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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The company’s manufacturing operations do not result in any significant noise, wastes, emissions or other risks and impacts. Also, the manufacturing facilities are located in the well-developed industrial zones and remote from the nearby residential communities. Hence, impacts related to PS4: Community Health Safety and Security are not expected for this investment.

Impacts related to PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected because the Project does not involve any new land acquisition and involuntary displacement, as envisaged under the PS5. Any future land purchase will only be in industrial areas and strictly through a willing-buyer-willing seller open market transaction or through a lease from the government agencies.

Key environmental and social (E&S) risks and issues related to this project include those that are typical to light to medium manufacturing industries, such as labor, occupational health and safety, pollution control and energy efficiency. Potential negative impacts from the project can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Moreover, Envision’s products (wind turbines and software solutions) contribute to the generation of renewable energy and avoidance of greenhouse gas (GHG) emissions; thereby resulting in environmental benefits.

The activities under the proposed project result in a limited number of specific EHS and social impacts, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The proposed investment has, therefore, been classified as a Category B project according to IFC’s Policy on Social and Environmental Sustainability.

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. IFC’s appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFC’s requirements. For purposes of this project there is no Environmental and Social Action Plan so as to close gaps though as the company’s activities, and those associated with the borrower entities, already operate in in accordance with Performance Standards objectives.

Management Systems:



Envision has implemented comprehensive EHS management systems across all its operations, including the borrower entities, as per Envision’s internal corporate standards, which are in turn aligned to international standards (ISO) and are consistent with IFC Performance Standards and relevant WBG/IFC guidelines.



As part of these management systems, Envision has developed a 3-tier documentation, including:

Level 1: EHS Management System Manual,

Level 2: Procedures (32 documents), and

Level 3 Operation Guidance (24 instances).



All these documents and operational requirements are accessible for all the staff via the company’s intranet and online systems.



Since 2012, Envision has implemented environmental and safety management systems certified compliant with ISO 14001 Environmental Management System (EMS) and OHSAS 18001 Occupational Health and Safety Management Systems international standards, covering all its facilities. These are audited by third-party auditors, viz. DNV, annually.



As mentioned earlier, the management systems implemented by the borrower entities are an integral part of these corporate EHS management systems.



- Organization:



Envision has established a robust EHS organization across its business lines. The corporate safety committee is chaired by the CEO and includes all the department directors as members, including the EHS department.



The EHS Management department, as a corporate resource, is responsible for all the operational matters related to EHS for the manufacturing, logistics, own wind farm operations and wind farms (erection and service support) all over China (including the borrower entities).



Envision’s EHS team comprises of 18 full-time professionals in China, with 4 staff for manufacturing operations in Jiangyin (primarily responsible for the borrowing entities), 1 for logistics, 1 for solar operations, and 1 for in own wind farms and all others based in Shanghai to support the commissioning and servicing of turbines at the clients’ wind farm sites.



The safety committee meets every 2 weeks, however, EHS reports are presented and issues are also discussed during weekly senior management meeting. While the EHS reports are submitted directly to CEO, the EHS management department reports to Deputy Chairman of the company for day to day operational matters.



Monitoring & Reporting:



As a part of the EHS management system an elaborate monitoring and reporting program has been put in place by Envision which enables management to understand the performance of day-to-day operations and also track the progress towards the annual objectives, targets, and Key Performance Indicators (KPIs) such as: Lost Time Injury (LTI) Frequency Rate, Recordable Incident (RI) and Illness Frequency Rate (IFR), Training Completion Rate etc.



Additional specific KPIs have also been developed for manufacturing facilities and wind farm development businesses. Weekly monitoring of KPIs is
carried out and regular reports are submitted to Envision senior management. In addition to accidents and incidents, Envision monitors near misses in its operations, which are reported to the management and regularly discussed in management meetings.



- Emergency Preparedness and Response



Envision has completed the risk assessment study for all its operations and accordingly, an Emergency Response Plan document has been finalized and an Emergency Response Team has been constituted. As per its emergency management procedures, a Site Manager is required to organize an emergency drill every three months, especially for wind farm operations and maintenance activities, which covers emergency escape from nacelle, fire extinguishing, first aid, etc.



- Managing Supply Chain:



To produce its high quality smart turbines, Envision has established a sophisticated supply chain of highly specialized hi-tech components, which are sourced from reputed and highly specialized international suppliers accredited by Envision. These include, leading international firms and brands such as: LM Glasfiber blades, Winergy gearboxes, SKF bearings and generators from ABB/Siemens, among others. About 10% of the components (such as the break system, shock absorption system) are imported, mostly from Europe. Others such as gearboxes, generators and transformers are purchased from reputed European brands.



Envision has a comprehensive process for the selection and monitoring of suppliers which includes an assessment by the quality and EHS departments on safety, environment and quality aspects. The assessment involves standard checklists, document review, as well as an elaborate inspections and audit process.



In addition to the specialized components, Envision extensively uses specialized transportation services to transport nacelle and hub to the site from its manufacturing facilities, while blades are delivered directly to the customers’ project sites by the supplier. For transportation, Envision has a pool of 18 specialized wind logistics companies which comply with Envision’s specific requirements including safety and labor compliance. Moreover, Envision has developed a detailed checklist to monitor and rate the vendor’s performance on safety, price, timeliness, team quality, vehicle quality on an ongoing basis. The contracts are awarded based on regional or project based bid, and each selected vendor is required to sign the safety contract. Nearly half of the contractors are classified as “Class A” contractors based on their performance, and enjoy favorable advantage while bidding for new contracts. Envision has developed a defensive driving program for all the contract drivers which requires a license issued by EHS department after completion of necessary training and testing; before driving to wind farm.



Envision retains 3% of the contract value as security deposit. Those contractors with low performance score by the end of the contract, lose the dep
osit which is given as award to other contractors with high score, to incentivize high standards of safety and service quality.



As a result of this strict screening and monitoring, none of Envision’s transport contractors have been involved in any major accident in the past. For minor accidents resulting in damage to blade etc. Envision’s EHS team conducts post-investigations and recommends corrective and preventive actions.



Security services are outsourced to reputed licensed companies, and unarmed guards are deployed at Envision’s manufacturing facilities. Security guards are trained for emergency response and actively participate in EHS drills and other related tasks.

Globally, Envision employs a total workforce of over 900, of which more than 150 are women across all levels. About 50 employees are hired through outsourced contractors for security, housekeeping, and as drivers.



In Envision’s Jiangyin manufacturing facility, an average of 400 blue collar employees are hired (up to 600 during peak season) through a labor contractor, while the white-collar employees are directly hired by Envision. Each employee receive the employment contract, either through the company or the labor contractor, for a period of 1-3 years, which can be renewed by mutual agreement, depending on business needs. Other than the contractual arrangements, in practice there is no differentiation in the direct recruits and contracted staff, in terms of benefits, training opportunities and EHS rules and standard operating procedures (SOP).



- Human Resource Policy, Management



Envision has articulated its corporate HR policies and procedures as per the local regulations. This covers: terms of employment and working conditions including recruiting, compensation, job change, leave, promotion, discipline, grievance redressal, fairness, non-discrimination, legal compliance etc.



Upon joining the company a copy of the Employee Handbook is provided to all employees, hired directly or through contractors. This handbook includes Envision’s Code of Conduct, HR policies as well as travel policy, safety policy, administration policy, confidentiality and non-compete requirements, IT policy and describes the benefits received by all employees (same for blue and white collar) viz. social insurance and pension, medical insurance, housing allowance, and free lunch in factory cafeteria. Envision does not provide dormitories at its manufacturing facilities.



Envision has a team of about 25 HR professionals across all its facilities, with 15 of them based in the corporate office in Shanghai, which manages the day to do HR related affairs.



- Training:



Extensive induction training is being provided to all staff. As a part of the mandatory induction program, all the new recruits undergo training on various company products, policies, quality and EHS issues. This is followed by on-the-job training and ongoing training depending on business needs, including both in-house and external trainings.



For EHS training Envision’s EHS Management department has developed 14 types of e-learning modules for different job functions. Of these, 2 trainings are mandatory for everyone including the CEO (e.g. on fire evacuation). After completing these modules the employees have to take a test and the online record of these trainings and test results are maintained. The company is currently developing a smartphone-based training platform for the convenience of its employees – especially those working at remote wind farm sites. Special EHS e-learning modules have been developed for the visitors (including contractors/ suppliers) as a pre-requisite for vi
siting the site.



- Freedom of Association, Grievance Mechanism



While Envision does not restrict formation of trade unions, there are no labor unions at Envision facilities. Instead a combined employee committee is active at Jiangyin.



All the regular and contract employees have access to various grievance mechanisms, which are articulated in the employee handbook. Firstly, the employees can raise their grievances through their manager, or the HR department. The grievances can also be raised through the employee committee or labor contractor. Envision has provided an online anonymous email box for all employees as well as a letter box at manufacturing sites to send anonymous complaints or suggestions. All the employee feedback is reviewed by the management and constructive recommendations / suggestions for improvements are recognized through payroll.



- Occupational Health and Safety



The company combines adherence to the national industrial safety standards as well as the Envision corporate standards for workplace health and safety. The company has instituted very high standards of occupational health and safety at its operational facilities as well as for activities on wind farms (erection, commissioning and maintenance).



Envision has set itself a goal of zero lost time injuries (LTI). This was initially applied only to Envision employees, but now is extended to all stakeholders including contractors, vendors, and visitors. As per Envision’s EHS management system, a LTI is defined as one requiring the staff to be away from work for 7 days; while less than that is counted as Recordable Incident (RI). Currently, Envision has set a target of RI <2.2 per 200,000 working hours.



To achieve these goals, Envision focuses on extensive training of all the employees, contractors, customers (i.e. wind farm developers) and their sub-contractors, suppliers and all the visitors to its wind farm sites. Moreover, safety SOPs are strictly enforced and monitored / audited by Envision on an ongoing basis – which are equally applicable for Envision staff and contractors.



Envision’s EHS team has issued “safety passport” to the site staff (own as well as contractors) based on EHS training and satisfactory passing of the tests. Once on site, daily work permits are signed by the site manager, who also prepares a daily safety report - all of which is uploaded in the intranet for monitoring by EHS team. The company has hired 2 interns to check and analyze these records and identify any non-compliances or safety violations.



Envision has installed about 200 cameras across all its sites, with each site having at least one camera. It is a requirement of the SOP to turn on the cameras when site teams are working there.



The company has issued personal protective equipment (PPE) to all the personnel on site (employees, contractors, or visitors) which is labeled with a unique ID. The PPE is checked monthly and unqualified / defective PPE is des
troyed.



In addition to a work permit system, Envision has developed a system to control the access and ensure the safety of visitors to the wind turbines. Anyone visiting the wind turbine site, including suppliers and contractors, need to make an online application, pass 4 safety related e-learning modules and bring their own PPE (or make an online request to borrow from Envision). Visitors are also required to obtain authorization from their own company management as part of this application. Only after this application is approved by Envision’s EHS Director is the visitor’s access pass issued for the site visit.



Based on a very detailed checklist with about 200 questions covering lifting, work at heights, 5S, chemical management, etc.; each site is assigned a safety score based on quarterly and annual performance and reported to the senior management. Envision has recently introduced a policy whereby sites with score less than 85%, are not eligible for corporate awards.



As a result of such an extensive safety management systems, there have been no LTI at the manufacturing facilities in 2013, 2014 and 2015, and the number of RI for producing one wind turbine has decreased significantly.

Envision’s facilities comprise of assembly of turbine components and does not result in any significant air emissions, wastewater discharge or solid/hazardous waste generation.



Water for Envision’s manufacturing facilities is sourced from municipal water supply, and has separated sewers for stormwater and sewage discharge. Sanitary sewage is discharged to Jiangyin sewage treatment plant. Small quantities of solid and hazardous waste from assembly operations (scrap, oil, cotton waste etc.) is sent to the licensed contractors.



Electricity is the main source for energy, and is sourced from national grid. Envision does not have boiler in the facility. Compressed gas in the facility is provided by air compressor.



- Resource Conservation:



At the company facility in Jiangyin, pollution prevention and resource conservation has been an important focus. Accordingly, the buildings are designed to maximize the utilization of natural light and are fitted with energy efficient lighting and solar water heater system.



For Phase I of the Jiangyin facility, Envision has installed rooftop solar photovoltaic cells, in an effort to achieve self-sufficiency of electricity generation and sell the surplus electricity to the grid.



The façade of buildings are designed with LOW-E hollow glass curtain walls, combined with a standard lighting system according to Energy-saving Building Design Standard. Barrow hoist in the facility is controlled by variable frequency system.



- Carbon Footprint:



Envision’s operations require very small quantities of electricity from the grid. As such, the carbon footprint of Envision’s operations is indeed small.



On the other hand, the wind turbines produced and installed by Envision and Envision could generate renewable energy to the tune of 1,851 Gwh by 2020 (based on proposed installed capacity with estimated yield of 25% and availability factor of 22% for 365 days of the year.)

Envision’s existing facility occupies a small area in an established industrial zone and is primarily surrounded by other industrial units. As such, the needs and opportunities for community engagement are rather limited for the nacelle and hub assembly facility. However, Envision extensively engages with its other stakeholders viz. employees, suppliers and contractors especially on safety management as described above.

Envision’s proposed wind farm development and operation will have close interaction with its neighboring communities at all stages – from land purchase, to transportation/erection and also during operation of turbines.

Both the SII and the ESRS will be made available via the World Bank Group’s InfoShop, in the corporate offices of Envision: 8F, Building B 1065 West Zhongshan Road, Changning District, Shanghai, China 200051 and on the Company’s website: envisioncn.com/en/index.aspx

Contact Person: Felix Zhang
Company Name: Envision Energy (Jiangsu) Co Ltd
Address: 8F, Building B. 1065 West Zhongshan Road, Shanghai, China 200051
Email: mailto:felix.xuyu.zhang@envisioncn.com
Phone: +8621 60318000
Facsimile: +8621 60318001

Broad Community Support is not applicable for this project