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
The company purchases land for its MMTs or CFSs through willing buyer-willing seller purchases. All the other warehousing space (required for DELEX operations) is leased within urban areas. The new warehouses/MMTs are also expected to follow the same procedures. Therefore, Performance Standard (PS) 5 Land Acquisition and Involuntary Resettlement is not applicable. No direct primary production of living natural resources is involved in the project and there is no material risk of significant conversion of natural and/or critical habitats and thus PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable. Also, the type of risks and impacts envisaged in 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 include: adequate social and environmental assessment of the impacts of the project; company’s commitment, capacity and systems to manage social, environmental, health and safety aspects of its operations in compliance with legal requirements as well as IFC Performance Standards (PSs) and World Bank Group (WBG) Environment, Health and Safety (EHS) guidelines; assurance of fair, safe and healthy working conditions for workers both during construction of terminals and their operations; traffic, security and construction related impacts on local communities; management of waste, emissions, effluents and management of hazardous cargo, if any, in compliance with legal requirements and WBG EHS guidelines; and compliance with IFC PSs requirements for land acquisition.

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.

Identification of E&S risks and impacts: Considering the kind of operations of the company, no formal environmental and social impact assessment (ESIA) is required for setting up new MMTs/CFSs/warehouses. The company, however, obtains the required permits for construction and operation of its facilities.

Before leasing a new warehouse location for DELEX, the company evaluates the location against its warehouse selection guidelines which include consideration location in industrial areas, adequate parking space and access road. Also, the company ensures that the new premise has the required regulatory permits and approvals. Additional permits as required e.g. registration under the shops and establishment act/rules, fire No Objection Certificate (NOC) are obtained by the company.

The company will implement a corporate checklist on screening of new locations to identify any risks with respect to IFC PSs and legal requirements and preparing a management plan for the same.

Policy and Management Systems: CWC’s CFSs at Red Hills and Madhavaram in Chennai have a quality policy and a quality management system certified as per requirements of ISO 9001. Though the company implements measures to meet national regulatory requirements and is in the process of documenting E&S policy and procedures, currently no documented E&S policy or management system have been developed by the company.

As per ESAP action #2, the company will develop and implement an environmental, health, safety and social management system (ESMS), which is consistent with IFC PSs. Under the ESMS, the company will develop and implement an environmental, health, safety and social (EHSS) policy consistent with the principles of the IFC PSs and national legal requirements and define a set of EHSS requirements including operational control procedures, responsibility allocation and performance parameters, all in accordance with IFC PSs and relevant provisions of applicable WBG EHS guidelines.

The ESMS will cover all the key elements as per PS1, including a policy, process of identification of risks and impacts, management programs and processes, emergency preparedness and response, stakeholder engagement, monitoring and reporting framework and will be implemented at all facilities of the company including MMTs/CFSs/warehouses, DELEX and food park operations. Some of the key procedures/programs in the ESMS (among others) will include: (a) Screening of new projects (either greenfield or brownfield acquisitions) including screening of new warehouse locations to identify any risks with respect to IFC PSs and legal requirements and preparing a management plan for the same; (b) training of employees and contract workers on the operational control procedures defined in the ESMS as relevant to their respective work; (c) occupational, health and safety management at CFSs/MMTs/warehouses covering both construction and operation phases; (d) monitoring, recording, reporting and investigation o
f EHS incidents/accidents/near-misses and implementation of corrective actions; (e) safe operation of lifting equipment (e.g. forklifts, hydra cranes, reach stackers); (f) storage and handling of hazardous cargo in line with the International Maritime Organization’s (IMO) Dangerous Goods Code, applicable legal requirements and IFC PSs; (g) transport safety; (h) provision and maintenance of life and fire safety systems at various facilities; (i) on-site and off-site emergency procedures (including training provision of equipment) e.g. for fire, spills/accidental release of hazardous materials and wastes, transport and/or medical emergencies; (j) contractor management programs to supervise and review their compliance with legal requirements and IFC PSs; (k) resource efficiency and greenhouse gas emissions reduction programs; (l) pollution prevention processes with respect to various environmental requirements during construction and operation including waste management, wastewater treatment and emissions management; (m) monitoring and reporting framework including ongoing review of compliance status of all facilities with respect to ESMS requirements; (n) external communications mechanism; and (o) management review based on inputs from internal and external audits, performance monitoring, incident/accident investigations and ongoing feedback on the efficacy of the operational procedures.

As per ESAP action #2, for the development of the policy and ESMS, CWC will engage a qualified consultant and agree with IFC on terms of reference (ToR) for the consultant. The policy and management systems, including procedures, will be developed (as per the ToR) and implemented by the company within agreed timelines for all its operations including the food park operations. The ToR of the consultant will also include providing support to the company in implementation of the ESMS (at least for a year) and conducting regular (e.g. quarterly) reviews based on a pre-determined plan to review implementation at various sites.

Organization: The Head of HR, Administration and IT is responsible at the corporate level for all environmental and occupational, health and safety (OHS) matters. Each location (CFS/MMT) has a HR and Administration Manager, reporting to both the General Manager of the CFS/MMT as well as Head-HR, Administration and IT, who is responsible for implementation of environmental and OHS procedures at the respective location. In its west region, the company has a dedicated Deputy General Manager – Safety, who is currently responsible for safety at CWC’s CFS operations at Mumbai and the company is planning to expand his role to monitor and review safety provisions at all facilities. At DELEX, the company did not have any safety personnel and has recently hired a corporate level safety manager. Going forward, the abovementioned safety managers will be involved in implementation of various EHSS requirements at all CWC facilities.

The transport safety
and transport related environmental initiatives at DELEX (mainly monitoring and reduction of GHG emissions) is the responsibility of the corporate transport coordination team.

Going forward, to strengthen the E&S organization, as set forth in ESAP action #1, the company will identify an appropriately qualified professional for implementation and monitoring of various E&S management procedures and systems discussed in this document for its entire operations including DELEX and the food park. The said E&S staff will coordinate with various departments to ensure compliance with IFC PSs.

Emergency Preparedness and Response: Based on the observations during site visits and discussions, the Mumbai CFS has a documented emergency response plan. Though the other CFSs at Chennai and DELEX have documented emergency response plans, they have not been fully implemented. The MMT at Hyderabad currently does not have any documented emergency response plan. The visited DELEX warehouse had markings on aisles, the warehouses at other visited MMTs/CFSs did not have any emergency evacuation route markings or exit signages.

As mentioned above, as part of the ESMS development and implementation, the company will develop on-site and off-site emergency procedures e.g. for fire, spills/accidental release of hazardous materials and wastes, transport and/or medical emergencies. The procedures will describe the including training and provision of required equipment at various facilities. Regular trainings and mock drills will be conducted based on these procedures. A sample of such emergency response procedures and training records for few of the facilities will be shared with IFC for review. The required provisions as per the emergency response procedures will be made at all facilities within agreed timelines.

Monitoring & Reporting: The DCs monitor consumption of electricity, diesel and water on a daily basis. Regarding occupational, health and safety (OHS), details of accidents are documented by HR and shared with the DC management and National HR team.

As per ESAP action # 2, the company will develop and implement a monitoring and reporting framework which will include processes on monitoring of certain key indicators (e.g. OHS incidents/accidents and their investigation, EHS training, mock drills, energy consumption and GHG emissions), internal E&S assessments/reviews, and management review at each facility and company level.

The framework will specify minimum key performance indicators (KPIs)/parameters to be monitored, monitoring frequencies for all facilities and type of monitoring and the definition of thresholds that signal the need for corrective actions. The monitoring procedure will also define and require monitoring of defined KPIs/parameters for under construction and operating facilities. Regular monitoring will be conducted for the defined parameters and CWC will ensure corrective actions are taken as necessary based on the results. The EHS perf
ormance of all facilities will be regularly documented in an integrated format as per the defined management system processes and reviewed by the management.

Specifically for construction phase of the MMTs/CFSs/food park facilities, the ESMS will include procedures to ensure that construction contractors are contractually required to comply with CWC’s EHSS policies and performance requirements. Under these procedures, the company will, prior to seeking proposals from construction contractors, detail the EHSS and labor construction phase requirements, which the successful bidder would be expected to adhere to during construction. These EHSS and labor requirements will be included in the relevant specifications and contract documents. Further, the company will develop appropriate monitoring procedures to exercise due oversight during construction and to obtain assurance that the contracted EHSS and labor requirements are met.

The company employs about 4000 people at its various locations, including contract labor. This includes about 1715 employees employed by DELEX across 90 locations (corporate office, branches/PuDOs and warehouses).

HR Policy and Management: The company has an HR policies and procedures manual which has policies on various operational matters e.g. induction, probation and confirmation, insurance, medical expenses, leave, business travel, employee exit, transfer and relocation. DELEX has a separate HR policy book, which has similar operational policies and procedures. As per ESAP action #3, the company will update its HR policy manual/book to make it consistent with IFC PS2 requirements and document and ensure implementation of specific policies on non-discrimination, freedom of association, retrenchment, grievance mechanism, prevention of forced labor and child labor.

Working Conditions and Terms of Employment: CWC has standardized employment conditions included in the written contracts of employment for each employee. The contracts describe the working conditions, terms of employment and benefits provided including probation period, working hours, wage structure, leaves, medical insurance, provident fund, etc. Also, all employees are covered under the mandatory statutory insurance (as applicable based on wage levels) and a personal accident policy. The attendance is recorded through a biometric system. The employees at DELEX are also covered under a medical insurance policy. However, currently improvements are needed in company’s tracking of minimum wages for various states and ensuring compliance with the same. Considering that (a) the company is operating in multiple states, (b) will have significant number of employees, (c) and state-wise wage structure keeps on changing, as per ESAP action #3, the company will develop a procedure to proactively monitor and review the changes in minimum wages and ensure compliance with applicable requirements on an ongoing basis.

Grievance mechanism: CWC HR policies and procedures manual includes a worker grievance procedure as per which the grievances can be raised with immediate supervisor and if not solved can be escalated to the next level of management (typically the General Manager of the facility followed by CEO of the region). In case the grievance is not resolved, a grievance committee will investigate the matter and convey the decision to the aggrieved employee.

DELEX also has a grievance mechanism under which the employees can report their grievances to their immediate manager, followed by the branch management and HR team. In case resolution is not achieved at these levels, the grievances can be forwarded to top management.

Both the CWC/DELEX grievance mechanisms need to be improved to include provisions of anonymous grievance submission and maintenance of adequate documentation on grievances received and processed. Therefore, as set forth in ESAP action #3, the company will upgrade the g
rievance mechanisms in line with PS2 requirements. Also, the company will ensure communication and accessibility of the mechanism to all employees and third party workers.

Freedom of Association: The employees at the company are currently not part of any union. As discussed above, the company will document and implement a policy on Freedom of Association in line with PS2 requirements.

Prevention of Child Labor and Forced Labor: Currently, age proofs are collected for the employees which are maintained on file to prevent use of child labor. As discussed above, the company will document and implement a policy on prevention of child and forced labor in line with PS2 requirements.

Occupational Health and Safety (OHS): Currently the company follows basic safety procedures at its facilities. At the visited MMTs/CFSs, all workers were noted to be working with adequate personal protective equipment (PPE) including safety shoes, helmets and safety vests. Workers involved in handling of steel (coils) and stone also additionally wear gloves. No significant incidents/accidents have been reported at any of the facilities.

At the new MMTs at Panipat and Chennai and CFSs at Chennai, the company has provided fire hydrant system with adequate water storage and fire extinguishers. However, the MMT at Hyderabad does not have a fire hydrant system though the company has plans to install the same. As per ESAP action #4, the company will provide the fire hydrant system at Hyderabad within the agreed timelines.

Also, the company does not have a documented OHS management system or program. Therefore, as mentioned above under PS1, as part of its ESMS development, the company will develop and implement an OHS management program. The key elements of the OHS management program will include: (a) roles and responsibilities for key personnel under the program; (b) safe operating and movement procedures for the mobile equipment (reach stackers, trucks/trailers, forklifts and rakes); (c) risk assessment of and safe working guidelines for key activities at each facility e.g. loading/unloading of containers, movement of materials, maintenance activities, storage of hazardous cargo (if any); (d) emergency preparedness and response (discussed under PS1) including maintenance of first-aid and fire safety provisions; (e) training needs for all employees and contract workers; (e) safe movement of vehicles and people (workers and visitors) within the terminal; (f) work permit systems for dangerous works e.g. work at height, hot work, deep excavation; (g) safe transport training for drivers (both employees and contract workers); (h) handling of dangerous cargo in line with IMO Dangerous Goods Code, applicable legal requirements, IFC PSs and WBG EHS guidelines; (i) construction safety requirements for contractors (discussed under PS1); and (j) monitoring and documentation procedures including accident/incident investigation, safety committees, internal/external safety inspections
, testing and inspection of lifting equipment.

Third party workers: The company employs third party workers for material movement (loading, unloading, stacking), security and housekeeping in its MMTs/CFSs. Also, in many cases, the forklifts and reach stackers are hired on lease and the drivers for these vehicles are third party workers. Typically, the number of contract workers will be around 50 to 60 at the MMT/CFS locations. In addition, 200-250 casual workers are employed on a temporary basis for a few hours when goods are to be unloaded from a train. For the third party workers, the attendance is recorded manually and the company collects wage sheets for these workers (except casual workers) to ensure payment of wages and applicable legal benefits to the third party workers. Casual workers are paid by the contractor for the time they are engaged in.

Similarly, at DELEX, third party workers are employed for material movement (loading, unloading, stacking), security and housekeeping. The in-city delivery vehicles are on lease and the drivers for these vehicles are third party workers. Also, a number of third party vehicles are utilized for inter-city transportation which account for 30 to 35% of company’s total transportation needs among cities. Similar systems are followed at DELEX as well.

However, improvements are needed in the company’s systems as the HR representative of the company is not present at the time of distribution of wages to third party workers. Also, considering the number of locations the company is operating in (including DELEX locations), the company needs to have better monitoring and review of wage payments to its third party workers. Therefore, as per ESAP action #3 and as part of the ESMS development, the company will put in place procedures (including periodic reviews by an external company) on contractor management to supervise and review compliance with legal requirements and IFC PSs for third party workers.

Emissions and Waste management: Electricity is mainly sourced from the public grid at the MMTs/CFSs/warehouses. For back-up, diesel generator (DG) sets are provided. DG sets have integral acoustic enclosure as per legal requirements. Similar infrastructure is also expected for the new MMTs and food park operations. Though a significant impact on ambient air quality is not expected on account of the company’s operations at facility level, the company will implement procedures to ensure that: (a) all vehicles used by the company are properly maintained and their emissions are within national standards; (b) trucks entering its premises have appropriate pollution control certificates; (c) truck dwell time (particularly engine idling time) is minimized; (d) emissions from the DG sets and ambient air quality is regularly tested to ensure compliance with the applicable national standards and WBG EHS guidelines.

Domestic waste/garbage generated at CWC/DELEX facilities is collected by authorized municipal contractors. Minor quantities of hazardous waste generated at these facilities include used oil (from DG sets), batteries and oil containing waste (from vehicle maintenance). The company will upgrade management of hazardous waste in accordance with good industry practices, applicable legal requirements and applicable parts of the WBG General EHS Guidelines. In particular: the company will, as part of the ESMS, implement a program to: (a) segregate and store all hazardous material appropriately under secondary containment; (b) identify all hazardous wastes generated (used oils, lubricants, oil containing wastes etc.) as per host country rules on hazardous waste handling and management; (c) label, segregate and store all hazardous wastes under secondary containment; (d) dispose of hazardous wastes through authorized entities only; and (e) maintain records of all hazardous materials used and wastes disposed of.

Water supply and wastewater: At most of the locations, the source of water is on-site borewells. The borewell water is used mainly for domestic purposes e.g. in toilets and handwash. For drinking, packaged drinking water is purchased. Domestic sewage generated is discharged in the septic tank and soak pits provided on-site. Septic tank sullage is periodically transported and disposed of by authorized municipal contractors.

For the food park operations, the company will provide a wastewater treatment plant to ensure that required level of treatment is provided before discharge to ensure compliance with the applicable national standards and WBG EHS guidelines.

Hazardous materials management: As per the company, no MMTs/CFSs are currently handling any hazardous cargo. During the site visits, one of the CFSs (at Madhavaram) was noted to have 30-40 drums/jerry cans of hazardous chemicals (identified based on the labelling on the containers). Also, old cargo (rejected by customs) was also noted to be stored at the terminal, which the company is e
xpected to dispose of. However, the company does not have adequately documented procedures for storage, handling and disposal (if required) of such hazardous cargo.

The company will therefore, as per ESAP action #2 and associated ESMS development, develop and implement specific procedures for handling of hazardous cargo in line with the requirements of the International Maritime Organization’s (IMO) Dangerous Goods Code, applicable legal requirements, IFC PSs and relevant paragraphs of the WBG EHS guidelines. The key elements of the procedures shall cover (a) establishment of segregated and access-controlled storage areas with the means to collect or contain accidental releases; (b) requesting Dangerous Goods Manifests for hazardous materials whether in transit, loading or unloading, including proper shipping (technical) name, hazard class, United Nations number and packing group; (c) training of personnel in relevant aspects of hazardous cargo management including screening and acceptance of dangerous goods; and (d) emergency response procedures specific to dangerous goods consistent with applicable requirements. Further R the company will construct at its container yards, appropriately located and contained area for placing leaky containers.

Resource efficiency and greenhouse gas (GHG) emissions: Based on available data on electricity and diesel consumption (for vehicles and DG sets), the current GHG emissions footprint of the company has been estimated to be around 8,500 tons CO2 equivalent per annum (tpa CO2 eq). As the company is expected to expand its operations, the additional GHG emissions are expected to be 10,377 tpa CO2 eq.

The company is evaluating opportunities of generating solar power through installation of solar panels on the roof of the warehouses at the MMTs/CFSs.

DELEX is part of Green Freight Asia (GFA), an industry led program and a non-profit organization, formed with the objective of lowering fuel consumption across Asia-Pacific sourced road freight movements, reduce CO2 emissions from these movements and lower shipping costs across the supply chain. As part of the program, the company reports its annual CO2 emissions to GFA. DELEX has worked on design of the roof of the cabin of its vehicles (to improve aerodynamics) and provided guidelines to drivers on maintaining tire pressure in order to reduce CO2 emissions.

The company employs unarmed private security guards at all its facilities through external agencies. The background check for the guards is conducted by the agency before deputing the guards. The company will maintain this documentation on file to ensure easy access. On the job training is provided to security personnel on fire safety, first-aid and their roles and responsibilities.

Typically the MMTs/CFSs are located close to the highways and/or access roads to the ports. For example, the MMT at Hyderabad is located just off the National Highway connecting Hyderabad and Bangalore and is accessible through an industrial area road and private access road of the company. Similarly, the MMT at Panipat is located on National Highway connecting Delhi and Chandigarh and has a private access road. The CFSs at Chennai are located on the State Highways. Based on the observations during the site visit, all CFSs/MMTs have adequate areas for parking internally. For DELEX, the company identifies warehouses typically in industrial areas, which have adequate parking spaces. Therefore, on significant impacts are expected due to movement of vehicles due to company’s operations.

In terms of transport, CWC has about 350 trucks, 65 trailers and 25 REEFER Vehicles. Most of these vehicles are for DELEX operations. Also, as mentioned above, the company also outsources transportation services and hires vehicles on lease. At DELEX, own vehicles serve 65-70% of the requirements, whereas the remaining is outsourced. A typical PuDO has 4-5 leased delivery vehicles.

In its own vehicles, DELEX has installed speed monitors through which the movement of vehicles can be tracked. As per the available information, since its inception, DELEX vehicles have been involved in two accidents where third party fatalities were involved. Between Mach 2014 and September 2015, DELEX vehicles have been involved in six major accidents (three with no damage, three with damage to the vehicles) and 13 minor accidents. Based on an investigation of these accidents, DELEX has implemented corrective actions such as ensuring two drivers for each truck for long haul trips (between cities); drivers are instructed not to drive between 0200 and 0600 hours; vehicles can be loaded in the night but can only drive after 0500 hours; maximum speed limit for vehicles to be 60 km/hour; fire extinguisher and first-aid kit provided in the trucks; and drivers with three years or more experience are recruited. All vehicles are maintained before their annual fitness checks required as per applicable requirements.

However, currently CWC/DELEX do not provide any transport safety training to its own or contracted drivers. Therefore, as per the ESAP and as part of the ESMS development, the company will develop a transport safety program which will include guidelines for drivers on traffic safety to minimize risks to safety of communities from vehicles plying to and from its facilities.

As part of its corporate social responsibility framework, the company plans to provide drinking water facilities to villages and schools located near the existing facilities of the company in Mumbai, Chennai, Indore, Tuticorin, Ahmedabad and Panipat. The company plans to install around 100 such plants over two years. It is in the process of negotiating with the vendors for supply, installation and maintenance of water treatment plants in various locations.
There are no directly affected communities associated with the company’s operations. Currently, except for the reporting of carbon emissions to GFA, the company does not externally communicate any sustainability related information. In terms of disclosure, the publication of the ESRS and ESAP will be company’s first disclosure of E&S information. As set forth in the ESAP action#2 and associated ESMS development, the company will develop and implement an external communications mechanism which will describe company’s procedures to (i) receive and register external communications (including any grievances from the public); (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the ESMS, as appropriate.

Considering the corporate nature of the investment, CWC will disclose this ESRS and the ESAP at the following address:

Continental Warehousing Corporation (Nhava Seva) Ltd.
404, Samarpan Complex, Chakala
Andheri (East),
Mumbai – 400099, India.
Phone: +91 22 61116999

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

Mr. Suresh Periasamy
Continental Warehousing Corporation (Nhava Seva) Ltd.
404, Samarpan Complex, Chakala
Andheri (East),
Mumbai – 400099, India.
Phone: +91 22 61116999
Email: mailto:suresh@cwcnsl.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Identify an appropriately qualified professional for implementation and monitoring of various environmental and social (E&S) management procedures and systems discussed under S. No. 2 for its entire operations including DELEX and food park.	03/31/2016
Engage a qualified consultant (that meets IFC’s requirements) and agree with IFC on terms of reference (ToR) for the consultant for development of a corporate level E&S management system, which covers all the key elements described in the ESRS, and includes (but not be limited to) the following: (i) Environmental, health, safety and social (EHSS) policy consistent with the principles of the IFC PSs and national legal requirements; (ii) Roles and responsibilities and training needs for responsible personnel; (iii) Screening of new projects (either greenfield or brownfield acquisitions) including screening of new warehouse locations to identify any risks with respect to IFC Performance Standards (PSs) and legal requirements and preparing a management plan for the same; (iv) training of employees and contract workers on the operational control procedures defined in the ESMS as relevant to their respective work; (v) occupational, health and safety management at container freight stations (CFSs)/multi-modal cargo handling terminals (MMTs)/warehouses covering both construction and operation phases, and including all key sub-elements described in the ESRS under PS2; (vi) monitoring, recording, reporting and investigation of EHS incidents/accidents/near-misses and implementation of corrective actions; (vii) safe operation of lifting equipment (e.g. forklifts, hydra cranes, reach stackers); (viii) storage and handling of hazardous cargo in line with the International Maritime Organization’s (IMO) Dangerous Goods Code, applicable legal requirements and IFC PSs; (ix) transport safety for own and contracted drivers and vehicles; (x) provision and maintenance of life and fire safety systems at various facilities; (xi) on-site and off-site emergency procedures (including training and provision of equipment) e.g. for fire, spills/accidental release of hazardous materials and wastes, transport and/or medical emergencies; (xii) contractor management programs to supervise and review their compliance with legal requirements and IFC PSs; (xiii) resource efficiency and greenhouse gas emissions reduction programs; (xiv) pollution prevention processes with respect to various environmental requirements during construction and operation including waste management; (xv) Hazardous waste management (xvi) monitoring and reporting framework including ongoing review of compliance status of all facilities with respect to ESMS requirements; (xvii) community grievance mechanism; and (xviii) management review based on inputs from internal and external audits, performance monitoring, incident/accident investigations and ongoing feedback on the efficacy of the operational procedures. The ToR of the consultant will also include providing support to the company in implementation of the ESMS (at least for a year) and conducting regular (e.g. quarterly) reviews based on a pre-determined plan to review implementation at various sites. [Development/documentation of the ESMS by 31st July 2016]	03/31/2016
Implement the ESMS for all operations including DELEX and food park. Share consultant’s progress and review reports on implementation of the ESMS. [As per the frequency defined in the ToR]	01/31/2017
(a) Update the Human Resource (HR) policy manual/book to make it consistent with IFC PS2 requirements and document specific policies on non-discrimination, freedom of association, retrenchment, grievance mechanism, prevention of forced labor and child labor. [by 31st May 2016] (b) Ensure implementation and communication of the new policies and grievance mechanism to all employees and third party workers. [by 31st July 2016] (c) Develop and implement procedures (including periodic reviews by an external company) on contractor management to supervise and review compliance with legal requirements and IFC PSs for third party workers.	08/31/2016
Install the fire hydrant system at the MMT at Hyderabad.	10/31/2016