OCP SA - UM6P Phase 3A Project

MIGA has been requested to provide guarantees to cover loans provided by Credit Agricole Corporate and Investment Bank and Société Générale S.A. to OCP S.A (OCP) for the construction and operation of the new phase (Phase III A) of the university campus of the Mohammed VI Polytechnic University (UM6P) located in Rabat, Morocco (the Project). MIGA issued guarantees covering the first two phases of the Rabat campus in 2022 and has been requested to provide guarantees for part A (described below) of the third phase. This ESRS was updated in October 2023 to include Phase 3A. 

UM6P is a higher education institution offering vocational and technical training in Morocco. The university’s educational and research & development programs are focused on the challenges faced by the African continent such as food security, urbanization, industrialization, and management of public policies. It operates a campus in Benguerir which was established in 2015.

The Project involves the expansion of UM6P through the construction of a campus near the city of Rabat, in Hssaine municipality and within the Technopolis, an existing technology park currently hosting another university as well as companies involved in engineering and product development.  The Rabat campus is hosting the Faculty of Governance, Economics and Social Sciences (FGES) and will have a total capacity of around 3,600 students. 

The campus is developed in several phases. The construction for the first phase started in January 2021 and included the FGES building, student center, theater, student accommodations, sports facilities, and a hotel. The second phase, for which construction commenced in April 2021 involved additional school buildings for hotel management, artificial intelligence, digital learning, and languages, as well as laboratories, administrative buildings, a health center, and a hotel for visiting lecturers and students. The campus opened in the fall of 2021, and the two first phases have been completed and are currently operational.

Phase 3A of the campus involves the Lycée d'Excellence Sport-Études (Lydex SE) of Rabat, which will provide sports and academic secondary education, and a state-of-the-art conference center of ~11,000 m2 with a capacity of 1,500 seats for hosting large scale events. Lydex SE will have a total capacity of 1,600 students and will include several facilities in addition to the academic buildings such as accommodations, a restaurant, a sports health center and sports facilities constituted of multi-activity athletics stadium, an aquatic center, a combat sports complex and basketball, handball and volleyball courts. Construction for the third phase commenced in 2023, with targeted completion in June 2024. 

The Project footprint will involve around 80 hectares within the Technopolis park, out of which 3A makes up 11 hectares. Technopolis was developed in 2007, on previously unused land which belonged to the Government.   

A consortium of EPC Contractors has been engaged to construct the Project. Construction management and supervision have been delegated to JESA, an OCP group affiliate specialized in Engineering and Project Management. 

The Project is a Category B under MIGA’s Policy on Environmental and Social Sustainability (2013). The Project is expected to have potentially limited adverse Environmental and Social (E&S) risks that are generally site specific, and can be addressed through the implementation of applicable Performance Standards (PSs), Environmental Health and Safety (EHS) guidelines, and design criteria. The key potential risks and impacts associated with the project include: i) community health and safety as including fire and life safety; ii) labor and working conditions; iii) environmental risks typically encountered during construction including waste management (solid and hazardous), water runoff, air and noise emissions; iv) occupational health and safety risks including risks related to gender-based violence ; v) resources efficiency (water & energy).

While all Performance Standards (PSs) are applicable to this investment, current information indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards:

• PS1:  Assessment and Management of Environmental and Social Risks and Impacts
• PS2:  Labor and Working Conditions
• PS3:  Resource Efficiency and Pollution Prevention 
• PS4:  Community Health, Safety and Security

The project is constructed on previously unused land owned by the Government, and PS5 does therefore not apply. Material impacts related to biodiversity or impacts related to Indigenous People are not expected, and therefore PS6 and PS7 do not apply. 

In addition to the PSs, World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines (2007) will also apply to this Project.

For this Project, MIGA’s environmental and social due diligence (ESDD) consisted of reviewing and discussing the following documents: 

• Sustainable Development Institutional Policy, UM6P.
• Sustainable Development Plan of Actions, UM6P. 
• UM6P Green Map
• Sustainable Development Best Practices Guide: For a More Sustainable Campus. UM6P.
• Responsible Purchasing Charter, UM6P. 
• Sustainable Development Summary Report 2022, UM6P.
• JESA HSE Management Program.

In addition to reviewing the above documents, MIGA carried out a combination of on-site visits and virtual (due to travel restrictions related to the ongoing COVID-19 pandemic) environmental and social (E&S) due diligence.  In April-May 2021 MIGA organized virtual meetings with key E&S staff and management to complement the MIGA-engaged local consultant’s E&S site visits in June 2021 which included meeting with community representatives, Project staff, and local authorities. For the expansion of the campus (phase 3A), MIGA held additional virtual meetings with key E&S staff in October and November 2023. 

In March 2024, MIGA climate team carried out an on site visit for the Rabat UM6P Campus phases 1, 2 and the construction site of phase 3A, which include LYDEX SE and The Conference center.

MIGA’s due diligence review considered the environmental and social management planning process and documentation for the Project and identified gaps between these and MIGA’s E&S requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (“ESAP”) attached to this Environmental and Social Review Summary (“ESRS”). Through the implementation of these measures, the Project is expected to be designed and operated in accordance with MIGA’s Performance Standards.

PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System

UM6P has established a system for managing environmental and social risks and impacts consisting of a set of policies and procedures as further described below. The policies and procedures apply to all UM6P operations and campuses and will be adopted for the operations of the Rabat campus. 

For the construction phase, a Health, Safety and Environment (HSE) Management System is implemented based on JESA corporate policies, applicable local regulations, and the requirements of PS1.

Policy:

UM6P has an Institutional Sustainability Policy in place, setting out the University’s objectives and guiding principles related to sustainable development. This includes aiming to be a benchmark and continuously improve processes and practices related to sustainability, and the efficient use of resources, and to integrate sustainable development concepts in all education and research activities.  The Policy also includes commitment towards the creation of a safe and inclusive work and study environment.

The Sustainability Policy is approved by the President of the University, and the implementation is coordinated by the Sustainable Development Department of UM6P. The Sustainability Policy applies to all UM6P activities, including the Rabat campus. 

For the construction phase, the JESA sustainability policy statement is implemented through the HSE Management System. The EPC Contractors engaged for the construction of the Rabat campus also have corporate-level HSE policies, applicable to the construction of the Project. 

Identification of Risks and Impacts:

An E&S Impact Assessment study is not required for this Project, but UM6P has carried out a process for the identification of E&S risks and impacts related to its educational activities and operation of the campus.  Identified risks are described in the Sustainable Development Plan of Actions (SDPA) and include for example use of resources, waste management and recycling, emissions, health and safety of staff and students, biodiversity, and community relations, as further described in the respective sections below.  

Identification of risks and impacts related to the construction phase is conducted as part of the JESA HSE Management System, which includes risk assessments, and identification of environmental impacts associated with construction activities. 

Management Programs:

UM6P has established the SDPA building on the Sustainable Development Policy and includes a framework to measure and guide actions related to sustainability management consistent with the objectives of PS1.

The SDPA is based on the Sustainability Tracking, Assessment and Rating System (STARS), a sustainability management framework for universities, and includes criteria for monitoring educational and research activities in sustainability performance related to community engagement, resource and waste management, building and energy efficiency, biodiversity and landscape management, sustainable transportation, sustainable procurement, planning and administration performances including health & safety of staff and students, and diversity.  

UM6P also has a Safeguarding Policy which commits to a safe and secure learning and working environments for all students including children (under 18 years old), professors, staff, and visitors. The Policy outlines UM6P’s approach to promoting safe space through measures that encourage inclusive social behaviors and includes provisions on mental health that aim to provide a compassionate environment that empowers UM6P members to seek support on related concerns. The Policy refers to a response measure in place which is detailed in the corresponding Safeguarding Incident Report Procedure (see PS2).

For the construction of the Rabat campus, the JESAs HSE Management System is implemented. The system is based on a Plan–Do–Check–Act process and places the primary responsibility for the implementation of HSE management programs on the EPC Contractors. HSE requirements are included in each EPC Contract, including the development of a project-specific HSE Plan for each contractor. EPC Contracts include obligations to adhere to EHS rules and requirements, including applicable national regulations and the Performance Standards, as well as the implementation of the HSE Plan. 

Organizational Capacity and Competency: 

UM6P has an established management structure for sustainability which includes the Sustainable Development Department (SDD), the HSE Department, and the Health Centre. The SDD oversees the implementation of the Sustainable Development Policy, Plan of Action, and related initiatives, in collaboration with the HSE Department and the Health Centre. The SDD is headed by the Sustainability LEAD, a project management officer, two project managers, a community mobilizer officer in charge of social initiatives and community service projects, in addition to an SD Facilitator.

The SDD is also supported by a Sustainable Development Consultation Committee consisting of representatives from researchers, teachers, students, and administrative staff. The Committee supports the SDD in its work but also acts as an advisory body for sustainability initiatives in the University.  The HSE department consists of a HSE Manager, supported by a team of HSE Officers.

The Sustainability LEAD regularly holds sessions with the students and university staff on topics related to Sustainable Development and the Plan of Action, and oversees emergency and preparedness, life and fire safety training, and fire drills performed by the HSE. The Sustainability LEAD is responsible for developing and implementing the SD training program. 

For the construction phase, JESA has an HSE Manager in place with overall responsibility for the implementation of the HSE Management System. Each of the EPC Contractors has a full-time HSE Officer who reports to the JESA EHS Manager, and any sub-contractor engaged at the site is also required to appoint an HSE representative. 

Emergency Preparedness and Response:

Procedures for Emergency Preparedness and Response Plan (EPRP) are included as part of the UM6P HSE program. This includes assessment of risks and hazards, training, evacuation procedures, and regular simulations and exercises. All premises are equipped with fire safety systems, and each building has designated teams training in fire and medical first response. For buildings where laboratories are located, an additional set of procedures are in place considering risks related to chemicals. 

The HSE Plans for construction include emergency preparedness and response procedures for the construction phase, including relevant emergency scenarios such as spills, leaks, fire, vehicle accidents, natural hazards, etc. The HSE Plans also include a description of related roles and responsibilities, training, and communication procedures in line with the requirements of PS1.  

Monitoring and Review: 

For the construction phase, the JESA HSE Management System includes a monitoring program consisting of HSE Audits, safety evaluations, and equipment inspections. In addition, the HSE Plan for each EPC Contractor includes a monitoring program developed in line with the requirements of the JESA HSE requirements (including the PSs) and considering the activities of the respective Contractor. Monthly HSE reports are prepared by JESA and submitted to UM6P. 

During the operation phase, the SDD is responsible for monitoring key environmental and social aspects as set out by the SDPA, including solid wastes, hazardous waste materials management, occupational health and safety, life and fire safety equipment maintenance, energy use, water usage and report to PE and relevant regulatory authorities as required. The Project will also be required to submit to MIGA annual E&S monitoring reports to MIGA. 

Stakeholder Engagement: 

UM6P operates a communications strategy that includes stakeholder engagement activities both with prospective students and the public, including information and awareness campaigns, dissemination of results from research activities, operation of demonstration farms and plantations as well as an experimental mine with activities open to the public. Stakeholder engagement activities are monitored by the SDD and led by the Communication Department. 

Stakeholder engagement activities related to the construction of the campus in Rabat included information campaigns concerning construction traffic and the communication of a grievance mechanism, as described below.  

External Communication and Grievance Mechanisms:

UM6P has an external communication channel and discloses sustainability-related policies and reports on a website specifically dedicated to sustainable development. A grievance mechanism is also in place, open to both students and the public through the external communications channel, including various modes of filing a complaint, such as the webpage, telephone, email, and social media channels. The grievance mechanism is operated by the Sustainability and Communications Department. UM6P is also in the process of finalizing a Non-Retaliation Policy to support access to its grievance mechanism. 

The UM6P grievance mechanism is also available to any party affected by the construction activities in Rabat, and JESA also implements a grievance procedure that has been communicated to stakeholders through billboards and signs at the entry points of the Project construction site. 

As part of its community engagement, UM6P also launched an initiative to disseminate mailboxes across the campus and created a dedicated email to receive concerns related to work and study conditions. Issues are reviewed and handled by a committee whose members include a psychologist and representatives from Human Capital, Student Affairs, Communications, and the University Registrar.   

PS2:  Labor and Working Conditions

During Construction, the EPC Contractors are expected to have up to 5,000 construction workers including unskilled, skilled, supervisors, engineers, and managers. Construction staff is primarily recruited locally from the Rabat region, and there is no accommodation for construction staff on the site. 

During operations, the Project will employ approximately 250 staff including teachers, researchers, and administrative staff at the Rabat campus. 

Human Resources Policies and Procedures:

UM6P has a set of Human Resources (HR) policies in place, including provisions for working conditions and terms of employment, written contracts for all employees, recruitment and retrenchment, grievance redressal, worker’s organizations, and occupation health and safety. The policies are based on Moroccan labor regulations and are in line with the requirements of PS2. 

In line with the HR policies, recruitment and employment relationships are based on the principle of equal opportunity, with prohibitions of any forms of discrimination based on gender, sexual orientation, race and or color of skin, religion, or political persuasion. In addition, UM6P has established a Code of Conduct for both staff and students which includes the prohibition of discrimination and any forms of harassment, and a commitment to ensure equality of opportunity. 

Following local regulations and the requirements of PS2, workers' grievance mechanisms are available at both the Rabat construction site and as part of UM6P HR policies. The mechanisms include the ability to make a report through different modes of communication, and anonymously. 

Protecting the Work Force:

The HR policies for UM6P, JESA, and EPC Contractors prohibit child and forced labor. For UM6P, all employees must be at least 18 years of age to qualify for a job as stipulated in Moroccan labor laws. The minimum age for employment is 18 years of age, for both UM6P and construction activities. All sub-contractors are required to implement the same requirement.

Occupational Health and Safety (OHS): 

UM6P has a Health and Safety program in place, implemented by the HSE department. The program includes risk identification and prevention, training and information campaigns, accident and incident reporting and follow-up, as well as management of the Health & Safety of contractors on the UM6P premises. The program is implemented in coordination with the UM6P Human Resources Department, and the Health Center. The Health Center is staffed by a doctor and nurses and provides health care services to all students, academic staff, and non-academic staff, including Student Health Service, Occupational Health Service, Psychological Support Unit, Food Quality Hygiene and Safety Department, Event Safety Unit, and a Lab of analyzes & research applied to food safety.  

Concerning incidents related to the Safeguarding Policy, UM6P has a Safeguarding and Children Protection Procedure in place which is available to all staff and faculty, visitors and third parties, as well as volunteers; and applicable to all UM6P activities whether on or off campus including online and social media.  The Procedure outlines the safeguarding incident reporting process and the corresponding response and support measures to be provided with provisions on confidentiality.  UM6P has a Safeguarding Committee led by the University Registrar and supported by different unit heads, which has responsibility for the implementation of the Procedure. 

In response to the COVID-19 pandemic, UM6P has implemented a set of protocols and measures to minimize infections and impacts. The protocols include rules for educational activities such as social distancing, options for remote learning, provision and use of PPEs, disinfection, health screens, limitation of large gatherings, and rules to follow and support in case of an infection. Information and awareness campaigns have also been carried out to ensure the implementation of the protocols and recommendations. 

During construction, the OHS risks include those typically associated with construction (e.g. noise, vibration, rotating and moving equipment, heavy vehicle operation, and site traffic). The JESA HSE Management System and the HSE Plan include programs and procedures related to OHS, including risk assessment, mitigation controls, permit-to-work system, use of PPEs, toolbox talks, training and supervision, safety board and visual management, and evacuation drills. Weekly HSE coordination meetings are conducted between JESA and the Contractors, and the implementation of all procedures related to HSE are reviewed as part of the HSE Auditing program. JESA’s HSE team maintains a record of occupational incidents accidents and traffic incidents, and corrective measures are taken to prevent recurrence. 

A site-specific COVID-19 management plan has been developed to ensure that the risks associated with COVID-19 are adequately addressed for the Project during construction. The Plan includes risk assessment, mitigation measures, training and awareness, medical and emergency plan, communication and reporting process, and inspection program.

Workers Engaged by Third Parties and Supply Chain:

The JESA’s EHS Management System sets out obligations for contractors and sub-contractors including health and safety management and labor standards as described above. 

UM6P has contractors on its campus to provide services related to food and dining, cleaning, and technical maintenance. To manage contractors and service providers, UM6P has developed a Responsible Purchasing Charter which describes the University’s commitment to the acquisition of goods and services from suppliers that respect the fundamental rights of individuals, including employees, and that commit to responsible practices. The Responsible Purchasing Charter includes sustainability criteria applicable to third parties and suppliers, including specific prohibition of child and forced labor and consistent with the requirements of PS2.

PS3:  Resource Efficiency and Pollution Prevention

Resource Efficiency: 

The UM6P Sustainable Development Plan of Actions (SDPA) includes programs related to resource efficiency including for example energy, water, and greenhouse gas emissions. Resource efficiency criteria and requirements have been defined for building design and maintenance, use of clean energy, food and beverage purchasing and recycling, landscape management, procurement and use of office supplies, sustainable transportation, water use, and rainwater management.

Resource efficiency considerations during construction include water resource use and potential greenhouse gas emissions. A limited amount of greenhouse gases will be emitted as part of construction activities, primarily associated with the operation of construction machinery and backup generators. During operations, the emission of greenhouse gases will be limited. 

During the construction, the water usage will primarily be linked to washing, preparing concrete, dust suppression, and domestic drinking water consumed by workers. The EHS plans include water management procedures, for both use and treatment.

During operations, the water usage is linked to domestic use, sanitation, and drinking water and is managed as part of the SDPA.

Pollution Prevention:

Environmental pollution related to the operation of the campus is primarily made up of waste generation and wastewater. The SDPA includes programs for minimization and recycling, storage, and procedures for the pick-up of waste by licensed contractors. Limited hazardous waste will be handled on the campus, such as electronic waste, and cans/packaging from oils or paints used for the maintenance of buildings. The SPDA includes procedures for the disposal of different categories of hazardous waste, minimizing its presence on the campus, and pickup by third-party contractors. 

For the campus in Rabat, a rainwater harvesting system is in place, and the campus is connected to the municipal network for wastewater treatment. 

Pollution impacts and risks during construction include noise, air emissions, effluent, solid waste generation, and hazardous materials storage, use, handling, and disposal. During construction, limited amounts of air, noise, and water emissions and soil erosion are anticipated, which is mitigated through standard pollution prevention and control measures set out in the JESA EHS Management System and the EHS Plans. As part of the JESA’s EHS Management System, EPC Contractors are required to implement pollution prevention measures to mitigate the risk of any pollution, also including specific provisions for erosion and sediment control, effluent management, chemical management, and waste management. 

PS4:  Community Health, Safety and Security

Community Health and Safety:  

The construction of the Rabat campus takes place within the Technopolis park and impacts related to community health and safety are primarily linked to increased traffic to and from the park. There is no accommodation for construction workers on the site, and impacts related to influx have not been identified. 

The engineering design of the campus buildings has been reviewed by JESA, and deemed in line with good international industrial practices for fire and life safety as described under PS1. UM6P has launched an awareness campaign targeting faculty, administrative staff, and students to create a safe and inclusive environment. As part of phase 3B, UM6P will continue its  awareness program. 

Food safety procedures in on-campus restaurants and cafeterias are reviewed by the Health Centre, staffed by an industrial food safety engineer, including monitoring of hygiene practices, supplier audits, sampling and testing, and training of staff. UM6P food safety procedures are based on the requirements of ISO 22000 (Food Safety Management) and those same procedures will be followed at the Rabat campus.

The EHS Management Plans include procedures for the management of construction traffic safety, including the use of vehicles, speed limits, and signage, protocol for loading/unloading, vehicle maintenance and refueling, and cleaning of vehicles before leaving the construction site.

Security Personnel:

The EPC Contractors have engaged a private security contractor licensed by the Government for the construction phase. During operations, UM6P manages its security and has established a Security Management Plan including the provision of security guards, security vehicles and access control, and a video surveillance system. 

For the campus in Rabat, UM6P has established a Security Management Plan including a code of conduct and rules for the use of force in line with the requirements of PS4.

Broad Community Support is not applicable to this Project. 

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org. 

• Sustainable Development Institutional Policy, UM6P.
• Sustainable Development Plan of Actions, UM6P. 

The above documentation is also available at the UM6P website: https://sd.um6p.ma/

For additional information on the Project, please contact:

• UM6P Communications Department

E-mail: communication@um6p.ma

Phone: +212 525 073 100

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MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, to improve environmental and social project outcomes and foster greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing at the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org