OCP SA - UM6P Project
Environmental and Social Review Summary
UM6P University Campus
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.
Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.
MIGA has been requested to provide guarantees to cover loans provided by yet-to-be identified lenders to OCP S.A (OCP) for the construction and operation of a new university campus of the Mohammed VI Polytechnic University (UM6P) located in Rabat, Morocco (the Project).
UM6P is a private education institution offering vocational and technical training. It currently operates a campus in Ben Guerir which was established in 2015. The university’s educational and research & development programs are focused on the challenges faced by the African continent such as food security, urbanization, industrialization, and management of public policies.
The Project involves the expansion of UM6P through the construction of a campus near the city of Rabat, in Hssaine municipality and within the Technopolis, an existing technology park currently hosting another university as well as companies involved in engineering and product development. The Rabat campus will host the Faculty of Governance, Economics and Social Sciences (FGES) and have a targeted total capacity of 1,000 students. The campus will be developed in two phases. The construction for the first phase started in January 2021 and includes the FGES building, student center, theater, student accommodations, sport facilities and a hotel. The second phase, for which construction commenced in April 2021 involves additional school buildings for hotel management, artificial intelligence, digital learning, and languages, as well as laboratories, administrative buildings, health center, and a hotel. The hotels located within the campus will only be open for university guests, such as invited lecturers and visiting students.
The Project footprint will involve around 30 hectares within the Technopolis park. Technopolis was developed in 2007, on previously unused land which belonged to the Government.
A consortium of three EPC Contractors have been engaged for the construction of the Project. The EPC Contractors include Clemessy, SOGEA, and SGTM. Construction management and supervision have been delegated to JESA, an OCP group affiliate specialized in Engineering and Project Management.
The Project is a Category B under MIGA’s Policy on Environmental and Social Sustainability (2013). The Project is expected to have potentially limited adverse Environmental and Social (E&S) risks that are generally site specific, and can be addressed through the implementation of applicable Performance Standards (PSs), Environmental Health and Safety (EHS) guidelines, and design criteria. The key potential risks and impacts associated with the construction of the Project include i) environmental risks including waste management (solid and hazardous), water runoff, air and noise emissions; iv ) occupational health and safety risks; and iii) working conditions. During operations, the key potential risks and impacts include: i) fire and life safety; ii) emergency preparedness and response; iii) labor and working conditions; iv) environmental management including solid and hazardous waste; and v) resources efficiency (water & energy).
While all Performance Standards (PSs) are applicable to this investment, current information indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:
PS1: Assessment and Management of Environmental and Social Risks and Impacts
PS2: Labor and Working Conditions
PS3: Resource Efficiency and Pollution Prevention
PS4: Community Health, Safety and Security
The project is constructed on previously unused land owned by the Government, and PS5 does therefore not apply. Material impacts related to biodiversity or impacts related to Indigenous People’s are not expected, and therefore PS6 and PS7 does not apply.
In addition to the PSs, the World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines (2007) will also apply to this Project.
For this Project, MIGA’s environmental and social due diligence (ESDD) consisted of reviewing and discussing the following documents:
Sustainable Development Institutional Policy, UM6P.
Sustainable Development Plan of Actions, UM6P.
UM6P Green Map (Benguerir Campus)
Sustainable Development Best Practices Guide: For a More Sustainable Campus. UM6P.
Responsible Purchasing Charter, UM6P.
Sustainable Development Summary Report 2020, UM6P.
COVID-19 Disaster Recovery Plan, UM6P. September 2020.
COVID-19 Sanitary Protocols, UM6P. September 2020.
JESA HSE Management Program.
In addition to reviewing the above documents, MIGA carried out a combination of on-site visit and virtual (due to travel restriction related to the ongoing COVID-19 pandemic) environmental and social (E&S) due diligence. In April-May 2021 MIGA organized virtual meetings with key E&S staff and management, complemented by a MIGA-engaged local consultant’s E&S site visits in June 2021 which included meeting with community representatives, Project staff and local authorities.
MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps between these and MIGA’s E&S requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (“ESAP”) attached to this Environmental and Social Review Summary (“ESRS”). Through the implementation of these measures, the Project is expected to be designed and operated in accordance with MIGA’s Performance Standards.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Assessment and Management System
UM6P has established a system for managing environmental and social risks and impacts consisting of a set of policies and procedures as further described below. The policies and procedures apply to all UM6P operations and campuses and will be adopted for the operations of the Rabat campus.
For the construction phase, a Health, Safety and Environment (HSE) Management System is implemented based on JESA corporate policies, applicable local regulation and the requirements of PS1 as further described below.
UM6P has an Institutional Sustainability Policy in place, setting out the University’s objectives and guiding principles related to sustainable development. This includes aiming to be a benchmark and continuously improve processes and practices related to sustainability, the efficient use of resources, and to integrate sustainable development concepts in all education and research activities, as well as the operation of campuses.
The Sustainability Policy is approved and supported by the President of the University, and the implementation is coordinated by the Sustainable Development Department of UM6P. The Sustainability Policy applies to all UM6P activities, and will be adopted by the Rabat campus once operational (ESAP item).
The Sustainability Policy currently does not include provisions related to prevention of discrimination and gender-based violence among students and staff. UM6P will adopt and amend the Sustainability Policy for the campus in Rabat, to cover prohibition of discrimination and gender-based violence (ESAP item).
For the construction phase, the JESA sustainability policy statement is implemented through the HSE Management System. The EPC Contractors engaged for the construction of the Rabat campus also have corporate level HSE policies, applicable to the construction of the Project.
Identification of Risks and Impacts:
An E&S Impact Assessment study is not required for this Project, but UM6P has carried out a process for identification of E&S risks and impacts related to its educational activities and operation of the campus. Identified risks are described in the Sustainable Development Plan of Actions (SDPA) and include for example use of resources, waste management and recycling, emissions, health and safety of staff and students, biodiversity and community relations, as further described in the respective sections below. An SDPA will be specifically developed for the campus in Rabat (ESAP item).
Identification of risks and impacts related to the construction phase is conducted as part of the JESA HSE Management System, which includes risk assessments, and identification of environmental impacts associated with construction activities.
UM6P has established the SDPA building on the Sustainable Development Policy, and including a sustainability standard to measure and guide actions related to sustainability management consistent with the objectives of PS1.
The SDPA is based on the Sustainability Tracking, Assessment and Rating System (STARS), a sustainability management framework for universities to manage, measure and orient actions in terms of sustainable development through performance indicators and objectives, including criteria for monitoring educational activities in sustainability performance including risk assessment, capacity and training, community engagement, resource and energy efficiency, waste management and recycling, health & safety of staff and students, biodiversity, sustainable procurement and reporting. The PE will ensure that HSE risks and impacts identified in the EIA are appropriately addressed in the Project’s HSE management system. The same system will be applied to the campus in Rabat (ESAP item).
For the construction of the Rabat campus, the JESAs HSE Management System is implemented. The system is based on a Plan – Do – Check – Act process and placing the primary responsibility for implementation of HSE management programs on the EPC Contractors. HSE requirements are included in each EPC Contract, including the development of a project-specific HSE Plan for each contractor. EPC Contracts include obligations to adhere to EHS rules and requirements, including applicable national regulation and the Performance Standards, as well as the implementation of the HSE Plan.
Organizational Capacity and Competency:
UM6P has an established management structure for sustainability which includes the Sustainable Development Department (SDD), the HSE Department, and the Health Centre. The SDD oversees the implementation of the Sustainable Development Policy, Plan of Actions, and related initiatives, in collaboration with the HSE Department and the Health Centre. The SDD is headed by the Sustainability Manager, two Project Management Officers, two Project Manager and a community liaison officer in charge of social initiatives and community service projects.
The SDD is also supported by a Sustainable Development Committee consisting of representatives from researchers, teachers, students, and administrative staff. The Committee supports the SDD in its work, but also acts as an advisory body for sustainability initiatives in the University. The HSE department consist of a HSE Manager, supported by a team of HSE Officers.
As part of the HSE policy and Sustainable Development and the Plan of Actions, the HSE department trains regularly the students and university staff on topics related to sustainable development, emergency and preparedness, life and fire safety and fire drills among others. The HSE department is responsible for developing and implementing the training program.
For the construction phase, JESA has an HSE Manager in place with overall responsibility for the implementation of the HSE Management System. Each of the EPC Contractors have a full-time HSE Officer which reports to the JESA EHS Manager, and any sub-contractor engaged at the site is also required to appoint an HSE representative.
Emergency Preparedness and Response:
Procedures for Emergency Preparedness and Response Plan (EPRP) are included as part of the UM6P HSE program. This includes assessment of risks and hazards, training, evacuation procedures, and regular simulations and exercises. All premises are equipped with fire safety systems, and each building has designated teams training in fire and medical first response. For buildings where laboratories are located, an additional set of procedures are in place considering risks related to chemicals. An equivalent set of Emergency Preparedness and Response procedures will be established for the Rabat campus (ESAP item).
The HSE Plans for construction includes emergency preparedness and response procedures for the construction phase, including relevant emergency scenarios such as spills, leaks, fire, vehicle accidents, natural hazards, etc. The HSE Plans also includes a description of related roles and responsibilities, training and communication procedures in line with the requirements of PS1.
Monitoring and Review:
For the construction phase, the JESA HSE Management System includes a monitoring program consisting of HSE Audits, safety evaluations, and equipment inspections. In addition, the HSE Plan for each EPC Contractors includes a monitoring program developed in line with the requirements of the JESA HSE requirements (including the PSs) and considering the activities of the respective Contractor. Monthly HSE reports are prepared by JESA and submitted to UM6P.
During the operation phase, the SDD is responsible for monitoring key environmental aspects as set out by the SDPA, including solid wastes, hazardous waste materials management, occupational health and safety, life and fire safety equipment maintenance, energy use, water usage and report to PE and relevant regulatory authorities as required. The Project will also be required to submit to MIGA annual E&S monitoring reports to MIGA.
UM6P operates a communications strategy which includes stakeholder engagement activities both with prospective students and the public, including information campaigns, dissemination of results from research activities, operation of demonstration farms and plantations as well as an experimental mine with activities open to the public. Stakeholder engagement activities are coordinated by the SDD and led by the Community Liaison Officer.
Stakeholder engagement activities related to the construction of the campus in Rabat included information campaigns concerning construction traffic and the communication of a grievance mechanism, as described below.
External Communication and Grievance Mechanisms:
UM6P has an external communication channel and discloses sustainability-related policies and reports on a website specifically dedicated to sustainable development. A grievance mechanism is also in place, open to both students and the public through the external communications channel, including various modes of filing a complaint, such as the webpage, telephone, email, and social media channels. The grievance mechanism is operated by the Sustainability and Communication Departments.
The UM6P grievance mechanism is also available to any party affected by the construction activities in Rabat, and JESA also implements a grievance procedure that has been communicated to stakeholders through billboards and signs at the entry points of the Project construction site.
PS2: Labor and Working Conditions
During Construction, the EPC Contractors are expected to have up to 3000 construction workers including unskilled, skilled, supervisors, engineers and managers. Construction staff is primarily recruited locally from the Rabat region, and there is no accommodation for construction staff on the site.
During operations, the Project will employ approximately 250 staff including teachers, researchers, and administrative staff at the Rabat campus.
Human Resources Policies and Procedures:
UM6P has a set of Human Resources (HR) policies in place, including provisions for working conditions and terms of employment, written contracts for all employees, recruitment and retrenchment, grievance redressal, worker’s organizations, and occupation health and safety. The policies are based on Moroccan labor regulation, and in line with the requirements of PS2.
In line with the HR policies, recruitment and employment relationships are based on the principle of equal opportunity, with prohibitions of any forms of discrimination based on gender, sexual orientation, race and or color of skin, religion or political persuasion. In addition, UM6P has established Code of Conduct for both staff and students which includes the prohibition of discrimination and any forms of harassment, and a commitment to ensure equality of opportunity.
Following local regulation and the requirements of PS2, workers grievance mechanisms are available at both the Rabat construction site, and as part of UM6P HR policies. The mechanisms include the ability to make a report through different modes of communication, and anonymously.
Protecting the Work Force:
The HR policies for UM6P, JESA and EPC Contractors prohibit child and forced labor. For UM6P, all employees must be at least 18 years of age to qualify for a job as stipulated in Moroccan labor laws. The minimum age for employment is 18 years of age, for both UM6P and construction activities. All sub-contractors are required to implement the same requirement.
Occupational Health and Safety (OHS):
UM6P has a Health and Safety program in place, implemented by the HSE department. The program includes risk identification and prevention, training and information campaigns, accident and incident reporting and follow-up, as well as management of Health & Safety of contractors on the UM6P premises. The program is implemented in coordination with the UM6P Human Resources Department, and the Health Center. The Health Center is staffed by a doctor and nurses, and provides health care services to all students, academic staff and non-academic staff, including Students Health service, Occupational Health Service, Psychological Support Unit, Food Quality Hygiene & Safety Department, Event Safety Unit, and a Lab of analyzes & research applied to food safety.
In response to the COVID-19 pandemic, UM6P has implemented a set of protocols and measures to minimize infections and impacts. The protocols include rules for educational activities such as social distancing, options for remote learning, provision and use of PPEs, disinfection, health screens, limitation of large gatherings, and rules to follow and support in case of an infection. Information and awareness campaigns have also been implemented to ensure implementation of the protocols and recommendations.
During construction, the OHS risks include those typically associated with construction (e.g. noise, vibration, rotating and moving equipment, heavy vehicle operation and site traffic). The JESA HSE Management System and the HSE Plan includes programs and procedures related to OHS, including risk assessment, mitigation controls, permit to work system, use of PPEs, toolbox talks, training and supervision, safety board and visual management, and evacuation drills. Weekly HSE coordination meetings are conducted between JESA and the Contractors, and the implementation of all procedures related HSE are reviewed as part of the HSE Auditing program. JESA’s HSE team maintains a record of occupational incidents accidents, and traffic incidents and that corrective measures are taken to prevent recurrence.
A site-specific COVID-19 management plan has been developed to ensure that the risks associated with COVID-19 are adequately addressed for the Project during the construction. The Plan includes risk assessment, mitigation measures, training and awareness, medical and emergency plan, communication and reporting process, and inspection program.
Workers Engaged by Third Parties and Supply Chain:
The JESA’s EHS Management System sets out obligations for contractors and sub-contractors including health and safety management and labor standards as described above.
UM6P has contractors on its campus to provide services related to food and dining, cleaning and technical maintenance. To manage contractors and service providers, UM6P has developed a Responsible Purchasing Charter which describes the University’s commitment to acquisition of goods and services from suppliers that respect the fundamental rights of individuals, including employees, and that commit to responsible practices. The Responsible Purchasing Charter includes sustainability criteria applicable to third parties and suppliers, including specific prohibition of child and forced labor and consistent with the requirements of PS2.
PS3: Resource Efficiency and Pollution Prevention
The UM6P Sustainable Development Plan of Actions (SDPA) includes programs related to resource efficiency including for example energy, water, and greenhouse gas emissions. Resource efficiency criteria and requirements have been defined for building design and maintenance, use of clean energy, food and beverage purchasing and recycling, landscape management, procurement and use of office supplies, transportation, water use and rainwater management.
Resource efficiency considerations during construction include water resource use and potential greenhouse gas emissions. A limited amount of greenhouse gases will be emitted as part of construction activities, primarily associated with the operation of construction machinery and backup generators. During operations, emission of greenhouse gases will be limited.
During the construction, the water usage will primarily be linked to washing, preparing concrete, dust suppression and domestic drinking water consumed by workers. The EHS plans include water management procedures, for both use and treatment.
During operations, the water usage is linked to domestic use, sanitation and drinking water and managed as part of the SDPA.
Environmental pollution related to the operation of the campus is primarily made up of waste generation and wastewater. The SDPA includes programs for minimization and recycling, storage and procedures for pick-up of waste by licensed contractors. Limited hazardous waste will be handled on the campus, such as electronic waste, and cans/packaging from oils or paints used for maintenance of buildings. The SPDA includes procedures for disposal of different categories of hazardous waste, minimizing its presence on the campus, and pickup by third-party contractors.
For the campus in Rabat, a rainwater harvesting system will be in place, and the campus will be connected to the municipal network for wastewater treatment.
Pollution impacts and risks during construction include noise, air emissions, effluent, solid waste generation and hazardous materials storage, use, handling and disposal. During construction, limited amounts of air, noise and water emissions and soil erosion are anticipated, which is mitigated through standard pollution prevention and control measures set out in the JESA EHS Management System and the EHS Plans. As part of the JESA’s EHS Management System, EPC Contractors are required to implement pollution prevention measures to mitigate the risk of any pollution, also including specific provisions for erosion and sediment control, effluent management, chemical management, and waste management.
PS4: Community Health, Safety and Security
Community Health and Safety:
The construction of the Rabat campus takes place within the Technopolis park and impacts related to community health and safety are primarily linked to increased traffic to and from the park. There is no accommodation for construction workers on the site, and impacts related to influx has not been identified.
The engineering design of the campus buildings have been reviewed by JESA, and deemed in line with good international industrial practices for fire and life safety as described under PS1. To mitigate risks related to gender-based violence in the university, a gender and gender-based violence awareness program will be implemented at the Rabat campus (ESAP item) in line with the recommendations of the IFC Sector Brief on Addressing Gender-Based Violence and Harassment (GBVH) in the Education Sector.
Food safety procedures in on-campus restaurants and cafeterias are reviewed by the Health Centre, staffed by an industrial food safety engineer, including monitoring of hygiene practices, supplier’s audits, sampling and testing, and training of staff. UM6P food safety procedures are based on the requirements of ISO 22000 (Food Safety Management) and those same procedures will be followed at the Rabat campus.
The EHS Management Plans include procedures for management of construction traffic safety, including use of vehicles, speed limits and signage, protocol for loading/unloading, vehicle maintenance and refueling, and cleaning of vehicles prior to leaving the construction site.
The EPC Contractors have engaged a private security contractor licensed by the Government for the construction phase. During operations, UM6P manages its own security and has established a Security Management Plan including provision of security guards, security vehicles and access control, and a video surveillance system.
For the campus in Rabat, UM6P will establish a Security Management Plan including a code of conduct and rules for use of force in line with the requirements of PS4 (ESAP item).
Broad Community Support is not applicable for this Project.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
The above documentation is also available at the UM6P website: https://sd.um6p.ma/
For additional information on the Project, please contact:
UM6P Communications Department
Phone: +212 525 073 100
MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.
In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.
Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.
Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:
International Finance Corporation
2121 Pennsylvania Avenue NW
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400