Kasada Hospitality Fund LP
ENVIRONMENTAL AND SOCIAL REVIEW SUMMARY
Kasada Hospitality Fund (#15036, #15071, #15028; Ivory Coast, Senegal, Rwanda)
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 (www.kasada.com). Kasada is the first large-sized, professionally sponsored and managed hospitality investment platform in Sub-Saharan Africa (SSA). Between 2021-2024 Kasada plans to build a portfolio of hotels in SSA primarily through the acquisition of existing and operating (brownfield) hotels as well as the development of a smaller number of new (greenfield) hotel developments. In the context of this report, greenfield hotels are considered to be both any new hotel developments, as well as those hotels which require extensive refurbishment prior to operation.
The first phase (the “Project”), implemented over a period of approximately 24 months, will comprise the acquisition, development, 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 greenfield hotels). Following each acquisition, the relevant hotels are developed or converted into and operated under the Accor hotels management and branding. To this end, all acquisitions will comprise financing for (i) providing liquidity injections to ensure the functioning of these hotels in the COVID-19 environment (when applicable) and (ii) capital expenditure / improvements to ensure the hotels’ compliance to Accor standards and to achieve higher operating efficiencies.
Senior debt for Phase 1 will be primarily provided by IFC on IFC’s own account and through syndications.
In addition, MIGA will provide a total coverage of up to €225.9 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. See the Summary of Proposed Guarantee for further details.
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.
As of May 2023, the following four sub-projects have been disclosed:
- Project Ayaba, which comprised the acquisition of 8 existing Accor-managed hotels (under the Pullman, Novotel and Ibis brands) in Abidjan, Cote d’Ivoire (4 hotels); Dakar, Senegal (3 hotels); and Douala, Cameroon (1 hotel).
- Project Wind, which included the acquisition of the Safari Hotel, Safari Court Hotel and associated conference center, located in Windhoek, Namibia.
- Project Umbrella, which included the acquisition and refurbishment of the Crowne Plaza in Nairobi, Kenya.
- Project Galaxy, which included the acquisition, refurbishment and expansion of the Southern Sun Ikoyi hotel in Lagos, Nigeria, together with an adjacent commercial property to be redeveloped for hospitality uses.
Project Ayaba is under IFCs financing package; accordingly, IFC has led in carrying out environmental and social due diligence (ESDD) for this sub-project, and disclosed the associated ESRS and associated Environmental and Social Action Plan (ESAP), on March 2021. As the other sub-projects are currently relying on alternative financing (or financing agreements between the IFC and Kasada have not been finalized as of the time of writing), MIGA coordinated the relevant ESDD activities and associated disclosure of the ESRS and the ESAP reports.
Details about the above-mentioned sub-projects are provided in the Project Briefs:
- Kasada Hospitality Fund LP (Senegal);
- Kasada Hospitality Fund LP (Cote D' Ivoire);
- Kasada Hospitality Fund LP (Cameroon);
- Kasada Hospitality Fund LP (Namibia);
- Kasada Hospitality Fund LP (Kenya);
- Kasada Hospitality Fund LP (Nigeria).
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) the state of hospitality industry relations in the country and the level of engagement with labour 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.
This ESRS initially focussed on the 8 hotels acquired under the first sub-project, Project Ayaba, and was disclosed in March 2021. It has since been updated to include the following sub-projects:
- Project Wind, disclosed in April 2022;
- Project Umbrella, disclosed in December 2022;
- Project Galaxy, disclosed in February 2023.
This ESRS is being updated to reflect three new sub-projects:
- Project Cosmos, which includes the development of the Ibis and Adagio hotels in Abidjan, Ivory Coast, together with a co-working space and a meeting, incentives, conferences and exhibitions (MICE) area; the hotels will be part of a larger mall complex, which development and operation will be independent from Project Cosmos.
- Project Kiwi, which includes the acquisition of the Umubano hotel in Kigali, Rwanda, and its full refurbishment to upscale standards.
- Project Lausanne, which includes the acquisition and refurbishment of the Lamantin Beach and Blue Bay, located in Saly, Senegal.
Each sub-project was subject to further Environmental and Social (E&S) due diligence, and relevant findings were reflected within each subsequent version of the ESRS; when deemed necessary, the ESAP was also subject to revision. Should additional hotels be acquired under further sub-projects, they will be also subject to further E&S due diligence, and the ESRS updated as necessary. In cases where IFC is not supporting the sub-project, MIGA will update the IFC ESRS and disclose it on its website.
The initial ESRS included a desktop appraisal 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 also encompassed 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.
Throughout the subsequent acquisitions and related updates of the ESRS, the following field appraisals were undertaken:
- The field appraisal for Project Ayaba, led by IFC and conducted on 26 and 27 January 2021, which consisted of site visits to three hotels (Pullman, Ibis and Novotel) located in Dakar, Senegal;
- The field appraisal for Project Wind, led by IFC and conducted from 18 to 20 October 2021, which included site visits to both hotels located in Windhoek, Namibia;
- The field appraisal for Project Umbrella, led by IFC and conducted from 6 to 8 June 2022, which included a site visit to the Crowne Plaza hotel, located in Nairobi, Kenya;
- The field appraisal for Project Galaxy, led by MIGA and conducted from 30 November to 3 December 2022, which included the site visit to the Southern Ikoyi Sun Hotel, in Lagos, Nigeria;
- The field appraisal for Project Kiwi, led by MIGA and conducted on the 15 of May 2023, which included the site visit to the Umubano Hotel, in Kigali, Rwanda.
Due diligence for the three new sub projects (Cosmos, Lausanne and Kiwi) includes desktop review of E&S documents. For Project Cosmos, a review of the E&S documentation for the larger mall complex development was undertaken, and further E&S studies have been required as part of the ESAP; the site was also inspected through the review of high-resolution drone footage.
Field appraisal for Project Lausanne is expected to be completed in May 2023. If impacts or risks not currently identified in this ESRS are found during the site visit, or through forthcoming due diligence documentation, the ESRS will be revised; if the differences are material, MIGA may re-commence the disclosure period.
The primary objectives of the field visits were to assess 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 reports carried out for the hotels, and assess the level and efficacy relating to the implementation of various E&S policies and approaches.
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;
PS 6 - Biodiversity Conservation and Sustainable Natural Resource Management (for Project Lausanne).
The project primarily involves the acquisition of existing operational hotels, the acquisition, renovation and completion of under-construction greenfield hotels, and the development of greenfield hotels (only Project Cosmos at the time of writing). Hence, it is not anticipated that the fund will undertake much land acquisition for the development of their Phase 1 hotel portfolio. None of the sub-projects assessed to date entailed any form of involuntary displacement or resettlement. 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 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, PS7: Indigenous Peoples and PS8: Cultural Heritage.
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 IFC’s/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:
As the Project includes greenfield and brownfield developments, Kasada is required to ensure that an Environmental and Social Management System (ESMS) is in place for the management of both the construction and operation activities of its portfolio.
Approach to greenfield construction activities:
As Kasada had initially been acquiring existing hotels, an ESMS for greenfield projects was not required. Now with the construction of Project Cosmos and major renovations at Kiwi, Kasada is in the process of defining an ESMS in line with PS 1 requirements to apply to greenfield sub-projects.
Some elements of an ESMS are already embedded in the practices that Kasada’s construction team implement. For example, the Environmental and Social Impact Assessment (ESIA) processes and the associated management plans required for each greenfield intervention, provide a mechanism to identify and address risks and impacts. Furthermore, Kasada construction team’s reliance on reputable consultants ensure an appropriate level of organizational capacity and competency, and robust monitoring and reviewing capabilities. Finally, for Projects Cosmos and Kiwi, Kasada is already developing a framework of environmental and health and safety management programs for construction, aligned to international best practices.
To formalize and consolidate its approach for greenfield sub-projects, Kasada will develop a Construction ESMP (ESMS-C) focused on construction activities and aligned with PS 1 requirements (ESAP 1).
Kasada will apply the ESMS-C to construction activities for subprojects Cosmos and Kiwi, which represent their first greenfield sub-projects (ESAP 1.iv).
Approach to hotel operations:
All assets acquired and developed under Phase I of the Project will be operated and managed by the Accor Group (“Accor” or the “operator”). As defined in the Hotel Management Agreements (HMA) with each respective hotel, Accor has the sole and exclusive control of the hotels in terms of management approaches and the determination and implementation of all policies and procedures, including Accor’s 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 & life safety, and security. In addition, all hotels will implement Accor’s Planet 21 program (or its subsequent versions) 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.
Prior to Kasada’s acquisition, Project Wind, Umbrella and Lausanne were privately managed assets. These hotels only had partial elements of an ESMS and are transitioning to Accor policies and procedures, including a formal ESMS as required by MIGA/IFC Performance Standard 1. Project Galaxy was managed under the corporate Southern Sun Environmental Management System (EMS) which included processes and procedures for the management of the key environmental and health and safety aspects of the business. This EMS was deemed to be broadly adequate and appropriately implemented; however, minor shortcomings were identified regarding human resources practices, social issues management, and engagement of workers.
Following the acquisition of the hotels, Accor will transition the hotels to their existing policies and ESMS over a period defined in the ESAP for each sub-project (ESAP 2). To this end, 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.
Identification of Risks and Impacts:
Mechanisms for the identification of risks and impacts in the context of the sub-projects are in place and consist of a combination of due diligence and ESIAs processes.
For the acquisition of greenfield hotels, Kasada has developed a screening procedure to assess the applicability and compliance of all the PSs; this procedure specifies investment eligibility criteria and standard operating methodologies for conducting E&S due diligence against local host country requirements and IFC/MIGA Performance Standards.
Alternatively, each greenfield sub-project is subject to an ESIA process that serves as a mechanism to identify E&S risks and impacts. A first draft of the ESIA for Project Kiwi has been completed in May 2023. The ESIA for Projects Cosmos is currently under development and will be submitted to MIGA by June 2023. For Project Lausanne, Kasada will complete an ESIA covering both the existing hotel the proposed upgrades, and construction relating to the existing marina. The ESIAs will be conducted in accordance with both local legislative requirements, as well as IFC PS requirements, and will be submitted to MIGA. All ESIAs process must be completed and completed as final version by September 2023 (ESAP 3).
Based on available information regarding these sites and the intended interventions, these sub-projects have limited adverse environmental and social risks and impacts that are site-specific, and can be avoided or mitigated by adhering to recognized GIIP (coherently with the E&S Category B).
For brownfield subprojects Kasada undertakes both pre- and post-acquisition due diligence processes. The existing pre-acquisition process predominantly relates to technical, financial, E&S, 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, Umbrella, Lausanne and Galaxy, Kasada also procured an independent pre-acquisition E&S audit of the hotels against the requirements of relevant local legislation and IFC/MIGA Performance Standards, with a focus on Life & Fire Safety (L&FS), and food and hygiene.
For greenfield sub-projects and projects potentially exposed to significant climate-related risks, Kasada will undertake climate risk assessment covering the following climate-related risks: floods due to extreme rainfalls or river flooding, hurricanes, cyclones, sea level rise, extreme temperatures (ESAP 4). This assessment should cover a time horizon of at least 20 years, or alternatively the lifetime of the sub-project. If significant and material risks are identified, Kasada will establish and implement necessary measures to mitigate such risks; these can include land levelling, improvements in drainage system, stormwater barriers and drainage lines.
Organizational Capacity and Competency:
Kasada has sufficient capacity at the Fund level to oversee its current Portfolio, including construction and operations. Kasada employs a dedicated E&S Manager to provide monitoring and oversight of its hotel portfolio. This role is supported by the general counsel, asset managers and the technical and construction team. As Kasada’s portfolio grew through ongoing acquisitions, as of May 2023 the Fund had appointed one general E&S coordinator for English speaking countries, with an imminent appointment of a coordinator for French speaking countries.
Kasada’s construction team manages greenfield sub-projects and is responsible for the design and quality standards of the hotels, selecting construction contractors, overseeing construction E&S management. Kasada’s construction team is supported by project management and construction consultants with regional experience.
Accor is responsible for hotel operations, per the hotel management agreements, including sustainability, crises management, occupational health and safety, security, provide Kasada with ongoing E&S oversight and monitoring support, and monitoring function to Kasada. With reference to the HMA’s, Accor, as the operator of the hotels, retains unfettered management control of the hotel, including recruitment; however, some recruiting, including the employment of the General Manager, must be agreed by Kasada. At 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 Kasada and Accor key performance indicators (KPIs).
Emergency Preparedness and Response:
For greenfield projects and associated construction activities, requirements for emergency Preparedness and Response procedures will be included as part of the ESMS-C.
In respect of operating hotels, 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.
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 a component of the transition to an Accor-managed hotel, any sub-project and its related hotels are required to implement the Accor ALLSAFE program. In addition, Kasada will obtain SAFEhotels certification for their hotels, that includes a hygiene element (further detail included under Performance Standard 4).
Monitoring and Review:
For greenfield projects and associated construction activities, monitoring and review practices will be formalized within the ESMS-C. These practices will build upon the current approaches and standards of work implemented by Kasada’s construction team.
In respect of the hotels in operation, the Fund has developed initial 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:
For greenfield projects and associated construction activities, the ESMS-C will define minimum terms of employment and working conditions for construction contractors and oversight of contractors’ labor practices; these parties will be required to operate in accordance with PS 2 and any other national requirements.
In respect of the hotels in operation, as per the HMAs, it is agreed that Accor has unfettered management control and absolute discretion, in relation to all human resources (HR) matters of the hotel employees including recruiting, secondment, training, supervisions, promoting, discharging, liaising with and negotiating with workers unions. 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.
At the close of the transaction, the eight Project Ayaba hotels had a total of 635 employees (approximately 66% male and 34% female); Project Umbrella had 38 employees, Project Wind 76 and Project Galaxy approximately 180 employees; at the time of due diligence Project Lausanne had approximately 240 employees. Construction workforce for Projects Cosmos and Kiwi has not been confirmed as of the time of writing, however each sub-project is not expected to employ more than 200 workers at peak. Hotel employees are predominantly engaged in the areas of management, human resources, front of house, housekeeping, food and beverage services, maintenance, IT, administration, sales, and marketing. It is understood that the use of third-party workers is mostly limited to restaurant and gardening staff (when applicable). The majority of employees are provided with open ended (permanent) contracts, while a smaller number with term (temporary) contracts. All hotels also employed a number of contractors provided through third-parties including security guards, gardeners, maintenance staff etc. The majority of employees at each hotel are locally sourced, with few expats mostly engaged in management functions.
Labor and Working Conditions:
In respect of the hotels in operation, all operating hotels have transitioned or are transitioning into 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, which 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 hotel, prior to acquisition a collective bargaining agreement was not present and hence labor and working conditions were defined by local legislative requirements. Within the Project Umbrella, labor and working conditions were defined by Kenyan legislative requirements and detailed within the staff handbook. This covered areas of non-discrimination and equal opportunity, retrenchment, and employee grievance management.
For Project Galaxy, labor and working conditions were defined by Nigerian labor requirements, and, under the previous ownership, working conditions were managed according to Human Resources (HR) handbook, which was deemed broadly aligned with minor gaps against IFC/MIGA PS2.
For Project Lausanne, labor and working conditions were defined by Senegalese labor requirements.
Following each respective acquisition and transition to Accor’s operatorship, all workers are provided with new contracts to ensure alignment with local legislative requirements as well as Accor procedures and policies.
Within the first six months of Accor assuming operations of the respective hotels, Kasada will commission an independent labor audit to verify compliance of labor conditions with local legislation, Accor policies and procedures and PS 2 requirements (ESAP 5).
This audit will cover areas relating but not limited to labor and working conditions, relations with the hospitality industry representatives and unions, occupational safety and comfort of working areas, hiring, compensation and benefits, employee relations, and security. Where gaps or non-alignment are identified, corrective actions will be implemented through a timebound action plan.
In the context of greenfield projects, construction workers will have freedom of association and the ability to bargain collectively, and this notion will be reflected in the ESMS-C.
In respect of the hotels in operation, 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 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 included a training schedule of all Kasada and Accor management and heads of department on the requirements of Performance Standard 2.
At the time of carrying out due diligence for Project Wind, eight employees were unionized with the Namibia Food and Allied Workers Union (NAFAU) and there was 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.
At the time of due diligence for Project Umbrella, Galaxy and Lausanne, a defined approach or policy regarding freedom of association or collective bargaining was lacking; however, Project Umbrella had several employees who are members of the Kenya Union of Domestic, Hotels, Educational Institutions and Hospital Workers (KUDHEIHA). None of the employees at Project Galaxy and Lausanne were unionized.
As a component of the transition to an Accor ESMS (ESAP 1), every 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:
In the context of greenfield projects and construction activities, provisions for equal working conditions and opportunity as well as non-discrimination requirements will be specified in the ESMS-C.
In respect of the hotels in operation, 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 and the 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.
In respect of the hotels in operation, based on the available information, 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.
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.
Regarding Project Galaxy, Kasada reported that employees were not retrenched during the pandemic, however some staff were placed on mandatory leave with salary reduction. During this period, the medical and pension coverage for all the employees were not affected; only bonuses, leave and transport allowances, and long-term service awards were suspended. Employees’ salaries and all benefits were reinstated up to the pre-COVID regime on 1st September 2021.
Kasada reported that the previous hotel owner of Project Lausanne did not undertake any retrenchment, despite being closed for a three-month period in 2020.
In the context of greenfield projects, the appointed construction contractors will be required to implement a workers grievance mechanism, which terms and minimum requirements will be specified in the ESMS-C.
In respect of the hotels in operation, Accor has developed a grievance procedure that will be applied across all sub-projects. The procedure details the process for raising grievances, timelines for feedback and resolution, documentation and the appeal process.
Furthermore, 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 hotel level and that was re-aligned with the Accor standards and requirements following change of operatorship.
At the time of due diligence, Project Umbrella and Galaxy lacked a formal documented employee grievance policy. Following transition to Accor’s operatorship, these sub-projects are implementing Accor grievance procedure, as well as their whistleblowing hotline. Similarly, Project Lausanne does not have any formal grievance mechanism in place, and will incorporate Accor grievance policies and procedures (ESAP 6).
Protecting the Workforce:
The ESMS-C for greenfield projects will incorporate appropriate policies prohibiting child and force labor.
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:
In the context of greenfield projects, the ESMS-C will define specific Occupational Health and Safety (OHS) requirements for construction workers. The OHS requirements will include, among others, mechanism to identify OHS hazards in working areas and activities, minimum management planning requirements to be adopted by contractors, training provisions, monitoring, supervision, and reporting regime. OHS management plans implemented on site must be aligned with the relevant provisions of the PSs and the relevant EHS Guidelines (especially with the construction and decommissioning provisions included in the General EHS Guidelines).
In respect of minor refurbishment activities, 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.
Accor has developed and will implement policies and procedures identifying specific occupational health and safety risks in its hotels and which will be applicable to all hotels (ESAP 1). Occupational Health and Safety is reiterated in the 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.
Third Party Workers
In the context of greenfield projects, activities performed by construction contractors will be supervised by Kasada through the implementation of the ESMS-C.
In respect of the hotels in operation, 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, garden maintenance, restaurant services (when applicable). Upon each hotel’s acquisition, 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.
Gender-Based Violence and Harassment (GBVH):
As part of the ESMS-C and in the context of construction activities, Kasada will develop mechanisms for addressing risk of harassment from (including sexual harassment and Gender-Based Violence Harassment (GBVH)) in line with PS 2.
To this end, the ESMS-C should specify the code of conduct to be adopted by construction workers in respect of GBVH matters, and include training requirements on identification and reporting on sexual harassment and GBVH.
PS 3: Resources Efficiency and Pollution Prevention
Resource efficiency will be considered, where applicable, during construction, and commitments will be included in the ESMS-C.
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 to achieve EDGE certification for all sub-projects and hotels by demonstrating at minimum 20% savings in energy, water and embodied energy in materials. Kasada will also look to achieve a 10% per room energy reduction by year two of operation.
Greenhouse Gas Emissions:
Greenhouse Gas (GHG) emission sources will be mainly related to hotel operations, and more specifically to grid electricity consumption and diesel emissions from back-up generators. 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.
Kasada, as a component of their monitoring framework, will monitor and record resource usage, including water, energy, fuel (when applicable) as well as their estimated gross GHG emissions from all the hotels.
Pollution Prevention and Waste Management:
In the context of greenfield projects, the ESMS-C will define specific pollution prevention and waste management requirements for construction workers. These requirements will include, among others, mechanisms to identify sources of pollution and sensitive receptors in the construction area, minimum environmental management requirements to be adopted by contractors, training provisions, monitoring, supervision, and reporting regime. Pollution prevention and waste management plans implemented on site must be aligned the relevant provisions of the PSs and the relevant EHS Guidelines (especially the construction and decommissioning provisions included in the General EHS Guidelines).
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.
PS 4: Community Health, Safety and Security
Community Health and Safety:
In the context of greenfield projects, key community health and safety impacts are temporary and result from construction activities include dust emissions, noise, vibration, construction-related traffic and disruption.
The ESMS-C will include a process to identify community health and safety risks and respective mitigation measures, community engagement and provision of safety information and awareness campaigns for surrounding communities. Where there are potential impacts to communities, contractors will be required to have a dedicated community liaison officer to receive and respond to grievances raised as well as provide information on the status and progress of the project.
Accor has 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 conducts independent audits of all hotels acquired to date 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 had 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.
Project Galaxy is subject to regular inspections of food safety undertaken by the relevant authorities, and the internal audit system assessed compliance with HACCP protocols. Employees working in the kitchen areas are trained in hygienic food preparation, storage, and processing.
Employees at Project Lausanne receive annual training on safe food handling and hygiene.
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 eventual 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 only ensured compliance with local Namibian L&FS regulations and have achieved certification on this basis. The hotels undertook 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 of this audit, to address the identified gaps with local legislative requirements and World Bank Group EHS Guidelines, were provided to and agreed upon with MIGA.
L&FS at the Project Umbrella hotel 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 is in possession of a current fire clearance certificate. As a component of the Project Umbrella refurbishment, two existing floors will be converted into a coworking space managed under the WOJO franchise. The coworking space will operate separately from the hotel while implementing its own policies and principles. As owners, Kasada will retain overall control of the asset, including ensuring adequate L&FS provisions as detailed under PS4.
Regarding Project Galaxy, the L&FS systems follow the design, maintenance, and auditing requirements of national and state legislation, holding valid certificates from the council demonstrating the adequacy of the fire systems in place. All auxiliary firefighting equipment assessed during the site visit showed valid service history documentation and appeared to be in good condition. Operations procedures outlined specific firefighting techniques relevant to the use of the equipment. The maintenance staff also regularly conducts internal audits on fire safety systems, infrastructure, training, as well as quarterly fire drills. Audit results reflected an appropriate performance in both fire protection and safety.
At the time of acquisition, L&FS at the Project Lausanne hotel was not aligned with either local fire security regulations or international standards and therefore, L&FS is required to be upgraded as a component of Kasada’s refurbishment process (ESAP 7).
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. In addition, Kasada will obtain SAFE certification (https://safehotels.com/) for their hotels, that covers L&FS, including detection, suppression, equipment and infrastructure, evacuation, training, and certification (ESAP 7).
For greenfield projects, the ESMS-C will include specific requirements regarding security at construction sites, site access control, establishing minimum requirements for security personnel and companies and a code of conduct, in accordance with national laws and PS 4.
Once in operation, 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 Senegal, Cameroon and Ivory Coast is provided by private third-party contractors. At the time of IFC appraisal for Project Ayaba (2021), due to perceived terrorism threats in the region, the Senegalese government was providing 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.
At the time of due diligence, security at the Project Wind was also provided by a third-party contractor who is responsible for vetting and ongoing training of their guards, and the hotel also employed a permanent security supervisor. The hotel underwent the necessary requirements, as per the Task World platform, to transition to the Accor Global Security Standard. This included conducting a comprehensive Security Risk Assessment which was 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.
Project Galaxy employs the services of a specialized international firm for conducting security services. Access to the hotel is controlled, and the perimeter of the property is regularly patrolled. The security provider and their employees are registered with the regulatory authority governing the legislation on private security services.
At the time of due diligence, all subprojects were required to undergo the necessary requirements, as per the Task World platform, to transition to the Accor Global Security Standard. Furthermore, Kasada is 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 (ESAP 7).
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project Lausanne hotel is located within a Key Biodiversity Area (KBA) along the Petite Côte, Senegal. Historically, the area was a significant fishing community, however, the area is now heavily urbanized and degraded from a biodiversity perspective. While the KBA comprises a wide area of approximately 25,000 ha, the only designated protected area is an avifauna reserve of 1,000 ha which is located over 12km away. Hence, no additional impacts to critical habitat stemming from the operation of Project Lausanne is envisaged.
As per ESAP 3, Kasada will conduct an ESIA for the refurbishment/upgrades planned for the Project Lausanne, including the identification of potential biodiversity impacts and related management practices. The scope of the ESIA will cover areas located along the coastline in the vicinity of the project. In addition, Kasada will assess the impact of ongoing coastal erosion, and propose mitigation measures aligned with good international industry practice and, when required, existing measures being implemented by Centre de Suivi Ecologique (CSE).
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: Pierre Etienne de Montgrand
Company Name: Kasada Capital Management
Phone: +27 10 541 0906