. ISA Lab has implemented a grievance mechanism using the "Contato Seguro" external platform for workers grievance resolution. Only the CEO and the HR Director have access to these reports and the platform allows for anonymous reporting. The time for responding to grievances is one business day, with immediate action taken in the event of serious issues.
Independent professionals. Independent healthcare professionals (ISAs) are classified as gig economy workers, meaning they are independent contractors with complete flexibility in choosing when and which assignments to accept. ISA monitors their working hours and compensation, ensuring it is competitive and, on average, up to four times higher than the minimum wage for their profession. ISAs are paid per visit/procedure and are responsible for their own social security contributions. The Company has a structured grievance redress mechanism for ISAs to address payment, workload, or working condition issues.
Occupational Health and Safety. ISA Lab has formulated a health and safety policy and developed its corporate EHS manual based on hazard identification of risks. Workplace noise and air quality monitoring records are within applicable standards. ISA has a formal Standard Operating Procedure (SOP) for incident and accident investigation, which outlines the steps for reporting, root-cause analysis (RCA), and implementation of corrective and preventive actions in case of lost-time injuries or safety-related events. The EHS team collects incident statistics monthly from each site. For ISAs, there is an emergency button within their app for immediate support in urgent situations, bypassing the ‘Contato Seguro’ process and going directly to the operations team. Since inception, there have been no lost time accidents, including traffic accidents or fatalities. The Company has set a target, in the next three years, to achieve zero accidents across all facilities and activities.
Healthcare professionals are required to use Personal Protective Equipment (PPE) and upload photos as proof via the Company's app. This app allows for real-time monitoring of compliance and creates an audit trail. Any patient safety event is reported in real-time via the app and reviewed by clinical and quality teams. Additionally, a safety checklist is completed during each visit, covering hygiene, electrical safety and mobility hazards. The app guides healthcare professionals step-by-step during visits and includes a panic button connected to a 24/7 support team. ISA monitors the location and travel time of healthcare professionals, even though they use their own vehicles, raising flags for high speeds or prolonged stops. Onboarding includes training in safe driving practices and emergency procedures. Professionals can report incidents or request assistance through the app. ISA identifies and avoids areas with high security risks for home visits.
ISA has a Code of Ethics and Conduct for Suppliers that applies to all third-party workers. The Company performs periodic oversight visits to key suppliers. ISA Lab will include the prohibition of all types of sexual and workplace harassment, as well as a prohibition of child or forced labor in its policy and code of conduct for suppliers (ESAP item #3).
The Company manages the risk of exposure to infectious diseases through mandatory vaccination for professionals, on-site vaccination programs with a discounted cost to staff and patients, infection control protocols, case identification and isolation and support to professionals and families through containment and follow-up.
PS3: Resource Efficiency and Pollution Prevention
Pollution prevention. ISA Lab operations primarily involve the provision of home-based healthcare services, which inherently result in a relatively low environmental impact compared to traditional healthcare facilities. The Company does not have significant air emissions or effluent discharge, and therefore, does not conduct ambient air quality monitoring or air quality impact studies. ISA Lab has an environmental management manual that provides information about the processes for compliance with environmental legal requirements. However, the Company will establish a procedure to identify any environmental impacts or risks associated with its operations and facilities. This procedure will facilitate the elaboration of a risk and impact matrix, enabling the implementation of necessary measures to mitigate those impacts. This activity will be carried out as part of the ESAP item #1 mentioned above.
The quality team is responsible for internal and external audits, managing all licenses and regulatory requirements and ensuring compliance with environmental legal requirements, including waste management and disposal. Additionally, as part of its primary supply chain monitoring, ISA Lab conducts audits of private waste management companies and primary suppliers. These audits include technical aspects and, to a limited extent, environmental aspects. ISA Lab will incorporate more comprehensive environmental, social, health, and safety criteria into its audit processes including a checklist as part of its ESMS (ESAP#1). This will allow for the identification of necessary measures to mitigate any deviations or risks within its operations or those of a supplier.
Resource efficiency. ISA tracks kilometers driven by healthcare professionals and estimates greenhouse gas (GHG) emissions based on this data. This information is reported for the “B Corp” certification. ISA monitors energy and water consumption in all operational hubs as part of its resource efficiency strategy.
Waste management is a key focus for ISA Lab, with procedures in place for handling medical waste and a commitment to reducing plastic use. The Company utilizes third-party contractors for waste disposal and has a waste management system detailed in their Health Services Waste Management Plan (Plano de Gerenciamento de Resíduos de Serviços de Saúde) including segregation of waste by risk groups, collection and transport by licensed companies and disposal methods such as incineration for infectious waste. ISA monitors waste generation by category and has initiatives to reduce waste, including a "Zero Plastic" project. Complementarily, the "Casa Segura" program includes random audits of patient homes to check waste management practices, ensuring compliance and promoting best practices. All non-hazardous waste is collected for disposal by an authorized public service agency and hazardous waste is collected by a private authorized company.
PS4: Community Health, Safety and Security
ISA Lab engages with its clients, primarily patients, families, and caregivers through direct and personalized communication strategies focused on transparency, education and risk prevention. This engagement includes pre-visit information, where patients and families receive clear instructions regarding safety protocols, PPE, sanitation, and emergency contacts prior to home visits by the ISAs (healthcare providers).
The Company maintains a formal grievance mechanism to handle concerns raised by patients, families, and community members, especially relevant in sensitive care contexts such as palliative care. Communication channels include a 24/7 hotline and dedicated WhatsApp support for incident reporting or clarifications. ISA uses surveys and complaint tracking to improve services and address concerns, with a dedicated email (ouvidoria@isasaude.com) and website contact form available for grievances. All grievances are processed following a structured procedure, which includes classification by severity, response timeline, investigation if applicable, resolution and follow-up communication. Protocols are in place for suspected contagious cases, including risk assessment, minimized exposure and notification to the team and sanitary regulators.
As part of its home-based health services, ISA provides services to the communities, including children. The group publicizes services through social media and local authorities. As per ESAP item #4, ISA will develop a child protection policy outlining its commitment to providing a safe and secure environment for children accessing services via its home program. The policy will require all workers, health service providers and other persons participating in or serving such programs to participate in mandatory training on the appropriate conduct around children, protecting children from abuse and neglect, reporting of known or suspected child abuse and neglect and adhere to conduct requirements. The policy will include handling any known or suspected abuse or neglect of a child under Brazilian law.
The Company, for their offices and hubs, complies with all local requirements set by fire safety authorities and have their respective fire permit (Auto de Vistoria do Corpo de Bombeiros “AVCB” in Portuguese). ISA also conducts regular training and drills to ensure preparedness for emergencies. The Company has Standard Operating Procedures for emergency response to fires, flood and storms events for their office and hubs. Furthermore, the company provides training to its employees on emergency response procedures.
ISA Lab has implemented security measures to ensure the protection of its facilities and personnel. The main office is equipped with building security services and electronic measures, while hubs have security cameras and alarms installed. Although there are no on-site security personnel, the company has established procedures for contacting the police in case of incidents. ISA Lab also regularly conducts security risk identification to detect high-risk areas, utilizing benchmarking with other users of similar platforms and collaborating with healthcare professionals to identify areas that should not be visited.
