This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability. Key E&S risks and issues associated with this project include: the company’s capacity and systems to assess and manage E&S risks and impacts from its operations – including future developments; occupational health and safety (OHS) risks including exposure to infections and hazardous materials; assurance of fair, safe and healthy working conditions including systems to address gender based violence and harassment (GBVH) risks in compliance with local regulatory and PS2 requirements; emergency preparedness and response including life and fire safety risks; pollution prevention including management of biomedical wastes, e-wastes and hazardous chemicals; and stakeholder engagement.

The company’s laboratory operations in Bengaluru and Mumbai have instituted quality management systems that are accredited to College of American Pathologists (CAP) Laboratory Accreditation Program. The infectious lab facilities within the larger facility are certified to ISO 15189:2012 Standards by India’s National Accreditation Board for Testing and Calibration Laboratories (NABL). The CAP and NABL accredited quality management systems address key E&S aspects of lab operations such as: occupational health and safety; waste management; chemical hygiene; fire safety; emergency response and incident management. The company recently promulgated an overarching corporate environmental and social governance (ESG) policy complementing the existing E&S related policies. In the ESG policy, company commits to: ensure compliance to state and national law related to environment, safety, and labor; promote efficient use of materials and resources; provide a safe and healthy working environment for employees and contractors; ensure no child, forced, slave or trafficked labor in its value chain; offer equality of opportunity to all employees and not to engage in or support discrimination; develop and maintain equitable procedures to deal with employee grievances and disciplinary practices; evaluate and select major suppliers and subcontractors assessing their ability to meet the requirements of company’s ESG policy; and strive to continually improve environment and social performance by periodically reviewing policy and practices.

The company identifies and mitigates E&S risks and impacts in its operations by straightforward application of local regulatory requirements, permit conditions, and pollution standards. The company is current on its E&S permits and regulatory submissions. As part of IFC investment and as per agreed environmental and social action plan (ESAP) #1, the company agrees to formulate and implement E&S risk screening process to assess legacy E&S and regulatory compliance risks associated with all future developments including the proposed small acquisitions and partnerships planned under the project and the overseas expansion. The outcome of E&S risk screening process shall be integrated into business decision-making procedures and be a key factor in “go or no-go” decisions of the company management and development of corrective actions plans as needed, to ensure compliance with IFC PS requirements.

The company has instituted a Corporate Environmental and Social Governance (ESG) Committee to manage the E&S risks and impacts arising out of its business operations and is currently formulating the ESG Committee operational procedures. The operational E&S issues associated with the lab are managed by the Laboratory Director supported by a dedicated health and safety officer.

The company has a documented procedure covering the emergency response planning (ERP) or business continuity management at its operational locations. The ERP covers emergencies such as: fire, severe weather conditions, flooding, power/water outage, civil disturbances, earthquake, HVAC failure, loss of specimen samples, and IT/computer network related emergencies. The company has promulgated procedures to undertake statutory environmental monitoring and reporting as per regulatory permit and the requirements of CAP and NABL accreditation. The existing quality management systems has instituted periodical internal audit checklists-based auditing and review systems covering key E&S aspects. The accredited facilities are externally audited under the CAP and NABL accreditation program.

As of February 2021, the company employed 500 on-roll staff (including 185 female staff) and engaged 56 contract workers across all its locations in India. Contract workers are mainly engaged for security and housekeeping duties.

The company has documented HR policies and procedures that are generally compliant with the local labour laws and IFC PS 2 requirements as well as those related to gender and gender-based violence & harassment (GBVH) issues. Key HR policies are published in Employee Handbook that is accessible to every staff.

The company does not restrict freedom of association of its employees though no employee/labour union is operational at any of its facilities. The company’s Employee Grievance Redress Policy, included in the employee handbook, provides a framework to resolve the grievances. The policy provides for a grievance redress process and formation of an internal 4-member grievance committee. Prevention of sexual harassment (POSH) policy defines and categorizes types of behaviours that will be construed as sexual harassment; presents the process to be adopted by internal Grievance Redress Committee (GRC); and provides for forming the internal GRC comprising of 7 members. As part of IFC investment and as per agreed environmental and social action plan (ESAP) #2, the company agrees to review its existing grievance redress policy and mechanism including POSH related grievance redress mechanism to allow for anonymous complaints to be raised and addressed.

Occupational Health & Safety (OHS): The CAP and NABL accredited quality management systems covers risks and impacts related to OHS. The company has documented OHS management program comprising of facility safe work policy; vaccination policy; safety manual; and procedures in place that are compliant to IFC General EHS guideline requirements. Every facility maintains an incident and accident log and the company reports zero incident or accident in the last 2 years across all its facilities and operations in India.

Immunization (Vaccination) against Hepatitis B is mandatory for those staff who may get occupationally exposed to human blood/blood stained body fluids. Annual health check-up is mandatory for all staff of the company. As part of CAP and NABL accreditation requirements, the company conducts instantaneous monitoring of volatile organic compounds (VOC) at laboratory to establish risks associated with occupational exposure. The company is currently working on revising and updating its OHS procedures with regards to health surveillance program based on the hazards identified and instituting an annual monitoring of indoor air quality and workplace VOC exposure monitoring program.

COVID-19 impact on the company’s workforce: The company did not undertake any retrenchment during the nation-wide lockdown phase and instead implemented a company-wide reduction in salary for initial 3 months duration after which the normal salary levels were restored. As an essential service provider, company was permitted to operate through the lockdown period during which employee’s health and safety were given priority. The company formulated and implemented a COVID safety protocol in its operations to prevent infections at workplace. Staff were provided with work passes for unhindered travel, private transport facility, food, and temporary accommodation for those in need. All other non-critical staff are encouraged to work from home and the practice is still being continued. Since the COVID-19 outbreak, the company has been communicating with its staff on safety precautions to be followed. Currently, all its staff are being vaccinated at the company’s cost. The company has reported that out of its 500 on-roll staff less than 15 staff were infected in the last 12 months.

The company records energy consumption but has not initiated resource conservation programs and estimated Green House Gas (GHG) emissions from its operations yet. Based on electricity and diesel consumption data available for company’s Bengaluru facility, the GHG emissions are estimated to be less than 1,500 tons of CO2eq per year.

Water for domestic consumption is sourced from local utility agencies. There are no air pollution sources other than a back-up diesel generator at its Bengaluru facility. The DG set is installed, operated and monitored for stack emissions & noise levels as per permit conditions.

The process wastewater stream (30 liters per day in Bengaluru Lab) is disinfected and stored onsite before transporting by road tanker to common wastewater treatment facility operated by an authorized 3rd party agency. The domestic wastewater across all the facilities are either treated in the onsite sewage treatment plant (STP) installed and operated by the landlord or discharged into municipal sewerage system.

The company generates waste streams such as municipal solid waste; biomedical waste; hazardous waste; used battery waste; and e-waste albeit in smaller quantities. To manage the risks and impacts arising out of waste management, the company has formulated a waste management policy that defines the procedures for the management of the wastes generated by the Lab through licensed contractors, in line with local regulatory and CAP and NABL quality system requirements.

The lab operations involve purchase, storage, use and handling of organic solvents and occupationally hazardous nucleic acid staining dyes. The safety manual has documented safety procedures covering the safe storage, handling and disposal of organic solvents, chemicals and gels used in the labs. In order to maintain a safe and healthful work environment, the company has developed chemical hygiene plan for all employees and contractors. The intent of this plan is to advise employees of the hazards associated with laboratory chemicals and to keep exposure of these chemicals to a minimum through engineering controls, administrative controls and personal protective equipment

For pest control, the company has a service contract in place with a 3rd party agency and the pest chemicals used internally and externally once in a month do not fall under WHO Class 1a or 1b.

As part of CAP accreditation, the company has mapped risks associated with its laboratory operations. The laboratory buildings and structures are not open to public access.

The company has arrangements with third party commercial logistics services providers in India for collecting samples from its network of 1600+ hospitals and 5500+ clinicians and deliver to the Company’s facilities across India. Adequate safety and infection control protocols are in place, in line with applicable regulatory requirements. The Bengaluru main lab and all other satellite labs are in urban areas that have good transport infrastructure and hence the traffic impact due to project is assessed to be low.

On life and fire safety, the company has formulated specific policy on fire safety. As part of fire safety infrastructure, fire extinguishers are installed at key locations throughout the lab and the safety map displays the places of the fire extinguishers and emergency exits. At all locations, there are smoke detectors, identified fire exits, fire evacuation plans, fire alarms, and fire hydrant pumping system.

Emergency evacuation plan with exit signages map are installed at key locations inside the lab. All the staff of the company are provided the life and fire safety training as part of the induction training program. The company provides fire safety training once in a year to all the staff including the usage of the fire extinguishers and conduct of the personnel in case of any emergency. As part of fire safety procedures, fire infrastructure is inspected monthly once based on an audit checklist. Additionally, the key L&FS infrastructure such as fire alarm panel are tested using 3rd party specialist agencies regularly. The company undertakes periodic fire evacuation drills and documents the same.

Unarmed security personnel have been deployed across all operational units through local security vendors authorized by government. The company briefs security personnel about policies on child labour and provides training on basic safety, first-aid, fire safety and emergency response.