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
Environmental and Social Assessment and Management System and Policy: FHH’s office, clinics, and medical centres are all in rented areas in established office buildings, healthcare centers, and private hospitals. Facility management usually follows each building landlord’s instruction for tenants. FHH does not have inhouse facility maintenance team and rely on contractors. FHH has established E&S management programs per national laws for medical waste, pressurized equipment operation, Code of Conduct and HR policies. However, they are not integrated into a structured management system that allows systematic identification and management of E&S risks and impacts commensurate to the operations of the Company. Therefore, as part of ESAP #1, FHH will develop and implement a corporate level integrated, risk-based ESMS commensurate with the E&S risks and impacts of its operations, compliant with national law and the requirements of IFC PSs, as well as 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, emergency preparedness response, key performance indicators, and an E&S monitoring and review process. The ESMS will be legally cascaded down to all medical centres and clinics.
Identification of risk and impacts: The Company currently manages E&S risks by complying with national regulations and permits. Malaysia law does not require an Environmental Impact Assessment (EIA) for establishing healthcare facilities in established healthcare centers; expansion site selection relies on FHH’s COO, local partners' experience. A third-party contractor with healthcare regulatory expertise will be engaged to support the establishment of new facilities. As part of ESAP #1, FHH will develop and implement a procedure to conduct ESDDs per national law and requirements of IFC PSs when selecting new sites or acquiring new assets, which may include existing buildings, health centers and established medical centres. The Company will also track licensing and national permit compliance across all facilities under ESAP #1.
Organizational Capacity and Competency: FHH’s COO is oversighting overall operation and on-going medical centre expansion activities. Each clinic and medical centre follow landlord instructions for tenants and receives landlord’s management services such as cleaning, security, and waste handling. The HR department manages labor and working conditions, including OHS, Company’s Code of Conduct. FHH needs to establish a structured ES team lead by an ES manager in Headquarter with ES focal person appointed at each clinic and medical centre, the team will oversee the ESMS development and implementation across all facilities and departments. FHH will also roll out structured ES training program. (ESAP#2).
Emergency Preparedness and Response (EPR): FHH currently does not have a corporate-level emergency plan in place. Each clinic follows the landlord’s schedule for LFS drills. To enhance emergency response preparedness, FHH will develop a comprehensive corporate Emergency Preparedness and Response plan (EPRP) as part of the ESMS under ESAP#1. This plan will address incidents involving biological or chemical hazards, as well as other risks such as civil unrest, flooding, and extreme heat. Additionally, the EPRP will include detailed evacuation procedures for patients with limited mobility or those who are immobilized following outpatient procedures Training programs will also be updated to incorporate these improvements, in accordance with ESAP#2.
PS 2 – Labor and Working Conditions
As of [31 December 2025], FHH directly employs [478] staff, [422] are full-time and [16] are part-time. 96 staff are in managerial roles, with [9] in Headquarter, [87] are medical specialists managing clinics and medical centres. Among the [326] operational staff, [34] are migrant workers from Philippines, Malaysia, Indonesia, and they engage in clinic operations, finance, nursing. Part-time workers were hired to support admin and finance functions. FHH also engages five visiting consultants through direct service contracts, and 5 third-party workers for the healthcare digital platform. As the company continues to grow, it remains focused on talent acquisition, with no plans for significant workforce retrenchment.
Working Conditions and Terms of Employment: FHH corporate policy adheres to principles of non-discrimination and equal opportunity. Employment conditions, compensation, attendance, leave, insurance, performance evaluation, and promotional policies are regulated by the corporate employee handbook, which is provided to all employees during the onboarding process. All staff sign an employment contract with the Company whose terms comply with national labor regulations. As the company continues to expand through acquisitions, it is transitioning the contracts and benefits of clinic staff, carefully considering their prior benefit structures. FHH will update corporate HR policy to enhance overtime management with reference to national law requirement and commit to zero tolerance on child labor and force labor, as per (ESAP#3). For Malaysia operation, FHH needs to adopt corporate level HR policy and procedure and tailored to comply with Malaysia local law requirement, including local requirement for migrant workers. (ESAP#4)
Worker's Organization: FHH does not have workers' organizations. Freedom of association is recognized in both Malaysia and Singapore under national law, though through different legal and institutional approaches. FHH commit to follow good practices established by Tripartite Alliance for Fair& Progressive Employment Practices (TAFEP), a national initiative that promotes equitable workplaces, enhancing employee well-being in Singapore. FHH will need to provide clear provision on Freedom of Association, which is aligned with Singapore and Malaysia national law requirement as per ESAP#3.
Grievance Redress Mechanism (GRM): FHH has put in place a formal GRM that applies to all employees and contractors. The mechanism includes defined roles, escalation procedures, guarantees against retaliation, and structured investigative processes. This GRM needs to be enhanced to include confidential and secure reporting channels with options for anonymous reports, clear provisions against retaliation, defined response timelines, and a survivor-centered approach. (ESAP#5)
Gender Based Violence and Harassment (GBVH) and Child Protection: FHH does not have comprehensive GBVH or child protection procedures, but it includes basic elements such as a confidential whistleblowing channel, disciplinary measures for harassment, and governance systems that help manage risks. These measures are generic and do not specifically address GBVH or child protection. FHH will establish group-wide GBVH and Child Protection policies, implement a Patient Safeguarding and Sexual Exploitation and Abuse (SEA) Policy, and appoint a GBVH focal point. The Focal Point will ensure regular GBVH training for all staff and relevant third-party workers. These measures, in line with local laws, will be applied throughout the Malaysia operations. (ESAP#5).
Protecting the Workforce: FHH’s HR policy does not have explicit statements on zero tolerance for child and forced labor. FHH will include clear statements on prohibiting child labor and forced labor in its HR Policy. Also, HR Policy will clearly explain that all migrant workers need obtain the work permit and clearly state all recruitment related expenses are borne by the company. (ESAP#3)
Occupational Health and Safety (OHS): FHH has developed workplace health and safety manual which provides a structured framework for OHS risk identification, incident prevention, reporting, and management. FHH will roll out this manual in its clinics and medical centres with specific risk identification, and propose effective prevention measures, including structured training and awareness raising program.
Management of Third-Party Workers: FHH employs 5 third-party workers remotely working for the healthcare digital platform through a third-party service agreement. The 5 workers closely work in FHH group operations. FHH verify all the labor contracts for the 5 workers to make sure they are aligned with the applicable national law requirements. FHH’s GRM is also applicable for them to raise workplace concern.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency: Energy and water consumption are comparable to standard office operations, classified as domestic use with minimal environmental impact. FHH is engaging with a third-party to identify potential resource efficiency programs.
Pollution Abatement: Wastewater management relies on landlord existing system. As most health care facilities are designed for health care consideration, wastewater collection and treatment have been approved by treatment networks.
Waste Management: General and medical waste are separated and collected daily from each clinic and medical centre, then stored at the nearest collection point until picked up by licensed collectors. For future Malaysia operations, the management system framework (see ESAP item # 1) will also address management of hazardous waste at storage points and handling procedures.
Hazardous Material Management: FHH will identify any chemical risk per ESMS and develop a Chemical Safety Management Program to provide guidance for the management of identified hazardous materials. The program should provide information to the workers/staff about health effects of exposure to hazardous substances, provide guidance for safe handling, incident response. The procedure requires placement of Material Safety Data Sheets (MSDS) at the facility level, where the chemicals are handled and used.
PS 4 – Community Health, Safety and Security
Infrastructure, and Equipment Design & Safety: FHH’s facilities are in healthcare centers and private hospitals which are designed for universal accessibility, incorporating ramps and elevators to facilitate the safe and comfortable movement of all patients and visitors. The facilities’ Life and Fire Safety (L&FS) features are regulated by local fire codes, requiring the landlord to maintain L&FS systems and coordinate emergency procedures. FHH cannot install or modify fire or security systems in leased spaces without written landlord approval and must ensure its installations do not affect building-wide systems. The landlord's service providers handle routine inspection and maintenance of the L&FS systems. Any changes or new installations within FHH’s premises require review and approval from both local authorities and the building management team before implementation. Based on IFC's site visit and review of selected facilities, the current L&FS features for FHH’s facilities in Singapore are aligned with Good International Industry Practice (GIIP).
FHH will create a corporate Life & Fire Safety Design Manual that follows relevant Singaporean and Malaysian regulations, aligns with international best practices for healthcare facilities, and provides guidance for new construction, major renovations, and assessments of existing buildings. Additionally, FHH will implement a program for inspecting, testing, and maintaining critical internal L&FS components in coordination with building operations. The program will use KPIs to track readiness and maintenance effectiveness and follow management of change procedures for any modifications to safety systems or infrastructure. (ESAP#6).
Community Exposure to Disease: FHH facilities are regulated and inspected by the Ministry of Health which approves clinics designs, issues operating licenses, and inspects healthcare units on a risk-based approach. The Company applies clinical and non-clinical measures such as cleaning and disinfection, vector control set forth in operational procedures to eliminate community exposure to disease exposure risk and prevent infections, including exposure to hazardous materials and waste.
Security personnel: Security services are coordinated with the landlords and the facility/building management. At each location, separate access controls exist.
