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Environmental & Social Review Summary
Project Number
51279
Company Name
Umai Group
Date ESRS Disclosed
Feb 11, 2026
Country
Kyrgyz Republic
Region
Central Asia and Turkiye
Last Updated Date
Jun 11, 2026
Environmental Category
B - Limited
Status
Pending Signing
Previous Events
Approved : Jun 10, 2026
Sector
Grocery Retail (Supermarkets, Hypermarkets, Convenience Stores etc.)
Industry
other
Department
Regional Industry MAS MCT
Project Description
IFC is considering an up to US$50 million secured senior loan (IFC Financing) to Umai Group LLC (Umai), the largest retail chain operator in the Kyrgyz Republic (KR), and LogoPark LLC (LogoPark), a newly established project management company. Both entities are subsidiaries of Visor International DMCC and will be co-borrowers (‘companies’). LogoPark will build a centralized distribution center (DC) to support the long-term growth of Umai in the next five to seven years. The IFC Financing will support Umai’s expansion plan up to 2029, which is expected to include 158 new stores, composed of supermarkets (3%), express grocery stores (18%) and proximity/convenience stores (79%). IFC Financing will be limited to (i) the construction of new retail stores, (US$38mn), and ii) a greenfield 26,000 sqm warehouse (US$33mn) which is in the planning stage (together, the Project).
Overview of IFC's Scope of Review
IFC’s E&S review of the proposed investment included (i) Umai’s E&S policies, site specific E&S documents and information that are for the retail store management and LogoPark investment; (ii) meetings with the Umai and LogoPark senior management team, Occupational Health and Safety (OHS) manager, Human Resources (HR) manager and team; (iii) site visits to existing and under construction retail stores and distribution centers in Bishkek, LogoPark’s location, primary logistics contractor maintenance area; and Umai’s fleet truck office and maintenance area; and (iv) interviews with direct workers, suppliers, contractors in the facilities visited.
E & S Project Categorization and Applicable Standard
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS5- LanLand Acquisition and Resettlement has been included for an associated facility
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS5- LanLand Acquisition and Resettlement has been included for an associated facility
This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability (2012) as the use of proceeds is limited to investments in assets that do not involve significant E&S risks.
The project presents several environmental and social risks that require careful consideration. Involuntary resettlement is a notable concern, as the planned access route will displace informal structures located on government land. While the resettlement process has not yet commenced, it involves physical displacement, and the government has offered alternative land plots to affected individuals. This situation underscores the importance of ensuring adequate consultation and compensation to avoid adverse impacts on affected parties. Additionally, the project is exposed to medium contextual risk, influenced by factors such as government instability, human trafficking, illicit trade, labor supply chain risks, and representational politics. These risks highlight the need for robust governance and supply chain management practices to mitigate potential vulnerabilities. Gender-based violence and harassment also pose a medium risk, particularly given that there would be workers who will be housed in the project area. Although the company adheres to relevant international conventions and maintains a zero-tolerance policy, gaps in risk assessment and record-keeping could exacerbate challenges related to workplace safety and gender equity. Community health and safety risks are evident, particularly concerning life and fire safety standards for new retail stores, which require alignment with good international industry practices. While the project is not expected to significantly impact biodiversity, cultural heritage, or ecosystem services, the medium risk of extreme heat due to climate change could result to water scarcity in the future. The reliance on an external EPC contractor for construction and operations further emphasizes the need for stringent oversight to ensure compliance with environmental and social standards. Overall, the project’s environmental and social risk profile necessitates proactive management to address resettlement, contextual risks, gender-based violence, community safety, and climate-related challenges effectively.
The project presents several environmental and social risks that require careful consideration. Involuntary resettlement is a notable concern, as the planned access route will displace informal structures located on government land. While the resettlement process has not yet commenced, it involves physical displacement, and the government has offered alternative land plots to affected individuals. This situation underscores the importance of ensuring adequate consultation and compensation to avoid adverse impacts on affected parties. Additionally, the project is exposed to medium contextual risk, influenced by factors such as government instability, human trafficking, illicit trade, labor supply chain risks, and representational politics. These risks highlight the need for robust governance and supply chain management practices to mitigate potential vulnerabilities. Gender-based violence and harassment also pose a medium risk, particularly given that there would be workers who will be housed in the project area. Although the company adheres to relevant international conventions and maintains a zero-tolerance policy, gaps in risk assessment and record-keeping could exacerbate challenges related to workplace safety and gender equity. Community health and safety risks are evident, particularly concerning life and fire safety standards for new retail stores, which require alignment with good international industry practices. While the project is not expected to significantly impact biodiversity, cultural heritage, or ecosystem services, the medium risk of extreme heat due to climate change could result to water scarcity in the future. The reliance on an external EPC contractor for construction and operations further emphasizes the need for stringent oversight to ensure compliance with environmental and social standards. Overall, the project’s environmental and social risk profile necessitates proactive management to address resettlement, contextual risks, gender-based violence, community safety, and climate-related challenges effectively.
Environmental and Social Mitigation Measures
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: Umai manages environmental and social (E&S) risks from its operations by complying with national standards and all relevant E&S permits and regulations in KR. Currently, the company’s policy framework focuses on OHS and HR. As per ESAP#1, the Umai and LogoPark will develop an E&S Management System (ESMS) to manage the risks of their retail operations, LogoPark, and fleet operations in line with IFC Performance Standards (PS) requirements. This will include development of: (i) an overarching E&S policy committed to compliance with IFC PS, and approved by the Umai and LogoPark’s senior management and communicated to all employees; (ii) a screening procedure to identify the potential E&S risks of new developments, including land acquisition for standalone stores, and LFS design considerations of stores located within existing buildings; (iii) a contractor management plan (CMP) in line with IFC’s good practice note on Managing Contractors’ Environmental and Social Performance, IFC PS and WBG EHS Guidelines. This will include legally binding conditions in the contract with the EPC contractor to comply with IFC PS; (iv) an E&S operations phase environmental management plan and monitoring procedures including but not limited to OHS, hazardous materials management, waste management, resource efficiency, greenhouse gases emissions, in line with WBG General EHS Guidelines in terms of scope, roles, and key performance indicators (KPI); (v) updated HR procedures; (vi) an updated Emergency Response Plan to cover all emergencies (e.g. earthquakes, natural calamities, terrorism etc.); (vii) a LFS commissioning plan that will be adopted from the project design stage to operations of each new retail store; (viii) updated transportation safety program; and (ix) an overarching stakeholder engagement plan (SEP) in line with PS1 requirements for managing external grievance mechanism.
Identification of Risks and Impacts: Umai adheres to the KR legislation for retail businesses. According to these regulations, only Umai’s stores with production facilities (i.e., kitchen, bakery) are required to obtain environmental passports, which serve as simplified assessments of their environmental impact. Other stores without such facilities are classified as non-hazardous and are therefore exempt from this requirement.
The local environmental assessment report for the LogoPark project (26,000 sqm warehouse) is currently being prepared and will be submitted to the regulatory agency, along with the overall project design. In accordance with ESAP#2, LogoPark will prepare an Environmental and Social Impact Assessment (ESIA) and management plans for the construction and operational phases, following the IFC PSs and WBG EHS Guidelines. The assessment will identify and manage impacts within the facility's area of influence, including the access roads connected to the municipal road and the railway connection. The ESIA will incorporate a climate risk assessment and will serve as the basis for further considerations in the final design of the facility.
Management Programs: Umai’s operational procedures cover fire safety, security, transportation safety, waste management, and pest control. The company manages solid municipal waste through contracts with specialized providers, and sends recyclable materials to licensed contractors for recycling. The company is implementing a HACCP-based food safety management system in line with ISO 22000 and preparing for the certification process. As per ESAP #1, an E&S CMP will be developed to manage the E&S performance of contractors and subcontractors for the development of LogoPark and new retail stores. Additionally, Umai will establish an operations phase management procedure for implementation in the retail stores, LogoPark, and transportation fleet will be updated in line with IFC PS.
Organizational Capacity: The General Director oversees the E&S performance at Umai operations. A corporate OHS Specialist develops and implements annual safety action plans, conducts employee training, monitors compliance across all facilities, and investigates accidents to suggest preventive measures. LogoPark currently does not have its own E&S staff.
Umai operates stores, existing DCs, and fleets in line with its OHS Policy and internal regulations, ensuring safe and efficient operations company-wide. As per ESAP #3, the company will designate an E&S officer to manage the broader E&S issues of the project and compliance with IFC PS and be supported by specialists that will be engaged by the project (i.e., LFS and GBVH focal person) to manage the project’s risks and comply with the FC PS requirements, WBG EHS Guidelines with Good International Industry Practices (GIIP).
Emergency Preparedness and Response: The company has an Emergency Preparedness and Response Plan (EPRP) covering all Umai facilities, outlining procedures for employees during emergencies. Each store displays evacuation routes in accessible areas, which comply with the KR's fire safety laws. Umai, emergency drills, and training sessions focused on fire safety and OHS are conducted regularly. Emergency drills are organized at specific stores upon request from representatives of the Ministry of Emergency Situations of the KR and take place at least once per year.
As per ESAP #1, the company will develop an EPRP to be used for each store, outlining how to handle emergencies such as earthquakes, natural disasters, and terrorist incidents. These documents will detail evacuation paths, assembly areas, key contact information, staff responsibilities during an emergency, and special instructions for assisting customers within vulnerable groups (e.g., children, seniors, and people with disabilities). The plan will also list necessary emergency equipment—including emergency lighting and reflective signs. The printed EPRPs will be kept in the security room for easy access. Additionally, these plans will require regular emergency drills and ongoing maintenance of fire safety systems.
Monitoring and Review: The company undergoes regular inspections by the Municipal Environmental Inspectorate to check hygiene and enforce fines under the KR's Code of Offenses. Occupational health and fire safety compliance are tracked through internal checks and external audits, as required by national law. ESAP #1 will develop an OHS monitoring plan following WBG General EHS Guidelines.
PS2: Labor and Working Conditions
Umai has a total of 6,514 direct workers spread across different departments, with the majority working as salespersons at the retail stores and in-house production (i.e., bakery, kitchen) for the stores. The company intermittently engages temporary contract workers to support operations through a service agreement with a main contractor.
HR Policy and Procedures: The company has an HR policy, known as the Internal Personnel Regulation. It covers all areas of the organization, including retail stores, production sites like bakeries, kitchens, confectioneries, and DCs. The policy is enforced in line with the KR Labor Code. All direct workers are issued employment contracts specifying their roles and responsibilities. The policy outlines the rules for standard working hours, scheduled breaks, and overtime procedures, which are primarily applicable to office workers. The store manager manually approves overtime before it is processed in the payroll system. The work shifts of workers vary depending on the assigned task and would require improvement in managing the overtime period rendered to ensure correct payment in line with the KR Labor Code. Onboarding sessions are provided for new staff to inform them of their rights and benefits. The company also supplies uniforms, meals, and refreshments during lunch and tea breaks, as well as transportation for late-night shifts as needed.
Ethical employment practices are upheld through strict adherence to national bans on child and forced labor. The policy includes provision regarding collective rights and activities, but many are not fully aware of these rights. Company policies support equal opportunity, ensuring employees with similar tasks receive equal pay regardless of gender. Women comprise about 66% of Umai’s workforce. Although there is no separate formal policy addressing discrimination, harassment, or exploitation, the company adheres to the Labor Code of the KR, which prohibits such practices. As per ESAP #4, HR policies and procedures will be enhanced to include (i) specific work schedules and allowable working hours, rules for calculation of payment and overtime, record keeping of workers consent on overtime; and applicable work schedule for the different types of workers (e.g., women with children, pregnant, persons with disability); (ii) strictly prohibit child and forced labor, discrimination, and foster gender equality; (iii) develop a sexual exploitation and abuse, and sexual harassment (SEAH) policy and implementation plan; (iv) implement a code of conduct for employees and contractors that also prohibits discrimination and SEAH, and that provides for disciplinary measures in case of violations; (v) include collective bargaining rights during onboarding could help close the current knowledge gap among staff; and (vi) provide training to all direct and contracted workers on the HR policies and procedures, particularly on discrimination and SEAH, during their initial induction and periodically thereafter.
Upon commissioning of the LogoPark, the company will transfer the operations of existing DCs in Bishkek to the new facility. As per ESAP #5, the company will prepare a Workforce Relocation Plan, including a retrenchment plan, to ensure that existing DC workers are provided with the necessary guidance to protect their rights and benefits during relocation to LogoPark or when offered alternative roles in the new retail stores. This plan also includes provisions for workers who are unwilling to continue moving due to personal limitations.
Grievance Mechanism: The company has an internal employee grievance mechanism to facilitate the resolution of employee concerns. Employees may submit written or verbal complaints to their immediate supervisor or management, use a telephone hotline, or file electronic grievances through the corporate online portal.
At the corporate level, the HR Department is responsible for receiving, registering, and processing complaints. Each grievance undergoes an internal review to assess the situation and determine any necessary actions. Following this review, employees receive formal feedback outlining the outcome and the decisions made. Confidentiality is maintained throughout the process, and employees are informed that submitting concerns will not result in adverse consequences. At the store level, line supervisors address workers' concerns, with most employees indicating that their issues are addressed. Currently, grievance logs are not available. In line with ESAP #6, the Grievance Redress Mechanism (GRM) will be be improved to include (i) turnaround time for addressing grievances, escalation procedures, and mandatory logs for retail stores, and (ii) a specific and accelerated pathway for sensitive issues, such as discrimination and SEAH, providing multiple reporting options (in person, writing, online, phone and anonymous). It will also identify and provide accessible referral pathways for complainants, accessible to all workers. As per ESAP #3, Umai will appoint a GBVH focal person in the HR team who has the capacity and experience to handle and investigate sensitive cases. The focal person will undertake specialized training to investigate allegations of discrimination and SEAH and lead the implementation of the anti-sexual harassment policy and relevant procedures.
OHS management: The company has established various control measures and technical provisions to protect employees and contractors from occupational risks identified within retail stores. These measures include: (i) providing employees with designated work clothing, such as insulated uniforms for staff in low-temperature warehouse environments; (ii) ensuring access to drinking water and hot meals at the workplace; (iii) equipping company facilities with designated rest areas; and (iv) conducting regular monitoring of compliance with sanitary and occupational health standards. OHS training requirements are determined by using an approved schedule, which factors in the results of regular inspections and internal audits. Line managers participate in OHS training once every three years, involving certified external OHS professionals. Line managers provide OHS training to retail store employees, with the support of the OHS manager. Under current legislation, retail store operations are exempt from mandatory workplace routine monitoring of occupational exposure factors for employees, such as noise, dust, and chemical exposure.
Contractor and third-party Management: The company adheres to responsible business practices, requiring all suppliers and contractors to comply with relevant legal obligations, especially those concerning the protection of workers' rights and the prohibition of discrimination, forced labor, child labor, and SEAH. The existing contractors of Umai are transport fleet companies that support the operations of the Project. An engineering, procurement and construction (EPC) contractor will be appointed for the LogoPark construction. Contractual agreements include a mandatory clause stipulating full adherence to the laws of the KR. As per ESAP #7, the company will update the legal agreements with the contractors and suppliers to include the code of conduct requirements (develop as per ESAP#4) and compliance with all applicable national regulations, particularly pertaining to working conditions and labor protections, and EHS incident reporting.. Umai will require contractors to report Umai EHS-related incidents and accidents during company operations, and will keep track of them as part of the OHS monitoring plan in line with ESAP #1.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: The primary source of electricity for warehouses and stores is the centralized power grid. The company is implementing technical solutions to reduce the consumption of electricity, water, and other resources. In particular, the company has incorporated resource conservation and energy efficiency measures in retail stores and warehouses both at the design stage and during day-to-day operations, such energy-efficient equipment, including refrigeration, water heating, household appliances, industrial equipment, and IT equipment; inverter air conditioners and energy-saving LED lighting; all equipment and lighting are turned off except for refrigeration units during non-working hours. The company records the water, electricity, and fuel consumption of its operation.
Air pollution/GHG emissions: The primary source of air pollution from retail stores and DCs is diesel generators, which are used exclusively as backup power sources and operate on an irregular and limited basis. The corresponding greenhouse gas emissions from the operations of the new retail stores and LogoPark, including the transportation fleet, will be monitored by the client in accordance with internationally recognized methodologies and good practices (ESAP #1).
Noise: The company uses diesel generators as backup power during outages. Occasionally, stores located within residential buildings receive noise-related complaints, which are handled according to procedures and followed by actions to reduce the impact on the community and environment. The company implements noise impact mitigation measures by installing noise shields and optimizing its distance from the residential buildings.
Water/Wastewater treatment: The company’s water supply is provided through connection to the centralized municipal water system operated by public utility services. The primary sources of sewage at the company’s facilities are sanitary and wastewater generated from kitchen and cafeteria areas. Wastewater disposal is through a centralized sewerage system (municipal sewer collector) in accordance with the applicable national regulations. No pre-treatment is performed at the company premises because the business activities do not generate wastewater containing toxic or hazardous substances. For the new supermarkets and stores with commercial kitchens, Umai will install grease traps in their kitchen in line with good international industry practice and dispose the collected grease in line with local waste regulations. The LogoPark will be designed and operated in compliance with the sewage authority’s acceptance criteria, WBG General EHS Guidelines, and GIIP requirements for the wastewater collection, treatment, and discharge (ESAP #8).
Hazardous Materials and Solid/Hazardous Waste Management: Hazardous materials are limited to cleaning chemicals and those used for maintenance, such as solvents, grease, and oil. Household chemicals and related products are stored in full compliance with applicable sanitary and fire safety regulations, in dry, specially designated areas with appropriate ventilation and safety controls in place. The chemicals used for pest control are applied by third-party certified companies and selected from food facility-compatible ones, which are in accordance with sanitary regulations and requirements.
As per ESAP#1, the Company will prepare a Hazardous Materials Management procedure for safe usage, storage, and handling, which will also promote the selection of environmentally friendly and non-hazardous materials.
The LogoPark will use the R1234yf refrigerant, the fourth-generation refrigerant, with low global warming potential. This will be used within closed-loop refrigeration systems. In the existing retail stores of the company, asbestos-containing materials (ACM) are not used. No asbestos-containing materials are used in the construction, renovation, or refitting of the company’s retail premises. The company adheres to responsible product handling practices and strictly complies with all legal requirements of the KR regarding the safe storage, use, and disposal of goods containing potentially hazardous substances.
The retail stores’ waste storage areas are not properly segregated for food waste, pallets and food packing. Due to limited areas, there is no clear demarcation between the waste storage area and new product stock area. The stores’ waste are collected and disposed of daily by licensed companies in compliance with the applicable sanitary and environmental regulations. As per ESAP #1, Umai will develop a waste management procedure for segregation, storage, recycling and disposal of all solid wastes, including damaged or expired products/food, packaging material, pallets, chemical containers to define practices and obligations of suppliers and Umai.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety/ Life and Fire Safety: The visited stores and warehouses have portable fire extinguishers, fire water pumps, hose reels, warning signage, alarm systems, smoke detection, and CCTV system. Improvements to the existing LFS design and practices of existing stores are necessary to meet GIIP. The company, as part of ESAP #1, will adopt an LFS commissioning plan in line with GIIP (e.g., United States National Fire Protection Agency Codes) for new stores and and engage a competent LFS expert to assist the company in its implementation (ESAP #3). The company will adopt the LFS criteria in the commissioning plan for screening locations of new stores. LogoPark LFS will be designed in line with the national requirements.
LogoPark will comply with the national construction and fire code of the KR and adopt the requirements of the LFS commissioning plan. The local State Fire Safety Authority will review the technical specifications for the LFS systems and emergency planning during the certification and permitting process for the facilities.
Traffic Management: The Umai's own fleet is primarily responsible for delivering goods from the distribution centers and production facilities to retail stores. Three outsourced transport providers are used as needed, particularly during periods of seasonal demand, increased delivery volumes resulting from promotional activities, or when shipment volumes fluctuate significantly. Umai also engaged a main transport contractor that handles Umai’s importation requirements. Umai's existing agreement with the contractor has limited E&S performance provisions. The company has internal regulatory documents, including the Instruction on Occupational Health and Safety for Motor Vehicle Drivers and internal procedures for the registration and monitoring of road traffic accidents. However, there is no documented procedure in place to address potential road safety risks to communities. As per ESAP#1, the company will develop a transport safety program, which will include guidelines for drivers on traffic safety and defensive driving to minimize safety risks of communities within the vehicle routes. The company will also provide comprehensive training to both existing and newly hired drivers and security personnel on the company’s policies, regulations, procedures, and grievance mechanism, with a particular focus on addressing issues such as discrimination and SEAH.
Security Services: At Umai, unarmed security personnel are employed in-house as company staff at select retail stores and other designated facilities. At the LogoPark facility, unarmed security services are provided by a third-party licensed security company under a formal service agreement. Umai developed working instructions for security personnel, and security staff are trained for communication and defensive use of force. There is CCTV monitoring in addition to other electronic security systems, including alarms, especially for night shifts
PS5 Land Acquisition and Resettlement
Umai's Development Department is responsible for selecting store locations and negotiating lease agreements with property owners, which include terms such as rent, lease duration, repairs, and other relevant conditions. The land designated for LogoPark has been leased from the government, having previously been leased to another company. This project aims to connect to the existing railway operated by the Gazprom company, facilitating the transportation of materials to LogoPark. The land area required for the railway connection falls under the jurisdiction of the railway authority. An agreement between LogoPark and the railway authority will be finalized to allow for the connection. The existing land arrangement for the retail stores and LogoPark do not entail land acquisition or livelihood impact that will trigger IFC PS5 requirements.
The borrower plans to construct an access road to connect LogoPark to the existing municipal road. The access road is in the early design stage but is projected to be approximately 2.35 kilometers long. Initial assessment indicated that there are two non-residential structures that may be affected by the proposed access road. The land between the municipal road and LogoPark area is owned by the land transportation authority and is currently designated as agricultural area. The authority has an existing lease agreement with one of the structure owners, permitting pasture use only, and no permanent structures are established on the land. No crops were noted during the appraisal visit. LogoPark has been in discussions with the land authority regarding the access road. The authority has decided to offer alternative land for the lessee who owns one of the existing structure. Additionally, LogoPark has hired a third party to evaluate the market value of the structure, and an estimated compensation amount has already been agreed upon with the structure owner. As per ESAP#9. the Borrower will engage a resettlement specialist to consult with the structure owners and other land users to evaluate further and confirm the potential impacts of the access road on the existing structures and livelihood of existing land users. The resettlement specialist will assess the adequacy of the process undertaken and the proposed compensation by the land authority and LogoPark to the lessee if its in line with PS5 requirements. If any gaps are identified in the assessment, the Borrower with the assistance of the resettlement specialist will prepare Supplementary Resettlement Action Plan to ensure that compensation is aligned with IFC PS5 requirements,
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Policy: Umai manages environmental and social (E&S) risks from its operations by complying with national standards and all relevant E&S permits and regulations in KR. Currently, the company’s policy framework focuses on OHS and HR. As per ESAP#1, the Umai and LogoPark will develop an E&S Management System (ESMS) to manage the risks of their retail operations, LogoPark, and fleet operations in line with IFC Performance Standards (PS) requirements. This will include development of: (i) an overarching E&S policy committed to compliance with IFC PS, and approved by the Umai and LogoPark’s senior management and communicated to all employees; (ii) a screening procedure to identify the potential E&S risks of new developments, including land acquisition for standalone stores, and LFS design considerations of stores located within existing buildings; (iii) a contractor management plan (CMP) in line with IFC’s good practice note on Managing Contractors’ Environmental and Social Performance, IFC PS and WBG EHS Guidelines. This will include legally binding conditions in the contract with the EPC contractor to comply with IFC PS; (iv) an E&S operations phase environmental management plan and monitoring procedures including but not limited to OHS, hazardous materials management, waste management, resource efficiency, greenhouse gases emissions, in line with WBG General EHS Guidelines in terms of scope, roles, and key performance indicators (KPI); (v) updated HR procedures; (vi) an updated Emergency Response Plan to cover all emergencies (e.g. earthquakes, natural calamities, terrorism etc.); (vii) a LFS commissioning plan that will be adopted from the project design stage to operations of each new retail store; (viii) updated transportation safety program; and (ix) an overarching stakeholder engagement plan (SEP) in line with PS1 requirements for managing external grievance mechanism.
Identification of Risks and Impacts: Umai adheres to the KR legislation for retail businesses. According to these regulations, only Umai’s stores with production facilities (i.e., kitchen, bakery) are required to obtain environmental passports, which serve as simplified assessments of their environmental impact. Other stores without such facilities are classified as non-hazardous and are therefore exempt from this requirement.
The local environmental assessment report for the LogoPark project (26,000 sqm warehouse) is currently being prepared and will be submitted to the regulatory agency, along with the overall project design. In accordance with ESAP#2, LogoPark will prepare an Environmental and Social Impact Assessment (ESIA) and management plans for the construction and operational phases, following the IFC PSs and WBG EHS Guidelines. The assessment will identify and manage impacts within the facility's area of influence, including the access roads connected to the municipal road and the railway connection. The ESIA will incorporate a climate risk assessment and will serve as the basis for further considerations in the final design of the facility.
Management Programs: Umai’s operational procedures cover fire safety, security, transportation safety, waste management, and pest control. The company manages solid municipal waste through contracts with specialized providers, and sends recyclable materials to licensed contractors for recycling. The company is implementing a HACCP-based food safety management system in line with ISO 22000 and preparing for the certification process. As per ESAP #1, an E&S CMP will be developed to manage the E&S performance of contractors and subcontractors for the development of LogoPark and new retail stores. Additionally, Umai will establish an operations phase management procedure for implementation in the retail stores, LogoPark, and transportation fleet will be updated in line with IFC PS.
Organizational Capacity: The General Director oversees the E&S performance at Umai operations. A corporate OHS Specialist develops and implements annual safety action plans, conducts employee training, monitors compliance across all facilities, and investigates accidents to suggest preventive measures. LogoPark currently does not have its own E&S staff.
Umai operates stores, existing DCs, and fleets in line with its OHS Policy and internal regulations, ensuring safe and efficient operations company-wide. As per ESAP #3, the company will designate an E&S officer to manage the broader E&S issues of the project and compliance with IFC PS and be supported by specialists that will be engaged by the project (i.e., LFS and GBVH focal person) to manage the project’s risks and comply with the FC PS requirements, WBG EHS Guidelines with Good International Industry Practices (GIIP).
Emergency Preparedness and Response: The company has an Emergency Preparedness and Response Plan (EPRP) covering all Umai facilities, outlining procedures for employees during emergencies. Each store displays evacuation routes in accessible areas, which comply with the KR's fire safety laws. Umai, emergency drills, and training sessions focused on fire safety and OHS are conducted regularly. Emergency drills are organized at specific stores upon request from representatives of the Ministry of Emergency Situations of the KR and take place at least once per year.
As per ESAP #1, the company will develop an EPRP to be used for each store, outlining how to handle emergencies such as earthquakes, natural disasters, and terrorist incidents. These documents will detail evacuation paths, assembly areas, key contact information, staff responsibilities during an emergency, and special instructions for assisting customers within vulnerable groups (e.g., children, seniors, and people with disabilities). The plan will also list necessary emergency equipment—including emergency lighting and reflective signs. The printed EPRPs will be kept in the security room for easy access. Additionally, these plans will require regular emergency drills and ongoing maintenance of fire safety systems.
Monitoring and Review: The company undergoes regular inspections by the Municipal Environmental Inspectorate to check hygiene and enforce fines under the KR's Code of Offenses. Occupational health and fire safety compliance are tracked through internal checks and external audits, as required by national law. ESAP #1 will develop an OHS monitoring plan following WBG General EHS Guidelines.
PS2: Labor and Working Conditions
Umai has a total of 6,514 direct workers spread across different departments, with the majority working as salespersons at the retail stores and in-house production (i.e., bakery, kitchen) for the stores. The company intermittently engages temporary contract workers to support operations through a service agreement with a main contractor.
HR Policy and Procedures: The company has an HR policy, known as the Internal Personnel Regulation. It covers all areas of the organization, including retail stores, production sites like bakeries, kitchens, confectioneries, and DCs. The policy is enforced in line with the KR Labor Code. All direct workers are issued employment contracts specifying their roles and responsibilities. The policy outlines the rules for standard working hours, scheduled breaks, and overtime procedures, which are primarily applicable to office workers. The store manager manually approves overtime before it is processed in the payroll system. The work shifts of workers vary depending on the assigned task and would require improvement in managing the overtime period rendered to ensure correct payment in line with the KR Labor Code. Onboarding sessions are provided for new staff to inform them of their rights and benefits. The company also supplies uniforms, meals, and refreshments during lunch and tea breaks, as well as transportation for late-night shifts as needed.
Ethical employment practices are upheld through strict adherence to national bans on child and forced labor. The policy includes provision regarding collective rights and activities, but many are not fully aware of these rights. Company policies support equal opportunity, ensuring employees with similar tasks receive equal pay regardless of gender. Women comprise about 66% of Umai’s workforce. Although there is no separate formal policy addressing discrimination, harassment, or exploitation, the company adheres to the Labor Code of the KR, which prohibits such practices. As per ESAP #4, HR policies and procedures will be enhanced to include (i) specific work schedules and allowable working hours, rules for calculation of payment and overtime, record keeping of workers consent on overtime; and applicable work schedule for the different types of workers (e.g., women with children, pregnant, persons with disability); (ii) strictly prohibit child and forced labor, discrimination, and foster gender equality; (iii) develop a sexual exploitation and abuse, and sexual harassment (SEAH) policy and implementation plan; (iv) implement a code of conduct for employees and contractors that also prohibits discrimination and SEAH, and that provides for disciplinary measures in case of violations; (v) include collective bargaining rights during onboarding could help close the current knowledge gap among staff; and (vi) provide training to all direct and contracted workers on the HR policies and procedures, particularly on discrimination and SEAH, during their initial induction and periodically thereafter.
Upon commissioning of the LogoPark, the company will transfer the operations of existing DCs in Bishkek to the new facility. As per ESAP #5, the company will prepare a Workforce Relocation Plan, including a retrenchment plan, to ensure that existing DC workers are provided with the necessary guidance to protect their rights and benefits during relocation to LogoPark or when offered alternative roles in the new retail stores. This plan also includes provisions for workers who are unwilling to continue moving due to personal limitations.
Grievance Mechanism: The company has an internal employee grievance mechanism to facilitate the resolution of employee concerns. Employees may submit written or verbal complaints to their immediate supervisor or management, use a telephone hotline, or file electronic grievances through the corporate online portal.
At the corporate level, the HR Department is responsible for receiving, registering, and processing complaints. Each grievance undergoes an internal review to assess the situation and determine any necessary actions. Following this review, employees receive formal feedback outlining the outcome and the decisions made. Confidentiality is maintained throughout the process, and employees are informed that submitting concerns will not result in adverse consequences. At the store level, line supervisors address workers' concerns, with most employees indicating that their issues are addressed. Currently, grievance logs are not available. In line with ESAP #6, the Grievance Redress Mechanism (GRM) will be be improved to include (i) turnaround time for addressing grievances, escalation procedures, and mandatory logs for retail stores, and (ii) a specific and accelerated pathway for sensitive issues, such as discrimination and SEAH, providing multiple reporting options (in person, writing, online, phone and anonymous). It will also identify and provide accessible referral pathways for complainants, accessible to all workers. As per ESAP #3, Umai will appoint a GBVH focal person in the HR team who has the capacity and experience to handle and investigate sensitive cases. The focal person will undertake specialized training to investigate allegations of discrimination and SEAH and lead the implementation of the anti-sexual harassment policy and relevant procedures.
OHS management: The company has established various control measures and technical provisions to protect employees and contractors from occupational risks identified within retail stores. These measures include: (i) providing employees with designated work clothing, such as insulated uniforms for staff in low-temperature warehouse environments; (ii) ensuring access to drinking water and hot meals at the workplace; (iii) equipping company facilities with designated rest areas; and (iv) conducting regular monitoring of compliance with sanitary and occupational health standards. OHS training requirements are determined by using an approved schedule, which factors in the results of regular inspections and internal audits. Line managers participate in OHS training once every three years, involving certified external OHS professionals. Line managers provide OHS training to retail store employees, with the support of the OHS manager. Under current legislation, retail store operations are exempt from mandatory workplace routine monitoring of occupational exposure factors for employees, such as noise, dust, and chemical exposure.
Contractor and third-party Management: The company adheres to responsible business practices, requiring all suppliers and contractors to comply with relevant legal obligations, especially those concerning the protection of workers' rights and the prohibition of discrimination, forced labor, child labor, and SEAH. The existing contractors of Umai are transport fleet companies that support the operations of the Project. An engineering, procurement and construction (EPC) contractor will be appointed for the LogoPark construction. Contractual agreements include a mandatory clause stipulating full adherence to the laws of the KR. As per ESAP #7, the company will update the legal agreements with the contractors and suppliers to include the code of conduct requirements (develop as per ESAP#4) and compliance with all applicable national regulations, particularly pertaining to working conditions and labor protections, and EHS incident reporting.. Umai will require contractors to report Umai EHS-related incidents and accidents during company operations, and will keep track of them as part of the OHS monitoring plan in line with ESAP #1.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: The primary source of electricity for warehouses and stores is the centralized power grid. The company is implementing technical solutions to reduce the consumption of electricity, water, and other resources. In particular, the company has incorporated resource conservation and energy efficiency measures in retail stores and warehouses both at the design stage and during day-to-day operations, such energy-efficient equipment, including refrigeration, water heating, household appliances, industrial equipment, and IT equipment; inverter air conditioners and energy-saving LED lighting; all equipment and lighting are turned off except for refrigeration units during non-working hours. The company records the water, electricity, and fuel consumption of its operation.
Air pollution/GHG emissions: The primary source of air pollution from retail stores and DCs is diesel generators, which are used exclusively as backup power sources and operate on an irregular and limited basis. The corresponding greenhouse gas emissions from the operations of the new retail stores and LogoPark, including the transportation fleet, will be monitored by the client in accordance with internationally recognized methodologies and good practices (ESAP #1).
Noise: The company uses diesel generators as backup power during outages. Occasionally, stores located within residential buildings receive noise-related complaints, which are handled according to procedures and followed by actions to reduce the impact on the community and environment. The company implements noise impact mitigation measures by installing noise shields and optimizing its distance from the residential buildings.
Water/Wastewater treatment: The company’s water supply is provided through connection to the centralized municipal water system operated by public utility services. The primary sources of sewage at the company’s facilities are sanitary and wastewater generated from kitchen and cafeteria areas. Wastewater disposal is through a centralized sewerage system (municipal sewer collector) in accordance with the applicable national regulations. No pre-treatment is performed at the company premises because the business activities do not generate wastewater containing toxic or hazardous substances. For the new supermarkets and stores with commercial kitchens, Umai will install grease traps in their kitchen in line with good international industry practice and dispose the collected grease in line with local waste regulations. The LogoPark will be designed and operated in compliance with the sewage authority’s acceptance criteria, WBG General EHS Guidelines, and GIIP requirements for the wastewater collection, treatment, and discharge (ESAP #8).
Hazardous Materials and Solid/Hazardous Waste Management: Hazardous materials are limited to cleaning chemicals and those used for maintenance, such as solvents, grease, and oil. Household chemicals and related products are stored in full compliance with applicable sanitary and fire safety regulations, in dry, specially designated areas with appropriate ventilation and safety controls in place. The chemicals used for pest control are applied by third-party certified companies and selected from food facility-compatible ones, which are in accordance with sanitary regulations and requirements.
As per ESAP#1, the Company will prepare a Hazardous Materials Management procedure for safe usage, storage, and handling, which will also promote the selection of environmentally friendly and non-hazardous materials.
The LogoPark will use the R1234yf refrigerant, the fourth-generation refrigerant, with low global warming potential. This will be used within closed-loop refrigeration systems. In the existing retail stores of the company, asbestos-containing materials (ACM) are not used. No asbestos-containing materials are used in the construction, renovation, or refitting of the company’s retail premises. The company adheres to responsible product handling practices and strictly complies with all legal requirements of the KR regarding the safe storage, use, and disposal of goods containing potentially hazardous substances.
The retail stores’ waste storage areas are not properly segregated for food waste, pallets and food packing. Due to limited areas, there is no clear demarcation between the waste storage area and new product stock area. The stores’ waste are collected and disposed of daily by licensed companies in compliance with the applicable sanitary and environmental regulations. As per ESAP #1, Umai will develop a waste management procedure for segregation, storage, recycling and disposal of all solid wastes, including damaged or expired products/food, packaging material, pallets, chemical containers to define practices and obligations of suppliers and Umai.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety/ Life and Fire Safety: The visited stores and warehouses have portable fire extinguishers, fire water pumps, hose reels, warning signage, alarm systems, smoke detection, and CCTV system. Improvements to the existing LFS design and practices of existing stores are necessary to meet GIIP. The company, as part of ESAP #1, will adopt an LFS commissioning plan in line with GIIP (e.g., United States National Fire Protection Agency Codes) for new stores and and engage a competent LFS expert to assist the company in its implementation (ESAP #3). The company will adopt the LFS criteria in the commissioning plan for screening locations of new stores. LogoPark LFS will be designed in line with the national requirements.
LogoPark will comply with the national construction and fire code of the KR and adopt the requirements of the LFS commissioning plan. The local State Fire Safety Authority will review the technical specifications for the LFS systems and emergency planning during the certification and permitting process for the facilities.
Traffic Management: The Umai's own fleet is primarily responsible for delivering goods from the distribution centers and production facilities to retail stores. Three outsourced transport providers are used as needed, particularly during periods of seasonal demand, increased delivery volumes resulting from promotional activities, or when shipment volumes fluctuate significantly. Umai also engaged a main transport contractor that handles Umai’s importation requirements. Umai's existing agreement with the contractor has limited E&S performance provisions. The company has internal regulatory documents, including the Instruction on Occupational Health and Safety for Motor Vehicle Drivers and internal procedures for the registration and monitoring of road traffic accidents. However, there is no documented procedure in place to address potential road safety risks to communities. As per ESAP#1, the company will develop a transport safety program, which will include guidelines for drivers on traffic safety and defensive driving to minimize safety risks of communities within the vehicle routes. The company will also provide comprehensive training to both existing and newly hired drivers and security personnel on the company’s policies, regulations, procedures, and grievance mechanism, with a particular focus on addressing issues such as discrimination and SEAH.
Security Services: At Umai, unarmed security personnel are employed in-house as company staff at select retail stores and other designated facilities. At the LogoPark facility, unarmed security services are provided by a third-party licensed security company under a formal service agreement. Umai developed working instructions for security personnel, and security staff are trained for communication and defensive use of force. There is CCTV monitoring in addition to other electronic security systems, including alarms, especially for night shifts
PS5 Land Acquisition and Resettlement
Umai's Development Department is responsible for selecting store locations and negotiating lease agreements with property owners, which include terms such as rent, lease duration, repairs, and other relevant conditions. The land designated for LogoPark has been leased from the government, having previously been leased to another company. This project aims to connect to the existing railway operated by the Gazprom company, facilitating the transportation of materials to LogoPark. The land area required for the railway connection falls under the jurisdiction of the railway authority. An agreement between LogoPark and the railway authority will be finalized to allow for the connection. The existing land arrangement for the retail stores and LogoPark do not entail land acquisition or livelihood impact that will trigger IFC PS5 requirements.
The borrower plans to construct an access road to connect LogoPark to the existing municipal road. The access road is in the early design stage but is projected to be approximately 2.35 kilometers long. Initial assessment indicated that there are two non-residential structures that may be affected by the proposed access road. The land between the municipal road and LogoPark area is owned by the land transportation authority and is currently designated as agricultural area. The authority has an existing lease agreement with one of the structure owners, permitting pasture use only, and no permanent structures are established on the land. No crops were noted during the appraisal visit. LogoPark has been in discussions with the land authority regarding the access road. The authority has decided to offer alternative land for the lessee who owns one of the existing structure. Additionally, LogoPark has hired a third party to evaluate the market value of the structure, and an estimated compensation amount has already been agreed upon with the structure owner. As per ESAP#9. the Borrower will engage a resettlement specialist to consult with the structure owners and other land users to evaluate further and confirm the potential impacts of the access road on the existing structures and livelihood of existing land users. The resettlement specialist will assess the adequacy of the process undertaken and the proposed compensation by the land authority and LogoPark to the lessee if its in line with PS5 requirements. If any gaps are identified in the assessment, the Borrower with the assistance of the resettlement specialist will prepare Supplementary Resettlement Action Plan to ensure that compensation is aligned with IFC PS5 requirements,
Stakeholder Engagement
Umai stakeholder engagement activities are currently limited to retail stores that are located in residential buildings, where Umai holds consultations with the Homeowners’ Associations officers of the buildings before signing an agreement. All retail stores, including standalone ones, have a customer feedback system that consists of various communication channels, such as contact numbers, digital or social media reporting, and forms available at the store entrance or directly delivered to the store manager. The data gathered are consolidated and addressed by the store team. Umai also has shared company related news to its customers a through the media section of its website.
As per ESAP #1, the project will develop a SEP in line with PS1 requirements, which will include an external grievance mechanism and formal procedures for managing community complaints. LogoPark will conduct community consultations as part of the ESIA preparation and engage with the structure owner along the project access road route in line with PS1. It will also create a site-specific SEP to for the facility as per ESAP #2.
As per ESAP #1, the project will develop a SEP in line with PS1 requirements, which will include an external grievance mechanism and formal procedures for managing community complaints. LogoPark will conduct community consultations as part of the ESIA preparation and engage with the structure owner along the project access road route in line with PS1. It will also create a site-specific SEP to for the facility as per ESAP #2.
720048 Kyrgyz Republic, Bishkek, Valikhanov str., Building 16
Broad Community Support
Broad Community Support is not applicable for this project.
Environmental & Social Action Plan
| S.no | Description | Anticipated Completion Date |
|---|---|---|
| 1 | a. LogoPark will develop a project Environmental and Social Management System (ESMS) to manage the impacts of its distribution centers (DC) and fleet operations in line with IFC Performance Standards (PS) requirements. This will include: (i) an overarching E&S policy committed to compliance with IFC PS, and approved by LogoPark Senior Management and communicated to all employees; (ii) a contractor management plan (CMP) in line with IFC’s good practice note on Managing Contractors’ Environmental and Social Performance and IFC PS and WBG EHS Guidelines. This will include legally binding conditions in the contract with the EPC contractor to comply with IFC PS;(iii) Emergency Response Plan to cover all emergencies (e.g. earthquakes, natural calamities, terrorism etc.) | 03/15/2026 |
| 2 | An overarching stakeholder engagement plan (SEP) in line with PS1 requirements for managing external grievance mechanism and formal procedure for managing complaints from the community. | 03/31/2026 |
| 3 | b. Umai will develop a project Environmental and Social Management System (ESMS) to manage the impacts of its retail stores and fleet operations in line with IFC Performance Standards (PS) requirements. This will include: (i) an overarching E&S policy committed to compliance with IFC PS, and approved by Umai Senior Management and communicated to all employees; (ii) screening procedure to identify the potential E&S risks of new developments, including land acquisition for standalone stores, and Life and Fire Safety (LFS) design considerations of stores located within existing structures; (iii) a contractor management plan (CMP) in line with IFC’s good practice note on Managing Contractors’ Environmental and Social Performance and IFC PS and WBG EHS Guidelines. This will include legally binding conditions in the contract with the EPC contractor to comply with IFC PS;(iv) E&S operations phase environmental management plan and monitoring procedures including but not limited to OHS, hazardous materials management, waste management, resource efficiency, greenhouse gases emissions, in line with WBG General EHS Guidelines in terms of scope, roles, key performance indicators (KPI);(v) updated Emergency Response Plan to cover all emergencies (e.g. earthquakes, natural calamities, terrorism etc.);(vi) Transportation safety program which will include guidelines for drivers on traffic safety and defensive driving to minimize safety risks of communities within the vehicle routes. The company will also provide comprehensive training to both existing and newly hired drivers and security personnel on the company’s policies, regulations, procedures, and grievance mechanism, with a particular focus on addressing issues such as discrimination and SEAH; and(vii) an overarching stakeholder engagement plan (SEP) in line with PS1 requirements for managing | 03/31/2026 |
| 4 | A LFS commissioning plan that will be adopted from the project design stage to operations of each new retail stores | 02/28/2026 |
| 5 | LogoPark will prepare an Environmental and Social Impact Assessment (ESIA) and construction and operations phase management plans, including the monitoring requirements, following the IFC Performance Standards and WBG EHS Guidelines. The assessment will identify and manage impacts within the facility's area of influence, including the access roads connected to the municipal road and the railway connection. The ESIA will incorporate a climate risk assessment and will serve as the basis for further considerations in the final design of the facility. The LogoPark will be designed and operated in compliance with WBG General EHS Guidelines, and GIIP.LogoPark will conduct community consultations as part of the ESIA preparation and engage with the structure owner along the project access road route in line with PS1. It will also create a site-specific SEP. | 02/28/2026 |
| 6 | LogoPark will prepare an Environmental and Social Impact Assessment (ESIA) and construction and operations phase management plans, including the monitoring requirements, following the IFC Performance Standards and WBG EHS Guidelines. The assessment will identify and manage impacts within the facility's area of influence, including the access roads connected to the municipal road and the railway connection. The ESIA will incorporate a climate risk assessment and will serve as the basis for further considerations in the final design of the facility. The LogoPark will be designed and operated in compliance with WBG General EHS Guidelines, and GIIP.LogoPark will conduct community consultations as part of the ESIA preparation and engage with the structure owner along the project access road route in line with PS1. It will also create a site-specific SEP. | 06/30/2026 |
| 7 | LogoPark and Umai to designate an environmental and social officer to manage the broader E&S issues of the project and compliance with IFC PS. The officer will be supported by a life and fire safety (LFS) expert to assist the project’s LFS to be compliant with Good International Industry Practices (GIIP). The project will also appoint a GBVH focal person in the HR team, who has the capacity and experience to handle and investigate sensitive cases. The focal person will undertake specialized training for investigating allegations of discrimination and SEAH and lead the implementation of the anti-sexual harassment policy and relevant procedures. | 05/31/2026 |
| 8 | a. LogoPark to develop HR policies and procedures following the national and local legislations and IFC Performance Standards 2 requirements on Labor and Working Conditions. | 06/15/2026 |
| 9 | b. Umai to update the HR policies and procedures to include the following:(i) work schedule and payment, including:(a) work shift schedules in the company and corresponding allowable working hours; (b) rules for salary calculation including differentiation of the overtime and night differential; (c) record keeping of workers consent on overtime; and (d) applicable work schedule for the different types of workers (e.g., women with children, pregnant, persons with disability) as per local Labor Law. (ii) strictly prohibit child and forced labour, discrimination, and foster gender equality; (iii) develop a sexual exploitation and abuse, and sexual harassment (SEAH) policy and implementation plan;(iv) develop a code of conduct for employees, contractors, third-party, suppliers to prohibit discrimination and SEAH, and that provides for disciplinary measures in case of violations; (iv) updated onboarding materials to inform workers of their collective bargaining rights; and(v) provide training to all direct and contracted workers on the HR policies and procedures, particularly on discrimination and SEAH, during their initial induction and periodically thereafter. | 05/15/2026 |
| 10 | LogoPark to prepare a Workforce Relocation Plan, including retrenchment plan in line with PS2 requirements, to ensure that the existing DC workers will be provided with the necessary guidance to protect their rights and benefits as part of the company’s decision to transfer workers to the LogoPark or retail stores. This plan is to also include provisions for the workers who are not willing to continue to move due to personal limitations. | 02/28/2027 |
| 11 | a. LogoPark to develop a Grievance Redress Mechanism (GRM) in line with IFC PS1 and include (i) turnaround time for addressing grievances, escalation procedures, and mandatory logs and (ii) a specific and accelerated pathway for sensitive issues, such as discrimination and SEAH, providing multiple reporting options (in person, writing, online, phone and anonymous). It will also identify and provide accessible referral pathways for complainants, accessible to all workers. | 03/31/2026 |
| 12 | b. Umai to develop a Grievance Redress Mechanism (GRM) be improved in line with PS1 and to include (i) turnaround time for addressing grievances, escalation procedures, and mandatory logs for retail stores, and (ii) a specific and accelerated pathway for sensitive issues, such as discrimination and SEAH, providing multiple reporting options (in person, writing, online, phone and anonymous). It will also identify and provide accessible referral pathways for complainants, accessible to all workers. | 04/15/2026 |
| 13 | Umai to update the legal agreements with the existing and new contractors and suppliers to include the code of conduct requirements (develop as per HR policies, ESAP #4b) and compliance and compliance with all applicable national regulations, particularly pertaining to working conditions and labor protections, and EHS incident reporting. | 09/30/2026 |
| 14 | a. Umai, new supermarkets and stores with commercial kitchen will install grease traps in their kitchen in line with good international industry practice and dispose collected grease in line with local waste regulations. | 04/30/2026 |
| 15 | b. The LogoPark WWTP will be designed and operated in compliance with the sewage authority’s acceptance criteria, WBG General EHS Guidelines, and GIIP requirements for the wastewater collection, treatment, and discharge | 03/15/2026 |
| 16 | LogoPark will engage a resettlement specialist to consult with the structure owner and other land users to evaluate further and confirm the potential impacts of the access road on the existing structure and livelihood of existing land users. The resettlement specialist will assess the adequacy of the process undertaken and the proposed compensation by the land authority and LogoPark to the lessee if its in line with PS5 requirements. | 02/28/2026 |
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.
For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.
Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.
IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.
Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.
Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.
Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.
Complaints can be submitted by any of the following methods:
- Online form: available at https://www.cao-ombudsman.org/
- Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
- Voice mail: +1 202 458 1973
- Email: cao@worldbankgroup.org
- SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627
CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).
The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.