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
Environmental and Social Management System (ESMS): Siglo21 has a number of plans and procedures for managing E&S risks, but does not have a well-defined E&S management system therefore as per ESAP #1, Siglo will develop and implement an integrated platform to streamline the management of E&S and gender-related risks. This platform will support Siglo’s monitoring, reporting, and analysis to improve data accuracy and operational efficiency, intended to assist E&S decision-making and continuous improvement.
E&S policy: Siglo has several policies including corporate environmental sustainability, waste management, ethics and general conduct, occupational health and safety and numerous policies related to staff management and benefits publicly disclosed in its bi-annual sustainability report. All these policies and procedures apply to the two new campuses.
Environmental & Social Risk Identification: Siglo 21 manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits, which are generally aligned with PS1 requirements. The project maintains a register of E&S risks currently covering the construction phase. Key risks include water management, liquid and solid waste management, resources efficiency, and OHS. As per ESAP #2, Siglo 21 will enhance its documented procedures to identify and assess all E&S risks and impacts associated with the construction and operations of the new campuses, including climate-related risks, and potential social impacts on neighboring communities.
E&S Management Programs: Siglo 21 has developed and implemented E&S Management Plans, including programs for waste disposal, and Integrated Pest Management (MIP) aligned with the applicable requirements. Social programs address harassment prevention and diversity. A well-established maintenance program is in place (JIRA), which ensures that corrective actions are assigned to responsible teams, progress is monitored until closure, and records are retained as part of the Company’s control and accountability processes.
As per ESAP#3 Siglo will develop and implement Contractor Management Plans, including contractor safety manuals, construction procedures, EHS training programs, and monitoring and reporting procedures. Contractors and subcontractors will be contractually required to prepare and implement site-specific EHS management plans aligned with the WBG General EHS Guidelines (2007). These plans will address, at a minimum, solid and hazardous waste management, air emissions and ambient air quality, water use and groundwater abstraction, traffic safety and control, and impacts on protected areas.
Sexual Exploitation, Abuse and Harassment: Siglo 21 mandates GBV/SEAH training line with national law, embedding gender responsive standards across academic and administrative functions. Mandatory onboarding and awareness measures ensure faculty, students, and staff uphold institutional responsibilities for a safe, equitable, and violence-free environment.
The “Protocol for the Detection and Intervention in Situations of Sexual Harassment, Gender-Based Violence, and/or Discrimination Based on Gender Identity, Gender Expression, or Sexual Orientation” (the GBV/SEAH Protocol) applies to the entire Siglo 21 community. Under ESAP #4, Siglo 21 will refine the GBV/SEAH Protocol to reinforce its survivor-centered approach. The updated protocol will specify all reporting channels, allow anonymous reporting, and strengthen confidentiality. It will foresee immediate psychological support and protective measures to separate survivors from alleged perpetrators. Investigations will be designed to minimize revictimization while maintaining formal, secure, and confidential procedures to protect all parties.
Organizational Capacity and Competency: E&S management responsibilities are distributed across several existing operational teams, rather than housed in a dedicated E&S management function. E&S management for the project is overseen by the Human Resources and Infrastructure Management Division. This leadership ensures that E&S responsibilities are integrated at corporate, campus and construction site levels. The team includes a dedicated Hygiene and Safety Specialist, who is supported by an external environmental advisor. Together, they provide technical supervision, ensure regulatory compliance, and oversee the implementation of the Environmental and Social compliance for the new campuses.
At the construction sites, an external project manager is contracted to supervise the construction process, with specific responsibility for managing environmental and occupational health and safety (OHS) risks, including oversight of contractors. The Infrastructure Management division is accountable for the comprehensive management of safety and hygiene, supported by an internal Environmental Advisor who ensures compliance with current regulations, risk prevention, and the promotion of healthy and sustainable work environments.
This structure ensures that qualified staff are in place to manage E&S risks effectively, with clear lines of responsibility and accountability for E&S performance at all levels of the project.
Emergency Preparedness and Response (EPR): While EPR plans are in place at Siglo’s existing site, plans for the new campuses have yet to be developed. Going forward, as per ESAP#5, Siglo will develop and implement EPR plans aligned with those at existing sites. These will address fire, medical incidents, extreme weather, and other anticipated emergencies, and will include coordination with local emergency agencies (e.g., Fire Department, Provincial Police, and ambulance services). Annual evacuation drills will be conducted with the participation of local responders. Each campus will include an aid room equipped for initial medical assistance, and at least 11% of the workforce will be trained in first aid and CPR in accordance with local regulations. Staff and building users will receive regular training on evacuation and firefighting procedures, including specific measures to assist individuals with reduced mobility, which will be tested through scheduled drills.
Monitoring and Review: Currently, Siglo 21 employs a structured process to monitor and review E&S risks associated with its operations and campus construction. The institution compiles a biennial sustainability report—next due in 2026—that consolidates updated data on environmental performance, supporting both accountability and compliance. Key policies affecting people, the environment, and the community are routinely reviewed and escalated to the Board of Directors, ensuring robust governance.
Ongoing tracking of waste management, energy use, and solar energy production is documented in specialized reports, with monthly and annual records feeding into the main sustainability report to drive continuous improvement. Management promotes interdisciplinary coordination for E&S issues, encouraging collaborative oversight and shared responsibility.
PS2- Labor and working conditions
Human Resources Policies and Procedures Working Conditions and Terms of Employment: Siglo 21 has formal, documented HR policies and procedures aligned with national law and IFC PS2 requirements, applicable to all direct employees. These cover recruitment, annual leave, leave without pay, flexible work, maternity and paternity leave, flexible work arrangements for new mothers, health benefits for teaching staff, scholarship benefits, and daycare expense reimbursement. Siglo 21 also has data protection measures, including an Employee Confidentiality Commitment, and a General Data Security and Management Policy.
The role of the three HR Business Partners (HRBPs) combines strategic HR support with operational follow-through, guided by key indicators such as delivering training plans, reducing staff turnover, ensuring completion of performance evaluations, and improving organizational climate scores. This structure enables HR to align workforce development and engagement initiatives with the university’s broader objectives through, guided by key indicators such as delivering training plans, reducing staff turnover, ensuring completion of performance evaluations, and improving organizational climate scores. This structure enables HR to align workforce development and engagement initiatives with the university’s broader objectives.
Non-discrimination, equal opportunities, forced and child labor: Siglo 21 applies non-discriminatory HR policies on recruitment, internal mobility, and employment conditions, supported by work-life balance and gender-responsive benefits such as flexible work, extended parental leave, childcare reimbursement, health coverage, and equal access to leave. Key PS2 risks concern consistent application across roles, career paths, and third-party managed workplaces, including the University Learning Centers (Centros de Aprendizage Universitario - CAUs), mitigated through centralized HR oversight, with no child or forced labor identified. Women’s leadership is supported through targeted internal initiatives and mentoring.
Workers’ Grievance Mechanism: Siglo 21 currently manages workers’ grievances through the HR Department and its three HR Business Partners (HRBPs), who meet weekly with cell leaders (academic, operations and services to students) and record cases in a planner, while exceptionally confidential matters may be handled off record. Employees may raise administrative and other queries through a self-service HR portal, via email for payroll related matters, or directly with HR.
Under ESAP #6, Siglo 21 will design and implement a formal Workers’ Grievance Mechanism (WGM) accessible to direct workers and third-party contractors, including CAU’s and construction workers, to receive and resolve workplace complaints. The mechanism will allow for anonymous submissions, protect complainants against retaliation, ensure timely, fair, and documented resolution of grievances, and be communicated to all workers and relevant third-party contractors. The WGM will be embedded in worker induction and periodic refresher training. Grievance monitoring will be integrated into the ESMS using gender responsive indicators and sex-disaggregated data. Workplace related SEAH will be handled through the GBV/SEAH Protocol, which is subject of ESAP #4 above.
Occupational Health and Safety (OHS): Siglo 21 has established a structured approach to OHS, consistent with IFC PS2, and maintains full compliance with municipal safety and hygiene regulations. The institution employs a qualified specialist responsible for designing and implementing OHS policies and procedures. This specialist is supported by a licensed external advisor and a safety and hygiene technician, at the Cordoba campus. In Buenos Aires, an additional external advisor ensures compliance with all legal requirements. These systems will be duplicated at the new campuses to ensure a consistent approach to OHS. During construction, an overall manager is on site daily to oversee the contractor's compliance with PS 2 requirements which will also be reinforced in the contracts as per ESAP #3.
The OHS management system includes regular risk identification and evaluation through control rounds, with findings recorded in a Risk Notices Register. Contractor management procedures require documentation checks prior to site entry and ongoing monitoring of compliance with safety requirements. Incidents are managed under established protocols and recorded in a unified registry, with no major or fatal accidents reported to date. Training needs are assessed annually, and mandatory OHS training is provided to all staff, with specialized modules for maintenance personnel and contractors.
Facilities are equipped to ensure worker comfort and safety, including climate control and access to potable water. The campus environment, with over 1,700 trees and extensive shaded areas, supports year-round use and well-being. The same will be implemented at the new campuses.
Workers engaged by Third Parties: Siglo 21 carefully screens contractors for technical skills and compliance with Health and Safety laws before engagement. All contracts require adherence to OHS standards. Once selected, contractors undergo ongoing OHS oversight, with any incidents promptly reported to the Head of Safety and Health and Safety Specialist. Formal incident reports are created for analysis and corrective action. Escalation to senior management occurs as needed, ensuring that third-party workers are managed in line with IFC PS2 requirements for safety and continuous improvement.
Document management procedures are applied to all individuals entering the campus, requiring submission and verification of minimum documentation to confirm compliance with applicable labor legislation, consistent with PS’s focus on worker protection and legal compliance. For the construction of new campuses, the Company is implementing a safety program approved by the workers’ compensation insurer accredited by the public authority. The program is enforced on site and adhered to by all contractors, with compliance subject to control by the authorities. A technical advisor remains on site full-time and interacts with the safety technicians of each contractor.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency: Siglo 21’s resource efficiency initiatives include LED lighting, energy-saving architectural elements such as natural ventilation and double-glazed windows, and the planting of 250 native trees to support local biodiversity. Water use, sourced from the public network, is optimized through 20,000-liter storage tanks, a 26-meter artificial lagoon for rainwater, and efficient irrigation systems, keeping annual consumption at 7,500–9,000 m³.
Although no specific water sustainability study was conducted due to reliable public supply, several measures ensure responsible use: rainwater retention systems, efficient irrigation, and permeable surfaces for better infiltration. These actions reduce demand on utilities and follow international sustainability standards, with resource efficiency tracked through established KPIs.
Greenhouse Gases (GHG) Emissions and Climate Risk Assessment. IFC’s review identified a low level of project E&S risks and impacts resulting from a changing climate, including extreme heat and flooding. The client manages and mitigates risks and potential adverse impacts by implementing relevant measures identified in the assessment and management plans. The client will monitor and report on their implementation.
Wastewater: The project’s wastewater management practices are designed to comply with all applicable provincial and municipal environmental regulations, including those governing effluent management, protection of water resources, and runoff control. All necessary permits and authorizations are obtained to ensure ongoing monitoring and regulatory oversight of environmental management throughout both construction and operational phases. At the new campuses, wastewater will be discharged to the municipal sewer network. Stormwater management is addressed through the use of retention lagoons, which collect and recycle rainwater for irrigation of extensive green areas on campus. The design incorporates semi-permeable surfaces wherever feasible to minimize runoff and promote groundwater absorption, supporting resource efficiency and pollution prevention objectives.
Waste management: Siglo 21 has established and implemented a comprehensive waste management policy that covers the separation, storage, and disposal of waste, in line with applicable legal requirements and good international industry practice, including PS3 requirements. Waste is segregated at source into recyclable, organic, and non-recyclable streams, following the University’s Waste Management Manual. All waste is managed by certified contractors, who are responsible for collection and final disposal. Each facility is equipped with dedicated waste segregation and storage rooms. The corporate-level waste management plan details procedures for the collection, storage, handling, recycling, accounting, reuse, and final disposal of waste. Only licensed contractors or government agencies, authorized by local authorities, are engaged for these activities, ensuring compliance with regulatory requirements. These corporate procedures will be implemented at the two new campuses.
Air and noise pollution: The university’s operations do not generate significant air emissions, and there are no breaches of environmental regulations. According to local regulations, Siglo 21 is not classified as an activity with a material environmental impact, and therefore, air quality studies are not required. The key national standard for ambient air quality (Resolution 833/2018) is observed, with provincial standards applied where more stringent. Noise impacts are not considered significant, as campuses are located away from local communities.
Hazardous materials: Siglo 21 has procedures and instructions for the handling, consumption, transportation and disposal of hazardous materials, considering their classification, and their materials safety data sheets (MSDS). Chemicals are utilized in controlled quantities only in teaching laboratories and are kept in approved fire rated cabinets. Most of the medical labs are simulation based, thus minimal amounts of chemicals or hazardous waste are used within labs. Any hazardous waste is stored and collected by third party contractors according to internal procedure in line with local legislation. Siglo 21 has an established pest management plan and selection of pesticides is controlled by the Safety personnel.
PS4-Community Health, Safety and Security
Community Health and Safety: The Villa Maria and Rio Cuarto University Campus projects of Universidad Siglo 21 are located in low-density urban and semi-urban environments, which limits the direct exposure of nearby communities to significant health and safety risks. Nevertheless, the institution has integrated a series of preventive and control measures throughout the design, construction, and operational phases to ensure that potential risks are minimized and that community well-being is safeguarded. These measures address a range of foreseeable hazards including vehicle movements during construction, fire and life safety considerations in public buildings, and natural hazard mitigation.
In terms of infrastructure design and safety, all buildings have been designed and are being constructed in accordance with the relevant national and provincial technical codes, including the local Seismic and structural regulations (CIRSOC in Argentina) and the “Instituto Argentino de Normalizacion y Certificacion” (IRAM) standards for electrical, sanitary, and ventilation systems. Compliance with the Fire Safety Regulations of Cordoba (Law 5920) is ensured from the design phase onwards. The campuses incorporate universal accessibility features, including regulatory ramps, adapted toilets, and corridors that comply with the requirements of National Law No. 24,314 and IRAM 11100 standards.
Life and Fire Safety (LFS): All Siglo 21 campus buildings are equipped with fire extinguishers, hydrants, smoke detection systems, emergency signage and lighting, and clear evacuation plans, including measures for people with mobility limitations. These systems are certified by local fire departments, with compliance certificates held for key campuses, and public accessibility standards are fully met.
For new facilities and as per ESAP #7, Siglo 21 will ensure designs meet both local and fire safety requirements of the WBG General EHS Guidelines, by developing a comprehensive L&FS Design Manual under professional guidance. This manual will capture best practices and include an EHS checklist for specialized areas like labs and kitchens, standardizing safety provisions across all future projects.
During construction, strict site safety protocols—such as perimeter fencing, controlled access, scheduled heavy vehicle movement, and clear signage—protect the public and workers. Natural hazard measures include elevated buildings, stormwater management, and over 50% permeable surfaces, with landscaping and extensive tree planting further enhancing climate resilience and campus safety.
Security Personnel: Security for the campuses is managed by a licensed private contractor. The number of personnel varies depending on the size of the campus. Private security guards are unarmed, while police personnel (public security) assigned to the campus are armed. All security staff meet contractual requirements that include background checks, municipal licenses, Ministry of Security authorization, and adherence to institutional rules of engagement. Training is provided to ensure compliance with institutional codes of conduct and applicable laws. Security Personnel, as third-party contractors, will have access to the Workers’ Grievance Mechanism (ESAP #6 above), and will be required to abide by the institution’s GBV/SEAH Protocol (ESAP#4 above).
