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
Nawy has adopted an Environmental, Social, and Governance (ESG) Policy (2023) in which the company declares its high-level commitment to responsible business conduct, compliance with applicable environmental and labor laws, employee health and safety, diversity and inclusion, ethical behavior, and transparency. In principal, the Policy is consistent with the objectives of IFC Performance Standard (PS) 1 and includes elements relevant to PS2 (Labor and Working Conditions) and PS3 (Resource Efficiency and Pollution Prevention), supported by a suite of internal corporate policies. However, the ESG Policy does not provide the framework that would result in the development and implementation of a formal Environmental and Social Management System (ESMS) aligned with IFC requirements. Nawy will develop comprehensive ESMS to ensure alignment with IFC PSs. This ESMS will include: procedures for E&S risk assessment of its current and future operations, including contractor and supplier management, Occupational Health and Safety (OHS), resource efficiency, Gender-based violence and harassment (GBVH), external communications and customer grievance management, emergency planning and response, auditing and monitoring of E&S performance indicators, and reporting to the Company’s senior management and Board of Directors in line with IFC PS1. (ESAP #1)
While Nawy’s operations are predominantly office-based, one of its subsidiaries, Nawy Unlocked, undertakes finishing works of existing properties. This work involves activities such as painting, electrical work, tiling, plumbing, etc. as well as furnishing properties. Nawy Unlocked employs around seven employees that do maintenance work for properties finished by Nawy Unlocked, but all other works are done by contractors (35 subcontractors). At the time of appraisal, Nawy Unlocked does not have a contractor management system. The ESMS to be developed will include specific policies and procedures for Nawy Unlocked to avoid, manage or mitigate the E&S risks associated with property finishing. These will include policies and procedures on contractor and supplier management, occupational health and safety, solid waste management, Grievance Redress Mechanism (GRM) for contractors and suppliers, etc. (ESAP #1)
To ensure the above enhancements to contractor oversight are implemented and are effective, the company will hire a qualified E&S/OHS team who will be tasked with ESMS implementation of contractor-facing activities (ESAP #2)
Nawy does not currently have an Emergency Preparedness and Response Plan (EPRP) responsive to the requirements of this Performance Standard. Whereas there exists reference to emergency procedures (provision of emergency exits, need to conduct fire drills and matters related to first aid) in their Office Space Security Guidelines (2024) specific details are omitted. Therefore, an EPRP will be developed to cover all of Nawy and Nawy Unlocked activities (ESAP #1). The beforementioned E&S/OHS team will also be tasked with the subsequent roll-out and implementation of the EPRP. (ESAP #4).
PS2- Labor and working conditions
Nawy has a broad set of Human Resource related policies in place, covering the following: non discrimination and diversity, workplace conduct and ethics, anti harassment, employee wellbeing, flexible working arrangements, compensation and benefits, and grievance handling. Collectively, these policies emphasize equal opportunity, respectful treatment, integrity, confidentiality, and adherence to local labor laws, and they generally apply to both employees and contractors. However, key gaps remain, resulting in less than complete systematic and operational compliance. While Nawy has high-level principles-based HR policies, they are not embedded within a formal ESMS. There is no consolidated occupational health and safety management system with defined procedures for hazard identification, incident reporting, investigation, corrective actions, and monitoring. Contractor management and oversight of labor and OHS practices are not adequately addressed and not consistently operationalized. These issues will be addressed by the development of a robust ESMS as per ESAP #1 and the hiring of a dedicated E&S/OHS team to monitor compliance (ESAP #2).
Currently, Nawy Unlocked’s subcontractor relationship managers follow up directly with subcontractors on site, doing daily checks about the progress of the works as well as any issues that may arise. While the subcontractor contracts include clauses that hold the subcontractors responsible for their workers including OHS and provision of PPE, Nawy’s relationship managers do not monitor subcontractors’ OHS. The dedicated E&S/OHS team to be hired will be responsible to regularly monitor OHS compliance as per the ESMS to be developed.
Nawy does not currently have a dedicated Child Labor (and Forced Labor) policy or an explicit child labor clause embedded in its HR policies. While child labor risk is low given the nature of Nawy’s general operations, Nawy Unlocked’s operations via contractors require clauses prohibiting child labor to be included in contractor agreements (ESAP #5). Contractor and Supplier Management procedures should also include a policy that clearly states that contractors will not employ workers under the age of 18 and establish measures for compliance monitoring by the E&S/OHS team (ESAP #1).
Nawy’s Grievance and Complaints Policy and Workplace Harassment Policy establish a simple, confidential, and nonretaliatory process for handling grievances from employees, contractors, and clients, including investigation, resolution, documentation, and an appeal mechanism, which broadly aligns with good practice and core IFC principles; however, compared to IFC Performance Standards expectations, gaps remain, notably with respect to the need to define timelines for grievance handling, the addition of an option to handle anonymous complaints, internal handling by the People & Culture team (HR) without independent escalation, a lack of differentiated procedures for different stakeholder groups, and a lack of provisions for monitoring, trend analysis, or disclosure of grievance data. Nawy will therefore update and operationalize its Grievance and Complaints Policy and Workplace Harassment Policy to ensure a unified, accessible, and effective grievance framework by: (i) defining clear timelines for grievance acknowledgement, investigation, resolution, and appeal of grievances and harassment complaints; (ii) introducing multiple reporting channels, including an option for anonymous complaints; (iii) clarifying escalation pathways for sensitive cases, including workplace harassment, sexual harassment, and cases involving managers, with senior management or independent review where appropriate; (iv) ensuring alignment and cross referencing between the Grievance and Complaints Policy and the Workplace Harassment Policy to avoid gaps or duplication; and (v) establishing a system to track, analyze, and periodically review grievance and harassment cases and trends as part of management and ESG oversight. (ESAP #6)
PS3-Resource Efficiency and Pollution Prevention
The main sources of project emissions include use of electricity at Nawy's offices and during finishing activities. Considering Nawy's activities are mostly office-based and the limited extent of property finishing, GHG emissions are expected to be well below 25,000 Ton Co2 eq.
Nawy does not currently have a waste management plan. Main hazardous materials used by Nawy Unlocked for its operations include paint and solvents used in finishing activities. Nawy will develop and implement a waste management plan and Nawy’s E&S/OHS team will ensure contractors adhere and implement Nawy’s waste management measures. (ESAP #1 & 7).
PS4 – Community Health, Safety, and Security
Nawy activities are expected to have potentially limited impact on nearby communities during finishing activities. These risks are expected to be mitigated through adequate implementation of contractor management procedures related to waste disposal and through the external grievance mechanism. Additionally, Nawy does not employ security contractors since all properties are located in gated communities where the developer is responsible for security.
