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

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not relevant as the project sites are located in modified urban or sub-urban neighborhoods or agricultural areas and there is no impact on biodiversity.

PS7: Indigenous Peoples does not apply as Indigenous Peoples are not present at project sites.

PS8: Cultural Heritage is not expected to apply as there are no known cultural heritage sites or issues associated with existing premises and are not expected for future developments.

The sponsor will review the applicability of all PSs for each proposed new development.

The Project has been categorized as Category B according to IFC’s Environmental and Social Review Procedure. The nature of the Company’s operations, which involve the provision of educational and IT services, is such that adverse environment and social (E&S) risks and impacts are limited, site specific and may be readily mitigated. Key environmental, social, health and safety issues associated with the Project during construction and operation include: the Sponsor’s system to manage E&S issues during construction and operation of schools; land acquisition issues at school sites; labor and working conditions; life and fire safety design and provisions; resource efficiency; and community engagement.

The Project may result in a limited number of specific adverse environmental and social impacts that can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The Company will manage its environmental and social performance in accordance with applicable local laws and regulations and international standards, including IFC’s Sustainability Framework and World Bank Group (WBG) Environmental, Health and Safety (EHS) General Guidelines.

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. The Company has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with host country laws and regulations, IFC’s Sustainability Framework, and WBG EHS General Guidelines. The information about how these potential impacts will be addressed by the Sponsor/Project is summarized in the paragraphs that follow:

Environmental and Social Assessment and Management System:
Educomp has a corporate team responsible for ensuring that key social and environmental impacts are assessed and accounted and regulatory consents are obtained for new school projects. The company follows a process of taking requisite approvals and clearances wherever applicable from the respective authorities.

Management Programs:
The Sponsor has a management system which it applies to the Millenium, Takshila and Universal Academy branded schools. The management system incorporates procedures and processes for procurement of computers and other electronic goods, school equipment, etc; a detailed laboratory safety process, including labeling, inventory and response to incidents; incident reporting; medical emergencies; first aid manual for common injuries and ailments; security procedures at entry and exit; and management of the school transport service, including emergency procedures and insurance and maintenance details for vehicles. There is a control checklist for the administrative head and principal of each school to monitor implementation of the management system. The Company also has a set of Quality Management System Manuals, in line with ISO9001:2008, which provide procedures and processes for three school brands. Quality reviews are periodically undertaken by an external contractor, and include a review of health and safety issues such as fire safety and provision of potable water.

The sponsor has indicated that it will further develop the management system to provide procedures for principals with respect to managing each facility, including local community engagement, energy efficiency, fire safety, and food and potable water safety. The Company will also prepare a process document for planning acquisition and construction of new schools, including through joint venture partnerships. This document will include procedures for complying with regulatory requirements, standardization of design, fire safety and other building standard compliance issues. The Company has plans to expand within India and internationally and will apply the same management system across the whole corporation.

Organizational Capacity and Competency:
Educomp has a corporate team within the infrastructure management department which manages E&S issues arising during acquisition and construction. Thereafter, the Principal is responsible for all environmental, social, health, safety and emergency management. For all outsourced services, the Principal of the school is responsible for monitoring and enforcing quality standards. Human Resources (HR) management is undertaken through the corporate HR Manager, who has representation at individual schools.

The Company has developed a corporate training program which is rolled out to all its teachers. The on boarding program introduces new teachers to the culture and ethos of the Company and develops skills in the appropriate teaching practices. New teachers have a one year mentoring program and thereafter all teachers are brought together several times a year for regular in-house training. The training is prepared centrally and programs are designed to cover corporate systems, policies and procedures.

Emergency Preparedness and Response:
The Incident Management and Controlling of Risks Manual outlines the policy and procedures for undertaking risk assessments and prevention, preparedness and response to incidents and emergencies. The Head of Institution has full responsibility for management of on-site and off-site school related emergencies and critical incidents. All schools are required to have an Emergency and Critical Incident Management Plan and procedures are in place for typical incidents and emergencies, including medical, transport, fire and laboratory incidents.

Monitoring and Review:
The corporate management team meets monthly to discuss all the aspects of the operation of the Company, including infrastructure, transport, human resources and recruitment. A monthly dashboard is maintained for the purposes of monitoring activities. Once the management system has been fully developed to be compliant with IFC Performance Standards, the quarterly dashboard will be amended to fully report on all internal compliance issues.

Stakeholder Engagement:
Communication with local communities is undertaken at each school on an ad hoc basis, involving communication with Resident Welfare Association as issues arise. The Company will develop a procedure for engagement with local communities prior to and during construction as well as on an ongoing basis once schools are open. The procedure will outline a clear grievance mechanism which will be communicated to local communities.

Educomp currently has more than 17, 200 employees, of which 37% are women. All management and teaching staff are on permanent contracts and Information and Communications technology (ICT) staff are on 3-5 year fixed term contracts.

Working Conditions and Management of Workers Relationship:
The Human Resource Policy and Guidelines document outlines policies on avoidance of sexual harassment, non-discrimination and equal opportunity in the recruitment process, employee code of conduct, recruitment and leave. All policies that are relevant to staff are communicated on the Company intranet site. Information on termination and compensation is provided in the employment letter. There is no retrenchment policy and to date there has been no retrenchment exercise, nor is one expected in this expanding Company. Grievance handling is undertaken on an ad hoc basis through the Company intranet site.

The Company rolls out its HR policies across the whole business and is in the process of completing integration of HR policies for newly acquired sections of the business. As part of this process the sponsor has indicated that it will develop written policies on grievance handling.

Educomp does not prohibit collective agreements but no staff are affiliated to any trades union.

Occupational Health and Safety (OHS):
The Company has a team responsible for approving the design of all schools, maintaining consistency and quality in the design and construction of new schools. The Company will prepare detailed procedures for exercising its responsibility for OHS, in accordance with PS2, on its own and joint venture partners’ sites, including incorporating OHS requirements in standard conditions of contract for construction and agreeing the same with joint venture partners; actively monitoring OHS activities on site and requiring contractors to demonstrate good OHS management through regular reporting.

Workers Engaged by Third Parties:
The Company outsources school transport, housekeeping, catering, security and maintenance. It verifies that the workers are paid at least the minimum wage. The Company will develop procedures to ensure that all aspects of PS 2 are complied with, including developing a grievance mechanism for all contract workers.

In a number of schools, the Company’s joint venture partner employs around 1500 teachers. In this case, the Company will ensure that the staff also benefit from working conditions that are compliant with PS 2.

Supply Chain:
In 2011-2012, the Company purchased around 50,000 each of computers, uninterruptible power supply (UPS), projectors and speakers from leading providers such as ACER, LENOVO, ACTO, Quady.

Educomp has 71 schools in operation or under construction, with around another 15 schools in the planning stage. Of these, 38 were designed, constructed and are fully owned by the Company, seven were acquired and are fully owned by the Company and 32 are asset light, which means the company rents the school buildings. Although, the Company has built many of its own schools, owning the land and building, it is moving towards the asset light model of expansion and plans to open more than 10 asset light schools in the next year. This model requires a partner to build a purpose-built school under a 30 year leasehold agreement. The Company enters into such an agreement at the concept stage and requires the partner to follow its design brief. The design brief refers to a number of construction guidelines which are aimed at maximizing energy efficiency, such as sun angle, elevation, wind flow and orientation of the building. Although not specified in the design brief, the Company now asks for a solar study and air circulation study during the design phase of all its schools to ensure that the orientation minimizes glare. The Company intends to improve on energy efficiency of its schools and is currently developing a business case for solar energy. In addition, the Sponsor will specify energy efficiency benchmarks for each school to achieve, and monitoring the outcomes. A procedure will be developed and integrated into the management system to ensure that a consistent approach is taken across all its new schools. For existing schools, it will ensure that a program of identification and replacement of low efficiency equipment such as lighting and air conditioning is rolled out. The Company will use the most cost-effective high efficiency replacements as standard.

The Company will develop guidelines for contractors and its joint venture partners to manage E&S issues on site, including handling and disposal of solid, liquid and hazardous waste.

While all schools are connected to grid electricity, where supply is intermittent schools rely on diesel generators to run the computers and fans. The Company’s schools use 11.8 million kWh electricity and 1.3 million kWh diesel. As a benchmark, the company uses 26kWh per square meter. Annual greenhouse gas emissions of the Company’s operations are approximately 11,000 tonnes per annum CO2 equivalent.

Annual greenhouse gas emissions of the Company’s operations are approximately 6,600 tonnes per annum CO2 equivalent.

To date, the Company has not specified water efficiency in its design briefs. It will undertake a review of water use in its schools and identify ways of minimizing use of water, set benchmarks for its schools to achieve and monitor implementation. It will review the cost-effectiveness of specifying more water efficient taps and toilets in its schools. Potable water in all schools is either purchased in 20 liter bottles or treated on site and tested biannually to ensure it meets local potable water standards. Going forward, the Company will test against potable water quality parameters outlined in the WBG EHS General Guidelines.

Solid waste at all schools is removed by municipal waste contractors. Sewage is either treated at an onsite treatment plant or disposed of into the municipal sewers or septic tanks, in compliance with local regulatory standards.

The Company has supplied computers and other electronic equipment to its own schools, information technology centers and head office. When these computers reach the end of their life they are sold in accordance with the Company asset disposal process. In case there is any disposal of electronic waste in the future, the Company will prepare a policy and procedures on safe disposal of such waste.

The Company does not use pesticides in the playing fields and lawns of any of its schools.

Life and Fire Safety (L&FS):
The Company has reviewed and will comply with IFC’s life and fire safety guidelines, including the requirement to develop a L&FS Master Plan for each greenfield development and major renovation, that identifies major fire risks, applicable codes, standards and regulations, and mitigation measures. Each L&FS Master Plan will be prepared by a suitably qualified professional acceptable to IFC, who will certify that the design meets the requirements of an international L&FS standard such as the British Standard or its equivalent. After completion of construction of each new or renovated property, the qualified professional will undertake a review of as-built L&FS features of the development and certify that construction of these systems has been carried out in accordance with the accepted design, or alternatively propose an action plan to bring about compliance. Where the school is built by a joint venture partner, the Company will ensure that IFC’s life and fire safety guidelines are also complied with.

For any schools currently under construction, the Company will commission a suitably qualified professional, acceptable to IFC to review and, if necessary, modify the fire safety design considerations and certify that the design meets the requirements of an international L&FS code such as the British Standard or its equivalent

The Sponsor is undertaking a L&FS audit of a selection of its existing schools to assess the degree of compliance with local and international fire safety codes and as necessary to recommend enhancements to meet such standards. Any corrective actions identified will be included to the IFC Environmental and Social Action Plan to bring about such compliance. If significant gaps exist, the Company will also include a Corrective Action Plan that demonstrates to IFC that L&FS deficiencies in all operational schools are corrected.

When the Company considers acquisition of schools, it will commission a L&FS audit of any target acquisitions prior to acquisition. These audits will either certify that the design meets the requirements of an international L&FS standard, or identify corrective measures to be added to the Environmental and Social Action Plan to bring about such compliance.

In order to address seismic stability of schools, current practice in the Company is to design all new schools in accordance with the relevant national building code. In order to ensure that all construction projects meet IFC’s PS, the Company will include a review in line with International Building Code in the design specifications for new schools and selection criteria for target acquisitions.

Emergency Preparedness and Response:
The Company implements emergency preparedness and response plans for its facilities, based on the requirements of the Incident Management and Controlling of Risks Manual. Emergency plans respond to the needs of L&FS requirements. The Company will develop and implement a training plan to ensure that all students and employees are knowledgeable of emergency procedures and will perform fire drills at the frequency required by the national regulations.

Once the schools are operational, they will contract a reputable Company to provide security services. The Sponsor will develop a policy in its management system that requires verification that all security guards are not implicated in past abuses and trained in the use of force and appropriate conduct towards workers and Affected Communities.

No local communities have been significantly affected by the Company to date, nor are future significant adverse impacts expected. The Company’s operations generate local employment opportunities and do not have adverse impacts on the communities. The Company intends to comply with the Government of India’s Right to Education policy.

Company will disclose this ESRS and the ESAP at its website: http://www.educomp.com.
as well as locally at the following addresses:

Mr. Sanjay Jain
Educomp Solutions Limited
514, Udyog Vihar, Phase – III, Gurgaon – 122001, Haryana, India
Ph.: 91-124-4529000

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
The Sponsor will update its management system encompassing social, occupational health and safety (“OHS”), human resources and environmental affairs for all its operations to comply with IFC policies and performance standards. At a minimum the management system will incorporate policies and procedures, compliant with PS1 to 8, on the following: · Employee grievance handling; · Verification of working conditions and provision of grievance handling for third party employees; · Detailed procedures for ensuring OHS management during construction and operation of its schools; · Policy and procedures for safe disposal of electronic waste. · Procedures for maximizing resource efficiency in line with Green Building Standards (see action 3); · Food and potable water safety, including testing according to WBG EHS guidelines. · Formal system for community engagement and grievance mechanism, during planning, construction and operation of schools, clearly communicated at each site and on the Company’s website. · Life and fire safety (“L&FS”) requirements (see action 4), including procedures for auditing L&FS standards at target acquisitions, and seismic hazard assessment guidance(in line with International Building Code); · Selection criteria for security services, to include a requirement to be licensed and staff to be fully trained, with verification processes. · Verification of land acquisition due diligence undertaken by joint venture partners · Monitoring and reporting through the quarterly dashboard and other formal reporting mechanisms.	12/30/2013 12:00:00 AM	In Progress	Under discussion with IFC client
Ensure adequate E&S oversight and management on construction sites. This will include: (i) Inclusion of environmental, social and occupational health and safety requirements in bids and contract documentation for all Company owned and joint venture construction projects. (ii) Preparation of E&S guidelines and procedures for construction sites, including management of solid, liquid and hazardous waste.	12/30/2012 12:00:00 AM	In Progress	Under discussion with IFC client
Develop Green Building design standards detailing benchmarks for energy and water consumption and specific requirements regarding building envelope and building services design, in line with international best practice and monitor implementation	12/30/2013 12:00:00 AM	In Progress	Under discussion with IFC client
For each new development and renovation contract a competent professional acceptable to IFC, to: (i) Prepare a L&FS master plan, including preliminary drawings and specifications; (ii) Provide to IFC certification that the design of each new school is in material compliance with local as well as internationally accepted L&FS standard(s), eg. US NFPA or relevant British standards; (iii) Provide to IFC certification that the construction of the L&FS systems has been carried out in accordance with the accepted design.	12/31/2016	In Progress	In Progress
For schools currently under construction contract a competent professional, acceptable to IFC, to review and if necessary modify the fire safety design and certify that the construction of the L&FS systems has been carried out in accordance with an international L&FS code.	12/31/2015	In Progress	In Progress
Undertake L&FS audit of one school at Mussorie and two schools at Chennai as agreed with IFC, to assess the degree of compliance with local and international fire safety codes and as necessary to recommend enhancements to meet such standards. Any corrective actions identified will be included to the IFC Environmental and Social Action Plan to bring about such compliance. If significant gaps exist, the Company will also include a Corrective Action Plan that demonstrates to IFC that L&FS deficiencies in all operational schools are corrected.	12/30/2012 12:00:00 AM	Completed	Completed	09/04/2012 12:00:00 AM