The company has presented plans to address the social and environmental impacts of its projects and operations, so as to ensure that upon implementation of the specific agreed measures, the company’s operations and projects will comply with the environmental and social requirements - the host country laws and regulations and the IFC environment and social policies and Performance Standards, and the World Bank Group (WBG)/IFC environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the sponsor/company is summarized in the paragraphs that follow. Further information is provided in the attached documentation.
- PS1: Social and Environmental Assessment and Management Systems
The sponsors recognize the importance of environment, social, occupational health and safety (ESHS) aspects associated with the company’s operations. However, these aspects have not been managed under a structured system in the past. Towards, upgrading management of ESHS aspects, the company will, within a timeframe agreed with IFC:
- put in place an ESHS management system (ESHSMS) across all of its operations, which is certified to ISO 14001 and OHSAS 18001 standards, with IFC Performance Standards appropriately incorporated;
- appoint/designate a fulltime appropriately qualified senior executive at the corporate level for oversight of ESHS aspects across all of Polycab’s operations;
- appoint/designate qualified professionals as ESHS managers at each of the operating locations/facilities; and
- put in place EHS standards in accordance with IFC Performance Standards/ EHS guidelines including an audit process for the contractors at the factory, their sub-contractors as also contract/casual workers engaged in construction and operation.
In light of the limited environmental impacts associated with the company’s project’s and operations, Polycab undertakes a limited environmental assessment. However, the company will, as part of the ISO 14001 and OHSAS 18001 certified EHSMS implementation program, undertake a comprehensive and systematic assessment of social and environmental aspects, potential significant impacts of the company’s projects and operations, and implement mitigation measures for the identified impacts. Further, the company will, within a timeframe agreed with IFC, make available to IFC all relevant and valid consents/clearances/permits/authorizations for each of its operating facilities including those pertaining to environment, occupational health, safety and labor related aspects.
- PS2: Labor and Working Conditions
The company, together with its subsidiaries, employs more than 3500 workers including more than 3000 contract workers. While the company does not have a structured HR Policies Manual, Polycab has put in place standalone policies including for:
- performance appraisal;
- leave;
- housing and accommodation;
- loan and salary advance; and
- other employee welfare/benefit measures.
The company has an induction training process in place and has also set up a training centre. The company has a draft Standing Orders (conditions of work), which the company will get certified by the Labor Commissioner, within a timeframe agreed with IFC. The Company needs to upgrade/improve its policies and practices/procedures to:
- ensure statutory compliance;
- communicate labor policies and conditions of work to workers; and
- manage employee grievance redress.
The company carried out a Phase I labor audit (based on document review of one facility and discussions with management team), to identify potential opportunities for improvement of labor policies and practices in the context of applicable labor laws and IFC’s Performance Standard (PS) 2 requirements. Based on the outcome of the Phase I labor audit, the company has developed an action plan to address the gaps identified with respect to applicable laws and PS2 provisions. Further, the company will, within a timeframe agreed with IFC, complete a comprehensive Phase II labor audit (which will include document review across all of Polycab’s operations, interviews with site management, contractors, workers and contract labor at each facilty), and will, based on the outcome of the Phase II audit, agree a corrective action plan with IFC and implement this plan.
Polycab will, going forward, manage occupational health and safety under the OHSAS 18001 certified management system. The company has commenced focusing on safety and is putting in place a safety organization. The company has recently carried out a noise level survey and is in the process of implementing mitigation measures (providing acoustic enclosures to high noise generating equipment etc). There are opportunities for improving: provision and use of appropriate Personal Protective Equipment (PPE) (particularly Bureau of Indian Standards certified ear plugs, shoes, helmets and gloves); safety signage; guarding/covering of moving parts; exposure to heat; fire detection and control system; and mapping/re-engineering of dangerous work practices needs to be undertaken. The company has commenced putting in place a safety committee process (with participation of both worker and management representatives). A monthly internal safety audit program is in place and a report is sent to Polycab Senior Management. In the interim, as part of the labor audit, the company has identified opportunities for improving occupational health and safety practices and has developed and will implement a corrective action plan.
- PS3: Pollution prevention and abatement
The company will undertake, as part of the ISO 14001 certified environment management system implementation program, a systematic assessment of key environmental aspects and potential significant impacts of the company’s operations. Going forward, the company will manage environmental impacts under the ISO 14001 certified EHSMS. While storage of scrap can be improved, Polycab has an active program to reuse and recycle cable waste generated in the process (including waste insulation material). Polycab will explore the feasibility of developing a generic cable waste recycling and reuse program. The principal source of energy is grid electricity, furnace oil is used in melting furnaces (wire mill) and boilers, but the annealing furnaces are electric induction type. Management of emissions, discharges, hazardous materials, hazardous wastes and other wastes need to be improved. Presently, Polycab does not monitor emissions to air (from its melting furnaces and boilers) and discharges from its operations. The company will, within a timeframe agreed with IFC, undertake a benchmark monitoring of:
- stack emissions from furnaces and boilers; and
- work area environment quality, including for presence of VOCs, dust, heavy metals and exposure to electromagnetic fields, to demonstrate compliance with IFC guidelines.
Based on the outcome of this benchmark monitoring, the company will develop an action plan to meet IFC EHS Guideline requirements. Process cooling water is recycled and sewage is discharged through septic tank and soak pit arrangement. Management of hazardous materials and wastes needs to be improved. The company will, within a timeframe agreed with IFC, upgrade management of hazardous materials and wastes to be in accordance with good industry practices and IFC guidelines on hazardous materials management. In particular, the company will implement a program to:
- segregate and store all hazardous material appropriately under secondary containment;
- identify all hazardous wastes generated (including used coolants, lubricants and hydraulic oils) as per host country rules on hazardous waste handling and management;
- label, segregate and store all hazardous wastes under secondary containment;
- dispose hazardous wastes through authorized entities only; and
- maintain records of all hazardous materials used and wastes disposed.
Borewell water is used for drinking purposes except at one facility where RO treated water is used as drinking water. The company will undertake benchmark testing of drinking water quality against IS 10500 standards.
- PS4: Community health, safety and security
The company’s Daman operations are located within an industrial area and material impacts on community health safety and security are not expected. However, in case of operations in Gujarat (Baska and Halol), there are resident communities in the vicinity of these plants. The company will, as part of the EHSMS, implement procedures to ensure that there is minimal impact on community environment, health and safety, during both construction and operation including procedures to mitigate risk of uncontrolled release of hazardous materials (oils, lubricants, hazardous wastes), including risk to communities from hazardous material transport.
The company’s project and capacity expansion is expected to result in an influx of migrant laborers (a majority of Polycab’s present workers are migrants). The company will ensure that appropriate amenities/facilities for labor are provided. In this regard the company will ensure that, to the extent possible, members of local community are employed but where migrant laborer are employed, appropriate facilities and amenities including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel, medical facilities is available; and other potential host community impacts on account of influx of labor are assessed and managed.
The company employs private security and the security personnel are armed. The company will, within a timeframe agreed with IFC, develop and implement procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of human rights violations, use of fire arms and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; bonafide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel.
