Environmental and Social Assessment and Management Systems:
Assessment:
Signature identifies the land for development as earmarked in master plan and designated for affordable housing by the directorate of town and country planning (DTCP) for which it issues public notice inviting application for affordable housing projects. As per the affordable housing policy, maximum land allocated for affordable housing projects ranges from 5-15 acres. Signature accordingly performs a due diligence of potential land which includes review of land titles by a legal firm. Signature is committed to purchasing land in principle through willing buyer seller transactions. Also, only land zoned as residential under the development/master plan of Haryana will be purchased for all the affordable housing developments.
Signature follows the local legal requirements for design, development and construction of the housing developments, including the specifications defined in the Master Plan, National Building Code of India (NBC) and requirements stipulated by the Ministry of Environment, Forest and Climate Change (MoEFCC). It obtains relevant permits such as environmental clearance (EC) from state environment impact assessment authority for all its projects prior to start of construction and which entails submission of Form IA for projects where built-up area is less than 150,000 m2 and Environmental Impact Assessment (EIA) for projects where built-up area is more than 150,000 m2 in line with the local regulatory requirements.
An accredited architect or engineer endorses the design, including structural and fire safety aspects, before it is submitted for the “Plan Sanction” by the local zonal authority and to obtain the “No Objection Certificate (NOC)”. The plan presented needs to be aligned with the building bylaws for each region, if they exist, and as included in the building regulations defined by the Ministry of Urban Development. Prior to hand over of the project to the residents, local authorities perform an inspection and issue an “occupancy certificate”.
Management Systems:
Signature has a formal Health, Safety and Environment (HSE) policy which is adopted, widely disseminated and implemented. The HSE policy reiterates company’s commitment to provide its employees with a safe work environment and to comply with applicable legal and statutory requirements. The company is certified for ISO 9001 (quality management system).
Signature has documented all the processes to be followed on construction sites in the HSE management plan which includes organization chart for safety, safety management guidelines responsibility of safety officer, guidelines for contractor’s safety rules, work permit procedures (including for working at height, moving machinery, electrical safety and fire prevention).
As indicated in the ESAP item#1, Signature shall develop an Environmental and Social Management System (ESMS) covering both construction and operation phases. The ESMS will include: (i) screening procedure/checklist for assessing E&S risks and impacts associated with the new projects and which will entail developing an evaluation checklist that will be completed for each new potential residence location covering requirements of PS 5, PS 6, PS 7 and PS 8; (ii) procedure for land purchase including policy/guidelines for: (a) purchase of land having no legal issues or claims; (b) detailed due diligence of land aggregated for all future projects to ensure that the purchase process followed by the aggregator is free from coercion and fair prices are paid to the landowners; (c) avoid purchasing land which has resulted in any involuntary resettlement unless resettlement and income restoration are managed in a manner compliant with IFC’s Performance Standard 5; (iii) EHS procedures for construction phase integrating the HSE management plan already in place (covering construction phase related impacts and risks); (iv) EHS procedures for operation and maintenance of diesel generator sets (backup for power supply), water treatment plant, sewage treatment plant, Life and Fire Safety (L&FS) systems, solid waste management, storm water drainage and also covering the monitoring, reporting and management review of E&S performance during construction and operation phase; (v) procedures for emergency preparedness and evacuation; (vi) employee and community grievance mechanism meeting PS2 and PS1 requirements; (vii) checklist for labor camp facilities (amending the existing checklist to also include IFC PS requirements); (viii) check-list for ensuring compliance with EHS requirements and legal requirements on working conditions and non-deployment of child and forced labor (including for contractors); and (ix) procedure for deployment of security personnel including dos and don’ts for deployment of armed security personnel.
Organizational Capacity and Competency:
The regulatory permits for all projects are obtained by legal department of the company, which is also responsible for ensuring compliance with various permits.
E&S aspects are managed at the corporate level by a Manager-Safety who is responsible for supervising all the project sites and co-ordinates with safety executive at each of the sites. Safety executive is deployed at each construction site and who oversees the contractor’s safety team. Manager- Safety and safety executive are responsible to ensure that E&S procedures are followed and to ensure conduct of regular safety training, safety inspections, accident investigation, preparation of monthly EHS statistics and reports, inspection of labor camp and monitoring of safety performance in tool box meetings and safety committee meetings. Labour required for construction is hired and deployed through contractors and each of the contractor is required to have safety executive (s) and adhere to Signature’s EHS procedures. The company is responsible for management/ maintenance of their buildings.
Emergency Preparedness and Response:
There is a standard emergency preparedness and response plan, and which is tailored for each individual construction site. The emergency preparedness and response plan include details on resources to combat emergency, emergency contact numbers, details of emergency response team, duties of emergency coordinator and fire and safety coordinator, list of first aiders and flow chart for emergency situation.
Construction sites are equipped with first aid kits and emergency communication numbers are displayed (including number of nearest hospital). Regular fire drills and training on use of fire-fighting systems are conducted at the construction sites. As included in ESAP item#1, the corporate ESMS to be developed will include procedures for emergency preparedness and evacuation (building upon the existing emergency preparedness and response plan).
According to information provided to IFC during the appraisal and based on visit to Solera project (recently completed), it was observed that fire-protection measures as required under the local regulatory requirements are provided and which includes fire extinguisher, hose reel, fire alarm, emergency exit, dedicated fire water storage with provision of jockey pumps. As indicated in ESAP item#2, Signature will hire an independent qualified fire safety professional acceptable to IFC to conduct a review for one completed and one under construction sample affordable housing projects to confirm fire safety compliance with the requirements of relevant L&FS Indian regulations and initial design. The review should include among others: fire prevention, means of egress, detection and alarm system, compartmentation, fire suppression and control, emergency response planning, and review of emergency plans to enhance and standardize the guidance for evacuation in case of emergencies, especially regarding life and fire safety. As needed a corrective action plan with a time frame for implementation will be submitted after the professional’s first review.
Monitoring & Reporting:
Environmental monitoring is conducted at all construction sites as per requirements stipulated by state pollution control board and include monitoring of ambient air quality, ambient noise, soil and wastewater quality and report is submitted to the regulatory authority as per defined frequency. At the construction site, weekly inspection is conducted by the designated safety executive to identify unsafe practices which are then reported to the project manager for making necessary improvements. In addition, compliance audit is conducted by Manager – Safety at each project site on a monthly basis and records of the audit are documented and tracked for completion with photographic evidence. There is a safety committee in place comprising of the project head, manager – safety, safety executive and contractor’s safety executive. Each of the construction site is required to submit monthly reports to the corporate manager-safety which includes data on manpower, number of incidents/accidents/first-aid cases/near misses and EHS induction trainings. Environmental monitoring during operation phase will be limited to stack emissions of diesel generator and treated wastewater from Sewage Treatment Plant (STP).
As included in ESAP item#3, Signature will conduct a third-party audit of EHS and labor related compliance for at least two construction projects through an external consultant (acceptable to IFC) against procedures developed as part of ESMS and IFC Performance Standards requirements. As part of the review, the land purchase process for the specific development will also be reviewed to ensure its compliance with land acquisition policy/guidelines developed as part of the ESMS.
