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) and Policy: Neither company had a project-specific ESMS aligned with IFC Performance Standards. In Zambia, E&S risk management mainly depended on the EPC contractor, whose systems are internationally recognized (ISO 9001, 14100 and 451001) but showed gaps in site enforcement and client oversight. The Djibouti project is greenfield with no formal ESMS or defined E&S practices. At the time of appraisal, no EPC contractor or equivalent construction arrangements had been defined. As such, responsibility for the development and implementation of the ESMS rests with Future Africa as the project company. This lack of project-owned and specific ESMS poses a material risk under PS1, limiting systematic risk management throughout the project life cycle. As such, to address this gap, the companies will create and implement tailored ESMSs and E&S Policies. In Zambia before hotel operations, while in Djibouti before construction starts [ESAP#3 and 4].
Identification of Environmental and Social Risks and Impacts: E&S risk identification differs by country operations, reflecting the maturity of each business’ ESMS. In Zambia, a hotel ESIA has been conducted that meets selected national regulations but falls short of IFC Performance Standards omitting critical issues like workforce conditions, waste management, sexual exploitation, abuse and harassment (SEAH), water use, and community health and safety. Notably, the due diligence identified gaps between the project and Zambia’s Gender Equity and Equality Act, which requires private sector entities to establish policies and procedures to prevent and address sexual harassment. To close these gaps, Zebra will establish a comprehensive environmental and social risk identification and assessment procedure as part of its ESMS. This procedure will ensure systematic identification and management of E&S risks associated with the operational phase of the hotel following IFC’s investment. Based on the outcomes of this process, Zebra will develop and implement appropriate management plans and mitigation measures through its ESMS, in line with IFC Performance Standards as outlined in the sections below. In Djibouti, no project-specific ESIA has been carried out to date. The facilities are located within Damerjog Industrial Park, which possesses a zone-level ESIA prepared in 2018. The ESIA is insufficient and does not meet IFC standards. To mitigate this gap, Future Africa will commission a full ESIA covering the project site and submit the terms of reference and final report for IFC review before construction begins [ESAP#1 and 2].
Management Programs and Mitigation Measures: during due diligence, neither project had environmental and social management programs in place to address identified risks. In Zambia, the absence of PS1-aligned management programs means that E&S risks associated with the transition to the operational phase of the hotel, such as occupational health and safety, emergency response, public and child safety, community health, and Gender-Based Violence/Sexual Exploitation, Abuse and Harassment (GBV/SEAH), were not managed through a project-owned system. During construction, E&S risk management largely relied on the EPC contractor framework with no significant issues recorded. In Djibouti, the absence of management programs means that typical hazards associated with warehouses and grain silos, including contractor oversight, traffic and logistics, occupational health and safety, dust, explosion and fire risks, and community health and safety, are not systematically managed through a project-owned system. . To address these gaps, as a result of IFC’s involvement, Zebra and Future Africa will establish and implement an ESMS, including management programs proportionate to the identified risks. These programs will be applied by contractors (during construction in Djibouti and by the hotel operator in Zambia) and will support proactive management of these risks, as well as strengthen client oversight and ensure alignment with IFC Performance Standards
[ESAP#3 and 9].
Organizational Capacity and Competency: The existent organizational capacity reflects the maturity of each project. In Zambia, construction-related roles are currently in place, including the project manager, architect, and site supervisors, supporting ongoing construction activities. The project manager and the future hotel manager are expected to transition into operations. During construction, day-to-day environmental and social health and safety management is undertaken by the EPC contractor. However, Zebra does not have a dedicated client-side environmental and social function to manage E&S risks, oversee the EPC contractor’s management of E&S risks during construction close-out and hotel operations. In Djibouti, no E&S structure exists due to the project’s early greenfield stage. To address this, both Zebra and Future Africa will set up qualified project-level E&S structures to effectively manage risks. In Djibouti, to address construction and grain silos handling related risks, Future Africa will also implement a Quality, Environment, Health, and structure by appointing an Health, Safety and Environment (HSE) officer for construction and operations [ESAP#5 and 6].
Emergency Preparedness and Response: Both projects currently lack complete emergency preparedness arrangements commensurate with their risk profiles. For the Lusaka hotel, emergency procedures were largely related to the EPC contractor’s construction-phase arrangements. Zebra does not yet have a consolidated, hotel-wide Emergency Preparedness and Response Plan (EPRP) for the operation phase, including guest safety and the public interface. For the Djibouti logistics project, no documented emergency procedures exist. The greenfield location with limited nearby emergency services increases reliance on robust on-site preparedness. Credible emergency scenarios for the two projects include construction (Djibouti) and operation incidents (Zambia and Djibouti) includes: fire and explosion, earthquake, evacuation and crowd management, medical emergencies, and security/public safety incidents; for the grain logistics facilities, scenarios also include combustible dust explosions events.
In line with PS1 and Good International Industry Practice (GIIP), both companies will ensure that hazard identification and emergency risk assessments are conducted for each project, and that site-specific EPRPs are developed and implemented as part of their ESMS. In Zambia, prior to hotel opening, Zebra will develop and implement a client-led EPRP for the operational phase. The EPRP will define roles, responsibilities, and escalation protocols; specify required emergency equipment and associated inspection and maintenance arrangements; establish training and competency requirements for workers and contractors; include periodic drills with documented corrective actions; and set out coordination and communication procedures with local authorities and emergency response services. Implementation will be aligned with Hilton standards, and emergency readiness will be verified through training and drills with a focus on guest and community safety. In Djibouti, where both construction and operational systems are yet to be established, Future Africa will conduct an emergency risk assessment and develop and implement a comprehensive EPRP prior to commencement of operations. The EPRP will address key risks associated with warehouse and grain silo operations, including grain handling hazards as well as constraints in external emergency response capacity [ESAP #20 and 21].
External Communications and Grievance Redress Mechanisms (GRM): during the construction phase in Zambia, workers were able to raise concerns and complaints verbally and directly with the on-site HSE Officer under an informal arrangement managed by the EPC contractor. However, IFC did not identify a formal grievance procedure or documented grievance log, nor any open construction-related grievances at the time of the due diligence. Zebra will establish and implement a formal grievance mechanism covering construction close-out and operations, including procedures for receiving, documenting, tracking, and resolving complaints. The GRM will accept complaints related to incidents which occurred prior to its implementation and were unsatisfactorily resolved. Zebra’s ESMS will also include provisions to ensure that the grievance mechanism addresses any legacy issues from the construction phase that may arise during operations and maintenance. The GRM will also include provisions for appropriate treatment of GBV cases. In Djibouti, no grievance mechanism is currently in place due to the early stage of project development. Future Africa will therefore establish and implement a formal grievance mechanism prior to the start of construction and maintain it during operations. The mechanism will be integrated into the ESMS and will include clear procedures for stakeholder access, documentation, monitoring, and periodic review [ESAP #7 and 8].
Supply Chain Considerations: For the Zambia hotel project, IFC did not identify supply chain risks at appraisal given the project’s construction stage. However, Zebra does not yet have ESMS-aligned supply chain procedures for hotel operations and will develop procurement procedures and contractor management frameworks to integrate E&S requirements into supplier and contractor oversight. In Djibouti, supply chain oversight is limited. For its current in-country operations, Future Africa procures commodities from traders in India, the UAE, Thailand, and Brazil but lacks policies and procedures to ensure sourcing aligns with the Performance Standards, including systems to identify and manage labor, environmental, and traceability risks. To address this gap, FZE will adopt a Sustainable Procurement Policy and Supplier Code of Conduct aligned with IFC requirements, integrate them into supplier agreements and training, and progressively prioritize lower-risk, more traceable supply chains [ESAP #9 and 10].
Monitoring, Management Review, and Ongoing Reporting: Both projects lacked systems for monitoring their E&S performance, incident tracking, corrective action management, and management review. In Zambia, Zebra had no formal procedures covering construction, construction close-out or operational oversight of the hotel. In Djibouti, Future Africa had not set up monitoring or reporting due to the very early stages of the project. Both companies will set up ESMS procedures for E&S monitoring, incident reporting, corrective actions, and management reviews. In Zambia it will cover the remainder of the construction and hotel operations, while in Djibouti, separate monitoring and reporting arrangements will be established for the construction and operational phases, starting prior to construction and continuing through operations.
PS2: Labor and Working Condition:
In Zambia, construction staffing is down to 20% of its peak, and hotel permanent staff will be decided before opening. Zebra manages hotel labor under Hilton’s franchise. In Djibouti, Future Africa will employ 250 - 300 workers during operations, aiming for at least 75% Djiboutian nationals and 30% women, with construction relying on EPC contractors and up to 250 temporary staff.
Human Resources (HR) Policies and Working Conditions: due diligence revealed that neither company has documented, project-specific HR policies aligned with PS2 for the relevant phase of each project. In Zambia, labor management during construction period is currently addressed through the EPC contractor system. However, Zebra does not yet have its own project-specific HR policy and procedures for hotel operations. As confirmed by Hilton during IFC’s due diligence, hotel staff will be employed by Zebra. Hilton will provide branding, operating systems, and standards, but not franchisee HR management. In Djibouti, Future Africa has not yet defined work schedules or developed project-specific HR policies for its planned construction and operations. These gaps create risks under PS2 in relation to recruitment, employment terms, wages, working hours, overtime, rest periods, sexual exploitation, abuse and harassment, discipline, and separation. To address these gaps, both companies will develop and implement PS2-compliant HR policies and procedures for their own operations before hotel opening in Zambia and before construction starts in Djibouti. These will cover working hours, overtime, rest periods, voluntary overtime, compensation, sexual exploitation, abuse and harassment, employee handbooks at induction, and systems for tracking hours and monitoring contractor compliance through the ESMS during construction and operations [ESAP#11 and 12].
Workers’ Organizations, Freedom of Association (FoA), and Collective Bargaining (CBA): Currently, neither project’s has HR policies and procedures about workers' rights to FoA or CBA, in line with national laws in Zambia and Djibouti allowing for these rights. Per PS2, projects must respect employees’ rights to organize and bargain collectively without interference, discrimination, or retaliation. As per ESAP #6 both companies will develop their HR policies and employee handbooks and include FoA and CBA as appropriate. The policies will include procedures which enable union activities such as access to workers for the purpose of conveying their rights, training, facilitating elections and engaging with worker representatives if and when workers decide to organize.
Sexual Harassment in the Workplace: During appraisal, neither project had policies on non-discrimination, sexual harassment prevention, or secure complaint channels, posing a PS2 risk. PS2 requires an abuse-free workplace with proper policies, training, and grievance mechanisms. The risk is increased due to contractor presence in Zambia's hospitality sector and upcoming workforce mobilization in Djibouti. Both companies will address this by introducing Codes of Conduct for all workers, contractors and security personnel and Anti-Sexual Harassment-specific policies, including confidential reporting and response, referrals, worker training, and coverage for contractors and staff during construction and operations [ESAP#13 and 14].
Child Labor, Forced Labor, and Child Protection: During construction in Zambia, the EPC contractor implemented a code of conduct and HR policy aligned with the Zambian Employment Act, which include provisions prohibiting child labor within contractor-managed activities. However, for the operational phase, Zebra has not yet established project-specific policies or procedures addressing child labor and forced labor risks. In both projects, reliance on contractors increases exposure to such risks in the absence of formal, project-led systems. To address these gaps, Zebra and Future Africa will establish and implement HR policies within their ESMS, including age verification procedures, restrictions on hazardous work for young workers, and clear labor standards applicable to contractors and suppliers. Forced labor will be explicitly prohibited through contractual provisions and oversight mechanisms. Compliance will be monitored through the ESMS, supported by targeted training for management, workers, and contractors on child labor, forced labor, and child protection requirements.
Workers’ Grievance Mechanism: At present, neither project has a worker grievance mechanism that meets PS2 standards, which require accessible, confidential, and non-retaliatory procedures. In Zambia, the existing grievance mechanism used by the EPC contractor is not well adapted to receiving sexual harassment reports or survivor centered. The risk is higher in Zambia due to the shift from construction to hotel operations, while in Djibouti, the risk stems from extensive contractor involvement during construction. Both companies will introduce mechanisms for all workers: ensuring multiple ways to report issues, confidentiality, protection against retaliation, prompt resolution of grievances, and appropriate mechanisms to take complaints on sensitive topics such as GBV/SEAH, child labor, and forced labor. Zebra will put in place a system to address workers grievances before the hotel opens, whereas in Djibouti, the system will be active before construction begins and continue throughout operations.
Occupational Health and Safety (OHS): At appraisal, neither project had a client-led OHS system fully aligned with PS2. In Zambia, construction OHS is managed by the EPC contractor. The contractor’s incident register recorded only a few minor incidents, all addressed on site, with no indication of major construction incidents. However, Zebra does not yet have its own OHS system for construction close-out and transition to operations. In Djibouti, the project is still at an early stage and lacks a formal OHS framework and documented hazard identification process. To address these gaps, both companies will establish OHS frameworks under their ESMS covering hazard identification, procedures, training, incident reporting and investigation, emergency preparedness and response, monitoring, and corrective actions. Zebra will do so for construction close-out and hotel operations, while Future Africa will establish its framework before construction and adapt it to site-specific operational risks [ESAP #15 and 16].
Workers Engaged by Third Parties: Both projects rely on third-party workers but lacked project-level contractor labor EHS systems at appraisal. This created a PS2 risk requiring commercially reasonable efforts to ensure contractors meet labor, safety, and grievance standards. The risk is greater in Zambia due to ongoing contractor activity during final works and hotel operations, and similarly in Djibouti with expected reliance on contractors for construction and services. To address this, both companies will implement contractor management systems aligned with PS2 covering labor, EHS, GBV/SEAH, child abuse and forced labor, and grievances including oversight, monitoring, audits, and supplier codes of conduct during construction and operations [ESAP#10].
Retrenchment and Construction Close-out: Retrenchment / demobilization risks persist across project stages under PS2. In Zambia, construction demobilization has reduced the EPC contractor’s workforce to 20% of its peak. Zebra will submit a demobilization plan and proof of labor law compliance before IFC investment and ensure clear communication, prompt payments, and proper grievance mechanisms for any future workforce reductions in line with PS2 standards. In Djibouti, major demobilization or retrenchment is not expected at this project stage, but Future Africa will manage any future separations following local laws and PS2 principles.
Supply Chain: PS2 requires clients to identify and manage labor and working conditions risks in their primary supply chains, particularly where risks such as child labor, forced labor, unsafe working conditions, or lack of grievance mechanisms may occur. During due diligence, neither company has documented processes to assess and manage such risks in their supply chains. In Zambia, potential risks may arise from suppliers to hotel operations (e.g., food and beverage, laundry, and other services). In Djibouti, Future Africa procures commodities through international traders. However, due to the absence of supply chain risk assessment and traceability systems, labor and environmental risks in the supply chain cannot be excluded. To address these gaps, both companies will establish a Supplier Code of Conduct aligned with PS2 requirements, incorporate contractual obligations for primary suppliers, and implement a risk-based supply chain monitoring system proportionate to identified risks [ESAP#10].
PS3: Resource Efficiency and Pollution Prevention:
The due diligence shows that Zebra and Future Africa have different PS3 risk profiles due to sector and project lifecycle. As described in the Project Description, the Zambia component also includes a waterpark developed by Zebra. However, this facility is not part of the IFC investment and was not assessed during IFC’s due diligence. Accordingly, the PS3 considerations presented in this section relate only to the Hilton-branded hotel in Zambia and to the warehouse and grain silo facilities in Djibouti. In Zambia, PS3 risks are associated with the completion and future operation of the hotel. During the construction phase, E&S risks related to resource use, emissions, waste, and pollution prevention are managed by the EPC contractor under contractor-led EHS procedures, with limited oversight by Zebra. Mitigation measures focus on operational readiness and the establishment of systems prior to hotel opening. In Djibouti, as a greenfield logistics development, PS3 risks relate to the design, construction, and future operation of warehouse and grain silo facilities, including resource efficiency, pollution prevention, and control of dust, noise, and emissions. Mitigation measures for Djibouti are defined primarily at the design stage and will be implemented prior to construction and commissioning through the ESMS.
Resource Efficiency: In Zambia, construction-phase resource efficiency is managed by the EPC contractor as part of contractor-led site practices. The hotel design includes resource-efficient features for operations, including high-performance glazing, guest room energy management systems, centralized heating, ventilation, and air conditioning (HVAC) with heat recovery, and hybrid solar and heat pump hot water systems. As the hotel is not yet operational, IFC reviewed construction progress and design specifications rather than performance. While these features are broadly aligned with GIIP, Zebra does not yet have formal procedures to monitor and manage operational resource efficiency and will establish these under its ESMS, including monitoring energy and water use. In Djibouti, the project remains at a greenfield stage and energy system design is still being finalized. Future Africa will incorporate resource-efficient design and equipment in line with GIIP and establish ESMS procedures to monitor and report resource use during construction and operations [ESAP #17].
Energy Efficiency: In Zambia, construction-phase energy use is managed by the EPC contractor. The hotel is designed to use ZESCO grid power, supported by on-site solar and backup diesel generators during operations. IFC reviewed design information showing projected annual electricity demand of about 5.6 million kWh, with solar expected to provide about 1.4 million kWh. As operations have not started, system performance cannot yet be assessed. Zebra does not yet have project-specific procedures to monitor and manage operational energy performance and will establish these under its ESMS before hotel opening, including tracking energy use against design assumptions. In Djibouti, energy systems are still being defined at the greenfield design stage. Future Africa will incorporate energy-efficient design and equipment in line with GIIP and establish ESMS procedures to monitor and manage energy use during construction and operations [ESAP #17].
Greenhouse Gas (GHG) Emissions: Both projects currently lack consolidated GHG inventories, which are relevant to PS3 requirements for screening and, where applicable, quantifying Scope 1 and Scope 2 emissions using recognized methodologies. Zebra's energy sources include grid electricity, on-site solar, and efficient diesel generators, but annual GHG quantification (tCO2e) was not completed during appraisal. Future Africa, as a greenfield project, lacks defined energy sources, so GHG estimates are pending. Both companies will collect yearly electricity and fuel data through their ESMS, review PS3 GHG rules, and, if needed, measure Scope 1 and Scope 2 emissions during construction and operations using standard methods.
Water Consumption: In Zambia, construction-phase water use is managed by the EPC contractor, but consumption data was not available for IFC review. During operations, the hotel is expected to source water from the Lusaka Water Supply and Sanitation Company (LWSC), supplemented by boreholes and rainwater harvesting, with filtration and reverse osmosis to meet applicable quality standards. Zebra does not yet have formal procedures to monitor and manage operational water use and will establish these under its ESMS before hotel opening, including monitoring municipal and borehole use, improving efficiency, and ensuring compliance with permits and licensing requirements. In Djibouti, water supply systems are still being defined at the greenfield stage. Expected demand includes domestic use, cleaning, dust suppression, and fire protection. Future Africa will define water requirements during design, incorporate water-efficient fixtures and systems in line with GIIP, and establish ESMS procedures to monitor and report water use during construction and operations.
Pollution Prevention (Air Emissions, Dust, Noise, and Explosion Risk): In Zambia, construction-phase air emissions, noise, dust, and waste were managed by the EPC contractor under contractor-led HSE procedures, with oversight from Zebra. During operations, the hotel is expected to generate air emissions from standby diesel generators and kitchen exhausts, and wastewater will be treated through grease traps and filtration before discharge to the municipal sewer in line with applicable permits. Zebra has not yet formalized procedures for air emissions, wastewater, and pollution prevention and will establish these under its ESMS before hotel opening. In Djibouti, as a greenfield project, pollution prevention measures are still being defined. Key risks include grain dust, equipment noise, and fire and explosion during storage and handling. Future Africa will incorporate design and operational controls, including dust collection, housekeeping, and explosion prevention measures such as venting, grounding, and spark-proof equipment. An independent ATmospheres EXplosibles (ATEX) review will be conducted, and procedures will be implemented through the ESMS for construction and operations [ESAP #17].
Wastewater and Stormwater Management: In Zambia, the construction phase, wastewater and stormwater management are the responsibility of the EPC contractor. However, detailed information was not available for IFC review. Once operational, the hotel is expected to discharge stormwater and wastewater through the municipal drainage and sewerage systems. However, formal procedures governing wastewater and stormwater management have not yet been documented by Zebra. To address this gap, Zebra will establish and implement wastewater and stormwater management procedures under its ESMS to ensure alignment with applicable permits and GIIP prior to commencement of operations. In Djibouti, Future Africa has not established wastewater or stormwater management yet. Plans for collection and treatment will be developed in the design phase, ensuring compliance with World Bank Group EHS Guidelines and keeping records. Stormwater systems will aim to prevent erosion, flooding, and uncontrolled discharge, with inspection and maintenance included in ESMS procedures.
Waste (Non-Hazardous and Hazardous Waste): In Zambia, construction related waste was managed by the EPC contractor which relied on the municipal waste collector services. For operations, Zebra has plans for segregating wet waste, paper, plastics, and glass using approved collectors and audit logs. However, operational procedures for waste and chemical management lack full documentation. As remedy, Zebra will create a comprehensive Operational Waste Management Plan covering segregation, storage, provider oversight, recordkeeping, and hazardous waste handling. For Future Africa, waste streams and procedures are not yet developed, creating PS3 risks for future operations. To comply with PS3, Future Africa will prepare an Operational Waste Management Plan in its ESMS before commissioning. Hazardous waste will be tracked via chain-of-custody for auditability.
Hazardous Materials Management (Chemicals, Fuels, and Spill Prevention): In Zambia, hazardous materials were not identified during construction. The EPC contractor ESMP used the municipality services for waste collection. During operations, the hotel is expected to use fuels for standby generators and chemicals for water treatment and maintenance. Zebra does not yet have documented procedures for storage, handling, spill prevention, and incident response, creating PS3 risks. To address this gap, Zebra will establish hazardous materials management procedures under its ESMS before operations, covering storage, containment, handling, staff training, spill prevention, and incident tracking. In Djibouti, hazardous materials management for fuels and chemicals is not yet in place, creating similar PS3 risks. Future Africa will implement procedures for safe handling, storage, containment, spill response, and incident tracking before operations begin, including secondary containment and leak detection for fuel storage.
Pesticide Use and Management (Including Fumigation): pest management measures are expected to be relevant during the operational phase of the hotel. However, Zebra has not documented whether pesticides will be used directly or through third-party service providers, nor established procedures for their selection, storage, handling, application, and disposal. To address this gap, Zebra will clarify the use of pesticides and establish pest management procedures under its ESMS, including requirements for contractor oversight, in line with PS3 prior to commencement of operations. In Djibouti, since it is a greenfield project, pest control plans are not yet defined, so Future Africa should confirm usage and develop an Integrated Pest Management (IPM) plan. This IPM plan will cover pest control measures such as maintaining cleanliness, preventing pest entry, using traps, repairing access points, and monitoring service providers, to meet PS3 standards.
PS4: Community Health, Safety and Security:
Road Traffic and Transport Safety: due diligence identified road traffic and transport safety as a key PS4 risk for both project companies, with different exposures. In Zambia, information on construction-phase traffic management arrangements is not available in the provided documents. Traffic-related risks during this phase are expected to be managed under contractor-led EHS frameworks, with oversight from Zebra. Looking ahead, the Zebra project is expected to increase light vehicle traffic near the hotel, while Future Africa’s project will raise heavy vehicle activity and community safety risks. As such, systematic measures, including management procedures, access controls, speed limits, driver qualifications, maintenance, and incident responses, will be integrated into each company’s ESMS and site emergency plans, aligned with local authorities, before construction and operations begin [ESAP#21].
Life and fire safety: Both projects face significant life and fire safety risks that must be verified against national regulations and GIIP before operations commence. The Zebra hotel, classified as a high-rise structure (over 95 meters tall), necessitates comprehensive fire and smoke control systems, effective compartmentation, reliable detection and suppression equipment, and safe, well-designed evacuation routes tailored to its hospitality function. Although the design follows Hilton standards, an independent review is required to confirm full readiness for life and fire safety prior to opening. Zebra will undertake any necessary upgrades and secure independent verification to ensure all fire and smoke controls, as well as evacuation procedures, are suitable for the building’s height and occupancy. [ESAP #20].
In Djibouti, Future Africa’s warehouses, silos, and bagging facilities pose significant fire and explosion risks linked to grain storage and handling, particularly from combustible dust. At the time of due diligence, fire protection and life safety systems had not yet been designed or confirmed. To address these risks, and in line with PS4 and GIIP, Future Africa will ensure that all mitigation measures are properly designed, installed, commissioned, and maintained. The company will obtain independent specialist verification before operations begin. This includes an independent ATEX review to assess explosive atmosphere risks, as well as a separate assessment by a qualified independent specialist. All recommended controls and measures will be implemented prior to the start of operations,
consistent with [ESAP #20].
Hazardous Materials Safety: For hotel operations, hazardous materials are typically limited to fuels for standby generators, cleaning agents, and maintenance-related chemicals. However, the extent of such use for the hotel project has not been defined. Potential risks associated with the use of fuels for backup power generation, and other operational materials will need to be managed through the Zebra ESMS, including procedures for storage, handling, spill prevention, and emergency response before hotel operations. For the Djibouti project, hazardous materials safety is a PS4 risk due to Future Africa's use of fumigation systems and small amounts of fuels and lubricants. Currently, specific management and spill response procedures have not been established. PS4 requires preventing releases and off-site impacts, so Future Africa will implement safety protocols for handling, storage, disposal, spill prevention, response, and emergency preparedness in the ESMS before construction and operation, in line with GIIP.
Food safety: Food safety is a risk for the Zambia project since Zebra will run several food and beverage venues. Management currently relies on Hilton standards without a unified oversight system to meet PS4 requirements. To comply, Zebra will add food safety management to its ESMS before opening, with site-specific procedures, clear roles, staff training, incident response plans, ongoing monitoring, and integration with health protocols.
Security management: Both projects identified security management risks. In Zambia, Zebra uses third-party providers for construction security and plans hotel-specific arrangements during operations but lacks a formal Security Management Plan. In Djibouti, Future Africa relies on industrial zone security and will hire private security personnel in the future yet has no documented system. PS4 requires proportionate, human rights-respecting measures aligned with GIIP. Both companies will establish Security Management Plans before construction or operation begins, as applicable.
Sexual Exploitation and Abuse: In Zambia, the operation of the hotel presents a risk of sexual exploitation and abuse (SEA) of staff, particularly female and lower-grade service workers, by non-staff individuals such as guests and visitors. In the absence of clearly defined policies, staff training, and accessible, survivor-centered grievance mechanisms, such risks may remain unreported and unmanaged. The client has an obligation to provide a safe working environment and to identify and manage risks arising from third-party interactions. In Zambia, the client will implement and enforce a comprehensive, survivor-centered SEAH prevention and response framework, including a code of conduct, staff training, clear procedures for managing inappropriate guest behavior, and confidential grievance mechanisms with referral pathways to qualified GBV service providers. In Djibouti, it is envisaged that there will be limited interaction between workers and the community which might only present in instances when workers such as drivers would be out in the community and this would be managed through a strict code of conduct applicable to all workers including drivers whether staff or contractual.
PS5: Land Acquisition and Involuntary Resettlement:
N/A
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources:
N/A
PS7: Indigenous People:
N/A
PS8: Cultural Heritage:
N/A
