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
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources

If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
No physical or economic displacement of people will be required. No acquisition of land will be triggered, as 1,284 acres for each of 50 MW windfarm has been provided by the Government of Sindh and lease agreements have already been executed with the provincial government. Finally, there are no indigenous people or areas of high archeological value in the project area of influence. As a result, Performance Standards (PS) 5, 7 and 8 are not considered applicable to this project.

In accordance to IFC’s Environmental and Social Review Procedure (ESRP) and Policy on Social and Environmental Sustainability (PSES) the project is categorized as a Category B project 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. The most critical environmental, social, and health and safety (ESHS) risks and impacts of the project include: (i) earth movements, vegetation cover removal, and soil erosion associated with excavation and the operation of construction equipment, (ii) occupational health and safety (OHS) risks to construction workers, and (iii) OHS risks to maintenance workers, (iv) potential health and safety risks to the nearby communities associated with dust emissions, high noise levels and blade throw, and (v) permanent landscape modifications.
The project site is located in a semi desert area and mostly barren land with sparse vegetation. There are no formal villages and communities within the project site. However, there are some scattered settlements within the larger land parcel awarded to the project and a few hamlets exist mainly in the buffer area between TBCPPL power plants A, B & C. Project micro-siting is being undertaken to minimize impacts (dust emissions, noise, shadow flicker, etc.) on those isolated settlements.

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. The Company has presented the information about how the E&S issues and impacts are being addressed, to ensure that the operations at TBCCPL comply with the environmental and social requirements including: the host country laws and regulations; IFC’s Performance Standards; and the relevant WBG EHS guidelines. This information is summarized in the paragraphs that follow. Further information is provided in the attached ESAP, which is agreed upon by IFC and other lenders, and will address compliance gaps with IFC’s requirements.

The main E&S risks/impacts of this project include the following: Company’s capacity to manage its social, environmental, health and safety performance in accordance with local requirements and IFC Performance Standards and applicable World Bank Group (WBG) Environmental Health and Safety (EHS) Guideline; inadequate practices and non-compliance with PS2 requirements by the contractors being engaged during construction and operational phases; inefficient raw water management during construction; inappropriate evaluation of noise and visual impacts on sensitive recipient during operation phase; non-compliance of security measures at site with PS4 requirements; inadequate stakeholders process; and Emergency Response Plan lacking response to site specific risks.

Policy-Social & Environmental Assessment and Management System: The Company does not have a certified E& S Management System at present. However, the Company has identified E&S risks in its operations and possesses an internal system with structured Social and Environment, Health and Safety (EHS) organization and responsibilities, an E&S policy, procedures, and supporting monitoring and reporting systems and training programs. As per TBCCPL’s Code of Conduct and E&S policy, the Company is committed to conducting its business in compliance with all applicable environmental and workplace health and safety laws and regulations and TBCCPL’s Social, Environmental, Health & Safety Policies (April 2016). These policies state that the Company will conduct operations in compliance to the applicable laws, regulations and international guidelines and best practices in order to meet social and environmental contractual obligations to investors, lenders, customers and other relevant stakeholders. The policies related to Environment, Occupational Health & Safety and Corporate Social Responsibility will be signed by the CEO of the Company and will be displayed at the corporate office, the project operation sites, and at the website of the Company.

Identification of E&S Risks and Impacts: In 2014, the previous owner conducted an Initial Environmental Examination (2014 IEE) for its windfarm power plants TBCCPL A, B & C and obtained an environmental approval from the Sindh Environmental Protection Agency for all three wind power plants. After the acquisition of TBCCPL and its three sub-projects by Sapphire Group, the Sponsor retained a local environmental consulting firm - Arch Associates, which have worked on other wind farms in Pakistan financed by IFC and OPIC - to perform a Cumulative Environmental and Social Impact Assessment and to prepare an ESMP in line with IFC Performance Standards and IFC’s Wind Energy EHS Guidelines.

The 2014 IEE studies assessed the individual wind power plant (TBCCPL A, B & C) impacts in various relevant areas including land use change, landscape and visual impacts, soil environment, water environment, air quality, noise, loss of natural vegetation, loss and disturbance of habitat, settlement and community access, land-based livelihoods, social and demographic structure impacts by influx of workers, local economy and employment, cultural environment, community health and safety including shadow flicker, blade glint, and blade throw. As captured in the ESAP attached to this review summary, a Cumulative Environmental and Social Impact Assessment is in preparation to take into account the total impact of the 150 MW project (3 x 50 MW) as well the impact of the neighboring windfarm projects. There are around 16 windfarm projects planned for the area, of which eight are under construction and the remainder of which have been issued Letters of Intent (LOI) and land leases as of January 2016. The cumulative assessment under preparation
will build on the 2015 Jhimpir Wind Farm Region Cumulative Impact Assessment report commissioned by OPIC. The Cumulative Environmental and Social Impact Assessment is taking into consideration key potential EHS aspects and impacts such as those related to birds, resettlement, economic impact, noise, visual impact, shadow flicker, transportation, biodiversity and natural resources.

A separate baseline Bird Study was conducted for seven months using the Scottish Natural Heritage Guideline for Birds Monitoring in order to determine current bird’s flight pattern, flight height, birds count, bird’s species identification, birds activity so that project impact on birds and bird’s collision risk can be determined. As noted above, no cultural heritage was identified within the project site.

Management Programs: For each of the E&S impacts assessed for individual wind power plants (TBCCPL A, B & C) and those in the Cumulative ESIA, a consolidated list of mitigation measures and commitments was compiled as an ESMP with specific management plans e.g. Waste Water Management Plan, Transportation Management Plan, Air Emissions Management Plan, Noise Management Plan, Waste Management Plan, Emergency Preparedness and Response Plan, Spillage Prevention and Counter Control Measures Management Plan, etc. as annexure to the ESMP. The ESMP sets out the arrangements that will be put in place by the Company to manage the E&S performance of the project, its EPC and O&M contractors and their sub-contractors, to outline further studies and surveys to redefine predicted impacts and design appropriate mitigation strategies, to describe the monitoring programs to assess actual impacts and adequacy of mitigation strategies, and to provide framework for compliance auditing and inspection of the project by the Company. In addition, the project has also performed micro /task level Environmental Aspects and Impacts and Occupational Health & Safety Risk Assessment for Construction and Operational phase and developed an Environmental Management Plan and Occupational Health & Safety Management Plan.

Organizational Capacity and Competency: The E&S performance of the Company will be managed by the Company’s EHS Manager, a Human Resources (HR) Manager and a Community relations Officer, with supplementary technical and managerial support to be provided by Arch Associates, the project ESIA consultants. During the construction phase, the EHS Manager will manage all EHS issues and coordinate with the EHS team of EPC Contractor for management of impacts and implementation of the ESMP and related plans and procedures. Social issues will be handled by the HR Manager and the Community Relations Officer, who will report to the Site Manager. During the operational phase, the EHS Manager will be part of the Company’s Engineering Department and will work in close coordination with O&M Contractor and site employees for management of impacts and implementation of the ESMP. 

Training: Construct
ion workers will receive training on EHS matters, and in particular OHS (safety) awareness and use of appropriate personal protective equipment. This training will be delivered by Arch Consulting and supplemented as necessary by TBCCPL’s construction manager.

Emergency Preparedness and Response: The 2016 ESMP includes an Emergency Response and Preparedness Plan setting out procedures and measures to be taken to deal with emergency situations including emergency escape, shutdown during emergency evacuation, accounting for all personnel after an evacuation, rescue and medical duties for employees, and other emergency reporting (e.g. fires, medical emergencies). The Company will familiarize all employees and contractors with the plan. The plan will be reviewed and amended when needed to ensure that all parties concerned are furnished with up-to-date information particularly related to snake bite risks.

Monitoring, Review and Reporting: The Company’s EHS Manager, together with the E&S team of EPC and O&M contractors, will monitor the E&S performance of the project, including the implementation status of the ESMP. The EHS Manager will handle regular reporting requirements to regulatory bodies such as SEPA, and to lenders including IFC. The Company has also appointed an Independent Monitoring Consultant (IMC) as per SEPA requirement.

The construction activities will be parallel in three wind power plants (TBCCPL A, B & C) and it is estimated that direct manpower required during the construction phase of the project will be about 600 workers during the peak construction period. In addition, about 150 support staff will be present on site including technical, administrative and security staff. During operation, the Operation & Maintenance (O&M) contract estimates about 50 employees in operations and about 20-30 people in security (as contract workers).

Working Conditions and Management of Worker Relationship: The Company has established Employee Relation Procedures and has a HR Manual in line with Pakistan Labor laws and IFC Performance Standard 2 requirements. TBCCPL will ensure that project workers engaged by the Company, EPC contractors and sub-contractors are given understandable documentation concerning their rights under Pakistan labor regulations and any applicable labor agreements, including working hours, compensation & benefits, harassment, freedom of association, workers accommodation, child and forced labor, etc.

Human Resource Policy and Management: TBCCPL has instituted and is implementing several formal and documented HR policies and practices that will be applied to both direct and indirect employee, which are in adherence with the Pakistan labor laws, and have incorporated the requirements for labor transparency and equitable treatment as described and detailed in Performance Standard 2. As captured in the ESAP attached to this review summary, TBCCPL will reinforce its HR capacity by appointing a well-qualified HR manager in charge of the implementation of its HR related policy and procedures.

Worker’s Accommodation: A worker’s accommodation camp will be built to house a portion of the peak construction workforce of around 600 persons, though the exact location and size of this camp have yet to be finalized. The Operation and Maintenance (O&M) of the plants will be carried out by GE together with local contractor Al Bario Engineering Pvt. The planned accommodation facilities will be located within the project site and far from any settlements. The size of the accommodation facilities will be designed based on the final EPC and O&M arrangements, as mentioned in the project description section above. A Workers Accommodation Management Plan has been prepared to assist the Company in managing any adverse impacts on employees during the construction phase. The framework provides key elements for the Company to manage construction labor including resource requirements, workers accommodation facilities, recommended mitigation measures, and monitoring and inspection of the workers accommodation facilities.

Non-Discrimination and Equal Opportunity: TBCCPL will make employment decisions on the basis of equal opportunity and fair treatment, and in accordance with Pakistan regulations on non-discrimination.

Grievance Mechanism: As per the project Stakeholder Engagem
ent Plan, a grievance mechanism for managing both external and internal (worker) grievances has been established. A Community Liaison Officer will be appointed to receive, process and record/respond to comments and/or complaints shared by phone, post or email from external stakeholders and report to Human Resource Manager. The EPC and O&M contractors will also appoint contact persons for receiving, documenting and responding to complaints.

Protecting the Work Force: The Company has already documented specific procedures encompassing TBCCPL and its EPC and O&M contractors and their sub-contractors related to prohibition of child labor, forced labor, freedom of association. The Company need to ensure that these procedures are implemented by its contractors.

Occupational Health and Safety: The Company has a Health & Safety Management Plan. It has performed an Occupational Health & Safety (OHS) Risk Assessment for Construction and Operation Phase and prepared an OHS Management Plan. The Company with its EPC contractor have carried out a Job Hazard Analysis (JHA) of all construction activities for all hazards associated with work at the WTGs construction site and associated activities (Batching Plant, Excavation, Pouring, Lifting, Electrical Testing etc.). The Company has also developed a procedure for operational controls e.g. Permit to Work, Working at Height, Working at Night, Confined Space, Lifting Plan, Drinking Water Quality Plan. These procedures define TBCCPL and its EPC and O&M contractors’ responsibility to manage occupational health and safety performance. It is noteworthy that the same EPC contractor worked with Sapphire Group to achieve physical completion at the Sponsor’s existing wind power plant with no lost time incidents recorded.

Key potential hazards addressed in the framework include chemical hazards, physical hazards, noise, vibration, biological hazards, malaria, pest and insect control, ergonomic hazards, working hours and working cycles, fitness to work, and work at height. An ambulance will be provided on site 24/7 for emergency needs. Contractor staff will be trained in the nature of the health hazards and specified controls. The Company will build its E&S capacity to monitor implementation of OHS management procedures by EPC contractor and sub-contractors and other service providers.

Resource Efficiency:

GHG Emissions: The project is estimated to generate 399,000 MWh per year, with greenhouse gas emission reductions of 226,911 tCO2 equivalent per year using a grid emission factor of 0.5687 tCO2e/MWh. 

Water Management: About 1 to 1.5 m3 per day of water will be required during the operational and around 200,000 tons of raw water will be required during the construction phases of the project. Considering the general scarcity of water in the region, the Company is planning to adopt water conservation measures including using recycled water as much as possible. The batching plant will require a stable good quality of raw water supply for concrete production that is to be obtained from the water supply contractor. Construction camps would also need a considerable amount of water, including potable water, for 600 workers in peak time (but for a limited duration). The Company and the EPC contractor thus need to identify a secure water supply sources for sufficient and consistent supply of water, especially during peak construction period, and develop a procedure to monitor the quality of water being supplied; a Water Management Plan as captured in the ESAP action item 6 will be developed.

Resource Efficiency: Since the project involves parallel construction of TBCCPL A, B & C, instead of establishing three separate construction camps, one common facility will be established at TBCCPL wind power plant B and two satellite offices at TBCCPL A & C. Similarly a common sub-station will be used for evacuation of power from TBCCPL A, B & C. This will result in resource efficiency in terms of direct and indirect construction material usage, water consumption during construction and operation phase, and fuel consumption during construction phase. Similarly selection of GE 1.7-100 WTGs results in a lower number of WTGs i.e. 87 for the project compared to Sapphire Group previous practice of using 1.6 MW WTG (reduction in the number of WTG foundations reduces the use of resources).

During the operational phase, one 250KVA diesel generator per 50MW wind farm will be installed for emergency power supply, to be operated only as back-up. Fuel will be unloaded in designated areas and stored in above ground storage tank.

Pollution Prevention:

Construction phase impacts: A 13-15 month construction phase for the project is envisaged comprising the construction of WTG foundations, sub-station, installation of towers and turbine facilities and all accompanying facilities. Access road construction/expansion and construction works associated with the wind turbines foundations and transformer station requires proper drainage and erosion management. All soil and land disturbed and excavated during construction will be re-contoured, replanted, and returned to its original use where possible. A concrete batching plant will be located on each wind farm site as each of the turbine foundations requires about 800 to 1000 m3 of steel reinforced concrete. The
prefabricated concrete batch plants will be provided, operated and decommissioned by the EPC contractor.

Noise, Air Emissions and Ambient Air Quality: According to the 2016 ESMP a batching plant emission control plan for air emissions and liquid effluents has been developed within ESMP. Dust emissions from excavations, access roads development, vehicular movements, etc. are potential nuisance risks to the nearby community and will be addressed with adequate mitigations measure. Noise from construction, especially from batching plant operations, being a prime concern to nearby community will be avoided by careful siting of the batching plant.

Waste Management: The construction phase will generate a limited amount of waste (packaging, metals, plastic etc.) which will be mostly recyclable and will be sorted and separated in appropriate leak proof containers and disposed of in designated placed by licensed waste management operators. A Waste Management Plan has been developed under the ESMP.

Hazardous Materials Management: Contractors will be required to implement specific procedures to reduce waste at source, segregate waste by type, and enhance recycling. During the operational phase, one 250KVA diesel generator per 50 MW will be installed for emergency power supply, to be operated only as back-up. Fuel will be unloaded in designated areas and stored in above ground storage tank. A small quantity of oil/oily water may be generated during the maintenance of pumping stations. Hazardous goods (diesel and oil) will be stored in a covered and controlled storage area with the secondary containment and impermeable floors. Necessary approval from explosive department may need to be acquired for storage of hazardous fuel. Raw Materials and Hazardous Materials Management Plan has been developed under ESMP.

Noise, shadow flicker and visual impact: The nearest noise sensitive receptors to any of the 87 turbine locations and substations are approximately 0.8 - 1 km away. As captured in the ESAP action item 7 a baseline noise assessment study before the construction phase and residual noise study during the operational phase will be performed based on the selected turbine specification. The IEE and Noise Management Plan prepared under ESMP concluded that the project will adhere to both relevant national and WBG EHS noise limits in the construction phase. As captured in the E&S Action Plan (ESAP), the project will conduct a shadow flicker study before construction phase based on WTG specification and other parameters and during the first year of operations will monitor the impact of WTG shadow flicker on any habitation identified as being potentially impacted. The project will use the criteria of a maximum of 30 hours per year for the shadow flicker impact (WBG Wind Energy EHS Guidelines) and will implement mitigation measures if this criteria is exceeded anywhere. Potential for cumulative shadow flicker impact will be addressed in the cumulative impact Ass
essment.

Operations Phase: Operations and maintenance activities will be limited, and will include normal periodic maintenance, control/metering and site security management. Key potential operational impacts include WTG noise and visual impacts and positive impacts related to employment opportunities for the local population. 

Community Health and Safety: The Company’s Health & Safety Management Framework sets out measures in Community Impact Management Plan to ensure community health and safety. Key measures include cordoning off the construction site from public access, implementing mitigation measures for transporting WTG parts and other materials, transmission line construction to prevent community health and safety (H&S) risks, placing information boards about public safety hazards and emergency contact information in the project area in the local language, ensuring that construction phase workers are housed in labor accommodation facilities built at least 1 km from any communities, providing H&S training to raise awareness about STDs and HIV, and maintaining worker behavior standards.

Road Traffic and Safety: To ensure traffic safety in the local communities the Company will require, as defined in the Transportation Management Plan, each contractor to ensure communities are advised in advance of project progress and near term activities where transport issues have the potential to impact local communities. Special attention will be given to any local religious fairs, market days or during movements associated with village processions.

Security Personnel: About 100 armed private security personnel and 100 guards will be working during the construction phase. Between 20 - 30 armed security staff will be working during the operational phase of the project mobilized by the O&M contractor. As captured in the ESAP attached to this review summary, the Company will develop a Security Management Plan as per IFC PS 4 requirements. The Company will make reasonable inquiries to ensure that those providing security are not implicated in past abuses; will train them adequately in the use of force (and firearms), and appropriate conduct toward workers and affected communities; and require them to act within applicable law. The Company will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat, and will provide a grievance mechanism for affected communities to express concerns about the security arrangements and acts of security personnel (the community grievance mechanism is discussed further under Stakeholder Engagement, below).

Protection and Conservation of Habitats: No wildlife reserves are located near the project site. Keenjhar Lake Wildlife Sanctuary, a designated Ramsar wetland and Important Bird Area, is located about 20 km from the project site, which is considered to be sufficient distance to minimize potential negative impacts on migratory birds. A seven month (September 2015-March 2016) bird monitoring study showed that 44 species were observed during the monitoring period covering winter migration and spring migration period. Out of 44 species observed, 11 are migratory birds and the remaining 33 are local residents. Maximum of 100 feet flight height was observed and mainly perching birds were observed in the project area. No endangered or threatened species were observed. The major reason for decline in bird’s population and number of species visiting the Keenjhar Lake is less availability of food on land and in the land, hunting pressure, fish catching, etc.

The Company established a Bird Monitoring Plan in April 2016 as prescribed by the monitoring study conducted by an ex-WWF ornithologist using the Scottish Natural Heritage Methodology, and will monitor bird movements using the vantage point and point search methodologies during construction and using the point search methodology during operations.

The Company will implement the following framework with respect to minimizing operational bird fatalities: (i) all WTGs to be erected at a distance of more than 200 m from each other to reduce the risk of avian collision and to give the birds a wider corridor for the access in the project area; (ii) internal electricity lines from each WTG to the project substation will be underground thus reducing collision chances; (iii) use of flash lamps on the WTGs to prevent bird collision at night; (iv) regular checking of the vacuums or holes in the towers to reduce the risk of birds nesting in the WTGs; (v) bird mortality count by point search in the immediate vicinity to establish any link between the wind turbines and birds mortality for two years starting from the commissioning of the wind farm.

As described in the attached ESAP, detailed bird and bat monitoring will be conducted to assess the exact impact of the WTGs on the birds in the project area, and to evaluate the effectiveness of the mitigation measures. The Company has appointed a bird expert to conduct bird monitoring during construction and operations as per the Birds Monitoring Plan.

Stakeholder Engagement:
The 2015 IEE update identified that the project site does not have any villages within the project site boundary, but there are three villages (Kallo Goth, Nazeer Plari Goth and Ali Khan jakhro Goth) that are observed while survey. Villages are based on around 100+ houses with the population of around 500+ personals, distance of villages from designated wind farm sites is over 3 km.
The Company has developed a Stakeholder Engagement Plan (SEP) according to IFC requirements. The SEP identifies key stakeholders and sets out information on ongoing engagement plans relating to the project. The first engagement was done during the IEE study in April 2014 and more recent engagement was done during the Bird Monitoring baseline Study in 2016 and cumulative impact assessment study processes in May 2016. These engagements have identified local expectations related to more employment opportunities for local residents living in Jhimpir city and surrounding areas. The SEP will be reviewed periodically during implementation and will be updated as necessary to ensure effective ongoing engagement with local communities.
The SEP contains a grievance mechanism for managing both external and internal (worker) grievances. A Community Liaison Officer will be appointed to receive, process and record/respond to comments and/or complaints shared by phone, post or email from external stakeholders and report to Human Resource Manager. The EPC and O&M contractors will also appoint contact persons for receiving, documenting and responding to community complaints.
The Company will provide updates to affected communities on an annual basis on the project development and environmental and social management plans that involve risks to or impacts on them. In addition, information on project development will be available at the local community offices of affected communities and at Company site offices. As mentioned earlier, a Community Liaison Officer will be appointed to ensure smooth interactions with local people and to oversee the working of the grievance mechanism.

Mr. Khalid Aslam
Chief Operating OfficerTriconboston Consulting Corporation Pvt Ltd7-A/K, Main Boulevard, Gulberg II, 54000, Lahore, PakistanPhone: +92-42-111-000-100Fax: +92-42-35788744Email: mailto:khalid.aslam@sapphire.com.pk

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
E&S Impact Assessment: TBCCPL shall: (a) Integrate the three individual IEEs into one ESIA of the entire project including updating the information mentioned therein, filling in the gaps identified at review of IEEs and discussions held at appraisal meetings.	12/31/2016
(b)Prepare a cumulative impact assessment to evaluate impacts from other development projects in the Jhampir Wind corridor.	12/31/2016
(c) Monitor the NTDC’s progress of their Environmental Impact Assessment for the associated transmission line that is needed for successful implementation of the TBCCPL project and consider supplemental mitigation of any significant gaps vs IFC Performance Standards with IFC and NTDC input.	11/30/2016
(d) E&S Management System: TBCCPL shall: (e) Establish an EHS&S Management Structure including an overall organizational chart detailing the Environmental, Social, Health and Safety teams, structure and relationship at the corporate and project site levels, including Contractors and sub-Contractors.	12/31/2016
(f) Designate the persons responsible and compile an EHS&S Manual incorporating all the relevant procedures and plans necessary for implementation of Environmental and Social Management Plan (ESMP) and EHS performance of the project, including activities undertaken by contractors and other third parties (supply vendors/service providers) as well as any on-site staff. (The manual should include the plans and procedures of EPC)	02/28/2017
(g) Emergency Preparedness and Response. TBCCPL shall undertake a review of its existing safety procedures against the requirements of IFC PS and EHS Guidelines, conduct a site specific risk assessment, including but not limited to, snake and insect bite, exposure to high ambient temperature/humidity, emergency evacuation, etc. to develop an Emergency Preparedness & Response Plan. Necessary procedure for implementation of the ERP shall be integrated into the EHS&S Manual.	12/31/2016
(g) Emergency Preparedness and Response. TBCCPL shall undertake a review of its existing safety procedures against the requirements of IFC PS and EHS Guidelines, conduct a site specific risk assessment, including but not limited to, snake and insect bite, exposure to high ambient temperature/humidity, emergency evacuation, etc. to develop an Emergency Preparedness & Response Plan. Necessary procedure for implementation of the ERP shall be integrated into the EHS&S Manual.	02/28/2017
(h) Monitoring and Review. TBCCPL shall submit to the IFC/lenders quarterly EHS&S Monitoring reports till completion of the construction phase as well as annual monitoring reports (AMRs). Quarterly reports should include details/information on EHS&S performance including: brief of project activities, work force, incidents/accidents, LTIFR, trainings, max/avg ambient temp/humidity; SEP implementation update, ambient dust levels, drinking water quality and consumption, water table monitoring (at groundwater extraction site), PPE usage/consumption records, road accidents/collisions, grievance/complaints, wastewater disposal, solid waste, hazardous waste, etc.	03/31/2017
TBCCPL shall: (l) Update the HR manual to: a) reflect the following: terms and conditions of employment, working hours and rest time, over time, weekly rest and gazetted holidays, minimum wages, equality of treatment, freedom of association, prohibition of forced and child labor, termination of contract, decertification, social dialogue, and mechanism for resolution of collective and individual labor disputes; b) provision of basic services at construction site and labor camps; c) make employment contracts consistent with the local Labor Codes and IFC PS2 requirements; d) reflect HR requirements applicability and binding on the contractors and third-party service providers;	12/31/2016
(m) Develop and include EHS and labour provisions and compliance conditions in its EPC and O&M contracts which will provide contractors and third part service providers (including security agencies) with clear guidelines on labour performance	02/28/2017
(o) Develop and implement contractor control system to monitor and enforce contractors’, sub-contractors’ and service providers (including private security agencies) compliance with HR policy and procedures.	02/28/2017
(q) TBCCPL or its EPC contractor will appoint a well-qualified HR manager in charge of the implementation of the HR related policy and procedures and action items mentioned under this ESAP.	01/31/2017
(r) Grievance Mechanism (GM). TBCCPL shall develop a mechanism related to managing workplace grievances to ensure that it entails: i) involvement at appropriate level of management (including designated staff and accountability); ii) addressing concerns promptly; iii) understandable and transparent process that provides timely feedback to those concerned, without any retribution; iv) allow for anonymous complaints to be raised and addressed; v) not impede access to other judicial or administrative remedies that might be available under Pakistani law. The GM shall include EPCC, sub-contractors and service providers. The plan should provide for establishment of an impartial Grievance Redressal Committee for the project and a process for record-keeping of grievances.	12/31/2017
(t) Water Management: TBCCP shall prepare a Water Management Plan that should include sources of water supply, water demand forecast, QA/QC procedure for supplied water, potable water treatment/management, water supply contractor(s) management, etc.	02/28/2017
(u) Noise and Visual Impacts: Conduct noise and shadow flicker assessment studies for the three wind farms to assess potential impacts on sensitive receptors (nearby residences)	02/28/2017
conduct operations phase monitoring to confirm actual impacts and (if needed) implement mitigation.	03/31/2018
(w) Security plan: TBCCPL shall develop a Security Management Plan in line with IFC Performance Standard 4, i.e. to ensure that TBCCPL and/or the EPC and O&M contractors make reasonable inquiries to ensure that those providing security are not implicated in past abuses; train security staff adequately in the use of force (and firearms), and appropriate conduct toward workers and affected communities; and require them to act within applicable law. The plan will confirm that the company will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat, and will provide a grievance mechanism for affected communities to express concerns about the security arrangements and acts of security personnel	12/31/2016
TBCCPL shall: (y) Update the existing SEP to make it project specific, including stakeholders mapping, physical structures and land use in the project area of influence and based on need assessment outcome.	12/31/2016
(z) Engage a Community Liaison Officer to implement the updated SEP, including grievance mechanism.	02/28/2017
TBCCPL will conduct seasonal bird monitoring throughout the construction phase and first year of operational phase in accordance with the bird monitoring plan and share findings with IFC.	02/28/2017
First quarterly monitoring report to IFC by February 2017	01/31/2017