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 E&S Risks and Impacts
Alice’s E&S commitments are articulated in its Code of Conduct (O Combinado Etico Magenta) and related internal frameworks. These commitments include promoting diversity, equity, and worker wellbeing, supporting social impact initiatives related to health access and prevention, and reducing the environmental footprint of its operations. As part of ESAP #1, the Company will consolidate and further articulate these commitments through the development and implementation of a standalone corporate E&S Policy, defining Alice’s approach to managing E&S risks and impacts in line with applicable Brazilian law and good international industry practice, and setting out the E&S objectives and principles that guide the Company’s operations.
While Alice does not own or operate healthcare facilities, its business model involves the provision and coordination of healthcare services that may be accessed by children and adolescents. Therefore, as per ESAP #2, Alice will develop and implement a Child Safeguarding Policy applicable across its operations to prevent, identify, and respond to potential risks to children, in line with applicable law and good international industry practices.
For its directly contracted network, the Company has established a formal due diligence, validation, and monitoring framework for accrediting and overseeing health institutions, designed to identify, assess, and manage environmental, social, safety, and reputational risks throughout the contracting lifecycle. The process combines screening and on site technical assessments based on applicable Brazilian regulations and recognized healthcare standards, covering patient safety and quality, operational controls, and patient centered care. Contracts with directly accredited providers require compliance with applicable health regulations, patient safety and non discrimination standards, and provide Alice with audit and termination rights in cases of non compliance.
Alice also relies on a network sharing agreement with CASSI to provide access to health providers outside its directly contracted network. Under this agreement, CASSI is responsible for ensuring that its accredited providers comply with applicable Brazilian laws and the regulations of the National Regulatory Agency for Private Health Insurance and Plans (Agencia Nacional de Saude Suplementar – ANS), including prohibitions on discrimination, as well as environmental protection obligations. The agreement provides information sharing and escalation mechanisms and Alice retains the right to request the exclusion of specific providers, granting a mechanism to address quality, safety, or reputational concerns despite the absence of direct contracting.
Building on the Company’s existing risk management practices (Code of Conduct, suppliers due diligence framework, quality and safety monitoring), Alice will, as per ESAP #3, develop a consolidated corporate-level E&S risk identification and assessment register covering its own operations, directly contracted providers, and network-sharing arrangements. The Register will be commensurate with the Company’s risk profile and will cover key E&S risks and impacts across its operations and provider networks, including child safeguarding and sexual exploitation, abuse, and harassment (SEAH), and defining corresponding mitigation measures, responsible functions, and monitoring mechanisms. Further, as per ESAP #4, Alice will extend its due diligence framework for directly contracted providers by explicitly incorporating screening for child safeguarding practices and SEAH risks. For providers accessed through the CASSI network, Alice will further strengthen its internal operational controls to manage these risks, including defined escalation triggers for SEAH and child safeguarding related allegations, survivor centered grievance handling through Alice’s internal mechanism, and the escalation to CASSI, including the exclusion of specific providers when needed.
Alice’s primary care strategy combines directly managed health professionals, including nurses and physicians, with proprietary digital tools. Artificial intelligence (AI) facilitated digital systems are used to collect symptoms and define priorities, while nurses and physicians provide protocol-based guidance, diagnose, decide on appropriate treatment and referrals, including escalation to secondary or tertiary services when clinically required. Alice’s AI systems do not make clinical decisions and operate under clinician-defined protocols with mandatory human oversight, and audits to mitigate potential bias. Health professionals are trained in patient safety, clinical protocols, regulatory compliance, data protection requirements and digital health systems.
Alice follows an operational protocol to manage clinical and safety emergencies reported through its digital channels. The protocol includes activation of public or private emergency services based on the member’s location and circumstances, continuous monitoring until assistance arrives, mandatory internal escalation, and real time recording in the electronic health record. As per ESAP #5, Alice will formalize and document its emergency response protocol.
Corporate level oversight of E&S risks is integrated within the Legal and Compliance function, while operational risks related to patient safety and service delivery are managed by a dedicated Quality and Safety team. Labor, occupational health and safety, and workforce related E&S aspects are managed by the People team.
PS2 – Labor and Working Conditions
By the end of 2025, Alice had 569 workers, of whom 68% were women. More than 90% of the workforce is employed under the Brazilian Consolidation of Labor Laws (Consolidacao das Leis do Trabalho – CLT), which includes provisions related to formal employment contracts, working hours, and statutory leave. In addition to legally mandated benefits, Alice provides health and life insurance, as well as extended maternity and paternity leave.
Alice also engages independent contractors following the Brazilian legal framework for independent professional services, including physicians providing primary care services and other healthcare professionals. These contractors operate with professional autonomy and are free to provide services to other companies as well.
Alice’s human resources policies and procedures are outlined in an HR Handbook covering recruitment, onboarding, performance management, compensation and benefits, working hours, leave, occupational health and safety, diversity and inclusion, and worker grievance mechanisms. In addition, Alice has established a Code of Conduct that extends to health professionals and defines standards of behavior, including zero-tolerance towards discrimination and sexual harassment. Further, all teams undergo mandatory institutional Compliance and anti-harassment training. Alice operates a grievance mechanism accessible to employees, contractors, partners, and third parties through an online platform, which allows for the submission of anonymous complaints. The Code of Conduct sets out procedures for the investigation and resolution of grievances, protection against retaliation, and oversight by the Compliance function and an Ethics Committee. HR policies and procedures and working conditions are consistent with the requirements of IFC Performance Standard 2. To further strengthen these mechanisms, as per ESAP #6, Alice will enhance its existing grievance mechanisms by developing and implementing a dedicated, survivor-centered SEAH Protocol encompassing informed consent, psychosocial support, and safeguarding of affected individuals during investigations.
According to the information provided by the Company, between 2022 and 2024, Alice undertook organizational changes and restructuring which included workforce adjustments. These processes were supported by structured communication plans, and included severance packages that met or exceeded statutory requirements. As per ESAP #7, Alice will formalize a retrenchment framework for any future workforce adjustments, aligned with PS2 requirements, covering alternatives analysis, transparent selection criteria, worker consultation, compliance with notice and severance requirements, and access to grievance mechanisms.
