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 the proposed investment is for an equity infusion to support the expansion plans for the company, the potential risks or impacts concern undefined assets and use of proceeds, the processes of how the company will address Performance Standards 3 through 8 is described within the detailed PS1 narrative below and represents the framework (hence its presentation under PS1) that will be applied by the company at corporate level as new assets and projects are developed under the expansion plan. Screening and assessment of issues identified in future projects against PSs requirements will be completed though through the company’s E&S management system, as discussed under PS1.

The proposed equity investment is a Category A project due to the diversity of E&S risks and impacts associated with planning, development and operations of large wind and solar projects mainly on account of land, biodiversity, noise and community related issues. While some of the individual projects that the company has or will develop/acquire may have limited risks and impacts, at this stage the residual risks and impacts associated with future pipeline (unknown/identified at this stage) of projects are not clearly known. HFE’s portfolio of existing/operating projects has residual issues as identified in the independent third party E&S due diligence that would need to be addressed in line with the agreed Environment and Social Action Plan (ESAP). These and other impacts on account of future planned projects will need to be carefully managed in accordance with Performance Standard’s requirements.

Update related to additional investment under the COVID-19 response facility:

E&S Performance: The Company has materially implemented the E&S Action Plan for the existing investment and has been regularly reporting to IFC through annual monitoring reports and regular updates. One of the pending actions from the previous E&S Action Plan was related to relocation of some households due to safety reasons and implementation of noise and shadow flicker mitigation at one of Company’s wind project. The Company has committed to complete this implementation by August 2020. Based on IFC’s supervision visits and review of information shared by the Company, the E&S performance has been satisfactory till date.

For review of the New Project, IFC relied on observations during the supervision visits (in December 2019) and updates from the Company on COVID-19 impacts and measures. As there is no change in the footprint, no separate visits were required. 

New E&S Risks: As all assets of the Company are already covered and supervised as part of the existing investment, the use of proceeds of the COVID-19 response facility is only for refinancing and no new project is expected to be constructed with proceeds of this loan, there will no new additional E&S risks due to this New Project. The agreement of the new investment will include similar requirement as previous agreement on compliance with IFC Performance Standards.

Response to COVID-19 Pandemic: As generation of power is classified under essential services under the Government of India directives, Company’s plants have been in operation throughout with enforcement of protective safeguards for COVID-19. Only construction activity for new projects was suspended. No retrenchment of workers has been undertaken by the Company (for both permanent and contract workforce). The Company has been ensuring regular supplies of essentials in its labor camp and guest houses. There has been no health impact due to COVID-19 on the workforce. The Company has developed procedures on safety and health of the workforce, which is strictly implemented and includes use of personal protective equipment, temperature checks, social distancing (e.g. in meetings, buses provided for employee transport), disinfection facilities, regular disinfection.

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.

HFE has in place a set of policies for management of Health, Safety and Environment (HSE), Corporate Social Responsibility (CSR), Human Resource (HR) aspects linked to its operations. These policies govern the scope of HSE and HR management at different assets and operations of the company. The company has also in place an organizational structure to manage and implement the environmental and social risks linked to its operations. The EHS organizational structure currently has two qualified environment and safety personnel to assess the risks and implement the mitigation measures. Apart from this the company has a HR Department with qualified and dedicated personnel to look after and manage labor and working relations, engagement and welfare aspects of its employees along with CSR activities. The EHS and HR organizational set up is based at corporate level and supported by site level personnel.



As a part of its operational procedure, the company a) undertakes an environment and social impact assessment (ESIA) for all its projects; b) incorporates HSE clauses in its EPC and O&M contracts; c) reviews the Health and Safety (H&S) performance of the different under-construction and operational assets on a periodic basis; d) undertakes internal supervision and audits on a periodic basis to assess risks and compliance to statutory requirements; and e) undertakes engagement activities and community development programs at its different project sites/locations.



The third party ESDDs undertaken for all operating wind and solar projects have assessed the legacy risks and current impacts arising on account of operations of these projects. Key gaps in the current E&S management practices of the company/assets include a) a robust identification and assessment of risk and impacts in the ESIA (for wind projects) especially those linked to biodiversity, noise (including cumulative noise), shadow flicker and assessment of community safety risks associated with blade throw and turbine fall (and the lack of consideration for maintenance of minimum set back distance from the Wind Turbine Generator (WTGs); b) deficiencies in labor and contractor management practices (especially at construction sites) linked to management of workers’ accommodation camps, working hours/overtime, workplace environment and facilities and grievance management; c) management of safety aspects especially linked to working at height and confined spaces; and d) overall implementation of E&S management plans emerging out of the ESIAs. The operational phase gaps in current E&S approach practices are mainly linked to stakeholder engagement, grievance management and monitoring impacts on account of noise, shadow flicker and avifauna impacts. Asset specific E&S action plans have been developed as an outcome of the ESDDs. HFE has committed to implementing these actions plans within a time bound manner (ESAP Action 1 #).



Key environmental impacts associated with HFE’s solar and wind projec
ts typically include; a) temporary impacts on ambient noise and air quality especially during construction linked to site preparation activities (foundation and road excavation, leveling, land clearing) and transportation; b) safety risks, noise and shadow flicker impacts on nearby sensitive receptors (for wind projects); c) management of construction waste (packaging and crating material, broken solar panels, construction debris etc.) and ensuring there safe storage and disposal; d) impacts associated with land take; and e) water usage and waste water discharge.



IFC reviewed the ESIA for a 100 MW project (located in Dhar, Madhya Pradesh and operational since March 2016). The study has identified risks and impacts of 13 WTGs, associated with noise, shadow flicker, blade throw and turbine fall on approximately 180-200 houses and some public institutions and government owned buildings like school, Anganwadi (kids care center) and panchayat house) located within the setback distance of about 220 meters (1.5 times the turbine height (tower + rotor radius) as specified in the World Bank EHS Guidelines for Wind Energy projects). The project facilities are located on government lands, most of which inhabited by scheduled tribes. These tribal households are mostly native to the region and have been living/using these lands for residential and agricultural (sustenance agriculture) purposes. Consultations with these groups suggest that they don’t enjoy customary or traditional rights to these lands and are predominantly informal settlers on government lands. Most of these habitations/houses located within the setback distance have existed prior to the setting up of these turbines.



To mitigate the risks and impacts on these houses/people, the company will offer/attempt to relocate households living within a distance of 150 meters from these 13 WTGs. To this effect, the company will develop and implement a relocation/resettlement plan (including budget and timelines) with the objective to relocate as many people/households as possible within the radius of 150 meters. The plan will be consistent with the relevant and applicable requirements of PS 5. It will be implemented by the company and monitored through a third party on a bi-annual basis (ESAP Action #3). A framework underlining the principles governing these relocations will be developed in consultation with the affected households. The company will undertake culturally suitable and appropriate communication programme to ensure disclosure/dissemination of information to all households and tribal groups in line with the processes laid out in the ICP (informed consultation and participation).



For turbine locations where relocation of all houses is not feasible, the company will undertake a Quantitative Risk Assessment (QRA) to assess the level of safety risks (ESAP Action #3). For turbines locations where the risk is assessed to be higher than As Low As Reasonably Practicable (ALARP), the com
pany will undertake measures with the objective to mitigate the risks so as to bring the risk levels down to ALARP. These measures will consist of a number of options as suggested by third party appointed to carry out QRA, based on the risk levels quantified, including relocation of the turbines relocation of structures/people, and other measures to minimize the safety risks. These would include (but not be limited to) strengthening of foundations/hub, enhanced monitoring/inspection, and on-going communication among other measures. The decision tree for the selection of the mitigation measures and the outcome of the risk assessment (pre and post-mitigation) will be documented.



In terms of noise levels within the setback distance of 220 m, the incremental noise levels in daytime are within the WBG EHS guideline limit of 3 dB (A); however, the total noise levels are slightly more than the ambient noise standards. For the night time, the incremental noise levels are more than 3dB (A) as well as the noise levels are exceeding the ambient noise standards. For people remaining within the setback distance of 220 meters, the company will ensure implementation of mitigation measures for noise (including installation of noise barriers, double glazing of windows and additional roof coverage to achieve the guideline limit or ambient noise standards in the households, whichever is lower) and shadow flicker impacts (including curtains and relocation/covering of windows) . The company will communicate, to all stakeholders, the risks of living under the turbines. This communication will be an ongoing process and will be documented by the company.



HFE has, with the help of an external consultant, developed an Environment and Social Management Framework (ESMF) at a corporate level to manage E&S impacts linked to its operations. This ESMF would, going forward, become the basis for undertaking site/asset level impact assessment and developing/implementing necessary E&S measures to manage and mitigate impacts linked to the company/assets operations (ESAP Action #2). The ESMF builds upon the existing E&S procedures and practices of the company, suggests additional measures/actions and defines new procedures for planning, developing and operating solar and wind projects of the company going forward. These include: a) strengthening the E&S screening process with a “Go/No-Go” decision at the planning/decision making stage of the project based on ground assessment of risks/sensitivities; b) committing to establishing and maintaining a set-back area/distance in accordance with WBG EHS guidelines for Wind Energy projects (for all new projects where construction activities are yet to commence); c) defining the terms of reference (ToR) for a robust ESIA; d) proposing a set of standard operating procedures for both construction and operation phase, including labor and stakeholder management, grievance handling, debris management, accident/incident reporting, waste man
agement, emergency response, chance find procedure, ongoing monitoring of noise/shadow flicker and avifauna impacts; e) strengthening existing E&S organization structure with additional/qualified resources (ESAP Action #2); f) strengthening contractor oversight mechanisms, especially during construction phase, g) proposing a set of internal systems/protocols for internal monitoring/reporting and documentation on E&S aspects of company’s operations and h) undertaking E&S due diligence and agreeing on a timeline for closure of E&S gaps to meet the PSs (in case of acquisition projects).



For all new projects, HFE will develop project specific management and monitoring plans and will: a) monitor noise and ambient air quality on a periodic basis; b) ensure implementation of mitigation measures in line with the ESIA; c) ensure disposal of waste to registered vendors and d) ensure that water is sourced from authorized vendors and ensure extraction/use of water from water bodies with necessary permissions from regulatory authorities. The company will also ensure that domestic wastewater during construction and O&M phases will be disposed of through septic tanks and soak pits and there will be no discharge of waste water to any surface water body. During rainy periods, appropriate mitigation measures to minimize erosion and water pollution will be implemented.



HFE projects are not expected to result in significant community safety and security risks (other than those outlined above). The equipment, plants and infrastructure meet good industry practice specifications. The sites are located in a low/moderate seismic hazard zone and natural hazards are taken into account in the design of foundations. The sites are generally not located on any air traffic route and turbines are not proposed within any airport obstacle limitation area. Impacts on account of labor influx and construction phase traffic will be mitigated in line with the ESIA/ESMF requirements. The company ensures that all transformers are fenced and cables insulated to avoid any electrical hazards. HFE allows grazing and agricultural activities in most part of its sites during operations for wind energy projects. Access to agricultural fields, villages, communities and their networks are not disrupted/hindered.



HFE employs (through contractors) unarmed private security personnel during project construction and operation. These personnel are mostly engaged through an outsourced and authorized security agency. Consistent with PS 4, HFE/ HFE’s contractor will require the security agency to implement procedures to ensure that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of abusive behavior; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate discipli
nary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel (ESAP Action #7). Contractor oversight procedures of the company will ensure compliance to the aforesaid requirements.



HFE will ensure that its projects are not located in/close or adjacent to any conservation areas/protected areas/World Heritage sites or Eco-sensitive Zones. The E&S screening process defined in the ESMF will be used to screen/decide upon projects located near any such conservation areas. The ESIA for the different projects will be undertaken in line with the ToR laid out in the ESMF including assessment of impacts on biodiversity and monitoring protocols for assessment of avifauna impacts associated with wind farm developments. These would include but not be limited to habitat assessment, collision risk, identification of migratory path/pattern and other ecosystem services that support the presence of birds/bats in the project area of influence. HFE will decide upon the location/siting of turbines and implementation of relevant mitigation measures based on the outcome of the ESIA and upon assessment of impacts associated with any avifauna. The company will, for its operating projects, undertake monitoring activities/program to assess any impacts on avifauna (ESAP Action #5). Should the monitoring activities demonstrate significant activity or/and bird/bat strikes, HFE will consider implementing measures, in consultation with recognized bird/bat species specialists, to address the impacts, including, if required, a targeted shutdown (curtailment) protocol, enhanced collision monitoring program or other good international industry practice measures listed in the WBG EHS Guidelines for Wind Energy projects.



HFE will, going forward, comply with the requirements of the IFC Performance Standards 2012 and will align its practices to the relevant WBG EHS Guidelines as applicable to its project and operations by implementing the mitigation, monitoring and management measures outlined in the ESMF and the ESAP. HFE will, as a part of its own oversight procedure, undertake periodic monitoring/review and reporting of E&S performance of the different projects to the management and investors. The company will also upon the written request of investor, conduct a) third party audit of high risks projects especially during construction phase; and b) annual third party audit to assess implementation of the E&S management systems and the agreed ESAP (ESAP Action #6).

The company employs about 125 employees at its corporate office and various locations. The company has documented HR policies and procedures on various operational matters e.g. leave, travel, reimbursement, insurance and medical claims, separation etc. The policies are available in a common folder for corporate office staff and communicated to all employees during the induction. Within the HR policies, the company has a code of conduct which includes basic responsibilities of staff on quality and EHS. All employees sign and acknowledge receipt of the code of conduct. Any change in the policies is communicated through circulars/notices.



HFE will undertake a review of HR policies (ESAP Action #4) and procedures and strengthen and upgrade them to make them consistent with PS2 requirements. This will include (but not be limited to) policies and procedures on: (a) non-discrimination and equal opportunity; (b) contract labor management; (c) freedom of association and collective bargaining; and (d) retrenchment. The company’s new HR Policies and procedures will be made available/accessible to all employees and communicated at the time of employee induction. The company has zero tolerance for child labor and as an operational practice collects age proofs of all employees including contract workers. During the visits to company’s project sites, no instances of child or forced labor were noted.



Since December 2015 HFE has developed a grievance redressal procedure which formalizes how grievances can be raised with reporting manager and, if not solved, can be escalated to HR. A corporate grievance committee has been established and, in case a grievance is not resolved, the committee would investigate the matter and convey the decision to the aggrieved employee. Finally, if the grievance committee is also not able to decide, the Chief Executive Officer and/or Managing Director will make the final decision. For reporting of grievances, the employees can use email or grievance register available at each company’s site. HR ensures confidentiality of employee raising the grievance.



The company has also formulated and implemented a prevention of sexual harassment policy in line with regulatory requirements. As per the policy, the company has constituted internal complaints committee (with majority of female members and external representation) in each region to handle sexual harassment related complaints.

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.

As discussed under PS1, the company has a documented OHS policy and has recently (in April 2016) developed an EHS manual. The EHS manual describes the roles and responsibilities of site engineers and safety officers (which are generally the HFE employees on-site) and covers basic OHS SOPs on formation of EHS committee, incident reporting and investigation, work
permit system, dangerous works (for example: hot work, working at height, excavation and foundation work, erection of tower and overhead lines), and emergency response.

Typically, HFE develops the projects on either on turnkey model or on self-development model. Presently most of HFE’s existing projects have been developed under turnkey model by reputed contractors. In such cases, contractors have their own OHS policies and procedures, which are reviewed by HFE before signing of the contract to ensure that they adequately cover the expected risks of the project and are aligned with the HFE policies. Contractors are required to deploy their EHS officers on-site to ensure implementation of the OHS policies and procedures both during construction and operation phases of the project. As contractors outsource a number of activities (e.g. civil, erection, electrical) to sub-contractors, they are responsible to ensure implementation of OHS procedures for their sub-contractors. HFE’s site and EHS teams conduct regular inspections of all under construction and operational projects to ensure compliance with its policies and procedures.

HFE has been including basic EHS clauses in the contracts signed with these contractors which have been further strengthened recently, and which HFE plans to roll out for their new projects. The clauses clearly require the contractor to follow HFE’s EHS policies and procedures (even if the contractor has its own policies) and analyze and bridge discrepancies, if any. The contractors are required to ensure compliance by their sub-contractors, comply with all legal requirements, have required EHS organization in place, coordinate with HFE’s site and EHS teams, have EHS committee on-site and report on identified leading and lagging indicators at mentioned frequencies. Further, the evaluation of performance of contractors and provision of penalties in case of non-compliance are included in the contract clauses.

The ESDD reports for operational projects concluded that there were limited OHS concerns. However, IFC observed that the quality of construction camp’s accommodations for workers could be improved further in terms of providing more space for each worker, better sleeping arrangements, housekeeping and through improved water and sanitation arrangements.

HFE’s monitoring and review processes need improvements to ensure contractors’ compliance with the applicable statutory requirements. HFE will ensure that as part of the contractor oversight procedures, the company will review the contractors’ HR policies and procedures and communicate to them the applicable provisions of its own HR policy and PS2 requirements. Also, the company will document specific guidelines for worker’s accommodation in construction camps which are reasonably consistent with the relevant IFC guidance note and with Building and Other Construction (Regulation of Employment and Conditions of Service) Act, 1996, including available living conditions
with basic amenities and electricity; potable water; mess facilities for food; where workers desire self-cooking, provision of fuel and arrangement for cooking; provision of toilets and bath including separate toilets and baths for women; appropriate sewage disposal facilities; and primary medical care for all workers engaged at site including protection against heat/cold and disease carrying animals (e.g. mosquitos). Further, the company will put in place detailed requirements including audit procedures to verify that: contractors comply with applicable statutory requirements, including those on wages and benefits; worker accommodation is consistent with agreed guidelines; workers have access to an appropriate grievance mechanism; and migrant workers are engaged on substantially equivalent terms as non-migrant workers performing the same work, all in accordance with PS2 provisions (ESAP Action #4). The company will provide training and capacity building support to the contractors to understand and meet the aforesaid requirements. The contract labor management process developed as part of the ESMF will be implemented by the company.

HFE projects are located in different states of the country. HFE undertakes stakeholder engagement activities as a part of a) the ESIA process and b) its ongoing engagement program for planning and implementing community development activities. As a part of the ESIA process, consultations are undertaken with different stakeholder groups including village representatives, land owners, women’s groups, opinion leaders of the affected communities, and affected community’s members. These consultations focus on understanding community/stakeholder perceptions around impacts and benefits/expectations from the project. Through the consultations, the company collects expressions of support or opposition to the project in general and community’s opinion on fairness of the process (especially relevant to land acquisition) in particular. A review of the stakeholder engagement process undertaken for company’s projects suggests that acquisition of privately owned land was mostly done on a willing-buyer, willing-seller basis and that the rates of compensation offered were higher than the prevailing rates for land in the project’s area. It also suggests that the process adopted for land purchase was transparent and participatory and affected communities/landowners were by and large aware of the process. Key concerns and expectations in these stakeholder meetings have been reported around a) increased local employment and contractual benefits, b) infrastructure development of villages (including roads, health care and education facilities) and c) better management of traffic. Meetings with village representatives, community elders, land/revenue officials and some impacted households supported IFC observations.
HFE’s corporate social responsibility activities include undertaking/supporting community development activities focusing on areas of health, education, water and sanitation, rural infrastructure and livelihood support. These programmes are identified by the CSR team in conjunction with the project/site personnel and delivered through local NGOs. Most of these programmes are based on identified community needs and are often targeted towards specific communities and groups (e.g., women and children).
Although engagement with communities appears to be consistently implemented, going forward, the company will undertake its stakeholder engagement activities in a structured and ongoing manner (ESAP Action #6). Each of HFE’s projects will develop and implement stakeholder engagement and grievance redress activities in line with the ESMF. These will include (but not be limited to); a) disclosure of the findings of the ESIA (and the ESMP) to the community/stakeholders, (b) seeking and incorporating their additional feedback/inputs; and c) engaging with the communities, panchayat (village council) and local administration on an ongoing basis to collect, analyze and, as needed, address all complaints/grievances/concerns of the stakeholder and to plan and implement community development activities. Specific to the Dhar project, HFE will undertake development activities directly targeted towards benefiting the affected tribal groups/households. In planning and implementing these activities, HFE will, adopt a gender inclusive approach.
As part of the grievance redress plan/procedure, all HFE’s projects will constitute a grievance redress committee prior to start of construction activity. The committee will comprise of company/panchayat representatives and will look into the community/stakeholder concerns and grievances (ESAP Action #6). Information about the grievance redress mechanism will be shared with the affected communities through locally appropriate communication tools. Community members will be encouraged to approach this committee with their concerns and suggestions. Minutes and proceedings of the meetings of this committee will be documented and shared with relevant stakeholders.

The company will locally disclose the social and environmental information at the following locations:

Name: Satish Chaturvedi
Address: Clean Wind Power (Ratlam) Pvt Ltd
Village: Khiledi, Tehsil: Badnawar
District: Dhar
Any queries and/or comments about the project may be directed to:
Mr. Satish Chaturvedi
Designation: Manager HSE
Address: Hero Future Energies Pvt Ltd, 202, Okhla-Phase III, New Delhi-110020, mailto:info@herofutureenergies.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
For the 100 MW Dhar project in Madhya Pradesh: • Offer to relocate people/households living within the setback area/distance of 150 meters. Implement the relocation plan developed by the third party consultant; • For WTG locations where relocation of all structures/people (within a setback area of 220 meters) is not feasible, undertake Quantitative Risk Assessment (QRA) to assess the level of safety risks [by 22nd October 2016]; • For WTG locations where the risk is assessed to be higher than As Low As Reasonably Possible (ALARP), either relocate the turbines or relocate structures/people to bring the risk levels down to ALARP; • For WTGs where the risk is assessed to be within ALARP, undertake additional measures as defined in the ESRS and the ESIA to further minimize the safety risks; • Implement mitigation measures defined in the ESIA for noise and shadow flicker impacts for people remaining within the setback distance of 220 meters; • In line with Informed Consultation and Participation (ICP) principles, communicate and maintain documentation on aforesaid relocation plan and risks of living under the turbines to all stakeholder; • Undertake bi-annual audit through a third party to assess compliance to the agreed relocation plan and aforesaid approach.	10/22/2018
Develop and implement security personnel procedure as described in the ESRS and consistent with PS4 provisions;	12/22/2016
Undertake a review of HR policies and procedures and strengthen and upgrade them to make it consistent with IFC PS2 requirements including (among other things as described in the ESRS) • Development and implementation of appropriate contractor oversight procedures to ensure compliance to labor laws and other E&S requirements as detailed in the ESRS; • Commitment to develop specific guidelines and ensure construction camp’s accommodation for workers in line with PS 2 and relevant IFC guidance note.	12/30/2016
Appoint an external qualified third party consultant to undertake; • Six monthly Social, Environment, Health & Safety and Labor Audit for high risk projects under construction; • Annual audit to assess implementation and compliance with the ESAP and implementation of the Environment and Social Management Framework; • Six monthly audit to confirm implementation of the relocation/resettlement plan and other measures as described in the ESRS, post implementation	10/22/2016
For its operating wind projects, Initiate (with the help of qualified experts), monitoring activities/program to assess any impacts on avifauna and implement mitigation measures as described in the ESRS.	12/22/2016
Implement the Environment and Social Management Framework (ESMF) for all future projects including (among other things as described in the ESRS); • E&S risk screening and project categorization procedure (PS-based) to be systematically applied to all new projects, with a “Go/No-Go” decision at the planning/decision making stage of the project based on ground assessment of risks/sensitivities. • Commitment to maintaining a set-back area/distance in accordance with WBG EHS guidelines for wind projects; • Strengthening the existing EHS team to ensure implementation of the ESMF and compliance to IFC PSs	10/22/2016
Implement the findings of the ESDDs undertaken for operating wind and solar projects.	01/31/2017
Undertake stakeholder engagement and Grievance Redress activities in a structured and ongoing manner in line with the requirements as described in the ESRS and PS 1 requirements	12/22/2016