While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the project’s ongoing compliance with the 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

This is a category B project according to IFC’s Policy on Environment and Social Sustainability. Based on information reviewed by IFC, the proposed project will have limited adverse environmental and social (E&S) impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key E&S risks and issues associated with the project include: the Company’s capacity to manage its EHS performance, and engage with local communities; assurance of fair, safe and healthy working conditions; including special mitigation measures in response to COVID-19 pandemic; utilization of equipment and operational practices that maximizes conservation of energy, water and process materials including recycling and reuse initiatives; management of wastes, emissions and discharges; handling and management of hazardous materials and wastes; and the impacts of operations on nearby communities and local ambient environment.   

 Policy

RKFL has articulated Quality, Environmental, Occupational Health and Safety (EHS) and Energy policies covering all its operations (https://www.ramkrishnaforgings.com/policy.html).

Management Systems:

The Company has an EHS management system implemented at the operational facilities in Jamshedpur. The Company’s operational facilities have implemented certified quality (ISO9001:2008), environmental (ISO14001:2015) and occupational health and safety (OHSAS 18001:2007) management systems; Unit 5 at Jamshedpur has recently upgraded to ISO 45000:2018 for occupational health and safety and the remaining units are expected to be upgraded soon.

Under the framework of these management systems, the Company is currently implementing programs for continuous improvements in the areas of resource efficiency (energy and water conservation), safety improvements, elimination of soil /land contamination caused by cutting fluid, oil leakage; etc. – supported by a rigorous monitoring and documentation systems. The Company has also started using online EHS compliance reporting and tracking management system, and the senior management is updated on the compliance status on a regular basis. As indicated in ESAP # 1, RKFL will establish a functional corporate level E&S management system to oversee and manage E&S performances at all sites and units across the group, including the planned new production sites to address environmental, social, occupational health and safety issues, consistent with IFC Performance Standard (PS) requirements, to ensure regulatory compliance as well as that with the World Bank Group (WBG) General EHS guidelines and sector specific EHS guidelines, as applicable. The ESMS will cover aspects such as internal and external communication, the standard operating procedures (SOPs) for hazard identification and risk assessment (HIRA), emergency preparedness and response procedures, waste management, resource efficiency, etc. and various documentation formats to ensure uniformity in EHS management practices across RKFL’s units. The Company will consistently implement the ESMS requirements across all the existing units of RKFL as well as the proposed facilities in the future, including those under the project.

Organization:

RKFL has a formal organizational structure in place to oversee the environment and safety matters at corporate as well as facility levels. At the corporate level, the Vice President and Head (Corporate HR), with a direct reporting line to the Chairman, has the responsibility to oversee EHS management across all facilities. In addition, an EHS coordinator (also the deputy Management Representative for the ISO management systems) and a safety officer are assigned for each facility, for day to day oversight of EHS activities.

Monitoring & Reporting:

The Company has put in place an elaborate monitoring and reporting program as documented in the management system manual. This program covers monitoring of emissions and waste as per the statutory requirements. In addition, Company regularly monitors water and energy consumption for internal benchmarking and reporting purposes (described below under Resource Efficiency).

As a part of its structured monitoring and reporting program, regular reports are prepared and shared with the senior management. Moreover, the Company’s Chairman reviews the EHS performance every week. The Company has updated its monitoring program to cover relevant parameters for workplace monitoring, such as temperature, noise, particulate matter and volatile organic compounds (VOCs) as per WBG General EHS Guidelines.

COVID-19 / Emergency Response:

Based on the identified hazards and risks, on-site emergency response plans have been developed by the Company for its operational facilities. Accordingly, potentially hazardous areas have been identified and evacuation routes and assembly points have been designated and clearly marked.

Fire detection and suppression equipment is fitted across all the facilities in accordance with the potential fire risks. Fire exits and the locations of fire extinguishers are marked. Security guards are trained by the Company and security agency in firefighting and first aid; and mock fire drills are regularly conducted. An occupational health center is available at the operational facility, and an ambulance is available as a compliance to Factories Act.

After the country wide lockdown due to COVID-19 pandemic since March 2020 the Company is preparing for gradual reopening of its facilities, through a detailed COVID-19 response plan in compliance with the local administration guidance and safety directive issued from time to time.                       

 RKFL currently has around 1700 regular employees, comprising technical staff, associates and management staff. In addition, RKFL employs around 1800 contract workers (contractors hired for service delivery on piece rate) mainly for movement and loading / unloading of material and finished products, and other functions such as housekeeping, security etc. In addition, around 200 employees of sub-contractors work on the outsourced job of cleaning the edges of the machined parts.

During the country wide lockdown due to COVID-19 pandemic the Company has not laid-off workers but has made temporary adjustments to its workforce by adapting to the national as well as respective local legislation. The Company has paid full salaries to the employees during the lockdown period. The contract work was mostly on the piece rate which was linked to production; therefore, the contract workers were not mobilized during the lockdown period. With the plants starting to operate and production work starting, the contract workers are also mobilized. RKFL mostly hires local workers and has no migrant workers. There have been no significant health impacts on workforce due to the pandemic. Accommodation facilities are only provided to the security personnel.

Human Resource (HR) Policy, Management

RKFL has articulated HR policies and procedures for its operations which are consistent with national labor laws and IFC’s PS2 provisions. The Company has HR professionals deputed at each of its facilities, who are responsible for implementing HR policies and procedures. RKFL manages its workforce under the Indian government’s Model Standing Orders. The Model Standing Orders are consistent with PS 2 provisions and are displayed in the local language at the Company’s premises. These cover terms of employment; non-discrimination and equal opportunity; leave, exit and termination policies; working hours, provident fund, training, welfare, and grievance mechanism. This information is also provided in the induction manual which all new recruits receive at the time of joining together with the employment contract. In addition, the Company has set up several computer terminals in the canteens and other public places across the facilities, through which the employees can access the HR systems on the Company intranet for accessing all the HR policies and procedures, applying/modifying leave, printing salary slips etc. This system also provides the employees access to several technical journals and websites.

The Company’s HR department also has the responsibility of monitoring the contractors and ensuring compliance with the provisions of the Contract Labour Act of India. For this purpose, documented procedures and monitoring checklists and formats have been developed.

Workers’ Organization:

A workers’ union exists at two of the Company’s plants, and collectively negotiates the wages and other benefits with the management. While the Company does not restrict the formation of workers’ union, there is no union at its other plants; however, work committees are used as a platform raise employee concerns and grievances if any. The worker’s union at two units has representation from only the permanent employees of the Company.

Training and Human Resources Development

RKFL has an extensive human resource development and training program for its employees, managed by the HR department in accordance with a well-defined documented procedure. Several structured training programs are delivered for different levels of employees to enhance their competencies in four areas: basic mandatory skills, job specific skills, system awareness and behavioral competencies. A detailed training calendar is maintained, and the training effectiveness is monitored post-training. Safety and resource efficiency /energy conservation are integral topics in the annual training calendar.

Grievance Mechanism

The Company has zero tolerance towards sexual harassment at the workplace and has adopted a policy on prevention, prohibition and redressal of sexual harassment at workplace in line with the provisions of the Sexual Harassment of Women at Workplace (Prevention, prohibition, and Redressal) Act, 2013 and the Rules thereunder. The policy is applicable to all Board members, executive and non-executive Directors, owners, shareholders, all employees, regardless of seniority or contractual status, i.e., permanent, short-term contract, and casual employees, probationer, apprentice, trainee or called by any other such name and all contractors and sub-contractors, personnel. The Company has a separate internal complaint committee (ICC) in place.

The Company has a grievance redressal committee (GRC) in all its workplace. The Company has a grievance redressal mechanism (GRM) applicable only to employees of the RKFL. The GRM spells out procedure of filing the grievances, and due process to be followed for grievance redressal. The grievances are supposed to be addressed by GRC within 10 days of receipt of grievance. As indicated in ESAP # 2,  RKFL will further update the GRM to (i) make it applicable for the contract workers too; (ii)provide for option of anonymous grievances; (iii) provide the option of legal recourse in case the complainant is not satisfied with the outcome from GRM process; and (iv) will specify that no retributive action will be taken against the complainant. RKFL will further ensure that the GRM availability is widely disseminated in the Company.

Occupational Health and Safety

RKFL’s Occupational Health and Safety Policy guides the overall safety management at its facilities as well as that of its contractors. Under its safety program, RKFL has the following key focus areas: ensuring safety related statutory compliance; safety awareness through visual messages; safety training; work permit system; identification and action on unsafe acts and working conditions, use and upgradation of proper personal protective equipment (PPE); annual health check-up of employees; accident reporting system and trend analysis including near misses. Various key performance indicators (KPIs) are displayed throughout the shop floor, together with visual safety signage and messages. Emergency procedures and contact numbers are prominently displayed and a safety instruction card is provided to all employees and visitors. The Company has reported zero fatalities, and similarly, total lost time accidents as well as number of lost workdays figures are zero for all the units of RKFL.                                                  

Primary inputs for the manufacturing process are metal and energy: electricity for various machines in the machining unit and other fuel (oil/gas) for forge furnaces. The Company conducts internal energy audits and accordingly, implements measures to reduce its energy consumption. In the past months, the Company has implemented measures such as: optimization of cooling tower operation, fanless cooling tower, repairs to prevent air leakage and optimization of compressor operation, changeover to energy efficient lighting etc.

Energy Sources and GHG Emissions:

The Company’s energy requirement includes electricity, which is procured from the national grid. And the natural gas used in the furnaces in the Press Forging Facility. Diesel generators are installed on site as backup generators, for use in the rare case of power failure. The GHG emissions from the Company during 2019 were 20,500 tons of CO2e as Scope 1 emission, while scope 2 emission for the Company was 100,000 tons of CO2e.

Water Supply and Effluent:

Water consumption for the Company’s existing operations is around 9,500 m3 per month which is sourced from the bore well. The Company’s operations primarily involve “dry” processes and do not result in significant amount of process wastewater. Small quantities of wastewater discharges include water-based cleaning and rinsing streams; cooling water; and water-based metalworking fluid operations; which is treated in effluent treatment plant; the treated water is used in gardening, fire hydrant reservoir, cleaning, water sprinkling etc.

Solid and Hazardous Waste:

Limited emissions of VOCs may result from the use of lubricating / cooling fluids. The solid waste primarily comprises of metal particles (e.g. iron filings, and chips arising from machining operations); metal-bearing machining fluid sludge etc. The metal scrap from the process comprises of steel scale from forging operations, flash removed from pieces, and steel waste – such as swarf from machining, iron filings from grinding operations etc. This is sold to recyclers.

RKFL complies with all relevant regulations for the storage, handling and disposal of hazardous materials used in the production process. Small quantities of notified hazardous wastes (waste lube oils, oil-laden cotton waste etc.) are disposed of through licensed waste management contractors, as per the regulatory authorizations.                                                 

The Company’s operational facilities are located in an industrial area; there are no local communities in the immediate vicinity of the facility. However, one of the units is located in a rural area closer to the state highway, away from any communities; the nearest community is at a distance of 200 meters from the unit.

RKFL recognizes that engagement with nearby communities and other stakeholders is the key for building long-term constructive relationships that are essential for the successful management of the project's environmental and social impacts. The Company also has a CSR policy which guides the intervention in the nearby villages (www.ramkrishnaforgings.com/investors/policy/csr-policy.pdf).                                                   

Local Access of Project Documentation

Contact Person: Rajesh Mundhra

Company Name:  Ramkrishna Forgings Limited

Address:   72 , Shakespeare Sarani.Kolkata-72.

Email:    rajesh@ramkrishnaforgings.com

Phone:   033-39840900.

Fax:    033-39840998