Mauricio Nassau

Environmental & Social Review Summary

This Environmental and Social Review Summary is prepared and distributed in advance of the IFC Board of Directors’ consideration of the proposed transaction. Its purpose is to enhance the transparency of IFC’s activities, and this document should not be construed as presuming the outcome of the Board of Director’s decision. Board dates are estimates only.
Any documentation which is attached to this Environmental and Social Review Summary has been prepared by the project sponsor and authorization has been given for public release. IFC has reviewed this documentation and considers that it is of adequate quality to be released to the public but does not endorse the content.

Project number

28755

Country

Brazil

(IDA)

Region

Latin America and the Caribbean

Sector

Colleges, Universities, and Professional Schools

Department

Reg Manufact, Agri & Services, CAF/CLA

Company name

Ensino Superior Bureau Juridico S.A

Environmental category

Status

Pending Disbursement

Date ESRS disclosed	March 25, 2010
Last Updated Date	February 8, 2012
Previous Events	Signed: June 18, 2010 Approved: May 19, 2010

View Summary of Proposed Investment (SPI), click here

Overview

Category & Applicable Standards

Key Issues & Mitigation

Community Engagements

Client's Documentation

Overview of IFC's scope of review

IFC’s appraisal of the project included visits to the main campus of Mauricio de Nassau in Recife, Pernambuco; and the Fac Joaquim Nabuco in Paulista, Pernambuco. The visit included Blocks A, B, C, D and Campus Paulista; administrative buildings; the Clinica Escola de Fisioterapia; and Escritorio Juridico. The appraisal included buildings in construction such as the new central library. IFC interviewed the human resources manager, the administrative manager, the civil engineer chief and the health and safety engineer within other Mauricio de Nassau’s staff. Environmental and social conditions of the operations were assessed through documentation review, interviews, and information submitted by Mauricio de Nassau.

Project description

Founded in Recife, Brazil, Ensino Superior Bureau Juridico S.A. (“ESBJ” or the “Company”) is a for-profit higher education company providing undergraduate, graduate and technical education to students in the North East region of Brazil. The Company targets primarily middle and low income students under two brand names Mauricio de Nassau and Joaquim Nabuco. ESBJ currently runs nine campuses in five North Eastern states and provides educational services to 25,000 undergraduate students. ESBJ requested IFC to help fund construction and upgrade of six new campuses. The proposed project aims to double the number of student enrolments to 50,000 in 2014.

Key environmental and social issues and mitigation

This project will comply with local and IFC’s environmental and social requirements upon implementation of the specific agreed measures. The information about how these potential impacts will be addressed by Mauricio de Nassau is summarized in the paragraphs that follow and in the attached Environmental and Social Action Plan (ESAP).
Social and Environmental Assessment and Management System
-Social and Environmental Assessment: Mauricio de Nassau operates in owned and leased facilities located in urban areas. The company customarily only renovates owned facilities. The majority of the buildings are leased; however, due to infrastructure needs the company constructs some of the buildings. The construction of new buildings and renovations are designed and managed internally by Mauricio de Nassau through its civil engineering department. The company has a well defined planning process to design and construct new facilities. Previous to the development of a new building Mauricio de Nassau obtains the construction license according to the local regulations, which includes the city permit, firefighter’s certification and environmental permits when applicable. According to local legislation Mauricio de Nassau does not require Environmental Impact Assessment for the new developments. During the planning process the Company also considers technical and environmental specifications, such as, seismic conditions, life and fire safety and proper distribution of areas.

The company manages its operations considering efficient use of resources and compliance with local requirements. Internal and external audits are performed; although its focus is mainly on quality aspects, infrastructure is also assessed. Mauricio de Nassau will include environmental, Occupational Health and Safety (OHS), and fire safety aspects in the planning process. In particular, Mauricio Nassau will screen future sites to be leased or acquired. The screening will aim at a timely identification and review of the potential risks particularly in terms of (i) land acquisition to ensure that involuntary displacement is avoided or minimized, (ii) cultural heritage to ensure it will be managed according to Brazilian requirements, and (iii) life and fire safety and structural conditions so that they can be addressed properly according to local and IFC requirements.

-Social and Environmental Management Program: Mauricio de Nassau has a quality assurance department overseeing the operations, which has developed some environmental initiatives throughout the campuses, including for example, identification of environmental impacts; segregation of solid waste in some buildings, and training of internal quality and environmental auditors. Mauricio de Nassau has implemented internal procedures during the design, construction and operation of the facilities aimed to control basic social and environmental impacts. The company will review its current management system to incorporate applicable environmental, Occupational health and Safety (OHS), and fire safety aspects. New elements to be covered include but are not limited to (i) screening and assessment of new facilities; (ii) efficient use of resources such as energy and water; (iii) solid waste management; (iv) OHS in construction sites, including contractors; (v) life and fire safety; and (vi) lab safety. All the campuses to be included.

-Organizational Capacity: Responsibilities for social and environmental aspects are shared among several positions throughout the company. For the development of new buildings the civil engineering chief ensures compliance with technical requirements including life and fire safety provisions of buildings. During the operative stage the administrative manager ensures proper maintenance, housekeeping and efficient use of resources. The company recently hired an OHS engineer who will ensure local compliance through proper application and operation of fire safety procedures, including emergency response plans. In addition there is a Human Resources Manager who coordinates all the HR programs at corporate level and HR coordinators in all the campuses. Environmental and Social responsibilities are shared with the local coordinator at each campus.

-Training: Training is provided to all the employees. There is an initial institutional training (induction) for all new employees and thereafter training is provided based on specific needs and skills required for the job. Regarding environmental and social aspects the company has provided training on accident prevention, use of Personal Protective Equipment (PPE), first aid, and emergency response. The company is developing a training plan and will include environmental protection and other relevant OHS elements.

-Monitoring and Reporting: Mauricio de Nassau monitors basic environmental and social aspects of the operations such as water consumption, potable water parameters, OHS events, and extinguisher inspections. The company, through the review of its management system, will enhance its monitoring and reporting system to define periodicity of monitoring and collection of data on the relevant parameters.

Labor and working conditions
-Human Resource Policy and Management: Mauricio de Nassau has 2461 employees, of which approximately 45% are female. The workforce is concentrated in the company’s headquarters in Recife. Mauricio de Nassau has recently reinforced its human resources team, which is headed by a HR manager. The company has an ethics code applicable to all the employees, which includes statements regarding non-discrimination, equal opportunities and protection of the workforce. In addition the Human Resources department has documented procedures including, hiring, selection, disciplinary measures, transfer of employees, payment of benefits, among others. The company will create and implement a formal internal grievance mechanism for the employees to raise reasonable concerns, consistent with IFC’s Performance Standard 2. The grievance mechanism will be communicated to all the employees and for new employees it will be made available at the time of hire.

-Terms of Employment and Workers Organizations: Conditions of employment are defined in the contracts Mauricio de Nassau signs with the employees and in the list of benefits, both of which are communicated to the employees during induction. Mauricio de Nassau has signed collective agreements with labor unions for teachers and administrative employees in the campuses of Campina Grande, Salvador, Joao Pessoa and Maceio. Collective agreements further define the benefits and conditions of employment. For the other campuses the management team of Mauricio de Nassau expressed that there has not been requests among the employees to have additional collective agreements and indicated that they would not prevent employees from organizing or participating in workers organizations.

Benefits provided to the employees include those entitled by law, in addition to grants for education in the courses offered by Mauricio de Nassau. The company facilitates the access to health care plan, dental services, pharmacy discounts and transportation subsidies. Benefits are communicated to the employees during induction.

-Non discrimination and equal opportunity: Mauricio de Nassau has well defined statements regarding non discrimination and equal opportunity. Fair treatment is observed in the company, including processes of hiring, promotion and termination of employment. Mauricio de Nassau has a well defined selection process, an annual performance assessment and leadership programs to promote personnel with defined skills.

-Protection of the Workforce: Mauricio de Nassau complies with local regulations regarding HR, all the employees are paid at least the legal minimum salary. No employees under18 years are contracted and no child labor or forced labor is allowed by the company.

-Retrenchment: The Company’s workforce has increased significantly over the last years and although it fluctuates based on the courses offered per academic cycle, it is expected to keep growing. Retrenchment is not expected from this project. If Mauricio de Nassau becomes responsible for retrenchment activities it will conduct them in a manner which complies with IFC requirements including development of retrenchment plans which are based on the principle of non-discrimination, reflecting consultation with employees, their organizations and, where appropriate, the government.

-Occupational Health and Safety: Mauricio de Nassau trains the employees and provides Personal Protective Equipment (PPE) for those employees working in the laboratories. The company has implemented procedures to manage the legally required programs such as the occupational medical monitoring program (PCMSO) and the internal committees for accident prevention (CIPA). The company recently hired an OHS engineer who is expected to reinforce OHS practices, develop safety procedures, and assess building safety and fire protection. As part of the review of the current management system the company will identify the main risks of the operations, including activities of the students and will define programs to control and monitor such risks. Such programs will include but not be limited to: lab safety, ergonomics, construction safety, and emergency response.

Mauricio de Nassau handles small amounts of chemicals and biological material for practical training of the students. Use of such products is limited to students’ practices, held few times during the academic period. The company provides PPE and training to the employees. Mauricio de Nassau will implement a Lab safety program. The program should include, but not be limited to: (i) handling of chemicals and biological materials; (ii) communication of hazards including Material Safety Data Sheets (MSDSs); (iii) maintenance of hoods and ventilation systems; and (iv) reduction of residuals and proper disposal of wastes.

Pollution Prevention and Abatement
-Resource Conservation and Energy Efficiency: Mauricio de Nassau has a strong orientation to optimize the use of the resources including electricity and water. Halls in most of the buildings are equiped with movement sensors to reduce the use of electricity; in addition, classrooms maintain the lights off when vacant. When feasible the design of new buildings has incorporated the use of natural lighting to reduce the use of electricity. The company will continue to identify opportunities to conserve resources in its operations.

- Solid Waste Management: Waste generated in the campuses include mainly domestic type of waste, office waste and small amounts of hazardous waste from the labs. Mauricio de Nassau has initiated in some of the buildings separation and recycling of waste. Adequate segregation was observed on the sites where containers were provided. The company will expand the recycling program to all the campuses and will identify mechanisms to reduce the amount of waste generated, as well as reuse, recycle and dispose properly the waste. The program should include hazardous waste generated throughout the facilities, including those from the labs. The company contracts the collection and disposal of waste with the municipality and with authorized companies.

-Hazardous Materials: The use of hazardous materials is restricted to the laboratories where small amounts of reactants, solvents, preservation agents and biological agars among other products are used. Mauricio de Nassau will include in the lab safety program or solid waste management program (to be implemented) provisions for handling, storage and disposal of hazardous materials.

Air conditioning uses refrigerant R-22, a hydrochlorofluorocarbon with low ozone depletion potential (ODP), the estimated annual use is approximately 600 pounds per year, mainly due to maintenance proposes. The company operates the conditioning systems following local requirements.

-Liquid effluents: Liquid effluents, mainly domestic effluents, are in most cases discharged to the municipal sewage systems; however, for some buildings Mauricio de Nassau has its own septic tanks and infiltration systems. Mauricio de Nassau follows local guidelines for the design and operation of the septic tanks. The Pernambuco’s environmental agency (CPHR-Agencia estadual de meio ambiente e recursos hidricos) has granted the respective operation licenses to the company. Mauricio de Nassau complies with the conditions defined in the licenses, including the collection of the sludge by authorized companies.

-Greenhouse Gas Emissions: Greenhouse emissions of the project are associated mainly with electricity consumption, but also with the use of fuels for daily operations such as vehicles and in emergency generators. The Greenhouse emissions of the current operations do not exceed 100,000 tons of CO2.

Community health, safety and security
-Life and Fire Safety: Mauricio de Nassau follows local building safety requirements during the construction and operation of its facilities. The buildings have the required firefighter’s licenses. The buildings located in Pernambuco have been assessed by the local authorities (secretaria de defensa social, corpo de bombeiros militar de Pernambuco) and have approved their inspection. In addition the company has specialized personnel to verify compliance with local regulation regarding Life and Fire Safety during the construction and the design phase.

New buildings or those currently scheduled for construction or renovation will be designed, constructed and operated in full compliance with the local life safety code and an internationally accepted life and fire safety (L&FS) standard. The design shall include assessment of fire prevention; means of egress; detection and alarm system; compartmentation; fire suppression and control; emergency response plans; and operation and maintenance as described in the IFC’s Environmental, Health and Safety General Guidelines. with the Life and Fire Safety requirements of the IFC General EHS Guideline.
A qualified fire protection engineer, acceptable to IFC, will prepare/review the Master Plans (engineering design) and will perform post construction inspections to verify that the system was installed as designed.

Where required, in the existing facilities, the company will enhance life and fire safety (L&FS) elements such as detection mechanisms, alarm systems, fire suppression systems, and emergency signage.

-Emergency Preparedness and Response: Mauricio de Nassau has provided basic training on first aid and emergency response; however, a detailed emergency response plan will be developed by the company to cover all the facilities. Mauricio de Nassau will perform and document annual fire drills and fire safety inspections as required by local law.

-Potable water: The company obtains potable water from various sources which include on site wells, private providers, and the municipality. Mauricio de Nassau has verified local compliance of the quality of the water supplied to the facilities from the wells and private companies. Cafeteria services are provided by third parties in the facilities of the company; Maurico de Nassau performs an initial assessment of the capacity of such vendors.

-Security Personnel: Mauricio de Nassau has security guards contracted directly by the company, such guards are not armed and have received training on crisis management.

Land Acquisition and Involuntary Resettlement
Mauricio de Nassau leases most of the facilities; however the company owns some buildings. Due to the growth of the campuses the company is planning to retain both modalities lease and ownership. The company only buys land in willing to buy- willing to sell transactions. Involuntary resettlement is not expected from the project. Mauricio de Nassau will avoid, minimize and mitigate any adverse effect on the community due to land acquisition or lease of new buildings. As part of the initial screening of future sites to be leased or acquired, the company will evaluate the land acquisition process, and the potential for involuntary resettlement, if any.

Cultural Heritage
Mauricio de Nassau follows local requirements regarding protection of cultural heritage. When applicable the company has modified buildings and has retained facades or structural parts as required by local legislation.

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