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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
As there are no physical assets (apart from company’s offices) and company’s operations are mainly based at patient’s homes, the other PSs i.e. IFC Performance Standard (PS) 3 (resource Efficiency and Pollution Prevention), PS4 (Community Health, Safety and Security), PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are thus not applicable.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because key E&S risks and issues related to this project is mainly assurance of fair, safe and healthy working conditions for its employees in compliance with the IFC PS 2.

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 company operations, E&S risks are limited to safety and security of employees while they are placed at patients’ homes and HR related risks and impacts. The company has nursing coordinators, who accompany the nursing attendants on the first day and conduct a risk assessment before placement of the attendant to ensure that the patient’s home is safe for nursing attendant to work.



Going forward, the company plans to lease spaces for hostels for their staff members which would typically be apartments or shared accommodation. As per the ESAP, the company will develop a documented safety and security criteria for leasing such apartments/shared accommodation which would include basic fire safety provisions and security requirements (considering that the staff members residing in such hostels may be females). This criteria should be used for selection of these rented apartments/shared accommodation.



Organizational Capacity: The company has an HR organization headed by GM - HR and is further divided into the functions of Talent Acquisition, Talent Management, HR Employees Services, Business Operations - HR Operations, and Administration and Facilities. In addition to the corporate office, there is HR staff in all regional offices. The corporate office develops the strategy, policies, reviews, etc. which are then implemented at all offices. Also, the local teams work on recruitment, people engagement and training. The company will strengthen and scale up the HR organization by hiring more people in line with the workforce expansion.



Emergency Preparedness and Response: For all its offices, Portea has emergency response plans. Required number of fire extinguishers and other systems are provided as per applicable legal requirements. Regarding medical emergencies at patients’ homes, Portea provides training to its staff to handle the same.



Monitoring & Reporting: Regular reports are submitted to the relevant authorities on HR issues as per applicable legal requirements. The payroll management is outsourced to an external agency and their output is reviewed by the HR department.

The company has a total workforce of 2,300 staff (including approximately 1,900 medical and 400 non-medical staff). Within the medical staff, 1,500 are nurses and nursing attendants. As part of the expansion plans, the workforce is expected to increase significantly in the next few years.



HR Policy and Management: Portea has a documented Human Resource (HR) policies manual which currently, mainly covers operational issues like recruitment, leaves, phones, reimbursements, etc. The company is in the process of preparing a staff handbook. The policies are communicated mainly verbally to the employees and are available in the offices for reference. As per the ESAP, the company will align and document its policies in line with the PS2 requirements and document specific policies on various aspects covered under PS2 including non-discrimination, freedom of association and grievance mechanism. The same will be communicated to the employees e.g. through intranet, displays and/or staff handbook.



Working conditions and terms of employment: Portea provides an appointment letter to all its staff members. However, as per the ESAP, the company will modify the appointment letter format to enhance communication of company’s policies and benefits the staff receives e.g. leaves, payment for extra hours worked, social security contributions, etc.



The Physiotherapists and Doctors typically have short term visits and are paid as per their skill level and experience with incentives on number of visits. The Nursing Attendants are covered under the legal requirements on minimum wage and are thus paid as per applicable wage requirements of each state where they are working. The company has outsourced the payroll management to an external agency. All staff members are paid through bank accounts. Going forward, 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, the company will proactively monitor and review the agency’s output and ensure compliance with applicable requirements on an ongoing basis. The nursing attendants work in patient’s homes on 12 hour or 24 hour shifts. Though at patient’s home, the work is of intermittent nature.

Freedom of association and grievance mechanism: Currently there is no staff union at Portea. However, the company does not restrict formation of employee unions and will document a policy as part of the HR manual on the same.



Portea has a dedicated email address for HR related issues and any other grievances. Staff members can write directly to HR for their grievances or other regular operational issues. However, as many of the staff members may not have access to emails, as part of the ESAP, Portea will align its grievance mechanism with PS requirements in order to make it accessible to all employees and also create awareness among employees about this upgraded mechanism.

The company has formulated and im
plemented sexual harassment prevention policy in line with regulatory requirements. A committee has been formed for investigating any sexual harassment related complaints consisting of all female members drawn from different departments of the company and a male external member. Awareness is created about the processes through displays in the offices and emails. The company is partnering with an external agency for online training on prevention of sexual harassment.

Prevention of child labor and forced and bonded labor: No instances of child, forced and bonded labor were observed. The company obtains age proofs of all the staff members before they are employed and keeps them as per of the personnel files.



Occupational Health and Safety (OHS): The employees normally use public transport for reaching patient’s homes. Considering the operations are at home, there are not significant OHS risks or impacts.



Third party workers: Except the consultant physiotherapists and doctors, all the staff is on company pay rolls and no third party workers are employed by the company.

Portea has contributed financially for supporting the victims of natural calamities (e.g. floods in Jammu and Kashmir and Earthquake in Nepal) and has also supported non-governmental organization in Chennai working on elder care. The company also has plans to initiate community work in schools and hospitals. In terms of disclosure, the publication of the ESRS and ESAP will be company’s first disclosure of E&S information.

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

Health Vista India Private Limited
No. 69/B, 1ST CROSS, 1ST STAGE
DOMLUR LAYOUT
BANGALORE – 560071, Karnataka
INDIA.
080 3355 4554

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

Meena Ganesh
Chief Executive Officer
Health Vista India Private Limited
No. 69/B, 1ST CROSS, 1ST STAGE
DOMLUR LAYOUT
BANGALORE – 560071, Karnataka
INDIA.
080 3355 4554

Broad Community Support is not applicable for this project

ESIP Portea(37150) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Align and document Human Resource (HR) policies in line with the PS2 requirements and document specific policies on various aspects covered under PS2 including non-discrimination, freedom of association and grievance mechanism. [to be completed by 31st July 2015] The same shall be communicated to the employees e.g. through intranet, displays and/or staff handbook.	30-Sep-2015	Completed	Completed	9/30/2015
Develop a documented safety and security criteria for leasing apartments/shared accommodation including basic fire safety provisions and security requirements. This criteria should be used for selection of these rented apartments/shared accommodation.	30-Sep-2015	Completed	Completed	6/13/2017