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
Policy: APU has established an ESG Policy structured around four key pillars: Sustainable Planning & Campus Design, People & Social Impact, Environmental Conservation & Biodiversity, Governance & Transparency. The ESG Policy sets forth specific objectives, targets, initiatives, and practices within each pillar to advance the institution's sustainability agenda. The ESG policy will be updated to explicitly express compliance with national E&S laws and adopt IFC Performance Standard, as per ESAP#1.
Identification of risk and impacts: As part of TPM, APU utilizes the technology park's infrastructure and ecosystem. An Environmental Impact Assessment (EIA) was completed in the early 1990s when TPM was established. For on-going campus expansion, APU follows the national law requirements to get Building Plan Approval and requires the EPC contractor to follow national law requirements on E&S matters. For daily operations, APU has prepared an E&S mapping to identify significant E&S issues and a gap analysis to improve sustainability practices.
Management Programs: APU is accredited by the UK Quality Assurance Agency (QAA) and holds ISO 9001:2015 and ISO 21001:2018 certifications. APU has established a Green Management Plan which sets out goals for energy and carbon reduction, waste and water management, sustainable transportation, responsible procurement, and integrating sustainability into 60% of courses, supporting a comprehensive approach to environmental sustainability.
Facility maintenance, including electrical work and L&FS, is managed daily by a five-member team led by an EHS officer. Security, canteen services, and shuttle bus operations are managed by third-party providers. Safety requirements for facility maintenance are included in the operational manual. However, during the ESDD site visit, observations were made regarding Occupational, Health and Safety (OHS) and environmental management gaps in facility maintenance. APU will establish: i) E&S risk identification; ii) roles and responsibilities; iii) EHS management programs, including high risk operation SOPs and pollution prevention programs, OHS incident reporting, life and fire safety (L&FS), traffic management; iv) training programs; v) EHS performance KPIs and monitoring program as per ESAP#2.
APU has already engaged an EPC contractor for future expansion construction work. During construction, OHS risks will be managed by construction EPC contractors to follow national and PS2 requirements including the composition of OHS person, OHS training and capacity building, use of personal protective equipment, incident reporting, safety supervision and oversight, etc. APU will have on-site EHS officers, work with inspection authorities, and hire third-party consultants to monitor construction OHS and E&S performance, following up with the team on any issues found. As per ESAP #3, APU will formalize its practice into an oversight construction management plan (OCMP) that aligns with IFC's PSs requirements and National Law requirement for future expansion construction. The OCMP (ESAP#4) will include: i) compliance of regulatory OHS management requirement, regulatory construction EMPs; ii) labor practice, including prohibiting child labor and force labor; and maintain oversight the EPC contractors migrant labor recruiting and management practice; iii) requiring worker accommodations meet IFC standards; iv) performances checking database with performance status of the contractors. APU will also require the EPC contractor to prepare and implement a Labor Management Plan including: i) labor recruitment plan fully aligned with national law and PS requirement and free of any practice of force labor and child labor; ii) worker’s accommodation management plan align with IFC guidance note for worker’s accommodation; iii) extend the above requirement to subcontractors to be hired for construction.
Organizational Capacity: The Environment and Climate Action Board and Sustainable Taskforce at APU oversee sustainability efforts and legal compliance, guided by the chief sustainability officer. The taskforce includes members from the quality management department, finance, and senior academic staff. Infrastructure, facility management, canteen and logistics service are overseen by different staff who report to the Chief Operating Officer. Human Resources (HR) and Regulatory Compliance are overseen by the Director of Administration and Human Resources. The Finance Department is responsible for managing procurement activities. A safety officer is responsible for overall coordination of OHS risk management activities in relation to the following: facility maintenance safety, construction work safety oversight, L&FS; emergency preparedness and response. The safety officer consistently delivers OHS training to operation staff. All staff are provided with an ESG induction and training.
Emergency Preparedness and Response Plan (EPRP): APU has created an Emergency Response Plan (ERP) outlining priorities and responsibilities for emergency responses for fire-related emergency scenarios. The plan includes Standard Operating Procedures (SOPs) for ERP implementation, details of the structure and roles of the Emergency Response Team (ERT) and covers training and response drills for emergency preparedness. However, emergency preparedness does not include other scenarios such as water quality degradation, food safety incidents, traffic-related accidents, natural disasters, and public health emergencies (e.g., epidemic outbreaks), to be improved as per ESAP#5.
Monitoring and review: APU prepares annual sustainability report focused on the United Nation Sustainable Development Goals (UNSDG). Although APU has established EHS management requirements into the facility operational procedures and monitoring programs, no written EHS Key Performance Indicators (KPIs) are defined. APU will indicate KPIs related to Environmental and OHS management, L&FS and traffic management as per ESAP#2.
PS2: Labor and Working Conditions
APU employs over 798 staff (of which 45% are female), including 634 full-time and 44 part-time teachers, administrators, support, maintenance, and security personnel, APU also hires 120 students in various student service roles. The company has direct contracts with all staff, salary and benefits levels are determined by referencing prevailing labor market rates at comparable industry levels. The company complies with national labor laws regarding minimum wage, working hours, and overtime. APU engages around 60 third party workers providing canteen service, security, and shuttle bus service. The company hires construction contractors to build or upgrade facilities. No major retrenchment is planned in the foreseeable future as the company is expanding operations.
Human Resources (HR) policies and procedures: APU corporate HR Policies and Procedures are established per Malaysia labor laws requirements and include policy commitments which prohibit the use of forced or child labor, non-discrimination provisions, and a general prohibition of workplace harassment.
Terms of employment and working conditions are specified in staff handbooks related to probation, working hours, performance review, insurance, salary and compensation, resignation, other leave, retirement, and respectful workplace, gender equality and harassment.
Working Conditions and Terms of Employment: All full-time employees have a signed employment contract with the key employment terms and conditions including job description, working place, duration of employment, salary, and benefits, leave entitlements, welfare and social insurance, probation and notice periods, etc. Part-time employees also signed an independent contractor agreement with defined service, payment, contract period, etc.
Worker's Organization: APU does not have a labor union, and its policies do not explicitly commit to allowing employees to form or join workers' organizations without retaliation or discrimination. The company will update HR policy to provide clear freedom of association provision as per ESAP#6.
Non-Discrimination and Equal Opportunity: The HR policy at APU outlines provisions for equal opportunity and non-discrimination, prohibiting discrimination based on gender, ethnicity, race, or political affiliation. It also guarantees equality and addresses harassment concerns.
Grievance Redress Mechanism: APU has a company-wide whistle-blowing policy and a grievance mechanism that is only accessible to full time staff. The grievance mechanism does not provide a channel for anonymous grievance, nor does it provide a clear response timeline. APU will upgrade the Grievance Mechanism and extend the applicability to all laborers, including part-time workers, construction workers and third-party contractors as per ESAP#7.
Prevention of Sexual Harassment and Protecting the Workforce: APU has foundational policies in place related to ethical conduct, whistleblowing, and disciplinary procedures. However, the existing policies do not explicitly address GBVH risks, outline clear protection for survivors, or ensure accessible, confidential, and safe reporting pathways. Most policies and the accompanied procedures and practices are generic in nature and do not reflect the specific risks and safeguards required to address GBVH and child safeguarding within academic institutions. As per ESAP #8, APU will (i) review and revise HR policies, codes of conduct, grievance procedures, and safeguarding frameworks to include explicit GBVH and child protection provisions, and establish GBVH referral pathways; (ii) appoint and train a designated focal point to manage survivor-centered grievance processes and ensure confidential case management; (iii) integrate mandatory training and awareness programs for all staff (including part-time teachers, student counselors, dormitory supervisors, construction workers and drivers), contractors, and students, supported by contractual clauses requiring contractors to prohibit GBVH and child abuse; (iv) roll out student-focused awareness campaigns and induction sessions on GBVH/SEAH, safeguarding, and safe reporting pathways; and (v) establish a monitoring and evaluation framework to assess the effectiveness of GBVH/SEAH measures, report annually to IFC, and integrate lessons learned into continuous institutional improvement.
Protection of workforce: APU complies with national law and does not hire workers below the age of 18 years. The HR team checks birth and school certificates during the hiring process. No forced labor practices are identified for direct workers. All migrant workers obtain the needed work permit.
Accommodation: APU does not provide accommodation for staff. APU will incorporate IFC and EBRD Guidance Note on Workers’ Accommodation into its construction management oversight plan and monitor implementation for compliance (see ESAP#3).
Occupational Health and Safety (OHS): There are no statistics on occupational health and safety (OHS) incidents in APU in the past including traffic accidents during daily commute. Given the company’s business nature, OHS risks during operation are limited. The clients will establish an OHS reporting procedure, including incident reporting and rout cause analysis. The OHS reporting requirement should also extend to third party workers, and construction workers as per ESAP#2.
Workers Engaged by Third Parties: APU collaborates with various third-party service providers to support university operations, including security, canteen operations, shuttle bus services, etc. Those providers are subject to corporate procurement policy with a focus on environmental management. Site visit discussion with APU confirms there is no oversight with those workers hired through third-party. APU will develop third-party labor management program as per ESAP#9, which will: i) make explicit statement on prohibiting any forced labor and child labor practice, ii) incorporate national and PS2 labor compliance provision into service contract, iii) maintain regular oversight of third-party labor practice, including quarterly check for national law requirement for minimal wages, working hours and over-time payment, social security etc.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: APU relies on municipal water and electricity for its operations. The client has developed a carbon neutrality roadmap aimed to reduce its footprint by improving energy efficiency across campus, including optimized air conditioning and lighting systems. The estimated greenhouse gas emissions are 5,623 tCO2e. APU collects rainwater for landscape irrigation and uses water-efficient fixtures, reducing potable water use by 35%.
Pollution Prevention: the APU campus operates two backup diesel generators. There are no boilers on campus; all shower water is heated electrically. LPG is used for cooking in the canteen and powering laundry driers.
Wastewater, which includes sanitary effluent and water used for cooling, is discharged into the TPM municipal sewage system. This water is then directed to the local wastewater treatment plant (WWTP) for processing before discharge. Stormwater is initially collected in separate stormwater drains and subsequently released into the combined municipal sewage system. Storm water contamination by canteen waste was observed during site visit, which needs to be improved as per ESAP#10.
APU uses centralized cooling equipment with cooling tower. Cooling water quality is regularly checked including pH, conductivity, total dissolved solids, NaCl, iron, and legionella.
Waste management: APU operates a campus-wide recycling program with bins across campus, collected daily and picked up weekly by a licensed company. Non-hazardous waste is centralized and collected twice weekly by licensed companies. Several bins were found overfilled during the site visit. This will be improved as per ESAP#10. Clinic waste is labeled and stored on-site, regularly handled by licensed third party.
Pesticide and chemical management: Both APU and canteen service providers use food grade Pesticide for pest control measures, which is biodegradable and poses limited risk to students and community. APU lab uses small quantity of chemicals. Lab managers maintain the content of the Safety Data Sheets for all chemicals. Access is restricted, emergency equipment such as shower and eye washing equipment are easily accessible. Chemicals are stored in approved labelled containers with secondary containment (for liquids) and are segregated based on their compatibility. Container integrity is regularly inspected.
PS4: Community Health, Safety & Security
There have been no major security and safety incidents (i.e. fires; food poisoning; harassment incidents; vandalism; etc.) at the campus since operational commencement. Unarmed security guards are provided by a third party and externally trained in professional conduct and security procedures.
APU follows Malaysia building code for university layouts and density, which includes specific building structural code for different function of buildings and facilities for the inclusion of safety features, taking into consideration gender appropriate facilities and amenities, with universal access features in their design. All detailed plans undergo approval by the relevant government agencies prior to the commencement of construction. During the construction phase, periodic and final inspections, including L&FS certification, are conducted by government authorities to ensure compliance with regulatory requirements. A third-party L&FS consultant will be engaged to undertake L&FS design and project completion review to verify each new or substantive renovated facility or cluster (i.e. a collection of campus facilities and buildings) upon their completion to confirm the L&FS systems has met with the accepted design and the L&FS section of the WBG General EHS Guidelines as per ESAP#11. Multiple gaps in L&FS maintenance were observed during the site visit, such as expired batteries in the fire system, improper placement of emergency shutoff mechanisms, and restricted access to designated exits. APU will enhance L&FS management capacity and engage a qualified LF&S consultant to i) identify L&FS gaps of existing buildings and develop a time-bounded corrective action plans (CAPs); ii) develop a plan for Inspection, Testing and Maintenance (ITM) for L&FS system (ESAP#11).
APU campus is not located within active earthquake zone, the client follows Malaysia local law requirement for building structure safety, which set minimum standards for design and materials. APU demonstrates its commitment to disability access by engaging architects in both refurbishment and new construction projects. Current facilities include wheelchair ramps at principal entrances, accessible lifts in multiple Blocks, as well as disabled-friendly restrooms on every floor of block. APU will require the EPC contractor to incorporate student and community safety prevention measures and maintain access for disabled people during construction as per ESAP#12.
APU works with several third-party food providers to manage its canteen outlets. A comprehensive food hygiene management system is lacking, with minimal fridge and freezer temperature checks, worn or unclean chopping boards, and no central register of food staff health or vaccination status at APU. APU will develop a clear food safety management program including: i) food safety and hygiene guideline applicable to all service providers; ii) maintain a central registration including certifications, vaccinations and expiry dates for all food related workers; iii) regular monitoring. This needs to be improved through ESAP#13.
