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 environment, health and safety management systems both at corporate level and facilities level; 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 water and energy); management of organic solvent usage and emissions of volatile organic compounds, other gaseous compounds and particulates; monitoring and management of wastewater treatment and discharge; solid/hazardous waste management; life and fire safety management including emergency preparedness and response; community safety; sources of raw materials and supply chain management and auditing.

As the Project mainly involves re-financing, no new assets are specifically being developed under the Project. Consequently no new land acquisition is envisaged for any of the activities in the Project and thus PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. Similarly, 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 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 that the JPL’s API manufacturing facility is covered under category of bulk drugs and intermediates excluding drug formulations, as defined in the Indian environment impact assessment rules, the company will be required to conduct Environmental Impact Assessment (EIA) studies for any major expansion at the existing API facility in Nanjangud or for any new API facilities. The parent company JLS has completed such EIA studies as per applicable legal requirements for a proposed capacity expansion project in Nanjangud (October 2013).



Additionally, any proposed CAPEX is evaluated through the corporate’s multi-stage project evaluation process (stage gate process). The Chief Sustainability Officer (CSO) is part of the steering committee of this process and provides inputs on any risks associated with proposed CAPEX projects as well as supports in identifying potential solutions. Any additional EHS studies as required (e.g. Hazard Operability (HAZOP), Failure Mode and Effects Analyses (FMEA) and effluent treatment feasibility of a potential effluent stream) are completed prior to approval of proposed CAPEX.



Going forward the company will include IFC Performance Standards and World Bank Group (WBG) EHS Guidelines (i.e., General, Pharmaceuticals and Biotechnology Manufacturing, Waste Management Facilities) as additional requirements while evaluating any proposed CAPEX. Also, any ESIA studies conducted by the company will meet IFC Performance Standard (PS) 1 requirements. As part of the ESAP, JPL will therefore develop a standard procedure and terms of reference (ToR) for any such future ESIA and E&S due diligence (for prospective acquisitions) studies meeting IFC PS1 requirement, and specifically integrating social impacts into the risks and impacts identification process to further align with the Performance Standards. The ESIA procedure will spell out commitments in terms of company’s minimum requirements for primary and secondary data collection and analysis, risk and impact identification and assessment, mitigation, development of project-specific environmental and social management plans, public consultation, disclosure, and stakeholder engagement.



Policy and Management Systems: The parent company JLS has the documented Corporate Sustainability Mission as well as corporate policies on EHS, Climate Change Mitigation and Green Supply Chain. The policies were noted to be displayed at the visited facilities. The same policy and management systems will be applicable to JGL and JPL after ratification by the Board of Directors of JPL and transfer of the production facilities. JPL’s Nanjangud facility has Quality, Environment, Occupational Health & Safety (OHS) management system certifications compliant with ISO 9001, ISO 14001, and OHSAS 18001 requirements respectively. Both pharmaceuticals facilities in India – Nanjangud and Roorkee - are approved as per Good Manufacturing Practices (
GMP) requirements of various countries including United States Food and Drug Administration (USFDA), United Kingdom (UK)’s Medicines and Healthcare Products Registry Agency (MHRA-UK), Brazilian Health Surveillance Agency (ANVISA–Brazil), Therapeutic Goods Administration, Australia (TGA-Australia), Pharmaceuticals and Medical Devices Agency, Japan (PMDA-Japan) among others. The North American pharmaceuticals facilities are also approved by the US FDA. At the facilities visited during the appraisal, the systems were noted to be adequately implemented. The relevant management system certifications will be transferred to JGL/JPL after surveillance audits by the relevant certification bodies.



Organization: Consistent with the organization of the parent company, JPL will have a Board Level Committee on sustainability comprising of independent and executive directors which will oversee the company’s performance on environment, economic and social factors and provides recommendations. At the corporate level, the E&S management responsibility will be with the CSO who will report to the Executive Director – Ops (Operations), Sustainability and BE (Business Excellence). The corporate sustainability team (CST) under the CSO will be responsible for design and implementation of a governance structure for guiding facilities in implementation of EHS, sustainability and corporate social responsibility (CSR) programs and monitoring performance for all JPL facilities globally. Depending on the risk, the CST will conduct regular risk assessments and compliance audits throughout the year across facilities.



The EHS teams at each of the facilities will comprise of EHS Managers, safety officers and other staff who are responsible for implementing facility specific EHS systems, sustainability projects and CSR activities and reporting back to corporate as part of the reviews and assessments.



The company recognizes that a consistent implementation of corporate management policies and procedures throughout its teams and facilities is a key factor that needs to be ensured in view of the transfer of pharmaceutical assets from JLS to JGL/JPL. JLS has confirmed that there will be a corporate sustainability management team with the necessary authority to implement the corporate sustainability management systems and practices and oversight role throughout the new organization in JPL. JPL’s EHS Head and sustainability team will report to the CSO to align on sustainability management and standardize procedures as per IFC PS requirements. The CST will also bring in functional expertise at JPL level.



Monitoring and Reporting: Consistent with the parent company, JPL will have a corporate standard operating procedure (SOP) on EHS and Sustainability Review and Governance mechanism. As part of the SOP, the safety performance of each facility will be reviewed every month at the facility level by the unit head with all senior and middle management group and reported to CST. Fu
rther JPL will have a corporate statutory compliance monitoring software where all facilities (as well as company’s departments) will report their statutory compliance status once in a quarter with relevant evidence of compliance. Statutory compliance on EHS will be a part of this software checklist. Summary of the compliance status will be presented to the board and reported/identified non-compliances will be followed up for corrective actions. JPL’s company secretary will be responsible for review of the evidences as well as facility audits for statutory compliance.



The CST will conducts sustainability and EHS audits at each of the facilities at least once a year, including cross functional EHS audits where EHS team members from different facilities will audit another facility. Any non-compliances/issues reported in these audits will be followed up regularly to ensure corrective actions.



A performance review is undertaken every quarter at the corporate level by the Apex Sustainability Committee chaired by Executive Director (Ops, Sustainability & BE) and including the CSO, facility heads and Head – Manufacturing. The committee reviews progress on sustainability targets, conducts gap assessment and takes essential decisions to improve performance. The Board Committee on sustainability reviews the sustainability performance on a half yearly basis.



In terms of external audit, third party certification bodies audit the facilities periodically as part of the certification/surveillance protocols. As needed, EHS processes are also reviewed in cases mandated by the internal audit committee and as part of the enterprise risk management (ERM) audits, both conducted by external consultants.



All facilities conduct regular environmental monitoring including ambient air quality, stack emissions, effluent quality, ambient noise, water quality, etc. in order to ensure compliance with the applicable legal requirements and standards. The monitoring parameters and their thresholds are governed by the consent conditions specified in CTO (Consent to Operate) and stipulated by respective State Pollution Control Boards which also vary within facilities. Current monitoring practices have scope for improvements. As part of the ESAP, JPL will develop a corporate environmental monitoring procedure which will specify minimum parameters to be monitored, monitoring frequencies for all facilities dependent on the type of sources (e.g. process stacks, incinerators, boiler stacks, effluent treatment plants, fugitive sources) and monitoring (e.g. ambient air quality, 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 and utility emission stacks and effluent quality in the applicable World Bank Group (WBG) General EHS Guidelin
es, EHS Guidelines for Pharmaceuticals and Biotechnology Manufacturing, and Waste Management Facilities. Regular monitoring will be conducted for these parameters and corrective actions taken as necessary.



As discussed under PS3, the production units have various storage facilities for chemicals and waste, including underground storage tanks for solvents at Nanjangud. In order to identify and timely mitigate risks of eventual contamination events, the corporate environmental monitoring procedure will specify the need for groundwater monitoring at the production facilities through installation of dedicated monitoring wells.



As regards external reporting, since 2002-03, the parent company JLS has been reporting its economic, environmental and social performance through Sustainability Reports, publicly available at http://www.jubl.com/cpage.aspx?mpgid=19&pgid=27. The reports have been receiving A+ Application Level Check statement since 2007 by GRI (Global Reporting Initiative). Third party auditors provide independent assurance statement on JLS Sustainability Report covering corporate’s sustainability performance during the financial year. Going forward, JPL data will be publicly disclosed as part of JLS'' Sustainability Reports.



Emergency Preparedness and Response: In accordance with local requirements, JPL will provide and maintain 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, water and foam monitors, sprinklers in API and product storage areas (at Roorkee only) as well as fire tenders (at Nanjangud). Smoke detectors, gas detectors, water deluge and alarm systems were observed to be installed at the facilities visited by IFC. Required number of personnel was noted to be trained in fire safety and emergency response at the visited facilities. There were emergency response kits (e.g., spill kits, self-contained breathing apparatus boxes, and fire proximity suits) well identifiable and located at various locations, based on expected risks, in the production units visited by IFC.



On-site emergency response plans (OSEPs) have been prepared for the operating facilities, including Nanjangud and Roorkee, covering various types of emergencies. Roorkee and Nanjangud facilities do not fall under the national requirements for Major Accident Hazards (MAH), hence offsite emergency plans are not mandated. JPL is required and committed to complete quantitative risk assessment (QRA) studies for its Nanjangud units according good international industry practice. As needed, JPL will complement the assessment carried out as part of the EIA for the proposed capacity expansion project to ensure that all units and solvent bulk storages at Nanjangud are assessed by a QRA and the actions identified in the EIA are implemented, including the development of a Disaster Management Plan, with bot
h onsite and off-site emergency preparedness and response plans.



The JPL’s facilities are member of Mutual Aid Response Group (MARG) created by respective District Administrations through which nearby companies coordinate and provide mutual support in disaster management in case of an emergency. Regular emergency response drills, including evacuation drills and fire drills, are conducted for different emergencies, as required by the OSEPs.

As on March 31st, 2013, the permanent staff of the pharmaceutical facilities in India was 1458 (958 for API and 500 for Dosage) while the contract workers were 570 (427 for API and 143 for Dosage).



Human Resource (HR) Policies and Procedures, Working Conditions and Terms of Employment: The parent company JLS is a member of United Nations Global Compact (UNGC) since 2010 and has thus committed to adhere to the principles of UNGC including abolition of child labor, elimination of forced and bonded labor, non-discrimination and freedom of association and collective bargaining. JPL will adhere to the same corporate principles.



For communication to its staff, policies and procedures are documented in an employee handbook given to employee at the time of joining as part of an e-joining kit called NEON (New Employee Onboarding Kit). As regards workers, Nanjangud and Roorkee facilities follow standing orders as required under the Industrial Employment (Standing Orders) Act 1946, and both have certified standing orders. The standing orders and abstract of applicable labor laws were noted to be displayed at the visited facilities. All workers sign a contract with the company. JPL provides statutory benefits to its workers. There are Codes of Conduct for employees and for directors and senior management. All corporate HR policies and procedures will be transferred to and adopted by JPL.



The facility head and HR manager are responsible for monitoring and reporting to the company secretary about statutory compliance on HR related aspects on quarterly basis through the Corporate Statutory Compliance Monitoring Software.



Non-discrimination and Equal Opportunity: As discussed above, as part of its commitment to UNGC, the parent company JLS has adopted policies of non-discrimination and equal opportunity. There are a Non Discrimination Policy and a Policy on Prevention of Sexual Harassment. As per the Sustainability Report 2012-13, two cases of discrimination were reported to the Ombudsman’s Office (discussed below) during this reporting period and were resolved after detailed investigations.



Freedom of Association: As part of its commitment to UNGC, the parent company recognizes workers’ freedom of association and right to collective bargaining in accordance with the local laws, as applicable. There is a Freedom of Association Policy. At Nanjangud workers have a union and a wage agreement with the union was signed by the company.



Prevention of Child Labor and Forced Labor: The parent company is committed to 100% elimination of child labor and forced and bonded labor, and has both a Child Labor Policy and a Policy on Forced and Compulsory Labor. The employees are free to quit work at any time after serving the requisite notice period as stipulated in the terms of appointment. Age proofs are collected prior to recruitment to prevent use of child labor or young workers in its operations. The information regarding the Child Labor Policy was disp
layed in local languages at all facilities visited (main entrance gate and inside places).



Third Party Workers: As mentioned above, contract workers hired at the pharmaceutical facilities are supervised by facility management team. A safety orientation and awareness program is conducted by site EHS team before issue of gate pass required to enter the work area. Specific requirements on safety and statutory compliance have been included in the contractor’s work order /contracts documents. Facility HR departments monitor contractor’s compliance with various statutory compliance requirements on providing wages, working hours and benefits to their workers. Contractors are also required to pay their workers through bank accounts in order to make the payments transparent and to provide evidences of payment.



Grievance Mechanism: JBG has an independent ombudsman which has been created to receive grievances/complaints on HR and harassment issues from all group companies, including JPL, through its portal and email address. Upon receiving the complaints, the ombudsman’s office gets the required investigation reports and is in charge of ensuring corrective actions are identified and implemented. A Whistleblower Policy has also been adopted, providing opportunity to permanent employees to raise a concern about internal irregularities and providing the necessary safeguards to the employees against unlawful victimization.



The company confirmed that workers can raise their grievances either through the unions/workers’ committees defined at various facilities, and follow up of each grievance is done as a part of the redressal process as mentioned in the standing orders.



As part of the ESAP, JPL will adopt the existing corporate grievance mechanisms for workers and, as needed, will include relevant provisions to ensure compliance with IFC PS2 requirements. The company will design awareness campaigns for workers (including contract workers) regarding available grievance mechanism channels and develop a consistent and structured system of documenting grievances received and processed through the available redressal channels.



Occupational Health and Safety (OHS): As discussed above, Nanjangud, has a certified OHS management system. Hazard Identification and Risk Assessment (HIRA) is conducted quarterly for all operations and recommendations are defined. HAZOPs and Failure Mode and Effects Analyses (FMEA) are regularly conducted for all projects implemented at the facilities. Job Safety Analyses are also carried out to identify specific potential occupational hazards. Safety induction is provided to employees, permanent workmen, contract workers and visitors. Regular safety trainings are provided to employees as well as contract workers. Safety talks are conducted in each department at the beginning of the work shift. Required safety equipment is provided including personal protective equipment (PPE) depending on hazards related to the type of task b
eing performed and the production unit, including hard hats, safety shoes, safety glasses, masks or respirators (including self-contained breathing apparatuses) and hearing protection. PPE usage was noted to be adequate at the visited facilities. There were toxic gas and oxygen level detection systems with alarms at several production units visited. The use of partitioned workplace areas with differential air pressure was observed at Roorkee facility. High efficiency particulate air filters were present at the pharmaceutical facilities as per GMP protocols. Safety signage was adequate and, as needed, in English, Hindi and other local languages as applicable at the facilities. Emergency exits and assembly points were well identified.



A Behavior Based Safety (BBS) campaign has recently been rolled out at the various operating facilities to encourage every employee to take responsibility for safer workplaces. An external expert was hired to conduct “train the trainer” programs for BBS and till date 30 executives have been trained at different locations including Roorkee and Nanjangud. In all facilities visited, there were well-equipped Occupational Health Centers (OHC), staffed with medical doctors, along with ambulances which cater to both employees and contract workers. Regular health checkups are conducted for both employees and contract workers, based on an analysis of workers’ exposure to workplace hazards. Workplace monitoring, including noise, illumination, air quality and ergonomic studies, is carried out as per statutory requirements. As part of the ESAP, JPL will review the workplace hazards at the various production units in India and North America, to ensure consistency in the approach implemented by the various facilities in addition to meeting the diverse state statutory requirements where the facilities operate, and will develop a corporate workplace monitoring procedure which will specify minimum parameters and monitoring frequencies required by the corporate level for each operating facility. Regular monitoring will be conducted for these parameters, results submitted to CST, and corrective actions taken as necessary.



All facilities have safety committees which review safety performance on a monthly basis. CST conducts quarterly safety review along with the Sustainability review where the leading and lagging indicators on OHS are reviewed for all facilities including accidents/incidents, near-misses, first-aid cases, shift wise safety briefing statistics, safety training, fire incidents, safety audit compliance status and status on closure to the issues reported in the company’s safety observation software (Sanchetna) and environment software (Jagruti).



In last three years 2011-12, 2012-13 and 2013-14, zero fatal accidents and 11 lost work day accidents were reported at the company’s pharmaceutical facilities in India. As per JLS’ Sustainability Report 2012-13, the medium (i.e. absence from work for more than 48 hours but
less than 2 months) and major accidents (i.e. absence from work for more than two months) per million hours were 0.24, 0 and 0.13 in 2010-11, 2011-12 and 2012-13, respectively. The minor accidents (i.e. absence from work for less than 48 hours) per million man-hours are reported to be 0.55, 0.96 and 0.59 in the same years respectively. The company provided examples of the accident investigation reports, including root cause analysis and corrective actions.



In 2012-13, the parent company JLS hired a third party specialized service provider to conduct comprehensive process safety review, safety audit, capacity building for design safety and emergency response preparedness for all Indian facilities. A program to address and close out the non-conformances observed during the audits has been developed, and, as per available status, the company has reported that most of the non-conformances have been addressed and closed out.



Based on the 2012-13 baseline, the established specific corporate safety goals are (i) 30% reduction on man-days lost due occupational health and injury by 2016-17 and 60% by 2020; (ii) 10% reduction of first aid cases by 2016-17 and 20% by 2020 and (iii) safety training man-hours increase - 4 hrs/person by 2016-17 and 8 hrs/person by 2020. These corporate safety goals are applicable across JPL operations including Nanjangud, Roorkee and North American facilities.



Supply Chain: Based on the corporate Green Supply Chain policy, JPL is committed to work with its partners to prevent child labor, adhere to EHS compliance, resource efficiency and other principles. There are a Head (Supply Chain) and dedicated supply chain team at the corporate level. “Partners in progress” meetings are organized for the company’s suppliers, where the policies and procedures are presented and discussed.



The company contracts reputed raw material suppliers and global logistic service providers. Suppliers of raw materials, packaging materials, transporters as well as contract manufacturers are screened and contracted from the corporate headquarters. Consistent with corporate requirements, JPL will have specific SOPs for vendor selection and evaluation for transporters, quality audits of suppliers of raw materials/packaging materials and contract/toll manufacturers. A dedicated contract manufacturing team at the corporate level manages toll/contract manufacturing operations whereas other contractors are managed by the supply chain team.



To promote prevention of child labor, the company encourages its suppliers also to work towards a no child labor policy. Self-evaluation questionnaires, which delineate prohibition of child labor, are required to be filled by each supplier.



Regular supply chain audits will be conducted by JPL for its suppliers/contract manufacturers. While contract manufacturing audit checklist has specific EHS indicators and provisions, the audits on raw material and packaging suppliers are currently mainly focused o
n quality. The company has confirmed to revise the current procedures and include similar EHS elements in all supply chain audits. As part of the ESAP, JPL will adopt the corporate procedures and include specific requirements on EHS including prevention of child labor, forced labor and ensuring safety of workers in the contracts and self-evaluation and audit checklists for all its suppliers.

Resource Efficiency: Total energy and water consumption figures are reported in the Corporate Sustainability Report.



The following corporate resource efficiency goals for JPL facilities have been set to be achieved by 2016-17 and 2020 (respectively in parenthesis) with 2012-13 as the baseline: reduction of specific energy consumption (-4% and -12%; baseline: 633 GJ/MT – API, and 201 GJ/million units of product – Pharma), reduction of greenhouse gas (GHG) emissions (-4% and -12%; baseline: 77 tCO2e/MT – API, and 13 tCO2e/million units of product – Pharma), and reduction of specific water consumption (-4% and -12%; baseline: 374 m3/ MT – API, and 250 m3/million units of product – Pharma).



All facilities identify energy and water improvement projects and progress of these projects is monitored by the CST. For example, the facility at Nanjangud switched the fuel for steam generation from furnace oil (in April 2012) to 100% bio-diesel (in April 2013). Now the facility has started procuring steam from an external company which generates steam from biomass. Some of the other projects taken up by the plant include increasing inorganic salts recovery from the reject wastewater and increasing the boiler efficiency. The facility also initiated co-processing under which hazardous waste (earlier incinerated in-house) is sent to cement kilns where it is used as alternate fuel for energy generation. In FY 2012-13, 281 MT of hazardous waste was sent to cement kilns for co-processing, and the company is currently exploring the scalability of this initiative to other production units.



Air Emissions and Ambient Air Quality: The main sources at JPL facilities are the process emission stacks and vents, and the utility stacks including boilers, incinerators for liquid and solid wastes, and back-up diesel generators. Appropriate pollution control equipment is installed at the various facilities visited. Particulate emissions are controlled through multi-cyclones, bag filters and high efficiency electro-static precipitators (ESPs). Volatile organic compounds (VOCs) emissions are abated through wet scrubbers, catalytic incinerators and thermal oxidizers. Their recovery is carried out through condensers and chillers. Emissions of VOCs from storage tanks are controlled through nitrogen blanketing. The process emission stacks at Nanjangud were provided with venture / packed bed scrubber and horizontal scrubber. VOC process emissions were abated with thermal and catalytic oxidation, adsorption and condensation. The venting system was provided with condenser, while dust was collected and abated through dust collectors, cyclones, and bag filters. At Roorkee process emissions were abated through dry scrubber and wet scrubber, the latter to remove water soluble VOC.



Ambient air quality is regularly monitored at every production facility and its surroundings. Process and power/steam generation stack emission monitoring results and ambient air quality monitoring resu
lts provided are compliant with the limits specified for the facilities by the relevant State Pollution Control Boards and with the National Ambient Air Quality Standards (NAAQS), and they are in line with the relevant WBG guidelines, although the sets of parameters are to be revised and complemented, as needed. As indicated under PS1, going forward JPL will develop and implement a corporate environmental monitoring program which will ensure consistent monitoring plans at the production facilities and monitor compliance with national limits as well as applicable WBG guidelines.



Water Consumption and Wastewater Discharges: The total water consumption for Roorkee in 2012-13 was 64,443 m3 from groundwater; water consumption in Nanjangud was 201,450 m3 supplied by the municipality. As indicated above, the company has established corporate goals to significantly reduce specific water consumption by 2020.



The parent company has adopted a zero discharge policy at most of its production facilities, and installed process wastewater treatment units at its major facilities with effluent recycling, including Nanjangud. At Nanjangud, the effluent is treated in a physico-chemical effluent treatment plant followed by stripper (for recovery of solvents), MEE and forced circulation evaporator, spray dryer or agitated thin film dryer (ATFD), biological treatment and RO. The treated water is utilized for cooling tower make-up. Semi-pure inorganic salts from MEE/ATFD are recovered, while waste salts are landfilled at government approved treatment, storage and disposal facilities (TSDFs). At Roorkee, the effluent is treated in a primary and secondary treatment process followed by tertiary filtration. The treated effluent is then used for gardening and greenbelt irrigation. Treated effluents are regularly monitored through in house laboratories as well as external agencies certified by the Ministry of Environment and Forest (MOEF).



Storm water from clean surfaces is collected and discharged through separate drainage systems. Going forward wastewater and storm water monitoring requirements (parameters and frequencies) will be included in the corporate environmental monitoring program which will be developed for implementation at all JPL’s facilities.



Waste Management: The major streams of hazardous waste generated at JPL facilities (6,640 MT from Nanjangud) include spent catalyst, ETP sludge, spray dried salts, inorganic salts from MEEs, spent solvents, used oil, and discarded drugs. The company has a strategy to reduce waste at source which includes prevention and reduction of waste generated, efficient use of raw materials and packaging materials and encouraging reuse, recycling and recovery, including co-processing in cement kilns for solid organic waste produced at Nanjangud. The hazardous wastes, which are not recycled and recovered, are incinerated on-site or sent to government licensed TSDFs. At Nanjangud facility, solid organic waste streams,
which are not co-processed in cement kilns, are incinerated in a rotary kiln, while waste inorganic salts are disposed of in a secured landfill. Roorkee plant is sending its hazardous waste to a licensed disposal facility. Hazardous waste generated at facilities visited is tested by an external laboratory as required.



Hazardous Materials Management: Production processes at the pharmaceutical facilities require the use of a number of hazardous chemicals in various quantities. Nanjangud facility’s production processes require the storage of a number of chemicals in bulk including different solvents (e.g. toluene, methanol, methylene dichloride, iso propyl alcohol), High Speed Diesel, and hydrochloric acid. At Nanjangud solvents are stored in underground storage tanks (USTs), which are located in a properly secured location.



Hazardous material management was found to be adequate at the facilities visited by IFC. Measures to manage the use, storage and handling of hazardous material have been implemented according to good industrial practice, although a corporate management plan has to be formalized. Hazardous materials handled at the production facilities were properly assessed and classified for associated hazards and their inventories were known by the staff. Material Safety Data Sheets (MSDS) were found to be properly maintained and readily available in all production units visited. Appropriate signage was present. Secondary containment as well as other safety provisions, including spill control and response, were provided, as needed, at the visited facilities for their storage. Training in chemical handling and emergency situations is provided to both staff and contract workers.



As part of the ESAP, JPL will develop a corporate hazardous material plan, including procedures to assess transportation, handling, storage, and use of hazardous materials at the Indian production facilities. As part of the hazardous material management measures, the company will implement an UST integrity review program at Nanjangud, and, as needed, conduct tightness testing.



GHG emissions: The parent company JLS calculates and discloses both direct and indirect GHG emissions according to GRI requirements. As per Sustainability Report 2012-13, total direct GHG emissions were 894,456 tCO2e (2% from Nanjangud and Roorkee facilities) while total indirect GHG emissions were 107,906 tCO2e (25% from Nanjangud and Roorkee facilities). Apart from these emissions, the GHG emissions from bio-mass for the reporting period were 12,057 tCO2e. As indicated above, GHG emission reduction goals have been established and voluntary reduction initiatives have been taken at the corporate level by participating in the Carbon Disclosure Project being executed by World Wildlife Fund and Confederation of Indian Industries in India. JPL will continue to implement the corporate approach in terms of GHG emission accounting and reporting, as well as definition of reduction goals.

Nanjangud facility is located in a notified industrial area, while Roorkee is located in a mixed-use development area. Local communities are located at close distance from the boundaries of the production site of Nanjangud. JPL will complement the risk assessment carried out as part of the EIA for the proposed expansion of Nanjangud production facility, to ensure that all operating and proposed units of the facility are assessed. The company will develop and implement, in coordination with local authorities, offsite emergency preparedness and response programs for both on-site accidental scenarios and hazardous material transportation accidental scenarios, including offsite drills and community preparedness and awareness measures in the area of influence of Nanjangud.



The pharmaceutical facilities receive the needed raw materials including hazardous chemicals through contracted specialized transport service providers. While transporting any hazardous chemical/API, it is a requirement by the company that Transport Emergency Management (TREM) cards are provided to the drivers. Recognizing the potential risks associated with chemical/API transportation, a program on behavioral safety was launched in November 2013 with defensive driving training program for the truck drivers and transport service providers. This program was attended by around 35 service providers across India who are providing their services to the company in transportation of chemical/API and dry cargo. As part of the program, the performance of the service providers was reviewed and areas of improvement and targets were established.



As part of the ESAP, JPL will adopt JLS’ procedures and implement a corporate process of screening, qualification, monitoring and regular evaluation of its raw material and product transport service providers with respect to their compliance with safety requirement, safety performance, transport equipment maintenance, driver’s training and awareness and emergency preparedness and response for safe transportation of hazardous chemicals.



Security personnel are employed at the company’s facilities through security contractors. In night shifts some armed security personnel are deployed at the facilities. Security personnel are briefed about corporate policies on child labor and training is provided on basic safety, first-aid, fire safety and emergency response. Also, the security personnel are given behavioral trainings on body language, dealing with visitors/employees and escalation of issues. As part of its management system, JPL will adopt JLS’ procedures, will regularly review and monitors the performance of the security providers, and will develop a Code of Conduct for security personnel consistent with the requirements of PS4.

According to information provided by the company, consultation and disclosure of EIAs where required is conducted in compliance with regulations of the jurisdiction where the project is implemented.

JPL will post contact details (name, phone numbers, email address) of the CSO and enquiry forms on its website to enable customers and stakeholders to make enquiries, submit comments, feedbacks or raise grievances regarding its operations at all of its plants. The corporate CSR team maintains regular contacts with the local communities, collects and reports on their concerns, and monitors the community development activities on regular basis while Board Sustainability Committee reviews the development on half yearly cycle. Community concerns will also be collected in the area of influence of JPL’s facilities, as part of Social Impact Assessments of the CSR activities, which are commissioned at an interval of 3 years by the Jubilant Bhartia Foundation (JBF), the CSR wing of JBG. The company also provided information relevant to the corrective actions implemented at Nanjangud in response to a public complaint filed in 2009.

In order to provide a structured framework to all relevant community engagement activities associated with the pharmaceutical operating facilities, JPL will develop a Stakeholder Engagement Framework (SEF) at the corporate level, to ensure that, going forward, public disclosure of relevant project information and consultation are consistently conducted throughout its operations and managed assets, in accordance with IFC PS requirements. Grievance management mechanisms which are made available to the affected communities will be described as part of the SEF and consistently implemented for all facilities. As discussed under PS1, JPL data will also be publicly disclosed as part of Corporate Sustainability Reports.

Jubilant Bhartia Foundation, a not for profit organization established in 2007, focuses on three key areas of social development including primary education, basic healthcare and skill development for employability and self-sustenance. Within these broad areas, specific needs are identified through participatory rural appraisal (PRA), group discussions and interviews. For example, JBF’s community development activities involve 7 villages in the area surrounding Nanjangud plant.

On education, JBF initiated its project “Muskaan” in 2007 for supporting public primary schools in rural areas to improve the learning environment in the school and bring down the dropout rates, to improve the quality of education imparted and to motivate the students to take up higher studies. At present, JBF supports 100 primary schools under the program. The impact of the program is measured against four indicators including infrastructure, community involvement, retention and quality of education.

On healthcare, JBF started various initiatives like community health services and Swasthya Praharis (or health guards). The health guards are identified local women who keep track of expecting and lactating mothers, malnourished children, birth and death in order to help them with available health care services. They also motivate people for visiting health institutions and promoting institutional child birth. Based on the indicators monitored by the CSR team, this initiative has helped in increasing the institutional delivery thus reducing infant mortality rate and maternal mortality rate in the areas where it has been launched. Also, health camps are organized to increase health care awareness and providing included eyes, dental, heart and veterinary care.

To improve the employability skills of the youth, JBF introduced Nayee Disha, a vocational training program. Under this program, skill development programs are run at JBF’s Vocational Training Centres at different locations. The training programs are on a wide array of areas like mobile and tractor repairing, electrician courses, stitching, retail management, soft skill development and beautician courses.

JBF and Schwab Foundation for Social Entrepreneurship, sister organisation of the World Economic Forum, have collaborated to institute “The India Social Entrepreneur of the Year Award” to recognize social entrepreneurs, with excellence in large-scale, system change models. JBF publishes an annual report of its activities which is publicly available on its website (http://www.jubilantbhartiafoundation.com/publications.html).

Apart from JBF activities, the company organizes various programs where employees volunteer or make contribution for specific causes in the communities surrounding the production facilities.

Due to the nature of this proposed investment, the corporate''s contact and headquarters are being provided in lieu of project locations.

Name: Arun K Sharma
Title: CFO
Company: Jubilant Pharma Ltd.
Address: Plot 1A, Sector 16 A
Noida – 201301
Uttar Pradesh
Tel: 0120 4361109
Mail to: mailto:arun_sharma@jubl.com
Website: http://www.jubl.com

Broad Community Support is not applicable for this project

Jubilant Pharma(35027) Supervision Disclosure Snapshot – Version 3
Description	Anticipated Completion Date	Status	Comments	Completion Date
Jubilant Pharma Ltd (JPL) will develop a corporate Environmental and Social Impact Assessment (ESIA) and E&S due diligence procedure meeting IFC PS requirements. The procedure will detail minimum corporate requirements for primary and secondary data collection and analysis, risk and impact identification and assessment, mitigation, development of project-specific environmental and social management plans, public consultation, disclosure, and stakeholder engagement.	31-Mar-2015	Completed	Completed	5/23/2015
JPL will provide evidences that JLS' E&S (including environmental, health and safety, social responsibility, human resources, and supply chain) policies and management system certifications have been transferred to JGL/JPL.	30-Jun-2015	Completed	Completed	3/31/2015
There will be a corporate sustainability management team with the necessary authority to implement the corporate sustainability management systems and practices and oversight role throughout the new organization, after the transfer of pharmaceutical assets from JLS to JGL/JPL.	31-Oct-2014	Completed	Completed	7/31/2014
JPL will develop and implement a corporate environmental monitoring procedure which will specify minimum parameters to be monitored for each facility, monitoring frequency, and relevant thresholds for corrective actions. The procedure will specify the need for groundwater monitoring at the production facilities through installation of dedicated monitoring wells.	31-Dec-2014	Completed	Completed	3/31/2018
JPL will adopt the existing JLS' grievance mechanisms for workers and, as needed, will include relevant provisions to ensure compliance with IFC PS2 requirements. The company will design awareness campaigns for workers (including contract workers) regarding available grievance mechanism channels and develop a consistent and structured system of documenting grievances received and processed through these channels.	31-May-2015	Completed	Completed	3/31/2018
JPL will develop and implement a corporate workplace monitoring procedure which will specify minimum parameters and monitoring frequencies required by the corporate level for each operating facility.	31-Dec-2014	Completed	Completed	12/29/2014
JPL will adopt JLS' supply chain audit procedures and will include specific requirements on EHS, including prevention of child labor and forced labor and safety of workers for all its suppliers.	31-Aug-2015	Completed	Completed	3/31/2018
JPL will develop a corporate hazardous material plan, including procedures to assess transportation, handling, storage, and use of hazardous materials at the Indian production facilities. As part of the hazardous material management measures, JPL will implement an UST integrity review program at Nanjangud, and, as needed, conduct tightness testing.	31-Mar-2015	Completed	Completed	3/31/2018
JPL will complement the risk assessment carried out as part of the EIA (March 2013) for the proposed expansion of Nanjangud facility, to ensure that all operating and proposed units of the facility are assessed. The company will implement the relevant actions, including the development of a Disaster Management Plan, with both onsite and off-site emergency preparedness and response plans.	31-May-2015	Completed	Completed	6/30/2016
JPL, in coordination with local authorities, will develop and implement an offsite emergency preparedness and response program for both on-site and hazardous material transportation accidental scenarios, including offsite drills, and community preparedness and awareness measures in the area of influence of Nanjangud facility.	30-Jun-2015	Completed	Completed	6/30/2016
JPL will adopt and implement a corporate process of screening, qualification, monitoring and regular evaluation of its raw material and product transport service providers with respect to their compliance with safety requirement, safety performance, transport equipment maintenance, driver's training and awareness and emergency preparedness and response for safe transportation of hazardous chemicals.	30-Jun-2015	Completed	Completed	3/31/2018
JPL will develop a Code of Conduct for security personnel consistent with the requirements of PS4.	31-May-2015	Completed	Completed	5/25/2015
JPL will develop a Stakeholder Engagement Framework (SEF) at the corporate level, to ensure that, going forward, public disclosure of relevant project information and consultation are consistently conducted throughout its operations and managed assets, in accordance with IFC PS requirements. Grievance management mechanisms which are made available to the affected communities will be presented as part of the SEF.	31-Mar-2015	Completed	Completed	6/29/2015
JPL data will be publicly disclosed as part of JLS' Sustainability Reports.	31-Dec-2015	Completed	Completed	12/31/2015