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COMPAGNIE HOTELIERE DE LA LAGUNE S.A.
Environmental & Social Review Summary
This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC’s activities. For any project documentation or data included or attached herein that has been prepared by the project sponsor, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein. It is distributed in advance of IFC Board of Directors’ consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision.
U-AA - City and Business Hotel
COMPAGNIE HOTELIERE DE LA LAGUNE SA
Date ESRS disclosed
March 27, 2012
Last Updated Date
April 22, 2013
Invested: March 20, 2015
Signed: March 28, 2013
Approved: December 4, 2012
View Summary of Proposed Investment (SPI),
Category & Applicable Standards
Key Issues& Mitigation
Overview of IFC's scope of review
As the Abidjan asset is not yet developed and it’s at an Environmental Impact Assessment stage, IFC’s review included the Azalai Group’s other assets to get a better context and sense of the management system in place in existing hotels. The review included:
Review of the Company’s existing Environmental and Social (E&S) management system and its implementation at the hotel level following onsite visits in Mali, Burkina Faso, Guinée Bissau, the new hotel construction site in Benin, and the site in Côte d’Ivoire. The hotels in Burkina Faso, Guinée Bissau and Benin are not part of this investment; they were appraised as part of the assessment of the Company’s E&S risk management practices. Supervision information of existing investments was also reviewed.
Technical Manager at each hotel operated by the Company with regards to E&S management at hotel level and relationship at the Group level. The interview focused on life and fire safety aspect; occupational health and safety training; food safety; hazardous material storage and handling; solid and liquid waste handling, storage, treatment and disposal, pest management, potable water sources and treatment measures; pool maintenance procedures; energy efficiency measures; monitoring and reporting; and housekeeping.
Construction site Supervisor: the interview focused on fire and life safety measures; electrical installations; liquid and solid waste management measures; construction site safety; onsite labor and working conditions; and land acquisition process.
Human Resource Supervisor: interview focused on labor and working conditions at the hotel level particularly human resource policy; hiring process; compensation and benefits; code of conduct; performance evaluation system; and grievance mechanism.
Workers’ Representatives: the interview focused on labor and working conditions (similar to interview with HR Supervisor); type of grievances as well as the effectiveness of the grievance mechanism in place.
Health and Safety Committee (HSC): interview focus on understanding of their role and verifying their awareness of the regulatory requirements of a HSC.
Onsite Nurse: the interview focused on understanding their role; the most common type of illnesses/incident reported by staff and action undertaken by the Company to resolve root cause; health awareness campaigns undertaken; adequacy of the infirmary and pharmacy; and incident reporting framework.
Head Chef: the interview focused on kitchen and food safety management including food procurement process and pest management.
The proposed Project consists of a loan to the Azalai Abidjan (“the Company”) a subsidiary of Azalai Group for the construction and operation of a new hotel in Côte d’Ivoire. IFC has a current investment with Azalai Group. For more information on financial structure of the investment please refer to the SII.
Identified applicable performance standards
PS 5: Land Acquisition and Involuntary Resettlement is not relevant to this investment as the site has been acquired on a willing seller willing buyer basis. There were two legal tenants with economic activities on the site who have been given sufficient notice of non lease renewal..
PS 6: Biodiversity Conservation and Sustainable Natural Resource Management does not apply as the hotel is located on a main street in an urban area which is ecologically degraded.
There are no communities in the areas of the Project, who would be considered as “Indigenous” under the definition used by IFC, and therefore PS 7 - Indigenous Peoples does not apply.
PS 8 Cultural Heritage is not applicable as all the hotel will be constructed on a site with existing structure. However, in order to adhere to good international practices, the Company will require that the construction contractor have in place in its Environmental and Social Management Systems (ESMS) a chance finds protocol specifying what procedures will be undertaken should archeological finds be encountered.
Environmental and social categorization and rationale
This is a category B investment according to IFC’s Procedure for Environmental and Social Review because the potential adverse social and environmental impacts of the proposed investment are limited, site-specific and reversible and may be mitigated by adhering to the IFC Performance Standards, generally recognized guidelines or design criteria.
Key environmental and social issues and mitigation
Key E&S issues associated with this investment are corporate environmental and social management capacity; management of environmental impacts (i.e. air emissions, spills, noise), and occupational health and safety during construction; labor and working conditions; food safety; fire and life safety, efficient use of energy and water resources; solid and liquid waste management; and permitting and licensing of the site.
During the appraisal, the Company presented information on its policies and practices that seek to address environmental and social risks and impacts associated with hotel operations and construction activities. The Company will adopt existing practices and procedures of Azalai group and wil supplemented them with specific additional agreed measures to ensure compliance with host country laws and regulations and the IFC Performance Standards on Social and Environment Sustainability dated January 2012. These additional actions to be undertaken by the Azalai Abidjan are listed in the attached Environmental and Social Action Plan (“ESAP”). The findings of IFC’s review and conclusions are summarized in the paragraphs below.
PS1 Assessment and Management of Environmental and Social Risks and Impacts
IFC’s review considered the Company’s current identification, assessment and management of E&S risks and impacts, as well the procedure for land acquisition.
Identification of Risks and Impacts
The Company hires a local consultant to identify the legal requirements and fulfill the necessary licenses’ requirements to obtain the applicable licenses. An Environmental Impact Assessment (EIA) is required by the local authorities and as such the Company commissioned a study and is in the process of following the legal procedures to obtain the required authorizations and permits prior to construction.
Management Programs and Organizational Capacity
As previously indicated, the Company is at an early stage of development and as such it has not yet developed its management program or organizational capacity. However, based on the Azalai Group’s model, the Company will have an EHS officer who will also be responsible for maintenance. Azalai Abidjan will develop its management programs based on Azalai Group’s (such as waste management, effluent treatment, pool treatment, food safety, fire and life safety) but also strengthen its management system with the additional actions required in the ESAP.
The EHS officer will develop an Environmental and Social Management System (ESMS) that will include an Environmental and Social Policy, the organizational chart and role and responsibilities of the EHS officer. The key E&S issues to be addressed by the management programs including: (i) local EHS regulations, (ii) fire and life safety and emergency preparedness and response; (ii) energy and water efficiency (iii) labor and working conditions; (iv) occupational health and safety and training during construction and operation; (v) food hygiene procedures; (vi) environmental management such as solid and liquid waste management during construction and operation; (vii) equipment maintenance (such as generators, boilers) and housekeeping;(viii) stakeholder engagement; (x) environmental performance monitoring.
Training on fire and life safety, and occupational health and safety will take place prior to the hotel opening. The ESMS will include training strategy and programs to ensure that staff is well trained in first aid and first response, occupational health and safety, and job related aspects.
Monitoring and Reporting
The Company will define data monitoring and reporting requirements consistent with the objectives of the ESMS. As part of this investment, IFC will develop with the Company an environmental and social reporting framework – Annual Monitoring Report (AMR). Such report will be reported and reviewed internally by the management team.
PS2 Labor and Working Conditions
IFC’s review considered the Azalai Group’s procedures and practices with regard to fair, safe and healthy working conditions in its operations.
Human Resources (HR) Policy
Azalai Group has currently two parallel initiatives: it is in the process of recruiting a HR Manager at a corporate level to harmonize practices across all the hotels; and it has also recruited a firm to undertake an HR audit and develop proposals for standardizing HR practices including compensation and benefits. The current structure of the group includes a HR officer at each hotel who reports to the hotel Director. Each hotel has a code of conduct, employees’ contracts, and compensation and benefits which are more competitive than the “Convention Collective de l’Industrie Hotelière” (the national union, industry, and governmental agreement on labor, compensation and working conditions) and above minimum wage. All workers are declared to the National Social Security System and benefit from medical insurance, and a pension. Azalai Abidjan will adopt the HR practices of the group but adapt it to local laws and in compliance with this Performance Standard. As part of this investment the Company will develop and implement an HR policy, procedures and handbook which will integrate the code of conduct, compensation and benefits, performance evaluation system and grievance mechanism. Azalai Abidjan similar to the Group, will provide additional benefits to its employees such as transportation allowance; food during working hours; allowances for funeral and birth of a child.
Non-Discrimination, Equal Opportunities and Protection of the Workforce
The Company will apply the principles of Non-Discrimination and Equal Opportunity as encouraged by Azalai Group. As per national labor laws the Company does not plan to hire employees under the ages of 18 and as such the Project is not anticipated to have any child labor issues. Prior to being hired candidates will have to provide a medical certificate, a birth certificate, a certificate of nationality (or similar identification), and a copy of his/her judicial standing. Furthermore the Company does not employ forced labor or trafficked people.
The Company will use commercially reasonable efforts to contractually stipulate that its suppliers and the construction firms (for the construction phase) comply with national labor laws, pay employees at a minimum the legal requirements, provide necessary personal protective equipment to carry out work in a safe manner and in the case of construction firms, additionally report on onsite health and safety incidents and corrective measures. The Company will include in its ESMS a procedure to audit contractors and suppliers with respect to the above mentioned matters.
The Company will have a salary grid which is internally accessible as well as a performance evaluation system to increase transparency in compensation and promotion. The Company will make explicit non-discrimination reference in its HR policy.
Freedom of Association and Grievance Mechanism
The Company will enable staff to elect workers representatives to serve as a formal liaison between management and staff. Staff will be free to join unions. The workers’ representatives will also liaise with the national labor union. The Company will establish a well functioning grievance mechanism in collaboration with workers’ representatives.
Occupational Health and Safety
Azalai Group hotels have modern kitchens for preparing food for guests as well as a semi open-air kitchen for preparing staff food; laundry rooms; and an onsite nurse to administer first aid, conduct basic medical checks, and records incidents. A similar set up is expected for Azalai Abidjan. .
As per legal requirements in Cote d’ Ivoire, any institution with staff of 50 people and over must have in place a health and safety committee. Azalai Abidjan is expected to have over 50 staff and as such will put in place a health and safety committee with legally defined terms of reference which include management of employees health and safety matters, quarterly meetings and meeting minutes.
Occupational Health and Safety (OHS) issues during construction will be supervised by an assigned Project Manager who will ensure that the contracted company complies with technical, administrative, and health and safety requirements. The Company will implement an OHS Management System to ensure social risks during construction and operation of the hotel are identified, monitored and controlled.
PS 3 Resource Efficiency and Pollution Prevention
IFC’s review considered the Azalai Group ‘management of key pollution prevention issues of concern such as air quality, solid waste management, effluent management, drainage system, pest management, as well as energy and resource conservation opportunities.
Air quality issues during the construction phase such as fugitive dust from site excavation and vehicular moments will be managed through dust suppression techniques, and complemented by personal protective equipment such as dust masks if necessary. Furthermore, smoke from equipments and trucks will also be mitigated through construction firm’s environmental, health and safety management plan.
During operation, the key sources of air emission will mainly be from boilers used to provide hot water and from the electricity generators used as backup. The hotels boilers and generators are likely to be considered as small combustion facilities and will be below the size threshold of 3MW thermal power input at which IFC requires emission monitoring. Green house gas emissions are expected to produce less than 8,000 tonnes of CO2 equivalent annually
The Azalai Group is already engaged in several energy efficiency initiatives in its hotels albeit the practices are not standardized. The initiatives include solar panel for heating water, room keys cards to shut off most electrical equipment in unoccupied rooms, energy saving lights, and raising awareness on water consumption by giving the option to guests to reuse towels. Azalai Abidjan being a new construction is expected to benefit from all existing practices on energy efficient and even consider options for water saving such as reuse of treated water for irrigation purposes which is common practice in hotels worldwide, and installing a controlled or automated sprinkler system instead of using open flow hoses.
Solid waste management practices will include segregation of plastic and glass bottles. Domestic waste will be put into garbage bags and stored in an air conditioned space. An authorized contractor will collect and dispose of waste in a municipal landfill. Used oil and grease from the kitchen operation will be collected via the drainage system into a holding tank which will be emptied by a third party contractor at scheduled intervals and recycled. As part of its ESMS, the Company will implement a comprehensive solid waste management program which will focus on reduction of waste generated and will aim to segregate, reuse and recycle the generated waste as well as ensure adequate storage and disposal practices. Local context and market for the products will be considered in the strategy.
Significant volumes of hazardous wastes are not to be expected from the project, some small quantities of oil might be generated from maintenance and sold for recycling purposes.
The Company will probably have some diesel onsite to fuel the generators, above ground storage tanks are recommended. The Company will include in its ESMS procedure for storage and handling of fuel.
The hotel is located in an urban area however should the municipality not have a sewage treatment facility, the Company will include in the hotel design a wastewater treatment plant. The Company will separate storm water from sanitary water in. Waste water from the kitchen should be designed to go through an oil and water separator before being discharged into the treatment system. Wastewater analysis data for the hotel will be conducted and reported in the Annual Monitoring Report.
Pesticides will be applied by a licensed third party contractor on a monthly basis and will be used in limited quantities. The Company will ensure that no class 1A or 1B pesticides are used in their operation. A procedure on pest control management should be included in the ESMS.
PS 4 Community Health, Safety and Security
IFC’s review considered The Azalai Group’s management of risks as a facility receiving public. In particular fire and life Safety, emergency preparedness and response, and food safety.
Community Health and Safety
Fire and Life Safety
A professional fire safety engineer will be retained to prepare a life and fire safety “master plan” which when implemented will cause the hotel design and operation to be compliant with an internationally recognized fire safety code. The professional shall also undertake an audit when the construction is partially completed and another at completion to identify any non compliances with the master plan, and hence with the internationally recognized fire and life safety code
Food and Water Safety
As part of the Company’s ESMS international Food and water safety standards will be adopted. Potable water will be monitored for basic parameters such as pH and hardness and the Company will implement a periodic and systematic monitoring system to ensure appropriate water quality. Furthermore, the hot water system which is a common source of Legionellosis will also be included in the monitoring program; and preventive measures such as ensuring its storage at temperature above 60 ºC will be implemented. With regards to food safety, the hotels in will follow an Hazard Analysis Critical Control Point (HACCP) based system and designed the kitchen accordingly.
The pool will be treated with algaecides and chlorine and monitored for pH and chlorine on a daily basis. A log of the testing result will be maintained. The pool maintenance procedure will be included in the ESMS.
Emergency Preparedness and Response
The Company will develop an emergency preparedness and response system as part of its ESMS which includes an evacuation plan. Muster points will be identified and clearly mark. Fire wardens shall be appointed in sufficient number to ensure adequate coverage; and they will be trained in first aid, and first response. Fire drills will be undertaken at least twice a year and involving the local fire department and hotel guests.
Security Forces and Community Safety
The Company will use the services of a credible third private security force to guard its premises will include in its ESMS a mechanism for reporting credible allegations of unlawful or abusive acts to police authorities.
Client's community engagement
IFC’s review considered the various hotels (under this investment) settings and their potential impacts to communities.
Based on the findings of this appraisal, this investment does not have physical elements, aspects, and facilities that are likely to generate ongoing risks to or adverse impacts on Affected Communities. Nevertheless, the Corporate ESMS will include stakeholder engagement with respect to future land acquisitions. Stakeholder engagement process on existing as well as future assets will be documented and community grievance channel established
Local access of project documentation
This ESRS is locally available at the following location:Azalai Group Hotels
Cocody Bd Latrille Cite Montbenon
The contact person: Mr. Luc Kiobin
Tel: 225 22 44 60 50
IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.
In addition, Affected Communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC. The CAO is mandated to address complaints from people affected by IFC-supported business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of IFC.
Independent of IFC management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of IFC’s environmental and social performance through its compliance arm.
Complaints may relate to any aspect of IFC-supported business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC-financed business activity. Complaints can be submitted to the CAO in writing to the address below:
Compliance Advisor Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
The CAO receives and addresses complaints in accordance with the criteria set out in its Operational Guidelines which are available at: www.cao-ombudsman.org
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