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 

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts 
PS 2 - Labor and Working Conditions 
PS 3 - Resource Efficiency and Pollution Prevention 
PS 4 - Community Health, Safety and Security 

PS5, Land Acquisition and Involuntary Resettlement is not applicable as proposed capital expenditures will be within JISL’s existing premises. During the appraisal, it was noted that the company has recently purchased land for proposed facilities in Kurnool (in Andhra Pradesh) and Morshi (in Maharashtra) from the respective state governments. 

As per information received from the company, the land in Kurnool (~600 acres) was part of a larger area (~2000 acres) owned by the National Seed Corporation and was later transferred to Andhra Pradesh Industrial Infrastructure Limited (APIIC).  The land was undeveloped and was allotted to JISL by APIIC in June 2017 as part of larger industrial cluster that APIIC is developing in Kurnool. 

Similarly, as per the available information, the land in Morshi (~97 acres) was part of the land acquired for Upper Wardha irrigation project (dam constructed in 1993). The land was lying unused since then and was purchased by JISL in an open government auction in May 2017. JISL confirmed that purchased lands are free of settlements or people dependent economically on the land; therefore, no physical or economic displacement is expected due to these land purchases. For review of any future land purchases, as set forth in the ESAP (#3), the company will develop a land screening procedure in line with IFC Performance Standards especially PS5 and in case any of the aspects are evaluated to trigger need for further assessments, the company will undertake required assessments before purchase of such land.

PS6: Biodiversity Conservation and Sustainable Natural Resource Management is not applicable because JISL facilities are situated in well-developed industrial areas or on land earmarked for industrial use. In these locations, there are no impacts on biodiversity, and no natural habitats are converted for plantations. 

PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable for the project because neither indigenous peoples or culturally sensitive sites are present.  

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 issues related to this project includes: company’s staffing, systems and procedures to assess and manage E&S risk and impacts of the project during both construction and operations; assurance of fair, safe and healthy working conditions for all workers including contract workers; utilization of equipment and operational practices that maximize conservation of energy, water and process materials including recycling and reuse initiatives; management of air emissions, wastewater treatment and effluent discharges in compliance national standards and World Bank Group (WBG) Environment, Health and Safety (EHS) guidelines, and solid and hazardous waste disposal community safety during construction and operations; and screening of land with respect to PS5 requirements before purchase.

Environmental & Social (E&S) Assessment: As JISL’s expansion is limited to owned premises, as per applicable requirements, the company will not need to conduct an E&S impact assessment (ESIA). Also, for the new facilities, the company does not need to complete an ESIA as the food and plastic facilities are not covered in the 2006 EIA Notification. However, the area of land for the facility in Kurnool is significant (600 acres or 2.4 million m ²), and the company will evaluate the applicability of the environmental clearance requirement for construction projects above 20,000 m ²  and/or development area above 50 hectares (500,000 m ² ).  In case required, the company will meet the requirements for obtaining the environmental clearance.  The company obtains required E&S permits for its facilities e.g. Consent to Establish/Operate, Hazardous Waste Authorization, and Factories License and ensures compliance with the same. Also, under the environment, health and safety management systems described below, the company completes a risk assessment for all its operations. 

E&S Policy, Management Systems, Identification of Risks and Impacts: The company has an environmental, occupational, health and safety (EOHS) policy. Each division develops its own policy based on the corporate policy. 

All JISL Indian facilities have implemented management systems in accordance with ISO 14001 (environmental management) and OHSAS 18001 (occupational health and safety (OHS) management) requirements. The plastic and food facilities in Jalgaon and other facilities have energy management systems certified in accordance with ISO 50001 requirements. JISL’s Turkey facility has environment and OHS management systems. The Israeli operation has an environment management system and is in the process of implementing the OHS management system. Few of the remaining overseas facilities are implementing these management systems.

Impact analysis, hazard identification, and risk assessment are carried out for various operations under these management systems. The required policies, procedures and management programs are developed to fully implement required actions to achieve the objectives in E&S policy statement. The company has documentation at three levels: APEX (Corporate Level), Facility Level and Department Level.  Existing documentation was well organized and adequate in coverage.   An annual E&S training calendar is prepared for each division and E&S training is provided at all facilities. Based on previous and recent visits to JISL facilities, management systems are adequately implemented.

The company has also implemented Jain Good Agricultural Practices (GAP) standard, which is a modified/simplified version of the GLOBAL GAP standard, which constitutes achievement of food safety in raw materials production, in its contract farming supply chain.

Organizational Capacity and Competency: Sustainability at JISL is driven by the Sustainability Committee of the Board of Directors, that monitors implementation of various sustainability related initiatives at the company. The company has a full-time team of qualified professionals for oversight of EHS aspects. The EHS heads for plastics, food, and other divisions at Jalgaon are also responsible for management of E&S aspects at respective facilities of their divisions in India. The EHS staff at facilities report to the EHS heads. The Sustainability Manager, in addition to being responsible for overall sustainability monitoring and reporting, is responsible for coordination with overseas facilities for implementation of management systems. A corporate team is responsible for implementation of Jain GAP in the supply chain. Finally, in compliance with regulatory requirements, JISL has a corporate social responsibility (CSR) committee for development and implementation of company’s CSR policy. 

Emergency Preparedness and Response:  JISL facilities have a documented emergency response plans. Required emergency response infrastructure includes identified emergency routes, exit markings, marked assembly points, fire alarms and firefighting systems. At Jalgaon & Hyderabad, the plastic parks have a fire hydrant system. The similar fire hydrant system was installed at food facilities at Chittoor and at Jalgaon, the installation work is under progress in the food park. The company has an occupational, health center, ambulance and fire tender at Jalgaon. Regularly conducted mock drills take place at the facilities and the results are reported in the AMR for all facilities. 

Monitoring and Review:  JISL has a monitoring and reporting program covering all its facilities. Ambient air quality, stack emissions, ambient noise, effluent quality and indoor air quality are regularly monitored at all facilities in accordance with both host country requirements and WBG EHS guidelines. Also, water consumption, effluent discharges, hazardous and other waste generation is monitored at all facilities. 

All accidents/incidents are monitored and investigated. Based on these monitoring activities, the facilities send regular reports to the EHS heads at the corporate level. Management review meetings are conducted annually for all facilities under the environment and OHS management systems. In accordance with the ESAP (ESAP #1), the company will develop an E&S dashboard with reports on various E&S key performance indicators (KPIs) to facilitate and enhance understanding of reporting by all facilities.  

Trained auditors conduct regular internal audits at each facility, with the corporate EHS heads participating in some of these audits as observers. The EHS heads follow-up with the respective facilities to ensure completion of required corrective actions, and present results to management. Annual surveillance audits are conducted by authorized Certification Bodies. Internal audits are conducted for sites where the company is installing MIS systems or irrigation projects.

JISL reports its E&S performance in independently verified Sustainability Reports aligned with the Global Reporting Initiative (GRI) guidelines and published on the company’s website ( www.jains.com ). The 2016 report documents company performance for the period covering 2013-2016. Following the Stock Exchange Board of India’s disclosure requirements, and as part of the annual report, a business responsibility report is published that explains environmental, social and governance initiatives taken by the company during the previous year; the most recent report addressed the period covering 2016-2017.     

JISL currently has a global workforce of approximately 11,000 including ~1000 at its overseas facilities. Similarly, ~5000 contract workers are employed at company facilities including about 300 at its overseas facilities. 

Human Resource Policy, Working Conditions and Terms of Employment:  JISL incorporated its HR policy and implementing procedures in a manual. The manual includes specific company requirements on non-discrimination, freedom of association, prevention of child labor and forced labor and a worker grievance mechanism. The policy and implementing procedures are consistent with the country legal and PS2 requirements. The policy and procedures are communicated to all workers during induction and through their appointment letters. The company has HR professionals, who are responsible for implementing JISL’s HR policy, and are deployed at each of its facilities.

Non-discrimination:  The company is an equal opportunity employer and has a specific policy on non-discrimination.

Prevention of child and forced labor:  The company has a specific policy on prevention of child and forced labor. Age proofs are collected for employees and contract workers. No instances of child labor or forced labor were reported by the company during the recent as well as previous supervision visits. 

Freedom of association and Grievance mechanism:  JISL has a documented policy on freedom of association and does not restrict workers to organize or collectively bargain. Currently, the company does not have a union at any of its facilities. Worker participation committees are formed at facilities that have equal representation of workers and management and are tasked to discuss and resolve workplace issues.   

The company has a documented grievance mechanism that utilizes multiple forums to receive grievances based on the type of grievance. Also, the company has suggestion and complaint boxes through which workers can submit grievances anonymously.  Grievances are reviewed by HR department and escalated in case resolution is not achieved at the level of HR. Necessary actions are taken to address gaps. 

As per applicable legal requirements, the company has formulated and implemented an anti-sexual harassment policy and an internal complaints committee (ICC) including female employees and an external member has been constituted. 

Occupational Health and Safety: The company completes an OHS risk assessment for all its operations in accordance with OHSAS requirements.  Safety instructions are displayed at the machines.  The company has rolled out key programs on OHS including work permit system, lock-out-tag-out and accident/incident investigations.   The company has safety committees comprised of both worker and management representatives, which meet on a regularly basis to develop and implement OHS corrective action plans.  Personal Protective Equipment was deployed at locations visited and equipment noted to be adequate. In terms of housekeeping, work areas are clearly demarcated and safety signage displayed throughout the plants. 

The sustainability report states that lost time injuries (LTIs) reported in the last three years up to 2016 are seven to nine and no fatalities have been reported till 2016. For 2016-17, eight LTIs (with 69 lost work days) are reported at Plastic facilities and no injuries are reported at any other divisions (with 18.36 million man-hours worked) of whereas only minor or first-aid injuries are reported at the overseas facilities. This is below the Occupational, Safety and Health Administration (OSHA) benchmark for plastic materials and resin manufacturing (compared with it since injuries only belong to plastic facilities). All accidents and incidents are investigated to identify corrective and preventive actions. In November 2017, there was a fatality reported at a warehouse in the food facility in Jalgaon, where a security guard died in an electrical fire. During the appraisal, the company informed IFC that it conducted a detailed investigation of this accident and has started implementing the corrective and preventive actions.   

Third party workers: JISL signs agreements with contractors to comply with the legal requirements and adhere to JISL’s EHS procedures and requirements, including those related to child and forced labor.  The contract workers mark their attendance manually on cards. JISL ensures payment of wages in presence of an HR representative. JISL’s HR department representatives review required documentation to ensure that third-party workers are provided all legal benefits.  As part of its management system, JISL monitors the EHS performance of its third-party workers as well as includes them in the EHS training. 

The company is constructing several MIS installation, irrigation and urban water projects; and will undertake construction at its new facilities. JISL’s needs to hire external contractors and sub-contractors for such works and currently only basic EHS provisions are included in contracts. As set forth in the ESAP (ESAP #2), the company shall prepare and implement an EHS procedures manual for construction activities as well as a monitoring procedure to ensure oversight and follow up on contractor EHS performance. The manual will include the following: 

(i)   clear EHS and working conditions requirements (in line with IFC PSs and legal requirements) to

       be implemented at the site; 

(ii) clear roles and responsibilities of company, PMC and contractors’ personnel for implementation

       and monitoring on-site aligned with the IFC PSs;  

(iii)  consequences of non-compliance for the contractors and their method of implementation;  

(iv)  requirements on labor law compliance including prevention of child labor;

(v)   labor camp guidelines in line with the IFC guidance note on workers’ accommodation (though considering the location of the site, no labor camp is expected on-site); and 

(vi)  construction management practices to minimize the impact on neighboring communities.

The EHS manual shall be included in the contracts signed with the contractors to ensure that the contractors act in a manner consistent with the requirements of the IFC PSs. 

Supply Chain for Agribusiness Operations: The company purchases several agricultural commodities like bananas, mangoes, pomegranate, oranges, onions and strawberries for its processing operations. Most of the agricultural commodities (used as raw materials for food processing) are sourced through local traders and some are sourced from captive production e.g. mangoes. 

For onion sourcing, the company has 5000 contract farmers who meet part of JISL’s sourcing requirements whereas the rest is met through purchases in open markets across India. The company provides technical and financial support for contract farmers. The company has implemented Jain GAP in its contract farming supply chain, which includes prevention of child and forced labor as well as mandatory use of personal protective equipment (PPE) for application of pesticides.  A sample of farmers are audited with respect to Jain GAP every year. Also, JISL’s customers conduct external audits using its own requirements. The supply chain management practices are noted to be consistent with PS2 requirements.  

Resource Efficiency: The company’s MIS division promotes water and energy conservation. Also, the company produces solar water heating, pumping and lighting systems contributing to overall energy conservation. JISL estimates the positive impact of water and energy conservation due to use of its products and reports these data in the Sustainability Report. The latest report dated 2016 estimated ~55 billion m3 and 1 billion kWh of water and energy savings due to use of its products by its customers.  

All JISL facilities have objectives on water and energy efficiency and thus implement several resource efficiency initiatives. Various energy and water conservation measures are disclosed in the Sustainability Report. Recently, the company switched from coal to mango seed fuel at its food facility in Chittoor, in Andhra Pradesh. The results of these initiatives are discussed below and also reported in the sustainability report.

Power Supply and Air Quality: Electricity is sourced from the grid for all the JISL facilities, and diesel generator sets provide backup power where required. Diesel fuel is stored in secured tanks with adequate secondary containment. At Jalgaon, the company has an 8 MW solar power plant as well as 1.67 MW biogas based power plant. Required pollution control equipment is incorporated into coal or biomass based boiler systems.   

The facilities conduct regular ambient air quality and stack emission monitoring. The available results reviewed during appraisal indicated compliance with the national standards and WBG EHS guidelines. The results are disclosed in the Sustainability Report.

Water Supply and Effluent management: JISL sources water from its own ground water wells or from municipal or industrial sources from the areas in which they operate. Also, at Jalgaon, the company has a network of check dams/embankment dams and ponds from which the collected rainwater is utilized for operations. As per company’s recent sustainability report, the water usage was about 1.6 million m ³ and 81,000 m ³ in India and overseas operations, respectively with 46% and 57% water recycled for various uses, respectively.

Effluent treatment plants (ETPs) are established at the facilities for treatment of industrial effluent; effluent quality is tested regularly and results showed compliance with the national standards and WBG EHS guidelines parameter limits.  Domestic sewage is disposed in septic tanks and soak pits. 

Solid and Hazardous Waste:  Agricultural product processing waste is used for bio-gas generation and as a fuel in the boiler at the Jalgaon facility whereas part of the biomass is used. All hazardous waste is disposed through authorized entities in a secure landfill or for regeneration or recycling at all JISL facilities. General scrap and other non-hazardous wastes are segregated and sold to recyclers. 

Hazardous materials management:  Fuel (diesel) and hazardous chemicals are stored with adequate secondary containment at JISL facilities. Ammonia is used as a refrigerant at the food facilities in Jalgaon. The company deployed an Ammonia sensor and provides required PPE and leakage repair equipment. Instructions for emergency response have been prepared and are included in training. 

Greenhouse Gas (GHG)Emissions : the company calculates its GHG or CO2-equivalent emissions. GHG emissions are estimated at 300,000 tonnes of CO2 equivalent (tCO2) (about 128,000 tCO2 direct and 172,000 tCO2 indirect) for 2015-16.  The company also reports to offset ~10% of its GHG emissions through its plantations and use of green energy.  

Integrated Pest Management JISL ensures no pesticides under WHO hazard class Ia, Ib or II are used neither on its own farms nor on contract farming operations. JISL has been implementing Integrated Pest Management (IPM) and Integrated Vector Management (IVM) programs in its contract farming operations through its extension services as well as on its own farms, to reduce reliance on chemical pesticides. 

The company has procedures to assess potential community impacts of its projects and operations; mitigate identified risks and impacts including risk of uncontrolled release of hazardous materials from its operations or in hazardous materials transport.  These precautions include process chemicals, fuels, fumigation chemicals, etc. JISL has also prepared and implemented an onsite and offsite Disaster and Emergency Management Plan. 

The company employs armed security guards at its Jalgaon facility who are JISL’s full-time employees. JISL’s procedures require checking the past records of security personnel for abuse an inappropriate behavior. Specific instructions are in place to ensure proper storage and use of arms and ammunition. Written instructions on use of force have are available and posted in the security office.  Further, JISL trains its armed security personnel in avoidance of human rights violations and the use of fire arms to comply with IFC’s PS4.                                                   

The company has a stakeholder engagement process which is described in detail in the Sustainability Report disclosed by the company on its website (www.jains.com). The process has clear identification of stakeholders and multiple forums of stakeholder consultation including for example awareness programs and farmer meetings which include non-governmental organizations (NGOs), academia and customers; capacity building and training for farmers from different states, government officers, other private companies, academia, students, dealers and associates. Additionally, a team of 100 Gram Sevaks (agronomy support team) stay in villages and support onion and banana growing farmers for seed sowing/tissue culture planting, fertigation, good agriculture practices (GAP) implementation and harvesting practices. Also, the company has supplier meetings, customer meetings, community development/CSR activities, engagement activities for their associates and families.

JISL’s corporate philosophy is doing business with a corporate social responsibility mandate perspective and has an extensive CSR program, comprising various components such as rural development, education, health, Jain Sports Academy, community events and climate change. In addition, Sustainability, business responsibility and CSR reports are disclosed through company website  www.jains.com. 

The company will disclose this ESRS and ESAP at its website:  http://www.jains.com, as well as locally at the following addresses:

Jain Irrigation Systems Ltd.  

Jain Plastic Park

N.H. No.6. P.O. Box:72

Bambhori, Jalgaon – 425001 

Maharashtra, India.

Tel :  +91 - 257 - 225 8011 

Fax : +91 - 257 - 225 8111

All inquiries and comments on the project may be directed to:

Mr. Atul B. Jain, Chief Financial Officer  
 Jain Irrigation Systems Ltd. 
 7, Kumtha Street, Ballard Estate, 
 Mumbai – 400 001 India

Telephone: +91 22 22610011 
 Fax: +91 22 22621177