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 Procedure for Environmental and Social Review of projects because it may create a limited number of specific environmental and social impacts that can be avoided or mitigated by adhering to generally recognized performance specifications, guidelines, or design criteria. Key environmental, health and safety, human resources and social issues that were reviewed included the following: environmental and social management system; emissions to the environment – air, water and subsurface; solid, and hazardous waste and materials management, including transportation; community and occupational health and safety; energy use and efficiency; community engagement; and land acquisition. The company will review existing facilities for comprehensive compliance with internationally accepted standards for life and fire safety, and ensure such in future projects where the Company is providing such services on its own or in any partnerships.

PS5: Land Acquisition and Involuntary Resettlement is not applicable since all facilities are either leased or collocated within existing hospitals.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable.
PS7: Indigenous Peoples is not applicable. No Indigenous People are known to have been in the area or affected by the project.
PS8: Cultural Heritage is not applicable. The projects being considered for IFC financing are not located in areas of known historical or cultural significance.

Because IFC’s proposed equity investment in NephroPlus will be used to support future but, as yet, undefined projects in addition to the existing project, the principal Performance Standards to be applied to this investment are those listed above. A condition of IFC’s investment going forward will be that the Company shall adopt IFC Performance Standards as part of the applicable legal and other requirements in all of its operations, and consider the issues identified in PS1 through PS8 when it is assessing any new business opportunities, acquisitions or mergers, or service models.

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.

NephroPlus management program includes operational policies and procedures that are implemented at the facilities level by facility managers who report to the company?s management on a periodic basis. If monitoring results indicate nonconformance with standards or deviations from established benchmarks, appropriate corrective or preventive actions are initiated. While the existing system is adequate for the present scale of operations, as NephroPlus continues to grow rapidly, it will need to augment its management capacity by assigning additional staff and resources to provide continued oversight of its environmental and social performance across many states in India.

National and Local regulatory requirements do not require NephroPlus to conduct a formal environmental and social impact assessment study for setting up its dialysis centers. However, as a part of permitting process for the setup and operation of healthcare facilities, the Company is required to assess and revise its designs/plans for various activities such as management of biomedical waste, fire safety and power back up etc., so as to comply with the stipulated requirements? thereby mitigating some key environmental and safety related impacts. Accordingly, NephroPlus has standardized design and safety features, which are adopted while designing all new facilities.

To ensure consistent service quality and safety standards across its network of dialysis centers, NephroPlus has developed several detailed operational manuals and procedures that conform to international best practice for the health sector. Standard operating procedures (SOPs) for tackling infectious spills, management of work related injuries, waste management, emergency response & contingency plan, fire prevention and control, etc. have also been developed by the company. Local regulatory requirements applicable to the Company operations vary across states in India. To keep track of compliance with permit conditions and regulatory requirements with respect to emissions and biomedical waste handling and disposal, the Company will maintain a legal commitment register for each facility and will develop a process for continual monitoring of compliance.

Human resources are managed effectively at NephroPlus through the Human Resources Department. Training of staff is done on a routine basis in compliance with local regulations and is summarized in training manuals available to the staff. Facility managers are responsible to ensure that employees are adequately trained to perform their work safely and provide a high quality of service. Subcontractors are contractually obliged to have adequately trained workers and comply with NephroPlus'' corporate standards. NephroPlus has a monitoring program for health and safety that are managed in compliance with local regulations. Internal audits of health and safety procedures and of the facilities are conducted periodically with oversight of senior management. Reporting requirements are consistent with national laws and regulations, and are used for continual improvement of training programs especially in health and safety.

As part of the Environmental and Social Action Plan (ESAP), NephroPlus will implement an Environmental and Social Management System (ESMS) to provide consistent oversight of environmental, social and health and safety for all its operations and sub-contracted tasks/labor. The ESMS will include a series of procedures, work instructions, and reference documents which, when combined with the findings of the E&S assessments, comprise a program of mitigation and performance improvement measures and actions necessary to effectively manage E&S risks and impacts of projects the Company undertakes. Also, as part of the ESMS implementation program, NephroPlus will designate an individual on the management team of the Company to ensure continued compliance with company policies, procedures and regulatory requirements, and ensure consistency with good international industry practice for ESHS performance, including IFC Performance Standards and applicable guidelines. At the operational level, responsibility for the management of environment, health, safety and social performance will be assigned to a senior level staff at each of the facilities operated by NephroPlus. These positions will be adequately resourced and have overall responsibility for implementation of strategies, policies, standards, compliance, and management initiatives related to environmental and social matters at the Company.

NephroPlus currently employs about 250 employees across all its operations. Housekeeping and security services are outsourced. The Company has a human resources policy that is consistent with Indian labor laws, and this policy is included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. This information is also provided in the form of an employee handbook at the time of induction into the company. Subcontractors, including housekeeping staff is required to comply with all NephroPlus labor requirements specified in contractual arrangements. The Company is in compliance with national regulatory requirements, and has not been the subject of any violations of applicable labor laws, or labor strikes or disputes.

Hiring practices and employment relationships recognize the principals of non-discrimination and equal opportunity, freedom of association and grievance. Employees are aware of their right to freedom of association and have the opportunity to collectively represent to the management any issues or grievances that they may have. Employees have the right to be part of a trade union, and may choose to do so at any time during their employment with NephroPlus. The minimum employment age at NephroPlus is 18 years. NephroPlus ensures that child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents.

There is a plan for accident prevention and worker safety in compliance with national regulatory requirements, and for international standards for health care facilities. The company has developed SOPs to ensure safe and healthy working conditions for its employees. These include SOPs to handle infection control, fire safety and hazardous waste management, which are consistent with national regulatory requirements and international best practices. There are SOPs for spills of (bio) hazardous materials, though the risk is minimal as only small quantities are stored at facilities in dedicated and secure storage areas.

Occupational health and safety (OHS) is managed by designated health and safety staff at each facility. All employees in the company have to undergo a full training program at induction and subsequently on worker health and safety relevant to their job activity. Human Resources department maintains permanent records of participation to ensure compliance. Facilities are audited annually by regulatory and insurance agencies. No fatalities or serious injuries have been reported at any of NephroPlus facilities. Labor and Working conditions at all NephroPlus facilities are in compliance with IFC Performance Standards and applicable IFC guidelines for the health care sector. Facilities are subject to annual audits by regulatory agencies to monitor compliance with labor regulations. The Company has been in compliance with regulatory requirements for OHS requirements and has recorded no significant lost time incidents or fatalities in its operational history.

Wastewater from NephroPlus facilities are primarily from dialysis units, water purification plants and miscellaneous housekeeping activities in addition to limited quantities of sanitary wastewater from toilets and washrooms. Wastewater is discharged to public sewers in compliance with local municipal regulatory requirements. Where no public sewerage system is available, wastewater is pretreated to regulatory acceptable standards prior to discharge. Sources of air emission from NephroPlus facilities include those from standby diesel generators for contingency power and discharge from HVAC systems. Monitoring of air emissions varies by location, but complies with applicable local regulatory requirements.

Handling and disposal of medical materials and bio-hazardous wastes at NephroPlus facilities comply with national and local regulatory requirements. Infectious and pathological wastes, sharps and sharps containers are stored in adequately secured storage areas before they are collected for treatment and disposal by licensed vendors. Procedures and mechanisms are in place to provide for separate collection and alternate disposal of excreta and body fluids containing prescribed drugs, antibiotics, etc. Ultimate disposal of these wastes varies by location, and typically includes incineration or landfill in approved facilities. NephroPlus does not own or operate any incineration facilities, and relies solely on government licensed waste processing facilities for disposal of its infectious, pathological and related hazardous wastes. NephroPlus facilities do not produce any radioactive waste.

Annual fresh water consumption by NephroPlus facilities is estimated to be about 56,000 cubic meters which is either supplied by the local municipal corporation or from groundwater wells, depending on availability and location. Water is treated at each of the standalone facilities to usable grade for dialysis prior to use. Where NephroPlus facilities are collocated within hospitals, water is provided by the hospital. Annual energy consumption will include 3,000 liters of diesel and 780,000 of electricity. Net greenhouse gas (GHG) emissions attributable to NephroPlus annual consumption of electricity and fuel, is estimated to be about 700 metric tons of carbon dioxide equivalents per year.

Dialysis centers are collocated either in hospitals or leased premises within existing buildings, and have fire safety provisions in line with local regulatory requirements. Where appropriate, the dialysis centers have obtained a No Objection Certificate (NOC) from local fire departments. NephroPlus has developed an SOP on the fire safety requirements for all its facilities that complies with local regulatory requirements. Fire safety drills are conducted at least once a year across all facilities and all fire hydrants and extinguishers are checked monthly.

NephroPlus facilities are typically located in a mixed use (commercial and residential) neighborhoods. Since health care facilities use specialized gases and chemicals, some of which may be hazardous, NephroPlus will ensure adequate engineering controls and staff training are provided to mitigate risks and issues associated with its operations and associated infrastructure, which also includes storage and transport of infectious and hazardous wastes, chemicals and gases. Use and storage of chemicals is subject to stringent safety standards at NephroPlus. The company has emergency prevention and control plans which specifies responsibilities, ensures appropriate response equipment and materials are in place, and detail a set of procedures to be followed to minimize the harm from any potential accident. Moving forward, NephroPlus will additionally develop a comprehensive emergency response plan for subcontracted operations such as transport of infectious and hazardous materials, and add a community involvement component that addresses appropriate behavior and safety measures to be implemented in the event of an accident during transportation, handling, etc. of such materials.

Health care facilities operated by NephroPlus are designed and operated to meet local regulatory requirements for life and fire safety (L&FS). These standards vary by region and location, and are not certified under any particular certification regime. In order to confirm that life and fire safety provisions are adequate across all its facilities and are in compliance with WBG?s EHS Guidelines, the Company will commission an independent review of life and fire safety provisions by a qualified external expert. The scope of review will include all existing facilities, and develop a set of minimum requirements / specifications for new facilities that is responsive to all national requirements and an internationally recognized fire and life safety code, as required by the life and fire safety section of the WBG EHS General Guidelines. These standard specifications should form part of the SOP on life and fire safety for all the company?s operations, and be basis for closing any gaps that that are identified in the review. Additionally, NephroPlus will adopt a disaster response plan for earthquakes, fires and other large scale emergency situations. The plan would include scenarios in which disease; pathogens and other bio hazards might be released under during normal and emergency scenarios, based on a risk assessment and analysis.

No local community have been significantly affected by environmental risks or impacts from NephroPlus’ ongoing operations, and has not been the subject of any public complaints or litigation with respect to its environmental, social or health and safety performance. NephroPlus has contributed significantly to local communities through activities such as providing free health care clinics, to improve awareness about dialysis, kidney disease and healthy living, support during natural disasters and philanthropic contributions. Other significant community activities undertaken by the company include - Aashayein Kidney Foundation founded by NephroPlus that helps subsidize dialysis for the poor, and Enpidia an internationally accredited institute that trains people in dialysis technology.
In India, dialogue and communication with affected communities including public consultation and disclosure of environmental and social impact assessment occurs through procedures established by local authorities. Additionally, as the company''s operations do not have any negative impacts on the surrounding community, no formal community engagement plan has been undertaken by the company to date. As part of its environmental and social management program, NephroPlus will establish methods for communicating environmental and social aspects to stakeholders and maintain procedures for receiving, documenting and responding to stakeholder concerns relating to the project, in full collaboration with local authorities.

NephroPlus will disclose the project documentation on its web site and locally at its corporate office and each of the dialysis centers operated by the company.

Corporate Office
NephroPlus
#1178, MLA Colony,
(Beside RNR Auditorium)
Road No. 12, Banjara Hills
Hyderabad – 500 034, India
Telephone: 040-6000-7200

And on its website at: http://www.nephroplus.com/

All inquiries and comments may be directed to:
Mr. Sohil Bhagat
VP, Strategy
#1178, MLA Colony,
(Beside RNR Auditorium)
Road No. 12, Banjara Hills
Hyderabad – 500 034, India
Email: mailto:sohil@nephroplus.com
Fax: +91 40-40184120
Phone: +91 9959568880
Website: http://www.nephroplus.com/

Broad Community Support is not applicable for this project