Provident purchases land on a willing buyer-willing seller basis or has joint development agreements with a partner who has the possession of land. For the proposed projects: (a) Land in Kochi (~18 acres) was purchased in 2006 from private landowners, however, it has not been developed till now; (b) the Land for Bengaluru township (~60 acres of non-agricultural land) is being purchased from financial institutions (who are selling it due to loan defaults by the original owners) and other private owners. Considering the above, no impacts as envisaged under PS5 (Land Acquisition and Involuntary Resettlement) are expected due to the project.

In addition, the proposed projects will be developed on land zoned under residential areas around major cities. In Kochi, the site is located in a well-developed residential/commercial area within the urban/municipal limits, whereas in Bengaluru, the site is located in an area which is near the airport and rapidly under development. Therefore, adverse impacts on biodiversity, indigenous people or cultural heritage are not expected. However, as the Kochi site is located within 5 km of Mangalavanam Bird Sanctuary, the company has applied for required permission from National Board for Wildlife (NBWL). Hence, no impacts of the project are expected which must be managed in accordance with PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not applicable.

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 risks and issued related to the Project include: (a) assessment of E&S risks and impacts of proposed projects and their adequate assessment and mitigation; (b) Puravankara and the companies’ capacity, systems and staffing to manage E&S aspects of its constructions and operations in accordance with legal requirements and IFC Performance Standards; (c) assurance of fair, safe and healthy living and working conditions for the workers (especially during construction); (d) management of air emissions, wastewater treatment and solid waste during construction and operations; (e) resource conservation mainly through green building design; and (f) impacts of construction activities on nearby communities.

Environmental and Social Assessment: The Group follows the local legal requirements for design, development and construction of the housing developments including the specifications defined in the Master Plan of each city, and the requirements defined by the relevant National Building Code of India (NBC)  as well as the Ministry of Environment, Forest and Climate Change (MoEFCC). An Environment Impact Assessment (EIA) has been completed and environmental clearance (EC) has been obtained for the Kochi project (except for the last phase of 2 acres)_in line with applicable legal requirements as the built-up area is more than 50,000 m2. Environment Management Plan (EMP) has been developed for the Kochi project which consists of mitigation measures and environmental monitoring plan for compliance with various environmental regulations. However, an appeal has been filed against the issuance of EC to the Kochi project in the National Green Tribunal and the case is ongoing. Purvankara has submitted their responses to the appeal.

Additionally, other required permits e.g. Fire No-objection certificate (NOC), consent to establish (CTE) from state pollution control board (SPCB), height clearance (AAI), etc. have already been obtained for the first phase of the Kochi project. Building plan approval and NBWL approval (mentioned above) are in progress. Similarly, as applicable, necessary assessments will be completed and required clearances/permits will be obtained for the Bengaluru project. Required management plan and mitigation measures as per these clearances/permits will be implemented by the companies on-site.

For the new projects which are yet to be identified, the Group will conduct E&S due diligence (ESDD) as per IFC PSs requirements and share the reports with IFC. Any improvement areas identified in the report will be implemented within the agreed timelines. Also, the land purchase process for the new development will be reviewed to ensure its compliance with IFC PSs requirements. As per the ESAP, IFC and Puravankara will agree on the terms of reference (ToR) for these reviews.

E&S Policy and Management Systems: Puravankara Group has a documented Environment, Health and Safety (EHS) Policy and an EHS Manual. As per the EHS policy, the Group is committed to provide environment friendly, safe and healthy work culture in all aspects of operations.

The EHS Manual describes the processes to be followed through planning and implementation of its projects including monitoring and reporting. Provident ensures that all contractors and sub-contractors comply with its EHS policy and manual. Based on the site visit observations (to Provident Park Square), document review and discussion with on-site staff, implementation of the procedures was noted to be adequate except for areas of improvements in periodic environmental monitoring (discussed below).

E&S Organization: EHS aspects are managed at the corporate level by Senior Vice President (Quality Assurance, Product Excellence & EHS) who is responsible for implementation of all the EHS related aspects for assuring compliance with support from the EHS Managers (separate for Provident and Puravankara). EHS Manager(s) are responsible for monitoring day-to-day implementation of EHS policy and manual through inspections, performance monitoring of EHS officers (at sites) and EHS trainings to employees. They are supported by EHS Engineers and safety officers.

Puravankara Group has divided its construction sites across the country in three regions and each region has a Zonal Head who reports to President (Technical) in Bengaluru. Under the Zonal Head, Project-in-charge (PIC) is responsible and accountable for EHS performance of the respective sites and is supported by on-site EHS Officer/EHS Engineer. EHS Officer/EHS Engineer is responsible for facilitating and implementing EHS requirements including safety training, incident investigation, labor camp inspection, monitoring and reporting.

Emergency Preparedness and Response: Puravankara Group has a standard emergency preparedness and responses procedure as a part of its EHS Manual and as per that, a specific emergency response plan is developed for each project site. The procedures require each site to provide fire extinguishers, identify assembly points, provide regular training of employees including through induction and periodic mock drills. During the site visit, the implementation of the procedures was noted to be adequate.

Monitoring and Reporting: Monitoring and reporting procedures have been described in the EHS manual. All sites have formed an EHS committee, which meets on a monthly chaired by the project manager with representatives of various departments including the contractors. The committee reviews EHS objectives and targets, concerns from the employees, EHS training and monthly safety reports.

The EHS performance of each site is reported to the corporate EHS team (through the EHS Manager). All sites are then rated on their performance based on about 200 parameters divided under incident details, safety performance (with sub-parameters on various works on-site), site and labor colony cleanliness and documentation and records. This provides a benchmarking of the sites and helps identify significant improvement areas. Key EHS statistics, including safety rating data, are then included in Management Information System (MIS) report for senior management which highlights certain key parameters like safe man-hours, number of EHS trainings, accidents/incidents, EHS training provided and audits completed during the reporting period.

One of the areas of improvements identified in the monitoring and reporting activities is that the EHS rating system does not include environmental parameters. As per ESAP#1, Puravankara /the companies will include specific parameters in the rating system which will cover requirements (for both site and labor camp) on dust and noise control, regular environmental monitoring (noise, air, wastewater), chemicals management, waste management, implementation of the EMP and compliance with permit requirements.  

Checklist based EHS inspections are conducted weekly by designated EHS officers on-site for various parameters. In addition, all project sites are audited at least once in six months by EHS Head or Management Representative as internal EHS audit to verify compliance with the EHS manual requirements. To strengthen review of proposed projects, as per the ESAP#2, Puravankara/the companies will conduct bi-annual third-party audit of EHS related compliance for the construction at the two projects through an external consultant (acceptable to IFC) and share the reports with IFC. The audits would focus on compliance with respect to Puravankara’s EHS Manual as well as IFC PSs requirements and any improvement areas identified will be implemented within reasonable timelines.

As of February 2020, Provident has a total workforce of 244 employees (~25% female). On each project site, the workers are hired through contractors for performing construction related tasks. For the proposed projects, there will be 500-1000 workers on-site depending upon the stages of construction.

HR Policy, Working Conditions and Terms of Employment: Puravankara Group has documented an HR Policy manual which includes policies on leave (including maternity), travel, time and attendance, employee welfare, training, performance management system, grievance handling, whistleblower and prevention on sexual harassment (POSH). An appointment letter is issued to each employee which covers details on key working conditions and terms of employment. The HR policy is also communicated to all new employees through an induction and through the intranet. There are a few areas of improvements on the HR policy, which are described in the following sub-sections. As per ESAP#3, the companies shall either adopt the Provident HR policy manual as their own (with the improvements suggested below) OR document a new HR policy manual incorporating all the PS2 requirements.

Non-discrimination: Puravankara Group has a non-discrimination and equal opportunity policy which aims to eliminate discrimination in employment on the grounds of age, gender, disability, race, color, nationality or religion. It also aims to comply with equal opportunity legislations as applicable, and to follow good management practices.

Protecting the Works Force: In compliance with local labor laws and its policy, Puravankara Group does not employ child labor or forced labor on its construction sites. Contractors are also required to hire employees older than 18 years of age, which is confirmed through collection of documentation of age of workers and controls at construction site gates. As per the ESAP #3, Puravankara/the companies shall include a specific prevention of child labor policy in the HR Policy manual.

Worker’s Organizations: Puravankara Group does not prohibit formation for unions or associations in compliance with the statutory regulation, though there is no collective bargaining agreement or any worker union presently. As per the ESAP #3, Puravankara/the companies shall ensure that the freedom of association policy is included in the HR Policy manual.

Grievance Mechanism: Currently, Puravankara Group has a documented grievance mechanism policy in place. The mechanism allows for raising anonymous grievances and has been communicated to all group employees As per ESAP#3, the companies shall document a similar grievance mechanism with clear process of receiving and responding to grievances in line with IFC PS2 requirements.

For protection against sexual harassment in workplace, as per applicable legal requirements, Puravankara Group has documented a formal POSH policy which covers all employees, including permanent, temporary, on training, on contract, consultants or anybody who are in the workplace. Complaints related to sexual harassment are handled by an Internal Complaints Committee (ICC) comprising of 10 members with majority of them being women and an external member. To enhance awareness on POSH, employees are required to complete a mandatory eLearning course (ePoSH) and repeat the same at a pre-decided frequency.

Occupational Health and Safety (OHS): As mentioned above, Puravankara Group has a documented EHS manual for construction work which covers key activities expected on construction site including excavation, dangerous works (hot work, confined space entry, work at height), construction vehicle, scaffolds and work platform, heavy equipment, use of PPE, etc. The manual describes key control procedures including Do’s and Don’ts referring to applicable standards and safety codes. All new employees, contractors, subcontractors, and visitors where necessary, are provided with EHS induction prior to working on site, and regular training (through toolbox talks and job safety training). Improvements and good EHS practices are acknowledged through recognition to motivate workers. Appropriate safety measures, use of PPE and Documentation of EHS induction and training were observed during the site visit. Implementation of the procedures is reviewed through the inspections, audits regular reporting and rating as described above.

Also, accident/incident investigation processed were noted to be in place. The EHS manual stipulates flow of reporting and responsibilities depending on severity of accident/incident with lost time injury formulae for quantitative evaluation which is incorporated into periodic EHS reporting. There have not been any fatalities or major incidents/injuries on any of the Puravankara construction sites in last three years.

Workers Engaged by Third Parties: Puravankara Group signs a documented contract with each of its contractors. The contracts were noted to include specific provisions on implementation of EHS manual (and consequences of non-compliance), prevention of child labor and compliance with applicable labor law requirements. Required documentation like certificate of registration and a labor license issued by the statutory authorities is collected from the contractors. Also, the required documentation to be maintained at the site is verified through a quarterly compliance audit by HR.

One of the areas of improvement noted was related to monitoring of contractors’ compliance with respect to applicable labor law requirements (e.g. working hours and overtime). As per ESAP#3, Puravankara/the companies shall have a specific review of working hours and overtime work by contract workers at a pre-determined frequency for each site. 

Workers Accommodation: Labor accommodation is provided in close proximity to the construction sites by the contractors. During the site visit, it was noted that the labor camp was provided with reasonable facilities and amenities. There were areas of improvements noted in the disposal of wastewater. Also, no specifications for the labor camp have been included in the EHS manual. As per the ESAP #4, Puravankara/the companies shall include in its EHS Manual a checklist for labor camp facilities aligned with good international industry practices including: adequate living/sleeping facilities and space per person; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities; locker/storage facilities; fire safety equipment; emergency response planning and facilities for management and disposal of garbage, sewage and other waste.                                         

In light of the COVID-19 pandemic, as per the ESAP, the companies/Puravankara will have to develop additional procedures as per government guidance and global best practices which will focus on preventive (like screening, social distancing) and emergency measures (like isolation, medical treatment). The companies will have to ensure that the required arrangements in the construction site and labor camps are in place before start of the work and adequate training is provided to all contractors, supervisors and workers.         

Resource Efficiency: A number of resource efficiency measures are typically expected to be implemented as per the conditions of the Environmental Clearance. As per the clearance requirements for Kochi project, Puravankara/the companies will implement following measures in its developments:

-          Rainwater harvesting

-          Low flow water faucets and 3 l/6 l dual flushing systems

-          Dual plumbing system for recycling of wastewater for flushing and landscaping

-          Outdoor (landscape, street areas) and common area (corridors) lighting to be LED  

-          Installation of Solar, wind or other renewable energy to meet electricity generation equivalent to 1% of the demand load (may be met by solar water heating) or as per the state level/ local building bye-laws requirement, whichever is higher.

The company is also planning to obtain Excellence in Design for Greater Efficiencies (EDGE) certification for the Kochi project, which would require the project to be 20% more efficient on energy, water and materials use than local benchmarks.

The Bengaluru project is essentially a plotted development and the company will only provide the common infrastructure. Required efficiency features as per environmental clearance will be implemented for the project.

Pollution Prevention: Environmental impacts and mitigation measures during construction and operation are properly identified in the EIAs and are mainly related to land preparation, air emissions (heavy equipment, vehicles, generators), noise, sewage from domestic use and waste management. As result of the EIAs, the companies prepare EMPs for mitigating adverse impacts along with delineation of project and post-project Environmental Monitoring Programs. 

Water and Wastewater: During construction, water is typically sourced through on-site borewells. Post construction, before the developments are handed over to the owners, water supply will be coordinated with local authorities; typically, water is supplied by local government agencies and/or from on-site bore wells and water treatment (as required) is provided on-site by Provident to ensure that water quality meets the national acceptability standards. For the Kochi project, the water requirement will be around 47 m3/day during construction and 3000 m3/day during operation (including ~1000 m3/day of recycled wastewater). The water requirement will be met by Kerala Water Authority supply and on-site borewells. For the Bengaluru project, these estimates are still in progress.

Wastewater during construction phase is disposed of in septic tanks including at labor camps. For operation, sewage treatment plants will be built for each project and treated water will be reused where feasible or discharged into the local municipal sewer line.

Waste Management: the EHS manual describes processes to be followed for each category of waste i.e. organic, non-organic, used oil and oil-soaked waste. All waste streams are segregated and stored separately. Recyclable waste is disposed through approved agency or recycler. Food waste is to be disposed of through composting or given to local pig farms. Domestic waste (from labor camp) is segregated and sent for further disposal to the municipal agency. Hazardous waste is handled as per applicable legal requirements and disposed through agency authorized by the Central/State Pollution control Board.

The proposed projects will implement same environmental management practices at the sites.

GHG Emissions: Based on available energy consumption data, the expected annual GHG emissions from the two identified projects will be 9000 tons of CO2 equivalent.

Infrastructure Safety: Puravankara Group follows local legal requirements for design, development and construction of housing developments, including the specifications defined on the Master Plans of each city, the requirements defined by MoEFCC and NBC.

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”.

Life and fire safety systems for the proposed developments under the Project will be designed, implemented and tested in compliance with the requirements of NBC 2016 (as amended) and building bye laws of the city/region (as applicable).

Community Impacts: Impacts to the community such as water extraction, noise, air pollution and exposure both during construction and operations are identified in the EIAs and as needed mitigation measures are identified and implemented. Puravankara Group manages its construction activities in a way to minimize the impacts on neighboring communities; dumpers carrying excavated soils is covered with polythene sheets and water is regularly sprayed to minimize dust due to vehicle movement and wind; vehicle movement and noisy activities around construction site are restricted to specific time.

As per the ESAP#6, Puravankara/the companies shall develop and implement a documented community grievance mechanism for the proposed projects including process of receiving and responding to the grievances which meets IFC PSs requirements.

Adequate parking arrangements will be made as part of the project design. Considering that the location of the sites is near major roads, no traffic impacts are expected on community.

Security Management: Puravankara Group hires unarmed security guards at construction sites through external security agencies. Security agencies are responsible for background verification of the guards and training the guards on dealing with the workers and neighboring communities.

As per applicable legal requirements, the Group - Puravankara Group has a documented Corporate Social Responsibility (CSR) policy. As per the policy, the CSR initiatives primarily focus on education and long-term environmental sustainability with other activities including improvement of civic amenities (greening of road median) and promotion of interest in arts and sports. Efforts include the development and maintenance of roads, parks, fire station and a war memorial, apart from supporting schools and creches for the children of unskilled labors, support to old-age homes as well as art and culture. Additionally, as a contribution to senior-level education, Puravankara also seeks to grant scholarship to students for completing their graduation in a course of their choice. A report on CSR activities for the year is included in the publicly disclosed Annual Report of the Group.

As mentioned above, as per the ESAP#6, Puravankara/the companies shall develop and implement a documented community grievance mechanism for the proposed projects including process of receiving and responding to the grievances which meets IFC PSs requirements.                                                 

The company will disclose this ESRS and the ESAP at the following addresses (corporate office and project sites):

Corporate office: Puravankara Limited, 130/1, Ulsoor Road, Bengaluru 560 042, India

Project sites:

1. Edapally South and Vazhakkala Village, Thrikkakara Municipality, Kanayannur Taluk, Ernakulam District.
2. Various Survey Nos. of Devanahalli, Gullobanahalli and Neeleri kasaba hobli, Devanahalli Taluk, Bengaluru Rural District, Bengaluru

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

 Kuldip Chawlla at kuldip@puravankara.com