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 existing facilities and warehouses are located in leased spaces. For the proposed facility also, the company is planning to lease space. Therefore, no expropriation of land is envisaged for the project and no physical or economic displacement has been/is expected to be caused by the company’s activities; consequently, IFC Performance Standard (PS) 5 (Land Acquisition and Involuntary Resettlement) is not applicable.

The company’s operations are and will typically be located in urban or sub-urban areas and, therefore, the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable. Going forward, as part of the management systems and procedures (discussed below under PS1), Lenskart will screen future projects with respect to IFC PSs requirements.

Key E&S risks and issues related to this Category B Project include: adequate social and environmental assessment of the project impacts; the company’s capacity and systems to manage social, environmental, health and safety aspects of its existing and proposed operations in compliance with legal requirements as well as IFC Performance Standards (PSs) and the World Bank Group (WBG) Environment, Health and Safety (EHS) Guidelines; assurance of fair, safe and healthy working conditions during both construction and operation; management of wastes, emissions and effluents; life and fire safety (L&FS) and emergency response for the company’s facilities and stores.

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 Assessment and Management System: Considering the company’s operations, Lenskart is not required to undertake a formal Environmental and Social Impact Assessment (ESIA) study and seek prior environmental clearance for establishing its stores or facilities. The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable E&S regulatory permits and requirements. The company has obtained basic permits and is in the process of obtaining the remaining E&S permits for its facilities. Additionally, the company is finalizing locations for its proposed facility and the company will shift operations to the proposed facility as well as obtain all the required operating permits. Also, for the proposed facility, the company will evaluate the operations with respect to IFC PSs and legal requirements and prepare management programs accordingly for the same.



Policy and management programs: Currently the company does not have a documented EHS policy or management system. As set forth in the ESAP, the company will document an EHS policy. Considering the operations which are mostly automated (e.g. lens manufacturing as well as cutting) or low risk (e.g. receiving, loading/unloading, assembly) and no significant generation of emissions, effluent or waste, the environmental and occupational, health and safety (OHS) risks are limited. However, as set forth in the ESAP, to strengthen its EHS management, the company will develop basic procedures on: (a) life and fire safety for manufacturing facilities (including provision and maintenance of fire safety systems, fire safety training); (b) emergency preparedness and response (including emergency response plans, regular training and mock drills); (c) OHS management (including general safety guidelines, use of appropriate personal protective equipment (PPE), injury prevention due to slips, trips and falls and lifting/handling of materials, storage and handling guidelines for chemicals, first-aid, regular OHS training, and accident/incident/injury reporting and investigation); (; (d) EHS monitoring (including testing of effluents, emissions from diesel generator sets, ambient air quality and noise, monitoring of EHS training, safety accidents and incidents). The procedures will be re-evaluated and modified as required once the proposed facility is being commissioned.



Organizational capacity and competency: The Vice President – Operations is responsible for EHS management at the manufacturing facilities. Currently the company does not have a specific EHS manager. As per the ESAP, the company shall identify an appropriately qualified professional to implement and monitor EHS procedures discussed above.



Emergency Preparedness and Response: The facilities were noted to be provided with a fire alarm system and fire extinguishers, which were adequately maintained. During the site visit, areas of improvements were noted in marki
ng of emergency evacuation routes and exits. Further, based on the observations during the site visits and discussions, documented emergency response plans have currently not been developed at the facilities. Also, no training/mock drills are reported to be conducted.



As per the ESAP, the company will provide adequate markings on emergency evacuation routes and exits. Further, the company will develop and implement emergency response plans for each of its facilities and ensure regular training and mock drills. Such emergency response plans and training records will be shared with IFC for review.



Monitoring & Reporting: As discussed above and as per the ESAP, the company will develop a procedure on EHS monitoring which will specify minimum EHS parameters (including energy consumption, EHS trainings conducted, health and safety accidents/incidents, effluent and emission testing etc.) to be monitored, monitoring frequencies and the definition of thresholds that signal the need for corrective actions. Regular monitoring will be conducted for the defined parameters as per the procedure and the company will ensure corrective actions are taken as necessary based on the results.

The company has a total workforce of about 350 employees which are employed in the head office, warehouse and operations.



HR Policies and Procedures, Working Conditions and Terms of Employment: The company has an employee handbook that describes company’s policies on various operational aspects including leave, separation, increments and promotions, travel, claims, medical insurance, disciplinary procedure etc. as well as company’s vision, mission, values and code of conduct. The policy is communicated to all employees during their induction and is accessible on company’s HR management system (HRMS). The company is in the process of revising its employee handbook. As per the ESAP, the company will strengthen its employee handbook by documenting and implementing of specific policies on non-discrimination, freedom of association, retrenchment, prevention of forced labor and child labor and grievance mechanism in line with PS2 requirements.



The new policies and procedures will be communicated to all employees through various means, including HRMS, displays, employee handbook and awareness sessions.



The company has standardized employment conditions included in the written contracts of employment for each employee. At its facilities, company has workers hired on its rolls as well as workers who have been hired on fixed term contracts (directly by the company). The company is evaluating the fixed term contract set-up and planning to either move these workers to permanent employees OR hire the workers through a third party contractor.



Freedom of Association: Currently there is no workers unions at the company’s facilities. As part of its employee handbook, the company will document a specific policy on freedom of association.



Non-discrimination and Equal Opportunity: As mentioned above, as part of its employee handbook, the company will document a specific policy on non-discrimination.



Grievance Mechanism: The company has a policy on prevention of sexual harassment at workplace, which described the process of addressing sexual harassment related complaints. However, currently the company does not have a documented grievance handling mechanism. As per the ESAP and as part of the employee handbook, the company will develop and implement a documented workers grievance mechanism which meets IFC PS2 requirements with a consistent and well-structured system of documenting grievances received and processed. The company will also create awareness among employees regarding the grievance mechanism.



Protecting the Workforce: The company does not employ anyone below 18 years of age. Based on observations during the appraisal, no instances of child labor or forced or bonded labor were noted.



Occupational, Health and Safety (OHS): Considering the operations which are mostly automated (e.g. lens manufacturing as well as cutting) or low risk (e.g. receiving, loading/unloading, assembly), the OHS risks are limited to fire safety and e
mergency response (covered above) and chemical safety (for lens manufacturing). The company provides first-aid boxes in its facilities. Based on discussion with the company, no incidents and accidents have taken place at the company’s facilities.



To strengthen OHS management for its operations, as discussed under PS1 above, as per the ESAP, the company will develop a basic OHS management program which will at least cover general safety guidelines, use of appropriate personal protective equipment (PPE), injury prevention (due to slips, trips and falls and lifting/handling of materials), storage and handling guidelines for chemicals, first-aid, regular OHS training, and accident/incident/injury reporting and investigation.



Workers engaged by third parties: Third party workers are employed at the facilities for security. As mentioned above, the company may hire workers through a third party (due to restructuring of the fixed term contract system). As part of its employee handbook, Lenskart will have a specific procedure to ensure that the contractors are complying with the legal requirements on wages and benefits.

Emissions and waste management: Electricity is mainly sourced from the public grid at the facilities as well as stores. For back-up, diesel generator (DG) sets (100 and 160 kVA capacities) are provided at both the facilities. As part of the EHS monitoring procedure, the company will conduct regular monitoring of emissions from the DG sets.



The operations at the Assembly facility do not generate any process effluent. As the new lens manufacturing line at the laboratory facility is expected to generate some effluent, the company has installed an effluent treatment plant (ETP). Additionally both the facilities are members of the Okhla common effluent treatment plant (CETP). As part of the EHS monitoring procedure, the company will conduct regular testing of quality of effluent discharge from the ETP to ensure compliance with the applicable national standards.



The domestic sewage generated from the facilities is discharged in the municipal sewage system.



Solid waste generated from the facility operations mainly include paper and packaging waste, glass waste and empty containers etc. The waste materials are sold to external agencies.



Greenhouse gas (GHG) emissions: The GHG emissions footprint of the project is expected to be less than 25000 tons CO2 equivalent per annum (tpa CO2 eq).

Security Personnel: The company employs unarmed private security guards at its facilities.

As part of its corporate social responsibility activities, Lenskart has taken a number of initiatives including (a) donating eye wear (about 1500 frames per month) to a non-profit organization which conducts free eye examinations and surgeries in villages in Maharashtra; (b) providing a platform to the Third Gender to pledged their eyes through its “Eye for An Eye” campaign where the Eye Bank Association of India (EBAI) was invited and 16,000 pledges were handed over to EBAI with a promise of 200,000 more; and (c) hire deaf and mute people in roles such as packaging, quality check and electrician.

In terms of disclosure of E&S information, the publication of the ESRS and ESAP will be company’s first disclosure of such information. As per the ESAP and as part of development of E&S procedures, Lenskart 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, Lenskart will disclose this ESRS and the ESAP at the following address:

Lenskart Solutions Private Limited
W-123, Greater Kailash -2
New Delhi – 110048.

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

Peyush Bansal
Chief Executive Officer
Lenskart Solutions Private Limited
W-123, Greater Kailash -2
New Delhi – 110048.

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Identify an appropriately qualified professional at the company to implement and monitor Environmental and Social Management procedures discussed under S. No. 2.	04/30/2016
Develop and implement an environmental, health and safety (EHS) policy as well as basic procedures on: (a) Life and fire safety for manufacturing facilities (including provision and maintenance of fire safety systems, fire safety training); (b) Occupational, health and safety OHS management (including general safety guidelines, use of appropriate personal protective equipment (PPE), injury prevention due to slips, trips and falls and lifting/handling of materials, storage and handling guidelines for chemicals, first-aid, regular OHS training, and accident/incident/injury reporting and investigation); (c) EHS monitoring (including testing of effluents, emissions from diesel generator sets, ambient air quality and noise, monitoring of EHS training, safety accidents and incidents); and (d) Community grievance mechanism including a process to receive and respond to grievances from the neighbouring communities.	07/31/2016
(a) Provide adequate markings on emergency evacuation routes and exits at both facilities. [Timeline: 30th April 2016] (b) Develop emergency response plans for each of its facilities. [Timeline: 31st March 2016] (c) Implement the emergency response plans and ensure regular training and mock drills.	07/31/2016
(a) Strengthen the employee handbook by documenting and implementing specific policies on non-discrimination, freedom of association, retrenchment, prevention of forced labor and child labor, grievance mechanism and contract workers management in line with PS2 requirements. [Timeline: 30th April 2016] (b) Communicate new policies and procedures to all employees through various means, including HR management system (HRMS), displays, employee handbook and awareness sessions.	07/31/2016