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

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

Key E&S risks and issues associated with this Category B Project include: development and implementation of corporate environment, health and safety management systems; engagement with local communities in accordance with local requirements and IFC’s Performance Standards; assurance of fair, safe and healthy working conditions in compliance with local regulatory requirements and relevant Performance Standards; impacts of transport infrastructure on nearby communities; life and fire safety management for all public use buildings (both existing as well as proposed) in accordance with international fire safety codes; resource efficiency (water and energy efficiency) and impacts of land acquisition where applicable.

The existing and proposed hotels are located in urban areas. Many of the hotels currently in the portfolio are being developed on leased land or spaces (owned/leased) as part of mixed use developments. Land required for hotels is purchased through willing buyer-seller transactions. No person or economic activity was previously displaced as a result of these transactions and therefore Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) is not applicable. All SAMHI hotels are located/being developed in urban areas and the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) do not seem to apply. Going forward, as part of the management systems and procedures (discussed below under PS1), SAMHI will screen future projects with respect to IFC PS requirements.

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.

Environmental and Social Impact Assessment (ESIA): Considering the built-up areas of current portfolio of SAMHI hotels are generally not required to undertake an ESIA study as per applicable legal requirements. However, some of the hotels are located in the mixed use developments in which the total built-up area exceeds the threshold for an assessment as per the environment clearance process. For such hotels, SAMHI reviews environment clearance for the development from the authorities before occupation. SAMHI reviews permits for the leased spaces as part of the legal review and obtains required E&S permits before operation of the hotels. Also, in case mandated by the operator requirements, SAMHI conducts environmental due diligence of land for greenfield developments. For brownfield acquisitions, a legal as well as life & fire safety (L&FS) due diligence is conducted to identify areas of improvements/refurbishments as per SAMHI/operators’ requirements.



As part of the ESAP and the Environment & Social Management System (ESMS) discussed below, SAMHI will develop a corporate procedure on screening of new projects (either greenfield or brownfield acquisitions) to identify any risks with respect to IFC PS and legal requirements and preparing a management plan for the same.



Policy and Management Systems: Currently hotels in SAMHI Group are developed and operated as per systems and processes of operators’ requirements. SAMHI does not have any E&S policy or management systems. To meet the requirements of the PS1, SAMHI will document its E&S and Sustainability policy and develop an ESMS. The policy and ESMS will cover entire SAMHI portfolio.



The ESMS will cover all the key elements as per PS1, including a policy, process of identification of risks and impacts, management programs and processes, emergency preparedness and response, stakeholder engagement, monitoring and reporting framework. The procedures and programs developed under the above mentioned corporate management system will ensure development and operation of SAMHI portfolio with respect to applicable legal requirements and IFC PSs.



Some of the key procedures/programs in the ESMS (among others) will include (a) Screening of new projects (either greenfield or brownfield acquisitions) to identify any risks with respect to IFC PS and legal requirements and preparing a management plan for the same; (b) Comparing new operators’/partners’ policies and procedures on HR, life & fire safety, resource efficiency and pollution prevention with respect to IFC PS requirements and ensuring compliance during operation; (c) Life & Fire Safety (L&FS) management programs to meet operators’ and IFC PS requirements including international L&FS codes; (d) Contractor management programs to supervise their compliance with legal requirements and IFC PS during both construction and operation; (e) Resource Efficiency programs; (f) Pollution prevention processes with respect to various environmental requi
rements during construction and operation; (g) Monitoring and Reporting Framework including ongoing review of compliance status of all hotels and internal/external assessments and reporting to the management/board/investors; (f) Stakeholder engagement and community grievance mechanism; and (g) roles and responsibilities and training needs for responsible personnel.



As set forth in the ESAP, for the development of the policy and ESMS, SAMHI will engage a qualified consultant (that meets IFC’s requirements) and agree with IFC on terms of reference (ToR) for the consultant. The policy and management systems, including procedures, will be developed (as per the ToR) and implemented for SAMHI portfolio within agreed timelines.



Organization: SAMHI has a Director - Projects who monitors development of various hotels with support from the project management company (PMC) and coordinates with the operators. SAMHI employs a PMC who is responsible for management of various contractors on-site including compliance with safety and labor law requirements. SAMHI has additionally appointed a person who will be responsible to monitor contractors’ compliance with various legal requirements.



During operation stage of the hotels, hotel operations are monitored by teams of various international operators for environmental and sustainability matters. Also, SAMHI has an Asset Management team which is responsible to review hotel performance.



As set forth in the ESAP, SAMHI will appoint/assign a person, within agreed timelines, who is dedicated to E&S management of entire SAMHI portfolio at various stages in order to ensure compliance with national legal requirements and IFC PS requirements and implementation of the ESMS.

Monitoring and Reporting: As per the ESAP and development of corporate ESMS, SAMHI will develop a corporate EHS monitoring procedure which will specify minimum KPIs/parameters to be monitored, monitoring frequencies for all facilities and type of monitoring and the definition of thresholds that signal the need for corrective actions. In addition to applicable legal requirements, the monitoring thresholds will include thresholds specified for ambient air quality, stack and effluent quality in the World Bank Group (WBG) EHS Guidelines, both general as well as sector specific on Tourism and Hospitality Development. The monitoring procedure will also define and require monitoring of defined KPIs/parameters for under construction and operating hotels. Regular monitoring will be conducted for the defined parameters and SAMHI will ensure corrective actions are taken as necessary based on the results. The EHS performance of hotels will be regularly documented in an integrated format as per the defined management system processes and reviewed by the management.



Specifically for construction phase of the hotels, a documented monitoring procedure and check-list shall be developed and followed to monitor contractors’ compliance with EHS manual (pa
rt of the agreements signed with contractors) and legal requirements on working conditions, labor camp facilities, labor law and safety requirements at all construction sites (including those for Formule1). The procedures will include reporting of EHS performance of all sites in an integrated format as per the defined processes and reviewed by the management.

Emergency Preparedness and Response: The L&FS systems of the existing and proposed hotels are discussed under PS4. Required fire safety equipment (fire extinguishers) was noted to be provided at the construction sites visited as part of the appraisal. All operators have requirements to document crisis management/emergency response plans for the hotels and training of the hotel staff on these plans. Such plans were noted to be available at the visited operating hotels.

A typical Formule1 hotel employs 20 to 25 employees. The other mid-range hotels of SAMHI employ about 100 employees.



The employees at Formule1 hotels are covered by Barque’s/Accor’s HR policies which are in line with PS2 requirements. The other hotels being developed by SAMHI will also be operated by reputed international brands. As per public data available, all these brands have adopted Human Rights Policies which cover compliance with applicable laws, prevention of child labor, elimination of forced and bonded labor, non-discrimination, freedom of association and providing a safe and healthy work environment. Therefore, HR policies at these hotels are expected to meet the PS2 requirements.

Third Party Workers: Formule1 hotels do not typically hire many service providers except security. The other hotels will have service providers mainly for housekeeping and security. Barque has a documented policy for outsourced employees. Many of the other operators also have publicly disclosed code of conduct/compliance requirements for their service providers/suppliers. As per the ESAP, SAMHI shall ensure that all hotels have procedures for service providers/suppliers on-site for meeting the applicable legal requirements as well as PS2 requirements.



Regarding off-site service providers (e.g. laundry services), as set forth in the ESAP, SAMHI shall develop procedures to prevent use of child labor or forced labor by such service providers and monitor service providers’ compliance with basic legal permit requirements. As per these procedures, the screening and contracting processes of these service providers shall include evaluation and ongoing monitoring on these aspects. For suppliers of goods/service providers, the level of screening and monitoring shall depend on leverage and/or control by SAMHI.

Occupational Health and Safety (OHS): Most (11 out of current portfolio of 17) Formule1 hotels are located in leased spaces where civil structure/cold shell is constructed by the owner and part of the space is allocated for the hotel. Though rest of the Formule1 hotels will be owned properties, the land and cold shell (in case of Gurgaon property - built as per Barque specifications) are purchased from the original owners. Therefore, development of Formule1 hotels will only involve fitment and furnishing work and no major construction activities. Development of other hotels involves civil construction as well.



During construction and development of hotels, SAMHI employs a PMC responsible for management of various contractors on-site. SAMHI has documented EHS requirements in a manual compliance which is included in the agreements signed with contractors. The PMC is responsible for monitoring compliance of various contractors with safety and labor law requirements. For the hotels involving major construction activities, a safety officer is present on-site to train the contractors and monitor their activities with respect to EHS manual. The safety
officer conducts safety inspections, reports and follow-up on any non-conformances (NCRs).

Based on observations during appraisal, areas of improvements were identified in safety systems at the Formule1 sites. At the other sites, improvements were identified in terms of documentation, reporting and follow-up of NCRs. As mentioned earlier, SAMHI has appointed a person (in Corporate Affairs division) who is responsible to monitor contractors’ compliance with various legal requirements. As per the ESAP and as part of the ESMS, SAMHI will develop a documented monitoring procedure and check-list to ensure contractors’ compliance with EHS manual and legal requirements on working conditions, labor camp facilities, labor law and safety requirements at all construction sites (including those for Formule1). The procedures will include reporting of EHS performance of all sites in an integrated format as per the defined processes and reviewed by the management.

Resource Efficiency: SAMHI focusses on resource efficiency as part of the designs of the hotels. Key features in the design of Formule1 hotels include the following.



On Plumbing, efficient dual flush water closets (3 liter/6 liter), water efficient fixtures in the bath, air to water heat pumps for hot water production, urinals with sensors in public toilets, auto shut-off/aerators in taps in the public wash rooms, pumps with variable frequency drives, rainwater harvesting system and reuse of treated wastewater from STP for cooling, flushing and cooling towers.



On heating and ventilation, Variable Refrigerant Volume (VRV) units for air conditioning and natural ventilation in smoke management and staircase pressurization.



On electricals, guest rooms, corridors and outdoor areas provided with LED lighting and T5 fluorescent lighting for back-of the house areas.



On Materials, using low E double glazed glass panels and heat insulation for building exteriors and roof.



Other SAMHI hotels will have similar features except the VRV units. The air conditioning systems in these hotels will have air conditioning system with water cooled chillers. Additionally these hotels will have a building management system (BMS) for monitoring various key parameters of electrical, plumbing, air conditioning, fire fighting and protection systems.



On an average, Formule1 hotel is expected to have an electricity consumption of about 400,000 kWh per year and have an energy intensity of 120-130 kWh/m2/year. The other hotels will have an electricity consumption of about 1.6-2.0 million kWh per year and have an energy intensity of 140-160 kWh/m2/year. A preliminary analysis of design of two SAMHI hotels (a Formule1 and a mid-range hotel) through IFC Green Excellence in Design for Greater Efficiencies (EDGE) tool indicates that hotels seem to have adequate energy efficiency features to qualify as a green building (i.e. 20% more energy efficient than the local benchmark). SAMHI has agreed to adopt IFC EDGE standards (i.e., 20 percent less energy, water and materials consumption compared to an equivalent benchmark) for two hotels in 2014 and make reasonable efforts to apply to same in all its assets. SAMHI is interested in obtaining IFC EDGE certification for eligible Formule1 hotels (and possibly some of the other mid-range hotels). This would involve a detailed analysis of hotel designs for resource efficiency (including on energy, water and materials). One of SAMHI’s mid-range hotels has already been EDGE certified.



During the operation stage, all hotels monitor key parameters on energy and water efficiency as mandated by the operators’ requirements. It was noted that typically all international operators have sustainability programs which include goals on energy and water efficiency. SAMHI will also monitor and compile data on energy and water consumption as part of the monitoring framework under the ESMS (discussed under PS1).



Water and energy supply
: Water for all the hotels is sourced from the local municipal sources and/or on-site borewells. The raw water is further treated (filtration, softening, reverse osmosis, as required) and the treated water quality is monitored to confirm that it meets the national potable water quality and operator standards.



The electricity is sourced from the grid. However, diesel generators (DG) are provided as back-up in case of grid power cuts. The diesel generators are provided with acoustic enclosure. The DG stack heights are maintained as per applicable statutory norms.



Pollution Prevention: SAMHI provides sewage treatment plants (STPs) on-site in all its hotels. The STPs were noted to be operating at the visited hotels except at Ahmedabad where the sewage is discharged into the public sewage system and treated in the city STP. The treated wastewater treated as per local standards and is used for gardening and toilet flushing at some of the hotels.



As regards solid waste management, food waste is generated only at mid-range hotels as Formule1 hotels do not have any kitchens. The food waste are disposed of either through municipal waste disposal system or provided as animal feed to local pig farms. STP sludge is used as manure for gardening. The other solid waste (paper waste, packaging materials, plastics etc.) is sorted and sold to local agencies that in turn recycle these waste. Used oil (from the back-up diesel generator maintenance) is disposed of through authorized recyclers.



Emissions are primarily from backup diesel generators (DG) as kitchens (wherever provided) will use LPG as fuel.



The DG set emissions (and treated effluent quality) will be monitored and managed in accordance with environmental permit conditions as part of the monitoring framework under the ESMS (discussed under PS1).



GHG emissions: Based on the available information on current portfolio of hotels and average energy consumption of Formule1 and mid-range hotels, the GHG emissions for the Project are estimated to be 18000 tonnes CO2 equivalent/year.

Regarding L&FS, all hotels are designed with respect to national building code (NBC) requirements, local fire department requirements and standards of the respective international operator. Most of the operators associated with current portfolio of SAMHI hotels (under construction as well as operating) were noted to have L&FS standards which meet the requirements of an internationally accepted L&FS code (e.g. National Fire Protection Association (NFPA)). The operators review the designs of the hotels with respect to these standards as well as verify their implementation on-site (either through internal L&FS teams or external consultants) before initiating operation of these hotels. SAMHI will keep required documentation confirming this review at design and post-construction stages for all its hotels.



The Formule1 hotels were also noted to be designed as per respective operator requirements which require L&FS systems to be provided based on applicable local standards and legal requirements. The L&FS systems are reviewed by an external consultant for compliance with these requirements. Any gaps identified in this review are closed before initiating operation of these hotels. As part of the ESAP, SAMHI will review the L&FS Master Plan of existing Formule1 hotels with respect to an internationally accepted L&FS code (e.g. National Fire Protection Association (NFPA). Based on the review, as required, suitable modifications will be made in the L&FS Master Plan to mitigate any additional identified critical L&FS risks within agreed timelines and required modifications will be made in the designs for future hotels.



As most of Formule1 hotels are located in leased spaces OR on land purchased alongwith the civil structures already constructed, no major construction activities are involved in development of these hotels. All SAMHI hotels are located in urban areas with access through major roads. PMCs manage the construction traffic as per Traffic department clearance conditions and mostly during night time.



Formule1 hotels do not have kitchen facilities. The other hotels will have kitchens which generally meet Hazard Analysis and Critical Control Point (HACCP) certification as mandated by the operator requirements. All hotels will supply potable water for all domestic needs such as drinking, food preparation and personal hygiene (washing or bathing). An onsite water treatment plant is provided in all hotels to treat the raw water to meet the local potable water quality standards as well as operator requirements.



During the operation of the hotels, unarmed private security guards are hired through external agency.

SAMHI conducts or is planning to conduct corporate social responsibility (CSR) activities in the areas of women empowerment, promoting education to differently abled children and health care for labors. Additionally, as part of the sustainability programs, all international operators design and undertake community outreach and CSR activities around each of the hotels (financed by the hotel budget provided by SAMHI).

As per the ESAP and development of ESMS, SAMHI will develop a community engagement and grievance mechanism including a process to engage with the neighboring communities, receiving and responding to their grievances.

SAMHI will disclose this ESRS and ESAP at the following address. Due to the corporate nature of this proposed investment, the company''s headquarters are being provided in lieu of project locations. Any queries and/or comments about the project may be directed to:

Mr. Sanjay Jain
Director – Corporate Affairs
SAMHI Hotels Pvt. Ltd.
14th Floor, Building 10C
Cyber City, Phase-II
Gurgaon, Haryana – 122002, INDIA.
Tel: +91 124 4910-100

Broad Community Support is not applicable for this project

Samhi Barque(34227) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Hire a qualified consultant (acceptable to IFC) to develop the corporate E&S management systems (ESMS) and agree with IFC on a terms of reference (ToR) for development of these systems.	31-Aug-2014	Completed	Completed	8/18/2014
(a) Develop and implement an environmental & social (E&S) policy and ESMS applicable for all hotels as per the agreed Terms of Reference (ToR) as described in the ESRS. (b) As part of the ESMS, and as described in the ESRS, develop and implement: • Corporate environment, health & safety (EHS) monitoring procedure as defined in the ESRS including an integrated reporting format for documentation of EHS performance of all hotels • Monitoring procedure and check-list for construction phase of the hotels including reporting of EHS performance of all sites in an integrated format and review by the management. • Community engagement and grievance mechanism including a process to engage with the neighboring communities, receiving and responding to their grievances. (c) Conduct regular monitoring and reporting as per the monitoring procedures and take corrective actions based on the monitoring results. [As defined in the ESMS process]	31-Mar-2015	Completed	Completed	7/31/2015
Appoint/assign a person dedicated to E&S management of entire SAMHI portfolio at various stages in order to ensure compliance with national legal requirements and IFC PS requirements and implementation of the ESMS.	31-Dec-2014	Completed	Completed	12/31/2014
(a) Develop and implement procedures for on-site service providers/suppliers for ensuring their compliance with the applicable legal requirements as well as PS2 requirements. (b) Develop and implement procedures for off-site service providers/suppliers to prevent use of child labor or forced labor by such service providers and monitor their compliance with basic legal permit requirements. The screening and contracting processes of these service providers shall include evaluation and ongoing monitoring on these aspects.	31-Mar-2015	Completed	Completed	12/31/2015
(a) Conduct a review of L&FS Master Plan of existing Formule1 hotels with respect to an internationally accepted L&FS code (e.g. National Fire Protection Association (NFPA)). The review shall be conducted through a qualified consultant (acceptable to IFC). (b) Based on the review, agree on a corrective action plan for undertaking suitable modifications in the L&FS master plan of existing hotels to mitigate any additional identified critical L&FS risks within agreed timelines and include these modifications in the designs for future hotels. (c) Implement suitable modifications in the L&FS master plan of existing Formule1 hotels to mitigate any additional identified critical L&FS risks as per agreed plans and include these modifications in the designs for future hotels. [Implementation to be undertaken as per plans agreed with IFC]	31-Jul-2014	Completed	Completed	7/31/2014