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
Policy: Sunway Healthcare's sustainability policy follows national law E&S requirements. The sustainability strategy is built on four main pillars: patients, employees, community, and the environment, all aligned with the United Nations Sustainable Development Goals.
Identification of risk and impacts: Sunway Healthcare identifies and manages E&S risks and impacts associated with its operations through applicable national standards and E&S regulatory requirements, including the requirement of environmental impact assessment (EIA). The company keeps a risk register of physical, chemical, biological, natural, and environmental hazards, reviewing it annually or whenever new hazards are identified, or hospital operating process changes occur.
Life & Fire safety permits have been secured for each operating facility. For on-going expansion activities, Sunway Healthcare maintains management program which stipulates ongoing compliance with relevant national permits, Life & Fire safety design code, Environmental and Occupational Health Safety (OHS) management requirements.
Greenfield project construction will follow national law requirements on environmental impact assessment, facility design standard for safety, accessibility, infection control, Life and Fire Security. The contractors of the greenfield projects are required to implement EMP and OHS management plan, providing accommodation for all migrant workers following national requirements and IFC Performance Standards.
For any future greenfield hospital project, Sunway Healthcare will implement a standardized greenfield project development procedure to identify environmental and social (E&S) risks and impacts against IFC Performance Standards. Identified E&S risks will be managed through a site-specific Environmental and Social Management Plans (ESMP) and Stakeholder Engagement Plans (SEP). The procedure should also include ongoing monitoring mechanisms. (ESAP #1).
Management Programs: Sunway Healthcare’s flagship hospital in Sunway City, Kuala Lumpur is accredited by Joint Commission International (JCI), the highest standard in the hospital sector in Malaysia and renewed every three years. All hospitals which commenced operations before December 2024 have been accredited by the Malaysian Society for Quality in Health (MSQH). The new hospital will seek accreditation once it meets the minimum required period of operation. Those accreditations set out hospital management requirements for quality and patient safety. The Company also maintains Occupational Health System accredited to ISO45001. Sunway is a member of the Global Green and Healthy Hospitals (GGHH) network.
Sunway Healthcare implements EHS programs across all hospitals. The program identifies different operational risks with Standard Operating Procedures (SOP) and Manuals (e.g. Safety Manual, chemical safety management, hospital waste management, hazardous material and waste management procedure, collection and disposal clinical waste, etc.). Those programs are aligned with World Bank Group’s EHS Guideline on Healthcare Facilities. Sunway Healthcare also implements green and sustainability programs such as waste recycling and resource efficiency, with more detail in PS3.
Sunway Healthcare has established contractor management for construction work. The contractor must have onsite OHS and Environmental officers during the construction, with joint performance monitoring by Sunway Healthcare’s EHS officer and a designated third party through monthly reports. Sunway Healthcare maintains standard covenants regarding migrant workers, which require compliance with immigration and employment laws and regulations. All construction workers working on the site are subject to Sunway Healthcare’s review of the work permit and the registration card issued by the construction department, which links social insurance and other labor skill certifications.
All construction work for Sunway Healthcare hospitals prior to the IPO were contracted to Sunway Construction. Sunway Construction is another subsidiary of Sunway Group and a listed company. Sunway Construction published a human right policy applying to all employees and third-party contractors and service providers, with zero tolerance for child labor and forced labor. Sunway Construction has implemented anti-harassment policies and established a Grievance Redress Mechanism (GRM) to manage grievances fairly, which is aligned with national law and IFC PS requirement. Post listing, Sunway Healthcare will follow relevant regulatory requirements and adhere to the directives of the audit committee for the potential appointment of Sunway Construction as its contractor for construction work.
Organizational Capacity and Monitoring and Reporting: Sunway Healthcare has established an ESG committee at the group level to oversee sustainability initiatives. This committee is responsible for managing strategic direction, setting ESG targets, and monitoring implementation progress. Each hospital maintains a cross-departmental EHS committee chaired by the CEO, supported by a minimum of two EHS officers who manage day-to-day operations. Hospital EHS committees review EHS matters quarterly.
The EHS team at each hospital conducts workplace inspections on monthly basis and presents the results to EHS committee. Such inspections identify gaps with proposed time-bound improvement action plan. EHS Key Performance Indicators (KPIs) includes regular tracking of those action plan completion ratio, training completion ratio, and other regular EHS work such as water quality, waste recycling ratio, etc. The relevant KPIs are reviewed on a monthly or quarterly basis, as determined by each specific parameter. The hospital EHS teams also have a dotted reporting line to Sunway Healthcare Group level.
Emergency Preparedness and Response: Sunway Healthcare has developed a comprehensive emergency preparedness and response system that fully complies with all relevant national codes for emergencies and fire safety. Every hospital and its associated facilities have an Emergency Response Plan (ERP) that is developed based on risk analysis to address potential emergency situations. Each hospital develops an annual ERP training schedule to ensure that all emergency codes are practiced at least once per year through realistic mock drills. Sunway Healthcare delivers ongoing emergency preparedness training to all employees, with a particular focus on nurses and fire wardens, emphasizing keeping patients safe within smoke-proof zones before evacuation. Detailed fire prevention standards and equipment checks are documented, and dedicated Emergency Response Teams (ERTs), supervised by the OHS Committee, maintain preparedness through routine testing and annual refresher courses.
A robust emergency communication plan keeps the public and stakeholders informed in collaboration with community relations and the Stakeholder Engagement Plan (SEP).
PS 2 – Labor and Working Conditions
Sunway Healthcare employs 6,489 full-time staff: 6,316 permanent, 173 on short-term contracts, including 77 migrant nurses from India, Pakistan, and Sri Lanka as at [31 July] 2025. Among these employees, about 50% are nursing staff, 30% are admin and operating support staff, 17% are other healthcare professionals, 3% are doctors. Most of the nursing staff are female. Sunway Healthcare also engages 631 consultant doctors as independent contractors as at 31 July 2025. Sunway Healthcare also engages 465 third-party workers for housekeeping, food and beverages, and security as at October 2025. Those workers do not have direct labor contracts with Sunway Healthcare. There is no plan for any major workforce retrenchment.
Working Conditions and Terms of Employment: Sunway Healthcare corporate policy adheres to principles of non-discrimination and equal opportunity. Employment conditions, compensation, attendance, leave, insurance, overtime, performance evaluation, and promotions are all governed by the corporate employee handbook, which is distributed to workers during on-boarding session. The company is committed to complying with national labour laws and international human rights standards. Each hospital facility adopts the same set of HR policies and procedures for their day-to-day HR operations. All staff sign an employment contract with the Company whose terms comply with national labor regulations. A review of sample employment contracts during appraisal indicated the inclusion of these clauses as stipulated in the contract.
Worker's Organization: There is no collective agreement or labour union in Sunway Healthcare. While Sunway Group’s human rights policy makes explicit commitment to respect freedom of association, there is no clear statement in Sunway Healthcare’s HR policy. This has been addressed as per ESAP#2.
Grievance Redress Mechanism: Sunway Healthcare upholds a Group-wide Grievance redress mechanism managed by Sunway Healthcare Group HR. Employees are encouraged to voice workplace concerns either through their direct supervisors or directly to HR. All grievances are systematically documented, impartially assessed, and resolved in accordance with established timeline. Sunway Healthcare will improve grievance redress by offering anonymous reporting channels and ensuring confidentiality and non-retaliation, also explicitly extend the GRM to third party workers as stated in ESAP#3.
Gender Based Violence and Harassment and Child Protection: Sunway Healthcare published an Anti-Sexual Harassment Policy and Code of Conduct and maintains a whistleblowing mechanism accessible to employees, contractors, vendors, and the public (patients and hospital visitors). These policies explicitly prohibit sexual harassment, outline investigation steps, and establish disciplinary actions applicable to all hospitals operating under the Sunway Healthcare Group. At the hospital level, management teams (CEO, HR, Nursing, Quality, and Procurement) operationalize corporate policies and integrate sector-specific requirements through patient-facing protocols. The company will need to create a Child Protection Policy at the group level and designate a dedicated contact person to oversee GBV-related risks. This focal point will also ensure ongoing, consistent GBV training and refresher sessions for all staff, including third-party workers (ESAP#4).
Protecting the Workforce: Sunway Healthcare’s human right policy explicitly makes statements on zero tolerance for child or forced labor. Sunway Healthcare complies with national law and does not hire workers under the age of 18 years. No forced labor practices are identified for direct workers. All migrant workers obtain the work permit needed.
Occupational Health and Safety (OHS): Sunway Healthcare OHS management system includes policies and procedures for managing OHS issues within its facilities. Several initiatives are undertaken by Sunway Healthcare to safeguard the health of employees and patients. Examples include: an Infection Control Plan to prevent, identify and control healthcare associated infections; provision of an employee health program that screens new employees to prevent, monitor, investigate potentially harmful infectious exposures and outbreaks among personnel and provides care for personnel for work-related illnesses or exposures; a radiation exposure control plan, which outlines measures to control and monitor exposure of staff to radiation sources; and implementation of a policy to manage healthcare workers exposed to blood and body fluids.
Safety orientation is part of the formal induction led by HR department, with mandatory annual training and on-the-job training provided by departments. Contractors and vendors receive safety briefings. Sunway Healthcare offers regular courses and webinars for healthcare professionals for quality and patient safety, infection prevention control, safety protocols etc.
Sunway Healthcare maintains OHS statistics for all incidents that occur during routine business operations: incidents are recorded, and corrective/preventive actions are undertaken accordingly, while incidents during construction are recorded by the contractors and reported to Sunway Healthcare separately. Sunway Healthcare has a ‘permit to work’ procedure to ensure that tasks having OHS risks are conducted only by authorized person at a specific time, under strict controls.
Management of Third-Party Workers: Sunway Healthcare employs 465 third-party workers through various companies who perform functions at various hospitals, such as building services, food and beverage and security. The company has established a contractor management program that involves pre-qualification reviews of service providers, regular performance monitoring and rating. Contract owners review the list of personnel assigned and assess their qualifications for specific tasks. Most third-party contractor management procedures focus on OHS and qualification requirements, with no specific guidance for labor compliance checks. Labor check-ins for third parties should be standardized at all Sunway Healthcare hospitals. Sunway Healthcare has legal covenants with third party regarding PS2 and national law compliance in their third party service contracts, and will implement routine compliance checks with national labor laws, PS2 requirement for these employees, including verification of working permits, labor contracts, compensation records and workers accommodation as per ESAP#5.
PS 3 – Resource Efficiency and Pollution Prevention
Resource Efficiency: Sunway Healthcare’s hospitals are member of the Global Green and Healthy Hospitals (GGHH) network, with commitment to international best practices in healthcare sustainability. Sunway Healthcare has implemented a corporate wide resource efficiency program, including a water efficiency program and waste recycling system. As part of Sunway Healthcare Group’s net zero commitment, Sunway Healthcare has taken an Energy Efficiency Program with rooftop solar installation. The estimated GHG emissions in 2024 are 59,279 tCO2e. Sunway Group discloses GHG emissions annually following internationally recognized GHG accounting protocol, which is aligned with IFC PS3 requirement for GHG disclosure. Sunway Healthcare's water supply is sourced from the municipality, with an annual usage of 546,080 m³. Water quality is tested twice a year.
Pollution Abatement: Wastewater management procedures vary depending on facility design and regulatory or clinical requirements. Wastewater is directed to the municipal or approved treatment networks, and hospital teams maintain monitoring reports to ensure compliance with regulatory standards. For new hospital projects and expansions, Sunway Healthcare maintains corporate level procedures to incorporate into wastewater management design and planning stages where required. For construction work, the contractors implement their environmental management plan.
Stormwater management is guided by Sunway Healthcare’s Hospital Operating Policy on Flood Management, which outlines preparedness and response protocols for potential flood events. Upon detection of a flood warning, caused by technical faults or extreme natural events, the building services team conducts investigations and, if necessary, identifies corrective action. Flood events are categorized into four levels within the policy, with corresponding communication, containment, and evacuation procedures implemented depending on the severity of the situation.
Solid and Hazardous Wastes: Sunway Healthcare has a Hospital Solid Waste Management Plan that ensures integrated waste management and regulatory compliance. The plan defines procedures, staff roles, and required protective equipment for handling waste. Waste is categorized as common, contaminated, or special, with segregation at source using color-coded bags. Special wastes such as radioactive, cytotoxic, and sharp materials are segregated at the point of generation, appropriately labelled, and managed in accordance with applicable regulations. Segregated waste moves from intermediate to central storage before licensed third-party collection, which occurs every 24 hours at minimum. All hospital waste complies with Malaysian Department of Environment requirements. Sunway Healthcare does not operate its own infectious waste incinerators, depending solely on certified third-party offsite treatment facilities. Third-party treatment facilities are inspected annually as per Sunway Healthcare’s guidelines. The handling of radioactive wastes is conducted in compliance with the Atomic Energy Licensing Act 304 of Malaysia, and related regulations.
Hazardous Material Management: Sunway Healthcare has a Chemical Safety Management Program which provides guidance for the management of hazardous materials in laboratories and other associated areas. It provides information to the workers/staff about health effects to exposure to hazardous substances, provides guidance for safe handling, incident response. The procedure requires placement of Material Safety Data Sheets (MSDS) at the department level, where the chemicals are handled and used.
Pesticide Use and Management: Pest control is addressed through a dedicated Standard Operating Procedure on Pest Management, under which appointed vendors conduct regular inspections, treatment services, and preventive measures to control pest populations at hospital facilities. The process includes ensuring pest control technicians are equipped with the correct personal protective equipment, chemicals, and tools, preparing and diluting necessary chemical solutions, reporting to hospital security or supervisors before treatment, applying relevant pest control methods across required areas, and issuing service reports upon completion. Pest management training is conducted annually by the appointed pest vendor to build awareness among hospital staff on the importance of maintaining a safe and hygienic environment. Compliance monitoring is incorporated into the SOP, with specified audit and inspection intervals to ensure the system’s effectiveness.
PS 4 – Community Health, Safety and Security
Infrastructure, and Equipment Design & Safety: Sunway Healthcare follows Malaysian structural, seismic, health, and fire safety codes for both the design of new facilities and upgrades to existing ones. Life and fire safety requirements are fully aligned with local legislation. The quaternary flagship has obtained international accreditations, such as Joint Commission International (JCI), the Australian Council on Healthcare Standards (ACHS), and the Malaysian Society for Quality in Health (MSQH), while the other hospitals which commenced operations prior to December 2024 are also accredited with MSQH. Hospital environments are purposefully designed for universal accessibility, incorporating ramps and elevators to facilitate the safe and comfortable movement of all patients and visitors.
Comprehensive emergency response plans and procedures are implemented across all Sunway Healthcare locations. Hospitals are required to obtain fire certificates, which are issued only after full compliance with fire-fighting equipment and safety installation standards outlined in the Fire Services Act 1988. This certification verifies that a robust fire safety organization is in place, and that a Fire and Emergency Response Plan, along with a Fire Safety Report, has been prepared for each designated facility in accordance with statutory requirements.
Specialized architectural and engineering firms with proven expertise in healthcare and regulatory compliance are engaged for all construction and renovation projects. For new hospitals, life and fire safety design and operations not only meet WBG General EHS Guidelines and global best practices but are also validated by certified experts. These professionals ensure strict adherence to the Malaysian Uniform Building By-laws (UBBL), with certificates of compliance required prior to operational start-up. Additionally, the Fire and Rescue Department of Malaysia (BOMBA) conducts annual inspections and checks of critical fire protection systems.
For new developments or renovations, qualified professionals carry out risk-based L&FS reviews, ensuring full compliance with local standards. The results of these reviews inform a systematic program for ongoing improvements in L&FS management. Any modifications to hospital infrastructure are governed by corporate “Management of Change (MOC)” procedures, which include: (i) structured review processes for medium-scale changes, similar to infection control risk assessments (ICRA); (ii) post-construction commissioning by independent consultants to verify L&FS features and report conditions to BOMBA; and (iii) the preparation of comprehensive Operations & Maintenance (O&M) manuals and as-built documentation.
Sunway Healthcare has established a Hospital Operating Policy on Infection Control Risk Assessment (ICRA) specifically for demolition, renovation, or new construction projects. This policy is designed to prevent contamination in occupied patient care areas during construction activities, safeguarding patient wellbeing throughout the process. It includes identifying at-risk populations, mapping their locations relative to construction zones, understanding potential transmission routes for pathogens, and mitigating risks proactively during the planning stage.
Community Exposure to Disease: Sunway Healthcare’s hospitals implement a strong patient safety program, compliant with local laws and international accreditation bodies, including comprehensive infection control measures. Engineering and administrative controls—such as proper ventilation, architectural segregation, decontamination protocols, and controls on water, food, and waste—are in place to prevent and address health risks. Potable water for operations is supplied by the municipality and regularly tested by Sunway Healthcare to ensure it meets physical and microbiological standards. Radiology and similar specialized areas are developed in accordance with local authority requirements and international best practices. Sunway Healthcare contracts experts to confirm compliance with Malaysian radiation protection laws.
Security personnel: Sunway Healthcare has established a comprehensive Operating Policy for Security Management that addresses a wide range of potential risks, including terrorism, vandalism, theft, fire and emergency situations, criminal damage, infant abduction, fraud, inappropriate access to or misuse of information, violence against individuals, and misconduct by employees, consultants, vendors, or tenants. The policy encompasses the systematic identification and assessment of security risks, vulnerability analysis for each hospital, and the implementation of robust security and control measures.
All Sunway Healthcare hospitals and facilities are safeguarded by unarmed security personnel from accredited private agencies, overseen and managed directly by Sunway Healthcare. Security staff are trained in accordance with Malaysian regulations as well as Sunway Healthcare’s Code of Conduct and Ethics. This training covers appropriate engagement with staff and the public, as well as clear protocols for emergency response.
