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

Neither land acquisition and involuntary resettlement, biodiversity conservation, indigenous peoples or cultural heritage have been identified as being relevant and therefore PS5, PS6, PS7 and PS8 were not triggered. All projects are located in urban areas.

If IFC's investment proceeds, IFC will periodically review the project's ongoing compliance with the Performance Standards.

This is a Category B project as per IFC's Environmental and Social Sustainability Policy, as the project activities have potential limited adverse E&S risks and impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures.

Key E&S aspects and potential risks associated with the project are: (i) Group’s ability to identify and avoid/manage/mitigate E&S risks related to construction & operation of the assets; (ii) labor and working conditions both for construction and operations stage, including compliance with local labor codes, rights of migrant workers, freedom of association (FoA), gender-based violence and harassment (GBVH), child protection and safeguarding (CPS) non-discrimination, grievance mechanism, (iii) occupational health and safety (OHS) especially during construction; (iv) potential labor influx due to use of immigrant workers in Iraq; (v) life and fire safety design and operations (vi) waste management and disposal for the healthcare facilities; (vii) community and users health and safety, including GBVH and CPS; and (vii) stakeholder engagement and community grievance mechanism.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts

Policy

Estithmar Holding has adopted a corporate Sustainable Governance Policy (that consolidates the Group’s commitments to environmental stewardship, occupational health and safety, sustainability and social responsibility with reference to international standards (ISO 9001, 14001, 45001) and generally consistent with IFC PS.

The policy applies to all subsidiaries, projects, and contractors, and sets out Estithmar’s commitment to pollution prevention, efficient resource use, safe and healthy workplaces, and equitable labor practices.

Apex Group have also developed complementary ESG frameworks aligned with IFC PS and applied at all the hospitals they operate. Apex’s Environmental Sustainability Policy and Sustainable Procurement Policy promote resource efficiency, and waste minimization, while maintaining health-care-specific safety measures and emergency preparedness procedures.

IFC also reviewed the hotel operator’s E&S policies as future operator of the hotel and have observed that the hotel operator has adopted group-wide sustainability and social responsibility policies, including the hotel operator’s sustainability policies which outline commitments to legal compliance, climate action, resource efficiency, biodiversity protection, non-discrimination and fair labor practices, guest health and safety, food safety, children’s rights, responsible procurement, and community engagement overall aligned with IFC PSs.

Environmental and Social Management Systems

Estithmar’s Sustainable Governance Policy functions as an E&S management framework which guides the E&S management systems among the business units. ESG performance is monitored through the ESG Business Unit Initiatives Tracker and Apex Group’s Geneva Sustainability Initiative reporting platform. Environmental and social responsibilities are distributed across different departments mainly driven by the E&S teams in business units, with external ESG advisory support where needed.

Apex Group sustainability strategy has four pillars - Responsible Business, Environmental Protection, Positive Social Impact, and Governance, Integrity & Risk Management - which collectively set long-term goals, actions, and KPIs for operationalizing sustainability across its healthcare facilities and articulated a group-wide ESG Strategy (2025–2030) that strengthens its environmental and social management approach.

Existing arrangements provide partial E&S oversight but are not integrated into a unified system for risk identification, screening, monitoring, and reporting at group level. As per ESAP#1, Estithmar will develop and implement a corporate-level Environmental and Social Management System framework proportionate to its operations and consistent with IFC PSs. Apex and Estithmar Ventures will update their ESMS in line with the corporate framework and IFC Performance Standards (PSs).

Furthermore as per ESAP#2, Estithmar will require the operator to develop and implement an operational ESMS for the hotel consistent with the requirements of IFC PSs and the ESIA.

Identification of Risk and Impacts

Estithmar has commissioned Environmental and Social Impact Assessments (ESIAs) for both the hotel and hospital projects in line with applicable national regulatory requirements and the IFC PSs, disclosed along with this ESRS. The ESIAassessed projects’ environmental and social risks and impacts across the construction and operational phases, including resource efficiency, pollution prevention, waste and wastewater management, land-use considerations, labor and working conditions, and community health, safety and security. As per ESAP #3, the Construction and Operational Environmental and Social Management Plan (CESMP) of project will be updated in alignment with the mitigation measures outlined in the ESIA.

Management programs, Monitoring and Review

Environmental and social risks are managed primarily through project-level plans implemented by contractors and business units.

As the construction has already started for Baghdad Hotel, UCC has prepared and implemented Construction EHSS (Environment, Health, Safety and Social) management plans consistent with IFC PS which identifies site-specific risks and mitigations in a comprehensive manner, as well as monitoring and reporting mechanisms including submission of monthly Health, Safety and Environmental (HSE) reports to the corporate HSE of UCC and monthly reports on working conditions to the Workers’ Welfare Committee of UCC, chaired by HR.

During visits to the construction site in Iraq, IFC observed generally good implementation of HSE plans covering inductions, toolbox talks, worker training, inspections, and site-level monitoring of environmental and occupational health parameters which also cover the sub-contractors. However, consistent with findings from the independent labor and OHS audits, IFC identified gaps in the effectiveness and consistency of implementation across subcontractors, particularly in relation to OHS risk assessment and control of high-risk activities, including electrical safety, work at height, work permits and other critical OHS hazards as described under relevant sections in PS2.

Apex hospitals apply standard operating procedures (SOPs) on infection control, waste management, emergency response, and corrective action tracking.

At corporate level, Estithmar has an ESG Committee, chaired by the CEO and composed of senior executives from Operations, HR, Engineering, Supply Chain, Quality & Patient Safety, and Finance, reviewing E&S performance based on business unit trackers. Energy performance is monitored through independent audits. Apex facilities undergo internal and third-party EHS audits, including periodic audits by JCI (Joint Commission International) which also cover EHSS topics.

As per ESAP #4, Estithmar will adopt a consolidated monitoring and review procedure for the project including key EHSS indicators covering all sub-contractors, audit frequency, and management review arrangements.

Organizational Capacity and Competency

Environmental and social management is overseen by an ESG Committee chaired by the CEO and composed of senior representatives from HR, Supply Chain, Finance, Engineering, and Quality & Patient Safety. The committee supervises policy implementation, regulatory compliance, and performance monitoring through quarterly reports and an annual sustainability report.

UCC has competent teams covering environmental, social, health and safety issues at the construction sites, supported with frequent visits by their HQ.

Apex has a corporate sustainability manager and QHSE manager working closely on managing the E&S standards for all group hospitals. As per ESAP #5, Estithmar will appoint a qualified E&S officer at corporate level, with clear reporting lines and escalation procedures to the ESG Committee, to monitor compliance of the project in line with IFC PSs and to oversee the implementation of the corporate ESMS.

E&S Contractor Management

Estithmar manages environmental, health and safety performance of contractors through prequalification, contractual, and monitoring processes applied at both corporate and project levels. Contractor selection includes evaluation of compliance with labor, OHS, and environmental standards, as well as verification of legal registration, certifications (e.g., ISO 14001, ISO 45001), and past performance. E&S clauses are incorporated into contracts covering labor standards, OHS practices, waste management, and audit rights. Apex E&S management system reflects same requirements for contractors.

For the construction sites, although UCC’s CESMP requires cascading the E&S requirements to sub-contractors, existing sub-contractor training, monitoring processes covering health, safety and labor requirements need to be strengthened in line with IFC PS. As per ESAP#6, a sub-contractor training and monitoring procedure will be adopted for the Baghdad Hotel construction site as part of CESMP, which will expand the frequency and scope of the current trainings and will include monitoring and internal auditing arrangements in line with IFC PS with a specific focus on management of labor and working conditions to be in line with PS2. This will include monthly reporting on the outcomes (any non-compliances and actions taken) to Estithmar and immediately for any significant E&S events (fatal accidents, fire, significant labor non-compliance and labor strikes). The monthly E&S reports will also be submitted to IFC during the construction period.

Emergency Preparedness and Response Plan (EPRP)

Emergency preparedness is managed at both corporate and project levels. Apex hospitals maintain emergency response procedures addressing incidents such as fire, medical emergencies, hazardous materials handling, and external disaster scenarios. Regular drills are conducted, including fire and evacuation exercises and simulated disaster responses coordinated with the National Command Center. Spill kits, first-aid stations, and emergency equipment are maintained at all healthcare sites.

UCC has prepared Construction Emergency Preparedness and Response Plans for Baghdad hotel that include hazard identification, define responsibilities, training requirements, and procedures for communication and evacuation. These plans are integrated into construction health and safety management systems and verified through periodic inspections and drills. UCC will develop similar plans for the worker accommodation sites as described in the relevant section below under PS2.

The operational emergency response and preparedness arrangements for the Baghdad hotel is included under PS4 section.
PS 2 – Labor and Working Conditions
Estithmar Group has over 28,000 direct employees divided into different subsidiaries. Apex, which is the healthcare arm of Estithmar employs over 2,000 employees and Elegancia Services mechanical and technical manpower subsidiary of Estithmar, providing support to construction and industrial projects has around 23,000 direct employees mainly coming from India, Bangladesh, Nepal and Egypt.

The hotel construction site in Baghdad employs over 3,000 workers at peak coming from 25 different countries, over 2,600 directly hired under UCC and Elegancia Services and the rest of the workforce coming from local specialized contractors. Once in operations, the employment is expected to reach around 650 (targeting 50% women) through direct hires.

IFC has conducted contextual labor risks screening including workers’ rights to unionize in the project countries and company’s labor performance in past projects. 2022 World Cup construction works have been a notable period for Estithmar Group and UCC. The group companies have undergone various independent labor audits during this period and strengthened their labor and working conditions policies and practices in Qatar, in line with the international standards. IFC’s appraisal for the project identified that lessons learned from this experience needs to be applied to Estithmar’s new site in Iraq.

Human Resources Policies, Terms and Conditions of Work

Estithmar has a group level HR policy, cascaded to group’s business units (including Apex, EWS and Estithmar ventures), including requirements for contractors and suppliers. The policy promotes employee health and wellbeing, inclusion and equal opportunities. The HR Department is in charge of oversight, ensuring that the group operations adhere to all the applicable laws and regulations of the country where the employee is working and required to promptly rectify any instances of non-compliance reported within the Group.

The labor and working conditions management is mainly led by UCC teams at Iraq construction site, with oversight from UCC’s corporate HR. This includes review of sub-contractor working conditions focusing mainly on OHS (onboarding, PPE etc.) timekeeping, information and awareness raising on HR policies, grievance mechanism and management of worker accommodations. UCC oversight on sub-contractors would need to expand to cover the full scope of PS2, on working time and overtime management, consistent pay controls, grievance mechanisms and non-retaliation, non-discrimination prevention, access to medical care, and systematic subcontractor auditing and corrective action follow-up, as indicated under ESAP#6.

As per the HR policy of Estithmar, all group entities are mandated to establish workers welfare committees at each workers' accommodation site. These committees are aimed to serve as a platform to address workers' concerns spanning accommodation, work environment, food services, and other welfare matters. Similar requirements exist at UCC.

It’s noted that the national regulations regarding freedom of association differ in Qatar and Iraq. While independent unions do not exist in Qatar, Estithmar has facilitated alternative forms of workers’ organization such as welfare committees (as stated above) and election of workers’ representatives. Iraq has ratified fundamental ILO conventions on Freedom of Association (FoA) and Collective Bargaining, therefore Estithmar’s policies will respect statutory and international requirements applied in Iraq. While IFC’s contextual risk screening did not identify any sectoral union with a direct interest at this stage, noting that the Baghdad Hotel is currently under construction, IFC has engaged with a tourism sectoral association to understand labor dynamics of this emerging sector in Iraq. It’s understood that the sector mainly relies on expat workforce and is expected to gradually increase local participation over time, which IFC will continue to monitor from a FoA perspective.
The HR policy of Estithmar covers various aspects of PS2 detailed under following sections, while not including explicit statements that address freedom of association, avoidance of child labor and forced labor and retrenchment policies. As per ESAP#7, Estithmar will augment the Group’s corporate-wide HR policy to include specific reference to Group’s adherence to freedom of association and collective bargaining regulations in the countries they operate; requirements to prepare a retrenchment plan as per PS2 if warranted; access to grievance mechanism for all workers; commitments and detailed provisions to protect vulnerable workforce including migrant workers, screen and avoid any child /forced labor and retaliation risks including for the company’s contractors and manpower suppliers.

Construction

UCC has corporate level HR policies applicable to Baghdad hotel construction site. It was observed that with the increasing number of employees and different language requirements, there’s limited awareness among the workers around the HR policies and country regulations applied on site and also standards vary among different contractors. IFC’s appraisal identified the need to adopt and effectively implement a site level HR policy in line with PS2 and national regulations.

As per ESAP#8, a specific HR policy will be adopted for the Iraq construction site aligned with updated corporate policies covering all contractors and sub-contractors, including adherence to PS2 and country regulations with regards to the provision of written contract, wage and working hours regulations, migrant workforce rights protection, zero tolerance for any child labor/forced labor and retaliation, access to grievance mechanism and recognition of workers’ rights to organize.

The construction site in Iraq currently works six days, two shifts per day of up to 12 hours including overtime., . Workers have written contracts and are provided with copies of it though in some cases employment offers were used in lieu of contracts. Workers are also provided with a worker handbook by UCC which explains their rights and duties, code of conduct, leave and compensation procedures. UCC/Estithmar covers agency, transfer, visa, airfare etc. costs.. Overtime hours are compensated as per the Iraqi law (1.5 time the normal hourly wage for overtime during the day shift and two times during night shift and public holidays/Fridays). While there is an expectation from expat workers to maximize their income during their contract period, the Group will need to adhere to the maximum allowable overtime hours and compensation requirements in the country as the construction site ramps up. In addition, discrepancies in overtime payments are observed relating to different time tracking methods applied at the site.

As per ESAP#9, an Overtime Management Plan will be adopted for the project, that will identify minimum statutory requirements regarding overtime compensation and maximum allowable overtime hours consistently for all sub-contractors, assess and incorporate health and safety practices as well as heat stress risks into the shifts and rest periods planning (including mandatory weekly rest days) and review the monitoring procedures.

In Iraq, the majority of the workforce at the construction site consists of expats who are provided accommodations through a limited number of on-site prefabricated units and off-site existing buildings within the city center. UCC Welfare Unit from the HQ conducts periodical audits of the accommodation facilities as well as catering and transport services although these audits do not reflect the full scope of PS2 requirements. During IFC’s visit, it was observed that the standards in provision of basic services and freedom of movement varied for different groups of workers, and certain basic services such as life and fire safety, sanitation, ventilation, access to basic medical services needed improvements.

As per ESAP#10, a Worker Accommodation Plan (WAP) will be adopted for the project, which will identify key requirements for adequacy and quality of basic services consistently for all workers in line with IFC PS2, following the principles of non-discrimination and equal opportunity. In addition, fire safety measures will be strengthened (installation of smoke/heat detectors, fire alarms, egression measures) to comply with international fire safety standards. The WAP will include emergency preparedness and response plans of the camp sites in compliance with PS1.

As the construction site in Iraq is currently at peak and involves around 15 sub-contractors with varying knowledge/application of local regulations and limited experience in working in line with international labor standards, further thorough labor review is needed to achieve consistency in application of abovementioned policies and plans.

As per ESAP#11, an independent labor audit report will be submittedby a qualified consultant covering Iraq construction site, worker camps and daily facilities, which will include a comprehensive review of gaps with statutory requirements and PS2 and specific, time-bound corrective actions with clear responsibilities.

Operations

The updated HR policy of Estithmar (ESAP#7) will be cascaded to operations of the project hospitals and hotels. In addition, hotel operator HR policies will be applied to the hotel in Baghdad. The current operator’s Human Rights Policy includes commitments in line with PS2 and details how the operator will respect workers’ rights to form and join unions and collective bargaining processes, avoid child labor, forced labor, discrimination, harassment and prohibits personal identification retention. Prior to start of operations, the Baghdad Hotel will align Estithmar corporate and hotel operator policies to come up with one consolidated set of HR policies and procedures aligned to statutory and PS 2 requirements that will be implemented going forward.

Non-discrimination and Equal Opportunity, Gender-Based Violence and Harassment (GBVH)

Estithmar’s HR policy strictly prohibits discrimination based on race, gender, religion, color, nationality, ethnicity or sexual orientation in both internal and external candidate sourcing, and states zero tolerance to any form of harassment including sexual harassment. The group Code of Conduct reflects similar commitments, details the types of behavior considered as harassment, and establishes the employer’s duty to take measures to prevent and investigate such behaviors. As per ESAP #12, policies on prevention and handling of GBVH occurrences. The company will also adopt child protection and safeguarding measures for the project. Training will be conducted during induction and annually thereafter for the operational staff also covering the contractors. Specialized training on how to handle and review sensitive cases will be provided to managers, focal points and HR.

UCC has robust non-discrimination and equal opportunities policies and currently employs 24% women, beyond the 7% female employment global average for the construction sector. During the site visit in Iraq, various female employees were observed at the construction site, demonstrating company’s commitments in practice.

Worker’s Grievance Mechanism

Estithmar’s corporate level grievance mechanism works either through direct applications to the corporate HR or to the Whistleblower Mechanism, or the grievance mechanisms of the relevant business units. All grievances that relate to the violations of Code of Conduct of the company are handled confidentially and in line with principles of non-retaliation. These apply to all employees including contract workers engaged by third parties.

As per ESAP #13, Estithmar will update its group level workers’ grievance mechanism in line with IFC PS2 to includea dedicated procedure for handling and reviewingsensitive cases and issues, such as discrimination, bullying, harassment, GBVH, child endangerment or abuse, and make it accessible to contracted and third-party workers. The revised grievance mechanism will also identify and provide accessible referral pathways for complainants (to access services such as medical and psychological support, and legal aid). Estithmar will disclose information about the mechanism at the project sites, and will do the same to cover operations.

UCC has a grievance mechanism (called Power Connect) in place which is aligned with PS2, disclosed at multiple access points such as the mobile app, helpdesks and QR codes. All the grievances received from construction sites are responded in a timely manner. As some workers raised access issues, UCC will also include awareness raising on grievance mechanism as part of the induction and ongoing trainings as part of ESAP #8 (HR policy for the construction sites).

As stated above for HR policies, Baghdad Hotel will align Estithmar and hotel operator grievance mechanism procedures prior to start of operations to have a PS2 compliant workers’ grievance mechanism available for the Hotel.

Occupational health & Safety (OHS)

Key OHS risks related to the project are relevant to the construction stage of the hotel, as well as OHS risks specific to hospital and hotel operations.

Hospital health and safety management system of Apex is implemented in line with ISO45001 standards, includes detailed risk assessment and mitigation strategies, trainings, accident investigation and monitoring procedures overall aligned with PS2.

The OHS management system of the hotel will be provided by the operator and will be focused on providing onboarding and regular training to employees, personal protective equipment, cleaning and sanitation protocols and supporting mental health and well-being of employees.

UCC’s OHS management system is applied at the construction site of the hotel. UCC appoints competent HSE manager and site supervisors in charge of overseeing the site, with reporting lines to the project director and UCC OHS Director. There’s also an independent supervision consultant based onsite and additional external audits are being commissioned.

HSE management system at the construction site includes detailed hazard identification and risk assessment, onboarding and specialized trainings and sub-contractor review procedures. Work permit system is implemented for high-risk tasks such as hot works and working at height, welding and cutting, vehicle safety, manual handling, lifting safety, electrical safety and night work. Incident reporting and investigations, emergency preparedness and response plans are also covered adequately. Working clothes and personal protective equipment are provided to employees in accordance with the type of performed works (special clothes, masks, goggles, gloves, ear plugs and etc.). All workers are subject to medical examinations upon admission and periodically thereafter.
Although there’s a medical clinic on site with presence of medical staff, it did not appear to be fully equipped for the potential risks at the site and does not maintain an ambulance onsite for emergencies.

Other safety measures observed at the construction site include installation of guardrails and lifelines, clear demarcation of hazardous areas or unsafe conditions, placing of safety signs and adequate warning and proper illumination of areas. Equipment used at construction sites (cranes, trucks, and excavators) undergo regular maintenance and inspections and is operated by experienced trained employees. The labor and OHS audit identified the need to further strengthen fall-protection arrangements, subcontractor supervision, and monitoring of electrical hazards, which are being addressed through enhanced monitoring, corrective action tracking, and oversight requirements under ESAP #14.

In Iraq, the lost-time injury frequency rate (LTIFR) has been low (2 LTI’s during first nine months of 2025). In October 2025, there has been a fatality due to fall from height. UCC has conducted detailed root-cause assessment and prepared a corrective action plan to increase monitoring during night shift and restrict high-risk activities of the relevant local sub-contractor. UCC has additionally commissioned an external audit for comprehensively reviewing site level implementation of HSE requirements which has provided an action plan. As per ESAP#14, Estithmar will prepare a) monthly progress reports on key safety performance indicators for the construction site and completion of corrective actions related to working at heights and fall protection, strengthened sub-contractor monitoring identified from audits (ISO45001, root-cause assessment and independent labor audit), b) assessment of heat stress risks related to occupational health and safety for the construction site, rev;ew and adjustment of site-specific heat protection and hydration measures including adjustment of working hours in extreme weather conditions, c) increase of OHS supervisor ratio to 1:50 workers in line with good international industry practices (GIIP), and d) strengthening of the onsite medical clinic for responding to site-specific risks and increase capacity to serve all workers present at the site, and contract ambulance services in case of emergencies.

PS 3 – Resource Efficiency and Pollution Prevention

Estithmar Holding’s environmental management approach is guided by its Sustainable Governance Policy and ISO-aligned procedures implemented at cluster level. The Group promotes energy efficiency, sustainable procurement, and waste reduction across its subsidiaries. An energy audit has been conducted to identify opportunities for improving building performance and reducing consumption. Apex hospitals in Qatar have adopted energy-saving technologies such as motion-sensor lighting, water-saving fixtures, and optimized cooling systems. Environmental Key Performance Indicators (KPIs) related to carbon footprint and energy efficiency are tracked through the Group’s ESG reporting system. Apex has Waste Management Policy, Laboratory Waste Disposal Procedures, Hazardous Materials Management Program and Spill Response Plans overall aligned with PS3 and good international industrial practices (GIIP such as JCI for medical sector), and IFC observed good implementation at visited hospitals in Qatar.

A construction environmental management plan is in place at the hotel construction site in Baghdad, which includes internal procedures for housekeeping, waste segregation and pollution control. Construction waste is sorted at site, and non-hazardous materials such as scrap metal and concrete are reused or sold to recycling vendors. Solid waste is collected by the municipal authority. More frequent maintenance of the on-site portable septic tanks will be included in the CESMP for sewage disposal (ESAP3#). Water is supplied through the local utility, filtrated through reverse osmosis to provide drinking water. The quality of water is monitored and has been found in line with WHO standards, as indicated in the ESIA. Power is drawn from the public grid, with backup diesel generators in place. No on-site fuel storage or combustion sources with significant air emissions were observed.

Although projections for energy and fuel use are not available at this stage for operations, GHG emissions are estimated to remain below 25,000 CO2eq tonnes as per comparison with similar sectoral benchmarks.

As per ESAP #15, Estithmar will require the Hotel operator to develop and adopt an environmental monitoring plan for the project, aligned with IFC Performance Standard 3 and the WBG EHS Guidelines. The plan will establish baselines and monitoring indicators for energy and water use, water quality (including potable and wastewater streams), emissions, hazardous materials management, and waste; define reduction targets; and incorporate measures for minimizing emissions, ensuring safe water quality for users and workers and improving waste recycling and disposal during operation.

PS 4 – Community Health, Safety, and Security

Key community health and safety impacts during construction are assessed and managed as part of the construction E&S management plan of UCC such as traffic management, noise, dust, emergency management. The ESIA under preparation will provide any further specific measures that will be incorporated into the CESMP as per ESAP#3.

In Iraq, although the construction site is located away from community access (green zone), the two buildings where workers are accommodated are within the city center. As the project creates an influx of workers coming from different cultures during construction and operations, health checks and examinations are done prior to arrival and the induction presentation includes awareness on rules and regulations of the host country. As per ESAP#16, a Worker Code of Conduct (WCoC) for the construction site of the project will be developed and adopted which will include awareness raising on site-specific community health and safety risks covering all sub-contractors (security, transport etc. included). The WCoC will have particular focus on addressing issues such as discrimination, bullying, harassment, SEAH and CPS.

Existing hospital and hotel operations of Estithmar are conducted with utmost care towards community safety, including management of communicable diseases, GBVH, SEAH, human trafficking and child abuse risks. Hotel operations implement operator’s policies and regular trainings which include age verification at check-in, staff training to identify trafficking indicators, escalation protocols and survivor-centric handling procedures in case of any suspected or confirmed harassment or abuse of guests, and collaboration with competent authorities. As per ESAP#17, Estithmar will confirm that the hotel operator has put in place child safeguarding and anti-harassment/GBVH programs addressing site-specific risks, providing regular trainings to staff and conducting awareness raising for guests at Baghdad hotel in line with IFC PS4.

Apex’s Code of Conduct for hospitals focuses on ethical considerations towards patients and does not include specific references to prevention of SEAH/GBVH and CPS. As per ESAP#18 Code of Conduct towards hospital patients will include clear statements prohibiting discrimination, sexual harassment, GBVH and child abuse. Hospital operations will implement child safeguarding measures (consent/assent procedures, controlled access to pediatric wards, visitor screening, staff-patient boundary guidance) and mandatory reporting consistent with national law. The Code of Conduct towards patients and specific measures will be communicated publicly in accessible locations.

Furthermore as per ESAP#19, Estithmar will establish a formal community grievance mechanism for the project and make it accessible to affected communities (those affected from construction activities and users of project hotel and hospitals) in alignment with PS4, which will cover any potential GBVH/SEAH/CPS risks, include multiple reporting options (including anonymous). In addition, clear referral processes will be set up to link complainants with the support services they need, such as legal aid, medical care, and psychological assistance. Estithmar will require that any community grievance of this nature, received through the construction contractor’s or operator’s grievance channels, be reported promptly.

Life and Fire Safety (LFS)

Estithmar applies US NFPA standards for the design and operation of hospitals and hotels in Qatar. For projects in other countries, the company follows both local regulatory requirements and relevant international standards are integrated into facility design.

Particularly, for the Baghdad hotel, the LFS design is based on NFPA standards and incorporates appropriate architectural and engineering features to manage LFS risks, including means of egress, compartmentation, and functional layouts. Additionally, the facility will be equipped with fire detection and alarm systems, automatic sprinkler system, staircase pressurization, and accessibility provisions particular for guests with reduced mobility. The standard hotel operator’s Emergency Preparedness and Response Plan (EPRP) will be adapted to the Baghdad hotel, including risk identification (including climate risks), mitigation measures and procedures consistent with IFC PS4 for the protection of the community. Emergency drills will be conducted at least quarterly, involving both employees and guests across different operational shifts.

In line with ESAP #20, Estithmar will commission a post-construction audit for the hotel by a qualified LFS professional. This audit will verify compliance with the design, IFC PSs, WBG General EHS Guidelines, and applicable local regulations. This will be followed by adoption of an LFS Operations and Maintenance (O&M) Plan, including inspection, testing, and preventive maintenance (ITM) procedures; and adoption of an EPRP addressing all probable risk scenarios and evacuation protocols, including climate-specific risks.

Security Personnel

The construction site in Iraq is fully secured with proper fencing and monitored 24/7 by contracted a reputable security companyfollowing established trainings and protocols, as per the security risk assessment and management plan in place in alignment with PS4. The guards are unarmed, though army presence is observed at the gates of the construction site due to close proximity to top governmental residential and office buildings. Similar security arrangements are expected for operations though not detailed at this stage.

Estithmar is a publicly listed company in Qatar and conducts disclosures to stakeholders on any material E&S risks and events affecting its stakeholders. Stakeholders can raise observations on unethical conduct to publicly disclosed Whistleblower Mechanism (https://www.estithmarholding.com/Contact/WhistleBlowing ). Issues falling under HR, compliance and legal matters are invited to be raised to Estithmar’s escalation procedure letstalk@estithmarholding.com. Both mechanisms accept anonymous submissions. The grievance mechanism to be developed as per ESAP#19, will be either incorporated to existing channels or designed as a standalone mechanism, and will be disclosed on company’s website and locations accessible to affected communities. Apex and the hotel operator also maintain their own external grievance mechanisms and will be reporting project related grievances promptly to Estithmar.

UCC maintains community grievance mechanism and regular engagement with local stakeholders around construction sites of the project. As stated under ESAP#19, UCC will promptly report community grievances to Estithmar.

Contact Person: Ishan Gitai
Company Name: Estithmar Holding QPSC
Address: Doha Qatar
Email: i.gitai@estithmarholding.com
Phone: +974 77103618

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Estithmar will develop and implement a corporate-level Environmental and Social Management System (ESMS) framework proportionate to its operations and consistent with IFC Performance Standards (PS). Apex and Estithmar Ventures will update their ESMS in line with the corporate framework and IFC PS.	06/30/2026
2	Estithmar will require the Baghdad Hotel operator to develop and implement an operational ESMS for the hotel consistent with the requirements of IFC PSs and the ESIA	07/31/2026
3	Update the Construction and Operational Environmental and Social Management Plans (ESMP) in alignment with the mitigation measures outlined in the ESIA.	03/30/2026
4	Estithmar will adopt a consolidated monitoring and review procedure for the project including key environmental, health and safety, social (EHSS) indicators covering all sub-contractors, audit frequency, and management review arrangements.	03/30/2026
5	Estithmar will appoint a qualified E&S officer at the corporate level, with clear reporting lines and escalation procedures to the ESG Committee, to monitor compliance of the project in line with IFC PS and to oversee the implementation of the corporate ESMS.	04/30/2026
6	Adopt a sub-contractor training and monitoring procedure for the Baghdad Hotel construction site as part of CESMP, which will expand the frequency and scope of the current trainings and will include, monitoring and internal auditing arrangements in line with IFC PS, with a specific focus on management of labor and working conditions to be in line with PS2. This will include monthly reporting on the outcomes (any non-compliances and actions taken) to Estithmar and immediately for any significant E&S events (fatal accidents, fire, significant labor non-compliance and labor strikes). The monthly E&S reports will also be submitted to IFC during the construction period.	03/30/2026
7	Estithmar will augment the Group’s Corporate-wide HR policy to include specific references to the Group’s adherence to freedom of association and collective bargaining regulations in the countries they operate; requirements to prepare a retrenchment plan as per PS2, if warranted; access to the grievance mechanism for all workers; and commitments and detailed provisions to protect vulnerable workforce including migrant workers, screen and avoid any child labor, forced labor or retaliation risksy including for the company’s contractors and manpower suppliers.	04/30/2026
8	A specific HR policy will be adopted for the Iraq construction site, aligned with updated corporate policies covering all contractors and sub-contractors, including adherence with PS2 and country regulations with regards to the provision of written contract, wage and working hours regulations, migrant workforce rights protection , zero tolerance for any child labor/forced labor and retaliation, worker access to grievance mechanism and recognition of workers’ rights to organize.	04/01/2026
9	Adopt a project Overtime Management Plan that will identify minimum statutory requirements regarding overtime compensation and maximum allowable overtime hours consistently for all sub-contractors, assess and incorporate health and safety practices as well as heat stress risks into the shifts and rest periods planning (including mandatory weekly rest days) and review the monitoring procedures.	04/01/2026
10	Adopt a Worker Accommodation Plan (WAP) for the project, which will identify key requirements for adequacy and quality of basic services consistently for all workers in line with IFC PS2, following the principles of non-discrimination and equal opportunity. Strengthen life and fire safety (LFS) measures (installation of smoke/heat detectors, fire alarms) and install egression measures for camp sites that comply with international fire safety standards. The (WAP)will include emergency preparedness and response plans of the camp sites in compliance with PS1.	04/30/2026
11	Submit an independent labor audit by a qualified consultant covering Iraq construction site, worker camps and daily facilities, which will include a comprehensive review of gaps with statutory requirements and PS2 and specific, time-bound corrective actions with clear responsibilities.	04/01/2026
12	Company to adopt policies related to the prevention and handling of GBVH occurrences. The Company will also adopt child protection and safeguarding measures for the project. Trainings will be conducted during induction and annually thereafter for the operational staff also covering the contractors. Specialized training on how to handle and review sensitive cases will be provided to managers, focal points and HR.	07/31/2026
13	Estithmar will update its group level workers’ grievance mechanism in line with IFC PS 2 to include a dedicated procedure for handling and reviewing sensitive cases and issues, such as discrimination, bullying, harassment, GBVH and child endangerment or abuse, and make it accessible to contracted and third-party workers. The revised grievance mechanism will also identify and provide accessible referral pathways for complainants (to access services such as medical and psychological support, and legal aid). Estithmar will disclose information about the mechanism at the project sites, and will do the same to cover operations.	09/30/2026
14	Estithmar will prepare a) monthly progress reports on key safety performance indicators for the construction site and completion of corrective actions related to working at heights and fall protection, strengthened sub-contractor monitoring identified from audits (ISO45001, root-cause assessment and independent labor audit), b) assessment of heat stress risks related to occupational health and safety for the construction site, review and adjustment of site-specific heat protection and hydration measures including adjustment of working hours in extreme weather conditions, c) increase of OHS supervisor ratio to 1:50 workers in line with good international industry practices (GIIP), and d) strengthening of the onsite medical clinic for responding to site-specific risks and increase capacity to serve all workers present at the site, and contract ambulance services in case of emergencies.	03/30/2026
15	Estithmar will require the Hotel operator to develop and adopt an environmental monitoring plan for the project, aligned with IFC Performance Standard 3 and the WBG EHS Guidelines. The plan will establish baselines and monitoring indicators for energy and water use, emissions, hazardous materials management, waste and water quality (including potable and wastewater streams); define reduction targets; and incorporate measures for minimizing emissions, ensuring safe water quality for users and workers and improving waste recycling and disposal during operations.	09/30/2026
16	Develop and adopt a Worker Code of Conduct (WCoC) for the construction site of the project which will include awareness raising on site-specific community health and safety risks covering all sub-contractors (security, transport, etc. included). The WCoC will have particular focus on addressing issues such as discrimination, bullying, harassment, sexual exploitation abuse and harassment (SEAH) and child protection services (CPS).	03/30/2026
17	Estithmar will confirm that the hotel operator has put in place child safeguarding and anti-harassment / GBVH programs addressing site-specific risks, providing regular trainings to staff and conducting awareness raising for guests at Baghdad hotel in line with IFC PS4.	09/30/2026
18	Code of Conduct towards hospital patients will include clear statements prohibiting discrimination, sexual harassment, GBVH and child abuse. Hospital operations will implement child safeguarding measures (consent/assent procedures, controlled access to pediatric wards, visitor screening, staff-patient boundary guidance) and mandatory reporting consistent with national law. The Code of Conduct towards patients will be communicated publicly in accessible locations.	06/30/2026
19	Estithmar will establish a formal community grievance mechanism for the project and make it accessible to affected communities (users of project hotel and hospitals) in alignment with PS4, which will cover any potential GBVH/SEAH/CPS risks, include multiple reporting options (including anonymous). In addition, clear referral processes will be set up to link complainants with the support services they need, such as legal aid, medical care, and psychological assistance. Estithmar will require that any community grievance of this nature, received through the construction contractor’s or operator’s grievance channels, be reported promptly.	03/30/2026
20	Commission a post-construction audit for the hotel by a qualified life and fire safety (LFS) professional. This audit will verify compliance with the design, IFC PSs, WBG General EHS Guidelines, and applicable local regulations. This will be followed by adoption of an LFS Operations and Maintenance (O&M) Plan, including inspection, testing, and preventive maintenance (ITM) procedures; and adoption of an Emergency Preparedness and Response Plan (EPRP) addressing all probable risk scenarios and evacuation protocols, including climate-specific risks.	09/30/2026