- PS 1: Social and Environmental Assessment and Management System;
- PS 2: Labor and Working Conditions;
- PS3: Pollution Prevention and Abatement; and
- PS4: Community Health, Safety and Security

This is a category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental and social impacts may result that can be avoided or mitigated by adhering to generally recognized performance standards and guidelines.

Environmental and social issues associated with this Project include: adequate social and environmental assessment of the impacts of the Project; the Company’s capacity to manage its social, environmental, health and safety performance, and engage with local communities in accordance with local requirements, IFC Performance Standards and the World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines; assurance of fair, safe and healthy working conditions during construction and operations; utilization of equipment and operational practices that maximize conservation of energy, water and process materials including recycling and reuse initiatives; management of air emissions, wastewater treatment and discharge, and solid and other waste disposal; handling and management of hazardous materials and hazardous wastes; impacts of operations on the local ambient environment; and impacts on transport infrastructure during construction and operations.

The Shendra facility is being developed in a notified special economic zone (SEZ). The land has been acquired from the State Government. As such, issues relating to PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Natural Resource Management, and PS8: Cultural Heritage are not applicable. Also, there is no contact with Indigenous Peoples, therefore matters related to PS7: Indigenous Peoples are not applicable.

PS 1: Social and Environmental Assessment and Management System

IFC’s assessment considered the Company’s management of its environmental, health and safety performance in the establishment and operation of its facilities; compliance with national and local permit requirements; and the Company’s engagement with local communities, regarding environmental, health and safety performance and corporate social responsibility. - Environmental & Social Assessment: 
The facility is located in a notified industrial area (SEZ). Considering the type of operations, detailed Environmental Impact Assessment (EIA) studies were not required as per the applicable requirements. The Company is in the process of procuring all the necessary regulatory permits for the facility. Accordingly, it will comply with stipulated measures to mitigate potential environmental impacts during construction and operation.

As per the ESAP, the Company will provide a copy of all environmental, health & safety (EHS) permits [including Consent to Establish, Consent to Operate, Factories License, Fire No-Objection Certificate (NOC) etc.] before full scale production is started.

Management Systems and Certifications:
The Company has documented policies for: Quality, Environment, Product Safety and Hygiene, Glass and Brittle Plastics, Energy, Safety and Social Accountability. These corporate policies guide the operational procedures at each of its facility. The respective facility heads and the engineering and EHS teams are responsible to develop and implement these site-level procedures.
Cosmo’s Waluj facility has a quality assurance system that is certified compliant with the requirements of ISO 9001 and an environment management system (EMS) which is certified compliant with requirements of ISO 14001. Regarding safety, though the system is not certified, Cosmo has conducted a risk assessment and has developed procedures/instructions and monitoring systems based on that. Similarly, the Vadodara facility also has implemented standardized practices and procedures for managing E&S issues which include well defined roles and responsibilities, and monitoring and reporting. In addition, Cosmo has been certified by European auditors to meet the British Retail Consortium’s Global Standard for Packaging and Packaging Materials (for direct food contact).
As part of the ESAP, Cosmo will extend the EMS (certified compliant with ISO 14001) and safety management system to include the Shendra facility.

- Organization:
The EHS management at the new facility will be overseen by the General Manager of the facility, who will be supported by engineering, safety, and security teams.

- Supply Chain:
The main raw materials (polypropylene pallets) will be locally procured, or will be imported. All other raw materials (specialty additives etc.) will also be procured from local suppliers or imported.

Fire Safety and Emergency Response: The fire fighting system at the Shendra facility will include fire hydrants and fire extinguishers throughout the premises. As required under the ESAP, Cosmo will provide the required fire-fighting and evacuation equipment/infrastructure including fire hydrant, fire extinguishers, evacuation alarm, emergency lighting, marked evacuation routes, etc.

For the Shendra facility, as part of the ESAP, the Company will develop and implement an on-site emergency plan and provide adequate training to workers through class room training as well as evacuation drills.

- Monitoring & Reporting:

Cosmo has an EHS monitoring program in place for all its operations based on the local regulatory reporting requirements. Building upon the existing regulatory reporting requirements, Cosmo will report to IFC on its E&S and safety related performance of Shendra facility through the Annual Monitoring Reports in accordance with the IFC’s reporting requirements. It will make necessary changes in its monitoring program (if any) for this purpose.

PS 2: Labor and Working Conditions

The Shendra facility will employ about 300 workers including both permanent and contract workers.

- Human Resource (HR) Policy and Management 
Building upon the corporate HR policies and guidelines as well as local regulations Cosmo has articulated policies and procedures for its employees. This includes: terms of employment and working conditions including procedures for hiring, training, performance review, grievance mechanism, freedom of association, occupational health and safety etc. As part of the ESAP, Cosmo will also document a non-discrimination policy.

Besides the requirement for a grievance mechanism as defined below, the approach to HR is considered aligned with this Performance Standard. Similar policies and procedures will be applicable to the Shendra facility. For ensuring contractors’ compliance with the legal requirements on wages and benefits, Cosmo uses compliance checklists, collects various compliance documents from its contractors and also conducts random audits. In order to improve the contractor management system, Cosmo will review its compliance checklists with respect to IFC PS 2 requirements and add additional requirements, as needed, to ensure contractors’ compliance with legal and IFC PS requirements.

Additionally, Cosmo will develop and implement a grievance mechanism for workers (including contract workers) which meets the requirements of PS 2 and create awareness among the workers about the mechanism.

- Occupational Health and Safety (OHS) and Training

Like other operational facilities, manufacturing operations at the Shendra facility will be fully automated and mostly consist of continuously operating closed production lines. Machinery will have adequate protection, and safety signage will be provided across the facility.
A full time safety officer is responsible for managing OHS at each of Cosmo’s facility. Workers are provided the required personal protective equipment (PPE) and were noted to be using the same at Cosmo’s operational facilities. A local doctor is available on call as needed. The Company has a calendar for safety training and fire drills, which is rigorously followed and supporting documentation is maintained at the facilities. Similar practices will be adopted at the Shendra facility.
Cosmo monitors accidents, incidents and near misses. Based on available data, no fatal accidents are reported at Cosmo’s operational facilities. Percentage of man-hours lost due to incidents is reported to have reduced from 0.27 percent in 2010-11 to 0.04 percent in 2012-13 at Waluj facility and 0.29 to 0.18 percent in the same period at Vadodara facility. Based on this, the overall OHS performance is considered satisfactory.

PS3: Pollution Prevention and Abatement

IFC’s assessment considered the Company’s operations with regard to resource consumption (water, energy, fuel), efforts to optimize resource inputs, waste minimization and management practices as well as the storage, handling hazardous materials used in the construction and operations of facilities.

- Legal Compliance

The Company maintains a compilation of all the statutory requirements and supporting documents (such as monitoring records). As part of the ESAP, it will procure all the necessary approvals and permits related to EHS for Shendra facility and provide copies to IFC before starting full scale production. It will; (i) undertake regular environmental monitoring as required by the law and maintain the records for the same, and (ii) confirm the compliance with local regulatory requirements as well as with the WBG EHS Guidelines. This data will be shared with IFC through the Annual Monitoring Reports.

- Water Supply and Effluent:

The Company sources its process water from the industrial area water supply. As the production process is dry (with only cooling requirements), the water consumption is primarily for domestic use. The industrial wastewater will be treated in the Effluent Treatment Plant (ETP) whereas domestic wastewater will be treated in the Sewage Treatment Plant (STP).The treated wastewater will be recycled for gardening. Water quality monitoring results from these sources will be submitted to IFC as part of the AMRs to confirm compliance with the WBG EHS Guidelines.

- Energy Supply:
The Project in Shendra will use grid electricity as the primary energy source. The GHG footprint of the Shendra facility is estimated to be approx. 30,000 t CO2 eq /year.
In line with its energy policy, Cosmo will try to enhance its energy efficiency through improved capacity utilization, continuous upgrading of process, technology and equipment, regular monitoring and control on energy use through effective energy management system and benchmarking performance against global best practices.

- Solid and Hazardous Waste:

Hazardous waste and scrap will be disposed through authorized service providers or sold to recyclers. This will include de-mineralized (DM) water sludge, used oil, oil drums etc. There will be no solid waste generated from the process as most of the BOPP waste will be regranulated and either used back in the production process or sold to other plastic goods manufacturers.

During the visit to the Waluj facility, the handling of hazardous chemicals (furnace oil, lubricating oil) and wastes (used oil) was noted to have scope for improvement as the drums were noted to be stored in open. Also, at some storage places, secondary containment was noted to be missing. As part of the ESAP, Cosmo will ensure storage of hazardous chemicals and waste in secured areas with adequate secondary containment and a roof. Also, the Company will develop work instructions for the storage and handling of chemicals and hazardous waste to prevent any impacts on environment and provide training to workers involved in the storage and handling of chemicals and hazardous waste.

PS4:– Community Health, Safety and Security

The Shendra facility is located in an industrial area. Also, there is direct access to the Shendra facility from the Mumbai – Aurangabad – Nagpur national highway so that the impact of vehicular movements and traffic during facility operations on surrounding communities is minimal.

The Company contracts with a security agency for 24 hour surveillance of the facility, with unarmed security guards at its Vadodara facility. Armed security (outsourced) is deployed at Waluj facility. Cosmo shall review the IFC requirements in this regard and accordingly provide training to the security guards regarding use of force.

Cosmo has a community engagement program as a part of its Corporate Social Responsibility (CSR). This program, implemented through Cosmo Foundation, focuses on education related initiatives such as computer literacy, vocational guidance, basic English speaking etc. For this purpose, a full-time team of professionals is deployed. As a part of this program, Cosmo has established several skills development centers in the local schools in the communities nearby its Vadodara facility. The foundation publishes its annual report describing the activities on the Company’s website.

The Company will disclose this ESRS and the ESAP locally at the following address and on their website (http://www.cosmofilms.com).

Cosmo Films Limited (SEZ Unit)
AL-24/1, MIDC – SEZ Industrial Area
Shendra, Aurangabad 431201
Maharashtra, India.

Enquiries and/or comments about the Project may be directed to:

Mr. Neeraj Jain
Cosmo Films Limited
1008, DLF Tower – A
Jasola District Centre
New Delhi - 110025, India.
Phone No: +91 11 49494949
Email: mailto:neeraj.jain@cosmofilms.com