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:
Live Easy is in the process of developing an Environmental and Social Management System (ESMS). Live Easy will establish a corporate ESMS and ensure alignment with IFC’s PS1 and national requirements (ESAP #1a) to formalize existing management practices for this project. The ESMS will include the following management programs to develop projects and operate in a manner consistent with IFC’s PSs: (i) Environmental, Health and Safety (EHS) management plan, (ii) Environmental and Social Risk identification and assessment procedures, (iii) Emergency Preparedness and Response Plan (EPRP), (iv) Contractor Management Plan, (v) Stakeholder Engagement Plan (SEP), (vi) Security Management Plan, (vii) Operations and Monitoring, including reporting procedure, and (viii) an External communication and grievance mechanism plan. In addition to this, the company will employ a qualified consultant with E&S experience to support the development of the ESMS manual (ESAP #1b).
Identification of Risks and Impacts & Management Programs:
Live Easy identifies and acquires properties for conversion into nano rental units through auction houses, brokerages, property funds, or direct sellers. It secures rezoning, fire safety, and municipal approvals for refurbishment and construction. Because the model focuses on existing structures, Environmental and Social Impact Assessments (ESIA) are generally not required by regulation. As part of its ESMS, the Company will establish an E&S risk identification and assessment procedure that will substitute for the ESIA and will assess project-specific risks prior to acquisitions. The procedure will incorporate local legal requirements and IFC PSs and will identify key risks related to life and fire safety, land acquisition, EHS, and emergency response (ESAP #1a). Live Easy will also develop management programs to address construction and operational risks and impacts to be formalized under the ESMS including OHS, noise, resource efficiency, air emissions, wastewater, solid waste, and hazardous materials.
E&S Organization Capacity:
The environmental consultant is responsible for the oversight and implementation of E&S aspects during construction, in line with national regulations, including keeps an OHS file on site and is responsible for monitoring construction performance. The operations team at Live Easy are responsible for E&S oversight during operations. Live Easy building managers, who live on site, are trained as first aid responders and are also responsible for conducting fire drills, tenant engagement, and identifying maintenance issues. In line with PS 1, the company will appoint an E&S Manager responsible for E&S coordination and implementation of the ESMS during construction and operation phase (ESAP #2). The company may continue with current consultant-led oversight as an interim measure pending recruitment under ESAP #2. Furthermore, Live Easy will appoint an E&S representative at each asset to support the E&S Manager and develop and define clear roles and responsibilities for E&S risk management in ESMS for the E&S Manager and E&S representatives (ESAP #1a).
Emergency Preparedness and Response:
Live Easy implements an Emergency Procedure Manual covering fire, medical incidents, suspicious activity/security threats, and service disruptions. The manual outlines general response principles, post-incident requirements, tenant reporting arrangements, and emergency contacts. Under the ESMS (ESAP #1a), Live Easy will consolidate and enhance these project-level procedures into a corporate Emergency Preparedness and Response Plan (EPRP) to establish a common standard across planned Pula assets during construction and operations. The EPRP will include a risk-based assessment of emergency scenarios (including climate-related events), evacuation decision-making, stakeholder communication protocols, defined roles and responsibilities for staff and occupants, response procedures, and periodic training, including internal fire marshal training, evacuation exercises, and semi-annual fire drills, in line with local regulations.
Monitoring and Review:
The appointed construction contractor hires an OHS contractor who visits the project site weekly and an appointed Safety, Health, and Environment (SHE) representative responsible for daily toolbox talks and inspections, who is part of the site construction team and is always on site. The contractor provides monthly management reports to the Live Easy management team, which tracks construction progress. As part of the ESMS (ESAP #1a), the company will create an E&S monitoring and reporting procedure to be implemented by the E&S manager to maintain consistent oversight of building performance throughout both construction and operational phases, tracking key performance indicators (KPIs) and corrective actions, and further shared with management for review.
PS2: Labor and Working Condition:
As of January 2026, Live Easy had a total of 175 directly employed staff (113 male and 62 female), composed of building managers, maintenance, and cleaners. Retrofitting of buildings typically requires between 20 – 60 third-party construction workers on-site at any one time.
Human Resources Policies and Procedures:
Live Easy implements a Human Resources (HR) Policies and Procedures manual. All employees are provided with written contracts along with the HR manual. The manual (effective February 2026) generally highlights provisions relating to legislation, equal opportunity and non-discrimination, Gender-based Violence (GBV) and sexual harassment, worker grievances, OHS, accident and near-miss reporting, and disciplinary guidance. In line with PS 2 requirements, Live Easy will update its HR manual (ESAP #3) to address topics that are currently absent which include: freedom of association and collective bargaining, child labor and forced labor/trafficking prohibition, retrenchment, and defined grievance mechanism policy and procedures. Updated HR policies and procedures will be communicated to workers and contractors through various channels including induction, regular training, and refreshers. In addition, Live Easy will develop and implement a GBV management plan to identify and mitigate risks of gender-based violence, sexual exploitation and abuse (SEA), sexual harassment (SH), and child abuse across its operations. The plan will include a standalone GBV, anti-harassment and child safeguarding policy, strengthened codes of conduct, confidential grievance channels for workers and communities with defined referral pathways, mandatory training, and integration of GBV requirements into contractor and supplier management (ESAP #4).
Working Conditions and Terms of Employment:
All Live Easy employees are issued written employment contracts that define job title, contract term, role-specific duties and responsibilities, working hours, statutory leave entitlements, compensation and benefits, health and safety provisions, probation, and termination conditions. The preferred construction contractor operates under a Joint Building Contracts Committee (JBCC) agreement, a standard construction contract in South Africa, which also applies to subcontractors engaged on the Project. Employees are further guided by a Code of Conduct covering workplace behavior, use of company property, data protection and confidentiality, dress code, and professional conduct. Under ESAP #3, Live Easy will review and consolidate its human resources policies currently spread across several documents into a streamlined suite of documents, with any supporting references annexed as necessary.
Non-discrimination and Equal Opportunity:
The HR manual states the commitment made by the company to provide equal employment opportunities and maintaining a work environment free from discrimination, in line with the Employment Equity Act of South Africa. The document also states a zero-tolerance to gender-based violence and sexual harassment. No incidents have been reported through existing channels in the last year.
Workers Organizations:
None of the Live Easy employees or contractors are unionized. Live Easy allows workers the liberty to join unions and has no restrictions to alternative mechanisms employees would use to express their grievance. As per ESAP #3, the company will update its HR manual to include explicit policy commitments to freedom of association in accordance with national regulations and IFC PS 2.
Retrenchment:
Live Easy has not undertaken retrenchments recently, and none are expected for this project. The HR Manual does not provide guidance on the process to be followed in the event of retrenchments. Live Easy will make provision around commitments to complete retrenchment consistent with requirements of IFC PS 2 and the local laws, as part of ESAP #3.
Grievance Mechanism:
Live Easy does not currently have a standalone, formally documented grievance mechanism dedicated to workers and third-party contractors that is aligned with IFC PS2 requirements. While informal channels exist, these are not clearly defined for workers nor supported by documented procedures, roles, or timelines. To address this gap, Live Easy will update its Human Resources manual to establish and implement a formal worker grievance mechanism that will also capture gender related complaints applicable to direct workers, contractors, and casual workers, including clear procedures for submitting grievances (including anonymous reporting), defined responsibilities, investigation and resolution processes, indicative timelines, and escalation provisions, consistent with IFC PS2 (ESAP #3).
Protecting the Workforce:
South African law prohibits the use of child labor and forced labor. As part of its recruitment process, Live Easy verifies prospective employees’ identities and conducts background checks, including criminal record screening and credit checks.
Occupational Health and Safety:
Occupational health and safety (OHS) risks at Live Easy construction sites include working at heights, dust and fumes from demolitions, slips and falls, and fire hazards. The construction contractor engages an OHS consultant to develop and implement site-specific OHS policies and procedures, conduct weekly site inspections, ensure provision of personal protective equipment (PPE), and maintain OHS records. Female workers are accommodated with dedicated lavatories and changing facilities. While monthly reports are shared with management, these currently provide limited coverage of E&S issues. At the operational level, OHS arrangements are guided by a basic OHS policy for maintenance and housekeeping. As part of the ESMS (ESAP #1a), Live Easy will develop and implement a corporate OHS Management Plan applicable to both construction and operations, covering minimum construction safety requirements, OHS, governance and committee roles, fall protection, PPE, site inductions, incident and near-miss reporting, safety meetings, and lost time injury rate (LTIR) tracking in line with national regulations, WBG General and Sector Guidelines, and IFC PS2.
Workers Engaged by Third Parties
Live Easy has contracted 14 contractors that provide security, cleaning, landscaping, elevator services, and waste collection, amongst others. During turnover/ move out periods, Live Easy will also hire causal workers to assist tenants with moving in. These casual workers are required to provide their identification documents and confirmation letters for their bank account. Live Easy has identified a group of preferred casual workers, selected based on previous experience and familiarity with their technical standards, quality of work, and on-site performance. Live Easy will develop a Contractor Management Plan within its ESMS to formalize processes for managing contractors and casual workers, including contractor vetting, application of occupational health and safety policies and procedures, and access to grievance mechanisms (ESAP #1a). At select sites, Live Easy provides on site accommodation for third party security personnel. Live Easy will assess existing accommodation for third party workers against IFC PS2 and the WBG Environmental, Health and Safety Guidelines for Workers’ Accommodation and implement corrective measures, as needed, with management of these actions integrated into the Contractor Management Plan (ESAP #1a).
PS3: Resource Efficiency and Pollution Prevention:
Resource Efficiency:
Live Easy incorporates energy efficiency measures in both design and operations, including redevelopment of existing buildings rather than new builds, use of energy-efficient lighting, and installation of day/night sensors and motion detectors. Projects will source electricity from the national grid. The units are fitted with pre-paid electricity meters. Live Easy makes use of solar solutions with batteries to provide power to common areas at some of its sites. In line with IFC PS3 requirements, Live Easy will formalize energy and water efficiency measures, monitoring, and management arrangements within its ESMS under the monitoring and reporting procedures (ESAP #1a).
Water and Wastewater:
The company plans to have boreholes at all its sites for the Pula project to supplement municipal supply. Any future borehole development would be subject to appropriate sitting, permitting, abstraction assessments, and operational controls in accordance with national requirements and IFC PS3, to be addressed through future management planning under the ESMS (ESAP #1a). Water at Live Easy sites is prepaid and each unit has a water meter installed. Live Easy uses dry walling to make the divisions of the units, which requires minimal water use at construction. Wastewater is discharged into the municipal sewer system.
Solid and hazardous waste management:
The company uses a private waste management company to collect solid waste during operations. During refurbishments, the contractor is responsible for the disposal of construction waste which is done by a waste company. Live Easy occasionally uses generators but does not store any fuel on site. An independent contractor will do the refueling on an ad hoc basis. While construction may generate rubble, concrete, wood, glass, and tiles, no significant hazardous waste is expected. The solid waste collected from the construction site is periodically collected and recycled by a licensed third-party contractor. As part of the management programs to be developed (ESAP #1a), Live Easy will develop and implement a corporate waste management plan that will cover construction and operation to ensure the correct disposal of waste.
PS4: Community Health, Safety and Security:
Infrastructure and Equipment Design, Life and Fire Safety (L&FS):
Live Easy prohibits the use of gas stoves and heaters on its premises to reduce fire risk and has building managers who conduct periodic fire drills. All properties are designed and refurbished in accordance with the South African National Building Regulations and Building Standards Act (SABS 0400), including applicable accessibility requirements. Fire safety systems for new projects will be designed, installed, and certified by independent fire experts at commissioning, and properties visited during the appraisal were equipped with fire hoses, extinguishers, and fire detection and alarm systems in common areas. The adapted buildings were provided with the required means of egress and adequate exit staircases, fire and smoke compartmentation, accessibility requirements and signage, as per local South African fire regulations. Under ESAP #1a, Live Easy will develop a corporate building commissioning program and a Life and Fire Safety (L&FS) Operations and Maintenance (O&M) plan defining system operation, inspection, testing and maintenance requirements, and emergency preparedness measures, which will be implemented by building managers across the Pula Project.
Community Health and Safety:
During construction, traffic on site may increase with the delivery of materials and equipment and is controlled by the environmental contractor on site. Periods when tenants would be moving in and out, also result in localized traffic disruptions. Live Easy will implement site-specific Traffic Management Plans under the Contractor Management Plan (ESAP #1a), to systematically manage traffic-related risks at each asset. At selected sites, Live Easy has made accommodations for a small childcare facility, canteen and convenience service and a hair salon. These amenities, offered by independent contractors, trigger health and safety risks to tenants at each site. Live Easy will apply the Contractor Management Plan once it’s developed in these cases, ensuring vetting and permitting compliance, where applicable. As part of ESAP #4, Live Easy will implement a Child Protection and Safeguarding Policy applicable to the site with the childcare facility and sites where children may reside.
Security Personnel:
The company engages the services of an independent security contractor licensed under South Africa’s Private Security Industry Regulation Act (PSIRA), which deploys 6-8 security personnel at each site. They are responsible for tracking visitor logs and recording any incidents. Security personnel are unarmed and provided with panic buttons linked to an armed response security firm. The construction contractor utilized the services of the same security contractor at construction sites. Under ESAP #1a, Live Easy will undertake a proportionate security risk assessment to identify and assess potential security-related risks and impacts and subsequently develop and implement a corporate Security Management Plan aligned with IFC PS4, defining security management practices, roles, procedures, and oversight arrangements.
