Goldwind has a certified management system for quality assurance (ISO 9001), environmental management (ISO 14001) and occupational health and safety (ISO 18000; GB/T28001, China) for its manufacturing facilities. The Company’s management program includes operational policies and procedures that are implemented at the facilities level by supervisors who report to management on a regular basis. Policies and procedures comply with applicable local regulatory requirements for operation of these facilities including those for human resources and labor, occupational health and safety, and environmental compliance. Existing management systems also provides oversight of environmental, social and health and safety issues in its extensive supply chain, with additional oversight of suppliers/subsidiaries with which Goldwind has a significant relationship.
For development of wind farms, the Company selects sites based on potential for wind energy and obtains the necessary approvals from the government before developing the sites. The Company currently owns and operates 10 wind farms of about 49.5MW each. The land take for each of these farms varies between 60 to 200 Mu, China’s wind resources, and therefore these and future wind farms are located in remote areas with few or no inhabitants. Approval processes typically include the completion of an impact assessment process conducted by the government, documented approval from potentially impacted communities for location of the facility, and biodiversity impact assessments. The government ensures that potential impacts of the project are identified and addressed during the project planning stage, and are used to prepare specific environmental control plans containing identified mitigation measures. The Company’s environmental management team has overall responsibility for obtaining appropriate permits and approvals from various government agencies, and ensuring all operations are consistent with the terms of the agreement with local regulatory agencies. Moving forward, Goldwind will ensure that compliance with IFC as well as PRC requirements is included through the project life cycle, from project selection through construction and operations as described later within this review summary.
Human resources are managed at the corporate level with oversight of all the Goldwind's facilities and operations. Training of staff is done on a routine basis in compliance with local workplace regulations. The department of human resources is responsible to ensure that all employees are adequately trained to perform their work safely. Supervisors monitor that standards are met and any reportable incidents are reported and follow up action taken when required. Training, monitoring and reporting framework is consistent with Chinese requirements, and good international industry practice.
Labor and Working Conditions:
Goldwind employs about 1750 directly, and about 1,000 third party workers. The number of sub-contracted employees can vary significantly depending on construction activities at any given time. Goldwind has a Human Resources policy that complies with local and PRC regulatory requirements, and is applied consistently to all direct employees and third party workers. As required by law, the policy is included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. This information is provided in the form of an employee handbook at the time of induction. As is common practice in China, although not explicitly stated, employment relationships recognize the principals of non-discrimination and equal opportunity. Employees at Goldwind have a trade union (Goldwind Union), and employees have the right to freedom of association and have the opportunity to bring to the attention of management any issues or grievances that they may have through union representatives. These provisions are consistent with PS 2.
The minimum employment age at Goldwind is 18 years. Goldwind ensures that child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. For its manufacturing operations, employees work on 8-hour shifts, five days a week. Wages are paid on a monthly basis and calculated on the basis of hours worked, inclusive of overtime. Working hours in wind farm development or site related work can vary by nature of activity and phase of project. Construction activity is largely subcontracted for which unskilled labor is procured from nearby villages. Regulatory requirements in PRC do not require Goldwind to provide direct oversight of wages, working or living conditions of subcontracted labor. Terms of employment for sub-contractors are as per PRC laws and the Company relies on regulatory agencies for ensuring that sub contractors comply with applicable labor laws. Moving forward, Goldwind will review its human resources policy to ensure consistency with IFC Performance Standard 2 on labor, working and living conditions for any labor employed by Goldwind, either directly or through sub-contractors.
Occupational health and safety of employees at Goldwind is managed by the Human Resources and Administration. There is a plan for accident prevention and worker safety consistent with local regulatory requirements. All employees in the company have to undergo a training program at induction and subsequently regarding worker health and safety relevant to their job activity. Facilities are audited yearly by regulatory agencies to monitor compliance with labor regulations. The Company has been in compliance with regulatory requirements and has recorded no significant lost time incidents or fatalities in its operational history. Although Goldwind has been in compliance with applicable regulatory requirements, there is variance between the Company’s regulatory obligations on criteria for recording and reporting incidents or accidents in the work place when compared to good international industry practice (also reference in IFC Performance Standard 2 and Guidelines on Occupational Health and Safety).
As part of the agreed ESAP, Goldwind will retain a qualified internal or external expertise to review and develop an implementation plan to achieve internationally acceptable standards for OHS for its employees and subsidiaries, as well as for products manufactured by Goldwind. The scope of review will include safety of equipment manufactured by Goldwind for use in China or for export to other countries. The Company will take corrective measures to enhance its training programs, workplace air quality and implement standard operating procedures that specifically seek to mitigate OHS risks during manufacture and assembly of magnets used in the WTGs, and during construction and operation of wind power facilities.
Pollution Prevention and Abatement:
The project is implicitly a net benefit from a pollution perspective as it will help generate electricity from a renewable resource and help facilitate the Government of PRC’s goal to reduce its greenhouse gas (GHG) emissions.
As of the end of 2009, Goldwind sold 7,203 units of WTG with a total capacity of 7,522 MW. This can be translated into significant reduction in emissions of GHG and other pollutants. Goldwind estimates this production capacity will reduce emissions of CO2 by approximately 15 million tons per annum (tpa), SO2 by 0.45 million tpa and NO2 by 0.22 million tpa (by avoiding emissions from traditional fossil fuel sources).
Limited quantities of wastes are generated from Goldwind’s manufacture and operation of WTGs at various locations. A majority of Goldwind's facilities are engaged in system integration and assembly of various electro-mechanical and electronic parts and components, and hence no process wastewater is generated at these facilities. Sanitary wastewater is disposed to the public sewer after initial pretreatment on site. Solid wastes are segregated, including recyclables, hazardous and non-hazardous wastes. Certified vendors are used by the Company for the disposal of wastes in accordance to applicable local regulations. A limited amount of general waste is also generated from its operation and maintenance of WTGs, such as packaging, metals, plastics, filters, oils etc. These wastes are disposed by certified vendors in accordance to applicable local regulations. Site development and construction at the wind farms also generates wastes and debris that are disposed by the Company in designated landfills or other sites in accordance with local regulatory requirements. Good construction management practices are used to minimize erosion control, dust and.
Electricity is obtained from the national grid and annual consumption by the Company is estimated to be about 3.5 million KWh for all its manufacturing operations. Water is obtained from the local municipal supply at all its facilities, and usage is estimated to be about 87,000 cubic meters per year, which is used for sanitary usage and irrigation of green areas within the facilities.
Community Health, Safety and Security:
Goldwind's manufacturing facilities and those of its subsidiaries are located in designated industrial zones and away from communities, and hence pose no direct risk to community health and safety. The Company has not received any complaints, negative publicity or legal/regulatory notices related to community health and safety since it commenced operations. The main risk to communities relates to the transportation of large equipment such as WTGs, blades and associate wind power generation equipment, and also to site development/construction rather than operational phase of the project. Key risks posed to the community relate to traffic movement, noise, visual impact, and shadow flicker. With regard to visual impacts it should be noted that the flat landscape, remote locations with very sparse populations, and a landscape that already contains multiple operating wind farms which has already altered its character. No visual impact or noise concerns have been raised by community members within the sight lines of the turbines. Given that the nearest households are far from turbines (in excess of 700 m), noise and shadow flicker impacts are negligible. Traffic safety procedures are being implemented by the project and its contractors as part of the project’s environmental and health and safety procedures. Additionally, there is restriction of access to specific areas/equipment that could pose any risk or hazard (e.g. electric shock, heavy equipment etc.) to community members.
Neither Goldwind nor its contractors employ armed security; if security guards or services are required by Goldwind, these guards will receive training consistent with PS4 requirements to ensure any response to threats to the project/personnel is in proportion to the threat. Goldwind will ensure that subcontractors will be contractually obligated to comply with this requirement.
Land Acquisition and Involuntary Resettlement:
IFC’s assessment considered the potential displacement and compensation of occupants and/or users of land acquired for the construction and operation of Goldwind's manufacturing facilities, project sites and wind farms. To date the Company has acquired land use rights for about 1,193mu (80h) and is in the process of obtaining land use rights for a further 159 mu (11ha) across 3 provinces. That 1,193 mu includes about 615 mu (41ha) for 7 wind farms and the rest for manufacturing facilities in different industrial development zones/parks spread across numerous provinces in China. Preliminary estimates provided by the Company indicate that about 450 individuals were compensated for the total land take. Although the Company has confirmed compliance with regulatory procedures in accordance with the Land Administration Law of the People's Republic of China, provincial implementation procedures and relevant laws, regulations and procedures of the local municipalities, the Company will retain a qualified internal or external expertise to perform an audit of the land acquisition, compensation and resettlement process, in accordance with the objectives of IFC Performance Standard 5 for Land Acquisition and Involuntary Resettlement (see ESAP). The audit will verify details of the process involving original physical and economic displacement compensation(s) made to affected persons. Based on findings from the audit, Goldwind will work with local governments as needed to ensure that gaps identified by the audit are settled in a manner consistent with IFC's PS5 requirements on best efforts basis.
Biodiversity Conservation and Sustainable Natural Resource Management
Environmental impact assessments were undertaken for all of Goldwind’s facilities, including wind farms. All aspects of project development, including those related to biodiversity and conservation are reviewed through government led impact assessments.
IFC has received documentation from the Company confirming approvals/acceptance of the assessments from the government for all Goldwind facilities and wind farms in operation. Some of the approvals for wind farms indicate that biodiversity issues have been addressed at some of the sites, and mitigation measures/requirements identified. Other approvals do not mention biodiversity concerns, though it is not yet clear whether that these issues were reviewed and found not to be applicable.
Pending review by IFC of the actual impact assessments for the wind farm sites, the approvals for the wind farms appear to indicate that biodiversity issues may have been addressed at some of the sites, and mitigation measures/requirements identified. As agreed in the ESAP, the Company will review impact assessments for adequacy of scope and scientific basis for assessment of risk and impacts on biodiversity. Further, to confirm consistency with IFC PS6 on Biodiversity, Goldwind will retain a qualified internal or external expertise, to assess, monitor, map and where required mitigate adverse conditions/impacts in accordance with PS6 provisions.
