TTL has over 2000 third party workers across all its facilities engaged in non-core activities such as loading, unloading, housekeeping and canteen service. These workers are hired by the company through the labour contractors.

Working Conditions and Management of Worker Relationship:
The HR function is structured at two levels: i) corporate HR responsible for defining overall HR policies and procedures; ii) facility level HR responsible for day-today HR and administrative related work.

Human Resources Policies and Procedures, Working Conditions and Terms of Employment:
The human resources management at TTL is guided by its HR policy, code of conduct and internal operating policies and rules. The HR manual includes recruitment policy, training policy, probation policy, leave rules, and retirement policy. The internal operating policy document covers statutory aspects such as working Hours and attendance, gratuity, labour welfare fund, employees' state insurance (ESI) provisions, provident fund, etc., while the code of conduct covers aspects such as personal communications, anti-corruption and anti-bribery. The employees are provided joining letter which mentions the terms and conditions of employment.
As a part of the internal operating policy, the company stresses on compliance with applicable legal requirements. The company will review the employee standing orders as well as the terms and condition of employment for the direct workmen and CIPET employees as per the legal norms as well as per the IFC PS 2 requirement (refer ESAP#3). 

Overtime Hours:
At the moment, the company does not have an overtime policy, either for direct workmen or contract workmen working at TTL units. The company will develop an overtime policy consistent with the applicable regulatory requirements and shall provide the information to the employees and workers as per IFC PS2 requirements.
The company has developed a plan and is working towards ensuring that overtime hours are brought within permissible limits and overtime payment is consistent with the regulatory requirements (covering both regular and contractor employees) in a phased manner as outline in ESAP #4. To achieve full compliance, TTL is preparing a facility-wise plan for salary correction and working hours reductions throughout the group. The implementation of the overtime policy and progress of the phased plan will be validated through a specialized third party.

Non-Discrimination:
The Company has an equal employment opportunity policy which mentions that employment opportunities will be provided without discrimination on the basis of age, sex, religion, race, disability, marital status, national origin, or disability. The policy also mentions about providing reasonable job accommodation for persons with disabilities who can perform the essential functions of the position for which they are qualified and selected.

Child Labor and Forced Labour:
The company has a policy against hiring of any labour below the age of 18 years. The company also has a policy on forced labour which prohibits any use of forced labour, whether in the form of prison labour, indentured labour, bonded labour or otherwise.

Workers’ Organization:
The company has worker union at 2 units (Hosur & Mahad) presently; although the company policy states that employees are free to choose to join a trade union in accordance with local law and the rules of the various trade union organizations. 

Training and Human Resources Development:
Daman units have a training calendar based on the training needs of different employees, and consists of safety awareness, internal on-the-job trainings and aspects such as ISO 14001 basic awareness, EOHS policy, occupational health and safety, fire safety PPE usage, emergency response etc.
At the Daman units, all contract workers are provided EHS induction before start of the work, while for routine activities, the contract workers are trained on the job. The company, as a part of the corporate ESMS document, will prepare SOP for training need assessment and training identification for various levels of staffs and workers depending upon the roles and responsibility (refer ESAP#1). The corporate EHS team at the corporate level will also be responsible for developing training materials for common topics such as machine safety, electrical safety, fire-fighting, safe raw material handling storage and movement, PPE usage, which will be uniformly implemented across all the TTL units.

Grievance Mechanism:
The company currently has informal procedures for handling employee grievances including those related to sexual harassment. As outlined in ESAP#3, the company will i) develop and implement a documented grievance handling procedure covering both employees and contract workers in accordance with the requirements of this performance standard; and ii) constitute the Internal Complaints Committee in line with The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013.  The grievance procedure will include provisions for the workers to submit the grievances anonymously.

Retrenchment:
The company presently has a separation policy applicable for the employee who wishes to resign from the services of the Company. The company does not envisage any retrenchment and offers the employees the option of transfer to other facilities of the company. TTL will develop retrenchment policy as part of the HR policy manual which will establish the requirement for developing a plan for addressing retrenchment if the need arises (refer ESAP#3). The plan will be based on the principle of non-discrimination, and will reflect the
company's consultation with employees and their organizations (as relevant).

Worker’s accommodation:
The company provides accommodation facilities to the staffs and in some case the direct workmen, mostly in the apartments and housing societies. The company provides labour accommodation to the contract workers in some of the locations such as Vadodara and is planning to provide the same in Silvassa. The company will develop guidelines for the labour accommodation either to be provided directly or through the contractors (especially during the construction stages). The labour accommodation guidelines will be developed as part of the contractor management system and will be used directly in case of TTL provided accommodation, both for existing accommodation as well as for any future labour accommodation facilities (refer ESAP#3).
Occupational Health and Safety:
Daman facilities (Unit 2, 7 and 8) with ISO 14001 certification and OSHAS certification (Unit 7), have conducted risk assessment for their operations in line with the procedures included in the IMS manual. Safety induction and regular training is provided to employees, workmen and contract workers. Personal protection equipment (PPE) such as gloves, safety shoes, masks and glasses is provided to all the workers on the shop floor, which is commensurate with the nature of operations and potential safety hazards, however enforcement
of PPE usage needs to be strengthened at all the facilities.
The company follows a work permit system and which is also adopted by contractors. Lock Out and Tag Out (LOTO) process is implemented at the facilities. The shop floor in all the visited facilities is properly maintained; however, the company needs to improve the housekeeping in raw material storage areas, screen painting, and wooden crate preparation area as it has direct implications for emergency response (refer ESAP#1). The company will ensure that all the units of TTL have fire NOC from the relevant town planning authorities and the NOC conditions will be included in the respective site level ERP.
Going forward, the Corporate level ESMS will include the hazard identification and risk assessment (HIRA) process for all the activities related to TTL units such as raw material handling and storage, machine operations including but not limited to blow molding, injection molding, wooden and plastic crate manufacturing, screen painting, finished products storage, waste storage and disposal including solid and hazardous waste and liquid effluent. The corporate ESMS will also include SOPs associated with various operations as identified through HIRA and aspect impact register for all set of activities at TTL Units (refer ESAP#1).
There is a safety committee in place at the facility level, as per the requirements of the Factories Act. The safety committee has representation from the management, staff and workers which reviews the concern of the workers and other related issues. The company will develop a corporate level EHS/ ESMS committee and a unit level EHS/ ESMS committee, for each unit which will review safety performance on a regular basis (refer ESAP # 2). The site level EHS committee will report to the corporate level EHS committee on a monthly basis
on EHS aspects including accidents/incidents, near-misses, first-aid cases, EHS training, fire incidents. There is an incident reporting mechanism in place which records all accidents and accident investigation report is prepared after site investigation and root cause analysis. Adequate first-aid is available at all facilities and records are maintained for the first aid incidents. The incident reporting mechanism will be updated to include first aid cases, near misses and lost time accidents along with cause of accident, immediate action taken and corrective action required (refer ESAP #1).

Workers Engaged by Third Parties:
The contract workers terms and condition of the employment are governed by the contract agreement between the company and the labour supply contractor, which also refers to the various labour provisions including the contract labour act and associated rules apart from other local labour laws applicable in the country. The company will hire the services of an experienced labour consultant to review the existing contractor practices and ensure contractor legal compliance across all units of TTL (Refer ESAP #4)

Supply Chain:
TTL primarily sources polyethylene and Propylene as raw material and is mostly sourced from middle east countries. TTL has put in place a code of conduct for suppliers to ensure compliance with all applicable laws, including laws relating to employment, the environment, health and safety. TTL reserves the right to reject suppliers who do not comply with the law.

IFC’s assessment considered the company’s operations regarding resources consumption (water, energy, fuel), efforts to optimize resource inputs, waste minimization and management practices as well as the storage and handling hazardous materials used in the construction and operations of facilities.
For all the processes the technology that will be applied has been developed by, TTL and in all the cases the technology has been selected considering material and energy saving and high quality of the final products.

Resource Efficiency:
The company monitors and consolidates the energy consumption data for all its units. The company also has sewage treatment plant (STP) and in some cases effluent treatment plant (ETP), where the treated wastewater is then re-used.
The company has taken initiatives for energy conservation which include: installation of AC drive on hydraulic motor, reduction of flash length, arresting of air leakage, replacement of lamps with energy efficient LED lighting, installing lighting energy savers, use of efficient compressor system, etc. The company has initiated undertaking internal energy audit of its facilities and documents annual resource and energy consumption data including electricity, water for its Daman units.

GHG emissions:
Primary energy requirement is that of electricity which is supplied from the national grid. Diesel fueled generators are installed on site as backup generators, and are in use in case of power failure. Therefore, the facilities of TTL are expected to produce GHG emissions around 100,000 tonnes per annum of CO2e (this includes direct and indirect emissions- direct emissions of GHGs from the client’s operations and arising from within the physical boundary of the project are referred to as Scope 1 emissions, while those associated with off-site production of energy used by the project are Scope 2 emissions).

Air Emissions and Ambient Air Quality:
TTL’s operations involve primarily process of blow molding, injection molding, extrusion molding; and electricity procured from the grid is the major source of energy. Main source of air emissions for TTL’s facilities are the diesel generators, which are only used as backup power supply and thus the emissions are not significant. All diesel generators are provided with acoustic enclosure and stacks.
At each of the facilities, there are shredders for the rejected products which are to be reused for molding operations. The dust bag collector is currently used for collecting the dust in the shredder area. Ambient air quality and stack emissions are monitored on a yearly basis or as specified in the permit conditions for the respective facility. Stack emission and ambient air quality monitoring results are compliant with the limits specified for the facilities by the State Pollution Control Boards and with the National Ambient  Air Quality Standards (NAAQS).

Water Consumption and Wastewater:
Water is primarily used for cooling and domestic purposes and is sourced from borewell or municipal or industrial authorities. Very small quantity of process wastewater is generated (water used for drop test and for the cooling process), which is again reused in the system. Treated water quality monitoring is undertaken regularly.
Silvassa, Unit 1 uses water for washing the containers post the screen painting, the containers are washed post the screen painting. The company has installed an ETP for the treatment of the water released from the painting process at Unit 1 in Silvassa; the company will review the requirement of ETP as highlighted in the regulatory permits for various units and shall make necessary upgrades to ensure compliance with the permit conditions. Domestic wastewater is either treated in STP or disposed to septic tanks and soak pits as per the permit conditions. Storm water from clean surfaces is collected and discharged through separate drainage systems.

Noise:
The source of noise includes various machines and equipment. Ambient noise monitoring is done on quarterly basis by third party while workplace monitoring is done in-house monthly. Noise levels were observed within the permissible limits. PPE usage needs to be improved and enforced strictly especially in high noise areas.

Wastes:
Solid waste is segregated and collected in designated bins and sent for disposal to municipality operated facilities. The company will ensure that hazardous wastes generated (such as used oil and discarded containers) are stored in designated hazardous waste storage area and sent for disposal to authorized contractors as stipulated by local regulations; transfer records and chain of custody records will be maintained (refer ESAP).