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 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
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 environmental and social (E&S) risks and issues associated with this Project include: development and implementation of facility level management systems covering EHS issues; 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; resource efficiency of the operations (mainly energy and water); monitoring and management of air emissions, wastewater treatment and discharge, solid and other waste disposal; life and fire safety management, including emergency preparedness and response; community safety; sourcing of guar and supply chain management, including internal auditing, management of natural habitats and living natural resources as part of own agricultural activities.

The new split processing facilities (Bikaner and Meglasiya) and agriculture farm (Mokheri) proposed under the Project are being set-up on land which was purchased under willing-buyer seller arrangements. The land for Jhagadiya facility is located in a notified industrial area and has been leased from the government. Thus PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. Similarly, the type of risks and impacts envisaged in PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) do not apply.

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 proposed type of operations, Lucid is not required to undertake a formal Environmental and Social Impact Assessment (ESIA) as per the Indian environmental regulations. However, the company has obtained all the required environmental and social (E&S) regulatory permits and approvals. The company has also obtained the required permit for setting up a new facility for Meglasiya facility and is in the process of obtaining the same for Bikaner facility. The operating facilities of Lucid were noted to have the necessary environmental, health & safety permits.



Going forward, as set forth in the ESAP, the company will evaluate if a formal ESIA is required for any new capital expenditure (CAPEX) proposals including setting-up of new facilities. In case required, any such ESIA studies conducted by the company will have to meet IFC Performance Standard (PS) 1 requirements. For any acquisition of any brownfield facilities, the company shall conduct E&S due diligence in accordance with IFC PS standards. Additionally all CAPEX proposals will be evaluated for any E&S risks as per IFC Performance Standards and World Bank Group (WBG) EHS Guidelines. Lucid will develop a standard procedure for any such future ESIA studies or audits and associated E&S due diligence (for prospective acquisitions) process meeting IFC PS 1 requirement, and specifically integrating E&S risk assessment and impacts identification process in its CAPEX evaluation process.



Policy and Management Systems: Lucid has documented corporate policies on quality, environment, occupational health & safety (OHS) and food safety. The two operational facilities of the company have implemented quality, environment and OHS management systems which have been certified against ISO 9001, ISO 14001, and OHSAS 18001 requirements respectively. In relation to food safety, Aurangabad facility’s food safety management system (FSMS) is certified as per Food Safety System Certification (FSSC) 22000. Jodhpur facility’s FSMS is currently certified for ISO 22000 and the facility is in the process of obtaining the FSSC 22000 certification. At the facilities visited during the appraisal, the systems were noted to be adequately implemented. As set forth in the ESAP, the company will implement similar management systems on quality, environment, OHS and food safety at its new facilities as per the requirements of IFC PS1 and international standards (ISO 9001, ISO 14001, OHSAS 18001 and ISO 22000).



Organization: The E&S responsibilities at the facilities are handled by the Environment, Health & Safety (EHS) Manager who reports to the Head – Operations for each facility. The regulatory compliance is handled by the Head – Operations. Further, for management systems implementation, every factory has a management appointee who reports to Quality Assurance (QA) head in the corporate office who is also the corporate management representative (CMR) for al
l management systems. Considering the increasing number of proposed and existing facilities, as part of the ESAP, Lucid will appoint/identify a qualified E&S manager at the corporate level. Lucid will share the terms of reference (ToR) for the proposed E&S manager with IFC which will at least include, among other activities, ensuring consistency in implementation of systems across facilities, creating corporate E&S goals and Key Performance Indicators (KPIs), governance processes including risk assessment process for new projects/investments (discussed above), monitoring and review of E&S performance of the facilities, ensuring supply chain E&S compliance and overall corporate and plant-level E&S reporting (to IFC and other stakeholders).



Monitoring and Reporting: Lucid conducts regular environmental monitoring under national jurisdictions, including ambient air quality, stack emissions, effluent quality, ambient noise, and drinking water quality at its facilities in order to ensure compliance with the applicable legal requirements and standards. Jodhpur facility conducts this monitoring on a six monthly basis whereas at Aurangabad, the monitoring is conducted on quarterly basis (except effluent quality which is tested monthly). As set forth in the ESAP, Lucid will develop a corporate EHS monitoring procedure which will specify minimum parameters (KPIs) to be monitored, monitoring frequencies for all facilities dependent on the type of sources (e.g. boiler stacks, diesel generator stacks, hot air/water generators, effluent treatment plants) and monitoring (e.g. ambient air quality, noise, stack and fugitive emissions, treated effluents), 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 emissions including process emission stacks and effluent quality in the World Bank Group (WBG) General EHS Guidelines. The corporate EHS monitoring procedure will also require monitoring at a pre-defined frequency of the following parameters (a) Safety – Lost Time Incidence Frequency Rate (LTIFR), Accident Free Days; (b) Resource Efficiency – energy usage (kwh/ton) and water usage (liters/ton); (c) EHS training provided (number of man-days and type of training). Regular monitoring will be conducted for these parameters and corrective actions taken as necessary.



It was noted that regular internal audits and inspections are conducted at Lucid facilities as part of the management systems. The findings of these inspections/audits are followed up for ensuring corrective actions. The EHS performance is reviewed in quarterly management review meetings. The monitoring and review procedure will be strengthened by having a dedicated E&S manager and having corporate KPIs monitoring processes as mentioned above.



In terms of external inspections, Lucid’s international customers also review its operat
ions with respect to good manufacturing practices (GMP) and food safety requirements. Based on one of the international customer’s requirements, the Aurangabad facility has undergone a SEDEX Members Ethical Trade Audit (SMETA) 4-pillar audit in March 2013. The audit is based on the Ethical Trading Initiative (ETI) code (with additional requirements) and covers 4 pillars of Labor Standards, Health & Safety Standards, Environmental Standards and Business Ethics. The audit reported 2 minor and 1 major non-conformances which have subsequently been corrected by the company. It is expected that such audits will be conducted for other facilities as well in the future (based on customer requirements).



Emergency Preparedness and Response: In accordance with local requirements, Lucid has provided fire safety equipment at its facilities based on the nature of risks involved. The fire safety system at visited facilities included portable fire extinguishers, fire hydrant systems with dedicated fire water storage and fire alarm. The equipment was noted to be regularly inspected and maintained.



At Jodhpur, Propane storage tank are located underground and provided with a sprinkler arrangement. The Propylene Oxide (PO) bullets are provided with sprinklers and chilling plant. Trolley mounted foam type extinguishers are provided for Methanol storage area. Based on the plans shared during the appraisal, the proposed facilities will also have fire hydrant system as well as required emergency response equipment for Propane bullets. Considering the nature and quantities of chemicals stored in bulk (PO, Propane, Methanol) at Jodhpur facility, as set forth in the ESAP, Lucid will conduct a Quantitative Risk Assessment (QRA) through an external consultant (acceptable to IFC) to understand the on-site and off-site risks in case of undesired events. Based on the QRA, required preventive measures will be taken and on-site emergency response plans (discussed below) will be updated accordingly. In case required, the information will be shared with the local authorities for their disaster management/off-site emergency response planning.



Lucid has prepared documented on-site emergency response plans for its facilities covering various types of emergencies. Marked emergency exits and assembly points have been provided. Fire safety and first-aid training is provided to adequate number of identified personnel. Regular mock drills are conducted at both facilities (though mainly focusing on fire). As set forth in the ESAP, Lucid will review the number of emergency exits in the Jodhpur facility and provide additional emergency exits (as required). Also, emergency lighting will be provided on the evacuation routes in all facilities (current and proposed). Regular training will be conducted on emergency preparedness and response for all workers including contract workers explaining their roles and responsibilities during any emergency. Also regular mock drills (including eva
cuation drills) will be conducted for all types of expected emergencies covering all shifts and workers at all facilities.

As on March 2014, Lucid employs 266 employees as well as 68 contract workmen. Additionally, the JV Taiyo-Lucid (which includes Aurangabad facility) employs 96 employees and 51 contract workmen. For the proposed additional facilities, Lucid is planning to employ 135 employees and 98 contract workmen.



Human Resource (HR) Policies and Procedures, Working Conditions and Terms of Employment: The HR responsibilities are handled at the corporate and facility level by the administration department of the company. Currently, Lucid does not have documented HR policies and procedures. As outlined in the attached ESAP, IFC will require the company to formulate and document comprehensive HR Policy and Procedures in a manual which will be implemented at all its facilities (including the Aurangabad) facility.

The manual will outline various HR processes covering staff and workers e.g. recruitment, wages and benefits, compliance with the legal requirements, promotions, training and development, contract workers management as well as on specific requirements under the IFC PS2 including non-discrimination, freedom of association, prevention of child labor and forced labor, grievance mechanism, third-party workers. Also, the company will establish a specific HR organization which will include HR managers at the facility level. The HR policies and procedures will be communicated to all employees and workers (including contract workers) through various means, including displays, employee handbook and awareness sessions.



At the existing facilities, Lucid signs a contract with the worker at the time of employment. Most of the workers are paid through bank accounts. The wages and benefits were noted to be in line with the legal labor requirements. However, as set forth in the ESAP, at Jodhpur facility, the company will align production schedules for workers with these requirements within a year. Also, for the proposed facilities, Lucid will provide adequate manpower and implement required systems to ensure compliance with the legal requirements.



As mentioned above (under Monitoring and Review of PS1), based on requirements of Lucid’s international customers, the Aurangabad facility has undergone a SMETA 4-pillar audit in March 2013 covering both labor standards as well as OHS requirements. The non-conformances identified in the audit have been corrected by the company. It is expected that such audits will also be conducted for other facilities (based on customer requirements).



Non-discrimination and Equal Opportunity: No instances of discrimination were noted. Lucid will document its policies and procedures on non-discrimination as part of the above mentioned HR manual.



Freedom of Association: At Aurangabad facility, 34 workers (out of 91 permanent staff and workers) are part of a registered union and have a memorandum of settlement with the company. At Jodhpur facility, workers have formed a works committee. As part of the HR Manual, Lucid will
document its policies and procedures on freedom of association.



Prevention of Child Labor and Forced Labor: The company collects age proofs prior to recruitment to prevent use of child labor or young workers in its operations. No instances of child labor or forced labor were noted in Lucid’s direct operations. As part of the HR Manual, Lucid will further document its policies and procedures on prevention of harmful child labor and forced labor.



Third Party Workers: As mentioned above, Lucid hires contract workers at its facilities which are supervised by facility management, including EHS teams. Contract format includes a requirement on statutory compliance. The administration team at the facilities monitors contractor’s compliance with various statutory compliance requirements on providing wages, working hours and benefits to their workers, and OHS measures, including PPEs. As mentioned above, in its HR manual, Lucid will have a specific procedure covering compliance with legal requirements and IFC PS 2 requirements on contract workers management. Specific conditions (including PS2 requirements) will be included in the contracts signed with these contractors.



Grievance Mechanism: Currently the grievances are raised by workers to their supervisors and plant heads, however, these are not documented. As part of the ESAP, Lucid will develop and implement a documented workers grievance mechanism which meets IFC PS2 requirements with a consistent and well-structured system of documenting grievances received and processed. The company will also create awareness among workers (including contract workers) regarding the grievance mechanism.



Occupational Health and Safety (OHS): As discussed above, both existing Lucid facilities have certified OHS management systems. Hazard Identification & Risk Assessment (HIRA) has thus been conducted and required procedures are implemented. Specifically for Jodhpur facility, Hazard Operability (HAZOP) studies have been completed for the derivative products manufacturing process as it involves use of Propylene Oxide. Also, a safety audit was conducted in February 2013 and most of the corrective actions based on recommendations of the audit have been implemented. At both facilities, regular safety trainings are provided to employees as well as contract workers. Required safety equipment is provided including personal protective equipment (PPE) depending on hazards related to the type of task being performed and the production unit and PPE usage was noted to adequate at the facilities. Safety signage is adequate and emergency exits and assembly points are well identified. A work permit system has been established for hazardous work including hot work, confined space entry, work at height and cold work. The EHS Managers at each facility conduct regular safety inspections (daily rounds + quarterly internal audits) and the findings of these inspections are documented and tracked for compliance. Both facilities h
ave safety committees which discuss safety improvements. The OHS performance is reviewed quarterly in management review meetings including internal audit findings, accidents/incidents/near-misses, training activities, resource requirements etc.



Accidents, incidents and near misses are documented and investigated. In the last three years, 2 lost work day accidents are reported at Jodhpur and none at Aurangabad. No major incidents or fatalities are reported at any of these facilities.



Also, as part of the ESAP action on corporate monitoring program (discussed below), the company will review the workplace hazards at its production facilities and specify minimum parameters for workplace monitoring and monitoring frequencies for all facilities.



For construction activities, Lucid has its own project management staff on the site. The construction contractors are provided documented instructions as part of the contract on legal compliance, OHS as well as facilities for construction workers (e.g. toilets, washing areas). At the under construction facilities, visited as part of the appraisal (i.e. Meglasiya and Mokheri), the OHS practices and facilities were noted to be acceptable.



Supply Chain: Based on the market conditions, the company either sources Guar seeds or Guar splits from traders at agricultural produce markets (Mandis). In case the company purchases seeds directly, the seeds are provided to splitting suppliers (currently 5 to 6) who then process then and provide the Guar splits to Lucid. Even for new products, the company is planning to source primary inputs (seeds/splits/husk) from a similar network of traders and suppliers.



Lucid’s Agri Research team has extension activities which currently cover 700 farmers. As part of the extension, the company supports farmers with information on good farming practices as well as solutions to typical issues associated with the Guar crop. The company also supports some of these farmers with good quality seeds. Though through the extension activities, the company has a direct contact with 700 farmers, the company does not directly source guar from these farmers except for a few farmers (120 to 130) where the company has contracts for growing organic guar (only 0.1% of company’s total sourcing).



Therefore, as almost all the procurement of seeds/splits from the markets is through traders, the company does not have management control and/or leverage over primary suppliers of guar seeds/splits. Guar from India is not known as a crop to have significant risks of child labor or biodiversity related issues as evaluated using the Global Map of E&S Risk in Agro-Commodity Production (GMAP) for the country-commodity combination of India and Guar as well as United States Department of Labor List of Goods produced by child labor and forced labor. The same is the case for other primary agricultural inputs proposed to be purchased by the company. Still, as part of the ESAP and extension services, Luc
id will create awareness on prevention of child labor, forced and bonded labor and non-conversion of natural/critical habitats for farming. In the future, in case the company increases its direct sourcing from farmers, the company will develop and implement a Supplier’s Code of Conduct and monitoring system, which will be mainstreamed into its contractual agreements with primary suppliers of seeds.



As regards splitting capacity, the company is backward integrating into splitting with its proposed facilities at Bikaner and Meglasiya to reduce their dependence on outsourcing and having better control on splits processing. With the new facilities beginning production, more than 50% of the company’s splits requirements will be met from in-house capacity whereas the balance will be sourced through outsourced splitting plants. One such splitting plant was visited as part of the appraisal and based on the observations at the plant, improvements are needed in Lucid’s processes of ensuring compliance with applicable PS2 requirements at such plants. As set forth in the ESAP, the company has confirmed its intention to strengthen the current procedures by documenting specific requirements for such outsourced facilities, including prevention of child labor, forced labor and ensuring safety of workers. As set forth in the ESAP, specific requirements will be included in the contracts signed with these splitting plants. Lucid will have oversight monitoring and review processes which will include inspections for screening as well as on an ongoing basis with agreed consequences of non-compliance.

Resource Efficiency: All the facilities utilize treated effluent for gardening. All the new facilities will implement rain water harvesting (RWH) systems for collection of rain water and use for domestic purposes. At the Mokheri Agri Farm and Research Station, Lucid will also install solar panels and a wind mill for renewable energy generation as well as demonstration purposes. The irrigation system at the farm will be a drip irrigation based system. As part of the management systems, Lucid facilities will define objectives on environmental, health & safety improvements, including resource efficiency. However, the activities to be undertaken and current status of such activities are not clearly documented. As part of the ESAP, Lucid will clearly document resource efficiency goals, plans and KPIs for both at the company level and at the facilities level with a clear monitoring and reporting framework.



Air Emissions and Ambient Air Quality: The main sources of air emission at existing Lucid facilities are stacks attached to the boilers (using Propane and Furnace Oil (FO) in some cases as fuel), hot water generators (fired on LPG), diesel generators (provided for power back-up) and process vents. Appropriate pollution control equipment is provided for the process vents, including cyclones and bag filters. For derivated products manufacturing process vents, where Methanol is used, the solvent is condensed, collected and reused. Ambient air quality and stack emissions are regularly monitored at each facility results provided are compliant with the limits specified for the facilities by the relevant state pollution control boards and with the Indian and state ambient air quality standards, respectively, and they are in line with the relevant WBG guidelines. Similar sources of air emissions are expected at the new facilities and Lucid will provide appropriate pollution control equipment. As indicated under PS1, going forward the company will develop and implement a corporate environmental monitoring program which will ensure consistent monitoring plans at all the production facilities and monitor compliance with national limits as well as applicable WBG guidelines.



Water Consumption and Wastewater Discharges: The source of company’s water consumption is mainly the piped water supply from the municipal/industrial area authorities. At Jodhpur, the company additionally purchases water through tankers (coming from off-site sources). The estimated annual consumption at Jodhpur and Aurangabad facilities is about 71100 m3 and 45695 m3. The new facilities at Bikaner and Meglasiya will have on-site borewells with estimated annual consumption of 6000 m3 each (mainly for domestic purposes) and Jhagadiya facility will receive the industrial area supply with annual consumption of 86000 m3.



Effluent treatment plants (ETPs) were noted to be provided at both the existing operating facilities. All new facilities will also have built-in ETPs for appropriate
treatment of effluent. The treated effluent is used for gardening on-site or provided to local farmers for their farms. The effluent quality results were noted to be meeting the applicable local standards as well as WBG EHS guidelines.



Waste Management: The major streams of waste generated at Lucid facilities include packaging materials (mainly empty bags), dust collected in the filters, used oil and ETP sludge. Empty bags are recycled/reused for packing Guar Splits or sold off as scrap. Dust and Filter is disposed in a dry state for use in low applications as a binder/filler such as textile printing, incense sticks, paper glue etc. Used oil is sold to authorized recyclers and ETP sludge is used as manure in the company’s agri farm. At the proposed Jhagadiya facility, company will also use Iso Propyl Alcohol (IPA) and generate used solvents which will be sent to an authorized agency for purification and recovery. Lucid will obtain required permits for this activity and also ensure that the identified agency has all the required permits.



As set forth in the ESAP, Lucid will develop specific procedures and work instructions at each facility for waste management (including storage, handling and disposal plans). Training shall be provided to all workers on these procedures.



Hazardous Materials Management: The hazardous materials stored at Lucid facilities are mainly the fuels – Propane, Liquefied Petroleum Gas (LPG), and FO, Diesel and the lubrication /hydraulic oils. The Jodhpur facility additionally stores Propylene Oxide and Methanol used for manufacturing the derivated products. Required storage licenses were available at the facilities for these materials. Hazardous materials were stored in barricaded areas. Appropriate safety signage was present at the storage locations. Secondary containment was noted to be provided. At the new Jhagadiya facility, IPA will be stored in bulk. As part of the ESAP, Lucid will develop specific procedures and work instructions for hazardous chemicals management and provide training on these procedures to the workers. Further, all underground storage tanks older than 5 years (e.g. used for storage of FO and diesel) will be tested for their integrity and any corrective actions (as required) will be taken.



GHG emissions: The GHG emissions for Lucid’s existing facilities are estimated to be 38,000 tCO2e (including 14,440 tCO2e direct from fuel consumption and 24,071 tCO2e indirect from electricity consumption). The total GHG emissions expected from the project are 85,544 tCO2e (including 21,900 tCO2e direct from and 63,554 tCO2e indirect).



Pesticide Usage: As part of its extension program, Lucid provides information on good farming practices which covers pesticide management. For the pesticide usage at the Mokheri Agri Farm, Lucid will prepare a pesticide management plan in accordance with the PS3 requirements.

The existing Lucid facilities are located in notified industrial areas, however, the local community is located at a close distance from the Jodhpur facility. Among the proposed facilities, Jhagadiya will be located in a notified industrial area. Though Meglasiya and Bikaner will be located in non-industrial mixed use areas, they are located on national highways.



Unarmed security personnel are employed at Lucid facilities through security contractors. As part of the ESAP, Lucid will regularly review and monitor the performance of the security providers, and will develop a Code of Conduct for security personnel consistent with the requirements of PS4.



As discussed above under PS1, considering the chemical storage at the Jodhpur facility (though not required as per the legal requirements), Lucid will conduct a QRA for its Jodhpur facility to understand the on-site and off-site risks in case of undesired events. Based on the QRA, required preventive measures will be taken and on-site emergency response plans (discussed below) will be updated accordingly. In case required, the information will be shared with the local authorities for their disaster management/off-site emergency response planning.

For establishing its agricultural farm and research station, the company has purchased land which was already under agricultural use and no forested land/natural habitat will be converted for agricultural use. The company will implement good farming practices at the agri farm in line with good international industry practices and endeavor to obtain international certification (like Global Good Agricultural Practices (GAP)) for its farming practices.



As mentioned above about supply chain, the company does not have management control and/or leverage over primary suppliers of guar seeds/splits. Guar from India is not known as a crop to have significant risks of child labor or biodiversity related issues as evaluated using the Global Map of E&S Risk in Agro-Commodity Production (GMAP) for the country-commodity combination of India. Still, as part of the ESAP and extension services, Lucid will create awareness on non-conversion of natural/critical habitats for farming. In the future, in case the company increases its direct sourcing from farmers, the company will develop and implement a Supplier’s Code of Conduct and monitoring system, which will be mainstreamed into its contractual agreements with primary suppliers of seeds/splits.

Lucid has an extension program where its Agri Research team works with Guar farmers in raising their awareness on good farming practices and providing them support with good quality seeds. The extension activities currently cover 700 farmers.

Lucid conducts its Corporate Social Responsibility (CSR) activities through a Registered Charitable Trust established by the promoters (of Lucid) in 1997 called Chaturbhuj Gordhandas Foundation (CGF). The current Corpus of CGF (as on Feb 2014) is INR 2 Crores (approx. US$ 330000), made up almost exclusively by donations from Lucid profits in the past years. CGF expends about INR 18,00,000 (approx. US$ 30,000) per annum from the Corpus income for two major objectives - Education (focusing on the girl child) and medical aid. CGF has a documented procedure for verification of all applications received for educational grants and medical aid, which is paid directly to the institutions (where education/medical treatment will be provided e.g. school, university, hospital, clinic etc.). In many cases, CGF provides food and household supplies to orphanages, notebooks to schools, lenses for cataract operations etc. Additionally, CGF supports educational aid and medical aid for family members of Lucid employees as well as third parties. The promoters of Lucid and an independent director regularly monitor the activities of CGF.

As per the requirements of the new Companies Act, 2013, Lucid will be required to spend 2% of its average past 3 years net profit (after tax) on CSR activity as defined under the CSR Rules, 2014. This goes in to effect starting April 2014. Lucid is therefore in the process of setting up a CSR Committee at the Board of Directors level and to document a CSR policy. Based on a legal review of the new guidelines, it is envisaged that Lucid’s CSR Board Committee will mandate CGF on the CSR programs it wishes to implement (as per Lucid’s CSR policy) and CGF will implement the same and report back to the CSR committee who will monitor the progress. It is also envisaged that a certain percentage of Lucid’s future CSR will be marked for programs to be implemented to aid the communities around Lucid facilities.
Under the new guidelines, the JV facility – Taiyo Lucid may also be required to spend on CSR activities separately and based on the legal advice, the same will be separately implemented.

Lucid has already committed funds as part of its CSR activities for FY 2014-15 towards setting up of a new mid-day meal kitchen for school children in Mumbai through the Rotary Organization. Lucid also plans to leverage its Mokheri Agri Farm and Research Station and its employees for supporting CSR activities such as helping the local communities in setting up rain water harvesting, awareness of water management technology, use of solar and wind energy, use of bio gas plants and other low environmental impact / low cost technologies.

To facilitate community engagement, Lucid will develop and implement a documented community grievance mechanism meeting the IFC PS requirements.

Lucid will locally disclose this ESRS at its website: http//:http://www.lucidgroup.com, as well as locally at the following addresses:
Corporate Office Facility:
401A Navbharat Estates,
Zakaria Bunder Road, Sewri West
Mumbai 400015, INDIA.

Jodhpur Facility:
B 5/7, Marudhar Industrial Area
Phase 1, Basni
Jodhpur 342995, INDIA.

Aurangabad Facility:
M-101, MIDC, Waluj
Aurangabad 431136, INDIA.

Any queries and/or comments about the project may be directed to:

Mr. Bharat Parikh
President Commercial & Corporate
401A, Navbharat Estates
Zakaria Bunder Road, Sewri West
Mumbai 400015, INDIA
Tel: +91-22-24158059

Broad Community Support is not applicable for this project

Task Description	Anticipated Completion Date
1. Develop a standard procedure for any future Environmental & Social (E&S) Impact Assessments (ESIA) and E&S due diligence studies (for new facilities or prospective acquisitions) in line with IFC Performance Standard (PS) 1 requirements. The procedure should specifically integrate E&S risk assessment and impacts identification (with respect to legal requirements, IFC PS requirements and World Bank Group (WBG) EHS Guidelines) in Lucid’s CAPEX evaluation process.	12/31/2014 OR prior to decision on acquisition/establishment of any new facility, whichever is earlier.
2.Develop and implement management systems on quality, environment, OHS and food safety at its new facilities in line with the existing facilities as well as the requirements of IFC PS1.	3/31/2015
3. Appoint/identify a qualified E&S manager at the corporate level and responsibilities as per agreed Terms of Reference (ToR) with IFC.	9/30/2014
4. Develop a corporate EHS monitoring procedure which will specify basic minimum parameters to be monitored for all facilities, monitoring frequencies for all facilities dependent on the type of sources and type of monitoring (e.g. ambient air quality, noise, stack and fugitive emissions, work area monitoring, treated effluents) in line with the applicable legal requirements as well as the WBG General EHS Guidelines along with EHS and resource efficiency parameters mentioned in the ESRS. Regular monitoring will be conducted for these parameters and corrective actions taken as necessary.	9/30/2014 As per frequency defined in the procedure
5. Upgrade the fire safety and emergency response systems by: (a) Reviewing provision of emergency exits in Jodhpur facility to ensure that all areas have adequate emergency exits. (b) Improving markings provided on emergency evacuation routes along with emergency lighting, as required. (c) Conducting regular mock drills (covering all shifts and kind of emergencies) and training on on-site emergency response plans with documented reports.	09/30/2014 03/31/2015 12/31/2014
6. Establish a specific HR organization including HR managers at the facility level. Communicate the HR policies and procedures to all employees and workers (including contract workers) e.g. through displays, employee handbook and awareness sessions.	09/30/2014 12/31/2014
7. Align production schedules for workers with applicable requirements at the Jodhpur facility.	3/31/2015
8. Develop and implement a grievance mechanism (covering both permanent and contract workers) meeting requirements of IFC PS2 and create awareness about it among the workers.	12/31/2014
9. (a) Strengthen the current procedures by documenting specific requirements for outsourced splitting facilities including prevention of child labor, forced labor and ensuring safety of workers. The procedures shall specify requirements to be included in the contracts signed with these splitting plants, monitoring and review processes including inspections for screening as well as on an ongoing basis with agreed consequences of non-compliance. (b) Create training material for increasing awareness on prevention of child labor, forced and bonded labor and non-conversion of natural/critical habitats for farming among farmers covered in the extension services. (c) In the future, in case the company increases its direct sourcing from farmers, develop and implement a Supplier’s Code of Conduct and monitoring system which is mainstreamed into contractual agreements with primary suppliers of seeds/splits.	12/31/2014 12/31/2014 To be assessed during ongoing supervision
10. Document resource efficiency goals and plans for both at the company level and the facilities level with a clear monitoring and reporting framework.	3/31/2015
11. Develop and implement a waste management plan in accordance with good industry practices at all facilities in order to: (a) identify all hazardous and non-hazardous wastes generated as per rules on hazardous waste handling and management; (b) label, segregate and store all hazardous and non-hazardous wastes; (c) dispose of hazardous wastes through authorized entities only; and (d) maintain records of all wastes disposed from site.	12/31/2014
12. Prepare and implement a hazardous chemicals management plan on order to ensure storage, handling and use of hazardous chemicals on-site is in accordance with good industry practices including but not limited to: (a) secondary containment for all the aboveground storage tanks; (b) spill prevention and control; (c) labeling of storage tanks; (d) provision of protective equipment and training of all workers involved in storage, handling and use of these chemicals.	12/31/2014
13. Conduct integrity testing for all underground storage tanks older than 5 years (e.g. used for storage of FO and diesel) and take corrective actions (as required) based on the testing.	6/30/2014
14. Prepare a pesticide management plan in accordance with the PS3 requirements focusing on pesticide usage at the Mokheri Agri Farm.	6/30/2014
15. Develop a Code of Conduct for security personnel consistent with the requirements of PS4 and regularly monitor their performance with respect to the code of conduct.	9/30/2014
16. Develop a documented community grievance mechanism including a method of receiving, handling public grievances and providing feedback on them. The information to be communicated to the local community through appropriate means.	12/31/2014