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
All the offices, warehouses, pre-schools (and coaching classes to be acquired in future) are typically located in urban areas in leased spaces in existing buildings. Therefore, Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) is not applicable. Similarly, the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Management of Natural Resources), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

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 related to this project are mainly associated with printing operations including assurance of fair, safe and healthy working conditions for its workforce (both company employees and third party workers); pollution prevention especially management of solid wastes and wastewater; and management of hazardous chemicals. The key E&S risks and issues with other operations are mainly related to company’s capacity and systems to manage its social, environmental, health and safety aspects of its operations in compliance with legal requirements as well as IFC Performance Standards and World Bank Group (WBG) EHS guidelines, life and life and fire safety (L&FS) management for its existing and future pre-schools and coaching classes as per WBG EHS guidelines and assurance of fair, safe and healthy working conditions for its workforce as per PS2 requirements.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental & Social Assessment: Considering the nature of business of the company, no formal environmental and social impact assessment (ESIA) is required. As per the observations during the appraisal, the company obtains required environmental and social (E&S) regulatory permits including consent to operate, factories license, and fire no-objection certificates (mainly for printing presses).As part of the ESAP, the company will develop a corporate procedure on screening of new projects (either greenfield or brownfield acquisitions) to identify any risks with respect to IFC PSs and legal requirements and preparing a management plan for the same.



Policy and Management Systems: Currently the company has a documented E&S policy. However this documented policy is not adequate and needs to be further strengthened in line with the IFC Policy and standards. The printing press does not have a documented E&S management system. Going forward, as set forth in the ESAP, the company will document a strengthened E&S policy. Also, the company will develop key E&S procedures (a) screening of new projects (either greenfield or brownfield acquisitions) to identify any risks with respect to IFC PS and legal requirements and preparing a management plan for the same; (b) Life & Fire Safety (L&FS) guidelines to be followed for construction or selection and operation of pre-schools, warehouses and coaching classes; (c) Hazardous chemicals management programs for printing press operations; (d) EHS Monitoring and Reporting Framework (discussed below).



Organization: The visited printing press has quality control person designated as an EHS management representative (MR) supported by the HR and Administration manager as the sub-MR. The company also has a fire and security officer responsible for the printing and warehouse operations. To strengthen the E&S organization, as set forth in the ESAP, the company will appoint/designate an EHS manager for all printing press operations who will coordinate with both printing presses as required to ensure compliance with IFC PSs and WBG EHS guideline requirements. Similarly, the company will appoint/designate a life and fire safety (L&FS) manager responsible for ensuring implementation and maintenance of required L&FS systems for all companies.



Emergency Preparedness and Response: The fire safety systems provided at the visited printing press include fire hydrant systems, sprinklers (in the basement used for paper storage), fire extinguishers and fire alarm system. The company is in the process of installing the fire pumps and is expected to complete the installation within one month. The fire safety systems are noted to be inspected on a regular basis (based on a checklist prepared by the fire safety officer) and maintained. The security and fire safety officer provides fire fighting training to the employees at the press and warehouse. The company has prepared documented evacuation plans for the press. A medical r
oom has been provided at the press.



Areas of improvements were noted in marking of emergency exits and evacuation routes and emergency lighting in the printing press and visited warehouse. As set forth in the ESAP, the company will provide appropriate marking on the emergency evacuation routes and emergency exits (in the press as well as warehouse). Also, emergency lighting will be provided on the evacuation routes in the press as well as warehouse. Further, the company will develop specific emergency response plans for spill control of hazardous chemicals (discussed under PS3) and explosion due to anti-offset powder.



Monitoring & Reporting: Currently the company does not conduct any testing of ambient air quality, stack emissions, effluent quality or work area air quality at the printing press. Also, the accidents/incidents are not recorded or investigated. As per the ESAP, the company will develop and implement an EHS monitoring procedure specifying parameters and frequency for ambient air quality, stack emissions, ambient noise, work area air quality and treated effluent quality monitoring in line with the applicable legal requirements as well as WBG EHS guidelines. The monitoring will be conducted as a condition of IFC investment through a laboratory (acceptable to IFC) and in case any corrective actions are required (based on the monitoring results), the same will be agreed and implemented.



Also, the procedure will describe the processes for accidents/incidents monitoring and investigation at the printing presses and warehouses.

The S Chand Group employs a total workforce of 2500 employees with approximately 500 employees in Company and rest in the subsidiary companies. As regards printing presses, Sahibabad press employs 210 employees whereas Rudrapur employs approximately 100 employees.



HR Policy and Management: S Chand has a documented HR policy manual which describes company’s policies/procedures (among other areas) on recruitment, joining and induction, training and development, insurance, leave, grievance redressal, disciplinary inquiries and prevention of sexual harassment. The policies are currently applicable for S Chand operations and subsidiary companies have their own HR policies, however, company is in the process of rolling out the same policies to all other subsidiary companies as well subject to necessary changes as may be required under applicable legal requirements of relevant States. Currently no specific policies have been documented with respect to key areas under PS2 requirements like non-discrimination, freedom of association, retrenchment, and prevention of forced labor and child labor. Therefore, as per the ESAP, company will document HR policies in line with PS2 requirements and ensure their implementation in all companies.



The policies are communicated to employees during induction. As set forth in the ESAP, the company will supplement communication of HR policies (including grievance mechanism discussed below) in all companies through intranet and display (mainly for employees who do not have access to intranet e.g. in the printing press and warehouses).



S Chand signs a contract with the employees at the time of employment. Most of the employees 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 its printing press operations, the company needs to align production schedules for workers (both own employees as well as third party workers) with applicable legal requirements.



Grievance mechanism: The company has a policy on grievance redressal. The policy encourages employees to lodge grievances without fear of victimization. As per the process, the grievances first need to be raised to the immediate supervisor and in case the employee is not satisfied with the outcome, the grievances can be escalated to the department manager and lastly to the HR / Business Head. As per the process, the employees have a right to be represented by fellow employee and in case of a group grievance, a spokesman and delegation of 10 (or less) employees. The policy specifies the timeline for each step of grievance handling and also that records shall be kept for all statements and decisions. As per the ESAP, the company will improve the grievance mechanism by addition of provisions on anonymously raising grievances. Also, the communication about the process will be supplemented with all other HR policies as discussed above.



The company has a prevention o
f sexual harassment policy. The visited press was noted to have formed a five member committee for handling of sexual harassment complaints with three female members including the presiding officer.



Occupational Health and Safety (OHS): The company has provided exhaust systems and bag filter at the machines for collection of paper dust as well as anti-offset powder (emitted from one machine). The inks are pneumatically fed to the machines. The company follows the operational manual of machines for ensuring provision of adequate safety measures in the machines.



The company has not conducted any work area monitoring. As discussed under PS1, the monitoring will be conducted through a laboratory (acceptable to IFC) as a condition of IFC investment and in case any corrective actions are required (based on the monitoring results), the same will be agreed and implemented.



During the visits to the printing press and warehouse, no other unmitigated OHS hazards were noted except for emergency response (discussed under PS1) and hazardous chemicals management (discussed under PS3).



Third party workers: At the printing press, third party workers are also employed as helpers and for security and housekeeping. Sahibabad press employs about 203 and Rudrapur press employs about 85 third party workers. Similarly at the warehouses, third party workers are employed for movement of goods and loading/unloading. At the visited press, it was noted that the payment is made to these workers in presence of facility HR. The wages and benefits are paid to contract workers as per applicable legal requirements. As discussed above, at its printing press operations, the company will align production schedules for third party workers with applicable legal requirements.

Resource efficiency: Based on the data available, the energy consumption per ton of product for most of the machines ranges from 0.1 to 0.25 MWh/ton whereas three machines have energy consumption of 0.495, 0.495 and 0.65 MWh/ton. The energy consumption thus is below OR meets the industry benchmark specified in the WBG EHS guidelines for Printing i.e. 0.52 to 0.77 MWh/ton. Similarly, the water consumption ranges between 0.046 to 0.11 m3/ton which is below the industry benchmark specified in the WBG EHS guidelines for Printing i.e. 0.62 to 2.09 MWh/ton.



For continual improvement, as set forth in the ESAP, the company will develop and initiate a resource efficiency program which would include setting efficiency objectives (on energy, water and materials consumption), identifying improvement areas for each of the objectives, monitoring and reviewing the progress against each of the objectives.



Emissions and Waste management: Electricity is mainly sourced from the public grid for company’s operations including the printing presses. The back-up for the printing presses is through diesel generator (DG) sets.



The cleaning of rollers in printing machines is through a dry auto cleaning process. The wastewater from the printing presses is therefore mainly from pre-press or development operations which is treated in the on-site wastewater treatment system before it is discharged into the wastewater drain. The other locations mainly have domestic sewage which is discharged in the public sewage system. The stormwater is discharged into the public wastewater drain outside the facility.

Currently the company does not conduct any testing of the emissions from DG sets or the treated effluent at the printing presses. As set forth in the ESAP and as discussed above under PS1, as part of its EHS monitoring framework, the company will document specific monitoring parameters and frequencies for ambient air quality, stack emissions and effluent quality monitoring in line with the applicable legal standards as well as WBG EHS guidelines. The monitoring will be conducted through a laboratory (acceptable to IFC) as a condition of IFC investment and in case any corrective actions are required (based on the monitoring results), the same will be agreed and implemented.



Solid waste from the printing press operations (primarily paper waste, aluminum printing plates) is disposed through external vendors. Printing plates are bent (and sometimes cut) before their disposal.

Hazardous materials management: The company only uses vegetable (soya) oil based inks which are pneumatically fed into the machines. However, a number of hazardous chemicals are used in printing press operations mainly including developers and plate cleaners. Also, solvent (1%) and alcohol (4%) are used in dampening process diluted with 95% of water. As per the ESAP, the company will develop a hazardous chemicals management procedure which would include regular training and specific work instru
ctions for workers on storage, handling, use and spill control of hazardous chemicals. Required personal protective equipment (for handling and use of chemicals) and spill control kits shall be provided by the company.

Both printing presses are located in designated industrial areas. Therefore, the company’s printing operations and other operations (offices, warehouses) are not expected to have any impact on the community health, safety and security.



Regarding Life and Fire Safety (L&FS) Systems, the company provides fire extinguishers at its pre-schools. The visited pre-school was noted to have emergency exits marked with signages. The teachers at the schools are trained in emergency evacuation. As set forth in the ESAP, the company will hire a consultant (acceptable to IFC) who will visit a sample of pre-schools and warehouses and document a L&FS master plan which will define minimum design and technical requirements on L&FS for their typical occupancies and buildings (i.e. pre-schools, warehouses and future coaching classes).



Before acquisition of any existing building, including proposed for lease, the property shall be evaluated against fire protection requirements set forth in the L&FS Master Plan. This evaluation shall form part of the company’s due diligence process. Final decision on acquisition shall be taken only with respect to the upgrades needed to conform to the Master Plan. In case of any deviation, the company shall seek a waiver from L&FS professional in the form of an expert opinion, and fully implement all mitigation measures specified by them.



The master plan and evaluation checklists shall adequately cover- fire prevention, means of egress, detection and alarm systems, fire suppression and control, emergency response plan, and operation and maintenance separately for pre-schools and future coaching classes. The company shall also have specific training, monitoring and reporting processes on L&FS for all employees and third party workers in warehouses, pre-schools and future coaching classes.

The company undertakes a number of corporate social responsibility (CSR) activities including (a) promotion of education through the Shyam Lal Charitable Trust (under which Shyam Lal College , Shahadra , East Delhi was established in 1964 under the University of Delhi); (b) promotion of social welfare and education amongst the poor through establishment of a School under Round Table India in partnership with a Fast Moving Consumer Goods multinational company;(c) establishment of a facility for audiology under the Amar Jyoti Foundation; (d) organizing free eye check-up camp and blood donation camp in association with the Friends of Parmanand Society (e) contribution to the Prime Minister Relief Fund for one of the natural disasters; and (f) contribution to various trusts and societies.

As per the ESAP, S Chand will develop a community grievance mechanism i.e. a process to receive and responding to the grievances from neighboring communities.

Considering the corporate nature of the investment, S Chand will disclose this ESRS and the ESAP at the following addresses and its website http://www.schandgroup.com:

S Chand And Company Private Limited
7361, Ramnagar
New Delhi – 110055
Tel: +91 11 23672080-2

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

Mr. Saurabh Mittal
A-27, 2nd Floor
Mohan Cooperative Industrial Estate
New Delhi – 110044
+91 11 4973 1800
http://www.schandgroup.com

Broad Community Support is not applicable for this project

SChand(35817) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Document a strengthened environment, health and safety (EHS)/Sustainability policy articulating company’s commitment to comply with the applicable EHS laws and regulations as well as compliance with IFC Performance Standards for all its companies.	31-Mar-2015	Completed	Completed	3/31/2015
Appoint/designate an EHS manager for all printing press operations and a life and fire safety (L&FS) manager for all companies.	31-Mar-2015	Completed	Completed	3/31/2015
(a) Document policies on non-discrimination, prevention of child labor and forced labor, retrenchment and freedom of association. (b) Improve the grievance mechanism by addition of provisions on anonymously raising grievances. (c) Supplement communication of HR policies (including grievance mechanism) through intranet and display (for employees who do not have access to intranet e.g. in the printing press and warehouses) in all companies.	31-Mar-2015	Completed	Completed	3/31/2015
Align production schedules for workers (both own employees and third party workers) with applicable legal requirements at all printing operations.	31-Mar-2015	Completed	Completed	3/31/2015
Provide appropriate marking on the emergency evacuation routes and emergency exits and emergency lighting on the evacuation routes in the press as well as warehouse(in the press as well as warehouse). Develop specific emergency response plans for spill control of hazardous chemicals and explosion due to anti-offset powder.	31-Mar-2015	Completed	Completed	3/31/2015
Develop and implement following procedures for all printing press operations : (a) Hazardous chemicals management procedure including regular training and specific work instructions for workers on storage, handling, use and spill control of hazardous chemicals. Also, provide required personal protective equipment (PPE) for handling and use of chemicals as well as required spill control kits. (b) Resource efficiency program which would include setting efficiency objectives (on energy, water and materials consumption), identifying improvement areas for each of the objectives, monitoring and reviewing the progress against each of the objectives. (To be concluded once the energy figures are available). (c) EHS monitoring procedure specifying parameters and frequency for ambient air quality, stack emissions, ambient noise, work area and treated effluent quality monitoring as well as accidents/incidents monitoring and investigation.	30-Jun-2015	Completed	Completed	6/30/2015
(a) Conduct monitoring of ambient air quality, stack emissions, ambient noise, work area and treated effluent quality for parameters as per applicable local standards and World Bank Group EHS guidelines for Printing through a laboratory acceptable to IFC. (b) Based on the monitoring results, agree on a corrective action plan with IFC.	15-Mar-2015	Completed	Completed	3/15/2015
Hire a consultant (acceptable to IFC, who will visit a sample of pre-schools and warehouses)and document a L&FS master plan which will define minimum design and technical requirements on L&FS for typical occupancies and buildings (e.g. pre-schools, warehouses, coaching classes). As described in the ESRS, the L&FS Master Plan shall be used for due diligence of any existing property before acquisition including proposed for lease and in case required, the upgrades shall be made before possession of such property. Also document specific training, monitoring and reporting processes on L&FS for all employees and third party workers in warehouses, pre-schools and future coaching classes.	30-Jun-2015	Completed	Completed	6/30/2015
Develop and implement a community grievance mechanism including a process to receive and respond to grievances from the neighbouring communities.	30-Jun-2015	Completed	Completed	6/30/2015