The company is essentially a buying club for RMs for SMEs. The main operations therefore are related to buying and selling of RMs through its platform. The only physical assets are warehouses located in leased spaces in urban/semi-urban areas zoned for locating such warehouses. Though the warehouses have a small back-up diesel generator (DG) sets to be used in case of power cuts, no significant environmental impacts are expected from company’s operations, therefore, PS3 (Resource Efficiency and Pollution Prevention) is not applicable. 

The warehouses are located in leased spaces in areas zoned for locating such warehouses. Private unarmed security guard is provided at the warehouse. Therefore, no impacts as envisaged under PS4 (Community, Health, Safety and Security) are expected. Further, as the warehouses are leased spaces and also, no land acquisition is planned in the future for the same, the kind of impacts envisaged under PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. No direct primary production of living natural resources is involved in the project and there is no material risk of significant conversion of natural and/or critical habitats in the supply chain and thus PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not applicable. Also, the type of risks and impacts envisaged in PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

  The company’s capacity and systems to manage its social, environmental, health and safety aspects of its operations in compliance with legal requirements as well as IFC Performance Standards and World Bank Group (WBG) EHS guidelines; assurance of fair, safe and healthy working conditions for its workforce (both employees and third party workers); management of transport related risks and impacts and ensuring compliance with IFC PSs requirements in the supply chain.

Identification of E&S Risks and Impacts:  Considering the company operations, E&S risks are limited to safety of employees at the office, HR related risks and impacts and supply chain risks. No environmental and social impact assessment (ESIA) is needed, however, the following sub-sections describe company’s policies and procedures (existing and proposed) to identify and manage identified risks and impacts.  

Policy: The company has a Health, Safety, Security and Environment (HSSE) policy, which documents various requirements on workplace environment, fire safety, equipment maintenance, security etc. The company has a HR manual (discussed in PS2 below) which also includes a code of conduct. 

Organizational Capacity: The company has a HR and administration team headed by Vice President - HR and Administration which includes training and development, business operations support, talent acquisition and administration. 

Senior Vice President (SVP) – Business Operations heads the teams responsible for supply chain, procurement and sales. The company has cluster, RM category and regional heads reporting to the SVP - Business Operations.  

Emergency Preparedness and Response:  As part of the implementation of its HSSE policy, the company has documented emergency response plans for its offices as well as provided required fire safety systems. Fire extinguishers were noted to be provided at the visited warehouse. As per the policy, the company conducts evacuation drills twice a year.

For storage of any hazardous materials in the warehouses (like pigments, paints and additives), the company will ensure that the Material Safety Data Sheets (MSDSs) are available and warehouse staff are adequately trained on emergency response measures related to these materials.  

Monitoring & Reporting: Regular reports are submitted to the relevant authorities on HR issues as per applicable legal requirements.

The company has a total workforce of about 225 employees and as part of the expansion plans, the workforce is expected to increase to 700 by FY 2022. The warehouses typically just have a warehouse in-charge and security guard (from an external company). Within its workforce, company has 20 runners who are the feet-on-the-street staff and are present at the loading site of the supplier and ensure appropriate documentation for the shipment. They are also involved in the inter-state warehouse-to-warehouse transfers within the company. 

Only a few (about 15) third party employees are involved in company’s operations for housekeeping, security and maintenance at the offices and warehouses.

HR policy, working conditions and terms of employment: The company has documented HR policies which mainly cover operational issues like salary, deductions and reimbursements, leaves, recruitment and selection, office hours, business travel, exits, communications etc. Also, the company has a code of conduct which covers among others confidentiality, anti-corruption and bribery, non-compete, non-solicitation, use of company property, ethics and integrity. The policies are available on company’s HR management system (HRMS) and are also communicated during the induction process. All employees have a written appointment letter from the company explaining the working conditions and terms of employment. 

As per the ESAP, the company will align and document its policies in line with the PS2 requirements and document specific policies on various aspects covered under PS2 including, non-discrimination, freedom of association, grievance mechanism and retrenchment. The new policies will also be communicated to the employees through HRMS and other mediums (e.g. awareness mailers/sessions). 

Non-discrimination: The company considers itself as an equal opportunity employer and is committed to non-discrimination. As per the ESAP, the company will document a specific policy on non-discrimination.

Freedom of association and grievance mechanism: Currently there is no staff union at the company. However, the company does not restrict formation of employee unions and will document a policy as part of the HR manual on the same. 

Currently, the company has provisions of raising grievances through the HR contact of the team or through the skip level meetings (with department head). Also, as part of the ESAP, the company will develop a grievance mechanism aligned with PS2 requirements and make it accessible to all employees and also create awareness among employees about this mechanism. The mechanism will allow employees to raise grievances anonymously. 

The company has a significant number of women staff members. Therefore, in line with the applicable regulatory requirements, the company has formulated and implemented a prevention of sexual harassment policy and constitute a specific committee to handle any sexual harassment related complaints.

Prevention of child labor and forced and bonded labor: Considering the operations and nature of the workforce, no child or forced and bonded labor is expected at the company’s operations. However, the company will include a specific policy in its HR manual. 

Occupational Health and Safety (OHS): Considering the type of operations, there are no significant OHS risks or impacts. Employees are provided with ergonomically designed workstations and designs office with adequate ventilation and lighting. Required fire safety and first-aid systems are provided at the offices and warehouses. 

Third party workers: The company employs its contract employees through different agencies. All these employees sign a written contract with the agency which explains various terms and conditions of their employment. The HR department of the company review required documentation to ensure that the wages, working hours and benefits are in line with the statutory requirements. 

Supply chain: The company has about 350+ suppliers which includes reputed pan-India tier-I manufacturing groups, authorized distributors and other tier-II/tier-III manufacturers. Some of the authorized distributors also conduct secondary processing of materials (mainly steel) before they supply it to P2S (or other customers). The contracts with these suppliers vary based on the RMs and supplier with the longest contracts with pan-India manufacturing groups which are annual memorandum of understanding (MoUs) whereas other contracts are mostly seasonal or one-time buys. Orders placed to the suppliers are based on back-to-back POs from SMEs. 

As per the requirements of PS2 and ESAP, the company will assess its supply chain for risks related to child labor, forced labor and significant safety hazards as well as its leverage and control of the suppliers. Based on this risk assessment, the company will implement procedures on pre-screening and ongoing monitoring of its suppliers for their compliance with respect to these requirements, which will be graded based on the risk and leverage/control.

Transport is arranged in most of the cases (~95%) either by the suppliers or the customers (SMEs). In the remaining cases, the transport is arranged by P2S’s logistics team who have identified transporters in each region. Currently, the company does not have any specific contracts with the transporters and therefore, does not have any specific E&S requirements for its transporters (for example on road safety, prevention of child labor). As per the ESAP, the company shall include specific E&S requirements in the contracts signed with the transporters. Also, the company will develop specific procedures for pre-screening and selection of transport companies based on their compliance with the identified E&S requirements.

  In terms of disclosure, the publication of the ESRS and ESAP will be the company’s first disclosure of E&S information.

  Considering the corporate nature of this investment, will disclose this ESRS and the ESAP at the following address:

1-B, Vikrant Enclave, 

Mayapuri, New Delhi-110064

India

Phone:  +91 124 4412629  

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

Mr. Deepak Gupta

1-B, Vikrant Enclave, 

Mayapuri, New Delhi-110064

India

Phone:  +91 124 4412629

Email :  deepak.gupta1@power2sme.com