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
While GHG’s E&S Policy provides an overarching framework for the environmental and social assessment and management of all its activities, including those at the assets that will benefit from the bond, it currently lacks other elements of a corporate ESMS to provide oversight of its subsidiaries’ functioning. As per ESAP#1 GHG will review and strengthen its corporate ESMS to enable a more functional enforcement at subsidiary level. Several CMC specific operational procedures do however apply at that asset level and have recently been enhanced as part of its current JCI accreditation, widely recognized as the most comprehensive benchmark for patient care and safety processes in the health care industry. The current CMC procedures will apply to the operations of the new oncology unit, to be constructed adjacent to the CMC. As per ESAP#2 the borrower will receive JCI accreditation at the new oncology facility.
The national permitting process is currently underway and no environmental impact assessment is anticipated to be needed for the new oncology facility. As part of this process, regulatory permits and licenses will however be required for the operation of all the equipment purchased through the bond as well as adherence to applicable E&S related laws and regulations, including those relating to labor. These requirements, together with the CMC procedures which will be applied at the new oncology facility, will address the E&S risks and management measures as required to meet national requirements for the operational phase of the project. As per ESAP#3 the borrower will therefore identify, and obtain, all the necessary E&S and equipment related permits and licenses, and create a register of applicable E&S related laws and regulations, and provide evidence of their validity. Specific actions to address potential gaps with IFC PS requirements are outlined in the following sections and relate primarily to management of risks during construction, the handling of radioactive materials and waste associated with cyclotron operations including during unplanned or emergency situations, and to exposure to radiation from the equipment purchased through the bond
The E&S impacts and risks occurring during construction of the new oncology facility are not covered by the current management procedures, which focus rather on operational activities. As per ESAP#4 a standalone project specific Construction Management Plan (CMP) will be developed by the borrower, or in their behalf by the specialist healthcare construction management company who will oversee that activity, with adherence to that plan being a condition of the construction contract. The CMP will describe in a comprehensive and structured manner the various E&S risks and controls to be applied during construction, to comply with IFC and national requirements. These will include, but not be limited to: labor, working conditions and worker grievance mechanism; OHS; pollution prevention, waste management, water supply and waste water management; disturbance to ongoing operations at the CMC and megalab, traffic management, controls of infection spread, fire, and emergency events, and stakeholder engagement. The CMP will also define roles and responsibilities for its implementation, processes for capacity building and training, including if necessary of the CMC Facility Management and Security (FMS) team member with construction E&S oversight responsibilities. It will set out how its requirements will be addressed in the contractor selection process and contract documentation, and establish monitoring and reporting requirements and specific KPIs to be applied, including those relating to OHS performance. As per ESAP #5 compliance with the CMP will be included in the construction contractor's contract.
CMC’s Emergency Response Plan (ERP) identifies the main emergency events as: fire, earthquakes, severe hailstorm, internal spread of pandemics, radiation and medical gas. For each it sets out measures to be applied to their prevention, preparedness, response and recovery. An Emergency Preparedness Plan (EPP) addresses patient care during events resulting in mass casualties, while a number of further procedures cover specific emergency related protocols and responsibilities. To enable the CMC ERP to be applied to the new oncology unit, as per ESAP#6 it will be updated to address any additional emergency risks (e.g. those resulting from handling of radioactive material) not currently covered by the plan. The update will also include a section on patient safety, mobilization and evacuation procedures during emergencies, align its fire related measures with IFC LFS requirements addressed under ESAP#9 and refer as appropriate to the CMC EPP and emergency procedures to provide an integrated and consistent approach. Emergency planning and response requirements during construction will be addressed under ESAP#4 within the CMP.
The head of personal administration and organizational development within the Vian business has overall responsibility for HR and H&S matters at CMC, while that for E&S performance is outsourced to an external E&S Advisor. Supported by the CMC Operations Director they provide oversight of CMC staff within the Facility Management and Security (FMS) team responsible for infection control, radiation, fire safety, waste, pollution control and hazardous materials management etc., within the Quality and Safety Team responsible for OHS performance and of an HR Director. These individuals, if necessary supplemented by additional coordinators will assume similar responsibilities at the oncology facility, once it is operational. To address specific risks associated with design and operation of the cyclotrons at the new oncology facility GHG has also secured the services of an internationally qualified radiation safety officer. A safety committee reviews and updates the H&S related policies every three years or when necessary, and reviews all proposed or existing programs to ensure they meet relevant standards.
CMC FMS team will be responsible for the construction of the new oncology facility, with supervision provided by the CMC Operations Director’s team. As GHG does not have in-house capacity for managing construction, including its associated E&S and OHS risks, it will appoint a specialist healthcare construction management company to undertake this function on their behalf. As the IFC requires its borrowers to be responsible for ensuring that their contractors are aware of and meet IFC’s Performance Standards relevant to their activities, GHG will under ESAP#4 identify an individual, within the CMC FMS team that will be responsible for E&S oversight of the construction management company and as necessary the construction contractor including as per ESAP#5 ensuring relevant sections of the CMP are included in contractors’ contracts and, verifying the appropriate implementation of the CMP Plan and delivery of the mitigation measures defined in it. GHG will ensure that this nominee will have, or receives, the required training in developing the required competencies in this respect, and the resources and support to fulfil this function.
CMC collates E&S and OHS data. These relate mainly to patient and staff safety (e.g. radiation exposure, infection control, medication errors, accidents incidents and near misses etc) which are collated on an online platform and are subject to root cause analyses by a dedicated team and discussed at various committees. Data is also collated relating to: fuel and water consumption, waste generated, volumes and quality of discharged water, employees by gender, training records and patient satisfaction. As per ESAP#4, during construction E&S monitoring and reporting against KPIs, including those relating to accidents and incidents, will be undertaken.
The E&S and OHS management systems proposed to be applied during project operation were noted to be generally commensurate with the scale and E&S risks and impacts of the project, and their current implementation at the CMC considered to be robust. However, since construction is not part of GHG’s core business some enhancement of the CMC ESMS to address this activity as well as to address risks associated with the handling of radioactive materials generated by the cyclotron is required as outlined further below.
PS2: Labor and Working Conditions
Once operational, the new oncology unit will employ approximately 30 staff, including 12 transferred from the current CMC oncology facility that will be closed. CMC currently has 1069 employees and has well documented policies that align with the Georgian Labor Code Labor Code (Law No. 4113) and the Trade Unions Law (Law No. 617) which generally align with IFC PS2 requirements.
CMC’s Employee Corporate Handbook, which will be adopted by the new oncology facility, applicable both for construction and operation, outlines key policies and procedures relating to working conditions including those relating to recruitment, wages and benefits, performance evaluations, disciplinary measures, working hours and entitlements such as leave and vacation, provisions for prevention and management of workplace sexual harassment and for workplace occupational and fire safety. It also includes a Code of Conduct (CoC) which prohibits any form of discrimination, and sexual harassment. All new employees are required to review and sign the handbook confirming their understanding of institutional expectations and procedures. As per ESAP#7CMC will revise its Employee Handbook and Code of Conduct to more comprehensively address gender-based violence and harassment (GBVH), as well as child protection and safeguarding (CPS). The update will include the establishment of a dedicated grievance procedure for GBVH and CPS, comprising a separate channel and a dedicated focal point for handling cases. It will also provide options for anonymous reporting, referral pathways and training for all direct and contracted workers during their induction and annually thereafter. The updated Handbook will also include a requirement for contracted workers to be screened for past cases of abuse or violence, particularly child abuse.
CMC has a suite of OHS related standards and procedures including those relating to: infection control, hazardous materials and waste; emergency management; fire safety; laser safety; medical and compressed gas; radiation and diagnostic imaging and workplace and patient violence, which will be applied to the new facility. Additional measures required to address safe handling of nuclear medicine and equipment and radioactive materials as well as exposure to radiation at the new facility will be implemented under ESAP#8.
Onboarding training for all new employees, delivered by the HR department, within 90 days of their start date covers: (1) HR policies, (2) quality and patient safety, (3) infection prevention and control, and (4) facility management and safety protocols. Further periodic training is organized for all employees based on identified needs, and includes professional skills improvement, fire safety (annually) and prevention of sexual harassment (SH).
The CMC procedure for Handling Staff Complaints, Dissatisfaction and Conflict Resolution will be extended to the new oncology facility. It enables all employees to submit complaints, including anonymously, online through an internal webpage or offline at the HR office, with an escalation procedure in place if these cannot be resolved informally. The process respects confidentiality with complainants being notified about final decisions within a defined timeline and records of all grievances being maintained by the HR department. The HR department also provides an additional platform for employee feedback via quarterly satisfaction surveys with the results being reviewed to identify areas for improvement.
As per ESAP#4 the CMP will specify measures to be applied during construction to comply with PS2 including those relating to: labor and working conditions, non-discrimination and fair treatment of construction workforce including migrant workers, prohibition of child and forced labor, provision of a worker’s grievance mechanism including GBVH and CPS provisions (accessible to both direct and subcontracted contractors), rights to freedom of association and collective bargaining, and OHS plans. The training requirements will include those relating to safety, labor rights, and SEAH prevention, while monitoring, reporting and contractor accountability measures will include those relating to incidents and accidents. The CMP will also implement the Georgian law, requirements for an on-site dedicated Health and Safety officer.
As per ESAP#8 the other assets benefitting from the bond will if required enhance their OHS-related procedures to address any new risks to the workforce, relating to radiation exposure that may arise from operation of the MRI, CT scanners and LINAC financed under the bond.
PS3: Resource Efficiency and Pollution Prevention
Owing to the use of electric boilers to supply hotwater and heating and the fact that ~80% of the national grid electricity mix is sourced from hydropower , the annual Scope 1 and 2 GHG operational emissions are expected to be 513.5tCO2e per year .
As there will be no gas boilers, the main sources of external air pollution from the new oncology unit are limited to ventilation of medical gases and fugitive emissions from sources such as medical waste storage areas, isolation wards and chemotherapy vapors and aerosols generated during drug preparation and administration. These will be handled through a combination of enclosed negative pressure rooms use of specialized equipment and filters. There will be no on-site incineration.
Domestic water will be provided through the existing CMC groundwater source, with the volumes required being covered by the current permit, and treatment provided at the current CMC facility. A connection to the municipal supply will be used during periods of maintenance of the groundwater supply system, or any shortfall in groundwater availability. Drinking water will be provided via water dispensers connected to the mains water supply. Domestic wastewater from showers, basins and toilets excluding special waste (e.g., blood and blood products, infectious waste, chemicals, radioactive wastes, which will be subject to the CMC waste management plan described below), will be discharged to the municipal system via the existing CMC waste water treatment plant which operates in compliance with the discharge permit conditions. The wastewater discharge quality is regularly monitored.
As per ESAP#3 the borrower will ensure respectively that the relevant permits for water abstraction and wastewater discharge to the municipal facilities are in place and that the anticipated discharges will be in line with national and WBG standards.
The CMC waste management plan, updated in 2025, will apply to the operation of the new oncology unit. It categorizes the different wastes generated, based on their nature, hazard classification, dangerous characteristics etc., quantifies amounts generated and establishes specific procedures for each including, on-site collection, segregation, storage, transportation, treatment and disposal, and specifies the authorized contractors and requirements for record keeping. The CMC waste storage facilities are currently operating at 40% capacity, so it can accommodate the additional waste generated by the new oncology unit. As per ESAP #8, the CMC waste management plan will be updated to identify and address any additional waste streams (e.g. radioactive waste) generated at the oncology unit that are not addressed in the current plans. Construction waste will be addressed through ESAP#4.
The CMC Hazardous Materials Procedure and Safe Handling of Hazardous Materials Procedure set out requirements for safe control of such materials including through use of safety data sheets, personal protective equipment, storage, and labelling standards as well as measures during transportation, provision for training, spill prevention and response, documentation, record keeping and responsibilities. This will also be updated under ESAP#8to identify and address additional hazardous materials that will be handled at the new oncology facility.
PS4: Community Health, Safety and Security
The company has engaged specialized architecture and engineering design consultants and equipment suppliers, with recognized experience in healthcare, local regulations and international best practice, to both specify and source the cyclotrons, and accommodate them in a facility that protects the safety and wellbeing of its patients, staff, visitors, and nearby communities. The building design has also been subject to review by both the International Atomic Energy Agency and Varian (the supplier of the cyclotrons) and will comply with Georgian and international structural, seismic, radiation and fire safety codes and measures,
The numerous procedures and practices that apply at CMC to protect patients’, staff and visitors’ health and safety and patient quality of care will also apply to the new oncology unit. These include practices relating to: facilities management and safety; prevention and control of infections; patient centered care and rights; protection of newborns and children from abduction, and emergency preparedness and response. Most measures to address any additional risks at the oncology facility (notably those associated with operation of the cyclotron) will be implemented as part of its regulatory compliance under ESAP#1 as well as the updates to procedures undertaken under ESAP#8. Further actions required to achieve alignment with IFC PS4 are outlined below.
A review of the design of the new facility undertaken as part of the appraisal included consideration of (i) the ability of the new facility’s fire protection systems to be fed from the existing CMC system, (ii) provision of fire sprinkler systems (iii) fire rated enclosures of staircases and other vertical openings (e.g., shafts, atriums),(iv) the nature of the connection between the existing hospital and the new oncology center. This established that its LFS provisions align with those of the WBG General EHS Guidelines, Under ESAP#9 a further IFC review will be undertaken, if required on-site, during the facility commissioning process to determine whether construction of its LFS systems has been carried out in accordance with the accepted design and relevant WBG Guidelines.
As per ESAP#7 the Employee Handbook and Code of Conduct will be updated also to prohibit direct and contracted workers from engaging in offensive behaviors, including GBVH and CPS, against patients and users. As per ESAP#10 CMC will establish a grievance mechanism for patients and users in alignment with PS4, which will include GBVH controls and CPS measures, as well as related awareness raising initiatives and referral pathways. The grievance mechanism will be integrated into a broader Stakeholder Engagement Plan (SEP), ensuring culturally appropriate and accessible communication with all affected parties. Provisions for anonymous reporting will be included, and a system for monitoring and evaluating the mechanism's effectiveness will be established.
Security at the new facility will be provided by the existing CMC security workers who are unarmed and whose main role is to regulate access to the facility. As the oncology facility will handle a small number of patients compared to those attending the CMC, its relative contribution to site activities including traffic generation will be minimal and no additional impacts on the health, safety and security of the local community beyond those identified above are expected during its operation. As per ESAP #7 security providers will be provided training addressing also GBVH and CPS.
During construction of the oncology unit, the adjacent CMC and megalab will continue to operate and there is thus potential for construction related disruption to their functioning and disturbance to their patients, visitors and nearby communities, including through construction related traffic, as well as specific risks from fire or infections spreading between the facilities under construction and the adjacent CMC hospital. As per ESAP#4 and ESAP#9 the CMP and LFS reviews/Infection Control Risk Assessment) (ICRA) will address such risks.
As per ESAP#8 the other assets benefitting from the bond will if required enhance their OHS-related procedures to address any new risks to patients and visitors and local communities relating to radiation exposure that may arise from operation of the MRI, CT scanners and LINAC financed under the bond.
