While all Performance Standards are applicable to this investment, IFC’s 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

PS1: Assessment and Management of Environmental and Social Risks and Impacts
PS2: Labor and Working Conditions
PS3: Resource Efficiency and Pollution Prevention
PS4: Community Health, Safety and Security

Land for the ICs near Ahmedabad and Pune (~350 acres and ~ 500 acres respectively) has been purchased/ is in the process of being purchased directly from third parties through willing buyer willing seller basis while for Jaipur project, the SPV would utilize 500 acres from the existing MWC in Jaipur (~ 3000 acres), which is 74% owned by the Sponsor and 26% owned by the Rajasthan State Industrial & Investment Corporation (RIICO).

The project at each location will be developed on pooled private barren and single- cropped agricultural land (as per revenue records). No expropriation of land is anticipated and a negotiated lump sum compensation will be paid to the land owners. As per the Sponsor’s business philosophy, only parcels of land where there would be no resulting physical displacement are identified for project development. The Sponsor or SPV, as applicable, advertises its intent to purchase land in a leading local newspaper in vernacular language and allows time for landowners/ residents to register complaints if any. Land at all locations is predominantly, non-irrigated and single cropped land mixed with open scrub land. SPV has already identified the required land for all locations and has entered into a Memorandum of Understanding (MOU) with land aggregator(s) for both Ahmedabad and Pune locations. PS5 (Land Acquisition and Involuntary Resettlement) will therefore be not applicable to the project.

There are no ecologically sensitive zones/ areas within a 10 km radius of the project site at all three locations. There is no protected area being impacted by planned developments and no significant adverse impact on fauna is expected.

Hence, PS6 (Biodiversity Conservation and Sustainable Management of Living Resources) is not considered applicable to the project.

With regard to PS7 (Indigenous Peoples), the project and its activities will not impact any indigenous people/community. No tribal land is being taken for the development of the project and its associated utilities. Hence PS 7 is not considered applicable to the project.

No cultural heritage is expected to be adversely impacted as the site does not contain any archaeological sites, or any structure that have paleontological, historical, cultural, artistic or religious values. No unique natural features, tangible or intangible are present in the project area which could be impacted by the project and its activities. Hence, PS8 (Cultural heritage) is not applicable to the project.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited
number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to
generally recognized performance standards, guidelines or design criteria.
Key E&S risks and issues associated with this project include: adequate social and environmental assessment of the project; the SPV’s organizational capacity and systems to manage social, environmental, health and safety aspects during construction and operation in compliance with legal requirements as well as IFC Performance Standards (PSs) and the World Bank Group (WBG) General Environment, Health and Safety (EHS) Guidelines including systems and procedures for i) managing occupational health and safety performance of third party contractors; ii) emergency preparedness and response; iii) energy efficiency and pollution prevention; iv) stakeholder engagement; v) land acquisition; and vi) management of wastes and effluents.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project
and gaps, if any, between these and IFC’s 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 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 Systems:
Assessment:
The Sponsor or SPV as applicable would be responsible for purchasing land and the SPV will be responsible for
developing the common infrastructure (water supply, storm water drain, electricity supply, street lighting, solid waste
management and sewage treatment). Accordingly, the SPV will carry out an EIA for overall development of each IC
and will obtain all required permits including environmental clearance as per the applicable local legislations. The SPV
would sign a lease agreement with each interested industrial unit, typically for 99 year lease period and permits required
by the individual unit such as consent to operate from state pollution control board (covering emissions, effluent and
hazardous waste) and no objection certificate from fire department will be obtained by each individual unit.
For IC near Ahmedabad, ICPL has already initiated the EIA process of environmental clearance while for industrial
estate near Pune where land purchase is at initial stages, the environmental clearance process is yet to start. The IC
near Jaipur has already obtained the environmental clearance and all necessary permits such as those related to water
supply, SEZ approval and consent to operate.
Typically, the Sponsor or SPV as applicable would engage external consultants to conduct an EIA study and develop
an environmental management plan (EMP) covering both the construction and operational phases for the development
of any new facility as per the local regulatory requirements. As indicated in ESAP action 1, the SPV, shall develop
terms of reference for environmental and social impact assessment (ESIAs) that meet the requirements of the
Performance Standards and local regulations and upgrade the regulatory EIA report to an ESIA meeting IFC PS
requirements for ICs near Ahmedabad and Pune (for IC near Jaipur, environmental clearance was obtained for the
entire 3000 acres industrial estate 2010 based on an EIA which was approved by the regulator. Further, significant
common infrastructure has already been developed by MWC at the Jaipur site. The requirement of an ESIA will
therefore not be applicable).
Management Systems:
The Sponsor has a corporate environmental policy, occupational health and safety (OHS) policy, corporate social
responsibility (CSR) policy and green supply chain management (GSCM) policy in place. These policies are followed
and adopted at all operating sites and will also be adopted by the SPV. The environmental and OHS policy reiterates
the Sponsor’s commitment for integration of EHS aspects into its business planning including employing processes
that foster safety, prevent pollution and conserve resources to provide its employees a safe work environment. The
GSCM policy reiterates the Sponsor’s commitment to sustainable development also covering contractors and
suppliers while the CSR policy provides commitment to CSR initiatives.
The SPV has developed an EHS plan specific to the construction phase which comprises EHS procedures associated
with incident reporting, safe work permit, fire prevention, risk assessment, environmental management and monitoring,
contractor responsibilities and contractor safety management and adequately covers the IFC PS requirements. EHS
plan is included as part of the contract document between SPV and the contractor engaged for developing the
common infrastructure. Construction of each individual unit is however done by the company (tenant) which signs the
lease agreement with SPV. As indicated in ESAP action 2, the SPV will include the EMP(s) to be developed as part of
the ESIA for each IC and the EHS plan in the MOM with the company to ensure that construction phase related
mitigation measures are implemented by each individual unit.
Whilst SPV has policy documents covering the environmental and safety aspects of its activities and also has in place an EHS plan covering the key EHS risks and mitigation measures to be implemented by the EPC contractor for the
construction phase however EHS management measures during operation and maintenance phase are not covered. As
indicated in the ESAP action item 3, the SPV shall develop an Environmental and Social Management System (ESMS)
integrating the EHS plan already in place (covering construction phase related impacts and risks) and incorporating
EHS procedures for operation and maintenance of common infrastructure such as diesel generator sets (backup for
power supply), water treatment plant, sewage treatment plant, solid waste management, storm water drainage and any
other maintenance activity and also covering the monitoring, reporting and management review of E&S performance
during construction and operation phase. In case any land acquisition is required for any component of the project
(such as right of way for the water pipeline), the ESMS should also include the land acquisition framework ensuring
that objectives of Performance Standard 5 are taken into consideration in future land acquisition processes, if any. All
of the Sponsor’s operational facilities (Chennai and Jaipur) have implemented certified management systems for
quality (ISO 9001), environmental management (ISO 14001) and occupational health and safety (OHSAS 18001). The
SPV plans to implement and certify similar management systems for the proposed project after it becomes
operational.
The Sponsor has been doing non-financial disclosure in the form of sustainability reporting since 2008. The Sponsor
has key E&S performance metrics defined as part of Sustainability Roadmap 2020. All related parameters are
monitored at business and location level and finally the overall performance is reported as part of Sustainability
Report. The Sponsor being part of Mahindra Group, also has internal metrics as part of business excellence
framework where the data is reported every year.
- Organizational Capacity and Competency:
The Sponsor has a well-articulated detailed organization structure with clearly defined roles and responsibilities and
reporting lines for staff managing the EHS issues with the ultimate oversight by a sector president at the Board level.
There is one General Manager for Safety, General Manager for Design and Sustainability along with an EHS manager
and one senior manager (sustainability) who have reporting from EHS managers of each operating facilities. A total of
30-40 personnel are directly responsible for EHS aspects within the company.
The SPV would be responsible for construction of common infrastructure and a designated team is made responsible
for implementation of EHS measures. The team includes project head/ manager who is responsible for ensuring that
the EHS plan is implemented and monitors the EHS conditions. He/ She is supported by relevant officers of the SPV
who co-ordinate with contractors safety supervisor for the EHS program implementation and who in-turn are
supported by a team of the Sponsor’s engineer/ supervisory personnel who are responsible for the overall EHS
performance of contractors and work under their charge and supervision. During the operation phase, a small team
from the Sponsor will be stationed supplemented with specialist vendors at each individual IC for Operation and
Maintenance (O&M) activities and which would include at least 1 personnel having EHS responsibilities.
- Emergency Preparedness and Response:
Based on the identified hazards and risks, an on-site emergency response plan is prepared for each operating IC and
the structure is defined in the corporate EHS plan. The EPC contractor engaged for construction of the common
infrastructure will prepare an Emergency Response Plan (ERP) for the construction phase covering various
emergencies such as natural disasters like floods and earthquakes and specific hazards like fire, chemical spill,
electrical shock and other environmental pollution incidents. The SPV shall ensure that each individual unit is provided
a copy of the ERP (included as part of EHS plan to be annexed with the minutes). In line with its corporate safety
policies and practices, SPV shall develop an ERP for the overall IC while each individual unit will develop their
respective onsite ERPs and conduct regular mock drills as per the local statutory requirements.
- Monitoring & Review:
The SPV carries out monitoring of water quality and treated domestic wastewater quality since operation of common
infrastructure is responsibility of the SPV. Environmental monitoring at each individual unit within the IC is governed
largely by the permit requirements and is undertaken for ambient air quality, stack emissions, ambient noise levels and
wastewater quality (as appropriate) by each individual unit. The SPV reports on KPIs related to safety for the
common infrastructure related services also including monitoring of water and energy consumption for internal
benchmarking and reporting.
The Sponsor publishes the information on various KPIs for EHS indicators such as energy and water efficiency,
waste reduction, health and safety, community development, responsible resource management and employee
development amongst others as part of its sustainability report.
- External Communications and Grievance Mechanism:
As indicated in ESAP action 4, the SPV will develop and implement an external communications mechanism in line wit
h the IFC PSs through which the SPV can: (a) receive and register external communications from the public; (b) scree
n and assess the issues raised and determine how to address them; (c) provide, track, and document responses, if any
; and (iv) adjust its processes, as appropriate.

IFC’s review considered the Sponsor’s activities with regards to fair, safe and healthy working conditions and is
based on an assessment of the practices in place and a review of the documents and information made available
during due diligence process. It is expected that on an average 200 workers of contractors and vendors will be
required during the 18-24 month construction period for common infrastructure. Once the IC is fully developed, a
small team of personnel from the SPV supplemented with specialist vendors will be stationed at each individual facility
for Operation and Maintenance (O&M) activities.
- Human Resource (HR) Policy and Procedures:
The Sponsor has in place a documented HR policy which includes policies on guarantee of fair treatment,
whistleblower policy, performance management, work life integration and wellness. The Sponsor has a policy on
prevention of sexual harassment and internal complaint committee (ICC) exists for all its operating facilities which are
responsible for receiving all complaints pertaining to sexual harassment. The Sponsor has a company commitment on
non-employment of child and forced labour and which is also included in the standard terms and conditions for its
contractors. All new employees receive a copy of the HR manual at the time of joining, together with their appointment
letter and contract. The HR policies and procedures of the Sponsor will also be adopted by the SPV.
The Sponsor has a policy on dealings with suppliers and vendors of products and services and which covers the
requirements for complying with EHS standards and regulations and labour legislations including abolition of child and
forced labour. The EPC contract issued for the proposed projects would require the contractor to adhere to IFC’s
Performance Standard 2 requirements and statutory labour acts and regulations (including amongst others requirement
of minimum wages, non-deployment of child and forced labour and workmen compensation) which is already
included as part of EHS plan annexed with the contract document for developed projects and would also be followed
for the proposed projects.
- Freedom of Association, Grievance Mechanism:
The Sponsor respects the staff’s freedom of association, and, hence does not prevent formation of employee unions.
As part of its HR policies, policy on guarantee of fair treatment exists which emphasizes two way communication
between management and the employees. A documented procedure is in place to address and resolve such
grievances, which also includes an oversight by the senior management. The grievance mechanism is open to the
contract workers also and allows for anonymous reporting of the grievance as well.
- Occupational Health and Safety:
The Sponsor has an OHS policy and EHS plan in place which includes various OHS procedures. The EHS plan
includes EPC contractor responsibilities (for construction of common infrastructure) and mandates the contractor to
have a comprehensive occupational health program, a risk assessment plan and an emergency/ crisis management plan
in the form of standard documents for implementation, monitoring and control of EHS requirements. EHS plan
developed by the SPV is annexed as part of contract document and includes procedure on incident reporting and
mandates that any incident / accident occurring, will be fully investigated to find out the root cause, and develop
preventive measures will be adopted to prevent its reoccurrence.
As part of statutory requirement, each operating unit within the IC reports on standard safety related KPIs such as lost
time accidents, recordable injury, first aid cases and the SPV reports on similar KPIs for the common infrastructure
related services.
-Workers Engaged by Third Parties:
The Sponsor has developed formal contractor management procedure to qualify and audit contractors as well as their
subcontractors. The procedures include compliance checklist against the applicable legal requirements; HSE
performance criterion as part of the contractor qualification and selection; and monitoring and audit procedures. All
project related EPC and other O&M contract documents include appropriate EHS provisions including those related
to contractor management, OHS requirements and implementation of EHS plans.
KPIs for this project will include OHS indicators which will be documented and reported as part of the sustainability report. The SPV shall ensure that its EPC contractors implement adequate OHS procedures and provide adequate training and protective equipment to all workers which is included as requirement in the EHS plan annexed with the contract document.

IFC’s assessment considered the SPV’s operations with regard to resources consumption (water and energy), efforts to optimize resource inputs, waste minimization and management practices as well as the storage and handling of
hazardous materials and wastes.
- Resource Efficiency:
Energy and water efficiency is emphasized in the Sponsor’s sustainability report and reducing carbon footprints,
energy conservation, water conservation, replenishment of groundwater and resource conservation are some areas
where has been working proactively to minimize waste and enhance resource efficiency.
The operations at Chennai and Jaipur are designed and certified in accordance to Indian Green Building Council
(IGBC) green rating system and all buildings are pre-certified or certified Gold rated. The Sponsor has a structured
approach to improve energy and water efficiency and where possible, energy is supplied by renewable power sources
such as solar power. MWC Chennai has already commissioned 75 kWp of roof-top solar at MWC Chennai and 210
kWp of roof-top solar at MWC Jaipur. LEDs are used for street lighting at most of the locations. At MWC Chennai
recently 10 TPD of Bio-CNG plant has been commissioned to treat the food waste. The bio-gas generated is used to
run gen-sets, tractors and buses for internal mobility options. The compost from this plant is provided to local
farmers as manure. Sewage Treatment Plant (STP) and Water Treatment Plant (WTP) are provided to increase
recycle/ reuse options of water in its operations. Also in landscaping, xeriscaping- species are provided that consume
less water. Energy and water during construction and operation phase is expected to be provided by the SPV to each
individual industrial units.
- Water and Wastewater:
During the construction phase of common infrastructure, water will be sourced by the SPV from local authorities or
from approved tankers. The SPV will provide water to individual units for their construction requirements.
During the operation phase, water for the project will be sourced from the local authorities and water treatment plant
will be provided by the SPV which in turn shall supply water to each of the individual units. The source of water for
ICs near Ahmedabad and Pune are yet to be finalized and ESIA report would cover the impacts related to water
pipeline development (including land acquisition if needed for ROW).
The SPV provides an integrated STP to treat sewage discharge and treated wastewater shall be recycled and reused
for landscaping and flushing requirements across the park. Treated wastewater from STP meets the statutory
requirements as included in the consent to operate from the state pollution control board. Sample STP treated
wastewater analysis reports for Jaipur and Chennai MWC were reviewed and observed to be in compliance with IFC
guideline values.
Process industries at both existing locations mainly comprise of auto/ apparel/ engineering related and handicraft
industries are non-polluting industries and similar industrial profile will be followed for proposed ICs also. Effluent
generated (if any) is required to be disposed off by the individual industrial unit as per their legal permit requirements
issued by the state pollution control board and which typically includes requirement for zero discharge (treated
effluent if any is used by the individual unit to meet their landscaping requirements and are mostly aligned with IFC
guideline values for treated effluent).
- GHG Emissions:
The GHG emissions of the project are due to the electricity consumption in common areas, with a small contribution
from loss of refrigerant from HVAC systems. GHG emissions are expected to be less than 25,000 tCO2eq/annum.
- Pollution Prevention:
Air emissions will primarily be dust/ particulates during the construction phase and fugitive emissions from equipment
during construction and operations. Noise pollution is expected during construction especially during excavation,
blasting and drilling. The SPV will ensure that EHS contractors for common infrastructure development implement
dust suppression measures and that appropriate measures are taken to minimize noise emission from the sites as
included in the EHS plan. The SPV will further ensure that mitigation measures as included in EMP are implemented at
site and since construction of each individual unit will happen in phases, construction related impact on surrounding
communities is expected to be low.
During operations, noise pollution will be mostly limited to vehicular movement and operation of equipment within
each individual unit (emissions and effluent generation would be very limited as nature of industries to be developed
would be non-polluting). These impacts are expected to be localized and local communities will not be impacted as
the projects are located in designated industrial zones.
-Solid and Hazardous Waste:
Construction wastes are expected to include domestic waste, inert waste (rubble, spoil) recyclables (plastics, paper,
metals) and small quantities of oil and oil-contaminated materials. the SPV will ensure that the EMPs and EHS plans
for the construction of common infrastructure cover the management of wastes. During operations, solid wastes will
be collected by the SPV from each individual unit and sent for disposal to the local authority. There is a well organized
waste collection mechanism at existing facilities whereby municipal solid waste is collected from each customer, segregated and the same is processed in to bio-gas/bio manure etc. The biogas generated is converted to
CNG and is utilized to operate the shuttle services as well as the waste collection tractors.
Hazardous Materials Management: Expected companies operating in the ICs will be nonpolluting
industries; therefore, management of hazardous materials is not expected to be a significant issue during the operations. Hazardous materials include fuels and lubricating oils. Petrol/diesel for generators will be stored in aboveground
storage tanks fitted with containment bunds. Any other hazardous chemicals used during construction will be stored in small quantities on site and the measures identified in the EMPs will be implemented to minimize any impacts.
The hazardous wastes generated (such as used oil, ETP sludge and process waste) from individual units will be handled and disposed as per the permit conditions.

The ICs will be located in designated area as marked in the master plan with limited impacts on communities. The
measures to minimize community health and safety risk will be included in the ESIA (including traffic planning,
managing influx related issues, sourcing water from authorized vendors, appropriate disposal of sanitary wastewater
and hazardous waste, appropriate accommodation and facilities for migrant workers) and associated management
plans (emergency, community development, stakeholder engagement).
As part of the ESIA, the contractor will be required to have measures in place to identify and mitigate risk of
community exposure to disease due to influx of labor and any other community health, safety and security risks,
which are expected to be minimal.
All the proposed ICs have good access (located along national highway) and overall road and access infrastructure in
the area is good (the site is well connected by road network) and significant pressure on infrastructure is not expected
due to the project.
The project will employ private security personnel during project construction and operation. These personnel will be
engaged through an outsourced and authorized security agency that conducts routine ID check at the gates and
security monitoring. As indicated in ESAP action 5, the project 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 disciplinary 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.
Contractor oversight procedures of the company will ensure compliance to the aforesaid requirements.
The ICs will have hydrant system linked to the water storage network. Additionally, each individual unit will also have their own firefighting
systems installed as per the local permit requirements. At Jaipur, there is a fire station within MWC premises while at Chennai fire station is located within 5 km of the IC. Each individual units will adhere to the prevalent NBC codes as well as the directives of the state fire services department if any.

The Sponsor or SPV as applicable, has conducted the required public hearings, as and when/ where applicable for
operational projects; going forward, once the EIA is completed and prior to approval, the relevant statutory authority
will conduct a public hearing as applicable where public can provide their comments, suggestions and raise any
grievances. In addition, consultations with key stakeholders including community will be carried out as part of the
ESIA. The Sponsor has published its sustainability reporting since 2008 and became the first real estate company in
India to issue externally assured GRI based sustainability report in 2011-12.
The SPV has identified different areas for its community partnership program: viz. education, water and community he
alth and is implementing community engagement and partnership activities at all the operating facilities. In line with the
corporate philosophy, the SPV organizes activities to engage with the local communities on a regular basis.

The Sponsor will disclose this ESRS locally at the following address:
Mahindra Lifespace Developers Ltd.
Mahindra Towers, Fifth Floor, Dr G M Bhosale Marg, Worli, Mumbai 400018

All inquiries and comments may be directed to:
Siddharth Bafna
Mahindra Lifespace Developers Ltd.
Mahindra Towers, Fifth Floor, Dr G M Bhosale Marg, Worli, Mumbai 400018

Broad Community Support is not applicable for this project