Policy and E&S Management System: Arise IIP has adopted an overarching Environmental, Social and Governance (ESG) Policy that sets out its overarching E&S objectives and principles, including a formal commitment to progressively  align with the IFC PSs and the World Bank Group (WBG) EHS Guidelines. The ESG Policy is supported by a series of  thematic policies including, among others,  (i)  an Environmental, Social and Governance Policy; (ii) a Human Resources Policy (including internal grievance mechanism), (iii) a Supply Chain Management Policy; (iv) a Sustainable Procurement Policy; (v) an Excluded Activity Policy; (vi) an Anti-Bribery and Corruption Policy;  and (vii) a Sustainability Charter. These policies are  operationalized through Arise IIP’s corporate Environmental and Social Management System (ESMS), which provides a structured and  standardized approach to E&S risk management across all Arise IIP operations. The ESMS has been rolled out at both PIA and GDIZ sites. At PIA, the ESMS is ISO 9001:2015, ISO 14001: 2015 and ISO 45001:2018 certified. Arise IIP intends to pursue similar certifications for the ESMS at the  GDIZ site.

Arise will review and enhance its existing corporate ESMS to further align with IFC PS. This process will include: a) the development and update of a Land Acquisition and Resettlement Framework (LARF) to be used as a reference framework for current and future land acquisition for all existing and new SEZs; b) a Worker accommodation framework to guide all operations involving worker accommodations;  c) the revision of the Supplier code  of conduct for a consistent application to all sectors ; d) a Contractor management Framework;  (e) an enhanced Grievance Redress Mechanism (GRM) covering all workers (including contract workers), and (f) Cultural Heritage Policy Framework. Once finalized, the updated ESMS will be applied to PIA and GDIZ  SEZs and will include provisions for monitoring and continuous improvement (ESAP #1).

Identification of Risk and Impacts: At pre-feasibility stage, Arise IIP selects the site for each SEZ based on the combination of land characteristics, existing land use, accessibility and proximity to key energy and logistic infrastructures (i.e. electricity and water). Once a site is selected and as per the corporate ESMS, ESIAs are carried out prior to the commencement of any construction activities. ESIAs for PIA and GDIZ Phase 1 were completed respectively in March 2022 and November 2020 and are aligned with IFC PS requirements. Both SEZs have received EIAs approvals and valid environmental permits from the respective national environmental authorities at the time of operation establishment. In Togo the renewal of the environmental certification is underway and is expected to be finalized by August 2025.  As part of the tenants’ agreement, Arise IIP requires each tenant operating within the SEZs to carry out their own site-specific EIAs and securing relevant approvals of their own facilities prior to initiating construction or operations, in line with national regulatory requirements and subject to tenant-led monitoring programs). 

E&S Management Programs: The ESIAs for each project include framework Environment and Social Management Plans (ESMPs), that define the organizational structure for E&S management, outline impact mitigation measures, and establish monitoring requirements for both construction and operational phases. Building  on these framework ESMPs, along with applicable national requirements, the Arise IIP ESMS, in alignment  with the IFC PSs and relevant WBG EHS Guidelines, PIA and GDIZ will each develop operations ESMPs. These will be supported by site-specific sub-plans and Standard Operating Procedures (SOPs) addressing key thematic areas including (i) waste management plan, (ii) water management and monitoring plan; (iii) hazardous material handling and management plan; (iv) pollution prevention plan; (iv) Site Drainage Plans (v) OHS Management plans and (vi) emergency preparedness plans. Additional plans, such as the Supplier Code of Conduct and the asset specific ERPs, which are integrated in the tenant-level contracts, will be also developed (ESAP #3).

Arise IIP will develop a Contractor Management Framework (ref ESAP #1) designed to ensure that environmental and social (E&S) performance of contractors and their subcontractors is consistent with national legal requirements, Arise IIP’s contractor E&S specifications, and relevant IFC Performance Standards. The framework will include detailed E&S requirements to be incorporated into both tender documents and final contractual agreements with construction contractors. The company will also establish a contractor monitoring procedure that outlines the use of both internal and external audits, as well as periodic reporting obligations, to provide assurance that contractors are meeting their E&S commitments. Contractors will be contractually responsible for ensuring that all subcontractors operating under their scope of work also comply with these E&S specifications, as outlined in the Contractor Management Framework.

E&S Organization Capacity: Arise IIP has established a dedicated Group Environmental Social and Governance (ESG) organizational structure to oversee the implementation and monitoring of its E&S commitments.  At corporate level, the ESG function is led by a Group ESG Head, supported by two E&S Managers who oversee a technical team based in Delhi, India. Additionally, Arise IIP hired an international E&S consultant responsible for conducting  quarterly audits to all its SEZs, all under the supervision of board-level ESSD oversight. At the asset level, ESG teams are fully integrated into national operations, managed by Site E&S Managers and Community Liaison Officers (CLOs). Operational health and safety (OHS) and HR Management are managed by different functions. The Health and Safety function is  staffed by  a dedicated five-person team, which reports to a Group Health and Safety Manager. Oversight of ESG matters is further reinforced by a Board-level ESG Committee, which includes the Group ESG Head and representatives from key shareholders.

Emergency Preparedness and Response: Both PIA and GDIZ currently have asset-specific ERPs for their Phase 1 operations. Arise IIP will review and update these ERPs to incorporate emergency scenarios related to tenant activities and to ensure alignment with relevant IFC PSs and WBG EHS Guidelines (ref. ESAP # 2). The updated ERPs will include procedures for communication and coordination with SEZ tenants, local authorities, and surrounding communities, in the event of an emergency. The SEZs are equipped with hydrant systems connected to a centralized water storage network and a fully equipped on-site fire station. In addition,  each tenant facility is also required to install and maintain its own life and fire safety (L&FS) systems in accordance with local permitting requirements and Arise IIP’s Tenant E&S requirements. These systems will be designed in line with GIIP, including applicable sector-specific standards.

Monitoring and Review: The organization has adopted a comprehensive ‘plan-do-check-act’ approach to guide its annual and five-year ESDD strategies, this approach is based on the outcomes generated from Global Reporting Initiative (GRI)-standard reporting and periodic external audits.  At the corporate level, governance mechanism includes the monthly monitoring of over 170 key performance indicators (KPIs), formalized GRI reporting disclosure, and evaluations by third-party rating agencies such as Sustainalytics and Morningstar. In addition, oversight is further reinforced through a board-level ESG committee, which reviews ESG reports quarterly and ensures escalation to the full Board of Directors. At asset level, ESG teams are responsible for ensuring regulatory compliance, managing stakeholder engagement, responding to incidents, and addressing workforce-related matters. Arise IIP organizes regular internal and external training sessions to ensure that all ESG, OHS, and Human Resources staff are trained and sensitized in EHS and Social/labor-related aspects. Arise IIP will develop and implement an E&S Monitoring Plan (ref. ESAP #1) to align it with IFC PSs, relevant WBG EHS Guidelines, as well as national environmental standards. This plan will include tracking of both OHS leading and lagging Key Performance Indications (KPIs) at SEZ (ref. ESAP #1).

Whilst each SEZ and their respective tenants will be responsible for conducting the E&S monitoring of the activities and infrastructure under their direct control, Arise IIP will establish a harmonized approach to ensure consistent and coherent data aggregation across sites. Arise IIP will develop a standardized E&S monitoring template for ARISE-affiliated industries  to complete and submit on a periodic basis (ref. ESAP # 1). In addition, Arise IIP will implement data management software to centralize monitoring and analysis of the E&S performance across SEZs operations and ARISE-affiliated industries  activities. 

The provisions in this section apply to workers directly employed by the SEZ operators, as well as those engaged by third party contractors to provide support and service functions to the SEZ and does not refer to workers employed by tenants. At the time of appraisal, PIA and GDIZ, employed respectively 204 and 13349 employees. In addition, PIA and GDIZ also engage 519 and 1065 employees through third-party service providers for support functions such as cleaning and security services and facility maintenance.

Human Resource Policy and Procedures. Arise IIP has adopted a Fair Employment Policy (FEP) that establishes six core standards: (i) Prohibition of Child Labor and Forced Labor; (ii) Workplace Conditions; (iii) Wages and Benefits; (iv) Diversity and Inclusion; (v) Health and Nutrition; and (vi) Freedom of Association and Right to Collective Bargaining. The FEP has been implemented at each SEZ level and applies to all workers, including those employed by third-party service providers. In addition to the FEP, Arise IIP also has a Sexual Harassment Policy and a Code of Conduct (CoC) outlining the values and behaviour expectations applicable to all staff in the workplaceAll direct employees are onboarded on key HR documentation, payroll systems, and EHS requirements at induction. The implementation of HR policies and procedures for the workforce is led by a corporate HR Director and supported by HR Managers responsible for the implementation of national legal requirements and relevant group policies, in each SEZ. At the time of appraisal two main gaps were identified: (i) the absence of a formal policy on overtime requirements and (ii) the need to extend the internal grievance mechanism to third-party workers. To address these issues, Arise IIP will perform an independent audit to assess compliance with statutory and PS2 requirements at SEZ level, as well as at factory sites where Arise IIP holds full or joint ownership. Based on the audit findings, a corrective action plan will be developed and implemented to address any identified gaps (ESAP #4).

Working Conditions and Terms of Employment: Specific parameters of working conditions and terms and condition of employment are governed by national labor laws in each country of operation. All SEZ workers, including those employed through third parties, are required to have a formal labor contract that specifies key employment terms, including the nature and classification of the role, place of employment, start date and contract duration, working hours, salary, leave entitlements, benefits and employee rights and obligations, in accordance with applicable regulations. Employees receive pay-slips detailing hours worked, wages earned, and statutory deductions for social security and other mandatory contributions. Minimum wages at each SEZ are aligned with the respective statutory requirements of the country of operations. While no workers are currently housed onsite, future accommodations with project expansion will be developed in accordance with the Workers Accommodation Plan (ref. ESAP #1).

Workers Organization: As per the requirements of the FEP and in line with the labor laws in each project country, Arise IIP does not restrict freedom of association and collective bargaining for its workers. Furthermore, there are no restrictions placed on freedom of association and collective bargaining within the SEZ operations. In both SEZs, employees' representatives are elected following national labor law requirements and meetings are held and documented on a monthly basis to discuss issues and share relevant updates.

Worker's Grievance Mechanism: Arise IIP has in place a labor grievance mechanism that outlines the procedures for lodging and managing grievances, identifies the responsible parties and specifies response timelines. In both Togo and Benin, the current procedure needs to be improved to ensure full alignment with PS 2. Specifically, the existing mechanism needs to include provisions for non-retaliation, and it also needs to be extended to third-party workers and include provisions to address Sexual harassment and Exploitation, Abuse and Harassment (SEAH)- including anonymous reporting. Arise IIP will update and operationalize the labor grievance mechanism in both countries to ensure that they are accessible to all workers, including those employed by third parties and contractors. The enhanced mechanism will incorporate clear provisions for anonymous reporting, and support confidentiality to explicitly address non-retaliation and SEAH complaints (ESAP #3).

Workers Engaged by Third Parties: Arise IIP will develop a set of minimum EHS/labor requirements aligned to the FEP, for inclusion in contracts with service providers and contractors involved in SEZ operations. Labor and working conditions performance will be audited as per the procedure established in ESAP #1. All tenants will contractually be required to meet Arise Tenant E&S requirements, which include compliance with national laws, as covered in ESAP #2.

Occupational Health and Safety: Arise IIP through its Health and Safety Policy is committed to ensuring a safe and healthy work environment for employees and contractors and to fostering a zero-harm culture. Arise IIP's safety management program is built around safe systems of work, including but not limited to, risk assessment and mitigation, standard operating procedures, emergency response plan and permit to work system. To promote a further culture of safety, Arise IIP also introduced a set of Life Saving Rules aiming at encouraging safer behaviors and raise awareness of high-risk activities. Health and safety are overseen by a dedicated five-person OHS team that reports directly to a Group H&S Manager. A strict zero-tolerance policy on fatalities is enforced, ensuring full investigation of any incidents and reporting to the board. During the construction phase, Arise IIP implemented a meticulous incident tracking system, leading to a significant reduction in Lost Time Injuries (LTIs) and fatalities in the operational phase. In line with national legal requirements, each SEZ has established a Safety Committee composed of key worker-management representatives. For the operational phase, the SEZ will develop and implement a Health and Safety Plan and related procedures as part of the roll out of the corporate ESMS (ref. ESAP #1). In addition, all SEZ tenants will be required to report on standard safety leading and lagging KPIs, including lost time injuries, recordable incidents, and first aid cases.

Supply Chain: A key part of Arise IIP's service offerings to SEZ tenants is an agro-commodity value chain. To support this, the company has developed a Supply Chain Policy, which makes provisions against forced and child labor together with EHS requirements. At the time of appraisal, Arise IIP had not yet commenced sourcing operations in Togo or Benin. AS part of its enhancement of the corporate ESMS, Arise IIP will i) update the Supply Chain Policy to cover supply chain risks associated with conversion of natural and/ or critical habitats in line with PS 6 requirements and develop a Supplier Code of Conduct (ref. ESAP #1).

Arise IIP, through its Sustainability Charter, is committed to managing resources such as energy, water, and waste in line with circular economy principles and to sourcing renewable energy.

Energy Use and Efficiency: Electricity for all project SEZ operations is sourced from their respective countries' national grids. Each SEZ also has back-up generators to be used in an emergency. Arise IIP is looking at opportunities to implement renewable energy technologies including rooftop solar, at each SEZ. Where feasible, commercial buildings will aim for LEED certification, and warehouses will be designed in line with EDGE principles

GHG Emissions: GHG emissions during SEZ operations will mainly be from the use of fuel in emergency generators and vehicles, and electricity consumption associated with the common infrastructure and services. GHG (Scope 1 and Scope 2) emissions at each SEZ are expected to be less than 25,000 tons of carbon dioxide emission equivalent per year, excluding GHG emissions associated with the industrial tenants. Arise IIP will develop a Carbon Reduction Action Plan for each SEZ, once respective operational baselines have been established and will provide advisory services to the tenants on GHG emission reduction subject to commercial agreement.

Water Consumption: Total peak net water demand at full SEZ occupancy has been estimated to be up to 2,300 m3/day, 6,500 m3/day for Phase 1 of PIA and GDIZ respectively Water for PIA and GDIZ is being sourced from deep/ lower aquifers using borewells. At the time of appraisal, three borewells have been installed at PIA Phase 1 and seven at GDIZ Phase 1. Additional borewells will be installed in line with an expected increase in water demand. Arise has determined that there is sufficient groundwater available in these aquifers to meet demand coming from SEZ operations.

The management of water resources within the GDIZ textile park in Benin is conducted with attention to sustainability and efficiency. Monthly water usage data is systematically collected and reported, revealing an average consumption of approximately 21,000 m3 per month in 2025. Textile operations within the park achieve an 85-90% internal reuse rate of water, facilitated by a robust circularity and reuse plan. The current operations do not foresee expansion in Benin thus water consumption is not expected to increase significantly.

Although there are no community complaints regarding groundwater levels, communities around the SEZs rely on shallow water wells for domestic use with sustainability concerns. As part of this IFC financing, Arise IIP will undertake and update the Water Resources and wastewater monitoring program for each SEZ to include ground water monitoring at SEZ level, monitoring potential impacts to community's water resources and wastewater discharge in line with IFC PSs requirements and relevant WBG EHS Guidelines (ESAP #5).

Pollution Prevention - Wastewater: Phase I of both PIA and GDIZ have one operational CETP each. The amount of wastewater generated is expected to vary between 60% to 80% of water consumed, depending on industry or other land-use. Arise IIP will contractually require industries with a higher pollutant load to undertake pre-treatment to meet specified standards prior to discharge into the trunk pipeline connecting to Common Effluent Treatment Plants (CETP) for further treatment. The CETPs will be designed for the intended purpose of the treated wastewater and in line with national laws and relevant WBG EHS Guidelines. Based on the findings of the WRSA, (ref. ESAP #5) treated wastewater may be reused for landscaping as necessary.

All operational SEZs have surface water drainage systems that discharge water into the environment. Surface water drainage systems at the SEZs have been designed in line with the recommendations made in the project ESMPs and relevant WBG EHS Guidelines, and additional treatment methods, such as installation of settlement tanks/oil separators will be implemented if needed per effluent monitoring results. As per ESAP # 5 piezometers shall be installed at predetermined locations around the SEZs from where ground water levels as well as condition will be monitored regularly and should any pollution be unveiled over time, to identify it source and implement corrective actions.

Pollution Prevention Air and Noise: Air emissions will primarily be dust/ particulates during the construction phase and fugitive emissions from equipment and vehicles during construction and operations phases of the SEZs. Noise is also expected mainly during construction. These emissions will be managed and monitored as per the provisions of the respective management plans to be developed under PS 1 (ref. ESAP # 1 and ESAP # 3). Any air or noise emissions associated with the operation of the industrial units will be managed in accordance with national law and Arise Tenant E&S requirements.

Solid and Hazardous Waste: Types of solid waste associated with industrial tenants during operations is likely to include process waste (e.g., textile offcuts, etc.). The project will develop Waste Management Plans for operations phases (ref. ESAP # 3). The plans will outline the process for appropriate waste segregation, storage, transportation, and disposal. Non-hazardous solid waste will be collected by Arise IIP from each tenant, subject to a commercial agreement and managed in accordance with the plan.In the absence of such an agreement, tenants will be responsible for managing their own non-hazardous waste in accordance with the approved waste management plan. Management of hazardous waste will be the responsibility of each industry in line with national law and Arise Investors E&S requirements.

Hazardous Materials Management: Petrol/diesel for generators will be stored in above-ground storage tanks fitted with containment bunds. Any other hazardous chemicals will be stored in small quantities on site and the measures identified in the management plans will be implemented to minimize any impacts. Arise has an Exclusion Policy that forbids industrial tenants from undertaking activities that manufacture or use chemicals or hazardous materials subject to international bans or phase outs. Tenants are expected to mostly be non-polluting industries; any use of hazardous materials will be in line with national law and Arise Tenants E&S requirements (ref. ESAP #2). The project will also develop a spill prevention and response plan commensurate with the potential risks present at the site. (ref. ESAP # 3).

Community Health and Safety: PIA and GDIZ are in rapidly expanding peri-urban zones. All SEZs are connected to their country's respective capital cities by road and close to several communities. The main community health and safety risks associated with the SEZ activities are (i) an increase in traffic during the construction and operation phases,(ii) increase pressure on community infrastructure and resources (iii) increased risk of health issues associated with construction related air and noise pollution, and (iv) GBVH related to the influx of workers and economic migrants. The transport of raw materials and finished products is predominantly managed by a transit company, which ensures adherence to regulatory and safety standards. Comprehensive training programs on defensive driving, code of conduct, and sexual harassment prevention are provided to all drivers and contractors. The ESMP under PS1 includes commitments to develop several plans during the construction and operations phases to manage these risks, including a Traffic and Road Safety Plan, a Community Health and Safety Plan, and an Influx Management Plan (ref. ESAP #3).

Life and Fire Safety: Each SEZ has a dedicated L&FS system in place and measures are in place to fight to detect and address bush fires that could extend to the zone. The GDIZ on-site fire station is manned by 10 to 12 firefighters per shift and supported by a fully equipped fire truck on standby. The facility is outfitted with an internal water pipeline system that supplies sprinklers throughout the premises. Regular audits, inspections, mock drills, and external evaluations ensure robust fire safety standards. The textile factories feature advanced heat detection technology, CO2 extinguishing units, multiple fire posts, beam and smoke detectors, manual alert systems, and clearly marked emergency exits. All operations adhere to OHS and OSHA standards, with certification from the Benin fire department and annual re-inspections conducted to maintain compliance. As part of the IFC financing Arise will maintain regular coordination (ref. ESAP #2) with the tenants in matters of ERP especially on L&FS measures at factory level.

Security Personnel: Each project SEZ site is enclosed by permanent fencing, with a single entry and exit point for both workers (on foot) and vehicles. Security and access control is provided on a 24-hour basis by unarmed security guards engaged through outsourced and authorized private security companies. As part of the operational ESMPs in in Togo and Benin, Arise IIP will undertake a Security Risk Assessment and update/ develop a Security Management Plan for each SEZ as per PS4 requirements and as guided by the IFC Good Practice Handbook on the Use of Security Forces: Assessing and Managing Risks and Impacts (ESAP # 3).

No tangible or intangible cultural heritage sites within PIA Phase 1 h been identified. GDIZ Phase 1 site has a 4.4 ha sacred forest under the custodianship of Anavie village. Arise IIP has fenced off the sacred forest to preserve and protect it from the development and allows the community members to access it. The management of the sacred forest will be done in line with the plan proposed under ESAP # 3.

Stakeholder Engagement Plans (SEPs) in line with PS 1 requirements were developed to guide stakeholder engagement activities for the ESIA and RAP development and for the future construction and operation of the SEZs. Engagement with key stakeholders such as local and traditional authorities and project affected communities has been undertaken in various forms (consultations, public meetings, focus groups and interviews/ surveys) to gather information for the social baseline, understand community issues and perceptions, and provide project feedback. Key concerns raised for both SEZs included how loss of land and livelihoods would be managed, adequacy of compensation measures, effects on social cohesion, community safety resulting from increased traffic, concerns about noise impacts, and access to employment opportunities. Minutes and attendance records of meetings undertaken by Arise IIP are maintained. Both SEZs have appointed a full time CLOs to manage relations between the SEZs and the communities. A corporate level Grievance Policy and Community Grievance Mechanism (CGM) in line with PS1 requirements and designed to be adapted at each SEZ is in place. To date most of the grievances logged have been in relation to compensation matters associated with the land acquisition. Arise IIP will enhance the communication campaign for the affected communities to increase awareness of how the CGM functions including how a member of the community can file a complaint.(ESAP #1).

Contact Person: Bhavin Vyas ESG Vice President

Company Name: Arise IIP

Address: Emirates Financial Towers - Dubai - United Arab Emirates

Email:bhavin.vyas@arisenet.com

Phone: