The proposed IFC equity investment in Healthcare Global Enterprises Ltd ("HCG" or the "Company") is a part of the equity issuance of the HCG initial public offering ("IPO"). The HCG network of cancer centers is the largest provider of cancer care in India as measured by the number of cancer treatment centers licensed by the Atomic Energy Regulatory Board (AERB), treating approximately 37,500 new patients per year (as of March 31, 2015) in India with 14 existing comprehensive cancer centers (CCCs), 3 diagnostics centers and 1 day care chemotherapy center.The company's cancer care network currently has 1,100 beds in operation (including 181 self-care beds) and spans 13 cities and towns across eight states in India.The company broadly establishes its CCC's under two constructs:Free standing/stand-alone CCCs : [ten out of the 14 of the existing HCG CCCs and 10 out of the 12 of the proposed CCCs]; andCCCs within the premises of another tertiary care hospital, wherein HCG establishes and has exclusive rights to operate the cancer center in said hospital [four out of the 14 and two out of the 12].Of the Free Standing CCC's, except for its Bangalore center of excellence (CoE) (for which the land is part owned and part leased), the CCCs at Double Road, Vijayawada and Ongole, Ahmedabad and the upcoming CCC at Kanpur, the company does not typically own the land and building for its CCCs. Typically the company enters into long term lease agreements with third party owners. In all such cases the lease is usually a fixed monthly rental and in a few cases the lease rental includes a variable component. For the CCCs housed within another hospital, HCG typically pays a share of revenue earned by the center to the partner hospital.In addition to the cancer care network, the company has two multispecialty hospitals in Ahmedabad and Bhavnagar (110 and 92 beds (of which 35 are operational currently), respectively). In 2013, HCG acquired a 50.1% stake in BACC healthcare, allowing it to operate four fertility centers in Bengaluru under the brand Milann. Also, the company has entered into a definitive agreement with a developmental finance institution to invest in HCG Africa, which has been formed to establish a network of CCCs in Africa.The company is planning an IPO, proceeds of which would help finance; (a) capital expenditures for 12 new CCCs in India which are in various stages of development; (b) purchasing of medical equipment at the existing 14 CCCs; (c) a major upgrade to the information technology (IT) systems, and (d) repayment of debt ("the Project").IFC would potentially be an "anchor" investor in the IPO with a straight equity investment of US$15 million equivalent [Indian Rupees (INR) 1,000 million].
OVERVIEW OF IFC'S SCOPE OF REVIEW
IFC's review of the proposed investment consisted of appraising technical, environmental, health and safety (EHS) and social information submitted by HCG including on Human Resource (HR) (HR) policies, EHS policy, quality management system documentation including various policies, manuals and procedures, and information related to life and fire safety. In addition, discussions with held with the company's corporate management from quality, legal, projects and HR departments as well as facility level quality and safety staff.The appraisal also included site visits in December 2015 and January 2016 to HCG's:CoE in Bengaluru (five towers, two of them owned by HCG and remaining on lease);CCC in New Delhi (part of a multi-specialty hospital);Multi-specialty hospital (independent building owned by HCG); andCCC in Ahmedabad (independent building leased by HCG);
IDENTIFIED APPLICABLE PERFORMANCE STANDARDS**
While all Performance Standards are applicable to this investment, IFC's environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards.PS 1 - Assessment and Management of Environmental and Social Risks and ImpactsPS 2 - Labor and working conditionsPS 3 - Resource Efficiency and Pollution PreventionPS 4 - Community Health, Safety and SecurityIf IFC's investment proceeds, IFC will periodically review the the project's ongoing compliance with the Performance Standards
As mentioned above, except for the Bengaluru CoE (the land for which is part leased and part owned), Ahmedabad hospital and a CCC in Vijayawada, building in Double Road and Ongole, the company has established and operates its centers/hospitals in leased buildings and this is expected to continue in the future in majority of the centers Therefore, no land acquisition is envisaged for the project and no physical or economic displacement has been/is expected to be caused by the company's activities; consequently, IFC Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) is not applicable.The existing centers and those proposed will be located in urban or sub-urban areas and, therefore, the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable. Going forward, as part of the management systems and procedures (discussed below under PS1), HCG will screen future projects with respect to IFC PSs requirements.
ENVIRONMENTAL AND SOCIAL CATEGORIZATION AND RATIONALE
Key E&S risks and issues related to this Category B Project include: adequate social and environmental assessment of the Project impacts; the company's capacity and systems to manage social, environmental, health and safety aspects of its existing and proposed operations in compliance with legal requirements as well as IFC Performance Standards (PSs) and the World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines; assurance of fair, safe and healthy working conditions during both construction and operation; management of wastes (particularly biomedical and hazardous waste), emissions and effluents; life and fire safety (L&FS) management for all hospital buildings in accordance with WBG EHS guidelines; and resource efficiency (water and energy efficiency).
**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability
ENVIRONMENTAL AND SOCIAL MITIGATION MEASURES
IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFC'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
Policy: HCG formulated a Corporate EHS Policy in August 2015 which covers pollution prevention; environmental protection; risk control; safety; compliance to regulations; and continual quality improvement aspects. The company is in the process of implementing a Quality Management System (QMS) across all operations as per the requirement of India's National Accreditation Board for Hospitals and Healthcare Providers (NABH) standards and this is in accordance with the corporate level quality policy and procedures. The same policy is implemented across all its centers/hospitals (even if the CCC/hospital is not NABH accredited/certified).Environmental and Social Assessment and Management System: Typically, the built-up areas for HCG's hospitals and CCCs are less than the regulatory threshold level of 20,000 m2 beyond which the company would be required to undertake a formal Environmental and Social Impact Assessment (ESIA) study and seek prior environmental clearance. However, all new buildings proposed for leasing are evaluated by the corporate project team as well as the quality team for their suitability for company operations. Also, the projects team works with the partners to ensure construction of new centers as per the required specifications especially construction of bunkers (i.e. specially designed rooms for installation of Linear Accelerator (LINAC) and Positron Emission Tomography - Computed Tomography (PET-CT) where radioactive isotopes are used as per the Atomic Energy Regulatory Board (AERB) requirements.The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable E&S regulatory permits and requirements.As per the ESAP and as discussed below, HCG will develop a corporate procedure on screening of new projects (either greenfield or brownfield acquisitions) to identify any risks with respect to IFC PSs and legal requirements and preparing a management plan for the same.Management Programs: HCG has implemented a QMS at its operational CCCs/hospitals in line with NABH. Among the 14 operational CCCs, three are already accredited to NABH standards; one is being assessed by the accreditation body and five centers will soon start the process of accreditation. The other centers will start the process of accreditation in a staged manner. The corporate quality department is rolling out the QMS across all operational centers in a phased manner. As per NABH requirements, relevant policies, operational manuals, procedures and institutional committees have been developed at each of the centers/hospitals. Some of manuals which cover E&S aspects include the HR manual, patient safety, safety manual, radiations safety and laboratory safety.To manage and mitigate the E&S risks and impacts of their operating assets consistently with IFC's PS, HCG will develop additional E&S procedures as identified as gaps via IFC's appraisal and implement these within agreed timelinesfor all existing and proposed hospitals and CCC's. These will include, but not be limited to; (a) life and fire safety (LFS) master plan and screening; (b) resource efficiency management; and (c) monitoring and management review of performance.Organizational capacity and competency: The Corporate Quality Head is responsible for implementation and monitoring of QMS at all HCG CCCs/hospitals. Quality coordinators at majority of the CCCs/hospitals (reporting to the Quality Head as well as head of operations at each facility) manage the QMS processes on a day to day basis in coordination with other departments. In few centers, the Center Manager is responsible for implementation of the quality systems as well.Recently (in November 2015), the position of EHS Manager was created at the corporate level and recruitment is underway. The EHS Manager will be responsible for general safety, fire safety and compliance with the EHS laws for all facilities. The safety officers at each facility who manage these aspects on a day-to-day basis will functionally report to the EHS Manager.At the CCCs/hospitals, key EHS related departments such as engineering/ maintenance, housekeeping, laundry, security, LFS and quality are under the responsibility of the head of operations. Also, as is required by the AERB, each facility has a designated and qualified radiation safety officer (RSO), who are approved by AERB.The company has a corporate projects team which is responsible for ensuring establishment of new centers/hospitals. The team reviews new assets proposed for leasing/purchase and also works with the partners on construction of new buildings.Emergency Preparedness and Response: As required by NABH requirements, each CCC/hospital has identified nine different emergency scenarios for which color codes, response team and emergency response plans have been formulated including for example, external disasters (Yellow), Fire (Red), missing child (Pink), bomb threat and physical threat (black) and dangerous individual (Purple). The emergency response preparedness includes identification of specific teams for these codes, periodic trainings, reviews and mock drills. However, based on the observations at the visited facilities, it was noted that currently the company does not have specific plans for patient triage especially for non-ambulatory patients during a total building evacuation. As per the ESAP, the company shall thus upgrade the emergency response plans to cover preparedness for total building evacuation and patient triage process especially for non-ambulatory patients. Regular drills shall be conducted to train people on the new processes. Fire safety systems are discussed in detail under PS 4 below.Monitoring & Reporting: As part of the NABH systems, the CCCs/hospitals monitor 64 NABH indicators which includes occupational, health and safety (OHS) KPIs such as patient falls, needle stick injuries, incidents, near-misses, variation in mock drills and major spills. The quality department presents the trend analysis and trend maps, month over month and year over year performance of various departments based on KPI data analysis. Each center level quality coordinator shares the monthly performance reports with the corporate quality department and also send quarterly performance reports to NABH (if accredited).A team of internal auditors has been identified across various departments to conduct quarterly audits as per the NABH standard checklists. Internal auditing is coordinated by the quality department in each of the CCCs/hospitals. After every quarterly audit, the audit findings are shared with concerned head of departments (HODs) for closure. Also, there are regular visits and assessments by the corporate quality department.External auditing is limited to NABH surveillance and recertification audits. NABH undertakes surveillance audits once in 18 months and a recertification audit once in 36 months. Surveillance audit findings are shared with concerned hospital management and the closure report has to be mandatorily filed with NABH.A formal management review is conducted at the center level and at the corporate level, and then the Quality Head briefs the Chairman on a one-to-one level.Most of the monitoring and review activities (e.g. internal audits, monitoring of KPIs) are currently focused on operations and quality in line with NABH requirements. Therefore as per the ESAP, HCG will develop a corporate EHS monitoring procedure which will specify minimum EHS KPIs/parameters (including resource efficiency benchmarks, EHS trainings conducted, health and safety accidents/incidents, effluent and waste related parameters etc.) to be monitored, monitoring frequencies for all CCCs/hospitals, type of monitoring and the definition of thresholds that signal the need for corrective actions. In addition to applicable legal requirements, the monitoring thresholds will include thresholds specified for stack emissions and effluent quality in accordance with the WBG EHS Guidelines (both general as well as sector specific on Health Care facilities) as per feasibility based on mutual agreement, regulatory and 3rd party approvals; resource efficiency benchmarks; and EHS training. Regular monitoring will be conducted for the defined parameters at existing and new hospitals as per the procedure and HCG will ensure corrective actions are taken as necessary based on the results. The EHS performance of hospitals (both existing and proposed) will be regularly documented in an integrated format as per the defined management system processes and reviewed by the management.
PS 2: LABOR AND WORKING CONDITIONS
The company had a total workforce of about 3371 employees as on 30th September 2015, the majority of which are employed in the oncology business. About 137 of the employees are employed in the corporate office.HR Policies and Procedures, Working Conditions and Terms of Employment: The company has a HR manual that describes company's policies on various aspects including manpower planning, recruitment, induction, training and development, performance management, employee separation, leave management etc. In addition, the policy covers key aspects required under PS2 on grievance mechanisms, OHS, and non-discrimination. The policy is communicated to all employees during their induction and is accessible by employees on the company's intranet (SPIDER). Based on the policies, working conditions and terms of employment are specified in the appointment letter provided to employees.Freedom of Association: Currently there are no staff unions at any of the HCG centers/hospitals. However, the company does not restrict formation of employee unions.Non-discrimination and Equal Opportunity: The HR policy of the company includes a policy on equal opportunity among employees and prohibiting discrimination of any nature.Grievance Mechanism: The company has a documented grievance handling procedure included in the HR policy and the same is communicated to the employees through induction/intranet. Grievances received are first directed to the concerned head of department (HOD) for redress and then escalated progressively to the HR department and the Grievance Redress Committee (GRC) that exists at both the corporate and facility level. The GRC has representation from all departments including nursing, medical operations, HR and accounts/finance. The GRC regularly meets and record their minutes of meetings as required under the NABH framework. The grievance handling time is defined in the procedures. As per the ESAP, the company will develop and implement a system of raising grievances anonymously, for example through a dedicated email address to file such confidential grievances.In addition, for addressing sexual harassment related complaints, a separate policy has been developed and a specific committee has been formed.Protecting the Workforce: The company does not employ anyone below 18 years of age. Based on observations during the appraisal, no instances of child labor or forced or bonded labor were noted.Occupational, Health and Safety (OHS): The OHS management systems followed at HCG are in line with the NABH requirements. The key OHS concerns covered include falls, needle stick injuries, management of infectious diseases, radiation exposure, chemical management and noise exposure. The key safety instructions on these aspects are communicated to the employees during induction. Under the QMS, the CCCs/hospitals have a safety manual which describes procedures on risk management; patient safety; electrical safety; engineering and facility safety; hazardous materials; fire safety; and disaster management plan. AERB guidelines are followed with respect to radiation equipment installation, operation, maintenance, and workplace safety across all its hospitals and are separately documented in a radiations safety manual.The CCCs/hospitals have a safety committee which monitors the implementation of safety procedures. Regular safety rounds are conducted to inspect the implementation thereof on-site. Additionally, periodical NABH surveillance audits (for accredited centers) and internal audits are undertaken. The data on patient falls, needle stick injuries, incidents, near-misses, variation in mock drills and major spills are recorded. All accidents and incidents are recorded and investigated through a root cause analysis process.Workers engaged by third parties: Third party workers are employed at the CCCs/hospitals mainly for housekeeping and security. HCG's HR department monitors compliance of the contractors with respect to compliance with labor laws for their workers. The contractors provide documentary proof for payment of social benefit contribution and opening of salary accounts for their workers before receiving payments from HCG. The contract workers can raise grievances to the HR department who then directs them towards their contract supervisor. The contracts with these contractors are renewed annually based on their performance and compliance with labor laws as well as HCG's own management systems and procedures.Typically, the company develops CCCs/hospitals in leased buildings where the construction work is in the scope of land owner and HCG has no responsibilities and limited management control. However, for projects where construction is managed by the company, as per the ESAP, HCG will develop an OHS manual for construction to ensure contractors' compliance with EHS requirements and legal requirements on working conditions, labor camp facilities, and labor law requirements. The procedures will include monitoring procedure, check-list and other documentation of OHS performance on-site by the company. The manual will be included in the contracts signed with various contractors and HCG will monitor its implementation on-site.
PS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION
Resource Efficiency: As described above, most of the CCCs/hospitals are operated in leased buildings and thus the company has limited scope for implementation of resource efficiency measures at the design stage. The company does not have a formal program on resource efficiency, however they have initiated monitoring of energy consumption data for various facilities and started implementation of a few energy conservation measures. For example, the company is upgrading the lighting system to LED from existing compact fluorescent lights (CFLs) and a solar water heater has been installed at the Ahmedabad CCC. The company is also considering the energy efficiency rating of the equipment purchased at the new centers.Going forward, due to new NABH standard requirements, the company expects to have a formal process of energy audits for its centers. As per the ESAP, the company shall develop a resource efficiency program which will describe resource efficiency measures to be implemented at its facilities; monitoring, recording and benchmarking of resource consumption across its facilities; and efficiency goals and targets.Electricity at HCG facilities is sourced from the public grid. For back-up, diesel generator (DG) sets and uninterrupted power supply (UPS) battery back-up systems are installed. At critical medical service centers (e.g., intensive care unit, operation theater), individual battery back-up systems are installed in addition to the overall back-up systems. The DG sets are provided with acoustic enclosures and the stack height is as per regulatory requirements.Based on available resource consumption data for few of the operating CCCs, the average annual electricity consumption is estimated to be 1.5 million units whereas the average annual diesel consumption is estimated to be 42,500 liters.Greenhouse Gases (GHG) Emissions: Based on the estimated average electricity and diesel consumption data, the GHG emissions from the proposed CCCs are estimated to be 18,500 tons CO2 eq/annum.Air Emissions: Air emissions from HCG facilities is limited to only the DG sets. As these are only used as back-up, the operating hours are limited. As per the ESAP, as part of its corporate EHS monitoring procedure (discussed under PS1), the company will conduct regular emissions monitoring of stack emissions from the DG sets (or any other source of air emissions, if there) to ensure compliance with the national standards as well as WBG EHS guidelines as per feasibility based on mutual agreement, regulatory and 3rd party approvals.Wastewater Treatment: Sewage treatment plant (STP) is provided at nine of the 14 CCCs of the company currently in operation. The Company is in the process of commissioning STP or receiving exemptions in this regard from relevant authorities for the remaining CCCs. As per the company, the radioactive isotopes (mainly FDG) used in the treatment have a short half-life (up to 110 mins) and thus are not an issue in terms of sewage disposal. The visited centers of Delhi and Bengaluru were noted to be provided with a STP and the treated wastewater is disposed of in the municipal sewerage system. In the Ahmedabad hospital and CCC, there are no STPs installed and the hospital wastewater is dosed with hypochlorite to kill harmful pathogens and disposed of into municipal sewerage systems as per the permit conditions. The wastewater quality is periodically tested by regulatory authorities and 3rd party testing labs hired by HCG.Based on the discussions and available test results, the STP at the Delhi CCC needs to be upgraded to meet the standards as well as wastewater load based on number of beds. As per the ESAP, the company will upgrade the STP of the Delhi CCC to treat domestic sewage generated in order to meet national standards and WBG EHS guidelines and capacity requirements as per feasibility based on mutual agreement, regulatory and 3rd party approvals.Hazardous materials management: The nuclear medicines handled in HCG centers are hazardous as they have radiation potential. Fluorodeoxyglucoses (FDGs) are manufactured in-house through the cyclotron machine at the CCCs. The FDGs have a half-life of 110 mins and are injected to patients before the half-life as otherwise they are ineffective. The patients consuming/or injected with nuclear medicines are provided with separate washrooms from where the human waste (such as urine and fecal matter) are collected, stored and held in separate tanks till the radiation potential becomes insignificant/half-life expired. The waste is then discharged into STPs for further treatment and disposal.Based on discussions at the visited facilities, the nuclear medicine is imported/procured in the form radioactive capsules only after AERB approval. The details of nuclear medicine related inventories, procurement plans, unused capsules/returned capsules are to be submitted to AERB which permits the plan with a validity period after which the plans are to be resubmitted again for approval. Unused capsules are returned to manufacturers through the AERB and cannot be disposed of with biomedical waste as each and every radioactive medicines procured by HCG are tracked by AERB.Biomedical and other waste management: As part of the QMS requirements, HCG Centers have bio-medical waste (BMW) management procedures which describe the system of appropriate sorting, labeling, handling, storage and disposal of BMW from its hospital facilities and is consistent with the applicable legal requirements. Every facility has a segregated BMW storage area where waste is stored in color coded bags. BMW generated at medical areas are segregated at source as per the waste management procedures and bagged into color coded bags. Segregated BMW is removed from the medical areas to BMW storage area from where it is collected by an authorized external agency for disposal.The radioactive wastes are managed as per AERBguidelines. Such wastes are stored in sealed conditions in specific areas till the radioactive materials become inactive and then disposed of through the authorized agency.
PS 4: COMMUNITY HEALTH, SAFETY AND SECURITY
Infrastructure and equipment design and safety: HCG's CCCs have radiation and nuclear medicine departments. All the radiation, radiology and nuclear medicine department related infrastructure (civil structures, equipment's and operational staff) and management procedures are regulated by the AERB. These facilities are approved by, periodically inspected, reviewed and permitted for operation after AERB safety codes are implemented. As per the company, to date there have been no incidents/accidents resulting in fatalities or major injuries to the community.Community exposure to disease: As per QMS requirements, HCG has an infection control manual aligned with the requirements of NABH, which includes control of nosocomial infections. The company has put in place engineering and administrative controls such as proper ventilation systems for critical care rooms. Only High Efficiency Particulate Arrestance (HEPA) filtered and cool air is circulated in open cycle Air Handling Units (AHU) or HVAC systems for improving infection control in operation theatres and with use of split air conditioners (ACs) in individual patient care rooms. Also other preventive measures include decontamination practices, access restrictions and controls on water, food and waste. Each center has an infection control committee to monitor implementation of the program and procedures.Security Personnel: All centers/hospitals have security guards who are either company employees (e.g. at Ahmedabad multi-specialty hospital) or outsourced to private security agencies (e.g. other facilities visited during the appraisal). The Chief Security Officer (CSO) is generally a company employee and reports to the Head of Operations. Security guards do not possess arms and no incidents has been reported whereby there has been conflict with communities. Security personnel are trained to manage the entry/exit gates, vehicular movement, pedestrian movement, lifts, parking areas, hospital floors and overall movement of visitors inside the hospital premises. They also form part of the critical emergency code response teams such as fire and external threat.Life and fire safety (L&FS) systems: As per discussions with the company, the projects team is responsible for evaluating new buildings proposed to be occupied by the company on lease with support from the quality team. For new buildings being constructed (by the owner) as per specifications of the company, the project team provides inputs to the building owner.The visited centers were noted to be provided with basic LFS infrastructure and systems including smoke detectors; fire exit signage; different types of fire extinguishers; manual call points; fire hoses/reels at every floor; fire alarm control panel and public address system. Except for a few towers in Bengaluru, the fire hydrant system has been provided at the visited centers including fire water storage tanks and pumping systems. Sprinkler systems are provided in the basement. All visited centers were noted to have the required fire no-objection certificates from the local authorities. However, based on a preliminary review, areas of potential improvements noted in the context of LFS systems include the provision of fire doors, compartmentation, enclosure of staircases, sealing of vertical shafts, and space for movement of fire tenders.Given the above the company will commission a qualified LFS consultant to review LFS infrastructure provided at a sample of existing CCCs/hospitals with respect to requirements under applicable legal and national code provisions. Based on the review and a prioritization of areas of improvements based on level of risk, and techno-economic feasibility, the company will prepare and agree with IFC on an enhancement plan of making suitable modifications in the LFS infrastructure at all facilities so as to comply with IFC's requirements within a reasonable time frame. Also, based on the assessment, the consultant and the company shall prepare a LFS master plan including standard LFS design specifications and a screening check-list for future centers to be developed by the company. The LFS master plan and standard design specifications shall meet national and locally applicable requirements as well as IFC requirements as specified in the WBG EHS guidelines.The standard design specification and screening shall be used for evaluation of any brownfield buildings potentially being considered for lease. This evaluation shall form part of the company's due diligence process. Final decision on acquisition shall be taken only with respect to the upgrades needed to conform to the master plan.The consultant shall certify that the master plan (and standard design specifications) meet LFS requirements as specified in the WBG EHS guidelines. The LFS systems at all new brownfield centers shall then be applied as per the agreed master plan and specifications and provision of the same shall be certified by a suitably qualified LFS consultant both at design and following construction / development (through the same process as explained for the greenfield buildings below). These certifications shall be shared with IFC as part of the annual monitoring report.For all future greenfield buildings being constructed either by project partners as per HCG specifications or owned by HCG, at the design stage, the company will commission a suitably qualified LFS consultant to review the site specific architectural brief and confirm that all the LFS-related aspects of design are consistent with an internationally recognized LFS code (e.g. United States National Fire Protection Association (NFPA), as required under the LFS section of the WBG General EHS Guidelines. Following construction, the L&FS consultant will inspect the newly constructed buildings to confirm the building has been constructed in accordance with the agreed design. In doing to the company will submit to IFC professional certifications (as part of the annual monitoring reports) that each such facility is constructed in full compliance with previously approved engineering design, and that all LFS systems were installed as designed and tested in accordance with an internationally recognized LFS code as well as locally applicable code. Any remedial measures needed to bring the building into compliance with IFC's requirements will be completed within a timeframe agreed with IFC subject to feasibility based on mutual agreement, regulatory and 3rd party approvals.With respect to roles and responsibilities on LFS, in addition to the safety officer of the center/hospital, a specific team is identified as the emergency Code Red Team for all major centers and in process of being identified for other centers. This team shall be trained and periodically tested for its readiness to attend to fire related emergencies through half yearly conduct of fire drills and mock drills.