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.

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
PS 7 – Indigenous Peoples
PS 8 – Cultural Heritage

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards.

The 154 acre (62 ha apprx.) Project site is largely barren with some parcels of cultivated land and includes scattered parcels of forest land that total 4 ha. This project will not have adverse impacts on Biodiversity and Natural Resources and thus PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable to this Project.

The Project has been categorized as A given it may result in significant adverse environmental and social risks and impacts that are diverse and irreversible which are associated with various applicable Performance Standards. More specifically, these relate to; i) land acquisition of 154 acres (62 ha apprx) with the resulting economic displacement affecting 321 households; (ii) economic displacement of 113 Scheduled Tribe (ST) households that are defined as Indigenous People (IP) as per PS 7; and (iii) potential impacts on communities immediately neighboring the Project site due to an increase in traffic, an influx of labor and emissions and noise during construction and operations.

IFC based this categorization on a site visit to the proposed Project site and surrounding areas, meetings with OCL management and Company representatives responsible for environmental and social assessment and management, meetings with communities impacted by the Project and a review of environmental and social documentations prepared for the Project. The Company will implement measures to mitigate the identified impacts in a manner consistent with the Performance Standards including those as defined in the 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. The Company has presented plans to address the environmental and social risks and impacts to ensure that the proposed Project will, upon implementation of the specific agreed measures, comply with the environmental and social requirements including the host country laws and regulations, IFC’s Performance Standards and the applicable World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow. Further information is provided in the attached documentation, which includes the ESAP.

OCL has implemented a certified Environmental, Health and Safety Management System (EHSMS) based on ISO 14001 and IS 18001 at its limestone mines and cement plant in Rajgangpur, and also the stand alone cement grinding unit in Kapilas, both of which are in in the state of Orissa, India. Further, the Company has committed to implementing a similar EHSMS for the Project with IFC Performance Standards appropriately embedded within 6 months of the Project commissioning. In the interim, OCL will manage EHS issues and impacts during construction according to its existing EHSMS augmented to address such impacts.



OCL undertook a limited Environmental Impact Assessment (EIA) for the project in 2008-09 so as to comply with national requirements for such projects. Subsequently, the Project received Environmental Clearance and Consent to Establish by the West Bengal environmental authorities. Prior to commencement of operations, the Company will obtain other applicable permits, consents, authorization and all regulatory approvals under all the relevant legislation. The Company will make available to IFC copies of all permits, consents and authorizations as and when these are obtained. Further, the Company will comply with all applicable host country labor laws and demonstrate compliance to IFC with these. The Project EIA has outlined a number of measures to minimize, mitigate and monitor impacts associated with the construction and operational phases. Prior to construction, the Company will develop an EHS Management Plan to mitigate risks and impacts during construction and operations in accordance with Good International Industry Practice (GIIP). The EHS Management Plan will include a Contractor Management Plan, Health and Safety Management Plan, Construction Labor Influx and Labor Camp Management Plans, Truck Parking and Movement Plan and a Community Health, Safety and Security Management Plan. The EHS Management Plan will also define mitigation measures for aspects including transportation of construction material and finished product; concrete mixing, casting on-site, and construction at site; the storage and handling of hazardous materials and wastes; worker accommodation; occupational health and safety; local hiring and training; community engagement; emergency response plans; monitoring and reporting; emissions to air; water and wastewater; solid, hazardous and other waste; and compliance requirements for contractors.



During operations the Company will also implement a detailed monitoring program for: stack emissions and ambient air quality; treated waste water and treated sewage; solid and hazardous waste; ambient noise levels; drinking water quality; and groundwater level and groundwater quality both during construction and operations. OCL will implement a stakeholder engagement plan for ongoing engagement with affected communities. Further, the Company will detail a program to monitor the progress/status of implementation and outcomes of the
mitigation measures defined in the SIA, and also the Community Development Plan (CDP). In addition, the Company will commission a third party social audit to be undertaken 2 years after finalization and implementation of the mitigation measures proposed in the SIA to confirm compliance thereto.



The Company will, as part of the ISO 14001 and IS 18001 certified EHSMS, implement an appropriate internal and third party EHS audit program, and also implement procedures for management review. OCL will also engage a full time appropriately qualified environment, occupational health and safety management specialist at site prior to construction. The Project EHS team will be actively supported by OCL’s corporate EHS team.



OCL has already deployed a team to engage with the affected communities.  In addition to the local disclosure of assessment documentation, OCL will as part of its EHSMS implement a social and EHS performance reporting program for senior management. In addition, on a six monthly basis OCL will submit compliance reports to regulators. Further, the Company will implement a program to share social and EHS performance information with communities’ resident in the vicinity of the plant.

The Company will contractually require the Project’s engineering, procurement and construction (EPC) contractor to adhere to applicable national social and environmental legal requirements and regulations and fully implement the EHS Management Plan as applicable for the construction phase, and the ESAP as applicable. The Company will also require the EPC contractor to deploy an appropriate EHS organization including qualified EHS professional(s) with roles and responsibilities clearly defined. Within its augmented EHSMS, the Company will develop and implement procedures to monitor, audit and document contractor compliance with national requirements, the EHS Management Plan, the EIA, ESAP and applicable IFC Performance Standard provisions.

The Company plans to employ 175 persons of which about 130 will be workers. The Company has Human Resource (HR) Policies and Practices that are generally consistent with IFC Performance Standards but these are applicable to employees. The HR Manual covers employee working conditions and terms of employment including amongst other aspects minimum age, hours of work, shift work, overtime work, emolument and benefits; eligible leave and holidays; code of conduct, misconduct and disciplinary procedures and employee grievance mechanisms. Conditions of employment as well as wages and benefits are communicated to employees through employment letters and notices. The Company will develop, for this plant, additional policies compliant with PS 2 provisions particularly related to contract workers. These policies and procedures will be consistent with the certified standing orders and address compliance with terms of employment, minimum age, wages, leave, hours of work, overtime, disciplinary procedures, access to a grievance mechanism, contractor compliance with labor laws, and procedures that OCL will implement to obtain assurance on contractor compliance.

It is expected that up to 500 workers will be employed during construction. The Company will ensure that appropriate amenities/facilities for contract labor and employees are provided during both the construction and operational phases. This will include the requirement for: i) appropriate facilities and amenities including housing, toilets, washing and cleaning water of appropriate quality, potable drinking water and cooking fuel; ii) treated sanitary waste water to meet the WBG EHS Guidelines prior to discharge; and iii) assess potential host community impacts on account of an influx of labor, and implement mitigation measures. OCL will put in place procedures to monitor contractors so as to ensure compliance with all statutory requirements.



During operations, occupational health and safety (OHS) will be addressed via the Company’s IS 18001 certified system. This will include procedures for safety signage; provision and use of personal protective equipment; safety awareness and training to employees including contract workers; work permit system; near miss, accident, incident monitoring, investigation, reporting and corrective actions amongst others. Further, the Company will develop for the EPC/construction contractor, a detailed OHS plan consistent with GIIP. OCL will contractually require the contractors to comply with the OHS plan.

Management of resources including energy, water, hazardous and other materials: The plant will manufacture Pozzolana Portland Cement (PPC) using fly ash and Portland Slag cement (PSC) using blast furnace slag. Consequently there will be besides the reuse of waste from power generation and steel manufacturing operations, GHG avoidance due to lower clinker use per unit of cement produced. Further, the Project will recycle and reuse up to 175 m3/day of treated waste water besides storing 2000 m3 of rain water. The principal source of power required for the Project is grid electricity that will be supplied via a 6.25 km 132 kV transmission line to be constructed by the Company from the nearest feeder point. Two 500 kVA backup Diesel Generator (DG) sets will also be put in place. Coal (0.06 mtpa) is the principal fuel for Hot Air Generator (HAG). The principal point source of air emissions are the stacks attached to packing plant, coal mill, cement mill (vertical roller mill), besides the stacks attached to bag filters for dust extraction units. The principal emissions are Particulate Matter (PM) from all sources, which will meet national standards and the WBG EHS Guideline limit of 50 mg/Nm3. Carbon dioxide emissions due to project operations are expected to be less than 250,000 tCO2e per annum.



The baseline air quality for particulate matter of less than 10 micron size (PM10), sulphur dioxide (SO2) and oxides of nitrogen (NOx) respectively is within the corresponding national ambient air quality standard. Incremental impact on account of the Project is predicted to meet national requirements and the WBG EHS Guideline limits. The incremental impact on ground level concentration of suspended particulate matter, SO2 and NOx is predicted to be 0.34, 8.8 and 4.7 µg/m3 respectively. Ambient daytime and nighttime noise levels in residential areas remain generally within national ambient noise standards. The Company will implement procedures to ensure that nighttime noise level in residential areas do not exceed 45 dB(A) and daytime noise levels do not exceed 55 dB(A) on account of the Project. The Company will, in accordance with host country regulations, demonstrate a 25 dB(A) reduction in noise levels from the DG set and, if required, will undertake acoustic treatment of the DG set/DG set room.



The Company will also ensure that the refrigerant used in chillers/air conditioning system and the fire extinguishers comply with the Ozone Depleting Substances Rules set by the Government of India (GoI) under the Montreal Protocol requirements.



The plant’s water requirement of 900 m3/day will be met through groundwater extraction until such time piped water supply becomes available. This is only expected in 5 years. The Company will extract water at a suitable pumping rate so as to not impact other nearby users of groundwater. This increase in consumption of fresh water is not expected to have a material impact on water availability in the region. Th
ere is no process effluent but domestic sewage will be treated through a Sewage Treatment Plant (STP) to meet national standards. Further, the Company will also ensure that drinking water complies with national standards.



The storage and use of hazardous materials will be generally limited during the construction and operational phases and primarily related to fuels, oils, lubricants, paints and the like. The Company will designate appropriately contained storage areas for all hazardous materials at the Project site for construction and operational phases.



In addition, the Company will make Personal Protective Equipment (PPE) available to workers handling hazardous materials, enforce the use of PPE, provide training to employees handling hazardous materials, and provide washing stations in material handling areas. The Company will ensure that relevant material safety data sheets are posted at appropriate locations and necessary antidotes for accidental exposure are available and readily accessible. During construction, the Company will require contractors to develop appropriate procedures and facilities for storage and handling of oils and lubricants and management of spills including provision of temporary secondary containment facilities.



The Company will implement procedures to segregate and store waste in designated areas. Sludge generated from the STP will be used as manure for plantation/green belt development. The Company will also define appropriate procedures allied to the requisite on-site infrastructure to store such waste which will comply with the national regulations. This will similarly apply to all hazardous waste generated in that it will be segregated, appropriately contained storage facilities constructed and there will be compliance with the GoI regulations as regards to handling, storage, transport and disposal thereof. Domestic solid waste from the plant and township will be collected and sent to the municipal waste disposal site allocated by the local administrative authorities. During construction, the Company will maximize the reuse of excavated earth and rubble wherever possible and ensure that all remaining solid wastes generated are appropriately segregated and disposed of as per regulatory authorizations.

OCL will construct infrastructure and use equipment that complies with good industry practices. There is an existing road that provides road access to the Project site through an adjoining village. During construction, the primary risks to community health and safety are associated with traffic safety, noise and dust generated by the transport of materials, equipment, and workers to and from the Project site. Similarly impacts may be expected during operations as there will be an increase in traffic with up to 200 trucks on the road daily mainly as result of incoming transport of slag and fly ash and the dispatch of cement. To manage traffic related issues during construction and operations the Company will prepare a Truck Parking and Movement Plan to mitigate potential impacts and this will be consistent with IFC’s requirements. This will include measures like speed control, appropriate provisions for safe movement of trucks through neighboring communities, deployment of traffic marshals, truck parking, minimizing dwell time and provision of facilities for drivers at the site amongst others. Further, OCL will ensure that all equipment operators and drivers including those on contract are trained in safe driving techniques, develop a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; undertake appropriate measures to reduce fugitive emissions from the storage and transportation of excavated earth and other construction material; and periodically monitor ambient air quality and noise levels in potentially affected communities/villages, and implement mitigation measures where required.



There are also potential risks related to labor influx into the project site during construction which may put pressure on local resources such as water, health and sanitation facilities and fuel wood availability. During construction, up to 500 workers are expected to be located at the construction site. The Company will thus develop a Labor Influx Management plan to manage associated impacts including measures to minimize the risk of community exposure to disease due to influx of laborers.



During construction and operation of the Project, OCL will employ security guards and will implement formal procedures related to screening of candidates’ past records, security personnel objectives and permissible actions, training in avoidance of abusive conduct, the use of fire arms and managing of situations where fire arms may be used, recording and investigating security incidents; investigations of bona fide complaints against security personnel and disciplinary actions. A grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel will also be defined.



The project is located in earthquake zone [4] with risk of high intensity earthquakes. The district is also in a zone prone to floods and cyclones.
Thus the Company will design the Project taking into account measures to ensure that the risks from these natural events are not exacerbated for communities resident in the immediate vicinity of the plant. In addition to appropriate design of plant and facilities, OCL will review the District Disaster Management Plan (DDMP) and prepare an Emergency Preparedness and Response Plan (EPRP) for both on and off site emergencies that is aligned with the DDMP. The EPRP will be communicated to communities and stakeholders alike and drills undertaken on emergency response that will involve nearby communities; OCL will also participate in the DDMP drills as required.



Further, the Company will implement procedures, on an ongoing basis, to identify and remedy potentially adverse impacts on community environment, health and safety.

Of the total 321 affected titleholders, 113 belong to the Santhal Scheduled Tribe (ST) and all affected sharecropper families also belong to the same ST. All affected tribal households speak ‘Ol Chiki’- the Santhal language and also speak in Bengali, several households have distinct cultural practices and some tribal households continue to maintain a collective attachment to their locality and prefer not to live in mixed communities. Further, the SIA indicates that the tribal families were distinctly economically worse off than the non-tribal families. However, the ST households have also adopted the cultural practices and rituals of the majority community with whom they reside. In light of the distinct identity and socio-cultural practices, the affected ST households have been considered indigenous people in accordance with IFC’s Performance Standards.



However, their ownership of land is not governed by traditional or customary tenure and all affected tribal households had individual land titles. No tribal families were physically displaced on account of land acquisition. Further, though there is dependence of communities on nearby forests, only scattered sections of forests totaling some 4 ha has been acquired. As per the SIA survey findings, there is no material loss of access to forest resources on account of the Project because the forest is degraded. While some project affected families (both tribal and non-tribal) have shifted out of the area, there has been no displacement of tribal households from lands and natural resources subject to traditional ownership or under customary use on account of land acquisition for the Project. Furthermore, there have been no significant impacts on critical cultural heritage. No place of heritage, sacred grove or shrine is being impacted by the Project.

Further, the nature of impact on the IPs is broadly similar to the other affected groups. However, the affected IP households have been recognized as vulnerable and additional measures are provided in the entitlement matrix for loss of livelihood, as in case of non Indigenous Affected Households. For the project, a separate Indigenous People’s Development Plan (IPDP) will not be prepared as the IPs will be considered as one of several potentially vulnerable groups addressed in the SIA, CDP, Stakeholder Engagement Plan and Resettlement Plan and Entitlements.



The Entitlement Framework includes specific provisions for tribal families for their economic rehabilitation. While cultural distinctions with other communities are limited, the economic condition of ST HH’s is distinctly worse than other caste and community groups. In addition to the Entitlement Framework, the Company has developed a CDP with interventions targeted specifically at tribal families. The CDP includes activities for the development of drinking water, health and sanitation programs, capacity building programs, programs focused on women and IP HH’s, and a strategy for ensuring th
eir participation. The CDP has been prepared in consultation with the tribal families.

One small temple located in the middle of the access road has been acquired. The Company will ensure that agreements regarding identified cultural heritage are concluded prior to the start of physical construction activities. The Company will relocate and restore this temple to a different location to be identified in consultation with the affected communities as defined in the SIA. A cremation ground which was within the land acquired by the Company has been specifically kept outside the boundary wall of the Plant to facilitate communities to continue accessing it. The Company has provided access to the cremation ground.

The Company initially conducted several informal discussions with the affected communities. The interaction with the project-affected families started immediately after the land was identified for acquisition in 2009. These consultations were carried out by the District Administration as well as the Company. During the course of the land acquisition process and in accordance with the applicable regulations, affected households were informed of the land acquisition and offered opportunities to lodge concerns. Further, there were multiple visits by Government Officials. A few Gram Sabha (village assembly) meetings were organized by the Government in 2008-09, and by the Company in 2009-10 and a follow up Gram Sabha meeting was organized in April 2012. Feedback from these were appropriately incorporated by the Company.

Subsequently, OCL’s SIA consultants conducted additional stakeholder engagement activities at all 4 mouzas/ villages as part of the public consultation related to the SIA study conducted in April 2012. The SIA consultant conducted a series of stakeholder engagement activities including focused group discussions, participatory rapid appraisal and social mapping to identify impacts and community development needs. Altogether four focused group discussions were held from April 9-14, 2012 at the respective villages. These consultations were conducted in the local language in different hamlets in the affected villages. The consultant conducted these meetings in the presence of OCL representatives. The Participatory Rural Appraisal techniques provided an understanding of the needs of the communities. The SIA has determined that OCL informed the affected villages about the proposed Project and OCL’s plan with respect to CSR activities. During the process of land acquisition the Company also obtained the required No Objection Certificates (NOCs) from the relevant Gram Panchayats and Medinipur-Kharagpur Development Authority. The SIA has identified the key primary and secondary stakeholders and potential impacts on the affected community.

The SIA provides a description of the Stakeholder Engagement Framework and the Community Grievance Redress Framework. The Grievance Redress Framework recommends creation of a grievance redress cell (GRC) with representatives from the affected community, local elected body, OCL’s representative, NGOs and the local government. OCL has prepared and locally disclosed a mitigation and community development framework that addresses the key concerns and expectations of the affected communities including the social impact assessment, the entitlement matrix, the community development plan and the environment and social action plan. Subsequent to the local disclosure of social and environmental information, the Company has engaged, consulted with, and raised the awareness of the affected communities about the Project’s impacts and benefits. OCL representatives continue to: undertake additional consultations with the affected communities; document the consultation; and implement measures to address concerns and expectations expressed in the engagement process.
OCL is committed to continue engaging with the affected communities to provide information on plant construction and operation, as well as safety and health related issues. OCL will prepare a Stakeholder Engagement Plan to describe the Company’s approach for engaging with the affected communities and project stakeholders and implementation of a grievance mechanism. The Plan will include; i) ongoing identification of stakeholder groups; ii) a schedule/time frame for disclosure of project information (pre, during and post project implementation); iii) staff and management resources to be allocated for implementation of the SEP; iv) documentation of all consultations; v) a budget for developing relevant materials for the meetings; and vi) describe how stakeholder engagement activities will be incorporated into the Company’s management system. The Company is also enabling capacity building of affected communities by: (i) facilitating development of community based organizations for effective dialogue with the Company; and (ii) facilitating development of women’s self help groups for their empowerment, besides enabling income generating and livelihood activities.

The key expectation of the Project affected households is for enhancement of employment opportunities, income generation, skills training and support to community infrastructure related to water, sanitation, health and education. OCL, in consultation with the representatives of affected communities, has prepared plans to address these expectations and has taken steps to address the key ones on a priority basis. The Company has already developed a Community Development Plan (CDP) and has started implementing activities in consultation with the community.

The documentation will be made available by the company at the local Panchayat Offices at village Karnagarh and village Kashijora, in West Medinipur District of West Bengal State of India as well as at the main gate of the Project.

For inquiries and comments about the Project contact:

Mr. DN Singh
Executive Director and Chief Financial Officer
11th Floor, Narain Manzil,
23 Barakhamba Road,
New Delhi -110001
Email: mailto:dnsingh@ocl.in

Based on the review of Project documentation, assessment of the Informed Consultation and Participation (ICP) process, and observations of a range of formal and informal meetings, as defined above, organized by the Company with the affected communities, IFC has determined that Broad Community Support exists for the Project. In general, the Affected Community considers the Project as a development opportunity for economic progress in the area surrounding the Project. *ICP - Information Consultation and Participation **BCS - Broad Community Support

Action		Due Date
Assessment and Management of E&S Risks and Impacts
Deploy a full time appropriately qualified environment, occupational health and safety management professional at site prior to start of construction. Develop and implement an environmental, health and safety management system aligned with the requirements of ISO 14001, IS 18001 and IFC’s Performance Standards. Develop an Environmental, Health and Safety (EHS) Management and Monitoring Plan (EHSMMP) as defined in the Environmental and Social Review Summary document.		December 2012 Within 6 months of Project commissioning March 2013
Labor and Working Conditions
As part of the EHS Management Plan develop and implement a Contractor Management Plan; Construction Labor Influx and Labor Camp Management Plan		March 2013
Community Health, Safety and Security
Prepare an emergency preparedness and response plan (EPRP) both for onsite and offsite emergencies, which is aligned with the District Disaster Management Plan		March 2013
Develop as part of the EHS Management Plan a Traffic Safety Management Plan based on best industry practices and IFC’s Performance Standards.		March 2013
Land Acquisition and Involuntary Resettlement
Complete implementation of the Livelihood Restoration Entitlement Matrix		October 2013
Develop and implement the Stakeholder Engagement Plan		March 2013
Perform an ex-post Resettlement Completion Audit to confirm compliance with IFC’s Performance Standards. Thereafter and if necessary, agree with IFC on a time-based action plan to address any deficiencies identified.		December 2014 December 2014