As per the AHL’s business philosophy, only parcels of land where there would be no resulting physical or economical displacement are identified for project development. Typically, AHL purchases land through commercial negotiated transactions directly from the land owners on a willing buyer-willing seller basis or enters into a joint venture with a local partner who has the possession of land. Therefore, PS5 (Land Acquisition and Involuntary Resettlement) are not applicable. All proposed affordable housing projects will be developed on land zoned under residential areas around major cities, in plots with no associated economic or physical displacement, or impacts to areas with high biodiversity value, indigenous people or cultural heritage. Accordingly, the type of risks and impacts envisaged in PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.                                                

 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 risks and issues related to this project include: company’s capacity, systems and staffing to manage social, environmental, health and safety aspects of its operations; adequate social and environmental assessment of the impacts of the Project’s designs and construction activities in accordance with legal requirements and IFC Performance Standards; assurance of fair, safe and healthy living and working conditions for the workers (especially during construction); conservation of energy, water and process materials including recycling and reuse initiatives through green building design; management of air emissions, wastewater treatment and solid waste during construction and operations; acquisition of land for the projects in accordance with IFC Performance Standard requirements; life and fire safety design of the projects and impacts on transport infrastructure during construction on nearby communities.                                                 

  -  Environmental and Social Assessment and Management Systems: 

Assessment: 

AHL follows local legal requirements for design, development and construction of the housing developments, including the specifications defined on the Master Plan of each city, the requirements defined by the Ministry of Environment, Forest and Climate Change (MoEFCC) and the National Building Code of India (NBC). An accredited architect or engineer endorses the design, including structural and fire safety aspects, before it is submitted for the “Plan Sanction” by the local zonal authority and to obtain the “No Objection Certificate”. The plan presented needs to be aligned with the building bylaws for each region, if they exist, of by the building regulations defined by the Ministry of Urban Development. 

AHL obtains environmental clearance for all its projects prior to start of construction: Form IA is submitted for projects where built-up area is less than 150,000 m2 and Environmental Impact Assessment (EIA) is carried out if the built-up area is more than 150,000 m2 in line with the local regulatory requirements. Prior to hand over of the project to the residents, local authorities perform an inspection and issue an “occupancy certificate”. 

AHL performs a due diligence of potential land which includes assessment of land use, presence of third parties at the proposed site, review of land titles and legal due diligence. AHL is committed to purchasing land only through willing buyer seller transactions. Also, only land zoned as residential will be purchased for all the affordable housing developments. 

Management Systems:

AHL does not have any formal E&S policy or management systems although it has initiated programs on waste management, water conservation and energy efficiency. To meet the requirements of PS1, as per the ESAP action item 1, AHL will develop an EHS/sustainability policy which will include company’s E&S objectives, articulate company’s commitment to comply with the applicable laws and regulations as well as compliance with IFC Performance Standards. 

AHL has documented all the processes to be followed on construction sites in a safety manual which includes details on safety procedures, responsibility of safety officer, safety induction and tool box talks, safe operation of construction equipment, guidelines for traffic movement, safety audit checklist, accident investigation and format for safety audit. 

As indicated in the ESAP action item 2, AHL shall develop an Environmental and Social Management System (ESMS) covering both construction and operation phases. The ESMS will include: (i) screening procedure/checklist for assessing E&S risks and impacts associated with the new projects. For this purpose, AHL will develop a set of criteria for site selection as well as an evaluation checklist that will be completed for each new potential residence location. Based on results of this screening, AHL shall make a decision on approval or rejection of each considered location. Moreover, with the help of the checklist, AHL will assess and summarize key E&S risks and impacts associated with the selected sites (covering requirements of PS 5, PS 6, PS 7 and PS 8) and any specific design features will need to be adopted, in order to comply with regulatory requirements and the company’s corporate standard design specifications; (ii) procedure for land purchase including policy/guidelines for: (a) purchase of land having no legal issues or claims; (b) detailed due diligence of land aggregated for all future projects to ensure that the purchase process followed by the aggregator is free from coercion and fair prices are paid to the landowners; (c) not purchasing land which has resulted in any involuntary resettlement unless resettlement and income restoration are managed in a manner compliant with IFC’s Performance Standard 5; (iii) EHS procedures for construction phase integrating the safety manual already in place (covering construction phase related impacts and risks); and (iv) EHS procedures for operation and maintenance of diesel generator sets (backup for power supply), water treatment plant, sewage treatment plant, L&FS systems,  solid waste management, storm water drainage and also covering the monitoring, reporting and management review of E&S performance during construction and operation phase. 

Organizational Capacity and Competency: 

E&S aspects are managed at corporate level by an environmental officer responsible for obtaining regulatory permits of all projects and to ensure compliance with various permits and with oversight by VP -Operations.  At each individual project/development, there is a safety officer who reports to the project manager on OHS aspects. Safety officer is responsible to ensure that EHS procedures are followed and ensures regular safety training, safety inspections, accident investigation, preparation of monthly EHS statistics and reports, hygiene of labor camp, and ensure monitoring of the safety performance in tool box meetings and safety committee meetings. Safety officer together with project manager is responsible for addressal of E&S issues and general operations. Recruitment of direct labor force for construction and through contractors is responsibility of the Assistant General Manager -Projects. AHL’s employees receive regular training on project management, quality, environmental and safety elements. An induction program is available for all employees and contractors. 

Emergency Preparedness and Response: 

AHL has an emergency preparedness and response system to ensure appropriate response in case of emergency situations. The system consists of (i) emergency evacuation plans for all residences, listing of emergency contacts, and communication procedures; (ii) emergency equipment, such as fire extinguishers and wet extinguishing systems, in line with NBC requirements and as included in the No Objection Certificate (NOC) for fire issued by the local fire department; (iii) semi-annual/annual emergency drills. According to information provided to IFC during the appraisal, for senior living projects, emergency alarm is provided in each of the residences apart from the other fire-protection measures as required under the local regulatory requirements. As indicated in ESAP action 4, AHL will review the emergency plans of affordable housing and senior living homes through a third-party fire consultant in order to enhance and standardize the guidance for evacuation in case of emergencies. 

Construction sites are equipped with extinguishers, first aid kits and communication mechanisms in case of emergency. AHL has a specific process on maintenance and use of fire-fighting systems which includes a format for inspection of these systems. The process includes requirements on conducting regular fire drills and training on use of fire-fighting systems. As part of the ESMS to be developed (ESAP action item 2), formal procedures for emergency preparedness and evacuation will also be developed which would need to be implemented at each of the construction site. 

Monitoring & Reporting: 

For monitoring the EHS performance, monthly compliance meeting is conducted. The compliance committee comprises of deputy general manager - engineering, legal officer, environmental officer, project management engineer from head office and DGM project, legal officer and project manager at the site. Minutes of the meeting are documented and tracked for completion. At the construction site, weekly safety audit is conducted by the designated safety officer to identify unsafe practices which are reported to the Project Manager for making necessary improvements. Further quarterly safety audit is conducted by Project Management Engineer for their respective sites. Based on the performance of the site, each site is awarded with a tag (based on an internal criterion: Green, Yellow and Red). Environment Management Plan (EMP) is developed for each project as part of the regulatory approval process and consist of mitigation measures and environmental monitoring plan for compliance with various environmental regulations All sites conduct environmental monitoring for parameters as per local pollution control board requirements including ambient air quality, ambient noise, and wastewater quality. The sites submit monthly reports to the corporate team which provides data on manpower, number of incidents/accidents/first-aid cases/near misses and EHS induction trainings. 

As included in ESAP action item 3, for the proposed affordable and senior living housing developments, AHL will conduct a third-party audit of EHS and labor related compliance for atleast two construction projects through an external consultant (acceptable to IFC) against procedures developed as part of ESMS and IFC Performance Standards requirements.  As part of the review, the land purchase process for the specific development will also be reviewed to ensure its compliance with land acquisition policy/guidelines developed as part of the ESMS.

 AHL has a total workforce of 581 direct employees, 12.22% are female employees, a typical proportion of female workers in the construction sector. At each project between 48 and 60 indirect workers are hired through contractors to perform specialized construction tasks in the developments. 

Human Resources (HR) Policies and Procedures, Working Conditions and Terms of Employment: 

AHL has a policy manual in place which includes policies on leave (including maternity), domestic travel, transfer, gender equality, increment, loyalty grant and working hours. Appointment letter is issued to each staff which covers details on wages, leaves, benefits and allowance. Hiring and employment practices recognize the principles of non-discrimination and equal opportunity and there was no evidence of child or forced labor in the workforce. The company is committed to ensure that no child labor is used in its operations. Visits to construction sites and discussions with staff confirmed working conditions to be reasonable, safe and clean. Remuneration is competitively determined by referencing market rates and complies with minimum wage laws. 

Non-discrimination: 

AHL has a gender equality policy which aims to eliminate discrimination in employment on the grounds of age, gender, disability, race, color, nationality or religion. It also aims to comply with equal opportunity legislations as applicable, and to follow good management practices. As per the policy, all policies and practices of the company are applied equally to all employees.

Protecting the Work Force: 

In compliance with local labor laws and the company’s policy, AHL does not use child labor or forced labor at its construction sites. Contractors are also required to hire employees older than 18 years of age, which is confirmed through collection of documentation of age of workers and controls at construction site gates.

Workers’ Organizations and Grievance Mechanism: 

AHL employees do not belong to workers’ organizations or unions, and there has not been such request among the employees. The management team of AHL confirmed that they would not prevent employees to organize or participate in workers’ organizations. Employees’ grievances are managed through the direct supervisor and the regional head. The company has a procedure in place for handling cases of sexual harassment and a committee has been formed for handling of sexual harassment complaints. As a part of the ESMS, the company will develop and implement a grievance mechanism meeting PS2 requirements including the provisions on anonymously raising grievances.

Workers Engaged by Third Parties: 

AHL verifies that companies/personnel contracted to do the construction work are legal entities with a certificate of registration and a labor license issued by the statutory authorities. The contract issued by AHL does not explicitly include clauses regarding labor, workmen compensation insurance and occupational health and safety. Labor accommodation is provided by AHL and includes basic amenities. The ESMS to be developed (ESAP action item 2) will include a checklist for labor camp facilities including: adequate living/sleeping facilities and space per person; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste.

Occupational Health and Safety: 

AHL has a documented safety manual which includes safety procedures applicable to all construction sites. All construction site workers, including contractors, are required to have initial safety training prior to starting work. Appropriate safety measures and use of personal protective equipment was observed during the site visits. Currently the monitoring of EHS performance on-site by the company is limited to usage of PPEs and adoption of safe construction practices. There have been three fatalities on AHL construction sites in last 3 years related to electrocution and fall from height. 

The ESMS to be developed (ESAP item 2), will include a check-list to be followed by AHL for ensuring compliance with EHS requirements and legal requirements on working conditions and non-deployment of child and forced labor. The ESMS will also include procedure for monitoring and documentation of EHS performance on-site by the company and strengthening procedures to record accidents/incidents, investigate them and implement corrective actions. 

Resource Efficiency: 

Resource efficiency measures are/will be considered in the design of the proposed affordable housing/ senior living developments. AHL has adopted various measures in its existing projects to ensure resource efficiency such as dual piping system of plumbing for utilizing recycled wastewater in flushing, low flow fixtures in sink faucets, shower heads, and toilets for conserving water, low volume or dual mode flush systems, provision of Sewage Treatment Plant (STP) for treatment of domestic wastewater and to be recycled for gardening and flushing purposes and provision of rain water harvesting system for recharging ground water and collection of rainwater from rooftops. 

AHL uses solar architectural features in the building such as adequate natural cross-ventilation, sufficient day-lighting, usage of glass only for windows, covering of roof with reflective china mosaic tiles for lesser heat gains inside the building or using traditional heat insulation process, usage of solar water heater and LED/CFL lights in common areas.

Pollution Prevention: 

Environmental impacts and mitigation measures during construction and operation are properly identified in the Form IA/EIA (as part of regulatory approval process) and are mainly related to land preparation, air emissions (heavy equipment, vehicles, generators), noise, sewage from domestic use, visual impact (e.g. publicity and cranes), and waste management. As part of the Form IA/EIA, Environmental Management Plan (EMP) is prepared for each project for mitigating adverse impacts along with delineation of project and post-project environmental monitoring programs. 

Water and Wastewater: 

During construction, typically water is sourced through on-site bore wells after obtaining requisite approvals. Post construction, before the developments are handed over to the owners, water supply is coordinated with local authorities; typically, water is supplied by local government agencies and/or from on-site bore wells and water treatment (as required) is provided on-site by AHL to ensure that water quality meets the national acceptability standards. Wastewater during construction is treated using septic tanks. 

Existing and planned projects developed by AHL include the installation of STPs for treatment of domestic wastewater. AHL will continue to incorporate relevant waste water treatment systems into the design of the project unless AHL can secure confirmation from relevant authorities of the acceptance of effluents as discharged to the sewage systems. AHL will monitor the quality of the effluents and will ensure compliance with local requirements for the management of the liquid effluents for each development.

Waste Management: 

Waste produced during construction is segregated and collected at the generation point; metal scrap is sold to local companies, organic/domestic waste is collected by the municipality and construction debris are located temporarily at designated points and as feasible reused for back filling, sub base work for roads and pavements within the project. The domestic solid waste is segregated and collected in waste chutes for further disposal to the municipal agency once the projects are operational. Hazardous waste is limited to used oil from the generators (both during construction and operation phases) which is collected and disposed by authorized vendors, as defined by the local State Pollution Control Boards. 

During the appraisal, it was noted that for senior living projects (including care homes), waste is handled, collected, temporary stored, transported, and disposed by the municipal waste management authority, or by certified waste management service providers, consistent with the Indian legislation. The care homes have provisions for appropriate temporary storage of waste, thereby preventing contact with clients and unauthorized people and which is then collected by authorized bio-medical waste agency. AHL as part of the ESMS will reinforce training to assure proper implementation of the waste management programs in all the developments as well as proper segregation and disposal of the materials.

Maintaining green areas: 

The requirement for leaving open/green areas varies from region to region depending upon the prevailing development control regulations in the region. On an average, 40%-50% of the area is left as green area or open space.                                                

 AHL typically builds multistoried units (upto G+14) and as discussed above, AHL follows the local legal requirements for design, development and construction of the housing developments and follows the provisions of NBC which covers fire protection standards, drainage, waste disposal, conservation of fuel and energy and accessibility among others. Fire safety consultants are hired to incorporate the fire-fighting requirements and typical fire safety measures including provision for: wet riser system, hose reels, portable fire extinguishers like dry chemical powder, CO2, fire bucket with sand & foam extinguisher, manually operated electric fire alarm system, automatic sprinkler system (required to be installed in basement if area of basement exceeds 200 sqm), fire hydrant, yard hydrant, underground and terrace water tank etc. Enough (at least two independent) fire exits and exit signage are required to be provided. Mock drills are conducted to trained the staff.

As a requirement of the Indian Building By-laws, local authorities inspect the projects, including fire safety provisions and issue the No Objection Certificate (NOC) for fire which is renewed on an annual basis after inspection by the local fire department and after ascertaining that the buildings are provided with fire protection measures as per the sanctioned plan. The developments consider the access to basic services such as electricity and water; the projects developed by the company so far has been in peri-urban areas where such services are granted. 

As included in ESAP action item 4, AHL will hire an external consultant who will visit sample projects (covering both affordable housing and senior living) to audit fire safety compliance with the requirements of relevant Indian regulation on L&FS, and to identify corrective actions (if any) to meet these requirements. Elements covered in the review should include among others fire prevention, means of egress, detection and alarm system, compartmentation, fire suppression and control, emergency response planning, and operation and maintenance. 

AHL manages its construction activities in a way to minimize the impacts on neighboring communities. AHL provides clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. Access to potable water is guaranteed to all employees at the worksite and at labor camp. As part of the ESMS, AHL will develop and implement a documented community grievance mechanism i.e. a process of receiving and responding to the grievances which meets IFC PS requirements and will be implemented for all the proposed affordable housing and senior living developments.

The company hires unarmed security guards at the construction sites through external security agencies. The contractors are responsible for background verification of the guards and training the guards on dealing with the workers and neighboring communities. The company will explicitly review during the selection of the providers of these services their rules of conduct, training and monitoring of their workers to ensure appropriate conduct towards the communities and require them to act within the applicable law.                                                   

 AHL has identified different areas for its community partnership program and is implementing community engagement activities at most of the project sites. AHL has received Corporate Social Responsibility (CSR) awards for its various projects. AHL has adopted various government schools to strengthen elementary education, creates environmental awareness through tree plantation activities and undertakes development of roads in the project area. AHL also takes various initiatives in its operational projects such as raising awareness and educating residents about the various sustainability features (segregating waste at source and voluntary self-monitoring of water). 

AHL provides Crèche and day-school for children (0-13 years) at its construction project sites along with focus on nutrition and medical aid for these children. AHL representatives interact with local authorities; the EIAs approval process (if required) requires environmental public hearing/public consultations which are undertaken before the document is approved. The process allows the company to communicate the plans and to address the concerns of the community. The company 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.                      

AHL will publicly disclose the contents of this report (ESRS) and will respond to concerns, and where necessary will undertake actions to address these concerns.                           

  Contact Person Name: Mr. S. K. Palit

Company Name:   Ashiana Housing Ltd.

Address:  304&305, Southern Park, Saket District Center,  Saket, New Delhi-110017

Email Id: skpalit@ashianahousing.com

Phone No.:        011-42654265

Fax No.:            011-42654200