II. dloHaiti's Environmental and Social Management System

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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
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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:
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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:

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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
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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:
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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:
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
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.
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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).
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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.
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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)
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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.
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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
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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
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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
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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)
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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.
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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
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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
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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
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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.
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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
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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
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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.
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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.
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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.
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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
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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
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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
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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
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