Environmental and Social Management System (Proposed Framework) VERSION 4 15 APRIL 2013 http://www.dlohaiti.com Market-Based Solution for Clean, Affordable Water in Haiti MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Table of Contents I. About this Document ................................................................................................................................................. 3 A. About dloHaiti .................................................................................................................................................................... 3 B. IFC’s Performance Standards ............................................................................................................................................. 3 II. dloHaiti’s Environmental and Social Management System ........................................................................ 4 A. Policy .................................................................................................................................................................................. 4 B. Identification of Risks and Impacts .................................................................................................................................... 5 C. Management Programs ..................................................................................................................................................... 5 1. Selection and acquisition of kiosk sites ........................................................................................................................... 7 2. Drilling of the borehole ................................................................................................................................................... 8 3. Construction of the kiosk facilities .................................................................................................................................. 9 4. Kiosk Operations .......................................................................................................................................................... 10 5. Water quality monitoring and management ............................................................................................................... 15 6. Hiring and Staff Management ...................................................................................................................................... 15 D. Organizational Capacity and Competency ....................................................................................................................... 17 E. Emergency Preparedness and Response ......................................................................................................................... 18 F. Monitoring and Review .................................................................................................................................................... 20 G. Stakeholder Engagement................................................................................................................................................. 20 H. External Communications and Grievance Mechanisms .................................................................................................. 22 I. On-going Reporting to Affected Communities.................................................................................................................. 22 Appendix 1: Development of Standard Operating Procedures .................................................................... 23 Overall Approach .................................................................................................................................................................. 23 Lists of Standard Operating Procedures ............................................................................................................................... 23 A. Site Selection and Land Acquisition ............................................................................................................................. 23 B. Borehole Drilling and Kiosk Construction..................................................................................................................... 23 C. Kiosk Operations .......................................................................................................................................................... 24 D. Water Quality and Routine Monitoring....................................................................................................................... 24 E. Hiring and Staffing ....................................................................................................................................................... 24 F. On-going Community Engagement.............................................................................................................................. 25 Appendix 2: Remote Monitoring Systems ........................................................................................................... 25 2 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI I. ABOUT THIS DOCUMENT The purpose of this document is to describe dloHaiti’s proposed approach to environmental, social and health and safety (ESHS) impact and risk management.\. This document was prepared aligned with IFC’s document titled Performance Standards on Environmental and Social Sustainability, and dated of January 2012. The Performance Standards presented in IFC’s document were used as guides to identify the risks and impacts of dloHaiti’s business. This document sets the general framework under which dloHaiti will develop specific plans and procedures to: Identify and manage ESHS impacts and risk related to its business activity; Design mechanisms to assure and monitor adequate ESHS performance, including implementation of corrective measures when needed; Maintain permanent communication and engagement with Affected Communities; and Document and report overall ESHS performance to interested parties and stakeholders. After a brief introduction about dloHaiti, this document discusses how the organization is aiming at responding to IFC’s Performance Standards. A. About dloHaiti dloHaiti is a for-profit venture that aims at providing safer drinking water at a lower price than is currently available in Haiti, making access to clean water more affordable. dloHaiti’s business model is the deployment and operation of decentralized drinking water kiosks dispensing or delivering good quality water to surrounding communities. dloHaiti is launching a 40-kiosk pilot project (referred to as the Project) in Haiti over 18 to 24 months starting in 2013. A successful pilot will be the foundation for a Haiti-wide deployment delivering a valuable resource and creating entrepreneurship opportunities for working- and middle-class Haitians. A post-pilot scale-up will seek to establish a 300-kiosk Haiti-wide network that could reach 5-8% of the population of Haiti who are currently underserved or beyond the limits of current sources. B. IFC’s Performance Standards The eight Performance Standards presented by IFC are the following, and are further discussed below: Performance Standard No.1 – Assessment and Management of Environmental and Social Risks and Impacts Performance Standard No.2 – Labor and Working Conditions Performance Standard No.3 – Resource Efficiency and Pollution Prevention Performance Standard No.4 – Community Health, Safety, and Security Performance Standard No.5 – Land Acquisition and Involuntary Resettlement Performance Standard No.6 – Biodiversity Conservation and Sustainable Management of Living Resources Performance Standard No.7 – Indigenous People 3 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Performance Standard No.8 – Cultural Heritage Performance Standard No.1 drives this Environmental and Social Management System (ESMS) document. Performance Standards 2-5 contain relevant compliance standards that dloHaiti ESMS will seek to address Performance Standards Nos. 6, 7, and 8 do not apply to dloHaiti’s Project, and are therefore not addressed in this document. II. DLOHAITI’S ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM The goal of the ESMS document is to identify the ESHS risks and impacts, and manage the environmental and social performance of the Project throughout its life. This ESMS document addresses the nine sections highlighted in IFC’s Performance Standards on Environmental and Social Sustainability document, as presented below: Policy Identification of risks and impacts Management programs Organizational capacity and competency Emergency preparedness and response Monitoring and review Stakeholder engagement External Communications and Grievance Mechanisms On-going Reporting to Affected Communities. A. Policy As stated in IFC’s guideline documents, the goal of dloHaiti’s policies is to define the environmental and social objectives and principles (i.e., a framework) that will guide the Project to achieve sound environmental and social performance. dloHaiti will develop the following policies, and they will be provided to all investors as they become available: Human Resources Policy Environmental, Social and Health and Safety Policy1 This ESHS Policy will cover all the applicable issues required per the IFC PS, including but not limited to: (a) principles of “do no harm”, environmental and social protection and precautionary approach, (b) continuous and good faith community engagement, transparency and meaningful consultation, (c) respect of Fundamental Principles of the Rights at Work, fair employment and nondiscrimination, (d) protection of the work force and application good international occupational health and safety industry practices, (e) fair land negotiation and principles of like-for-like or better when physical or economic displacement takes place, and (f) respect for human rights in the use of security forces to protect physical assets or patrimony. 1 4 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI B. Identification of Risks and Impacts This part of the ESMS will present a process for the identification of the Project environmental and social risks and impacts. The process also will considers the relevant environmental and social risks and impacts of the Project identified in Performance Standards Nos.2 through 5. If in the future PS6-PS8 should arise the ESMS will be updated accordingly. To identify doHaiti’s environmental and social risks and impacts, the key Project activities, components and elements were separated and analyzed individually, as follows: 1. 2. 3. 4. 5. 6. 7. Selection and acquisition of kiosk sites Drilling of the borehole Construction of the kiosk facilities Kiosk Operations Water quality monitoring and management Hiring and Staff Management Community engagement Table 1 presents below summarizes the environmental and social risks and impacts of each of the above Project components, taking into consideration IFC Performance Standards 1-5. Considering that this ESMS will be a living document, other risks and impacts may be identified and addressed as the project evolves. C. Management Programs The Management Program will be consistent with the ESHS Policy presented above, and will be supported by specific procedures to tackle ESHS risk and impacts associated to the main seven activities or components listed in the Identification of Risks and Impacts section. It will describes the mitigation and performance improvement measures and actions to address the identified environmental and social risks and impacts of the Project. DloHaiti will apply the mitigation hierarchy as defined in FIC PS, and will first and foremost attempt to avoid risks and impacts, but if/where/when this is not possible, these risks and impacts will be minimized, mitigated, or compensated, taking into consideration technical and financial feasibilities. dloHaiti’s proposed framework for its Management Program is also presented in Table 1 below. One of the main management approaches is through the development of Standard Operating Procedures (SOPs) for the tasks and activities that are necessary for the good planning and operation of the water kiosks. A document that summarizes dloHaiti’s approach and the necessary SOPs that have been developed or need to be developed is in progress and is presented in Appendix 1 of this document. The SOPs themselves will be attached to this document as they become available or as needed by IFC and other shareholders or Lenders. SOPs will be developed in two versions, as appropriate, and reviewed as needed: One version of each SOP will be more elaborated and provide all necessary details and explanation. These SOPs will be prepared in English and combined into a manual. Each SOP will be summarized into a single sheet as possible, with limited words in simple bullet points and pictures/drawings. These SOPs will be translated in Creole and posted in appropriate areas of the water kiosks (e.g., the SOP for container disinfection by chlorine will be posted in the Cleaning Area of the kiosk, above the sink where this step will take place). 5 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI To ensure compliance with identified standards for each activity, DloHaiti will establish appropriate staff training for each activity and a system for assessing staff readiness both before the start of work and in regular intervals thereafter. 6 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Table 1 – Project component and corresponding environmental and social risks and impacts (In the final version of the ESMS, each of these impacts/risks will be color coded to reflect probability of occurrence vis-à-vis the significance or severity of the impact. For instance in the table below, “involuntary displacement” is unlikely to occur, but if and when it occurs its impact will be permanent. On the other hand construction impacts will occur for sure, but noted noise, dust etc impacts over communities relate to minor construction activities and are temporary, etc) Project Component 1. Selection and acquisition of kiosk sites Risks and Impacts Management Programs Compliance with legal requirements Obtain legal licenses for business operation from local government authorities Obtain necessary permits and licenses from the Ministry of Commerce, Ministry of Agriculture, and DINEPA. Develop a model for the selection of kiosk site compliant with PS1 and PS5. Considering that land ownership can be uncertain in Haiti, ensure that negotiations are being held with the true landowner(s) of a target site (PS1) Obtain the necessary approvals for site access (right of way) if needed (PS1, PS5) Involuntary displacement of existing tenants of the land Ensure that any displacement of current land tenants is lawful and compensated and accepted by the displaced and the community (PS5) The installation of a water kiosk attracts additional residents The local community including community leaders, and particularly the neighbours of the proposed kiosk sites will be contacted early on in the Project life. (PS1) 7 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component 2. Drilling of the borehole Risks and Impacts Management Programs Social impact and environmental pollution in the community in violation of PS3 or PS4 (e.g., noise, disruption of local transport, pollution due to drilling work, creating safety hazard) Develop and sign a clear and detailed agreement that specifies compliance with PS3 and PS4 for the community and surrounding land The preparation of a hydrogeological study with a preset list of aspects to address was required from the borehole driller prior to drilling to ensure that enough water of appropriate quality is available without depletion of the aquifer (PS3) Supervise, oversee, coordinate and verify the work of the borehole driller to ensure compliance with PS3 and PS4. Health and Safety practices of Borehole Drilling Staff in violation of PS2 Develop and sign a clear and detailed agreement that specifies compliance with PS2 for its own workers Obtain copy of OHS policies and procedures of subcontractor Monitor the work of the borehole driller to ensure compliance with PS2. 8 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component Risks and Impacts Management Programs 3. Construction of the kiosk facilities Social impact and environmental pollution in the community in violation of PS3 or PS4 (e.g., noise, disruption of local transport, pollution due to drilling work, creating safety hazard to community) Develop and sign a clear and detailed agreement that specifies compliance with PS4 and PS5 for the community and surrounding land Supervise, oversee, coordinate and verify the work of the construction company to ensure compliance with PS3 and PS4. Health and Safety of construction staff and contractors practices in violation of PS2 Develop and sign a clear and detailed agreement that specifies compliance with PS2 for its own workers MonitorVerify the work of the construction contractor to ensure compliance with PS2. Obtain copy of OHS policies and procedures of subcontractor 9 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component 4. Kiosk Operations Risks and Impacts Occupational Health and Safety risks to dloHaiti staff and partners from production of chlorine Management Programs SOP development and proper training for safe operation of all equipment related to chlorine production, storage and and distribution, both for kiosk operators as well as technical support staff Verification of compliance with SOP and on-going training Provisioning of safety equipment including gloves, masks, goggles Establishment of emergency procedures for dangerous exposure to chlorine Ensure that chlorine is produced at safe concentrations for intended uses, and is consumed before expiration of shelf life Posting of clear signs and warnings in Creole of the dangers of chemical exposure to chlorine 10 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component Risks and Impacts Non-compliance with PS3 or PS4 due to inappropriate disposal of chlorine, wastewater, and other products from kiosk operations Management Programs SOP development and proper training for safe operation of all equipment related to chlorine production, storage, distribution, and disposal for kiosk operators Use of purification technologies that do not produce significant wastewater SOP for wastewater disposal and periodic monitoring of SOP compliance at the kiosk Verification of compliance with SOP and on-going training Regular (no less than quarterly) monitoring of source water quality to check for changes in water quality and identify trends toward degradation in water table quality which may be a result of dloHaiti operations Depletion of aquifer due to high volume water usage by dloHaiti kiosks (PS1, PS3) Follow hydrological study to avoid areas where aquifer is at the limit of overuse Regular (no less than quarterly) monitoring of source water quality to check for changes in water quality over time and identify trends toward depletion and/or seawater encroachment Additional hydrological assessments prior to significant ramp up of groundwater extraction 11 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component Risks and Impacts Management Programs Environmental pollution and CO2 emissions resulting from energy consumption (PS3) dloHaiti kiosks are run on solar power so carbon emissions and pollution from fuel use are non-existant or minimal If generator power is used, dloHaiti will develop SOPs for generator use for OHS compliance (PS2) as well as environmental and sound pollution, including fuel storage and handling (PS3, PS4) Policy and SOP for proper non-operative battery and battery waste product disposal Environmental pollution from improper jug disposal (PS3) SOP for jug decommissioning and recycling Safety hazards for driver and for community residents resulting from water delivery operations (PS3, PS4) Driver guidelines for all delivery agents. Defensive driving training. Establish partnership with local recycler to receive nonusable jugs Verification of proper driver licensing and commercial permitting for all agents GPS tracking of delivery vehicles including speed and driving behaviour for monitoring SOP for emergency response to accidents Channel for receiving local grievances on driver behaviour (number to call) 12 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component Risks and Impacts Occupational Health and Safety risks to dloHaiti staff from the operation of the electrical system (PV array, batteries) Management Programs SOP development and proper training for safe operation of all electrical equipment both for kiosk operators as well as technical support staff Designation of clear roles and responsibilities of kiosk staff versus technical support staff Verification of compliance with SOP and on-going training Establishment of emergency procedures for injury as a result of electrical shock Posting of clear signs and warnings in Creole of the dangers of electric shock The operation of a kiosk facility creates nuisances to the neighbouring community (e.g., smells, excessive water discharges) in violation of PS3 or PS4 The wastewater systems for grey and black waters were selected for their environmental friendliness, easiness of operation and maintenance, and costs with low risk of environmental impact SOPs for the maintenance of grease traps, shower and toilet will be developed. The local community including community leaders, and particularly the neighbours of the proposed kiosk sites will be contacted early on and informed of the potential Project drawbacks. 13 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component Risks and Impacts Management Programs Maintaining security at the kiosk may put Kiosk staff in physical conflict with local residents (PS4) SOP for all kiosk staff on dealing with security issues arising from community members or visitors to the community, clear guidelines will be provided for the use of security forces. Policy of no weapons in the facility or on the property Regular monitoring and engagement with the community to ensure grievances are heard and addressed at the management level 14 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component Risks and Impacts Management Programs 5. Water quality monitoring and management Impact to community health due to low product quality (PS4) Identify and track water quality parameters and targets in accordance with WHO standards Establishment of a comprehensive water quality monitoring system that ensures and verifies the attainment of target water quality standards. This system includes SOPs, IT-based remote monitoring systems, frequent training, external lab testing, and regular operational and operational audits Develop SOP’s for key operational tasks that affect product quality. Appendix 1 list some of the key SOPs that will ensure water quality standards are met and monitored 6. Hiring and Staff Management Unfair and discriminatory employment practices or other violations of PS2 Establish clear HR policies that prohibit discrimination and promote equal opportunity Establish and follow a clear process of hiring that includes public communication of a job profile, evaluation by multiple members of staff based on clear performance-related criteria, documentation of hiring decisions Establish clear salary ranges based on employment qualification and job descriptions Establish clear HR policies that prohibit hiring of minor or those under the legal age for employment Establish clear guidelines for firing employees and severance payment policy 15 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Project Component 7. Community engagement Risks and Impacts Management Programs Unsafe workplace and staff injury that lead to Occupational Health and Safety violations under PS2 Establish clear HR policies that comply with local labor laws on working conditions for occupational health and safety Establish safety training and emergency training for all staff Monitor compliance and repeat training on a regular basis Provide safety equipment for dangerous tasks such as chlorine production Provide clear response protocols and functioning response equipment in case of fire, injury, or other threats to safety Install safety placards on all areas of risk including electrical equipment, chlorine production, and machinery Provide staff facilities for staff including toilets, changing areas, and showers The local community including community leaders, and particularly the neighbours of the proposed kiosk sites will be contacted early on and informed of the potential Project drawbacks. Regular dialogue with local competitive businesses to voice and grievances where possible Quarterly community meetings communicate dloHaiti plans, policies, and activities as well as seek feedback from customers on product and service satisfaction Improper communication of dloHaiti policies and activities leads to community dissatisfaction and violence against dloHaiti facilities 16 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI D. Organizational Capacity and Competency The responsibility for compliance with IFC Performance Standards will rest with the dloHaiti Management team and led by the CEO, Jim Chu, and the CFO, Jane Choi, who is responsible for compliance with local laws and IFC Performance Standards. The CFO will develop a staffing plan that ensures the on-going compliance with Haitian laws and IFC Performance Standards. Initially, the CFO will function as the PS Compliance Officer but as operations expand, the CFO will establish two new teams to ensure compliance: 1. Compliance team that reviews and develops SOPs from the perspective of E&S impact, risks, and compliance for PS1-PS5. 2. Training team tasked to assist in developing and executing trainings in conjunction with the rest of the company to ensure on-going compliance The responsibilities for SOPs development in each functional area will rest with the management team member overseeing each area. The CFO, along with the compliance and training teams when in place, will support and monitor each functional area with respect to compliance with IFC Performance Standards. The chart below outlines the functional areas and the management team member responsible for SOP development and compliance. Functional Area Responsible Selection and acquisition of kiosk sites Ken Michel, COO Drilling of the borehole Iain Silver, Deployment Manager, in conjunction with STEACI, dloHaiti borehole partner Construction of kiosk facilities Iain Silver, Deployment Manager in conjunction with Tecina and Veerhouse Voda, dloHaiti construction partners Kiosk Operations Ken Michel, COO Water quality monitoring and management Helene Baribeau, CTO Hiring and Staffing (at Kiosk level) Ken Michel, COO Hiring and Staffing (at HQ level) Jim Chu, CEO On-going Community engagement Ken Michel, COO Figure 1 below provides the organizational chart of the company for reference. Additional consultants will be retained if deemed necessary (medium to high risks in areas in which dloHaiti does not have expertise). In this case, dloHaiti will follow Leopard Capital’s ESDD Annex 7, Guidance for Using Environmental and Social Consultants. 17 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Jim Chu CEO Jane Choi Chief Finance Officer Emilie Grandoit Chris Lewis Marketing Ken Michel Chief Operating Officer Gestionnaire Régional Helene Baribeau CTO / Water Quality Tech Service Manager Eventually: 1:10 Kiosk Bookkeeper Gestionnaire Régional Initially: 1: 3-5 kiosks Gestionnaire Kiosk Senior Operateur Kiosk Dan Retz Ronald Lacrete Nanoucheka Olis Admin Office Manager Technicien Regional Eventually: 1:10 Kiosk Gest. Kiosk Junior Technical Consultants Chauffeurs Gestionnaire Régional Gestionnaire Régional Sarah Schlessinger Product Manager Technicien Regional HR Sylvie Handal Outside Counsel Initially: 1:5 kiosks Iain Silver Deployment Manager Technicien Regional Securité Legend Technicien Regional Kiosk Staffing Hired Full Time Hired Part-Time/Temp Fixed Overhead Securité Variable Staffing Figure 1 – dloHaiti’s organizational chart Note: the CFO will be CFO will be responsible of ESHS issues until the growth requires specific people to manage ESMS monitoring and reporting. E. Emergency Preparedness and Response The Emergency Preparedness and Response section of the ESMS should provide adequate responses to accidental and emergency situations associated with the project in a manner appropriate to prevent any harm to people and/or the environment. A number of accidental and emergency situations that may be encountered by dloHaiti are presented in Table 2, along with their respective mitigation measures and response plans. Other accidental and emergency situations and their corresponding mitigation measures and response plans may be added as dloHaiti’s Project evolves. Table 2 - Accidental and emergency situations, and mitigation measures and response plans 18 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Accidental and emergency situations Mitigation measures and response plans Hurricane The kiosk building, its satellite structures and equipment positioned on them were designed to withstand strong winds and harsh weather, and the design was reviewed several times by dloHaiti’s staff and the selected construction contractors. Among others, metal roll-up doors will be installed on the window and door openings. The construction contractor was selected because of its experience in designing building in hurricane prone areas. Depending on the severity of a weather event and the community’s needs at that moment, the possibility of closing a water kiosk during a particular event will be considered by the kiosk staff and management team. An SOP to rapidly secure a kiosk in case of severe event will be developed. Flood Kiosk sites are selected in areas that are not prone to flooding. dloHaiti has insisted on the implementation of a deep sanitary seal and a concrete slab around the borehole head. The borehole will be accessible for routine and emergency disinfections as needed. An SOP for borehole disinfection has already been developed. The borehole driller was selected for his experience in designing boreholes and related infrastructures that prevent borehole contamination in case of extreme weather events. Riots The local community including community leaders, and particularly the neighbours of the proposed kiosk sites will be contacted early on and informed throughout the Project development. Community engagement will be used as a security tool to protect dloHaiti’s kiosks. If the situation gets out of control, the water kiosks will be equipped with metal roll-up doors to secure windows and doors. An SOP to rapidly secure a kiosk in case of crisis will be developed, and guidance on the use and management of security forces will be provided Staff injury on the work site The water kiosks are designed to be as comfortable and ergonomic as possible. The water treatment unit was selected to eliminate the need for harsh chemicals (e.g., membranes will be changed instead of cleaned with acids and bases). Safety devices will be provided, including safety glasses, face masks, gloves, and a shower area in case a worker receives undesirable substances (e.g., concentrated chlorine, petroleum). All kiosk sites will have a sign that posts the nearest medical facility with contact information. Staff at each site will undergo regular training to respond to medical emergencies at the kiosk 19 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI F. Monitoring and Review DloHaiti will establish procedures to monitor and measure the effectiveness of the Management Program, as well as compliance with any related legal and/or contractual obligations and regulatory requirements. This function will be managed by the dloHaiti CFO in conjunction with the CEO. dloHaiti will submit an annual self-audit of its compliance of IFC Performance Standards. This will be provided to all investors. G. Stakeholder Engagement The goal of the Stakeholder Engagement section of the ESMS is to build a meaningful, strong, constructive, transparent, and responsive good-faith relationship to help successfully management the Project’s environmental and social impacts. The steps followed to determine the appropriate Stakeholder Engagement as they pertain to dloHaiti’s Project are the following: Stakeholder analysis and engagement planning Disclosure and meaningful consultation of information with Affected Communities Private sector responsibilities under government-led stakeholder engagement. Table 3 summarizes the stakeholders that pertain to dloHaiti’s Project, the nature of the information that they will receive, how this information will be given to them, and when they will receive this information. Other stakeholders may be added as the Project evolves and a better understanding of the communities where dloHaiti interacts is gained. Because dloHaiti’s Project does not present significant adverse impacts on Affected Communities, a Consultation and Participation process was not considered necessary. Likewise, the Project does not present adverse impacts specifically to indigenous people. Table 3 – Stakeholder analysis and engagement Stakeholder Information disclosed Information method Time period and frequency as applicable Investors Self-audit report on compliance with IFC Performance Standards. Provided in writing and distributed electronically. Annually Ministry of Commerce All necessary documents for registration of dloHaiti S.A., including the purpose, the nature and the scale of the Project. Provided in writing. At the beginning of the Project. 20 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Stakeholder Information disclosed Information method Time period and frequency as applicable Ministry of Agriculture All necessary documents to obtain the authorization to drill boreholes. Provided in writing. Provided prior to starting work on each borehole DINEPA All necessary documents to obtain the authorization to drill boreholes, including the purpose, the nature and the scale of the Project, the Project duration. Water quality reports. Provided in writing. At the beginning of the Project. Water quality reports will be provided at a frequency determined by DINEPA, but no less than annually. Ministry of Health Water quality reports. Provided in writing. Water quality reports will be provided at a frequency determined by the Ministry, but no less than annually. Local community, including community leaders Information about dloHaiti, including the potential risks and impacts of the water kiosks and dloHaiti’s business, the proposed mitigation measures, how dloHaiti proposes to engage them, and the grievance mechanism. Education on the value of treated water and hygiene. Introduction of new products and services. Provided by holding a public forum with community participation From the beginning, when a community is being considered for a water kiosk site. No less than annually. Information about dloHaiti and its intentions, including the potential risks and impacts of the water kiosks and dloHaiti’s business, the proposed mitigation measures, how dloHaiti proposes to engage them, and the grievance mechanism. Provided in writing. Water kiosks’ neighbors Collected by customer surveys Provide a clear Grievance Mechanism Permanently From the beginning, when a site is being considered for the implementation of a water kiosk. 21 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI H. External Communications and Grievance Mechanisms dloHaiti will implement and maintain a procedure for external communications that includes methods to (i) receive and register external communications from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate. dloHaiti will also establish a grievance mechanism to receive and facilitate resolution of concerns and grievances about its environmental and social performances. I. On-going Reporting to Affected Communities dloHaiti will prepare reports that describe progresses on the implementation of the Project’s Action Plans on issues that specifically involve ongoing risks to or impacts on communities. These reports were described above in Table 3. 22 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI APPENDIX 1: DEVELOPMENT OF STANDARD OPERATING PROCEDURES Version 2, 19 March 2013 Overall Approach Standard Operating Procedures (SOPs) will be developed for each task and activity that are necessary for the good operation of the water kiosks, along with the maintenance requirements of the various kiosk components. SOPs will be developed in 2 versions, or as appropriate: The first version of each SOP will be more elaborated and provide all necessary details and explanation. These SOPs will be prepared in English and combined into a manual. Each SOP will be summarized into a single sheet, with limited words in simple bullet points and pictures/drawings. These SOPs will be translated in Creole and posted in appropriate areas of the water kiosks (e.g., the SOP for container disinfection by chlorine will be posted in the Cleaning Area of the kiosk, above the sink where this step will take place). Lists of Standard Operating Procedures Below are the lists of SOPs that have been developed or an in the process of being developed, separated by department. A. Site Selection and Land Acquisition SOP Responsibility Site Selection Data Gathering and Evaluation COO Initial community engagement COO Local legal requirements compliance check COO Lease negotiation COO Current tenant resettlement guidelines COO B. Borehole Drilling and Kiosk Construction SOP Responsibility Contractor agreement compliance checklist Deployment Manager Contractor information transmittal Deployment Manager Compliance monitoring and verification of contractor Deployment Manager Community grievance receipt and response Deployment Manager 23 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI C. Kiosk Operations SOP Operation and maintenance of the power generation systems Responsibility Deployment Manager Operation and maintenance of water purification systems CTO Waste disposal including waste water Toxic chemical disposal including chlorine CTO Maintenance of employee areas including shower and toilet COO Emergency preparedness and response plan COO Non-event security protocols COO Civil unrest security protocols COO D. Water Quality and Routine Monitoring SOP Responsibility Container cleaning CTO Borehole operation and maintenance CTO Cleaning of water storage tanks CTO Operation and maintenance of the water treatment unit CTO Operation and maintenance of the Dosatron CTO Generation of concentrated chlorine solution CTO Analysis of water production parameters CTO Water quality analysis: Temperature and turbidity CTO Water quality analysis: pH, chlorine, alkalinity and hardness CTO Water quality analysis: Total dissolved solids CTO Entry of routine water quality data CTO E. Hiring and Staffing SOP Responsibility Recruiting guidelines CFO Employee on-boarding CFO Labor law compliance checklist CFO 24 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI Employee grievance communication and response CFO Employee termination guidelines CFO Workplace OHS compliance checklist CFO Salary Range and Promotion guidelines CFO F. On-going Community Engagement SOP Responsibility Community meeting kit COO Community and customer grievance communication and response process COO On-going legal compliance checklist COO APPENDIX 2: REMOTE MONITORING SYSTEMS All of dloHaiti’s water kiosks will be equipped with a remote monitoring system (RMS) that will track system operations, maintenance performed, problems encountered, and data collected. The RMS functionality can be broken down into the following four parts (see also Figure 3): 1. Automated data capture of water system diagnostics through physical sensor inputs (e.g., gauges, meters). 2. Manual data capture of point-of-sale information through kiosk staff input during the sales process. 3. Manual data capture for other performance data relevant to operations (water quality data). 4. Storage in a centralized database, which can be accessed by query and reporting tools as well as automated alarms for systems failures. More specifically about the water system diagnostics, dloHaiti will provide electronic water meters that would measure water flow continuously and to be stored as part of the RMS. Water meters will be located at the borehole, and at a number of locations around the water treatment unit and distribution points. A number of pressure sensors and total dissolved solids (TDS) meters are also located in the water treatment unit, and considerations are being given to sensors that could communicate the information continuously to the RMS. All water quality data, including data collected manually, will be entered into the RMS and central database. Although kiosk staff will remain responsible for the analysis of the critical water quality parameters and performance indicators of the water treatment unit, dloHaiti will hire a Water Quality Analyst that will be responsible for water quality monitoring of all kiosks as the number of kiosk grows. This will relieve the burden of kiosk staff, and will provide a “semi third-party” evaluation of the water treated by the kiosks. All kiosks will undergo a complete water quality profiling by an external laboratory on an annual basis. Data obtained from the meters and sensors, kiosk staff, Water Quality Analyst and external laboratory will be reviewed and compared by the Water Expert as they become available. Any discrepancies will be addressed 25 MARKET BASED SOLUTION FOR CLEAN, AFFORDABLE DRINKING WATER IN HAITI immediately by the Water Expert and Chief Technology Officer as needed, by repeating the analysis(ses), and reviewing the analytical procedure with the staff as needed. Monthly reports will be prepared and provided to dloHaiti’s management team. The reporting frequency to DINEPA, the Ministry of Health, IFC and the other investors will be discussed with each organization, but will be provided no less than annually. Figure 3 – RMS conceptual diagram 26