While all Performance Standards are applicable to this investment, IFC's environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFC's investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement

This is a Category B project according to IFC’s Environmental and Social Review Procedure as the potential adverse environmental and social impacts presented by the project are few in number, site-specific and have been or can be readily addressed through mitigation measures.

The key environmental and social (E&S) issues have been identified as: (i) VBHC’s ability to provide systematic and consistent management of E&S issues across different projects including the adoption of necessary mitigation measures; (ii) VBHC’s E&S assessment of prospective projects including land acquisition processes to ensure that land acquisition is the result of voluntary transactions, avoids adverse impact on cultural heritage, and considers the biodiversity value of the areas; (iii) pollution control measures during planning and operations including access to public services (water and electricity) and management of liquid effluents; and (iv) management of labor conditions and occupational health and safety risks during construction.

VBHC has presented information on how its current practices and policies address the identified impacts and how it will ensure that the proposed project, upon implementation of the specific agreed measures, comply with the environmental and social requirements, which include the Indian laws and regulations and IFC’s Performance Standards (dated January 01, 2012). The information about how these potential impacts will be addressed by the project is summarized in the paragraphs that follow. Additional actions are summarized in the attached Environmental and Social Action Plan (ESAP).

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Identification of Risks and Impacts and Management Programs: VBHC has a systematic and comprehensive assessment for land acquisition and site development. The company performs a comprehensive due diligence of potential land which include identification of proximity to protected areas and natural parks; assessment of land use and presence of third parties at the proposed site; assessment of topography; availability of water; access to transportation; and availability of public services. Once the land is screened and has potential to be purchased a more detailed assessment is performed including a comprehensive review of land titles; legal due diligence; and technical studies such as geotechnical engineering investigation, infrastructure survey, electrical survey, prefeasibility studies for underground water availability and quality, and hydro geological investigations. VBHC will formalize by means of a policy or/and formal procedures the commitment to assess and manage environmental and social aspects during project planning and execution in a manner compliant with IFC’s Performance Standards.



Design, development and construction follow local legal requirements, including the specifications defined on the Master Plans of each city, the requirements defined by the Ministry of Environment and Forest and the National Building Code of India 2005 (NBC 2005). An accredited architect or engineer endorses the design, including structural and fire safety aspects, before it is submitted for the Plan Sanction by the local zonal authority and to obtain the No Objection Certificate. The plan presented should be aligned with the Building Byelaws for each region, if they exist, of by the building regulations defined by the Ministry of Urban Development. As required by local authorities, VBHC commissions the Environmental Impact Assessments (EIAs); such documents detail the social and environmental impacts and mitigation measures to be implemented in order to avoid, manage or mitigate expected impacts of the projects. Prior to hand over the project to the residents, local authorities perform an inspection and issue an Occupancy Certificate. The Company identifies best practice across different projects to apply procedures consistently throughout all projects.



VBHC has a well defined sustainability vision built-in the corporate strategy; sustainability elements are incorporated starting with the initial design of the housing development. The key principles that are core to VBHC’s strategy include: responsible use of water resources, proper waste management, efficient use of energy, and building community awareness towards sustainability. Environmental elements are managed according to the “Environmental Management Plans (EMPs)” defined in the EIAs and specific procedures such as the manual provided to subcontractors for safety and environment (Roles & Responsibilities for Contractor Works on Safety, Environment & Health). VBHC will expand the current Envir
onmental and Social Management System (ESMS), to cover labor and working conditions, including workers’ accommodation; community engagement; solid waste management; effluent management during construction; and resource efficiency. As part of the implementation, VBHC will provide training to employees and develop management programs, procedures, monitoring and reporting protocols.



Organizational Capacity and Competency: E&S elements at VBHC are managed at corporate level by a Human Resources (HR) director and a Manager responsible for Sustainability initiatives each of them with a support team. At each individual project/development, operational elements such as OHS and management of debris are responsibility of the Regional Business Manager and the Assistant General Manager-Construction with the support of a team of around four EHS supervisors on site. Recruitment of direct labor force for construction and through contractors is responsibility of the Sr. Vice President for Contracts and Procurement. The EHS manual provided to contractors defines clearly their roles and responsibilities regarding environment and safety elements. VBHC’s employees receive regular training on project management, quality, environmental and safety elements. An induction program is available for all employees and contractors.



Emergency Preparedness and Response: VBHC has basic evacuation plans at each site, emergency response is discussed during safety briefing meetings on site and all contractors must follow it. Requirements for emergency response for contractors defined in the safety manual; in addition, EIAs define the principles for basic emergency response plans (Disaster Management Plan: DMP) for the developments. Construction sites are equipped with extinguishers, first aid kits and communication mechanisms in case of emergency. VBHC will develop and implement a formal emergency response plan for construction site and will ensure that supervisors and employees are trained on the procedures. As defined by location the emergency plans will consider communication with local communities.



Monitoring and Review: Project management at VBHC involves various types of monitoring and reporting including assessments of contractor performance, assessment of safety conditions, accident statistics and training; the company is working on defining metrics for human resources performance. Project planning and execution are followed up closely and that includes verification of legal compliance and attainment of licenses. During construction and as part of the EIAs an Environmental Monitoring Programme is implemented. The monitoring reports are well recorded and made available to VBHC’s management through the existing planning system.

VBHC has a total workforce of 274 direct employees, 17% are female employees, a typical proportion of female workers in the construction sector. At each project between 450 and 600 indirect workers are hired through contractors to perform construction tasks in the developments.



Human Resources Policies and Procedures, Working Conditions and Terms of Employment: VBHC has formal human resources policies for sexual harassment, leave holidays, travel, and whistleblower; such policies are available in the Intranet of the Company and at the construction sites. Terms of employment are provided in the contracts the company signs with the employees, such contracts include information regarding place of posting (location where the job will take place), term of employment, working hours, duties and functions, remuneration and benefits, discipline and decorum, and termination of employment among others. Conditions of employment follow Indian law. VBHC is in the process of documenting formal procedures, as part of the expansion of the ESMS VBHC will formalize its human resources policies and procedures and will communicate them effectively to its entire workforce.



The Company will ensure that adequate facilities and amenities are provided in the labor accommodation including: adequate living/sleeping facilities and space per person; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste.



Workers’ Organizations and Grievance Mechanism: VBHC employees do not belong to workers’ organizations or unions, and there has not been such request among the employees. The management team of VBHC confirmed that they would not prevent employees to organize or participate in workers’ organizations. Employees’ grievances are managed through the direct supervisor and the regional head. VBHC has a formal grievance mechanism for workers to raise workplace concerns.



Protecting the Work Force: In compliance with local labor laws and the Company’s policy, VBHC does not use child or forced labor. Contractors are also required to hire only employees older than 18 year of age, which is confirmed through verification of documents and controls at construction site gates.



Workers Engaged by Third Parties: VBHC verifies that companies/personnel contracted to do the construction work are legal entities with a Certificate of Registration and a labor license issued by the statutory authorities. VBHC has included in the contracts with construction companies explicit clauses regarding labor, workmen compensation insurance, and occupational health and safety. The company will review these clauses to incorporate conditions for worker’s accommodation, access to grievance mechanisms, and any additional conditions derived from the implementation of the ESMS such as management of construction debris or reporting in case of finding ar
cheological property.



Occupational Health and Safety: VBHC has a well documented manual for safety and environment (Roles & Responsibilities for Contractor Works on Safety, Environment & Health). Safety procedures applicable to all construction sites are defined in the manual; topics covered include work at heights, electrical safety, material handling, hand tools and power tools, excavation and trenching, fire safety, first aid, hot work operations and lock out-tag out among others. All construction site workers, including contractors, are required to have initial safety training prior to starting work. Internal EHS inspectors are appointed at each construction site and they perform audits, inspections and training of personnel. Appropriate safety measures and use of personal protective equipment were observed during the site visits. VBHC uses only metal scaffolding and includes safety criteria in the selection of construction equipment e.g. cranes, aerial lifts.

Resource efficiency: Resource efficiency measures have been considered in the design of the developments; in particular, VBHC has focused on the final user’s benefits; as mentioned above in this document, the company has a well defined sustainability policy. VBHC homes are designed with floor to ceiling openings into the living room for ample daylight and natural ventilation throughout the day. Spacing between buildings and their orientation is such that even the lowest windows will get sufficient sunlight during the day. Materials used in the building include some eco-friendly materials such as wood substitutes (composite) for doors. Solar heaters are provided for apartments in the upper two floors, lifts and pumps uses variable-frequency drives, and LED (light-emitting diode) lighting is used for common areas in the developments. In addition, the developments have rain water harvesting structures; water is collected and reused for sanitary services within the homes and for irrigation purposes, and for ground water recharge.



Pollution prevention: Environmental impacts and mitigation measures during construction and operation are properly identified in the Environmental Impact Assessments (EIAs), impacts are mainly related to land preparation, air emissions (heavy equipment, vehicles, generators), noise, sewage from domestic use, visual impact (e.g. publicity and cranes), and waste management. As result of the EIA’s the company prepares Environmental Management Plans (EMPs) for mitigating adverse impacts along with delineation of project and post-project Environmental Monitoring Programs.



Existing and planned projects developed by VBHC include the installation of waste water treatment plants. VBHC is currently using innovative “Decentralized Wastewater Treatment Systems” (DEWATS) with vortex, a technology that requires very low maintenance, uses no chemicals and very little power. Such system is estimated to reduce the monthly maintenance cost for residents by around 20% compared to other treatments. The proposed designs are aimed to achieve potential reuse of water, depending on the location of the project and local requirements water can be discharged to surface water or infiltrated, such discharges are planned to be in compliance with local standards for sanitary discharges. VBHC will continue to incorporate relevant waste water treatment systems into the design of the project unless VBHC can secure confirmation from relevant authorities of the acceptance of effluents as discharged to the sewage systems. VBHC will monitor the quality of the effluents and will ensure compliance with local requirements for the management of the liquid effluents for each development.



Waste produced during construction is segregated and collected at the generation point; metal scrap is sold to local companies, organic/domestic waste is collected by the municipality and construction debris are located temporarily at designated points and as feasible re
used for back filling, sub base work for roads and pavements within the project. Hazardous waste is limited to used oil from the generators and some construction equipment, which is collected and disposed by authorized vendors, as defined by the local State Pollution Control Boards. VBHC as part of the ESMS will reinforce training to assure proper implementation of the waste management programs in all the developments as well as proper segregation and disposal of the materials.



VBHC developments include green and social areas, both for recreational and preservation purposes.

VBHC designs and builds the properties in accordance with national standards, including the National Building Code of India 2005 (NBC 2005), which covers fire protection standards, drainage, waste disposal, conservation of fuel and energy and access for disabled people among others. As a requirement of the Indian Building Bye-laws, local authorities inspect the projects, including fire safety provisions; after ascertaining that the buildings are as per the sanctioned plan, and the project architect/engineer has confirm completion, an Occupancy Certificate is issued and residents can move to the project. The developments consider the access to basic services such as electricity and water; the projects developed by the company so far has been in peri-urban areas where such services are granted. Other impacts to the community such as water extraction, noise, air pollution and exposure to industrial activity both during construction and operations are identified in the EIAs and as needed mitigation measures are identified and implemented.



During construction measures are implemented to protect the community, including clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. Access to potable water is guaranteed to all employees at the worksite and at the worker’s accommodation. As part of the implementation of the ESMS VBHC will cover the risks to the communities; in particular VBHC will develop and implement a community grievance mechanism.



Water supply to the developments is coordinated with local authorities; typically water is supplied from on-site wells. The pre-feasibility studies consider the availability and quality of the water in the selection of the new developments. VBHC will ensure that water delivered to the community in the developments complies with national acceptability standards.



The Company outsources security services at their offices and construction sites with a professionally managed security company, which has a well defined training program that include proper conduct towards community.

VBHC has in place important initiatives for the operational phase of the projects, anchored in one of the Company’s sustainability principles: building community awareness towards sustainability. Such initiatives include, use of the terrace space for urban agricultural projects using simplified hydroponics technology; raising awareness and educating residents about the various sustainability features of their community such as segregating waste at source and voluntary self-monitoring of water; and use of organic waste as fuel to produce biogas, among other initiatives. A key component of the developments is the construction of schools (in collaboration with external partners) for the inhabitants of the housing developments and surrounding areas, the company is also developing working women’s center at the developments.

VBHC representatives interact with local authorities; the EIAs approval process requires environmental public hearing/public consultations which are undertaken before the document is approved. The process allows the Company to communicate the plans and to address the concerns of the community. VBHC will publicly disclose the contents of this report (ESRS) and will respond to concerns, and where necessary will undertake actions to address these concerns.

This Environmental and Social Review Summary (ESRS) and accompanying Environmental and Social Action Plan will be publicly disclosed locally at VBHC’s headquarters as well as in the following sites:

Bangalore: VBHC Vaibhava, Property No. 51, Chandapura, Anekal Main Raod, Opp Gobardhan Granite
Bangalore – 562106
Chennai: No.205, Valayakkaranai Village , Oragadam , Sriperumbudur Taluk , Kanchipuram District ,
Chennai - 603204

Please contact the following for inquiries or concerns about the environmental and social impacts of this project.

Mr. Srinivas Thatikonda
Company Secretary, Value and Budget Housing Corporation Pvt Ltd
HM Strafford House, # 29/4, 3rd Floor, 7th Cross, Vasantnagar Extension,
Off Millers Road, Bangalore 560 052
Tel: +91 80 43479500
Fax: +91 80 43479502
Email: mailto:srinivas.thatikonda@vbhc.com

VBHC will make adequate public disclosure of this transaction in the Indian business and trade press.

Broad Community Support is not applicable for this project

VBHC India(28392) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Prepare Corporate Environmental and Social Policy. VBHC will formalize by means of a policy or/and formal procedures the commitment to assess and manage environmental and social issues during project planning and execution in a manner consistent with the principles of the requirements of the Performance Standards. Such requirements include management of potential economic and physical displacement associated with all land acquisition, legacy issues, potential cultural heritage findings, biodiversity and natural resource management issues, among others.	30-Jul-2013	Completed	Completed	6/28/2013
Expand the Environmental, Social and Occupational Health and Safety Management System (ESMS) VBHC will expand the current ESMS, to cover labor and working conditions, including workers’ accommodation; community engagement and grievance mechanism; solid waste management; effluent management during construction; and resource efficiency. As part of the implementation, VBHC will provide training to employees and develop management programs, procedures, monitoring and reporting protocols.	31-Dec-2013	Completed	Completed	12/30/2019
Develop and Institutionalize a Cultural Heritage Chance Finds VBHC will develop a formal chance finds protocol providing appropriate protection in the event of unexpected discovery of items of cultural heritage, and the contractual right to apply such a protocol if necessary. Such protocol will be communicated to all construction companies previous to start construction of the projects.	30-Jun-2013	Completed	Completed	6/28/2013
Revise Construction Contracts to Include E&S requirements The company will review the construction contracts to incorporate environmental clauses to address elements such as management of construction debris, minimum requirements for worker’s accommodation and any additional conditions derived from the implementation of the ESMS such as reporting in case of finding archeological property.	30-Jun-2013	Completed	Completed	6/28/2013
Plan and Implement Emergency Preparedness and Response Systems at Project Level. VBHC will establish and maintain an emergency preparedness and response system. Preparation and planning shall include identification of areas where accidents and emergency situations may occur; communities and individuals that may be impacted; response procedures; provision of equipment and resources; designation of responsibilities; communication, including with potentially Affected Communities; and, periodic training to ensure effective response.	30-Jun-2013	Completed	Completed	6/28/2013