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| Tanmiya |
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| 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 | 28647 |
| Country |
| MENA Region |  |
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| Region | Middle East and North Africa |
| Sector | Colleges, Universities, and Professional Schools |
| Department | Reg Manufact, Agri & Services, EMENA |
| Company name | Al Tanmiya Holding KSC |
| Environmental category | B |
| Status | Hold |
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| Date ESRS disclosed | December 22, 2009 |
| Last Updated Date | February 8, 2012 |
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| View Summary of Proposed Investment (SPI), click here |
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| Overview | Category & Applicable Standards | Key Issues & Mitigation | Community Engagements | Client's Documentation |
| Overview of IFC's scope of review |
This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects. The review of this project consisted of appraising information provided by the sponsor related to technical, environmental and social issues as well as visits of S.O.S. Recruitment Consultants Company and training center of Qualitas Consulting and Training Company (QCT) in Kuwait, and the English Language & Training Centers of Jiaxing World Educational in Shanghai, China. Documents reviewed included the following:
EDU Draft HR Policy and Procedures
EDU Code of Ethics
QCT Disciplinary Code and Measures including warning notice & letter template,
QCT draft Emergency Management Plan |
| Project description |
Educational Holding Group (EDU) is an established, publicly listed education group in Kuwait operating in countries in the Gulf Cooperation Council (GCC) and Middle East and North Africa (MENA). EDU has investments across a wide spectrum of educational sectors ranging from nursery schools, elementary and high schools, colleges, training centers, universities and educational support services. Al Tanmiya Holding Company (the company), a wholly owned subsidiary, will focus on human capital development in the emerging markets. The company is in the process of acquiring the existing EDU companies in the GCC, India and China. Furthermore, it will also expand these businesses and acquire additional businesses in MENA and Asia. The company will focus on various business segments, including, but not limited to, corporate training & development, industrial vocational & language training, HR assessment, testing and consulting services, business process outsourcing, recruitment and related HR services. Al Tanmiya Holding will own 7 companies in the field of human capital development:
Universal Knowledge Solutions, United Arab Emirates (UAE): 100% owned company specialized in E-content development and E-Learning solutions.
S.O.S, Kuwait: 100% owned company specialized in executive search, recruitment, corporate training, HR outsourcing and support services.
QCT, Kuwait: 100% owned company specialized in training, education consulting, government and private projects.
Synergy Corporation, Kuwait: 29% owned company specialized in leadership, training, corporate development, consulting and market research.
Human Dimensions, Kuwait: 100% owned company specialized in HR assessment and consulting.
Prolific, India: 45% owned company specialized in industrial vocational training for retail and corporate and Turnkey automated solutions.
Jiaxing World Educational (JWET), China: 45% owned company specialized in English language training for retail and corporate. |
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| Identified applicable performance standards |
While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
While all Performance Standards (PSs) are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts that must be managed in a manner consistent with the following PSs:
PS1: Social and Environmental Assessment and Management Systems;
PS2: Labor and Working Conditions;
PS3: Pollution Prevention and Abatement; and
PS4: Community Health, Safety and Security.
The project appraisal also assessed the applicability of PS5: Land Acquisition and Involuntary Resettlement, PS 6: Biodiversity Conservation and Sustainable Natural Resource Management, PS 7: Indigenous Peoples, and PS 8: Cultural Heritage. In regard to PS5, no land is being acquired as Al Tanmiya’s current strategy is to lease/acquire established facilities on a “willing buyer-willing seller” basis, rather than to construct new facilities. With respect to PS 6, the project sites are usually located in heavily modified urban neighborhoods and no impact on biodiversity is therefore expected. Regarding PS 7 and PS 8, no indigenous peoples or cultural heritage resources are affected by development of the project. |
| Environmental and social categorization and rationale |
| No land is being acquired for this project as Al Tanmiya’s business model is to lease or acquire existing facilities. The nature of Al Tanmiya’s operations is such that adverse E&S impacts are minimal, limited largely to the site of each facility, and easily mitigated and managed. For these reasons the project has been classified as a Category B. |
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| Key environmental and social issues and mitigation |
The key environmental, social, health and safety associated with the project include implementation of environmental, health and safety management system; employment practices and working conditions; and occupational health and safety, including life and fire safety. The information about how these potential impacts will be addressed by the Sponsor is summarized in the paragraphs that follow.
PS1: Social and Environmental Assessment and Management Systems:
The Sponsor EDU recognizes the need to develop an environmental, health and safety (EHS) management system for Al Tanmiya, as well as facility guidelines and maintenance procedures, and incorporate these into a comprehensive social and environmental management system (SEMS) to guide the operation of its existing facilities and future acquisitions based on their assessment of the relative costs and benefits of implementing such an SEMS. The SEMS will ensure compliance to applicable host country(s) environmental and social regulations as well as IFC’s PSs and guidelines, and will be implemented at corporate level in accordance with a timeframe agreed with IFC. The SEMS will include a provision that future acquisitions are screened against IFC PSs, IFC guidelines and national requirements, and that corrective action plans are prepared and implemented for gaps identified. The SEMS will include a land acquisition procedure that complies with the requirements of PS5 to cover instances (if any) in which land is not acquired on a willing buyer-willing seller basis.
Because it is not a majority shareholder in any of the training centers it operates, EDU must obtain the endorsement of the other shareholders based on their assessment of the relative costs and benefits of implementing such an SEMS in Al Tanmiya, before the corporate SEMS can be implemented at specific facilities. As the largest shareholder in each of these facilities, however, Al Tanmiya can and will exercise all reasonable efforts to recommend to its shareholders that the SEMS be adopted.
Host country regulatory requirements for educational/training premises in the Kuwait do not require preparation of an environmental impact assessment, but do require compliance with building codes, including life and fire safety (L&FS) codes prior to receiving an operational license. Existing facilities of QCT and SOS in Kuwait have complied with all national L&FS requirements. QCT has developed a draft emergency response plan that will be used by Al Tanmiya as the basis to develop corporate guidelines for emergency management plan, including fire, hazard, assault, violence and personal injury, and will recommend to its shareholders that this corporate plan be adopted at each of Al Tanmiya’s training facilities, in accordance with a timeline agreed with IFC..
EDU has reviewed IFC’s guidelines related to Life & Fire Safety (L&FS) for Al Tanmiya, including the requirement to develop an L&FS Master Plan that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures. EDU recognizes that the L&FS Master Plan for Al Tanmiya is to be prepared by a suitably qualified professional acceptable to IFC who certifies that the design meets the requirements of IFC’s Life and Fire Safety guidelines. EDU understands that, on the basis of the Master Plan’s findings and recommendations, IFC may determine whether additional conditions to the attached Environmental and Social Action Plan (ESAP) are needed, and agree with the company on a mutually acceptable time frame for implementing these conditions. EDU further understands that the qualified professional who prepares the L&FS Master Plan also would be expected to undertake a review of L&FS systems testing and commissioning of existing facilities and new acquisitions and certify that construction of these systems has been carried out in accordance with the accepted design; and that findings and recommendations of this review may be incorporated into the ESAP, as needed, along with a mutually acceptable time frame for implementation.
As above, because it is not a majority shareholder in any of the facilities it operates, EDU must obtain the endorsement of the other shareholders, based on their assessment of the relative costs and benefits of implementing such an SEMS in Al Tanmiya, before the L&FS Master Plan can be undertaken at specific facilities. As the largest shareholder in each of these facilities, however, Al Tanmiya can and will exercise all reasonable efforts to recommend to its shareholders that the SEMS be adopted.
PS 2: Labor and Working Conditions:
At present, full time staff is about 40 in SOS, 95 in QCT, and 300 in JWET. In addition to about 70 free lance consultants that work with QCT. Total staff in Al Tanmiya Holding is 0 . Staff Manuals and general HR policies are present at the facility level. All newly-hired employees will undergo a probation period of 100 days as per Kuwait Law . Employee benefits will include governmental medical insurance in Kuwait.
SOS, QCT and JWET have confirmed that it complies with all host country labor laws in the countries in which they operate. Once the capital is raised EDU will recommend adoption of an HR system for Al Tanmiya to its shareholders. EDU will recommend the system to include an HR Manual, policies and procedures, including grievance mechanism, that conform fully to all PS2 requirements including forced labor forms as well as host country labor law and regulations.
JWET employees are direct employees, including its expatriate English teachers hired through labor intermediaries. JWET confirms strict adherence to China’s Labor Contract Law in its labor practices. Working conditions appear reasonable at the JWET training center in Wuxi, Jiangsu Province.
PS 3: Pollution Prevention and Abatement:
Al Tanmiya’s strategy is to acquire developed facilities in urban areas where infrastructure facilities of water supply, wastewater collection and power are supplied by relevant municipalities.
PS 4: Community Health, Safety and Security:
As noted above, EDU will recommend to Al Tanmiya shareholders to submit a life and fire safety Master Plan to IFC for its existing facilities. EDU will also recommend to Al Tanmiya’s shareholders to put in place a disaster response plan for earthquakes, fires and other large scale emergency situations. |
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| Client's community engagement |
| Al Tanmiya regularly provides charity donations (zakat), a practice that is mandatory for KSC closed companies by law. |
| Local access of project documentation |
Translated versions of the ESRS and ESAP will be available at:
Mr. Eugene Koshi
Al Tanmiya Holding Company
Hamad Towers, Tower B
Qebla Area
Kuwait
Tel : +965 22974847
Fax: +965 22974849 |
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| Availability of Full Documentation |
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| Information Disclosed |
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