While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

The project is classified as Category B under IFC’s Policy on Environmental and Social Sustainability, reflecting site specific environmental and social risks typical of large scale urban hospitality developments, particularly during the construction phase.
Key environmental and social risks include: (i) temporary impacts on air quality, noise, traffic, and community disturbance, given the project’s proximity to residential areas; (ii) construction phase risks, including occupational health and safety risks for workers, labor and contractor management, particularly related to subcontractor oversight and grievance handling: (iii) environmental risks relate to the potential presence of legacy soil contamination and asbestos containing materials, as well as greenhouse gas emissions during operations, which will require formal quantification and monitoring; (iv) human resources and labor management systems.

While the Sponsor has experience operating internationally branded hotels, these findings indicate institutional gaps in both construction and operational environmental and social management systems.

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 (ESMS): Aldau Hospitality does not have a fully operational ESMS framework applicable to its operations and/or the development of new projects. At the time of appraisal, a legal entity responsible for the construction and operation of the Aldau GEM Hotel Project had been established and is called “ADD Mansouria for Hotels SAE” also referred to as “ADD GEM”. While ADD GEM was created to operate the Aldau GEM Hotel, there is still no project-level ESMS currently in place to manage environmental and social (E&S) risks.
According to Aldau Hospitality, newly established operating companies are required to develop management systems aligned with international hotel chain requirements covering environment, health and safety, and labor matters. ESMS documentation from existing hotels were reviewed as part of the appraisal. These systems include EHS policies and a range of human resources and operational procedures addressing, among others, health and safety risk assessments, contractor management, permit-to-work systems, grievance management, emergency response, waste and wastewater management, food safety, incident reporting, and operational safety risks.
The ESMSs implemented at existing operating hotels demonstrate compliance with applicable Egyptian regulatory requirements and partial alignment with international lender standards. However, gaps were identified in relation to IFC Performance Standard 1 requirements and presented in the relevant sections of this ESRS. Overall, the ESMS applied across operating assets is largely driven by individual international hotel brand standards and therefore lacks consistency in structure and content across the portfolio. In addition, some procedures—particularly those related to contractor E&S management—were assessed as being high-level and would benefit from further strengthening to ensure systematic application across all assets and alignment to the IFC Performance Standards.
Aldau Hospitality will develop an ESMS framework to guide the development of project-specific ESMSs during operations. ADD GEM will then be required to develop its own project-specific ESMS for Aldau GEM Hotel that identifies assesses, manages, and monitors E&S risks and impacts during operations, in line with IFC PS1 (ESAP #1.1 and ESAP #1.3). Based on discussions with Aldau Hospitality, no ESMS framework is currently in place to manage E&S risks during the construction phase. The company contracted for construction oversight does not have a dedicated E&S team responsible for overseeing contractor E&S performance. The contractor management plan to be developed in the ESMS framework will ensure a dedicated team is made available (ESAP # 1.1).
In addition, and due to the close proximity of the Aldau GEM Hotel site to the Pyramids of Giza, chance finds cannot be completely ruled out during the various construction activities involving excavation, levelling, grading, etc. Chance find procedures are thus to be developed (ESAP #1.1). These procedures should be designed to address any potential discoveries of new cultural heritage during the construction phase and ensure appropriate measures are taken accordingly.

Environmental Impact Assessment: In accordance with Egyptian environmental legislation, the Aldau GEM Hotel Project is required to prepare an Environmental Impact Assessment (EIA). While operational risk assessments from existing hotels were reviewed and found compliant with national requirements, these do not systematically address social risks, as required under IFC Performance Standard 1. As part of the future developments and before construction, Aldau Hospitality will conduct an environmental and social impact assessment (ESIA) for each new hotel for submission to the national regulatory authority. ADD GEM will conduct an ESIA for the Aldau GEM Hotel and submit it to the relevant authorities (ESAP # 1.4).

Environmental and Social Management Plan (ESMP): While operational requirements are expected to follow international hotel chain standards, limited information is available for the proposed project. A review of EIAs for other Aldau projects indicates that mitigation measures are limited in scope and do not clearly define implementation responsibilities, monitoring, or corrective actions. In the absence of a robust construction ESMP, the Aldau GEM Hotel Project is exposed to elevated E&S risks, and E&S requirements are not integrated into contractor tendering and contractual arrangements. ADD GEM will develop a site-specific Construction Environmental and Social Management Plan (ESMP) that, at a minimum, incorporates regulatory limits, clearly defined objectives, detailed roles and responsibilities for both management and site teams, appropriate mitigation measures to address potential impacts, key performance indicators (KPIs) for measuring performance, and specified monitoring parameters along with the frequencies at which monitoring will be conducted. (ESAP # 1.5)

Organizational Capacity and Commitment: At the time of the appraisal, the project company had not yet allocated project-level E&S resources, including for the construction phase. Based on a review of existing operating assets, Aldau hotels have established EHS and HR teams responsible for environmental, health and safety, and labor management, supported by occupational health and safety committees in compliance with Egyptian legal requirements and aligned with IFC PS2. These teams demonstrated adequate competence in managing E&S risks during operations; however, organizational capacity for the construction phase is currently absent, which may expose the Project to regulatory non-compliance and misalignment with IFC PSs unless addressed. ADD GEM will ensure that contractors with a workforce of 50 or more must appoint adequate HSE and HR staff to oversee environmental and social (E&S) management during construction in compliance with Egyptian laws and IFC PSs and ensure workforce training on these requirements. The EPC contractor must also provide sufficient first aid and emergency response personnel, including an onsite clinic. (ESAP #1.6)

Contractor Management: In accordance with IFC PS 1, the client is required to ensure that contractors engaged on the Project manage E&S risks and impacts in line with the ESMS and applicable management plans, including through contractual requirements, monitoring, and application to subcontractors. At the time of the appraisal, no project-specific contractor management plan had been developed for the construction phase and Aldau Hospitality did not provide evidence of a corporate-level contractor E&S management system. While the Aldau GEM Hotel Project is expected to adopt contracting practices broadly aligned with international best practice (FIDIC requirements), these do not substitute for a structured E&S contractor management framework as required under PS1. A review of contractor management practices at existing operating hotels indicates that a primary focus on occupational health and safety, with limited coverage of broader environmental, social, labor, and community health and safety risks, and no systematic monitoring or grievance linkage. In the absence of a comprehensive contractor E&S management system for construction and refurbishment, the Aldau GEM Hotel Project and refurbishment of other hotels owned by the co-borrowers are exposed to heightened E&S risks and potential non-compliance with IFC PS. Aldau Hospitality will therefore ensure that contractor management is included as part of their corporate-level ESMS framework (ESAP # 1.1), ADD GEM will include E&S and OHS requirements in the tender documentation and contractual agreements for contractors of the Aldau GEM Hotel Project (ESAP #1.7) and other hotels will update their ESMS to include the same and be aligned with the ESMS framework and IFC PSs (ESAP # 1.3).

Emergency Preparedness and Response: Aldau have emergency response plans for their operating hotels which include information on the types of emergencies, roles and responsibilities, emergency response equipment available, evacuation details, emergency numbers, training/drills, etc. A project-specific emergency preparedness and response plan for Aldau GEM Hotel will be developed by ADD GEM and appropriate training will be given to workers and communities (ESAP # 4.2).

Project Monitoring and Reporting: Monitoring practices implemented at existing operating hotels, such as: tracking energy and water consumption, waste generation, incidents, and occupational health and safety statistics are considered adequate for operational risks and compliant with Egyptian legal requirements, these arrangements are not yet formalized at the Aldau GEM Hotel Project level and do not comprehensively cover labor and broader social aspects. At the time of appraisal, no project-specific monitoring program had been developed for either the construction or operation phases. ADD GEM will develop a structured E&S monitoring and reporting framework, proportionate to Project risks, and consistent with IFC PS1 requirements. (ESAP # 1.1 and ESAP # 1.3)


PS2: Labor and Working Conditions

Human Resources and Labor Management Policies and Procedures: ADD GEM has only recently been established and no project specific HR or labor policies are currently in place. While existing branded hotels are operated by Aldau Hospitality which applies a comprehensive employee handbooks aligned with national legal requirements and international standards. However, the absence of a centralized and project specific labor management framework presents a risk of inconsistent application and potential non compliance. Aldau Hospitality will develop and adopt a unified Human Resources Policy applicable to all Aldau operated hotels, aligned with Egyptian Labor Law and IFC PS2. The policy framework will also remain compatible with brand standards and integrate a standardized grievance management procedure across all E&S management plans, covering both direct and third-party workers. Additional provisions will include measures to appropriately handle Gender Based Violence and Harassment (GBVH). In addition, for the GEM construction phase, a Labor Management Plan will be developed to ensure that all workers are engaged in compliance with Egyptian labor legislation, have unrestricted access to appropriate welfare facilities (including sanitation, potable water, and food preparation and eating areas), and are provided with fair working conditions. The plan will prioritize local employment, ensure wages are compliant with national minimum wage requirements and market benchmarks, and promote equal treatment of women and migrant workers. (ESAP # 2.1 and ESAP # 2.2)

Working Relationships: Aldau Hospitality and all its subsidiaries will continue to issue written employment contracts in Arabic in line with requirement stipulated in Labor Law No. 14/2025 and IFC PSs. Aldau relies on hotel chain data protection standards, which include robust data privacy and cybersecurity policies, supported by training and industry standard systems to protect employee and guest information.

Wages, Benefits and Conditions of Work: Documentation reviewed from operating hotels demonstrates that Aldau Hospitality provides a range of statutory employment benefits, including enrollment in social insurance and medical insurance schemes, issuance of itemized pay slips, maintenance of leave and attendance records, and employment and resignation registers. An employment contract sample provided does not include clear clauses on hours of work, overtime arrangements and compensation, and rest periods. Instead, it includes several clauses that are not aligned with Egypt’s labor law, such as stating that the salary includes overtime, public holidays, days off or stating that the notice period is 15 days instead of 30 days. A unified Human Resources Policy applicable to all Aldau Hospitality-operated hotels and aligned with Egyptian Labor Law and IFC PS 2 will therefore be developed and adopted by all Aldau Hospitality hotels (ESAP #2.1).
While payroll documentation was not provided for review, a review of resignation records indicates that some employees’ basic salaries fall below the national minimum wage. It is unclear whether this difference is compensated for with benefits or allowances but one sample pay slip showed that variable wages significantly contribute to employee salaries as hotel staff. Aldau has also provided a sample employee handbook which states that in an effort to reward associates based on the total revenue generated by the hotel, an equal service charge (12% of revenue) is paid each month to all except employees on a package basis. In addition, Aldau also provides additional financial support through an annual “13th Month” allowance, paid in installments ahead of major holidays to assist with living costs. The handbook also states that overtime work is not compulsory and workers are free to request leave, consistent with the principles of IFC PS2.

Workers’ Organization: Aldau does not restrict workers’ rights to form or join such organizations, provided these are established in accordance with national law. In addition, the brand’s Human Rights Statement affirms respect for freedom of association, providing a framework for alignment with IFC PS2 requirements.
Occupational Health and Safety (OHS): ADD GEM has not yet established project specific OHS plans, organizational capacity, or monitoring procedures. However, Aldau Hospitality’s operating hotels apply OHS systems that include defined organizational structures, risk assessments, mitigation measures, monitoring KPIs, incident reporting, and OHS committee oversight, and interviews with HSE personnel demonstrated good understanding of national requirements. These systems include standard procedures for hazard identification, permit to work, incident prevention, and reporting, supported by staff training, PPE requirements, medical screening, and periodic health checks. While construction phase OHS risks are expected to be typical and manageable through good practice, the absence of construction phase OHS planning and resources will need to be addressed prior to commencement of works. (ESAP # 4.1)

Contracted Workers: Given the known labor compliance risks associated with the construction sector in Egypt and the absence of a defined approach to managing third party workforce conditions, a construction phase Labor Management Plan is required to establish clear expectations and monitoring arrangements for contractors. (ESAP # 1.3 and ESAP # 2.1).

Supply chain workers: Aldau Hospitality has a supplier management approach that prioritizes certified suppliers and incorporates sustainability, environmental performance, and labor rights compliance as key evaluation criteria. For branded hotels operated by Aldau, suppliers are expected to comply with the brand’s supply chain standards, which align with the Sustainable Hospitality Alliance Principles on Forced Labor and prohibit forced, bonded, indentured, or involuntary prison labor. These standards require suppliers to ensure freedom of movement for workers, prohibit recruitment fees and debt bondage, prevent the retention of identity documents, and allow workers to terminate employment freely with reasonable notice. Suppliers are also expected to work towards best practices in OHS, fair compensation, diversity, and human rights monitoring, and to prohibit the use of child labor at any stage of the supply chain. (ESAP # 1.1 and ESAP # 1.3)

Gender-based Violence and Harassment: The branded hotels operated by Aldau Hospitality apply a Dignity, Respect and Harassment Policy that prohibits harassment and includes reporting mechanisms, confidential handling of complaints, investigation procedures, disciplinary measures, and non retaliation provisions for complainants and witnesses. These policies provide a foundation for alignment with IFC PS2 requirements and are expected to inform the development of ADD GEM specific GBVH prevention and response measures. (ESAP # 2.1)

Child Labor and Forced Labor: Workers under the age of 18 are not employed. While Aldau Hospitality does not have a clear policy prohibiting forced labor, the branded hotels will be subject to the brand’s Human Rights Statement and the brand’s Modern Slavery and Human Trafficking Statement which commits to compliance with applicable laws prohibiting child and forced labor provides a basis for alignment with IFC PS2 requirements.
Non-discrimination and Equal Opportunity: HR policies for Aldau operated hotels include clear commitments to non discrimination and zero tolerance for harassment, consistent with national law and international hotel brand standards. Furthermore, the branded hotels apply policies that prohibit discrimination and harassment on legally protected grounds and affirm respect for diversity through the brand’s Code of Conduct. Other Aldau operated hotels similarly commit to equal employment and hiring opportunities, ensuring that all applicants and employees are treated fairly based on qualifications and competencies, including non permanent staff and trainees.

Grievance Mechanism: Aldau Hospitality does not have a corporate level worker grievance mechanism, and only grievance procedures from two operating hotels were made available for review. While these procedures demonstrate partial alignment with PS2, gaps and inconsistencies were identified, including the absence of provisions on non retaliation, anonymous complaints, access for contracted workers, referral to judicial remedies, and specific handling of sensitive cases such as GBVH. A worker grievance mechanism will be established at Aldau GEM Hotel Project commencement, accessible to all workers (including third-party workers) and allowing for anonymous submissions. The mechanism will include procedures for the safe and confidential handling of GBVH and SEAH related complaints, and a grievance register will be maintained to document grievances and track their resolution. (ESAP # 2.3)


PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: Aldau Hospitality has implemented resource efficiency measures across its operating hotel portfolio, including standardized staff instructions and operational frameworks focused on reducing energy and water consumption and minimizing waste. Existing hotels apply energy efficient technologies and operational controls for lighting, HVAC, refrigeration, and power systems, alongside water conservation measures such as low flow fixtures, sensor operated taps, efficient irrigation, and leak detection. While the GEM Project has not yet developed project specific resource management schemes, resource efficiency is expected to be integrated into project design and operations, including through pursuit of LEED certification or equivalent and the application of circular economy principles covering sustainable construction, energy and water efficiency, waste reduction, and resource reuse. Aldau’s experience with LEED certified assets in Egypt indicates capacity to implement measures in line with PS3, with the Aldau GEM Hotel Project targeting at least LEED Silver certification.

Water: Aldau Hospitality monitors water consumption across its operating hotel portfolio, with sample data indicating average monthly water use of approximately 6,092 m³ and 2,777 m³ at two existing hotels, respectively, and the application of water saving systems at select assets. The Aldau GEM Hotel Project’s estimated daily water demand of 780 m³ is below the threshold requiring a detailed water balance and is expected to be supplied entirely from the municipal network, with no groundwater abstraction anticipated. Aldau GEM Hotel specific water efficiency and management measures are expected to be defined during detailed design and operation, consistent with PS3 requirements.
Wastewater management for the Aldau GEM Hotel will follow the brand’s design requirements, including the installation of bar screens and grit chambers, oil and grease separators for kitchen effluent, flow equalization tanks, and treatment measures to neutralize detergents and chlorine prior to discharge. Provision will also be made for greywater reuse for irrigation and toilet flushing where feasible. All operational waste water will be discharged to the municipal sewer network, and Aldau’s operating hotels have demonstrated compliance with Egyptian regulatory requirements.

Waste Management: Aldau has implemented waste management practices at its operating assets, including the application of waste management plans and maintenance of waste registers documenting waste streams and quantities, consistent with good international industry practice (GIIP). Preliminary estimates indicate that the Aldau GEM Hotel Project is expected to generate approximately 115,000 kg of waste per month during operations, although these estimates will be refined following completion of the ESIA. Waste management measures are expected to be defined during the assessment, design, and operational planning stages in line with PS 3. (ESAP # 1.5)

Pollution Prevention and Control: During construction, the Aldau GEM Hotel Project is expected to generate point source and fugitive air emissions, primarily from the operation of construction equipment, machinery, and vehicles, as well as dust generated by earthworks, material handling, and transport activities. Construction activities are anticipated to generate noise emissions associated with the use of heavy equipment and machinery; however, no construction phase air quality or noise management plans have been developed at this stage. In addition, the site has a potential risk of soil contamination linked to its former use as mechanical workshops, including possible fuel spills and improper waste handling, which will need to be assessed as part of the ESIA. While Aldau’s operating hotels implement pollution management measures for air and noise in compliance with Egyptian regulations, project specific mitigation and management measures will be required to meet IFC PS3 requirements during construction. (ESAP # 3.1)
The site may also contain asbestos containing materials (ACM) due to the age of existing structures, although no surveys have been undertaken to confirm their presence to date. Aldau will retain a qualified third party to undertake an asbestos survey to determine the presence of asbestos containing materials. If asbestos is identified onsite, an Asbestos Management Plan will be prepared (ESAP # 3.1)

Greenhouse Gas (GHG) Emissions: The GHG emissions produced during construction and operation are directly produced from electricity grid and vehicle fuel consumption. Egypt does not have any specific regulations or requirements in place for the reporting of GHG emissions. As a result, there is no standardized framework for assessing and monitoring the carbon footprint of activities or operations in the country. Based on initial assessments, the Aldau GEM Hotel Project is expected to emit 28,000 tons of CO2 annually during operation. ADD GEM will retain a qualified third party to quantify GHG emissions expected for the Project (ESAP # 3.2).

PS4: Community Health, Safety and Security

Traffic Management: Community health and safety risks are primarily associated with the movement of construction personnel, materials, and equipment, as well as staff transport during operations, which may increase traffic and accident risks for nearby communities. An external traffic assessment commissioned by Aldau concluded that project generated traffic is expected to operate at acceptable service levels, provided that appropriate site access design, parking arrangements, and traffic signage are implemented. ADD GEM will thus develop a Traffic and Road Safety Management Plan that identifies risks and impacts and includes measures to address them. (ESAP # 4.1).

Security Management: Aldau Hospitality’s operating hotels apply comprehensive brand security standards, which are risk based and tailored to assess crime and terrorism threats, and include access controls, surveillance systems, CCTV coverage, intrusion detection, and regular testing and staff training. Enhanced measures are applied at properties assessed as higher risk, including vehicle screening and perimeter security. In Egypt, hotel security is jointly managed by trained, screened hotel security staff and armed personnel from the Tourism, Museums and Antiquities Security Department, providing a structured framework for managing security risks consistent with international good practice. A Security Management Plan will be developed for the Aldau GEM Hotel as a part of its ESMS (ESAP # 1.3)

Life and Fire Safety: Qualified professionals will be engaged to design and construct structural elements of the Project, with safety risks addressed at the design stage wherever feasible. Independent life and fire safety reviews will be undertaken for public and communal buildings prior to operation, and facilities will be designed in accordance with universal access principles. Branded properties operated by Aldau Hospitality apply comprehensive Fire and Life Safety standards, aligned with international codes (including NFPA) and local regulations, covering fire detection, suppression systems, emergency power, evacuation, and operational readiness. Aldau has confirmed that hotels are subject to inspection and permitting by the Civil Defense Authority prior to operation and certification by third parties such as Intertek Cristal demonstrate that Aldau hotels conform to the requirements of “Fire Check”. Daily firefighting system monitoring reduces the risk of loss or injury from fire.

Aldau Hospitality has prepared a draft Stakeholder Engagement Report for the Aldau GEM Hotel Project, which identifies key stakeholder groups and outlines proposed engagement methods, including consultations, surveys, and focus groups, as well as a high level grievance redress mechanism. While the report demonstrates a commitment to transparency and alignment with stakeholder engagement principles, relating to documentation of past engagement, defined objectives and responsibilities, information disclosure arrangements, contact details, and monitoring and reporting indicators. At the time of the appraisal, no project information had been disclosed to stakeholders, although Aldau indicated that corporate disclosure practices typically include reports, website updates, public notices, press releases, and meetings.
As part of the Project ESMS, ADD GEM will prepare and disclose a Stakeholder Engagement Plan (SEP) covering the full Project lifecycle, with tailored engagement approaches for different stakeholder groups and particular focus on neighboring communities. The SEP will define information disclosure, consultation, monitoring, and documentation arrangements, and will be periodically updated. An external stakeholder grievance mechanism will also be established under the SEP, accessible to all stakeholders, including provisions for anonymous complaints and the safe handling of GBVH related grievances, with grievances recorded and outcomes tracked. (ESAP # 10.1)

Contact Person: Ihab Kamel Iskander
Address: 22 km Cairo/Alex Desert Road, Giza, Egypt
Email: iiskander@aldaudevelopment. com

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Develop an Environmental and Social Management System (ESMS) framework to guide the development of project-specific environmental and social management systems during operations that are a) compliant with Egyptian E&S laws and regulations; b) aligned to relevant IFC PSs; and c) complementary to international hotel chain E&S standards. The framework must include the following elements: • Permitting requirements (including environmental permits and civil defense permits).• E&S policy.• Human Resources (HR) policy and procedures.• Procedures for identifying E&S risks and impacts.• Procedures and criteria for assessing the past performance of potential Engineering, Procurement and Construction (EPC) contractors with regard to employment and occupational health and safety.• A procedure to include legal covenants for tenders and contracts, as well as procedures for supplier/contractor verification and auditing.• Management programs to control identified E&S risks and impacts.• Training matrix to cover the implementation of Environmental and Social Management Plans (ESMPs) as well as EBRD and IFC requirements, in particular labour management and subcontractor monitoring.• Defined roles and responsibilities, as well as requirements to improve the organisation’s competency in implementing the ESMS.• Workers’ Grievance Mechanism.• External Grievance Mechanism.• Contractor management.• Security management.• Chance Find Procedures• Monitoring and reporting procedures.	11/23/2027
2	Appoint a qualified representative having oversight of the development and the implementation of the corporate ESMS framework. Develop clear roles/responsibilities for this representative in implementing the ESMS framework. Representative to have oversight of contractor E&S performance during construction of projects. Ensure the Corporate level Environmental and Social Management System is applied consistently across the portfolio of hotel assets in the scope of the Project. Formalise portfolio wide environmental monitoring and reporting, covering waste, water, emissions, energy use and compliance registers, building on existing hotel level practices.	11/23/2026
3	Update the existing Environmental and Social Management Systems of Project assets to align with IFC Environmental and Social Requirements.ADD GEM to develop a project-specific ESMS for the Aldau GEM Hotel operations, in line with the ESMS Framework for Aldau Hospitality (ESAP 1.1) which should be compliant with Egyptian E&S laws and regulations, aligned to relevant PSs, and complementary to international hotel chain E&S standards.	05/21/2028
4	Conduct an environmental and social impact assessment for Aldau GEM Hotel and submit to the relevant competent authority. The assessment should consider the following aspects:• Resource usage and efficiency• Air, noise, waste and land quality impacts• Occupational health and safety impacts• Climate change and natural hazards • Community H&S risks• Cultural heritage risks• Socioeconomic impacts	02/21/2027
5	Develop a site specific Construction ESMP for GEM, including the following components as a minimum: • Regulatory limits.• Objectives.• Roles and responsibilities of management and site teams.• Mitigation measures.• Key performance indicators (KPIs).• Monitoring parameters and frequencies of monitoring.• Budgets.ESMP to include the following sub-management plans as a minimum:• Resource efficiency management plan (addressing water, fuel, electricity consumption).• Air quality management plan.• Noise management plan.• Non-hazardous and hazardous waste management plan (including the establishment of a hazardous waste storage area according to Law 4/1994).• Wastewater management plan.• Health and safety management plan. • Contractor management plan.• Traffic management plan. • Labour management plan. • Hazardous materials and substances management plan.• Chance find procedure. • Emergency preparedness and response plan, including the integration of community in the emergency preparedness and response plan.• Construction security management plan.• Ensure the appointed EPC contractor acknowledges and adopts the ESMP or develop one aligned with Company’s ESMP.	02/21/2027
6	Contractually require the all project contractors to appoint sufficient HSE (only those have a workforce of 50 and above) and Human Resources (HR) staff to oversee the Project’s E&S management at all times during construction in line with Egyptian E&S laws and regulations, and IFC’s PSs. Ensuring training program for construction workforce and E&S resources includes training on relevant E&S laws and regulations and IFC PSs. EPC contractor must ensure sufficient first aid and emergency response personnel are present onsite, including a clinic.	02/21/2027
7	Tender documentation and contractual agreements for contractors of the Aldau GEM Hotel Project to include E&S and OHS requirements, where relevant (i.e., E&S risks present in contractor’s scope of work). These will include as a minimum:• Complying with and explicitly referencing local environmental, health, safety and labour laws and regulations and IFC PSs.• Complying with the Project’s Construction ESMP.• Ensuring sufficient HSE and labour management personnel are present onsite.• E&S and OHS reporting requirements.• Ensuring all of the above minimum requirements apply to all subcontractors.	02/21/2027
8	Develop and adopt a unified Human Resources Policy applicable to all Aldau Hospitality-operated hotels, aligned with Egyptian Labour Law and IFC PS 2, while remaining compatible with brand requirements.Integrate unified grievance management procedures into all E&S management plans, ensuring coverage of workers and non-employee workers, including Gender-Based Violence and Harassment-sensitive handling and non-retaliation provisions.	05/21/2028
9	Develop a labor managament plan during the construction phase of the Aldau GEM Hotel Project which ensures that all workers are engaged in accordance with Egypt’s labor laws and reguations (for leave, working hours, overtime, etc.) have unrestricted access to sanitation facilities, welfare facilities, potable water, and appropriate facilities for food preparation, storage, and eating. The labour management plan will prioritise the recruitment of local labour and commit to ensuring that wages are in compliance with Egypt's minimum wage regulations and within the market average, as well as making sure that women and migrant workers are employed on equal terms.	02/21/2027
10	The Aldau GEM Hotel Project will establish a grievance mechanism accessible to all workers at the start of the Project. The mechanism will allow for workers to submit anonymous grievances and will be equipped to deal with sensitive complaints about GBVH and SEAH appropriately. A grievance register will be kept to track grievances and their outcomes.	02/21/2027
11	The Company will retain a qualified third party to perform an assessment of soil contamination at the workshops present onsite and establish measures to remediate any damage and mitigate potential impacts in a Soil Remediation Plan.The Company will retain a qualified third party to undertake an asbestos survey to determine the presence of asbestos containing materials. If asbestos is identified onsite, an Asbestos Management Plan will be prepared.	01/27/2027
12	The Company to retain a qualified third party to quantify GHG emissions expected for the Project in accordance with the Egyptian National Laws and IFC requirements.	06/30/2030
13	Develop an Occupational Health and Safety (OHS) Management Plan for the construction phase of the Project. This plan must include the following procedures as a minimum and be prepared in accordance with Egypt’s MD 211/2003 requriements and, IFC’s performance standards, and GIP: • Risk assessment procedure• Permit to work procedure• Roles and responsibilities for OHS team• Working at height procedure• Personal protective equipment procedure• Equipment inspection procedure • Electrical and mechanical safety procedure• Manual handling procedure• Incident investigation and reporting procedure• Pre-employment check up procedure• Community health and safety• Traffic and Road Safety Management Plan	02/21/2027
14	Develop a Project-specific emergency preparedness and response plan (EPRP) which may include the following elements: • Determination of potential emergency scenarios (including flooding, extreme heat and earthquakes).• Training requirements for specialized emergency response teams.• Maintenance of a list of emergency contacts and the implementation of communication systems and protocols.• Guidelines for interfacing with government authorities, including emergency, health, and environmental agencies.• Maps showing locations of of emergency equipment and facilities, such as first aid stations, automated external defibrillator, firefighting gear, spill response tools, and personal protective equipment for the emergency response teams.• Standard procedures for utilizing the emergency equipment and facilities.• Clear marking of evacuation routes and designated assembly points at consumable and spare part warehouses.• Scheduled emergency drills, with frequency based on assigned emergency levels or tiers.• Protocols for decontamination and immediate actions to mitigate, limit, and reduce pollution within the Project’s physical boundaries and assets whenever feasible.• Integrate community in the emergency preparedness and response plan.	02/21/2027
15	As part of the Project’s ESMS, the Company will develop and disclose a Stakeholder Engagement Plan (SEP) that covers the entire Project and includes engagement methods for different stakeholder groups, with emphasis on the neighbouring residential area. The plan will be reviewed and updated as needed. The plan should also allow for meaningful consultation with stakeholders and keep them informed about project updates and changes. The SEP will include information disclosure procedures (including the disclosure of adopted community health and safety measures) and monitoring procedures to implement improvements to the process when needed. An external communication procedure will also be established as part of the plan. Any stakeholder engagement should be documented. As part of the SEP, the company will develop an external grievance mechanism that is accessible to all stakeholders and equipped to handle grievances related to Gender Based Violence and Harassment (GBVH) including an anonymous mechanism. The grievances received will be documented and their outcomes will be tracked.	01/07/2027