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 Assessment and Management System and Policy: DrC has established several E&S management and operational procedures per national laws for waste, hazardous materials, physical, chemical, and biological exposures, Code of Conduct and HR policies which are not integrated into a structured management system that allows a systematic identification and management of E&S risks and impacts commensurate to the operations of the Company. Therefore, as part of ESAP #1, DrC will develop and implement a corporate integrated, risk-based ESMS commensurate with the E&S risks and impacts of its operation, compliant with national law and aligned with the requirements set forth in IFC PSs, including the WBG EHS General Guidelines and the EHS Guidelines for Health Care Facilities. The ESMS will include a sustainability policy, risk and impact identification procedures, E&S management programs, stakeholder engagement, emergency preparedness, key performance indicators, including those informed by sex-disaggregated data, and an E&S monitoring and review process. The ESMS will be cascaded down to diagnostic centers and clinics.
Identification of Risks and Impacts and Management Programs: The Company currently manages E&S risks by complying with national regulations and permits and is developing an E&S risk-impact matrix. Brazilian law does not require an Environmental Impact Assessment (EIA) for the construction or expansion of clinics and diagnostic centers. As part of ESAP #1, DrC will develop and implement an ESMS acquisition management procedure to conduct ESDDs per national law and requirements of IFC PSs when selecting new sites, which may include existing buildings, individual properties, or undeveloped land. The Company will also implement an automated system to track licensing and authorization compliance across all facilities under ESAP #1.
During mergers and acquisitions (M&As), DrC uses a due diligence checklist to assess regulatory compliance, including verification of EHS aspects. As part of ESAP #1, DrC will adopt the best practices in due diligence processes, including the adoption of cost-benefit analysis and the mapping of compensatory environmental and social mitigation measures, in line with national requirements and IFC PSs, during M&As.
Organizational Capacity and Competency: The Legal and Infrastructure departments oversee E&S matters, including ethics management and regulatory compliance. The HR department manages labor and working conditions, including OHS and L&FS. Diversity, Equity and Inclusion (DEI) is led by the Legal Department, which also supervises the Company’s Code of Conduct.
At the corporate level, DrC’s teams for environmental and OHS matters include EHS engineers, architects, lawyers and technicians. In clinics and diagnostic centers, E&S monitoring is handled by facility supervisors and OHS technicians. Under ESAP #2, DrC will appoint a corporate-level E&S Manager to coordinate environmental, OHS and social (including labor) matters, and oversee the ESMS development and implementation across all facilities and departments. While the E&S Manager is not hired and as part of ESAP #2, DrC will appoint a dedicated E&S focal point at corporate level.
Emergency Preparedness and Response: DrC has Emergency Action Plan procedures at corporate level and for each clinic, developed as per Brazilian regulations and generally aligned with PS1. The plan requires that all DrC facilities have a documented emergency preparedness and response plan (EPRP) comprising of: (i) facility and surrounding areas description; (ii) available firefighting equipment; (iii) internal communication protocols; (iv) designated meeting points; (v) emergency procedures communications and dissemination; and (vi) Fire Brigade details and nearest hospital location.
All DrC units hold the Fire Department Inspection Report of their respective state, certifying compliance with fire safety standards. All facilities have emergency brigades and professional firefighters with clearly marked emergency exits, and annual evacuation and fire drills coordinated with the local Fire Service Department. Under ESAP #3, DrC will augment its EPRPs in line with medical procedures to: (i) address workers and patients’ exposure to biological or chemical hazards, flooding, and civil unrest; (ii) include safe evacuation procedures for patients with limited mobility or immobilized after medical procedures; and (iii) update the training program.
Monitoring and Review: DrC’s monitoring system follows EHS regulations, including L&FS provisions, waste and hazardous materials management, radiation exposure, water and energy consumption, and OHS. Data is reported to senior management monthly, while OHS and Infrastructure personnel inspect units for compliance with OHS and L&FS requirements every month. All incidents are reviewed, and corrective actions are implemented based on root causes analysis.
As part of ESAP #1, DrC will standardize E&S key performance indicators (KPIs) across all operations in alignment with IFC PSs and WBG EHS Guidelines for Health Care Facilities, including gender-responsive and sex-disaggregated data analysis of E&S risks, with reporting to senior management. KPIs will cover labor and working conditions, resource efficiency, pollution prevention, and community health, safety and security, as discussed under PS2, PS3 and PS4.
PS2- Labor and working conditions
Human Resources Policies and Procedures: DrC has a set of corporate HR instruments —policies, procedures, and employment contracts —covering: (i) selection and recruitment; (ii) compensation, working hours, and benefits; (iii) induction, training, and professional development; (iv) dismissal and disciplinary processes; (v) performance evaluation; and (vi) OHS. DrC’s new Code of Conduct and internal regulations align with the Brazilian labor code, PS2 requirements, and SEAH protection requirements, and prohibit child and forced labor in any of its operations.
Working Conditions, Terms of Employment / Non-Discrimination and Equal Opportunity: DrC employs 877 professionals (nurses, technicians, receptionists and other administrative staff at corporate and facility levels), of which 81% are based in the medical centers. The workforce is predominantly composed of women (87%), aged 25 to 40. The company has consistently promoted gender diversity and pay equity, with 38% women at the C-level and 44% in senior leadership roles.
Workers’ Organizations: DrC complies with PS2 requirements on workers’ organizations, freedom of association and collective bargaining. Based on its workforce profile covered by the Brazilian Consolidation of Labor Laws, DrC signs collective agreements governing employment terms and conditions.
Retrenchment: Between 2023 and 2024, DrC’s transition process led to 103 layoffs. No further layoffs are expected in the short or medium term, though the company plans to expand artificial intelligence use and may pursue future M&As. As a part of ESAP #4, DrC will develop a Retrenchment Plan aligned with IFC PS2 requirements, applicable legislation, relevant collective agreements, and IFC’s Good Practice Note: Managing Retrenchment.
Workers’ Grievance Mechanism: Workers at DrC can report Code of Conduct violations and ethical concerns through the Ethics Care Line, which offers multiple channels, allows anonymous claims, and uses survivor-centered procedures for SEAH cases. This whistleblowing mechanism does not address labor and working conditions grievances as required in IFC PS2. Under ESAP #5, DrC will design and implement a Workers’ Grievance Mechanism to receive and resolve workplace complaints not covered by the Ethics Care Line. It will allow anonymous claims, protect against retaliation, ensure timely, fair, and documented resolution, be communicated to all workers/third-party contractors, and be embedded in induction and refresher training. For workplace-related SEAH reports, it will apply gender-responsive and survivor-centered procedures that ensure informed consent, psychosocial support, victims safeguarding during investigations, a minimum gender representation in investigation and decision-making, and integrate grievance monitoring into the ESMS using gender-responsive indicators and sex-disaggregated data.
Occupational Health and Safety: All facilities have undergone OHS risk assessments aligned with PS2 requirements, with safety procedures monitored and employees trained in job-related risks and controls. A specialized safety engineering and occupational medicine oversees workers’ health. Safety measures and KPIs, including incidents and accidents, are recorded and investigated, and national radiation safety regulations are followed, and the clinics obtain the respective certification.
All facilities maintain Risk Management and Medical Control Programs, provide PPE training, keep technical workplace condition reports, and have accident prevention committees (CIPA) to promote safety awareness. The OHS committee meets regularly to review and implement safety plans.
In 2024, DrC recorded 45 occupational accidents resulting in 102 lost workdays, with a nonfatal injuries incident rate of 3.16 —below healthcare international benchmarks. No serious accidents or fatalities have occurred in the past three years, and near-miss incidents are not currently reported.
As part of the ESMS and ESAP #6, DrC will develop and implement an OHS Policy and procedures to meet the WBG’s EHS Guidelines for Health Care Facilities, including exposure to infections, diseases, hazardous materials and waste, and radiation, L&F Safety, and OHS. Compliance to Brazilian Regulatory Standards will also integrate the OHS Policy and procedures. This will include enhanced periodic inspections, monitoring, and OHS performance review, as well as proactive OHS KPIs with regular inspections and audits of facilities and construction works. Under ESAP #6, DrC will also establish a procedure for reporting, recording, and analyzing near misses across all facilities.
Workers Engaged by Third Parties and Supply Chain: DrC requires its third-party suppliers and contractors to comply with national laws through specific contract clauses, such as labor and OHS obligations, prohibition of child and forced labor and environmental aspects.
DrC’s current Code of Conduct applies to contractors and suppliers, but there is no structured process ensuring they are aware of or have acknowledged it. To address this, the Company is developing a dedicated Supplier Code of Conduct for contractors, suppliers and freelance medical professionals (e.g., doctors and dentists). Under ESAP #7, the Supplier Code of Conduct will include: (i) a procurement policy addressing child and forced labor and major safety issues as per PS2 requirements; (ii) contractual clauses prohibiting forced and child labor, extending this obligation to lower-tier suppliers; (iii) a communication strategy to inform all primary suppliers of labor requirements and risks; (iv) capacity-building through training and guidance on child and forced labor, safety, anti-SEAH and child safeguarding; (v) a policy of zero-tolerance for SEAH, other forms of GBV, child abuse, and discrimination.
The existing contracts and the current Code of Conduct do not include monitoring of labor and working conditions or EHS audits for third parties and partner hospitals, laboratories and when the DrC clinic is inside shopping malls. As part of ESAP #7, DrC will establish an operational procedure to assess and monitor its primary suppliers and partners (e.g., hospitals, laboratories, and shopping malls) to manage PS2 requirements, including labor and OHS aspects, GBV, SEAH and child safeguarding. Complementary, under ESAP #1 and as part of the ESMS, DrC will establish a contractor management procedure to meet environmental, social, health and safety (ESHS) requirements in line with IFC PSs and WBG General EHS Guidelines. This procedure will include ESHS preselection criteria, ESHS audits and monitoring, and reporting.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency: Electricity for all facilities is supplied from the national grid (67%, 26 units of low-voltage) and from renewable energy (33%, 4 units, medium-voltage). In 2024, the total amount of electricity consumed was 3.801.668 kWh. This data is reported to senior management and sponsors. DrC takes internal actions to reduce the consumption of electricity, including internal communications campaigns, which resulted in a 9% reduction in the use of energy between 2023 and 2024. Heaters/boilers supply only hot water, and natural gas is used for cooking. Most facilities have backup diesel generators, with both natural gas systems and generators periodically monitored as required by law.
In 2024 the Company consumed 15,442 m³ of water from the public supply network. DrC has installed water-meter monitoring equipment in all units, which allows the prompt identification of changes in water consumption patterns, and suspected leaks, thus reducing water loss.
Greenhouse Gases: DrC uses the Persefoni platform to quantify Greenhouse Gases (GHG) emissions, applying the GHG Protocol and Partnership for Carbon Accounting Financials (PCAF) methodologies. In 2024, the Company replaced R22 with the more environmentally friendly R410 refrigerant, which is less harmful to the ozone layer and contributes less to global warming. That year, DrC’s total carbon footprint was 17,450.23 tons of CO2eq: direct emissions, Scope 1, 1,441.35 tons; and indirect emissions, Scopes 2 and 3, 15,981.88 tons.
Air Emissions: DrC’s existing and planned facilities have no significant impact on ambient air quality. The Company does not own incinerators —hazardous waste for incineration in handled externally by legalized partners — nor use styrene oxide or other harmful substances in sterilization, which is done via autoclave for dentistry and minor procedures. Laboratory work is not performed in-house; all samples are analyzed by certified third-party laboratories.
In compliance with Brazilian regulations, DrC hires service providers for periodic testing and cleaning of internal airducts to protect employees and patients and prevent infectious agent transmission via ventilation system.
Wastewater Management: All domestic wastewater from DrC facilities is discharged to municipal collection networks in compliance with local regulations. Liquid effluents, including biomedical test waste (e.g., blood, urea) and chemicals, are collected separately and disposed of as hazardous waste by certified third-party companies.
Solid Waste Management and Hazardous Materials: DrC has a waste management operational procedure aligned with PS3 for managing hazardous and non-hazardous waste, including health service waste. All facilities follow a Healthcare Waste Management Plan, ensuring segregation, packaging, identification, transport, storage, and disposal in compliance with national law for regular waste, batteries, fluorescent bulbs, infectious, chemical, sharp, and radioactive waste. Biomedical and radioactive waste are segregated and temporarily stored in isolated and specific areas. Certified third-party companies collect the waste within 24-72 hours. Domestic and organic waste go to licensed sanitary landfills, while chemical, infectious, and sharp waste is incinerated by accredited providers.
DrC follows an operational procedure for Chemical Products Management across all facilities. Hazardous materials are limited to small volumes of chemicals, solvents, drugs, anesthetics, and diesel for power generation. They are stored in well-ventilated areas, segregated by their risk, and handled by trained staff using required PPE, with Material Safety Data Sheets available for all compounds. Radioactive material, including liquid effluents, in imaging and radiology rooms are controlled through internal procedures, accessible only to approved personnel, and not kept in DrC’s facilities’ storage. Radioactive waste is transferred and disposed of by authorized companies in accordance with Brazilian regulations and WBG General EHS Guidelines.
Pesticide Use and Management: DrC conducts urban pest control at all its facilities every six months, targeting rodents and insects through certified contractors in compliance with national EHS laws and regulations. Current chemicals include Alpha-cypermethrin for insects (CAS No. 67375-30-8, WHO hazard class II – Moderately hazardous) and Brodifacoum for rodents (CAS No. 56073-10-0, WHO hazard class Ia – Extremely hazardous). Under ESAP #8, DrC will: (i) develop a phase-out plan to decommission WHO Class Ia pesticides; (ii) update hazardous chemicals management procedures and procurement practices to meet IFC PS requirements, committing to avoid Class Ia, and Ib (and Class II if appropriate control measures are not in place); and (iii) replace the highly and extremely hazardous substances with alternatives of low human toxicity, proven effectiveness against the target species, and minimal impact on non-target species and the environment.
PS4-Community Health, Safety and Security
Community Health and Safety and Community Exposure to Disease: DrC facilities are regulated and audited by the National Agency for Sanitary Vigilance (ANVISA), which approves clinics designs, issues operating licenses, and inspects healthcare units regularly. The Company applies clinical and non-clinical measures set forth in operational procedures to eliminate community exposure to disease exposure risk and prevent infections, including exposure to hazardous materials and waste. Rooms with ionizing radiation equipment have appropriate lead-based protection and undergo periodic tests. The Company monitors community and patient health and safety through bacteriological checks of floors and walls, water quality testing, and radiation exposure. Air ducts are periodically tested and cleaned as per local regulations by certified providers. Pest control systems and good sanitation practices were identified in all facilities.
Infrastructure and Equipment Design and Safety and Emergency Preparedness and Response: L&FS infrastructure and systems comply with local regulations and include various fire extinguishers, a centralized fire detection and alarm system, hose reels on every floor, and water tanks with fire pumps. When selecting the sites for healthcare facilities, the Company hires specialized consultants to develop a complete feasibility report (EVTL), providing E&S managers with information for decision making and identifying required modifications to correct non-compliances and structural issues.
Under ESAP #9, DrC will develop a corporate standard “L&FS Design Manual” based on the safest local laws across Brazilian states of operations and international best practice for clinics, ambulatory units, laboratories and storage facilities. The Manual will guide all new constructions, major renovations, evaluation of existing buildings, and during M&As, including internal approval procedures to manage L&FS risks in exceptional situations in which DrC has limited leverage over building design, provided that compliance with the legislation and established requirements is guaranteed. L&FS professionals certify that buildings meet local fire codes and consider site-specific conditions, a practice that will be maintained and extended through the new Manual.
As a part of ESAP #9, DrC will strengthen inspection, testing, and maintenance of L&FS systems across all Brazilian states by developing L&FS-related KPIs for operation and maintenance, including systems that support patient life.
Security Personnel: DrC hires a third-party company to provide unarmed security for 10 facilities, with training delivered by the provider. Security presence is determined by the Patrimonial Security Risk Assessment, as some units are in shopping malls or commercial buildings with their own security personnel. The provider’s Patrimonial Security Management Policy, tailored to DrC facilities, enforces zero-tolerance for harassment, discrimination, or any conduct undermining dignity. Under ESAP #7, the security personnel will also receive anti-SEAH and child safeguarding training.
