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Kenya

Kasada Hospitality Fund LP

$31.5 million
Tourism
Environmental and Social Review Summary
Proposed

Environmental and Social Review Summary 

Kasada Hospitality Fund LP

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. 

Kasada Hospitality Fund (“Kasada” or “the Fund”) is a US$500 million hospitality sector focused private equity fund backed by the Qatar Investment Authority (QIA), Qatar’s sovereign wealth fund and Accor, Europe’s largest hospitality group. Kasada is the first large-sized, professionally sponsored and managed hospitality investment platform in Sub-Saharan Africa (SSA). Over the next three years (2021-2024), Kasada plans to build a portfolio of hotels in SSA primarily through the acquisition of existing (brownfield) hotels as well as the development of a smaller number of new (greenfield) hotels. The first phase, implemented over a period of approximately 18 months, will comprise the acquisition, refurbishment, and improvement of up to 20 hotels (or c. 4,000 hotel keys) across six or more SSA countries (comprising operational hotels as well as under-construction greenfield hotels).

Senior debt for Phase 1 will be primarily provided by IFC on IFC’s own account and through syndications. The deployment of IFC’s loans, MIGA’s guarantees, and the Fund’s capital will be structured as sub-projects, each of which will be progressively reviewed by IFC and MIGA, subject to standardized investment criteria and terms.

In addition, MIGA will provide a total coverage of up to €264.7 million (ca.US$268.2 million) to Kasada and its subsidiaries for their equity, quasi-equity and/or shareholder loan investments against the risks of Transfer Restriction (“TR”), Expropriation (“Expro”), and War and Civil Disturbance (“WCD”). The individual sub-projects will be issued for a maximum tenor of up to 15 years and the guaranteed percentage will be up to 90 percent for equity /quasi equity investments and up to 95 percent for shareholder loans. Further details are provided in the Project Briefs for the first and second sub projects:

Kasada Hospitality Fund LP (Senegal)

Kasada Hospitality Fund LP (Cote D' Ivore)

Kasada Hospitality Fund LP (Cameroon)

Kasada Hospitality Fund LP (Namibia)

IFC has led in carrying out environmental and social due diligence for the Kasada projects and disclosed the environmental and social review summary (ESRS) and environmental and social action plan (ESAP) for the first sub-project  on March 1, 2021. The first sub-project, Project Ayaba/Awale, comprises (i) the acquisition of 8 existing Accor-managed hotels (run under the Pullman, Novotel and Ibis brands) in Abidjan, Cote d’Ivoire (4 hotels); Dakar, Senegal (3 hotels) and Douala, Cameroon (1 hotel); (ii) operating liquidity injections to ensure the functioning of these hotels in the COVID-19 environment and (iii) capital expenditure / improvements to ensure the hotels’ full compliance to Accor standards and to achieve higher operating efficiencies. The second sub-project, Project Wind, comprises (i) the acquisition of the Safari Hotel, Safari Court Hotel and associated conference center located in Windhoek, Namibia. These hotels will be converted to the Accor Ibis Styles and Movenpick brands respectively. The third sub-project, Project Umbrella, comprises of the acquisition of a well-established hotel complex which is currently owned by Golden Jubilee Ltd and operated as Crowne Plaza by IHG. It has been in operation since 2010 in Nairobi, Kenya and comprises of a 206-key hotel complex with an annex which was completed and opened in 2016. The annex includes a commercial office space section. After Kasada’s acquisition Accor will operate the hotel.

MIGA has been asked to provide coverage against the risks of war and civil disturbance, transfer risk, and expropriation for Kasada’s equity investments and shareholder loan, in sub-project Umbrella, for up to 15 years. See the Summary of Proposed Guarantee for further details.

 

This is a Category B project according to IFC’s / MIGA’s Policy on Environmental and Social Sustainability (2012 / 2013). Based on IFC’s review, coupled with existing knowledge of the sector, the project is expected to have limited adverse environmental and social risks and impacts that are site-specific, and can be avoided or mitigated by adhering to recognized good international industry practice (GIIP).

Key E&S risks and issues associated with this project include: (i) the Fund’s E&S management system and procedures allied to the their internal capacity to effectively identify, assess and manage E&S risks and impacts associated with the portfolio of hotels as well as future new greenfield developments; (ii) provision of fair and safe working conditions for workers (including contractors) during both operational and refurbishment activities; (iii) consistent and inclusive engagement with labor unions; (iv) resource efficiency and waste management; (v) life and fire safety and emergency preparedness and response; and (vi) stakeholder engagement, including effective grievance management and redress.

While all Performance Standards are applicable to this investment, IFC’s/MIGA’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:

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts;

PS 2 - Labor and Working Conditions;

PS 3 - Resource Efficiency and Pollution Prevention;

PS 4 - Community Health, Safety and Security.

The project primarily involves acquisition of existing operational hotels, the acquisition and completion of under-construction greenfield hotels, and potentially building greenfield hotels. Hence, it is not anticipated that the fund will undertake much land acquisition for the development of their Phase 1 hotel portfolio. Further, based on the fund’s current and proposed business plans, coupled with the urban and brownfield nature of the hotels, it is expected that the project will not result in adverse material impacts on local indigenous groups, biodiversity and natural resources and cultural heritage. As such, no impacts for this project are expected which must be managed in accordance with IFC PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Natural Resource Management, PS7: Indigenous Peoples and PS8: Cultural Heritage.

This ESRS initially focussed on the 8 hotels acquired under the first sub-project, Project Ayaba. It has subsequently been updated and disclosed in April 2022 to include the second sub-project, Project Wind and updated and disclosed in [August 2022] to include the third sub-project, Project Umbrella. Each sub-project is subject to further Environmental and Social (E&S) due diligence, and if deemed necessary, updating of the Environmental and Social Action Plan (ESAP). Should additional hotels be acquired under further sub-projects, they will be subject to further E&S due diligence, and the IFC ESRS will be updated as necessary, where IFC is also supporting the sub-project. In cases where IFC is not supporting the sub project, MIGA will update the IFC ESRS and disclose on its website.

IFC’s E&S review of this investment conducted in January 2021 (Project Ayaba), October 2021 (Project Wind), and June 2022 (Project Umbrella) included a desktop review of existing Kasada and Accor Environmental, Health and Safety (EHS) policies and processes, hotel level polices and processes, as well as phone and video interviews with the Kasada Head of Asset Management and Legal Counsel. Document review included the appraisal of Kasada’s proposed E&S management approach (both pre- and post-acquisition) focusing on the Fund’s ability to monitor the implementation of E&S policies and standards at each of the hotels within their portfolio. This included their existing capacity, monitoring and reporting mechanisms and their ability to enable future project compliance with IFC’s Performance Standards. An independent pre-acquisition audit was also conducted for Project Umbrella.

The field appraisal for Project Ayaba, conducted on 26 and 27 January 2021, consisted of site visits to three hotels (Pullman, Ibis and Novotel) located in Dakar, Senegal. The field appraisal by IFC for Project Wind, conducted from 18-20 October 2021 included site visits to both hotels located in Windhoek, Namibia. The IFC field appraisal for Project Umbrella, conducted 6 – 8 June 2022, included a site visit to the Crowne Plaza hotel, located in Nairobi, Kenya. The primary objectives of the field visits were to appraise the physical condition of the hotels with a particular focus on the management of life and fire safety, hold discussions with key management, human resources personnel and employee representatives, review the findings in the environmental and social due diligence report carried out for Project Wind, and assess the level and efficacy relating to the implementation of various E&S policies and approaches.

If deemed necessary, the appraisals will be supplemented with further field visits as required. 

IFC’s/MIGA’s appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

PS 1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System:

All hotels acquired under the Ayaba phase of the project are currently and will continue to be operated and managed by the Accor Group (“Accor” or the “operator”). The two hotels comprising Project Wind were operated by an independent operator and are now owned by Kasada and operated and managed by Accor. As defined in the Hotel Management Agreements (HMA) with each respective hotel, Accor, as the hotel operator, controls, under the conditions agreed between Kasada and Accor in the HMA, the hotels in terms of management approaches and the determination and implementation of all policies and procedures, including Accor E&S policies and procedures.

Accor’s Environmental and Social Management System (ESMS) includes E&S management programs, policies, charters, and global standards relating to environmental compliance, safe food and hygiene, ethics and corporate social responsibility, grievance management, recruitment and selection, workplace health and safety (for both employees and contractors), hotel incident management, fire and life safety and security. In addition, all hotels will implement Accor’s Planet 21 program that looks to improve the sustainability of hotels in relation to energy and water efficiency, food management, carbon emissions, waste management, sexual harassment, non-discrimination, employment equity, and corporate social responsibility.

For Project Wind, where previously privately managed hotels are required to transition to Accor policies and procedures, Accor has a dedicated Task Team to ensure the suitable implementation and adoption of key policies and standard operating procedures. This process is implemented through the Accor Task Manager platform over the transition period and covers key areas such as talent and culture, finance, procurement, engineering (including L&FS), marketing, IT, security etc.

For Project Umbrella, the hotel currently has in place elements of an ESMS, however this is not managed or structured in a consolidated or centralized manner. The hotel currently has various E&S policies in place, including an Environmental policy, staff handbook, hiring policy, and disciplinary code and procedures. Hotel management and operations are thematically and departmentally structured, however no formal E&S functions (quality, occupational health and safety, stakeholder engagement) are defined. The hotel is subject to annual audits by the National Environmental Management Authority (NEMA). As the hotel was privately managed, it will also be required to transition the existing ESMS to Accor policies and procedures over a 3–6-month period. (ESAP 2a and 2b).

Identification of Risks and Impacts:

As a component of its hotel acquisition approach, Kasada currently undertakes both pre- and post-acquisition due diligence processes. The existing pre acquisition process predominantly relates to technical, financial and legal due diligence at the time of acquisition, as well as the assessment of compliance with national standards, E&S regulatory permits, building permits, land titles etc. The post-acquisition assessment process requires an ongoing commitment to Accor’s existing ESG and Planet 21 programs and policies. For Project Wind, Kasada also procured an independent pre-acquisition E&S audit of the hotels and is also conducting further audits relating to Life & Fire Safety (L&FS) and food and hygiene. For Project Umbrella, Kasada procured an independent pre-acquisition E&S audit of the hotels against the requirements of relevant local legislation and IFC Performance Standards.

For the acquisition of under-construction greenfield hotels, the Fund has developed a screening procedure vis-à-vis the agreed eligibility criteria and the standard operating procedure for conducting E&S due diligence of potential investments against IFC/MIGA Performance Standards. As part of the screening procedure, the Fund will assess the applicability of all the PSs for all the future greenfield acquisitions and developments to comply with PS requirements and was captured as an action in the first sub project ESAP.

Organizational Capacity and Competency:

As a component of the Project Ayaba ESAP, Kasada has employed a dedicated E&S Manager to provide monitoring and oversight of its hotel portfolio. The approach going forward, will include conducting pre- and post-acquisition due diligence and the management and assessment of E&S KPIs. This role is supported by the general counsel, Asset Manager and the technical and construction team. As Kasada’s portfolio continues to grow through ongoing acquisitions, the Fund will be required to review and assess their internal E&S capacity to ensure adequate oversight and monitoring (ESAP 4).

As the operator of the hotels, the various Accor departments (including sustainability, crises management, occupational health and safety, security etc.) provide an ongoing E&S oversight, support and monitoring function to Kasada.  As per the HMA’s, as the operator of the hotels, Accor, has the management control of the hotels, including recruitment, however, some recruiting including the employment of the General Manager must be agreed by Kasada. At a hotel level, the General Manager is ultimately responsible for all E&S aspects of the hotel, including providing monthly feedback to the business review meetings and annual monitoring against the pre-defined Accor KPIs. Hotel management will create capacity for presenting E&S roles and responsibilities at Project Umbrella 

Emergency Preparedness and Response:

Accor has developed and implemented a Hotel Incident and Crises Manual for all hotels they operate in the Middle East and Africa (MEA). All incidents, including accidents, armed robbery, electrical failure, bomb threats, fatalities, demonstration, food poisoning, fire or explosion and theft, are classified as either bronze, silver or gold which determines the appropriate management response. As per the manual, each hotel must have a crises response team as well as a Crisis Plan. All employees are required to receive training in relation to the procedures and guidelines detailed in the Crisis Plan. The general manager of each hotel has ultimate oversight of crises management and reporting. For significant incidents, Accor has established a MEA Crises Response Team.

Ongoing training, maintenance as well as any incidents in relation to the Crisis Plan will be recorded and reported as per the requirements of the Hotel Incident and Crises Manual and monitored by Kasada as per the monitoring framework and is applicable for Project Umbrella.

COVID-19:

In response to the ongoing COVID-19 pandemic, all Accor managed hotels have been required to implement the ALLSAFE program. This has introduced intensified hygiene and prevention measures and safety standards. The program includes a dedicated guest hotline, enforcement of social distancing in all common areas, contactless check-in and payment (where possible), provision of hand sanitizer in public areas, reinforced cleaning of public areas, employee safety and hygiene training, guest access to medical professionals and reinforced food safety standards and protocols. As of March 2022, the Project Wind hotels are currently undergoing a transition to the Accor ALLSAFE program through the Task Manager platform. Project Umbrella, as a component of the transition to an Accor-managed hotel, will be required to implement the Accor ALLSAFE program.

Monitoring and Review:

The Fund has developed initial key performance indicators (KPIs) that go beyond the current industry benchmarks, which they aim to achieve over the next three to four years. These KPIs relate to enhanced sustainability in the areas of employment equity, improved energy efficiency, Excellence in Design for Greater Efficiencies (EDGE) certification for all hotels, food waste reduction and Hazard Analysis Critical Control Point (HACCP).

As a component of the first ESAP, Kasada has also developed and implemented a standardized monitoring framework that assesses individual hotel compliance against predefined Kasada KPIs, Accor policies and procedures, including Planet 21, local regulatory requirements, IFC Performance Standards, contractual and collective bargaining agreements.  All hotels are required to provide feedback on any material E&S issues to Kasada at the monthly business review meetings and quarterly reviews. Comprehensive monitoring results against all the KPIs will be provided for the annual review, and where necessary, mitigation and management measures factored into the budget requirements.

In addition to these measures, as per the HMA’s, Kasada agrees that the operator, Accor, may once every fiscal year, carry out an audit of the hotel’s systems to ensure compliance with Accor Group Policies, including policies relating to the security of the network. Kasada will be responsible to implement all recommendations following such an audit.

PS 2: Labor and Working Conditions

Human Resources Policies and Procedures:

At the close of the first transaction, the eight Project Ayaba hotels had a total of 635 employees (approximately 66% male and 34% female) in the areas of management, human resources, front of house, housekeeping, restaurant, kitchen, maintenance, IT, administration, sales and marketing.

As of March 2022, Project Wind hotels have a total of 76 employees. The majority of employees (≈77%) are provided with open ended (permanent) contracts, while a smaller number (≈8%) are provided with term (temporary) contracts. The remainder of the employees (≈15%) are contractors (security guards, garden maintenance etc.). The majority of employees at each hotel are locally sourced, with only four expats across the two hotels. As of June 2022, Project Umbrella has 38 employees.

It is agreed that Accor, as the hotel operator, has management control, in relation to all human resource (HR) matters of the hotel employees including recruiting, secondment, training, supervisions, promoting, discharging and liaising with, and negotiating with workers unions, under the conditions agreed between Kasada and Accor under the HMA.

Accor HR policies and procedures will be implemented across all of the hotels. This includes a recruitment and selection policy, recruitment charter, Code of Conduct, Ethics and Corporate Social Responsibility charter, grievance management procedure, workplace health and safety procedure among others. These policies are noted to be consistent with the respective local labor laws and requirements of IFC PS2.

Labor and Working Conditions

Building upon the Accor’s HR policies and procedures, labor and working conditions at the eight Project Ayaba hotels reviewed, are determined predominantly by existing collective bargaining agreements, that are aligned with respective local legislative requirements. The collective bargaining agreements cover working conditions including recruitment, probation, salaries, working hours, benefits, leave, disciplinary action and termination, retrenchment etc. All employees are provided with a written contract (open ended or term), as per the requirements of the collective bargaining agreements, detailing their terms of employment.

For the Project Wind hotels, no collective bargaining agreement is present and hence labor and working conditions are defined by local legislative requirements. All employees will also be provided with new contracts to ensure alignment with local legislative requirements as well as Accor procedures and policies. Kasada will commission Accor to undertake internal labor assessments and will provide the labor audits findings. Kasada and MIGA will agree upon an improvement plan to fulfill the gaps (if any) versus local legislative and PS requirements.

Labor and working conditions within the Project Umbrella hotel are defined by Kenyan legislative requirements and detailed within the staff handbook. This covers areas of non-discrimination and equal opportunity, retrenchment, and employee grievance management. Within the first three – six months of Accor assuming operations of the respective hotel, through their Task Manager Platform, a labor assessment will be completed to ensure alignment of existing practices, procedures, and employment contracts with both local legislation, as well as Accor policies and procedures. This will cover areas relating to labor and working conditions, hiring, compensation and benefits, employee relations, safety, and security (ESAP 5). Where gaps or non-alignment are identified, corrective actions will be implemented through a timebound action plan.

Workers Organizations:

As articulated in Accor’s Ethics and Corporate Social Responsibility Charter, all employees have the right to find and join organizations of their choosing with the aim of collectively defending their interests through a collective bargaining process. This stance is reiterated in the respective HMA’s which state that Kasada, as the owner and employer, will comply with hotel employees’ rights to join and form workers’ organizations and/or unions of their choosing, and undertake collective bargaining.

The majority of employees at the eight Project Ayaba hotels are currently unionized, however, membership of the unions is on a voluntary basis. Each union has an elected representative committee who engage with hotel management on a regular basis. The committees are re-elected every three years. At the close of the first transaction, each hotel currently had a collective bargaining agreement (CBA) in place. The CBAs govern all aspects of the employment terms and conditions in accordance with local legislative requirements.

 

In order to ensure immediate and long-term labor management, including engagement with local unions, is completed in accordance with the requirements of both local legislation and Performance Standard 2, Kasada has developed a timebound management and engagement action plan detailing their approach to labor management as part of the ESAP for Project Ayaba. The action plan includes a training schedule of all Kasada and Accor management and heads of department on the requirements of Performance Standard 2.

 

For Project Wind, currently, eight employees are unionized with the Namibia Food and Allied Workers Union (NAFAU). Currently, there is no sectoral or hotel specific CBA in place; however, should worker representation reach 51%, the option to enter into a collective bargaining process is available.

 

The Project Umbrella hotel does not currently have a defined approach or policy regarding freedom of association or collective bargaining; however, several employees are currently members of the Kenya Union of Domestic, Hotels, Educational Institutions and Hospital Workers (KUDHEIHA). As a component of the transition to an Accor ESMS (ESAP 2a and 2b), the hotel will be required to adopt Accor’s Ethics and Corporate Social Responsibility Charter, whereby all employees are entitled to join an organization / union of their choosing, and bargain collectively.

 

Non-Discrimination and Equal Opportunity  

Accor has developed and implemented, across all of their managed hotels, a compulsory Ethics and Corporate Social Responsibility Charter, which is overseen by the Groups Ethics an CSR committee. As per the charter, all Accor managed hotels are committed to eliminating all sources of discrimination and promoting equal opportunity, including in the areas of recruitment, promotion, training and career support.

Furthermore, as captured in the Diversity and Inclusion Commitment, Accor promote diversity and non-discrimination on the grounds of country, region or neighborhood of origin, family name, culture, age, gender, physical appearance, disability, sexual orientation, education and others. Accor has also implemented the RiiSE initiative which is an international network to promote diversity and gender equality in the workplace.

Additionally, Kasada is targeting 100% gender pay parity across all their hotels and 50% female general managers by 2025.

Retrenchment:

None of the Project Ayaba hotels were required to retrench any staff due to the ongoing Covid-19 pandemic and all salaries were maintained, however, approximately 183 term contracts were not renewed during this period, representing 78% of temporary employees. Any planned retrenchment in the future, has to be managed as per the requirements of the existing collective bargaining agreements, taking into account length of service, family responsibilities, professional qualities etc. The employee representative is consulted regarding any retrenchment plans.  

Due to COVID-19 implications and more than one year prior to the acquisition of Project Wind hotels by Kasada (and without Kasada’s involvement), significant salary reductions occurred in April 2020, and the majority of employees were retrenched in May 2020. The previous hotel owner provided impacted employees with written notices as well as engaged with employees, NAFAU and the Ministry of Labor as per the requirements of local legislation. The Project Wind hotels have now started to re-engage, to the extent possible, the pool of retrenched employees.

Similarly, due to COVID-19 related restrictions and financial constraints, the Project Umbrella hotel was required to retrench 144 employees and place an additional 46 on unpaid leave. The process included the payment of salaries up to end August 2020, severance pay, payment of accrued leave, and a certificate of service.

Grievance Management:

Accor has developed a grievance procedure that is applied across all its hotel operations. The procedure details the process for raising grievances, timelines for feedback and resolution, documentation and the appeal process.

Accor has also implemented a Whistleblowing hotline, the Accor Integrity Line, allowing employees to report any grievances or conduct that is contrary to Accor policies, in complete confidentiality and anonymity if necessary. The mechanism is also offered on an internet platform accessible 24 hours a day, 7 days a week and is available in 29 languages.

Prior to Kasada’s acquisition of the Project Wind hotels, a Grievance Management process was implemented at the Project Wind hotels. This process is currently under review and will be updated to ensure alignment with the Accor standards and requirements, if needed (and verification of these updates will be part of the labor audit being carried out as part of the ESAP).

Project Umbrella lacks a formal documented employee grievance policy in place at the time of their respective appraisals. The transition to an Accor managed hotel would require the implementation of the Accor grievance procedure as well as their whistleblowing hotline (ESAP 3).

Protecting the Workforce:

As per Accor’s Ethics and Corporate Social Responsibility Charter, no hotels under their management are permitted to institute any form of forced, child or undeclared labor. In terms of child labor, Accor commits to comply with the legal minimum working age in each host country and to never employ anyone under the age of 14. As a component of Accor’s selection and recruitment process, the age of all potential employees is verified and recorded. In addition, the Charter also details a zero-tolerance approach to any form of harassment, including sexual harassment, and bullying in the workplace. These policies are applicable to both employees within Accor managed hotels, as well as suppliers and third-party service providers.

Occupational Health and Safety:

Accor has developed and implemented policies and procedures identifying specific occupational health and safety risks in its hotels and which will be applicable to Project Wind. Occupational Health and Safety is reiterated in Code of Conduct. As per the Hotel Incident and Crises Manual, all hotels are required to develop their own Hotel Incident and Crises Manual to facilitate the response to an incident.

During planned refurbishment and upgrades to the hotels, it is anticipated that numerous contractors will be on site. For this purpose, Accor has developed and implemented a Workplace Health and Safety Policy and associated agreement for contractors and suppliers to ensure a suitable safe environment and work site. This forms the basis of all agreements with contractors and covers areas such as product safety, environmental management, health and safety, hazardous material handling, hygiene, insurance and compliance (fire, electrical, plumbing and ventilation).

Should an employee be involved in an incident, even a minor one, they are required to immediately report the incident to the relevant hotel manager, who subsequently completes either an Accident and Dangerous Occurrence Report or Incident Report which is sent to the Director of Operations and the MEA Risk Management team. After every incident a debrief form must be completed and a meeting held to review the outcomes of the incident. Incidents must be reported within 48 hours.

Third Party Workers

The hotels in the current pipeline of acquisition under Phase 1 utilize a limited number of third-party service providers to fill roles such as security and garden maintenance. These third-party service providers are required to comply with all Accor policies and standards, as well as local legislative requirements.  All third-party workers and service providers are also required to comply with the Accor policy on Workplace Health and Safety Agreement for Consultants, Contractors and Suppliers. The policy forms the basis of all agreements with contractors and suppliers and sets out the minimum health and safety, environmental protection and fire prevention requirements of all contractors, suppliers or consultants. These same requirements are applicable for Project Umbrella.

PS 3: Resources Efficiency and Pollution Prevention

Resource Efficiency:

Accor has committed to environmental management and sustainability through several policies and standards. The Ethics and Corporate Social Responsibility Charter reiterates its position on energy and carbon footprints, pollution and discharges, water conservation and waste recycling.

In addition, Accor have also developed and implemented an Environmental Compliance Guideline that provides design and operational strategies and technologies to reduce energy and water consumption, carbon footprint and maintenance costs. Lastly, all Accor managed hotels are required to achieve at least a mandatory ‘bronze’ status in terms of the Planet 21 requirements. This includes initiatives to improve and monitor water and energy efficiency as well as waste management. 

In addition to Accor’s mandatory requirements of the Environmental Compliance Guideline and Planet 21, Kasada is looking to operate its hotels following internationally accepted green building standards, as part of IFC’s Excellence in Design for Greater Efficiencies (EDGE) certification. The fund, as one of their KPIs, is targeting at least 20% of hotels to be EDGE certified by 2025. Kasada will also look to achieve a 10% per room energy reduction by year two of operation. Kasada will aim to achieve EDGE certification for Project Umbrella by demonstrating at minimum 20% savings in energy, water and embodied energy in materials. 

Greenhouse Gas Emissions:

Greenhouse Gas (GHG) emission sources from operations will be mainly related to grid electricity use, diesel use for back-up generators and vehicles. As per the Accor Environmental Compliance Guidelines, all hotels are required to keep accurate and documented records and measurements of all energy consumption. This includes sub-metering at high-energy use areas kitchens, laundries and swimming pools. All hotels are required to track their energy consumption via the Planet 21 Gaia platform.

GHG emissions, associated with grid electricity and diesel consumption for Project Ayaba are estimated at 9,300 tons of CO2-eq/year. Kasada, as a component of their monitoring framework, will monitor and record resource usage, including water, energy as well as their estimated gross GHG emissions from all the hotels.

Pollution Prevention and Waste Management:

As per the Accor Environmental Compliance Guidelines and Planet 21 mandatory ‘bronze’ requirements, all hotels are required to manage their waste, (water, solid and hazardous), in a sustainable and environmentally friendly manner. This includes the removal of plastic straws and cotton buds, using eco-friendly cleaning products, ensuring that 100% of wastewater discharge, including sewage and grey water, is connected either to a municipal wastewater treatment network or a hotel owned treatment facility and sorting and processing of hazardous (paint, batteries, fluorescent bulbs, printer cartridges, aerosols, waste oil etc.) and solid waste (glass, paper, plastic, cardboard) into appropriate waste streams.  Hotels are also required to identify and document all hazardous material on site.

In addition to the Environmental Compliance Guidelines and Planet 21 requirements, the fund is targeting zero waste to landfill at 20% of their hotels by 2025.

PS 4: Community Health, Safety and Security

Community Health and Safety:

Food Safety

Accor have developed and implemented a Safe Food and Hygiene Standards Manual that includes a Food Safety Policy, roles and responsibilities, food safety team, Hazard Analysis Critical Control Point (HACCP) requirements, supplier management, receiving and storing of food, pest control etc. Accor’s intention is to ensure that all their managed hotels will achieve a basic compliance level of food safety based on international food safety requirements, with an expectation that hotels move forward to seek HACCP certification.

Kasada are currently conducting an independent audit of the Project Wind hotels to ensure alignment with Accor food safety and hygiene requirements which are in line with the requirements of Performance Standard 4. This covers areas such as general maintenance, cleanliness, food storage control, hygiene etc.

Project Umbrella has the relevant food and hygiene license granted by the Nairobi City Council. Food and hygiene were also covered under the annual NEMA audit for Project Umbrella.

Life and Fire Safety

Accor has implemented a corporate life and fire safety (L&FS) system technical document (i.e. L&FS Master Plan), aligned with the requirements of the WBG EHS General Guidelines and international fire safety codes, that provides the minimum requirements for L&FS at all Accor managed hotels (new facilities or to be renovated).

For existing Accor-branded hotels, and before starting under Kasada’s management, the hotel general manager is required to commission a L&FS audit (or “Fire Safety Strategy”) against the minimum performance requirements set out in the technical document. The audit is prepared by qualified fire safety consultants who put together a corrective action plan with an associated implementation timetable to correct the deficiencies and non-compliances. Additionally, the hotels have implemented a periodic O&M plan, including inspection, testing and maintenance of L&FS systems by own personnel and qualified local subcontractors.  

IFC’s virtual visit to hotels based in Dakar confirmed that the hotels have the required L&FS infrastructure and systems including required L&FS features, as described above. Also, the hotels have fire brigades with good emergency training provided by an external certified company.  The evacuation procedures, roles and responsibilities of the various staff are reviewed regularly through pro-active measures and exercises.

As of March 2022, the Project Wind hotels have only ensured compliance with local Namibian L&FS regulations and have achieved certification on this basis. The hotels are currently undergoing an independent L&FS audit focusing on areas such as prevention, early detection, containment and mechanical, electrical and plumbing (MEP). The findings and remedial measures, to address the identified gaps with local legislative requirements and World Bank Group EHS Guidelines, of this audit will be provided to and agreed upon with MIGA.

L&FS at the Project Umbrella hotel and building is compliant with national requirements, including emergency exits, ventilation, fire suppression and containment, equipment maintenance, and the hotel is subject to annual NEMA audits. The hotel and building are in possession of a current fire clearance certificate. As owners, Kasada will retain overall control of the building, including ensuring adequate L&FS provisions as detailed under PS4.

All hotels in Kasada’s portfolio, both as a component of this phase and potential future acquisitions, will adopt and comply with Accor’s Fire Life and Safety System technical document, local legislative requirements and the World Bank EHS Guidelines (ESAP 1).

Security:

All hotels in Kasada’s portfolio are required to adopt and implement the Accor Global Brand Security Standard. The standard provides minimum baseline security requirements pertaining to physical, technical, human and operational practices and is largely aligned with the requirements of IFC Performance Standard 4 as well as the Voluntary Principles on Security and Human Rights

Security at all the hotels in Dakar, Cameroon and Ivory Coast is provided by private third-party contractors (between 5 and 10 guards per hotel). At the time of IFC appraisal for Project Ayaba (2021) due to perceived terrorism threats in the region, the Senegalese government does provide armed gendamerie for additional security. As per the Accor Global Brand Security Standard, contracted security companies must be properly licensed in accordance with local laws and comply with the requirements of the standard. This includes the justified and legitimate use or force, training and vetting.

Security at the Project Wind hotels is also provided by a third-party contractor who is responsible for vetting and ongoing training of their guards. The hotels also employ a permanent security supervisor. The hotel is currently undergoing the necessary requirements, as per the Task World platform, to transition to the Accor Global Security Standard. This includes conducting a comprehensive Security Risk Assessment which has been scheduled during the transition period and updating security related plans as necessary and in line with PS4 requirements.

Security at the Project Umbrella hotel is provided by a third-party service provider, Secure Kenya Limited. Project Umbrella will be required to undergo the necessary requirements, as per the Task World platform, to transition to the Accor Global Security Standard (ESAP 1).

Kasada are in the process of ensuring all their hotels are SAFE certified (https://safehotels.com/). This covers processes and procedures, training, management and organization, systems and infrastructure, and crises management. Audits and subsequent certification for the Project Ayaba hotels will commence in Q1 2022 while Project Umbrella will be conducted in Q4 2022.

Stakeholder Engagement

Accor, through its Ethics and Corporate Social Responsibility Charter commit to responsible communication practices, including responsible marketing, communication and transparency. This includes engagement with communities in which they operate, as well as with guests. Stakeholder engagement is managed at a global, regional and brand level. Accor also utilize engagement channels such as their webpage (https://group.accor.com/en/commitment/planet-21/our-partners), social media platforms and their annual integrated report to communicate progress and performance in relation to diversity, challenges, strategy, and sustainability (https://group.accor.com/-/media/Corporate/Investors/Documents-de-reference/2019-integrated-report.pdf).

In 2009, Accor signed the Responsible Communications Charter, which was revised and consolidated to become the FAIRe program in 2018, which Accor is a signatory. Accor also contribute to local economic development through direct and indirect employment by promoting local recruitment practices and offering skills and technical training.

 

Accor, through its Ethics and Corporate Social Responsibility Charter commit to responsible communication practices, including responsible marketing, communication and transparency. This includes engagement with communities in which they operate, as well as with guests. Stakeholder engagement is managed at a global, regional and brand level. Accor also utilize engagement channels such as their webpage (https://group.accor.com/en/commitment/planet-21/our-partners), social media platforms and their annual integrated report to communicate progress and performance in relation to diversity, challenges, strategy, and sustainability (https://group.accor.com/-/media/Corporate/Investors/Documents-de-reference/2019-integrated-report.pdf).

In 2009, Accor signed the Responsible Communications Charter, which was revised and consolidated to become the FAIRe program in 2018, which Accor is a signatory. Accor also contribute to local economic development through direct and indirect employment by promoting local recruitment practices and offering skills and technical training.

 

External grievances can be lodged on a variety of platforms including the Accor website, phone, email, social media and via Accor’s Integrity Line.

 

Local Access of Project Documentation:

Contact Person: Mokgadi Maunatlala

Company Name: Kasada Capital Management

Email:  mokgadi.maunatlala@kasada.com

Phone: +27 10 541 0923