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Bogota COVID-19 Pillar 1

$381 million
Financial Services
Environmental and Social Review Summary

Environmental and Social Review Summary

Bogota COVID-19 Pillar 1

This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.

Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.

MIGA has been requested to provide a guarantee covering non-honoring of sub-sovereign financial obligations on a seven-year loan from Banco Bilbao Vizcaya Argentaria, S.A. of Spain (BBVA Spain) to Bogotá Distrito Capital (Bogota), the capital and largest city of Colombia, to help finance emergency response measures to the COVID-19 pandemic and to strengthen the quality of healthcare services in the city by upgrading and expanding existing healthcare facilities (these uses, together, are the Project). The loan proceeds may be used to finance both future expenditures and to reimbursements of Project-related expenses. The implementing entity for the Project is the Secretaria Distrital de Salud (SDS), either directly or through its four subsidiary regional subnetworks. The SDS has allocated debt financing for individual sub-projects related to both emergency response measures and upgrading existing facilities. The Project is part of MIGA’s response package for the COVID-19 crisis and additional details can be found in the Summary of Proposed Guarantee (SPG.)

The COVID-19 pandemic has had a profound impact in Colombia. The country, with a population of just over 50 million people, has had over 2.6 million cases and over 67,000 deaths as of mid-April 2021, placing it in the top-15 globally for both case counts and deaths. On March 17th, 2020, Bogota declared a state of emergency as a result of the COVID-19 pandemic and thereafter began a city-wide lockdown on March 25th, 2020, maintaining varying levels of lockdowns and restrictions in response to the state of the pandemic. Despite these containment measures, Bogota has been disproportionately affected by the pandemic, straining the capacity of Bogota’s healthcare system, particularly in the southern and poorer part of the city. Bogota responded with urgency, increasing intensive care unit (ICU) capacity, acquiring ventilators and personal protective equipment (PPE), building up testing capacity and contact tracing, training additional emergency responders, and creating additional temporary hospital space in the Corferias convention center. To date, Bogotá accounts for approximately 28% of the reported cases of COVID-19 in Colombia.

As of April 26, 2021, Bogota has had 770,603 cases of COVID-19 (nearly 10% of the population), with a rate of 522 active cases per 100,000 inhabitants. Deaths due to COVID-19 have total 15,406 (2% of total cases).[1]

he SDS is the governing body for health in Bogotá and is responsible for  managing the health system in the capital, specifically: (i) the management, regulation, financing, and implementation of essential public health functions; (ii) harmonization of service delivery; and (iii) inspection and control of the health system in accordance with the requirements/guidance of the Pan American Health Organization (PAHO) and the World Health Organization (WHO). SDS’s COVID-19 response program is provided on its website and detailed information on Bogota's covid-19 programs, actions and initiatives can be found at the following link:

The SDS is divided into five Sub-Secretariats with different components of the MIGA Project corresponding to different Sub-Secretariats. The COVID-19 response components of the Project are managed by the Sub-Secretariat of Public Health (Subsecretaría de Salud Pública) and the Directorate of Health Emergencies (Dirección Urgencias y Emergencias en Salud) under the Sub-Secretariat of Health Services and Insurance (Subsecretaría de Servicios de Salud y Aseguramiento). The health infrastructure components are managed by the Directorate of Infrastructure and Technology (Dirección de Infraestructura y Tecnología) under the Sub-Secretariat of Planning and Sectoral Management (Subsecretaría de Planeación y Gestión Sectorial), in cooperation with the four regional subnetworks.

 SDS will be responsible for implementing the components of the Project, as follows:

  1. Expansion (including construction) and upgrade of approximately 39 existing public hospitals and clinics, including the purchase of protective personal equipment (PPE), diagnostic equipment (scanning machines) and clinical care equipment (ventilators) for existing healthcare infrastructure; ; and
  2. Sub-projects to improve COVID-19 emergency response capacity that include:
    1. the purchase of over 120 ambulances that will be owned and operated by Bogota,
    2. investments to acquire and implement a new information system to help improve the quality of Bogota’s emergency line (123),
    3. the procurement of PPE and other equipment to support measures to mitigate the spread and impact of COVID-19,
    4. the procurement of laboratory equipment and test kits for COVID-19 detection, and;
    5. preparation of a feasibility study for the development of a biocontainment laboratory

The loan proceeds may also be used to reimburse previous expenses related to the above Project components. If the SDS comes to MIGA with additional Project components after disclosure, the list will be updated, and re-disclosed.

[1] Daily updated information on COVID-19 cases in Bogota can be found here:

The Project is a Category B under MIGA’s Policy on Environmental and Social (E&S) Sustainability (2013) because the potential E&S impacts are limited, site-specific and readily addressed through mitigation measures. The main E&S risk is related to the development and implementation of an Environmental and Social Management System (ESMS) to facilitate E&S compliance of Project components. In addition, the risk to the vulnerable social groups access to health facilities and services has also been assessed. Other E&S risks vary depending on the Project component, as follows:

  • Potential E&S risks and impacts related to hospital expansion and upgrade include; (i) medical waste management and disposal; (ii) occupational health and safety (OHS) and the potential exposure of hospital staff to COVID-19; (iii) community health and safety including the potential exposure to COVID-19, and  (iv) minor/ moderate scale construction impacts related to air, water, noise emissions and waste.
  • Potential E&S risks and impacts related to the COVID 19 response spending include: (i) OHS and the potential exposure of ambulance and laboratory staff to COVID-19; (ii) risk of traffic accidents caused by high speed ambulance driving under emergency or extreme weather conditions.

While all Performance Standards (PSs) are applicable to this Project, based on our current information, the Project will have impacts which must be managed in a manner consistent with the following Performance Standards:

  • PS1:  Assessment and Management of Environmental and Social Risks and Impacts
  • PS2:  Labor and Working Conditions
  • PS3:  Resource Efficiency and Pollution Prevention
  • PS4:  Community Health, Safety and Security

The expansion and upgrade of existing hospitals will be implemented within facilities owned by SDS therefore PS5: Land acquisition and Involuntary Resettlement does not apply. Hospital infrastructure is located in modified urban environments therefore PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources does not apply. As Indigenous Peoples (IP) are not expected to be detrimentally affected by the Project, PS7: Indigenous Peoples is not applicable. PS 8: Cultural Heritage also does not apply since the infrastructure components of the Project will be developed within existing facilities.

In addition, the following World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines are applicable to the Project:

  • World Bank Group (WBG) General EHS Guidelines (2007)
  • WBG EHS Guidelines for Health Care Facilities (2007)

The following documents were reviewed by MIGA:

  • MIGA E&S Due Diligence Questionnaire, November 2020
  • Presentación Banco Mundial - Sostenibilidad Ambiental y Social (World Bank Presentation - Environmental and Social Sustainability). SDS, November 2020.
  • SDS Environmental Management Policy (January 2017, latest revision  October 2020). 
  • Institutional Plan for Environmental Management (PIGA), SDS October 2018
  • Plan de Gestión Integral de Residuos Sólidos (Plan for the Integral Management of Solid Waste or PGIRS Integral Solid Waste Management Plan or PGIRS), SDS, July 2020
  • Social Management Plan (Plan de Gestión Social) SDS, 2020.
  • Procedimientos de Participación de las Partes Interesadas (Stakeholder Engagement Procedures), SDS, November 2018.
  • Adjunto Personal de Planta (List of Formal Staff), SDS, 2020.
  • Formato Presentación Preguntas Quejas Acoso Laboral (Presentation Format for Workplace Harassment Complaints), SDS, November 2019
  • Manual de procesos y procedimientos Acoso Laboral - Gestión del Talento Humano (Manual of procedures for Workplace Harassment - Human Talent Management), SDS, November 2019
  • Plan Estratégico del Talento Humano (Strategic Plan for Human Talent), SDS, January 2021
  • Plan de Seguridad y Salud en el Trabajo (Security and health plan at work), SDS, January 2021


In addition, the following management plans and templates prepared by SDS primarily for the expansion and upgrade projects were also reviewed:

  • Planificación de Intervenciones (Interventions Planning).
  • Plan de Gestión Social (Social Management Plan).
  • Normatividad (Regulatory Plan).
  • Localización de obras y replanteo (Re-planting trees management).
  • Intalación de campamento (Camping Installation).
  • Demolición (Demolition).
  • Descapote (Stripping).
  • Manejo de Material de Excavación (Excavation Materials Management).
  • Cargue, transporte y disposición de escombros (Debris management, transportation and disposal).
  • Materiales de Construcción no petreos (Non-Stony Construction Materials).
  • Materiales de Construcción petreos (Stony Construction Materials Management).
  • Operación de Maquinaria, Equipos y Vehículos (Operation of machinery, equipment and vehicles).
  • Manejo de Cobertura Vegetal (Vegetation Coverage).
  • Circulación Peatonal y Manejo de Tráfico (Pedestrian Circulation and Traffic Management).
  • Señalización (Signaling).
  • Plan de Acción Interno para el Aprovechamiento Eficiente de los Residuos (Internal Action Plan for the efficient Use of Waste) March, 2018
  • Manejo de Residuos Peligrosos (Hazardous Waste Management). August, 2020
  • Gestión Integral de Residuos Hospitalarios (Integral Management of Hospital and similar Waste), July, 2020
  • Manejo de Residuos Sólidos (Waste Management).
  • Manejo de aguas residuales y lluvia (Waste and Rainwater Management).
  • Higiene, Seguridad Industrial y Salud Ocupacional (Hygiene, Industrial Safety and Occupational Health).
  • Análisis de Riesgos y Plan de Contingencia (Risk Assessment and Emergency Preparedness).
  • Control de la Contaminación Atmosférica (Air Pollution Management).
  • Plan Integral de Movilidad Sostenible-PIMS (Integral Plan of Sustainable Mobility-PIMS), September, 2019.
  • Uso Eficiente del Agua (Efficient use of water), May, 2019
  • Uso Eficiente de Energía, (Effient Use of Energy), January 2020
  • Programa de Consumo Sostenible, (Sustainable Procurement Program), January 2020
  • Formulación, Implementacoón y seguimiento del Plan Institucional de Gestión Ambiental, PIGA, (Formulaton, Implemetation and Monitoring of the Institutional Environmental Management Plan PIGA), May 2019
  • Identificación de Aspectos y Valoración de Impactos Ambientales (Identification of aspects and assessment of environmental impacts), November, 2019
  • Programa Integral de Gestión de Residuos (Integral Waste Management Program), July 2020
  • Formulación del Plan Operativo de Gestión y Desempeño del Proceso de Inpescción de Vigilancia y Control (Management and Performance of the Operetaional Plan for the Formulation of Public Health Management Process), February 2021
  • Estrategia Institucional de Respuesta de la Secretaría Distrital de Salud (Strategic Institutional Response of the Districts and Secretariat of Health), June 2020
  • Investigación de Accidentes e Incidentes de Trabajo (Labor incidents and accidents investigation), February, 2018
  • Prevención de Conductas de Acoso Laboral (Prevention of Work Harassment Behaviors), November, 2019
  • Plan de Prevención, Preparación y Respuesta a Emergencias (Emergency Prevention, Preparedness and Response Plan), November 2020
  • Plan Institucional de Capacitación, (Institutional Training Program), January 2021
  • Plan de Sistema de Gestión, Seguridad y Salud en el Trabajo (Workplace Health and Safety Management System), January 2021
  • Política Insttucional Antisoborno, (Institutional Anti-Bribery Policy), December 2019

Due to COVID-19 WBG travel restrictions, MIGA was not able to undertake a due diligence site visit. In addition to reviewing the above documents, MIGA carried out virtual E&S due diligence in November 2020, which included meetings with key SDS staff and management, as well as discussions with IFC and World Bank. MIGA also engaged an international E&S consultant to identify any gaps between Colombian legislation applicable to the Health Care Sector (including District of Bogota norms), with respect to PS2 and PS7 requirements.

MIGA’s due diligence review considered the E&S management planning process and documentation for the Project and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the E&S Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards. Key E&S issues associated with the Project business activities are summarized in the paragraphs that follow.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System

As all of the components of the Project are the responsibility of SDS, the focus of the E&S risks and impacts management and MIGA E&S due diligence is on SDS as the implementing entity. This includes SDS’s existing E&S management systems, and mechanisms to ensure compliance with PS requirements for all Project components. In line with the ESAP, all Project components will be required to apply the PS, and where SDS is not directly responsible for implementation, SDS will be required to pass down the relevant E&S requirements to the implementing unit and / or contractors through a formal agreement/contract. SDS will share copies of the formal agreements/contracts with MIGA (ESAP action item #1).


SDS has developed and is implementing an Environmental Management Policy (January 2017) in compliance with national legislation. As part of the ESAP, SDS will develop a Policy specific to the MIGA-guaranteed components, which includes social aspects and a commitment towards compliance with the PSs  (ESAP action item #2).

Identification of Risks and Impacts:

SDS has developed and implemented a Mandatory Health Quality Assurance System (MHQAS) (February 2016), that governs its operations and activities (including the Project components) in line with national legislation, which includes the following standards to systematically identify and address E&S risks and impacts:

  • Sistema Único de Habilitación,Resolución 3100 de 2018 (Unique Enabling System or SUA) that includes aspects such as environmental management and identification of environmental risks and impacts related to their activities; and
  • Programa de Auditoría para el Mejoramiento de la Calidad, February 2016, which includes an environmental audit program for their systems.

While the MHQAS is sufficient for screening in line with national legislation, SDS will develop a process for identification of risks and impacts of Project components in line with PS 1 requirements (see section on Management Programs below).

Management Programs:

For the MIGA guaranteed Project, SDS will engage an E&S Consultant to develop and implement an Environmental and Social Management System (ESMS) in line with the Performance Standards (ESAP action item #3), which will be integrated within the MHQAS. The ESMS will enhance the following existing MHQAS elements to include consideration of PS requirements: (i) policy; (ii) identification of risks and impacts; (iii) management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response and be revised to include the following elements (vi) stakeholder engagement; and (vii) monitoring and review. The ESMS will also include a COVID-19 Risk Management Plan.

SDS has developed templates for the following management plans governing construction activities, which will be applied to the hospital expansion and upgrade components of the Project. These templates are shared with construction contractors who update and implement them on a project-by- project basis, in line with the MHQAS E&S policies and procedures. The Project-specific management plans are approved by SDS prior to their implementation:

  • Demolition, Stripping and Excavation Materials Management Plan.
  • Hazardous, non-hazardous and construction Waste Management Plan.
  • Hazardous Material Management Plan.
  • Vegetation Cover Management Plan.
  • Water, Wastewater and Rainwater Management Plan.
  • Risk Assessment and Emergency Preparedness Plan.
  • Traffic Management Plan.
  • Construction Camp Management Plan.
  • Community Health and Safety Management Plan.
  • Subcontractor Management and Monitoring Plan.

In addition, SDS has developed a Social Management Plan (2021) (Plan de Gestión Social) which aims to reduce negative E&S impacts of construction activities on local communities. Therefore, in line with the ESAP, management plans for operations will also be developed as part of the ESMS (ESAP action item #3). Each infrastructure sub-project will have its own E&S management plan.

Organizational Capacity and Competency:

In SDS, E&S management for health infrastructure projects is the responsibility of the Directorate of Infrastructure and Technology, while E&S management for other activities falls within the mandate of the Quality of Health Services Department. There are 11 staff in the Environmental Management Technical Team, which falls under the Sub-directorate of Goods and Service (Subdirección de Bienes y Servicios).  

The Quality of Health Services Department is focused on the following aspects: (i)

providing technical assistance[1]to public and healthcare providers (which includes improving E&S performance); and (ii) E&S monitoring and control, which includes inspection, surveillance and control of both SDS’s activities and third party contractors. As per the ESAP, SDS will designate a senior official from the Quality of Health Services Department with the overall responsibility for ensuring and reporting on compliance with MIGA’s PSs, ESMS development and implementation, and implementation of the agreed ESAP (ESAP action item #4).

In addition to developing and implementing the ESMS, the E&S Consultant will also develop E&S training and capacity building materials for the management of E&S risks and impacts, and thereafter conduct training and capacity building to the relevant SDS staff (ESAP action item # 5).

Emergency Preparedness and Response:

As mentioned previously, for construction projects, including the hospital expansion and upgrade component the Project, SDS has in place a Risk Assessment and Emergency Preparedness Plan (November 2020). This Plan provides procedures to: (i) identify hazards, and (ii) evaluate and control endogenous and exogenous risks or factors that are present in the development of construction activities that may affect workers, the environment, the community or that may cause property damage. In addition, SDS has developed District Emergency Response Program Framework specifically to address the COVID-19 Pandemic, including: (i) emergency health measures and (ii) social, economic and environmental emergency measures. Furthermore, SDS has also prepared an emergency-related management plan template (Normatividad) used to develop and manage the national system to prevent and attend natural disasters;

SDS will hire a suitably qualified life and fire safety (L&FS) professional to develop and implement a L&FS Plan for the expansion and upgrade of existing hospital infrastructure (ESAP action item #6). For hospital upgrade and expansion projects, the L&FS professional will also assess existing infrastructure to determine whether it is in accordance with the L&FS / structural section of the WBG General EHS Guidelines (ESAP action item #7).

Monitoring and Review:


The Quality of Health Services Department conducts E&S monitoring and control every four years, which includes inspection, surveillance and control of its own activities and other healthcare providers in Bogota. This is reported on their website.


In addition, the ESMS will include a Monitoring and Measurement Procedure for the Project components, describing the overall requirements to ensure that there is adequate control of significant E&S aspects, compliance with local Health Safety and Environmental (HSE) legislation and requirements. This Procedure will include compliance with the PS and the WBG EHS Guidelines (ESAP action item #3). SDS will also be required to submit annual E&S monitoring reports to MIGA.


Stakeholder Engagement


SDS has developed and is implementing a Social Health Management Plan (2021), which is applied to each sub-project and includes the following procedures incorporating elements related to stakeholder engagement, external communication and ongoing reporting to affected communities:

  • Gestión de Orientación e Información al Ciudadano En Salud, Código October 2020 (Management of Citizen Guidance and Information in Health,
  • Participación Social en la Gestión Local en Salud, Código October 2019(Social Participation in Local Health Management), and
  • Participación Social en Salud en las Dimensiones Poblacionales Y Diferenciales, Código January 2019 (Social Participation in Health Population and Differential Dimensions):
  • Procedimientos de Participación de las Partes Interesadas (Stakeholder Engagement Procedures), 2021
  • Plan de Gestión Social en Salud (Health Social Management Plan), August 2020
  • Sistema de Gestión Integral de Control Social en Salud (Integrated Management System: Social Control In Health, November 2020

Participación Social en la Gestión Institucional en Salud, (Social Participation in Health Management), September 2020


SDS will develop and implement a Stakeholder Engagement Plan (SEP) in line with the PSs and scaled to the Project risks and impacts (ESAP action item #8). The SEP will: (i) incorporate the existing social health management  plan and procedures, (ii) outline SDS’s objectives in terms of stakeholder engagement; and (iii) describe the activities to be conducted with the stakeholders during each stage of the Project’s development. The SEP will also include procedures for documenting engagement activities and ensure that consultation is gender-sensitive, and the vulnerable population is identified and consulted.


External Communication and Grievance Mechanisms

As part of the Social Management Plan, SDS has developed various mechanisms that allow for grievances to be raised by the community through the following channels: over 360 physical mailboxes located throughout Bogota, a public health line, provision of email addresses of the relevant entities; and a direct system of complaints (Bogotá listens to you). For the Project components, SDS will ensure that the grievance redress mechanism tracks and reports on grievances and responses specific to the sub-components (ESAP action item #9).

PS2:  Labor and Working Conditions

Working Conditions and Management of Worker Relationship:

There are over 570 direct employees within SDS. In addition, there are approximately 769 contractors that are responsible for supporting the administrative development of the investment processes within the SDS - Fondo Financiero Distrital de Salud Furthermore, there will be approximately 4,294  indirect jobs that will be generated as a result of the execution of the investment projects for the 2021 fiscal year. Construction activities for the expansion of existing hospitals are expected to last approximately 36 months and there will be approximately 11,500 workers during the construction phase, with women comprising almost 5% of the total number of construction workers.

Human Resources (HR) Policies and Procedures, Working Conditions and Terms of Employment:

Policies and procedures governing SDS’s Human Resources (HR) practices have been developed in line with national legislation and are consistent with PS2. They include provisions for working conditions, internal grievance mechanisms, non-discrimination, payments, prohibitions against child labor (with no employment of people under the age of 18) and forced labor, occupational health and safety and third-party suppliers. HR plans and procedures are listed below:

  • Strategic Plan for Human Talent (October, 2020).
  • Institutional Training Program (January, 2021).
  • Human Resources Forecast Plan (January 2021).
  • Security and health plan at work (January 2021).
  • Incentives Plan (August 2015).
  • Manual of procedures for Workplace Harassment - Human Talent Management (November 2019)

For all Project components, SDS will provide workers with documented information regarding their rights under national labor and employment law. Labor contracts will include the type of workers’ data and information that will be retained by the SDS and maintain a system that keeps all applicable records of all its directly contracted workers (ESAP action item #10).

SDS have developed and are implementing a sexual harassment procedure (Workplace Harassment Behavior Prevention, 2019). The procedure applies to all workers who wish to file a complaint of harassment at work and includes guidelines as for the handling of sexual harassment complaints. As part of the ESAP (action item #11), SDS will  develop and implement policies and procedures related to gender-based violence (GBV), including the existing sexual harassment procedure, the existing Code of Ethics, disciplinary procedures and employee grievance mechanism. These policies and procedures will be applied to the sub-networks and contractors. .

Workers’ Organization:

SDS’s HR policies are policies are aligned with National law which stipulates workers’ right to unionize and rights to collective bargaining. There are no barriers to freedom of association through trade union membership and/or collective bargaining.  

Grievance Mechanism

SDS has an internal grievance mechanism in place through which staff members, including third-party workers, may raise employment concerns and/or report any misconduct in the workplace associated with the Code of Ethics. The mechanism allows for anonymous complaints and grievances to be registered through a toll-free number, intranet, and grievance boxes distributed in the offices and facilities. In addition, SDS also provides psychological support to employees and have an in-house counselor that is available to both staff and third-party workers.

Occupational Health and Safety:

SDS have developed and are implementing a Hygiene, Industrial Safety and Occupational Health Plan, April 2019 (Higiene, Seguridad Industrial y Salud Ocupacional), which provides technical procedures and requirements to maintain the health, safety and physical integrity of workers during construction. As part of this OHS procedure and prior to the commencement of any construction work an assessment of the proposed impacts associated with the intended activities on the receiving environment, social aspects and COVID-19 considerations is undertaken.  In addition, there is the risk of potential exposure of hospital and ambulance staff to COVID-19, if proper infection control procedures are not followed. SDS existing practice will minimize transmission risk at all hospitals as part of the Project by adhering to infection control and prevention protocols in line with WHO / PAHO guidance and national legislation on COVID-19. Furthermore, SDS have developed the following management plan templates:

  • Señalizacion (Signage), which provides for the signage in work/construction sites; and
  • Higiene, Seguridad Industrial y Salud Ocupacional (Hygiene, Industrial Safety and Occupational Health Plan)), which provides technical procedures and requirements to maintain the health, safety and physical integrity of workers.


Workers Engaged by Third Parties:

Each third-party company working for SDS is required to abide by their labor and OHS-related provisions, in line with Colombian law and regulations. To facilitate compliance with PS 2, SDS  will ensure that all its contracts with primary suppliers specifically includes general conditions and requirements regarding the prevention of child labor, forced labor, discriminatory conducts, and also the disclosure of grievance mechanisms that would be available for all workers (ESAP action item #12).

In addition, SDS will also develop a procedure/protocol to  monitor high-risk[1]primary suppliers (ESAP action item #13).

PS3:  Resource Efficiency and Pollution Prevention

PS 3 risks and impacts are primarily related to the hospital expansion and upgrade components. During the construction/upgrade period, the workers will be exposed to hazards and risks including from moving machinery; noise, dust and exhaust emissions; confined spaces and excavations; working at heights; working over water bodies; hazardous and flammable materials; and hazardous waste. Additional risks include road accidents and as such SDS will ensure that the following mitigation measures are applied: safety signs, barriers, speed limits appropriate for construction zones, traffic calming measures and visible Personal Protective Equipment (PPE). During the operation of the hospitals, risks and impacts include solid and medical waste management and disposal.  

Resource Efficiency 

SDS has developed an overall plan for management of the physical environment. The Plan Institucional de Gestión Ambiental, October 2018 (PIGA), includes provisions relate to the efficient use of water and energy and solid waste management. PIGA includes soil, air, energy, water, waste, environmental and sustainability resource efficiency and best management practices and is based on National legislation and is in line with PS 3 requirements.

Pollution Prevention

PIGA also includes pollution prevention measures in relation to soil, air waste management and water), environmental impacts prevention.

Wastes and Hazardous Materials Management

The following plans have been developed for the management of waste and hazardous waste management:

  • Sistema única de Habilitación, November 2019 (Unique Enabling System or SUH), that details  the integrated waste management process;
  • Plan de Gestión Integral de Residuos Sólidos (Plan for the Integral Management of Solid Waste or PGIRS) (September 2002). PGIRS has the following components: identification and classification of waste, segregation at source, transportation of the waste, storage and disposal. In addition, PGIRS contains guidelines for: (i) the proper management of hazardous waste from generation to use and/or final disposal are established and (ii) transportation of the hazardous waste. PGRIS specifies hazardous wastes must be delivered to general service personnel duly packed, packed and labelled with the type of waste and hazard characteristic. Once the waste is, transported to the temporary storage room, weighing and registration is carried out. Finally, the waste is are delivered to the hazardous waste manager who then issues the manifest and subsequently the final disposition certificate at sites authorized by the District Secretariat of Environment.

The ESMS will require  Project components to have proper waste management measures related to the disposal of infectious waste from service providers and ensure that the waste is disposed of in an environmentally sound manner (ESAP action item # 14). This will be in line with the above management plans and PS 3.

PS4:  Community Health, Safety and Security

Community Health and Safety:

Potentially negative community health risks and impacts during the expansion and upgrade of existing hospitals stem from dust and noise due to the movement of heavy equipment, materials and project personnel, traffic accidents, increased demand for natural resources, soil erosion as well as pollution and hazardous materials. During operations, negative impacts are expected to be related to noise, air emissions, traffic and potential emergency scenarios. The construction projects of the District Health Secretariat and the Integrated Health Services Sub-networks are awarded to contractors  , who must ensure compliance with environmental regulations and the environmental management plan. These responsibilities are part of the contract minutes, so that it becomes a contractual obligation.

Additional community health and safety risks are related to the potential infection of community members if there are not adequate measures and adherence to infection control, self-quarantine and isolation.  The hospital component of the Project will receive, test and treat COVID-19 suspected and confirmed patients which may in turn present risks for hospital and ambulance if proper infection control procedures are not followed. However, SDS will ensure that all ambulances and hospitals as part of the Project, adhere to infection control and prevention protocols in line with WHO/PAHO guidance and national legislation on COVID-19 to ensure that areas surrounding the hospitals, and visitors are not placed at risk.

As mentioned previously, SDS has several mechanisms in place for citizens to file petitions, complaints and suggestions, which are listed below:

  • Physical mailboxes
  • A public health line for all
  • Emails from entities
  • Bogota listens to you- District Complaints and Solutions System

Health institutions have digital tools through social networks, websites of entities and media to disseminate information of interest to citizens on health issues, including on COVID-19.



A Broad Community Support determination is not required for the Project.

For additional information on the Project, please contact:


  • NAME & Title : Luz Stella Campillo – Subdirector Banca Multilateral

E-mail :


  • NAME & Title Lilian Vanessa Marrugo – Asesor Subsecretaria de Planeación

E-mail :

Phone : 3187739792



MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) 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 MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed 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 MIGA.

Independent of MIGA 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 MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed 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 a MIGA-guaranteed 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
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400