Environmental and Social Assessment and Management System

JK Paper’s corporate philosophy commits to “environmental and social care”. In accordance with the corporate philosophy, both CPM and JKPM have implemented their own respective integrated quality, environment, health and safety management system (IMS) certified to international standards. JKPM’s IMS is certified to ISO 9001:2015, ISO 14001:2015 and OHSAS 18001:2007 standards while CPM’s IMS is certified to ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007 standards. CPM has commenced the process of upgrading its IMS to 2015 standards and expects to fully roll out the upgraded IMS by June 2017.  Part of Wood sourcing at JKPM  is certified to FSC Control Wood and FSC Forest Management standards and at CPM it is certified to FSC-Control Wood standards. Further, both JKPM and CPM have formal employee management (HR) and community relations (CR) policies and procedures. The IMS, the FSC certified wood sourcing management system, HR and CR policies and procedures all together constitute the ESMS at each plant. Additionally, as mentioned at ESAP # 1, JK Paper will develop and implement an appropriate corporate level ESMS based on the requirements of the IFC Performance Standards (IFC PSs) so as to provide enhanced companywide oversight of environmental and social management and to derive better E&S performance. While the respective ESMSs of JKPM and CPM already incorporate compliance with national requirements, the company will, as part of the corporate ESMS development and implementation process, ensure that the ESMS of JKPM and CPM: (a) also incorporate the IFC PSs and the World Bank Group (WBG) Environment, Health and Safety (EHS) General Guidelines, 2007, WBG EHS Guidelines for Pulp and Paper Mills, 2007, and WBG EHS Guidelines for Perennial Crop Production, 2016 and WBG EHS Guidelines for Thermal Power Plants, 2008; and (b) include procedures to identify, map and define an appropriate engagement strategy for each of the key stakeholders in a structured manner both at corporate and plant level (ESAP # 2). There are opportunities for further improving the ESMS implementation both in JKPM and CPM’s operations. These opportunities for improvement have been identified through internal and third party audits, and the company is implementing improvement actions based on the audit findings in a timeframe agreed with IFC (ESAP # 3).

Policy

JK Paper will, as part of the corporate ESMS adopt and implement an Environment, Health, Safety and Social (EHSS) Policy that is aligned and consistent with both JK Paper’s corporate philosophy and IFC PSs. JKPM  has in place QEHS Policy, Human Resource Policies, Control Wood Policy, FSC Public Policy, Farm Forestry Policy, Wood Tracking Policy, Pesticide Policy, Contract of Contractor Policy, Publicly Available Information Policy, Monitoring and Evaluation Policy, and a Community Relations Policy. Similarly, CPM has in place QEHS Policy, Human Resource Policies and policies and procedures for FSC-Control Wood System. While the intent of these policies is broadly in line with the principles of IFC PSs, JK Paper will as part of ESAP # 1 and 2, upgrade these policies to appropriately incorporate and reflect the relevant requirements of IFC PSs. The corporate ESMS will include procedures to periodically review the corporate and plant level EHSS Policies and ESMSs to ensure that they remain relevant and provide a framework to address the risks, impacts and opportunities as these evolve over time.

Identification of Risks and Impacts

JKPM and CPM have, as part of their IMS, undertaken a structured identification of risks and impacts through formal Hazard Identification and Risk Assessment Process (HIRA) and Aspect, Impact and Significance (AIS) determination processes. Further, JKPM has, as part of the process to upgrade the IMS to the 2015 version of ISO standards, has reviewed and upgraded their risk and impact identification process, and undertaken a fresh HIRA and AIS determination. Some of the key risks and significant aspects/impacts identified include those relating to: handling, storage and use of chlorine; emissions to air and water; handling, storage and disposal of hazardous wastes; fire risk in coal, wood chips, wood and finished product handling and storage areas among several others. CPM has also upgraded the risk and impact identification process and is undertaking renewed HIRA and AIS determination in accordance with the upgraded process. The company will also, as part of the corporate ESMS development, undertake an appropriate risk and impact assessment process.

Prior to implementing brownfield or greenfield expansion projects, the company undertakes an environmental and social impact assessment (ESIA) in accordance with the national regulatory requirements. The company will, as part of its ESMS and depending on the nature and scale of risks and impacts, require JKPM and CPM to undertake an ESIA, HIRA and/or AIS for every project they implement. These assessments will take into account: risks of cumulative impacts; quantitative risks assessment; risks and impacts from decommissioning and relocation of parts of the plant; and impacts from associated facilities where relevant. The ESIA, HIRA and/or AIS (collectively referred to herein as ESIA) will be commensurate with the risks and impacts expected from the project and will meet both national regulatory and IFC PSs requirements. The ESIAs will be completed before any land acquisition takes place, will apply restrictions on access to natural resources, and will precede the award of EPC/construction contracts. The ESIA shall result in the development of an Environmental and Social Management Plan (ESMP) that meets the IFC PSs setting forth: (a) measures to mitigate adverse impacts; (b) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; and (d) an implementation schedule for these activities.

Further, J K Paper will as part of the ESMS have procedures in place to identify the potential for impacts on Critical Habitat, Indigenous Peoples (IPs) and Cultural Heritage from the projects and operations at JKPM and CPM. JKPM and CPM have in place a Controlled Wood Policy covering their farm forestry operations under which these plants verify the source of wood to avoid sourcing wood harvested illegally, in violation of traditional or civil rights, from high conservation value forests or forests where high conservation values are threatened due to the forest management activities, from forests being converted to plantations or non forest uses, and from forests where genetically modified trees are planted. In addition, the company will, as a policy, not undertake project or operational activities at JKPM and CPM that are in, or have the potential to impact, the following: (a) Tier 1 critical habitat; and (b) Tier 2 critical habitat without first developing a mitigation plan in line with PS6 provisions particularly related to creation of offsets and measures that demonstrate net gain.

JK Paper will as a matter of policy obtain Free, Prior and Informed Consent (FPIC) from IP communities prior to undertaking any projects and operations at JKPM and CPM, if impacts of the nature that trigger FPIC are expected on IP communities. In all cases, where communities of indigenous people are likely to be impacted from JKPM and CPM’s projects and operations, JK Paper will implement, as part of the ESMS: (a) an engagement and grievance redress mechanism based on the principles of informed consultation and participation (ICP); and (b) mitigation measures in accordance with the provisions of PS7.

The company will, as part of the respective ESMSs of JKPM and CPM, require each plant to develop and implement a chance find procedure for their projects and operations including for finds of archaeological, paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves. JKPM and CPM will be required to put in place procedures to protect and enhance sacred sites (e.g., ponds, forest groves, etc.) in consultation with community members consistent with IFC’s Performance Standard 8.

Management Programs

JKPM and CPM’s ESMS include procedures for: aspect, impact and risk identification; compliance with regulatory requirements; development and implementation of management programs, including standard operating procedures for managing EHSS risks and impacts from operations and maintenance; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; EHSS organization, responsibility and resource allocation; training and awareness; communication and consultation; monitoring, recording, reporting and documentation of environmental and social performance; quarterly internal and annual external audit of the ESMS; management review; and EHSS performance reporting to the JKPL management. The ESMSs at JKPM and CPM will be upgraded to incorporate IFC PSs and applicable WBG EHS Guidelines.

Organizational Capacity and Competency

At both JKPM and CPM plants, while overall responsibility for ESMS implementation is with the plant head, dedicated Environment, Safety, Medical, Community Relations and Human Resource (HR) /Personnel Management/Industrial Relations personnel have been employed to oversee the day to day implementation of each plant’s ESMS. Any biodiversity related aspects at each plant is managed by the raw material team. JK Paper will, as part of the corporate ESMS, include provisions for putting in place an appropriate corporate sustainability organization or council.  This corporate sustainability organization or council will be responsible for: (a) oversight of implementation of the corporate ESMS, consistent application of the company’s E&S policies across each of its plants, and monitoring follow up on improvement actions; (b) oversight of E&S staff deployed at each plant site; (c) performing an advisory role for each plant management on interpretation of E&S standards, sharing good practices between plants, from the industry, from other industry and being the source of knowledge on state of practice on all E&S aspects; (d) development of corporate training and capacity building programs; (e) corporation wide management of internal and third party audits, corrective actions and management review processes; (f) oversight of compliance with legal and other corporate commitments; and (g) reporting E&S performance and exceptions to the company’s senior management, board, investors, and other stakeholders.

Monitoring and Review

JKPM and CPM have in place an EHSS monitoring plan taking into account the identified risks and impacts and regulatory monitoring requirements. JKPM and CPM have both installed online continuous monitoring system for monitoring air emissions and treated effluent quality. The current monitoring program includes: emissions to air, ambient air quality, ambient noise levels, energy and water consumption, drinking water quality, wastewater generation, treated domestic waste water quality, treated industrial effluent quality, surface water quality, ground water quality, hazardous wastes generated and disposed, other solid waste generated and disposed, health and safety data, accidents/incidents, training and drills, community development initiatives, resource efficiency initiatives, and security incidents. The analysis of information from the monitoring and audit programs feeds into periodic management system review process to assess efficacy of the ESMS and to identify measures to further strengthen the ESMS. JKPM and CPM will, as part of the ESMS upgrade, commence monitoring and analysis of information related to stakeholder engagement, employee and community grievance redress, community health and safety, workplace environment quality, night time noise levels at sensitive receptors, total reduced Sulphur emissions from recovery boiler, hydrogen sulphide emissions from lime kiln and total phosphorus, total nitrogen and total suspended solids in treated effluent. Both plants will, as part of the ESMS upgrade, review the current EHSS monitoring program and align it with the monitoring requirements as per applicable WBG EHS Guidelines, IFC Performance Standard requirements and information requirements of key stakeholders.

Human Resources Policies and Procedures

JK Paper has in all about 2510 employees on their rolls encompassing its entire operations including 1295 and 1045 employees in JKPM and CPM respectively. In JKPM and CPM, there are 504 and 755 workmen and graded staff respectively; the balance is made up of management category staff at both locations. There are about 170 persons in Head Office to manage the corporate roles, including the all India sales and marketing staff of about 75 persons.  In addition, at CPM, there are approximately 1050 contract workers hired through different contractors. The contract workers are mainly involved in loading/unloading, wood handling, coal handling, material movement, security and housekeeping. Similarly, at JKPM there are about 2570 contract workers engaged through different contractors.

JKPM and CPM have in place certified standing orders and human resource policies and procedures aligned with PS2 provisions, which together include procedures relating to compliance with applicable labor laws, attendance and working hours, leave, conduct and discipline, employee grievance redress, wage and compensation,  working age, prevention of child and forced labor, equal opportunity and nondiscrimination,  freedom of association and collective bargaining, and avoidance of sexual harassment, working age, and industrial relations. Human resource (HR) and personnel management/industrial relations (PM/IR) team oversees implementation of these policies. JKPM and CPM have 30 and 14 member HR/PM/IR teams respectively. The company will as part of the ESMS upgrade process: make available the HR Policies and Procedures through intranet to all employees; through provision of handbook and training programs communicate the HR policies to employees and workers that do not have access to intranet; implement appropriate audit procedures to obtain assurance on statutory compliance by contractor/service providers with applicable labor laws.

Working Conditions and Terms of Employment

Basic terms and conditions are communicated in the employment letter to direct employees. Details pertaining to benefits, leaves, deductions, hours of work, overtime arrangements and overtime compensation, breaks and such other are specified in the HR policies and procedures, certified standing orders and the collective bargaining agreement.

Workers’ Organization

At JKPM, a four year collective bargaining agreement has been signed with the recognized workers’ union which is valid to December 2017 and covers all the on the roll workmen and graded staff. Contract workers have a separate union and a separate tripartite collective bargaining agreement signed between JKPM, contact workers’ union and the contractors. About 1400 of the total 2600 contract workers are covered under this collective bargaining agreement. Contract Workers in power plant, cutter section and maintenance are not covered as they work only during annual maintenance. There are also other joint management and worker committees at JKPM including joint works committee, safety committee, canteen committee, welfare committee, and house allotment committee.

CPM has a registered workers’ union and a staff association (for on the roll workmen and the graded staff). The most recent collective bargaining agreement expired in March 2016a and CPM is in advanced stage of discussion on a fresh collective bargaining agreement to be affective for 4 years commencing April 2016, which will cover all of the 856workmen and graded staff. Further, contract workers are part of another union and have signed a separate tripartite memorandum of understanding between the union, contractors and deputy labor commissioner based on which various contractors provide wages and benefits to their employees.

Non-discrimination and Equal Opportunity

JKPM and CPM have in place formal non-discrimination and equal opportunity policy and procedures aligned with PS2 provisions.

Retrenchment

There are no plans for retrenchment at JKPL, JKPM and CPM. The company will, as part of the corporate ESMS, develop and maintain a retrenchment policy and procedure that meets PS2 provision.

Grievance Mechanism

JKPM and CPM have a joint grievance committee with Union representatives and a formal grievance redress procedure with provision for time bound resolution of grievances received. However, not many grievances have been received as per the committee records. The grievance redress procedure will be upgraded as part of the ESMS upgrade process at JKPM and CPM to: (a) provide for anonymous complaints and confidentiality protection, where the aggrieved person so desires; (b) ensuring service provider/contractors’ employees access to an appropriate grievance mechanism; and (c) improve documentation, analysis and reporting of grievances received and resolved to senior management.

Protecting the Work Force

JKPM and CPM have in place formal and well defined HR Policies and Procedures for prevention of child and forced labor.

Occupational Health and Safety

JKPM and CPM manage occupational health and safety through their OHSAS 18001 certified management system that includes: OHS Policy; OHS objectives; roles and responsibility allocation; safety committee composition and procedures; safety induction, training, tool box talk procedures for employees and contract workers; provision of safety signage; provision of emergency response facilities (leak sensors, SCBA, online breathing apparatus/continuous airline, containment tanks, wash showers etc.) as relevant in chlorine and hazardous material handling areas; accident investigation, reporting and corrective action procedures; work permit system and safe work procedures for various activities that exposes workers and employees to hazardous conditions; periodic internal and third party audit, and management review. JKPM and CPM provided personal protective equipment (PPE) to workers and have required contractors to provide PPE to their workers. Contractors are in the process of providing PPEs to all of their workers. The OHS system includes periodic general medical examination program for workers and will be upgraded to a targeted health surveillance program covering both employees and contract workers. JKPM and CPM will continue to focus on further improving use of activity specific PPEs, particularly under dangerous working conditions. JKPM and CPM have an active safety training program in place. JKPM and CPM ensure that doctors or para-medical staff are available or that there is access to emergency medical facilities and ambulance is available at plants together with facilities for administering first aid. Firefighting equipment has been provided at CPM and JKPM. To further upgrade OHS management, JKPM and CPM have undergone third party safety audits and are implementing a comprehensive improvement action plan based on the findings of the third party audit. This includes among other findings: conversion of underground fire hydrant system to over ground system at CPM; and a fire load assessment study to test the adequacy of the firefighting system in place at JKPM.

JKPM and CPM have commenced the following: monitoring leading and lagging indicators; analysis of nature and causes of accidents; and use of safety risk mitigation hierarchy in risk evaluation to strengthen accident and incident prevention. The monitoring data indicates improving safety performance trend at both JKPM and CPM. At JKPM, reportable accidents (where the injured person does not return to work for 48 hours) has come down from 3 in calendar year 2013 to zero in 2016. Total person days lost in 2013 was 122 which has now come down to zero in 2015 and 2016 both. Similarly, the number of first aid incidents has been reduced by 50% between 2013 and 2016. Also near miss reporting at JKPM has increased fourfold between 2013 and 2016 indicating increased safety awareness and a developing safety culture. At CPM, reportable accidents have come down from 2 to zero between 2013 and 2016. Total person days lost in 2014 and 2015 was three and this has come down to zero in 2016. Further, at CPM also, the number of first aid incidents has reduced from by 20 % between 2013 and 2016 and near miss reporting at CPM has increased almost two and half times between 2013 and 2016. The OSHA incidence rate at both JKPM and CPM at less than 1 is within internationally recorded levels for this industry.

Workers Engaged by Third Parties

JKPM and CPM have procedures in place to review contractor compliance with key statutory requirements particularly related to wages, overtime, leave, age and OHS performance. The two plants will, as part of the ESMS upgrade process, expand this contractor management and oversight procedure by including: (i) a comprehensive compliance checklist against the applicable legal requirements and PS2 provisions and a periodic internal audit procedure; (ii) OHS performance criteria as part of contractor qualification, selection and contract renewal decision; (iii) procedures to ensure consistency of worker accommodation provided by contractors with IFC PSs; (iv) requirements to enable contract workers can access an appropriate grievance mechanism; and (v) procedures to ensure that engagement of migrant workers is on substantially equivalent terms as non-migrant workers performing the same work.

Supply Chain

Resource Efficiency

JKPM and CPM manage environmental impacts of their operations as per the ISO 14001 certified ESMS. Resource efficiency objectives and targets are set every year and achievement monitored. Further, in case of future greenfield or brownfield expansion, project specific resource conservation, pollution prevention, and mitigation measures that meet the Performance Standards and the WBG EHS Guidelines will be identified during the project specific environmental assessment, and incorporated into the Environment and Social Management Plan (ESMP).

Energy and Material Efficiency Projects

JKPM has reduced electrical power consumption from 1272 kWh/t of paper in 2014-15 to 1140 kWh/t of paper in 2016-17, which is within the range of good international industry practice (GIIP). Process steam consumption has come down from 7.4 t/t of paper to 5.8 t/ton of paper between 2014-15 and 2016-17 and utilization of energy from the recovery boiler as a percent of total energy consumed has increased from 52.8% to 62.6% in the same period. The total energy consumed is 14.25 GJ/t of paper and this is close to GIIP levels.

CPM has reduced electrical power consumption from 1506 kWh/t of paper in 2014-15 to 1334 kWh/t of paper in 2016-17, which is marginally higher than the range considered good international industry practice (GIIP). Process steam consumption has come down from 8.1 t/t of paper to 7.4 t/ton of paper between 2014-15 and 2016-17 and utilization of energy from the recovery boiler as a percent of total energy consumed has increased from 21.8% to 22.8% in the same period. The total energy consumed is 26.9 GJ/t of paper and this is higher than GIIP levels. In the next major capital investment program CPM will implement measures to bring total heat energy per ton of paper and electricity consumption per ton of paper to within GIIP range. In the interim, CPM plans to by December 2018, implement several energy efficiency initiatives including: installing a new winder and refiner in paper machine; speed increase of one of the paper machines; augmentation of PCC plant; replacement of old motors, pumps and agitators; increase in number of variable frequency drives; installation of steam profiler in one of the paper machines; and exploring the feasibility of installing steam profiler on board machine and improving the efficiency of pre-group driers of the board plant. These initiatives are expected to reduce the electricity consumption per ton of paper to 1325 kWh and also reduce heat energy consumption per ton of paper.  

Water

Water consumption at JKPM has come down from 43.35 m³/t of paper to 39.64 m³/t of paper between 2014-15 and 2016-17, and is within the range of GIIP. Water consumption at CPM has come down from 51.7 m³/t of paper to 50.7 m3/t of paper between 2014-15 and 2016-17, and is within the range of GIIP. The water is sourced from nearby Nagavalli river at JKPM and from Ukai dam at CPM.

Greenhouse Gases

JKPM requires 42 MW of electricity and has a 55 MW of captive power capacity with 30 MW connected to coal fired boiler and 25 MW connected to chemical recovery boiler. CPM requires 17 MW of power of which 16.8 MW is generated in-house and 0.2 MW is purchased from the grid. In-house installed capacity is 30 MW with recovery boiler linked power capacity at 12 MW and the balance is coal fired. JKPM captures CO₂ from the lime kiln to manufacture precipitated calcium carbonate (PCC). It is estimated that the total CO₂ capture per annum for PCC manufacture is 25,250 t. The total scope 1 GhG emissions from JKPM has been estimated at 1.35 million tons of CO_2e per annum. CPM also has an SPCC plant which captures 2560 t of CO₂ every year. While CPM does not currently estimate GhG emissions, an approximate estimate indicates that the total scope 1 emission from CPM is about 554,000 tCO_2e per annum. CPM will as part of the ESMS upgrade commence annual estimation of scope 1 GhG emissions.

Pollution Prevention

Air Emissions and Ambient Air Quality

Measurements of particulate Matter of 10 micrometers or less (PM₁₀), PM_2.5, Sulphur Di-Oxide (SO₂) and Oxides of Nitrogen/Nitrogen Di-oxide (NO₂) at 51.3, 39.6, 15.9 and 13.5 ug/m³ respectively are all within national ambient air quality standards at JKPM. At CPM, PM₁₀, PM_2.5, SO₂ and NO₂ at 78, 46.5, 14 and 20.5 ug/m³ respectively are all within national ambient air quality standards.

Emissions to air at JKPM and CPM are primarily from power boiler, recovery boiler and lime kiln. At CPM, while SO₂ and NOx emissions at 141 and 6 mg/NM³ respectively from power boiler are within GIIP and national regulatory limits, the particulate matter (PM) emission at 51 mg/NM3 while well within national standard marginally exceeds the GIIP emission levels. Further, the total particulate load, SO₂ as S load, and NOx as NO₂ load emitted from recovery boiler and lime kiln taken together at CPM is 0.38, 0.37 and 0.02 kg/t of air dry pulp respectively is within GIIP levels. The particulate load, SO2 as S load and NOx as NO2 load from the power boiler at 0.47, 0.22 and 0.008 kg/t of air dry pulp respectively is within the GIIP levels.

At JKPM, PM, SO₂ and NOx emissions at 29.6, 74.6 and 42.7mg/NM³ respectively from power boiler are within both national standards and GIIP levels. Further, the total particulate load, SO₂ as S load, and NOx as NO₂ load emitted from recovery boiler and lime kiln taken together at JKPM is 0.0.13, 0.24 and 0.20 kg/t of air dry pulp respectively is within GIIP levels. The particulate load, SO₂ as S load and NOx as NO₂ load from the power boiler at 0.15, 0.39 and 0.22 kg/t of air dry pulp respectively is within the GIIP levels. Both JKPM and CPM will, as part of the ESMS upgrade, also commence monitoring emission of total reduced Sulphur (TRS) and hydrogen sulphide (H₂S). NCG gases are being burnt in lime kiln at JKPM and CPM will install the NCG gas burning system as part of its pulp mill upgrade program.

Wastewater Treatment

While JKPM is elemental chlorine free (ECF), CPM minimizes use of elemental chlorine through use of chlorine dioxide. Both JKPM and CPM have effluent treatment plants with activated sludge process. JKPM also has a cooling tower. At CPM, a significant portion of the treated effluent is supplied to nearby villages for irrigation. Currently this program covers 1200 farmers irrigating an area of 229 acres. The remaining effluent is discharged in a natural drain (the Ghoda Nala) which discharges into Tapi river. At JKPM, 10% of the treated effluent is used on plant premises and the balance is discharged in the Nagavali river. The effluent is discharged after cooling in a cooling tower and holding it for a day. The treated effluent at JKPM is discharged only in the night as per regulatory requirements. Effluent generation at JKPM has reduced from 38.35 m³/t of paper to 34.52 m³/t of paper between 2014-15 and 2016-17. The effluent generation at about 35 m³/t of air dry pulp is within GIIP levels. The CPM effluent generation has reduced from 43.7 to 42 m³/t of paper during the same period. The effluent generation at about 42 m³/t of air dry pulp at CPM is within GIIP levels.

At JKPM, the total load of Total Suspended Solids (TSS), Biochemical oxygen demand (BOD), the Chemical oxygen demand (COD) and Adsorbable Organic Halides (AOX) at 0.91, 0.61, 7.02, and 0.14 kg/t of air dry pulp respectively are within GIIP levels. At CPM the total load of BOD, COD and AOX at 0.9, 8 and 0.13 kg/t of air dry pulp is within GIIP levels but total load of TSS discharged at 1.65 kg/t of air dry pulp marginally exceeds GIIP levels. The concentration of TSS, BOD, COD and AOX discharged from both CPM and JKPM meets regulatory limits. Both JKPM and CPM will, as part of the ESMS upgrade, also commence monitoring load of total nitrogen and total phosphorus discharged. Depending on the monitoring data, JKPM and CPM may have to optimize N and P dosage.  At JKPM, the treated effluent is discharged directly into the river at a temperature about 6-7 degree Celsius above the ambient river water temperature. JKPM will, implement a monitoring program and undertake thermal dispersion modeling, and if required a implement mitigation measures to demonstrate that the temperature of the treated effluent is less than 3 degrees Celsius above ambient river water temperature at the edge of the mixing zone. (ESAP # 8) JKPM has installed a sewage treatment plant in the colony. The treated sewage meets applicable national standards and about half of the treated sewage water is reused in the plant. The remaining treated sewage is mixed with treated industrial effluent and discharged in the river. Sewage at CPM is disposed through septic tank and soak pit route. CPM will, as part of the next plant upgrade capital investment program, install a sewage treatment plant (ESAP # 4).

Solid Waste Management

JKPM disposes: (a) 100% of the approximately 63,000 tons per annum (tpa) of fly ash to fly ash brick manufacturing units; (b) 98% of the 7000 tpa lime sludge by re-burning it in the lime kiln for reuse in the process with the remaining 2% being used for acidic soil treatment by Government of Odisha; (c) about 5000 tpa slaker grits are used in repairing of roads and road making; (d) about 19,000 tpa of bamboo and wood dust is consumed as fuel in boilers; (d) paper machine sludge is sold to other lower grade paper manufacturers; and (e) fiber line rejects are recirculated in the process. CPM disposes (a) 100% of the approximately 46,000 tpa of fly ash to fly ash brick and cement manufacturing units; (b) 50% of the about 45,000 tpa lime sludge by re-burning in the lime kiln for reuse in the process and the balance is disposed in an abandoned stone quarry; (c) about 5000 tpa slaker grits by usage in road repair and road making ; and (d) about 8000 tpa of bamboo and wood dust by using it as fuel in boilers.

Hazardous Materials

Both JKPM and CPM dispose hazardous waste to authorized entities. 7000 tpa and 4000 tpa ETP sludge from JKPM and CPM respectively is disposed to fiberboard manufacturers. Any ETP sludge that is not disposed to fiberboard manufacturers at JKPM is disposed of in an onsite engineered secure landfill. JKPM is in the process of implementing a groundwater monitoring program in the vicinity of the engineered secure landfill. Both JKPM and CPM will undertake a full characterization and toxicity characteristic leaching procedure (TCLP) test of the ETP sludge (ESAP#5). About 20 tpa and 8 tpa of used oil from JKPM and CPM respectively is disposed to authorized recyclers. Labeling and containment of hazardous materials and wastes needs to be improved. Overall, as part of the ESMS upgrade process, both JKPM and CPM will review their procedures, facilities and practices relating to segregation, labeling, handling, storage, and disposal of solid and hazardous wastes and develop an action plan to fully implement procedures that meet GIIP.

Pesticide Use and Management

Community Health and Safety

There are communities in the immediate vicinity of both JKPM and CPM plants including employee colonies. Both the plants have access from major roads and the material receiving gate is typically located on these major roads. JKPM has provided a dedicated parking area for trucks and tractor/trolleys that deliver the raw material. Movement of trucks into the chipper and log yard is regulated. However, as part of the ESMS upgrade, both JKPM and CPM will review the traffic management rules and detail formal rules for the following: parking, movement, access control, restriction on speed, norms for deployment of marshals/traffic scouts, documentation requirements (valid licenses, road tax certificate, gate/entry pass), dedicated truck parking areas, driver rest areas, and dealing with transport emergency situations (accidents, injuries). The ESMS will include procedures to identify choke points and management of traffic arising from plant operations at choke points will be done through scouts/traffic marshals who will be trained and engaged by JKPM and CPM. In addition, for the drivers and helpers who regularly visit the plants, JKPM and CPM will as part of the ESMS have procedures instituting a training program on defensive driving and dealing with transport emergencies. JKPM and CPM will as part of the ESMS have procedures to ensure that prior to any project involving significant influx of labor, an assessment of community exposure to health and disease risks from water-borne, water-based and vector-borne diseases is undertaken. JKPM and CPM will in such cases implement procedures for health check-up of incoming workers and provision of adequate medical assistance and on-site medical facility.

Infrastructure and Equipment Design and Safety

JKPM and CPM have in place procedures to identify and meet statutory requirements for structural safety, stability and integrity related to infrastructure and equipment including procedures for testing as required. JKPM and CPM are required to undertake pressure vessel testing, lifting tools and tackles testing and structural stability/integrity assessment for all major equipment and machinery (like boilers, all air storage tanks, compressed tanks etc) on a periodic basis.

Ecosystem Services

JKPM and CPM will as part of the ESMS upgrade: (a) undertake a review of main water users and uses downstream of their respective intake points; (b) assess the downstream consumption, lean season water availability (in the Nagavalli river and Ukai dam respectively for JKPM and CPM) and their respective water intake; and (c) commence monitoring river water quality upstream and effluent dispersion plume downstream of the point of effluent discharge into the river.

Emergency Preparedness and Response

JKPM and CPM have onsite and offsite emergency response plan in place. Joint emergency response drills with district emergency management authority is undertaken every year.

Security Personnel

JKPM has 30 ex-servicemen employed in security team headed by a retired naval officer. In addition, there are 120 outsourced guards including 30 armed guards. JKPM also has a dog squad with three dogs. No formal security threat assessment has been undertaken but the security team interacts with relevant law enforcement and intelligence agencies to obtain updated intelligence and security risk information. Arms are typically not provided to guards to carry. These are kept in the armory and issued to guards under specific conditions by order of security head and Plant head. The recorded security incidents indicate theft as the main area of concern. CPM has 3 permanent security staff and 75 outsourced security personnel. There are 5 armed guards at CPM. While the IMS at JKPM includes security personnel procedure, the focus of this procedure is on access management, security incident reporting and fire/emergency response. CPM IMS does not cover security personnel procedures.

While security personnel are trained in the performance of their duties and limited level of behavioral training provided, the latter is not structured and formalized at both JKPM and CPM. JKPM and CPM will, as part of their respective ESMS upgrade process, implement additional procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in use of fire arms and handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; security personnel are trained in avoidance of human rights violations; bona fide complaints against security personnel are investigated/disciplinary actions 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.

Going forward, as part of the ESMS upgrade, JKPM and CPM will: (a) complete a formal security risk assessment (ESAP#6) and implement procedures aligned with PS4 provisions on security personnel; (b) strengthen their onsite and offsite emergency management plan to cover aspects like natural hazards, chemical leak, arson and other security risks; (c) engage with communities including providing training and building awareness with off-site emergencies/risks and (d) ensure adequate training to security personnel on company’s policies and applicable PS 4 requirements.

CPM purchases bamboo from IP communities in Gujarat who have rights to harvest/extract bamboo from forests. The IP communities are expected to undertake bamboo harvesting and extraction in accordance with the management plan for that area prepared by the forest department. The IP villages/communities then sell the bamboo.

JKPM purchases wood from two IP farmer cooperatives that undertake farm forestry operations. The two cooperatives have been formed with IP farmers as members. There are about 2600 IP individuals who are members of these two cooperatives. The IP individuals have land titles in their name on which they were undertaking subsistence farming. As part of the cooperative arrangement, the IPs contribute land and labor. The cooperatives carry out all farm forestry operations (Eucalyptus plantation mostly) from provision of plant/sapling to harvesting, extending these services as a loan to the members. Each member has a passbook that details the allocated cost/loan and income (as wages when members contribute labor) in the passbook. Upon harvesting and after selling to JKPM, the cooperatives deduct the costs extended as loan & interest and pay the balance to the members. Since Eucalyptus has a rotation of 4 years, in the first two years, the cooperatives undertake intercropping with cotton and lentils also to add to the cooperatives income. JKPM buys the wood from this cooperative paying them a guaranteed price at mill gate.

CPM will, as part of its ESMS include procedures to obtain assurance that the decision to sell bamboo to them by the IP villages/communities has been approved by the gram sabha (village assembly) of the respective IP villages/communities in a manner consistent with Free, Prior, and Informed Consent (FPIC) principles.

JKPM will as part of its ESMS include procedures to obtain assurance that the two cooperatives’ processes for enrolling members and their decision processes are consistent with Informed Consultation and Participation (ICP) principles.

CPM and JKPM’s ESMS will include procedures for engaging with IP households directly as part of their respective farm forestry program. The procedures will require them to ensure adherence to ICP principles.

Stakeholder mapping and Stakeholder Engagement Plan

 JKPM  as part of its FSC policies have in place a Public Information Policy under which they commit to be transparent about their farm forestry operations to promote sustainable farm forestry. JKPM and CPM have as part of their IMS, procedure for receiving and responding to communication from external parties. Further, JKPM publicly discloses through the JK Paper website environmental clearance compliance reports, fly ash generation and utilization report, river water quality (upstream and downstream) monitoring report, groundwater quality monitoring report, environmental submission to pollution control board and corporate social responsibility spend related information. Stakeholder engagement activities are carried out by the community relations and corporate social responsibility (CSR) team (for community development, grievance collection and handling) and by the forestry team (for farm forestry purposes).

JKPL, JKPM and CPM do not have formally defined processes for stakeholder identification and engagement. While JKPM and CPM both have extensive corporate social responsibility programs and there is engagement with the communities in this context, there is no formal stakeholder engagement plan in place.

The company, JKPM and CPM will as part of their respective ESMS prepare a Stakeholder Engagement Plan (SEP) with stakeholder profile, identification of key concerns, expectations, impact and influence, and risk rating of various stakeholder groups. It will include details on engagement strategy, information disclosure, monitoring, reporting and guidance on maintaining records of stakeholder consultations. SEPs will be developed to ensure ongoing community engagement during current operations, and updated for construction as also and operation phases of any expansion projects. Further, as part of the SEP, the company will develop a plan for ongoing disclosure of information to key stakeholder groups.

Consultation

JKPM and CPM do not have formal procedures or guidelines for carrying out public consultations other than complying with the public hearing requirement for obtaining environmental approvals. There is consultation with local opinion leaders and villagers as part of the extensive CSR program implemented by JKPM and CPM. Appropriate mechanism for periodic and ongoing consultation with neighboring communities will be put in place as part of the SEP.

External Communications and Grievance Mechanisms

JKPL, JKPM and CPM have external communication procedure as part of their IMS. This will be further upgraded to cover environmental, OHS and social aspects and sharing of relevant information with neighboring communities on an ongoing basis. Further, JKPM and CPM will also put in place a formal procedure to: (a) receive concerns and grievances from members of affected communities; (b) communicate to affected communities the channels/means for  lodging concerns/grievances; (c) redress the grievances in a time bound manner; (d) upon redress communicate the decision to the aggrieved person/community; (e)  provide a mechanism to appeal against a redress decision in a higher joint committee if the aggrieved persons/community is not satisfied by the redress proposed in the first instance; (f) document grievances received and redressed; and (g) analyze grievance related data to identify patterns and undertake systemic improvements as needed. (ESAP # 7)

Information Disclosure and Ongoing Reporting to Affected Communities

JKPL will disclose this ESRS, ESAP and subsequently when it is developed, an outline of its ESMS through its website. JKPM and CPM will disclose the ESRS and ESAP to the neighboring communities in an appropriate form and language at a third party location nearby. Further, JKPM and CPM will periodically disclose information on status of implementation of the ESAP.

Considering the nature of the investment, JKPL will disclose this ESRS and ESAP through its website and these will also be disclosed in the local language and English both in Fort Songarh and Jaykaypur at the following address:

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

Contact Person: V. Kumarswamy

Company Name: JK Paper Ltd.

Mob: 9871394893Email ID: vkmr@jkmail.com

Facsimile: +91-11-23712680