Bangladesh National Schools

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	25771
Country	Bangladesh
Sector	Education Services
Department	Health and Education
Company name	Scholastica Private Limited
Environmental category	B
Status	Pending Approval

Date ESRS disclosed	July 18, 2007

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

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The following potential environment, health and safety and social aspect of the project were analyzed:

- social and environmental assessment and environmental, social, and health and safety management systems;
- labor and working conditions;
- pollution prevention and abatement;
- community health, safety and security; and
- cultural heritage.

The review of this project consisted of appraising technical, environmental and social information submitted by the project sponsor including the business plan for the proposed development and rollout of schools, assessment of supplemental information submitted by the company on key environmental and social assessment issues; and meetings with the project’s management team to discuss IFC’s Performance Standards (PSs) and other requirements. Because many of the relevant details of the project (school designs, exact site locations, and specific construction contractors) are still at an early stage of development, IFC has requested additional information on each of the relevant issues, as described in the attached Environmental and Social Action Plan (ESAP).

Project description

The Scholastica Group (Scholastica or the company) is planning to construct four K-12 schools located in the three main cities of Bangladesh – Dhaka, Chittagong and Sylhet. Scholastica is a group of seven operational companies, where the premier company, Scholastica School, operates private K-12 schools with multiple campuses. With a student body of 5,800, Scholastica is the largest English-language school in Bangladesh. Scholastica was founded in 1977 in a small school house, and today occupies seven campus sites, employs 400 teachers, and has a total student population of 5800. To pursue the project, Scholastica will incorporate a new company to implement the project, own the schools and centrally manage operations. Scholastica Group companies and individual members of the Murshed family will contribute the initial equity to the Bangladesh National Schools Project (BNS project) and will maintain control of the company. Management expertise will come from Scholastica, particularly in the areas of education administration, human resources and finance. The schools will provide a combination of international and local curriculum, taught in English. At maturity, schools will have an average of 3,000 pupils. At full capacity, the four BNS schools will enroll more than 12,000 students and employ approximately 650 teachers.

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:

- PS1: Social and Environmental Assessment and Management Systems;
- PS2: Labor and Working Conditions;
- PS3: Pollution Prevention and Abatement;
- PS4: Community Health, Safety and Security;
- PS5: Land Acquisition and Involuntary Resettlement; and
- PS8: Cultural Heritage.

The project appraisal also assessed the applicability of PS6: Biodiversity Conservation and Sustainable Natural Resource Management, and PS7: Indigenous Peoples. Because all of the school sites will be located in heavily modified urban/peri-urban neighborhoods, no impacts on either biodiversity or indigenous peoples are anticipated to result from the project.

Environmental and social categorization and rationale

This project involves construction of several school facilities, using a limited number of standardized designs, on small (1-2 acres) sites in urban or peri-urban areas. Key issues associated with the project include:

- social and environmental management systems;
- liquid and solid waste management;
- water quality;
- labor and working conditions, employee occupational health and safety and community health and safety during construction; and
- life and fire safety.

The company has indicated that it will only select sites with no formal or informal residents or users of resources, and that all land for the project will be acquired on a willing buyer-willing seller basis. Moreover, the limited nature of the impacts indicates that mitigation measures can readily be designed to address the impacts identified, adverse impacts are not expected to be diverse or irreversible and will be limited to project site. For all of these reasons the project has been classified as a Category B.

Key environmental and social issues and mitigation

The sponsor has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. Further information is provided in the attached Environmental and Social Action Plan (ESAP).

- PS1: Social and Environmental Assessment and Management Systems

Scholastica has indicated that it will develop an environmental, social and health and safety (ESHS) management system and procedures to guide the operation of all BNS facilities that will ensure compliance with both IFC PSs, IFC guidelines, and relevant national and local government requirements. The ESHS system and procedures will ensure that BNS plans and implements its current and future building programs in accordance with the PSs, IFC guidelines and Bangladeshi requirements. Scholastica will obtain a Land Clearance for each site from the Ministry of Works. Before construction begins, Building Approval will be acquired from the relevant municipal authority. Prior to commencing operations, BNS will obtain all required utility (water, sewerage, electricity and gas) connection permits from the relevant municipal entities. The EHSH system and procedures will include a process for reviewing sites to ensure that no physical or economic displacement has occurred. Submission of a draft ESHS management system acceptable to IFC is included in the ESAP.

- PS2: Labor and Working Conditions

BNS’s Human Resources (HR) policy and procedures will be consistent with the comprehensive HR systems already in place in Scholastica. The company has reviewed IFC’s Performance Standards and indicated that its policy/procedures conform to the requirements of PS2. BNS will work with the same construction management company that Scholastica partners with on its projects, and which has a stringent approach to occupational health and safety (OHS) on site. BNS will ensure that environmental, health and safety (EHS) provisions and procedures at all sites are consistent with PS2, and that contractors’ performance is monitored to ensure that safe working conditions and procedures are maintained. Submission of standard contract provisions and written on-site procedures are included in the ESAP. Scholastica expects to utilize standard designs for all facilities developed under the project. None of the facilities proposed for the first phase of the development program will include boarding accommodations for students or staff.

Adequate provision will be made in the school designs for natural light and ventilation in each campus. A separate infirmary will be incorporated in the campus design which will have first aid facilities and a hospital bed. Each campus will have at least one member of staff with medical background, either a nurse or doctor, to cater to any medical emergencies situation in the school. All campuses will be cleaned and maintained on a regular basis to ensure a hygienic and safe free environment.

The Scholastica Group places strong emphasis on staff training and development, both on the job and through specialized courses and training programs. With the establishment of a training company in the Group, the provision of training programs and appropriate facilities has expanded considerably. The core areas of training are English language, teachers training, basic IT skills, and other professional development programs. A similar strategy will be implemented in the case of BNS employees in terms of regular training programs to develop their skills. As an organization, Scholastica also provides awareness training for staff on topics related to personal health and well being.

The company has reviewed IFC’s Life and Fire Safety guidelines and agreed to incorporate its requirements into the standard designs, and to provide IFC with copies of the detailed drawings for these designs. In accordance with the L&FS Guidelines, BNS will submit an L&FS Master Plan to IFC that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures as a condition in the investment agreements. The L&FS Master Plan will be prepared by a suitably qualified professional acceptable to IFC who will certify that the design meets the requirements of IFC’s guidelines. On the basis of the Master Plan, IFC will determine whether additional conditions in a Corrective Action Plan (CAP) are needed, and agree with the company on a mutually acceptable time frame for implementing these conditions. The qualified professional who prepares the L&FS Master Plan will also undertake a review at the time of L&FS systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design. Findings and recommendations of this review may also be incorporated into the CAP, as needed, along with a mutually acceptable time frame for implementation.

- PS3: Pollution Prevention and Abatement

As noted, Scholastica plans to utilize relatively standard designs for all of the facilities developed under the BNS project. The company will ensure that this design includes waste water pre-treatment facilities as required to ensure compliance with IFC and national/local requirements. Power for all BNS schools will be drawn from the grid, in conjunction with standby diesel generators in those locations where power supply is unreliable. Scholastica will provide written confirmation from diesel generator suppliers that air and noise emissions meet IFC and government requirements. Water will be obtained largely from municipal sources, although borewells will be drilled at each site for standby purposes. Water for drinking will be treated and routinely tested to ensure compliance with Government of Bangladesh and international potability standards.

- PS4: Community Health, Safety and Security

The school facilities developed by Scholastica under the BNS project are not expected to pose significant health, safety or security issues to nearby communities. To comply with insurance and other requirements, BNS will engage security personnel at each of the facilities. Security personnel will be on duty around the clock and will be given regular briefings on fire safety and handling of emergencies. BNS will ensure that each of the facilities is equipped with appropriate signage including contact details for a BNS employee who can respond to public queries at each school, which will be posted near the school entrance.

- PS5: Land Acquisition and Involuntary Resettlement

As noted, the school sites are expected to be small (1-2 acres) in size, located in urban or peri-urban areas, and acquired through a willing buyer-willing seller arrangement. The company has indicated that it will only select sites with no formal or informal residents or users of resources.

- PS8: Cultural Heritage

Scholastica will endeavor only to acquire sites for each of the schools developed under the BNS project that have no monuments, temples or other cultural property that would be covered under PS8. However, the company will include in all of its construction contracts a standard procedure for assessing cultural heritage ‘chance finds,’ developed in consultation with IFC, that may be identified during either construction or operation to ensure that any such finds are not disturbed until they have been assessed and documented by a competent specialist.

IFC PROJECTS