While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts that must be managed in a manner consistent with the following Performance Standards

PS1: Assessment and Management of Environmental and Social Risks and Impacts

PS2: Labor and Working Conditions

The company does not own physical assets (except offices in Mumbai and Bangalore in leased premises), and provides online education, without physical classrooms. Hence, the issues and risks envisaged by Performance Standards (PS) 3: Resource Efficiency and Pollution Prevention, PS4: Community Health, Safety and Security, PS5: Land Acquisition and Involuntary Resettlement, PS6: Biodiversity Conservation and Sustainable Natural Resource Management, PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected for this investment.

This is a Category B project according to IFC's Policy on Environment and Social Sustainability. Key E&S issues assessed include: HR policies and practices; grievance mechanism for promotion of gender equality at workplace; responses to the COVID-19 impacts; and life and fire safety (L&FS) for the office facilities.

Given that the nature of the company's business operation (online education platform), E&S risks related to this investment are limited. The company manages its operations in compliance with applicable national and local laws and regulations

Policy: The company has established several policies relevant for its day to day operations. These include primarily HR related policies such as: Employee Conduct and Work Rules Policy, Employee Grievance Mechanism Policy, Prevention of Sexual Harassment, Leave Policy and Relocation Policy. Through these policies, the company has committed to healthy and safe work environment and good working conditions.

In addition, Privacy Policy is also in place which stipulates how the company should collect, use, update, delete or share information collected from users through its platform in accordance with relevant data protection laws such as General Data Protection Regulation, 2018, the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures And Sensitive Personal Data or Information) Rules, 2011.

Organization: Head of Administration oversees compliance with regulatory requirement (e.g., No Objection Certificate for fire safety from the local fire department), while the HR team oversees HR aspects in general. Both administration and HR teams are stationed in Mumbai Office where they report to senior management supported by staff in Bangalore office.

Monitoring and Reporting: Management Information System is in place, with the Internal Audit team responsible for monitoring and internal reporting. Key performance indicators (KPIs) are reported to senior management on a monthly basis including HR-related information, asset management, regular inspection of life and fire safety equipment, etc. Such internal monitoring is then audited by external auditors on a quarterly basis, reports of which are submitted to senior management directly from the external auditors.

Emergency Preparedness and Response: As the company’s two offices are located in leased commercial buildings, emergency preparedness and response, including L&FS are primarily a responsibility of the building owners. On the other hand, the company also ensures compliance with fire safety requirements and obtains permits from the local fire department, and regularly conducts inspection for the fire safety equipment. In addition, fire drills are conducted annually, and training sessions are provided particularly to fire marshals semi-annually who are in charge of leading evacuation in case of emergency in their respective departments. Reports on drills and trainings are shared with senior managements indicating observations for improvements of fire safety management. The company has developed and implemented necessary measures for COVID-19 pandemic in accordance with government requirements.

At the time of appraisal in Jan 2021, the company had more than two thousand employees, with more than half of them being female employees. The majority of the employees are full time, with fixed-term employees, consultants and third party workers comprising of less than ten percent of the total number of employees.

Human Resources Policies and Procedures: The company has documented HR policies and procedures in place aligned with national labor laws and PS2 requirements. These cover Employee Conduct and Work Rules Policy (e.g., ethical conduct, fair manner, confidentiality), Employee Grievance Mechanism Policy, Prevention of Sexual Harassment, Leave Policy and Relocation Policy. These policies are communicated with employees through intranet, induction sessions, etc. Terms and conditions of employment (e.g., working hours, salary, benefits) are stipulated in a written appointment letter issued to each employee at the time of joining.

Considering the nature of the company’s business and the workforce, no child labor or forced labor is expected at the company’s operation. HR team ensures that no employee below 18 years of age is hired by checking age proof documents.

Grievance Mechanism: A documented grievance redress mechanism is in place which is applicable to all employees regardless of employment type to raise all types of issues.

While the policy stipulates escalation hierarchy to be followed, channels of communication is currently limited to emails and grievances raised anonymously cannot be addressed except that employees can reach out to Head of HR for confidentiality if in fear of retaliation. As per ESAP #1, the company shall update the grievance mechanism policy by allowing anonymous grievance raising through various channels (e.g., open door policy, intranet, suggestion box) in addition to email, and make it accessible to all employees.

Currently there is no employee union in pace. However, the company does not restrict formation of the employee unions; as the Constitution of India provides for freedom to assemble and the freedom to associate.

Occupational Health and Safety (OHS): Significant OHS risks and impacts are not expected considering the nature of the company’s business operation. As such, no accidents, incidents or injuries have been reported at office premise in the past 3 years. Vehicle safety training is provided to the outsourced drivers of commuter transportation by their direct employers. Awareness to safety for female employees during transportation in the course of duty is also highlighted in its policy in addition to safety at workplace.

Prevention of Sexual Harassment: To promote safe work environment for all its employees free from sexual harassment, the company has a documented formal Policy on Prevention of Sexual Harassment (POSH) as per applicable legal requirements. POSH covers aspects such as awareness raising, prevention, grievance mechanism, etc. Grievances related to sexual harassment are handled by Internal Complaints Committee comprising of 10 members including nominated members. In addition, employees are required to take annual awareness training sessions for POSH and as part of induction session for new employees.

Impact of COVID-19 Pandemic on Workforce: In the current COVID-19 situation, the company is encouraging the employees to work from home taking the advantage of existing remote IT infrastructure to the extent possible. It also has created a helpline channel so that employees can reach out in case of any emergency or when support is required. All possible measures have been taken for employees who need to work at office such as adequate social distancing, use of separations, hand sanitizing, use of face masks, etc. As such, the company did not implement any significant changes to its workforce in terms of reduction of personnel, salary and benefit cuts, or changes to contracts.