There are no impacts of concern associated with the following Performance Standards: PS5: Land Acquisition and Involuntary Resettlement is not applicable since all the existing facilities are located on land that is either leased or purchased from private owners through willing buyer willing seller arrangements.  PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable since the Company’s activities do not impact biodiversity resources or negatively influence sustainable use of natural resources. E&S risk of commodities used in feed production is low and mostly procured locally. The Company does not use or procure any products/ingredients from sources that are listed as threatened or endangered. PS7: Indigenous People – No indigenous people are known to have been in areas or affected by projects being considered for IFC financing; PS8: Cultural Heritage – The projects being considered for IFC financing are not located in areas of known historical or cultural significance.

Because IFC’s proposed investment in the Company may be used to support future but, as yet, undefined projects in addition to the existing project, a condition of IFC’s investment going forward will be that the Company shall adopt IFC Performance Standards as part of the applicable legal and other requirements in all of its operations on an ongoing basis, and consider issues identified in PS1 through PS8 when assessing any new business opportunities, acquisitions or mergers, or business models.

If IFC’s investment proceeds, IFC will periodically review the Project’s ongoing compliance with the Performance Standards.

This is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy, as the proposed investment is expected to have limited environmental and social impacts which are few, site-specific, temporary and none regarded to be significant. Project related impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. The project is designed to avoid, minimize and manage environmental and social risks and impacts of the Company’s operations in compliance with applicable IFC Performance Standards and World Bank Group (WBG) General and sector-specific Environmental, Health and Safety (EHS) Guidelines for Poultry Production, Poultry Processing & Vegetable Oil Production and Processing.

Key E&S issues applicable to this investment are: consistency of EHS management across the different operations, including contract farming; EHS management on contract farms with respect to,  labor and working conditions, assurance of fair, safe and healthy working conditions for all workers; certified food safety management systems; optimization of water and energy use through project design and resource conservation measures and greenhouse gas emissions; wastewater collection and treatment, air emissions from incinerators, generators and boilers; solid and hazardous waste management, infectious / pathogenic waste handling and disposal, management and control of pests and vectors; emergency response and preparedness (biosecurity); and community engagement.

Environmental and Social Assessment and Management System: Srinivasa presently does not have a corporate level environmental and social (E&S) policy, but manages relevant E&S aspects within its existing management system which is commensurate with its current scale of operations. The Company’s focus to date has largely been on ensuring regulatory compliance for its facilities. The corporate level HR, administration and legal departments provide support to site management as per requirement. There are no regulatory requirements for Environmental and Social Impact Assessments (ESIA) for any of the existing facilities of the Company. The operating units of soya plant, feed plant, chicken processing plant (CPP), and the MFP (which is currently under construction) have relevant permits from the respective state pollution control boards (SPCB).   Technical staff who have been associated with the Company since many years are central to the informal E&S management system in use, while conducting operations in line with the regulatory requirements. Although none of the units currently have a formal environmental and social risk assessment process, some units such as the CPP has prepared a manual consistent with the requirements of ISO 9000:2005 (quality management system), HACCP based Food Safety System June 2006 (4th version), ISO 22000:2005 (Food Safety Management Systems), ISO/TS 22004 (Food Safety Management Systems – Guidance on the application of FSSC 22000), it is still in the process of achieving certification for the same. As agreed in the ESAP action item #1, the Company will develop and implement a comprehensive ESMS consistent with IFC Performance Standards (PS) requirements, with clearly defined lines of responsibility, monitoring and reporting functions, with Corporate Environmental Social and Governance (ESG) roles and responsibilities cascaded down to relevant operational levels. The combined ESMS will provide consistent oversight of environmental, social and health and safety aspects for all its operations, sub-contractors and supply chain, as well as have provisions for screening of new opportunities, product lines and business models among others. The Company through its corporate ESMS will establish and maintain a process for identifying the environmental and social risks and impacts of the project.  In case of any new greenfield facility to be developed, Company will conduct ESIA as required by the local regulations, or a full scale environmental and social impact assessment, a limited or focused environmental and social assessment, or straightforward application of environmental siting, pollution standards, design criteria, or construction standards. The process will consider all relevant environmental and social risks and impacts of the project, including the issues identified in Performance Standards 2 through 8, and those who are likely to be affected by such risks and impacts. The Company will hire a full time EHS staff at the corporate level and designate a qualified individual at each business line to ensure compliance with group E&S policies and procedures, IFC and regulatory requirements and to ensure consistency with good international industry practice for E&S performance. The corporate EHS manager will have adequate resources and support staff at each facility to ensure there is a program of continuous improvement that includes identification of E&S risks and impacts, training, monitoring, and reporting, and equally, communicating environmental and social aspects to external affected parties.

The potential EHS incidents which could result in emergency situations include grain dust explosions at the feed mills, poultry disease break-out, leakage and spillage of hazardous substances, ammonia incident, fires, fatal or serious accidents, and strike/riots/civil unrests. Currently the Company has not developed emergency response plan for its facilities. As part of ESAP action item # 7, the various operations of Srinivasa will develop emergency response plan clearly identifying potential EHS incidents that could result in emergencies and appropriate and adequate response to any emergency incident.

The Human Resources department at the Company has responsibility for overseeing matters related to labor, working conditions and health and safety. The Company provides training to all staff to ensure they have adequate training to perform their work. Training of staff is done on a routine basis in compliance with local workplace regulations. Supervisors monitor that standards are met and any reportable incidents are reported and follow up action taken when required. Outcomes of training, monitoring and reporting comply with applicable national regulations, and largely consistent with IFC PS1 requirements.

The Company’s monitoring and reporting program is largely responsive to regulatory requirements, such as on labor issues, environmental discharges and miscellaneous permit requirements. As part of the corporate level ESMS, the Company will integrate internal and external EHS monitoring and reporting provisions for timely and consistent oversight of risks and issues across the Company’s operations, including contract farming in the boiler integration business line.

Supply chain management: Key stakeholders for the Company are contracted farmers engaged in the broiler integration business line. The Company places day-old chicks with contracted farmers and provides specially formulated feed, veterinarian care and technical advice through the Company’s extension services. Contracted farmers are responsible for providing labor, and infrastructure, including utilities (such as electricity, water, waste and carcass disposal) and ancillary services. At the end of the growing period, the Company takes back grown-up broilers from the farmer per terms of the contract agreed upon. Engagement with contracted farmers has been primarily through the Company’s extension services and limited to biosecurity, productivity, quality and commercial terms only. To improve the EHS standards in the boiler integration operations, the Company will extend support to contracted farmers to improve their EHS performance in line with good international industry practices for the sector. As agreed in ESAP action #1 (v), the Company will develop and implement a Code of Conduct as part of the contract/registration process. For existing contracts, these will be added as contracts are renewed. The Company will also develop and implement a review and vetting process to ensure compliance with Company procurement policies and procedures as set forth in the Code of Conduct, with special emphasis on management of occupational health and safety risks, emergency preparedness and response in the event of an avian disease outbreak, elimination of labor risks such as child and forced labor, and not engaged in prohibited activities.

 The Company currently employs about 2500 staff across all its operations, which includes 600 contracted staff. The Company also employs about 380 daily wage workers who are primarily engaged for janitorial, loading/unloading crates and boxes, and general housekeeping, and an additional 190 non-muster roll (NMR) employees, who are directly hired by the Company, but do not have the same benefits as on-roll employees such as joining letter, pay slip, gratuity etc.; these workers are mostly engaged in layer and broiler breeding farms and hatchery. A common set of Company policies are applicable for all on-roll employees, and those classified under the ‘workmen’ category (means any person including an apprentice employed to do any manual, unskilled, skilled, technical, operational, clerical or supervisory work for hire or reward, whether the terms of employment be express or implied) are guided by the employee standing orders (regulatory requirement). Employment relationships are managed at the Corporate level by the Human Resources (HR) department, and at the facilities by designated staff. The HR function is structured at two levels: i) corporate HR (22 employees) comprising three major divisions namely payroll and operations, recruitment, learning and development; responsible for defining overall HR policies and procedures; and ii) regional level HR (8 employees) based out of Vijayawada, Vishakhapatnam and Nammakal; these are responsible for day-today HR and administrative related work.

The HR at the Company is guided by service rules and myriad standalone policies and procedures related to employees. These policies and procedures cover requirements as stated under the various local laws and regulations, including wages and benefits, working hours and overtime.  The company is working towards adhering to IFC Performance Standards 2 – Labor and Working Conditions by addressing the gaps identified. To ensure consistent implementation of the Company’s HR policies, the Company will undertake a comprehensive review of its HR policies, procedures and documentation with the objective of having a consolidated document applicable to all its employees, and include specific provisions for t, daily wage workers, and non-muster roll employees. As agreed in ESAP action #2, the review will be undertaken by an experienced external labor consultant. The scope of review and update to policies and procedures will include assessment of and addressing gaps in compliance with regulatory / statutory requirements and those with IFC PS2 requirements such as those on payment of wages (including overtime), working conditions, terms of employment, freedom of association and grievance mechanisms.

The Company ensures that child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. Although not explicitly documented, hiring practices and employment relationships recognize the principles of non-discrimination and equal opportunity, freedom of association and grievance redress. As agreed in ESAP action # 2(c), the Company will document a policy against hiring of any labor below the age of 18 years as well as a policy on forced labor which prohibits any use of forced labor, bonded labor in any form. The Company has a worker’s union for operations in Vishakhapatnam (Andhra Pradesh), which is registered under the existing laws (Union Act, 1961) and is recognized by the Company. There is no restriction on freedom of association at the Company. Employees are aware of their right to freedom of association and can collectively represent to the management any issues or grievances that they may have. All employees have the right to be part of a trade union or collectively organize, and may choose to do so at any time during their employment with the Company.

The Company has prepared detailed procedures for handling grievances related to sexual harassment at work place and has put in place the Internal Complaints Committee (ICC) in line with The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013. The Company currently has however, informal procedures for handling employee grievances. As outlined in ESAP action # 2(b), 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) gradually constitute ICC at various units (already existing at corporate level).  The grievance procedure will include provisions for the workers to submit the grievances anonymously.

The Company has a plan for accident prevention and worker safety in compliance with national regulatory requirements. Occupational health and safety (OHS) is managed by designated health and safety staff at each facility. All employees in the Company undergo a full training program at induction and subsequently on worker health and safety relevant to their job activity. Human resources department maintains permanent records of participation to ensure compliance. Facilities are audited annually by regulatory and insurance agencies. No fatalities or serious injuries have been reported at any of the Company facilities.

OHS programs are in place and include identification of occupational health & safety risks, job hazard analysis, implementation of controls, and monitoring of working conditions and accident statistics. Personal protection equipment (PPE) such as gloves, safety shoes and glasses, dust masks are provided to workers, which is commensurate with the nature of operations and potential safety hazards. As part of continued improvement, the Company will prioritize review of current safety practices prioritizing operations with higher intrinsic risk such as at the feed mill, and implement as needed facilities improvements, provision of safety equipment, appropriate safety signage, training and consistent use of PPE, workplace air quality for fugitive dust, noise and general working conditions. As part of ESAP action # 2, the Company will also include a review of potential risk to workers from exposure to biohazards and pathogens.

Facilities are subject to annual audits by regulatory agencies to monitor compliance with labor regulations. The Company has followed regulatory requirements for occupational health and safety and has recorded no significant lost time incidents or fatalities in its operational history. The Company conducts medical tests on a routine basis for compliance with regulations for food safety and hygiene for workers engaged in this sector, and annual medical check-ups for all its employees in compliance with regulatory requirements.

Main sources of air emission at the Company’s facilities are coal fired boilers (soybean plant and feed mill), rendering plant (at the CPP) and diesel generators used for contingencies. Boilers and generators undergo regular maintenance inspection to optimize efficiency. All diesel generators are provided with acoustic enclosure and stacks. Ambient air quality and stack emissions are monitored on a yearly basis or as specified in the permit conditions for the respective facility. The Company presently monitors emissions from boilers and generators to ensure compliance with respective state pollution control levels and going forward, as set forth in ESAP action # 3, will also monitor against applicable IFC/WBG EHS guidelines for point source emissions to atmosphere. Where incinerators are in use, the Company will review the design and operation of the incinerators to ensure consistency with GIIP, with an emphasis on adopting practices that eliminate the potential for the formation of dioxins and furans.  At the CPP, flue gases from the rendering plant are passed through a biofilter and scrubber for odor control.

At all the Company’s facilities, water is primarily obtained from groundwater wells. Annual consumption of water by the Company is estimated to be 1,300 kilo liters (KL)/day, with 100 KL/day used at the CPP. Several initiatives to conserve water are being implemented across the Company’s operations, these include installation of water flow meters in different areas such as boiler, feed water tank, domestic usage, slaughter area, rendering plant, canteen, screw chiller and ETP at the CPP. The Company is also working on increasing water use efficiency at other facilities and operations. 

Wastewater generated at the Company's facilities vary depending on the nature of their operations. Small quantities of effluent are generated from poultry growing operations and feed mill. Effluent from these operations mainly consist of wash water from housekeeping and reject water from pure water systems, and sanitary wastewater from staff quarters, toilets and food preparation areas. These effluents are either discharged directly to neighboring fields or through septic tanks. The CPP generates 80 KL/day of effluent which is composed of process wastewater from slaughtering operations, blowdown from cooling towers, sanitary wastewater from housekeeping, toilets and food preparation areas. At the CPP, the Company has installed water meters at various locations to monitor water usage with the objective of reducing consumption. Water consumption at the CPP is estimated to be 12.5 liters/bird, and electricity consumption is 0.52 kWh/bird which is in line with industry standards of 15 to 20 liters/bird and 0.4 to 0.6 kWh/bird. All effluents generated at the CPP are treated in an effluent treatment plant in compliance with local regulatory requirements prior to discharging into adjoining land owned by the Company. Stormwater is discharged to the environment without pretreatment.

The quantity and nature of solid, hazardous and pathogenic waste generated at the Company's facilities vary depending on the nature of their operations. Waste generated at the feed mill and soybean plant include hydrocarbons, disinfectant drums and rags, plastic and cardboard paper, which are disposed by licensed third party vendors. Waste produced from the Company’s poultry operations primarily include litter, hatchery waste and carcasses. These waste streams may contain biohazards or be pathogenic. Litter from the poultry sheds and waste from the hatcheries are sold to local farmers for use as fertilizer. Carcasses are either buried in pits, or burned in incinerators where available. Ash and other residue is disposed to agricultural land. Waste from the CPP mainly includes blood, viscera, feathers and other rejects from the slaughterhouse which are sent to a rendering plant on site for further processing into by-products that are sold to vendors for use in preparation of animal and aquatic feed.

Hazardous materials in use include hydrocarbons, cleaning/disinfection products e.g. formalin, paint, LPG gas, liquid nitrogen, ammonia, and veterinarian products such as potassium permanganate for prevention and control of poultry disease.  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. Limited quantities of biohazard and potentially pathogenic waste is also generated and sometimes informally transported off-site to laboratories for analysis. As agreed in ESAP action #4, for its own operations and contract farmers, the Company will develop and implement policies and procedures for management of biohazards and pathogenic wastes/materials consistent with GIIP, and protective of public health and environment.

Principal energy usage includes electricity procured from the grid which is estimated to be about 12.9 million kWh annually, of which about 10% is generated from renewable energy sources (solar). Annual consumption of coal is estimated to be 6600 MT, annual briquette consumption is around 1500 MT and annual diesel usage estimated to be about 0.18 million m3. It is estimated that the Company’s current usage of electricity and fossil fuels results in emission of about 27,000 tons of CO2 equivalents annually. Since net greenhouse gas (GHG) emissions attributable to the Company’s annual consumption of electricity and fossil fuels exceed 25,000 metric tons of carbon dioxide equivalents per year, the Company is required to review energy usage at its facilities, and explore opportunities for improving energy efficiency in its operations to reduce operational cost and its carbon foot print. The Company will also monitor and report on an annual basis its net GHG emissions using internationally acceptable methodologies for quantifying such emissions.

The Company does not have any specific procedure for pest management and vector control. The Company as part of corporate level ESMS (ESAP action# 6) will prepare a management system procedure for pest and vector management. The procedure will aim to eliminate the use of WHO Class 1a and 1b chemical formulations, if any being used in their premises. The Company will ensure mandatory training to workers and ensure provision of adequate PPE based upon Material Safety Data Sheets - MSDS and/or International Chemical Safety Cards - ICSCs for the materials used. This consideration will be added in employee’s OHS training programs to be developed as part of corporate ESMS.

 Engineering controls and staff training mitigate risks of transmission of avian influenza or other related communicable diseases. The Company has a strong biosecurity program for all its operations that details a set of procedures to be followed to minimize the harm of any outbreak of diseases at its farms. However, the biosecurity program does not cover contract farmers in its boiler integration business line who lack the technical knowledge or capacity to mitigate risks of transmission of diseases. Importantly it also lacks a clear strategy for communication and emergency response for communities who are potentially at risk from the Company’s operations. The Company is required by local regulatory requirements to have emergency prevention and control plans which specifies responsibilities, ensures appropriate response equipment and materials are in place to minimize the harm of any potential outbreak of disease.

As agreed in ESAP action #7, the Company will develop specific plans and procedures for emergency preparedness and response for its own operations as well as contract farmers. The Company will review its scope of emergency response and update procedures as needed, including drills to test the effectiveness of its program, and include a community involvement component that addresses appropriate behavior and safety measures to be implemented in the event of an outbreak beyond the facility boundaries, including during transportation of biohazards/pathogenic materials. The Company will also undertake a review to ensure that public health care facilities are adequately equipped and staff trained to handle any large-scale outbreak of avian influenza or other related communicable diseases. Where poultry litter and bedding material are disposed or sold to farmers for land application, the Company will educate farmers and provide training on good management practices to safeguard human health and protection of surface water and groundwater.

No local community have been significantly affected by environmental risks or impacts from the Company’s ongoing operations, and the Company has not been the subject of any public complaints or litigation with respect to its environmental, social or health and safety performance. Dialogue and communication with affected communities, including public consultation and disclosure of environmental and social impact assessment, occurs typically through procedures established by local authorities. To strengthen its consultation and communication processes with concerned communities on the E&S risks of its operations and to streamline its stakeholder engagement process, the Company will develop a Stakeholder Engagement Plan (SEP) that includes stakeholder identification, mapping, profiling, influence and impact of these stakeholders to the Company’s operations as well as proposed frequency of engagement and provision for documentation of the outcome of the engagement processes (ESAP action #1).

The Company has been actively involved in Corporate Social Responsibility (CSR) activities in education (distribution of notebooks/ train the trainer), sustainable agriculture (soil fertility/capacity building workshop for farmers), health & hygiene (health camp for villagers, water & sanitation), environment protection & supporting wildlife conservation. The CSR activities through direct intervention or capacity building programs are spread out across various villages in AP and Telangana.

For more information contact:

Srinivasa Farms Private Limited

Mr. Ganesh Uppala

Director - Finance

Plot No 82, Kavuri Hills- Phase 2

Madhapur, Hyderabad

Telangana – 500081

India

Tel: +91 40 2363 3500

E-mail: contact@srinivasa.co

Website: http://srinivasa.co/