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
Policy and E&S Management System. Pickalbatross Morocco has a set of documented corporate policies and procedures demonstrating its commitment to environmental, social, and health and safety management, including an Environmental Policy, Occupational Health and Safety (OHS) and Hygiene policies, a Code of Conduct, Food Safety procedures, Waste Management procedures, Security policies, and documented Health, Safety and Environment (HSE) procedures. Operational manuals, Standard Operating Procedures (SOPs), and environmental Key Performance Indicators (KPIs) are established at group level and tracked at each hotel, with monthly monitoring of electricity consumption, laundry loads, waste quantities, and other indicators. Food safety and HSE audits are conducted on a regular basis by third-party certified entities. While these core elements of an E&S management system are in place, their implementation can be further strengthened across sites and activities, in particular with respect to construction works and the management of third-party contractors. The Company will consolidate and formalize its E&S framework to ensure alignment with the IFC Performance Standards (PSs), covering: (i) E&S risk screening and assessment procedures for refurbishment and construction activities across all hotels; (ii) site-level E&S implementation requirements; and (iii) consolidated E&S monitoring and reporting procedures addressing operational, contractor, and labor aspects (ESAP #1).
Identification of Risks and Impacts. Environmental and Social risks and impacts linked to the company’s hotel operations are identified and managed in line with Moroccan regulatory requirements, under the oversight of the Ministry of Tourism and the Ministry of Health. All operating hotels have Emergency Response Plans, investigation procedures, and risk assessments addressing fire, flooding, earthquakes, and risks for persons with reduced mobility. Construction permits required by Moroccan law have been obtained. However, current practices do not consistently address emerging E&S issues such as gender-based violence and harassment (GBVH) and child protection risks. As part of this investment, the company will conduct Environmental and Social Impact Assessments before or during (if not already completed) any refurbishment or new construction works (ESAP #2). Moreover, under the enhanced Environmental and Social Management System (ESMS), the company will integrate GBVH and child protection risks into its ongoing E&S screening, audits, and monitoring at the hotel level (ESAP #1).
Management Programs. A set of internal environmental, health and safety, and labor procedures are applied to its direct workers, and core health, safety, and security rules are extended to contractors and service providers — including those engaged in security, maintenance, construction, and other outsourced activities — while they operate on hotel premises. Contractor oversight is currently exercised by the hotel's Chief Engineer and the hotel management team. The appraisal identified the need to strengthen the consistency and effectiveness of contractor E&S supervision, particularly during construction and refurbishment activities. The Company will develop and implement a dedicated contractor E&S management procedure, setting out pre-qualification, contractual, induction, monitoring, incident-tracking, and grievance-handling requirements applicable to all contractors engaged in construction, refurbishment, and outsourced operational services (ESAP #3).
Organizational Capacity and Competency. At construction sites, EHS management is currently the responsibility of the Company's project management team, with support from third-party contractors. At hotel level, E&S and EHS matters are managed by the General Managers and Heads of Department within their respective areas of operation. However, the Company does not yet have a dedicated corporate-level E&S/EHS function with a consolidated oversight mandate, which limits consistency of implementation and monitoring across sites. The Company will appoint a qualified EHS Specialist responsible for coordinating and overseeing E&S risk management across all hotels — covering operational activities, contractor management, and any future construction or refurbishment works — and for supporting the development and implementation of site-level procedures, monitoring and reporting systems, and technical guidance to hotel management (ESAP #4).
Emergency Preparedness and Response. The Company has emergency response arrangements in place across its hotels, including documented Emergency Response Plans for scenarios identified during risk assessments. These include evacuation procedures, and coordination protocols with on-site clinics and external medical services. On-site clinics staffed with nurses operate at all hotels, supported by agreements with external clinics and hospitals. Staff are trained on emergency procedures, and periodic drills are conducted at hotel level. As part of the strengthened ESMS, these arrangements will be reviewed and updated to ensure consistent coverage across all hotels and alignment with the PSs, the WBG EHS Guidelines, and the contractor E&S and life and fire safety (LFS) requirements developed under the framework (ESAP #1).
Monitoring and Review. Pickalbatross Morocco currently tracks a set of operational environmental indicators at hotel level on a monthly basis, including electricity consumption, laundry loads, and waste quantities. As part of the strengthened ESMS, the Company will develop a consolidated E&S monitoring and reporting procedure defining KPIs across: (i) occupational health and safety (incident performance, workplace monitoring data, near-miss and hazard reporting); (ii) resource efficiency (water and energy); (iii) pollution prevention and control (air emissions, noise, effluents, and solid and hazardous waste management); (iv) food safety; and (v) worker grievances. Each hotel will compile monthly and quarterly E&S reports against these KPIs, consolidated at group level to support supervision by the EHS Specialist and reporting to IFC (ESAP #1).
Training and Awareness. Training on OHS and GBVH is not yet fully formalized or consistently delivered across the five hotels. The Company will develop and implement a structured E&S training program for all categories of workers — including direct employees, third-party workers engaged through labor agencies, contracted workers, and independent service providers — covering OHS, Human Resources policies, the Code of Conduct, GBVH and sexual harassment, food safety, emergency preparedness and response, and environmental management. Training content will be function-specific, documented, delivered at induction and refreshed on a regular basis, and tracked through attendance and completion records maintained at hotel level (ESAP #1).
PS2 : Labor and Working Conditions
Human Resources Policies and Governance. Pickalabtross Morocco has a HR team operating within a framework of policies and procedures, including the Internal Rules, the HR Standard Operating Procedures, and the Sustainability Management Policy. These instruments comply with Moroccan labor legislation and are broadly aligned with the requirements of IFC PS2. The HR function is further supported by modern information systems that enable efficient HR management and reliable access to data. However, the appraisal identified that certain PS2 requirements — in particular those related to contractor labor management, grievance handling, non-discrimination, and the prevention of sexual harassment and GBVH — are only partially reflected in the existing policy framework. The Company will update and strengthen its HR policies and procedures to close these gaps, including by formalizing provisions on non-discrimination and equal opportunity, prevention of and response to sexual harassment and GBVH, workers' grievance handling, recognition of freedom of association and collective bargaining, and contractor labor management (ESAP #5).
Employment Status. The Company's workforce is composed of a mix of permanent staff and temporary workers supplied through temporary work agencies. The appraisal noted that that temporary contracts also appear to be used for certain positions that are currently retained on a seasonal basis. The Company will: (i) conduct a workforce mapping exercise to identify all positions that qualify as permanent in nature, and develop a plan to transition the corresponding workers to permanent contracts; or, alternatively, (ii) document a legal review justifying the continued use of temporary labor on the basis of work for which it is customary, under the Moroccan Labor Code, not to enter into a permanent employment contract .In case of any change of ownership or management of the hotel, Pickalbatross will ensure that it will be accompanied by a structured workforce transition plan prior to the effective date of any such change, ensuring continuity of employment terms and mitigation of any adverse impacts on the existing workforce. (ESAP #6)
Working Conditions and Terms of Employment. All workers are paid at or above the statutory minimum wage and receive an annual bonus together with additional benefits. The Company operates a variety of work schedules and shift patterns, with working hours maintained within the legal weekly limit of 44 hours over six days. These arrangements are consistent with Moroccan labor legislation and PS2 requirements.
Workers' Organization. The Company demonstrates a commitment to respecting freedom of association and collective bargaining in practice; however, its current HR policy framework addresses these rights only indirectly. Worker representatives have not yet been elected across all hotels, and Works Councils have not been established. As part of the HR framework update, the Company will: (i) explicitly recognize workers' rights to freedom of association and collective bargaining, consistent with PS2 and applicable national law; and (ii) support worker representative elections in all Moroccan hotels during the upcoming nationwide electoral cycle, (iii) establish Works Councils where legally required, and hold regular meetings — at least monthly — with the elected representatives (ESAP #5).
Non-Discrimination, Equal Opportunity, and Prevention of GBVH. The Company has a clear commitment to non-discrimination, with women representing 27% of the workforce, and has identified the structural barriers limiting women's participation. Interviews with workers during the appraisal indicated that the work environment is respectful and supportive, and that workers feel comfortable raising concerns or reporting inappropriate conduct to their supervisors. However, the Company does not yet have a dedicated policy on the prevention of and response to sexual harassment and GBVH, nor a confidential mechanism specifically designed for reporting, documenting, and addressing GBVH-related complaints. As part of the HR framework update, the Company will formalize and communicate a dedicated GBVH prevention and response policy, establish a confidential GBVH reporting and response channel, and designate at least one trained focal point in each hotel to support its implementation (ESAP #5).
Occupational Health and Safety. Pickalbatross Morocco operates in a generally low-risk environment and demonstrates strong performance in food hygiene and safety. However, the broader OHS management system remains limited: with no dedicated OHS specialists in place; OHS policy is in place — including hazard identification, risk control, training, and incident investigation — but is however inconsistently applied across the hotels; and Health and Safety Committees have not been established across all hotels. During the appraisal, site-specific observations at the Marrakesh construction site highlighted instances of unsafe practices, \inadequate use of personal protective equipment (PPE), and poor housekeeping. The Company will appoint a qualified QHSE Specialist to lead the development and implementation of a comprehensive OHS management system aligned with PS2 and the WBG EHS Guidelines, including: (i) formalization of OHS policies and procedures covering hazard identification, risk assessment and control, training, and incident investigation; (ii) establishment of Health and Safety Committees across all hotels; (iii) a structured incident reporting and tracking process; and (iv) strengthened OHS oversight of all construction, refurbishment, and maintenance activities, including contractor performance (ESAP #7).
Grievance Mechanism. Worker–management relations are constructive, and workers reported feeling comfortable raising concerns directly with supervisors, senior managers, or HR, consistent with the channels described in the Company's existing arrangements. Complaints received in recent months have been minor in nature. A grievance mechanism is in place but it is largely informal: grievances and the actions taken to resolve them are not systematically recorded or tracked. As part of the HR framework update, the Company will strengthen and formalize its workers' grievance mechanism to ensure full alignment with PS2. The revised mechanism will be accessible to all workers — including workers engaged by third parties where their employer does not provide an adequate system — will allow concerns to be raised safely and without fear of retaliation, will set out clear steps for receiving, investigating, responding to, and closing out complaints, and will offer multiple reporting channels, including anonymous options such as grievance boxes and app-based reporting. A dedicated confidential channel will also be established for the reporting of sexual harassment and GBVH-related complaints (ESAP #5).
Workers Engaged by Third Parties and Supply Chain Workers. The Company relies on a limited network of local Moroccan suppliers, primarily for food and cleaning products. While the Company has a general understanding of its suppliers' profiles, it does not yet have visibility over potential elevated risks of child labor, forced labor, or significant safety issues in its primary supply chain. The Company will complete the mapping of its Moroccan food and non-food suppliers and conduct a desktop risk assessment to identify high-risk exposures related to child labor, forced labor, and significant health and safety concerns. Where such risks are identified, the Company will develop contractual requirements — including a supplier code of conduct — and implement measures to communicate expectations, mitigate identified risks, and establish ongoing monitoring of supplier labor practices (ESAP #8).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. The hotels are connected to the national electricity grid, with back-up diesel generators installed for use during grid outages. Space cooling is provided by centralized chiller systems, and waste heat recovered from the chillers is used for domestic hot water production. Electricity consumption is monitored on a daily basis at each hotel, and a range of resource-efficiency measures is in place across the hotels, including energy management and guest-awareness initiatives aimed at reducing electricity, water, and laundry demand.
Greenhouse Gas (GHG) Emissions. The Company's operational GHG emissions arise primarily from grid electricity consumption, fuel use by operational vehicles, and diesel combustion in the back-up generators. Each hotel maintains documented records of energy consumption, which provide the basis for subsequent GHG accounting. Upon project completion, total annual emissions across the five hotels are expected to remain below 25,000 tonnes of carbon dioxide equivalent (tCO2e) per year.
Water Consumption. Water supply for both construction and operational phases is provided through the municipal network. Potable water quality is monitored periodically, and swimming pool water quality is tested against applicable standards. As part of the strengthened ESMS, the Company will develop a consolidated water and wastewater management plan covering consumption monitoring, water-use optimization, and reduction of wastewater generation across the hotels (ESAP #1).
Hazardous Materials and Waste Management. Non-hazardous solid waste — primarily cardboard, paper, plastic, glass, and wooden packaging — is segregated at source and handed over to certified recyclers. Food waste is composted, either on site for landscaping purposes or off site through third-party providers. Used cooking oil (UCO) is collected and transferred to a certified third party for safe disposal and recycling under a dedicated operational procedure. Hazardous materials stored and used on site include chlorine and other pool chemicals, disinfectants and cleaning detergents for housekeeping, LPG, diesel, lubricants, and other specialty products. A dedicated bulk LPG storage facility is installed and equipped with a fire detection and suppression system. As part of the strengthened ESMS, the Company will develop: (i) a formal non-hazardous solid waste management procedure, including arrangements for sorting, storage, transfer, and disposal; and (ii) a Hazardous Materials Management Plan covering the safe storage and handling of hazardous substances, together with procedures for the regular inspection of LPG and diesel tanks. Both instruments will be aligned with Moroccan regulatory requirements, the PSs, and the WBG EHS Guidelines (ESAP #1).
Pesticide Usage and Management. Pest control activities across the hotels are carried out by licensed third-party contractors, with pesticide use managed under the Company's existing Pesticide Usage Manual and applied in controlled quantities. As part of the strengthened ESMS, the Company will formally integrate pest control procedures into the hotel-level management programs — including contractor oversight, record-keeping, and the selection of pesticides consistent with WHO hazard classifications — to ensure alignment with the PSs and the WBG EHS Guidelines (ESAP #1).
PS4: Community Health, Safety and Security
Food Safety. The Company has established food safety management practices across its hotels, supported by documented food safety procedures and regular internal and external food hygiene audits. These procedures define roles and responsibilities for food handling, supplier requirements, receiving and storage practices, and pest control, and are applied at hotel level, consistent with Moroccan regulatory requirements and broadly aligned with the PSs and the WBG EHS Guidelines.
Guest Safety. Guest safety is managed through site-level measures covering pool and water-based activities, including water quality controls, safety signage, and the presence of trained lifeguards at water parks. The appraisal identified the need to strengthen guest safety arrangements at private beaches — in particular by increasing the number of lifeguards. In addition, a formal mechanism for the handling of guest complaints presents gaps and dedicated procedures to be better formalized.. The Company will: (i) reinforce lifeguard coverage at private beaches under the hotel-level safety procedures; (ii) establish a formal procedure for the receipt, investigation, and resolution of guest complaints related to unethical conduct, harassment, and other human-rights concerns; and (iii) develop and implement a dedicated Child Safeguarding Procedure setting out measures to protect children staying at the hotels, including online safety controls and supervision arrangements for kids' clubs and family areas (ESAP #1).
Life and Fire Safety. The Company has established life and fire safety (LFS) arrangements across its operating hotels, including fire detection and alarm systems, portable fire-fighting equipment, emergency exits and staircases, and evacuation procedures, supported by periodic inspections and drills consistent with Moroccan regulatory requirements and good international industry practice (GIIP). A dedicated bulk LPG storage facility is installed and equipped with a fire detection and suppression system. Core LFS systems are generally in place, and all inspections of portable fire extinguishers were found to be up to date at the time of the appraisal.
Security Arrangements. Security is managed through a combination of on-site hotel security staff and licensed private security companies providing unarmed guards for outdoor areas, including hotel perimeters and private beaches. The appraisal identified the need to reinforce security coverage, particularly at private beaches and family-oriented resorts, by ensuring continuous staffing of entrances and exits and adequate guard presence for access control and risk management. The Company will develop and implement a site-specific Security Management Plan aligned with PS4 and the Voluntary Principles on Security and Human Rights (VPSHR), addressing security risk assessment, guard deployment, access control, use-of-force protocols, training, and incident response. Reinforced staffing arrangements at private beaches and family-oriented resorts will form part of this plan (ESAP #9).
