All of Hikal’s six operational manufacturing facilities are located inside industrial estates and the R&D facility is at Pune, Maharashtra. All the estates are long established and in existence in excess of 15 years. No additional land is required for the CAPEX program at the Pune, Panoli and Taloja locations.  However, Hikal is in the process of acquiring additional industrial land located within the industrial estate for the plant expansions in Mahad and Jigani. This land is vacant with no encroachment and not physical or economic displacement required. In Gujarat and Maharashtra, the respective industrial estate authorities have allocated the land to Hikal on which existing facilities operate on a 100-year lease. In Karnataka, the ownership and title deed of industrial land at Jigani has been transferred to Hikal.

Given the above whereby Hikal’s existing and proposed facilities are located within established industrial areas, isks and impacts associated with land acquisition, biodiversity, indigenous people and cultural heritage will not occur. Therefore, PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable to the project.

This is a Category B project in accordance with IFC’s Environmental and Social Sustainability Policy. Key E&S risks and impacts include: ii) the Company’s E&S management system (ESMS) including organizational capacity so as to effectively manage operations aligned with the Performance Standards, national requirements and good international industry practice (GIIP) ii) fair, safe and healthy working conditions including occupational health and safety (OHS) and COVID infection control aligned with local regulatory requirements and current good manufacturing practices (cGMPs) as applicable to the pharmaceutical and pesticide sector; iii) pollution prevention including emissions and discharge of volatile organic compounds and other gaseous compounds; iv) compliance with local and international regulatory requirements for hazardous chemicals and material use aligned with GIIP; v) management of risks and impacts on communities associated with storage and transport of hazardous materials; vi) life and fire safety and onsite and & off-site emergency preparedness systems; and 7) cumulative impacts.

Environmental and Social Policies: Hikal has a documented overarching corporate EHS policy in place which is applicable to all its facilities. The EHS policy commits to compliance with all applicable EHS laws and regulations in India to ensure a safe and health working environment for all employees. The policy also commits to prevent or eliminate undesirable EHS risks and impacts which may result in injuries / loss of life and damage to the environment throughout Hikal’s operations. Hikal supports compliance with the EHS policy through strict adherence to all applicable legal and statutory requirements.

Identification of Risks and Impacts: An Environmental Impact Assessment (EIA) is required as per the Indian EIA notification (2006) for greenfield developments and brownfield expansions associated with Hikal’s activities. Accordingly, Hikal has prepared EIA reports with support of certified external consultants as per regulator approved Terms of Reference (TOR) for all its existing facilities and for those to be expanded except the EIA for the facility expansion at Mahad as described later in this section. In addition to baseline environmental status, modelling analysis, impact assessment and mitigation measures which are overall satisfactory and in line with the WBG EHS Guidelines and IFC PS’s, EIA reports also undertook quantitative risk assessments (QRA) for the proposed raw materials to identify area of impact in case of accidental chemical release including ammonia. The QRA indicates that area of worst hazard is within 1km for all the hazardous chemicals for which a QRA has been undertaken. Considering that manufacturing facilities are located within the notified industrial areas and the nearest communities are at least 1km distant, review of the EIA reports indicates that potential impact on community in case of any failure is considered to be limited.

As per ESAP #1, Hikal shall submit the EIA reports (inclusive of QRA reports as applicable) to IFC for the Mahad facility expansion (including multipurpose plant and plant for biocide manufacturing) which will be initiated after the required land has been secured. Based on the findings of the EIA and QRA, Hikal will agree with IFC on mitigation measures to be implemented.

As per ESAP #2, Hikal shall finalize the QRA reports for hydrogen storage at all existing facilities where this is used as a raw material (i.e., Jigani-1, Jigani-2 and Mahad) so as to assess the hazard and impacts on adjacent areas including neighbouring communities in the event of any incidents.  Based on the findings the Company will then agree with IFC on mitigation measures if required and incorporate the QRA findings into the applicable emergency preparedness should neighbouring communities are found to be within the area of hazard .

In addition, as part of OHS risk assessment procedures, Hikal undertakes Hazard Identification and Risk Assessment (HIRA) for all activities and operations based on occupational exposure levels (OELs). Quantitative exposure assessments along with mitigation and prevention measures have been incorporated into Hikal’s standard operating procedure (SOP) on Industrial Hygiene, Hazard Communication & Respiratory Program which is described in PS2 below.

Furthermore, Hikal does not procure, manufacture or sell any raw materials or products which are banned / regulated by Indian regulations or international conventions such as Stockholm Convention on Persistent Organic Pollutants, World Health Organization Recommended Classification of Pesticides by Hazard, Rotterdam Convention on the Prior Informed Consent Procedure for Certain Hazardous Chemicals and Pesticides in International Trade, or Food and Agriculture Organization’s International Code of Conduct.

EHS Management Program: Hikal has instituted ESMSs’ that are certified to international standards including ISO14001, ISO9001 and ISO45001 (environmental, quality and OHS respectively) at all the pharmaceutical and crop protections facilities. In addition, pharmaceutical facilities (Jigani and Panoli) have been inspected and certified by the respective global regulatory authorities including the US Food and Drug Agency (USFDA), Pharmaceutical and Medical Devices Agency (PMDA) in Japan, Therapeutic Goods Administration (TGA) in Australia, Korea Food and Drug Administration (KFDA) in South Korea, as well as having received EU cGMP approval. Hikal has also enlisted its pharmaceutical manufacturing facilities under the Pharmaceutical Supply Chain Initiative (PSCI) with the independent audits having been completed in September 2021. Pharmaceutical manufacturing facilities are expected to join the PSCI program soon. Hikal’s facilities have current and valid legal permits including that related to Environment Clearance, Factory License, Consent to Establish, Consent to Operate and Hazardous Waste Authorization from the local State Pollution Control Board (SPCB), Petroleum & Explosive Safety Organisation (PESO) License, Hydrogen License and Fire No Objection Certificate (NOC) for all buildings as applicable.

Moreover, Hikal has developed more than 30 standard operating procedures (SOPs) at the facility level covering various EHS aspects such as chemical handling, HAZOP studies, OHS, workplace monitoring, incident reporting and investigation, safety review of facility, and others.. Details of these SOPs are described in the respective section of this ESRS as needed.

Organizational Capacity and Competency: At the corporate level, EHS and sustainability is headed by the Head – EHS and Sustainability who is a trained engineer with over 20 years of experience in managing E&S aspects and is under direct supervision of the Managing Director & CEO. Business operations are largely divided into two divisions i.e., Pharmaceuticals and Crop Protection, where Head - EHS staff are assigned to oversee each respective business line at the corporate level including coordination of EHS activities at the facility level. At the facility level, 10-15 qualified and experienced staffs are assigned at each facility as members of the EHS team who manage daily EHS activities such as safe hazardous chemicals/material handling, life and fire safety, process safety, incident management, pollution control, training and capacity building, EHS quality monitoring, auditing and performance reporting etc.

Emergency Preparedness and Responses: An on-site emergency plan is in place at each facility based on the Hazard and Operability Analysis (HAZOP) and QRA undertaken as part of EIA. On-site emergency plans cover various emergency situations such as fire, toxic gas release, spillage of chemicals, natural disasters, food poisoning, as well as the handling of pandemic situation. In the plan, emergency situations are classified into five categories where necessary actions to be taken are stipulated based on the magnitude of emergency situations. For example, Category I is for a minor emergency situation which may or may not cause damage on properties without requiring evacuation while Category IV stipulates emergency situations requiring evacuation and actions for both on-site and off-site. The onsite emergency plan is reviewed and updated every two years or when any major changes to activities occurs.

Facilities are designed and constructed in accordance with the National Building Code 2016 in India and are subject to external audits as per statutory requirements. Facilities are assessed to be equipped with adequate emergency infrastructure including fire suppression system (e.g., fire extinguisher, siren, fire hydrants, smoke detectors, sprinklers, fire reservoir, fire pumping system), medical rooms, ambulance van, automated external defibrillator, emergency control center, emergency cupboard and trolley, site evacuation route and organization chart displayed at visible places, and others. Mock drills are provided to employees on a regular basis (e.g., 3 fire drills per year, monthly checking of fire hydrant and fire extinguishers, refilling of fire extinguishers every two years), statistics and findings of which are compiled into a report to be shared with Head – EHS at the corporate level.

Off-site emergency plans are also established to respond to major emergencies which can typically occur externally to facility premises including transportation of treated effluent, hazardous wastes, solvent and finished goods and intermediates from Hikal’s facilities to suppliers. Off-site emergency situations are handled by Hikal’s Safety, Commercial, Marketing & Quality Assurance Team in close coordination with the District Emergency Authority (DEA), a local government authority at the respective State, based on off-site emergency plans developed by the DEA.

No significant emergency situations have occurred in the past.

EHS Monitoring and Review: Regular EHS monitoring practices are in place at the individual facilities which are managed by the respective EHS teams. Key performance Indicators (KPIs) such as incident statistics (e.g., reportable incident, first aid, near misses), training statistics (e.g., training hour provided to employees), environment statistics (e.g., resource consumption, environmental monitoring), life and fire safety audit reports by independent auditors as per the national and local regulatory requirements, and legal and statutory updates are collected and compiled at the facility level. Details of this monitoring are described in the respective sections of this ESRS. These KPIs are compiled and shared with the Head – EHS at the corporate level on a monthly basis. Based on the information collected from facilities, a meeting of the Sustainability and EHS Committee is held every two weeks chaired by the Head EHS and Sustainability. In addition, Hikal has recently initiated new initiatives for EHS monitoring and reviewing such as; i) use of balance score card systems wherein 65 indicators are used with weightages defined to assess the compliance and performance level; and ii) a tracking system of legal clearances using legal registers and a software systems (Aventis) in which alerts are sent for permit renewals and escalated to corporate level if alerts are not adequately addressed at facility level,  Further, Hikal expects to start publishing a an annual sustainability report in 2023.

As of October 2021, Hikal employs approximately 1,660 direct staff (7% female employees). In addition, there are approximately 650 third party employees / contract workers. Some 100-200 employees workiat each facility on average, with the largest number of employees being 530 at the Jigani Unit 1. Staff turnover (attrition) rates have been approximately 15% in the past few years which is well aligned with the sectoral trends according to Hikal. Some of the causes of attrition are due to junior staff separation seeking for career advancement after being trained and gaining experience at Hikal.  Hikal has won awards previously including the coveted Confederation of Indian Industry’s “Significant Achievement in HR Excellence” award in 2019, and “India’s Best Companies to Work for 2019” by the Great Place to Work Institute.

Human Resources Policies and Procedures: Hikal has a set of established human resource (HR) policies which are applicable to all employees and facilities. The HR policies and procedures cover aspects such as prevention of sexual harassment and gender-based violence and harassment (GBVH), workers’ organization rights (freedom of association), non-discrimination and equal opportunity, prevention of child labor and forced labor, occupational health and safety, retrenchment, grievance mechanism covering all types of employees and workers engaged by third parties.

Working Conditions and Terms of Employment: Hikal shares the documented HR policies and manuals with the employees at the time of joining, and issues appointment letters to all direct employees in which the working conditions and terms of employment based on company HR policies are defined. Working conditions and terms of employment are aligned with the statutory requirements set by the local regulatory framework including minimum wage, working schedule, overtime, social security benefits (e.g., Employees’ Provident Fund, Employee’s State Insurance), and others. The Union Agreement concluded between employees and management at the facility level also stipulates excess wage payments associated with overtime work and night shift work, compensation and benefits, as well as other working conditions. Hikal monitors working hours of its employees and keeps records to ensure that excess wages are adequately paid and to ensure that employees do not work more than that allowed as per the regulatory requirements.

Non-discrimination and Equal Opportunity: Hikal has its Code of Conduct where Hikal explicitly sets clauses to commit to promote and maintain a culture of diversity and equal opportunity supported by ethical business practices and regulatory compliance. . The Code commits that all decisions on recruitment, selection, compensation, development and promotion must be made solely on the basis of a person’s ability, quality of experience, behaviour, work performance. In addition, the Sustainable Procurement Policy also promotes non-discrimination practice at vendor locations where a vendor must ensure there is no discrimination in their hiring and employment practices on the basis of race, colour, gender, age, nationality, religion, sexual orientation, marital status, citizenship, disability, veteran status, medical condition etc.

Worker’s Organization: Hikal does not restrict the formation of the employee unions as the Constitution of India provides for freedom to assembly and association. In practice, all manufacturing facilities have operational worker unions and Hikal concludes the Union Agreement between employees and managements at the facility level to promote collective bargaining power and worker rights.

Retrenchment: Hikal has not undertaken any collective dismissals in recent years even during the COVID-19 pandemic. All possible alternatives to retrenchment shall be considered in coordination with unions based on the Union Agreements, if any retrenchment is unavoidable, and the dispute is settled based on the regulatory requirements such as Industrial Disputes Act. As per ESAP #3, Hikal shall formalize and documents its policy on retrenchment in accordance with IFC PS2 requirements ensuring analysis of alternatives to retrenchment, measures to reduce the adverse impact where retrenchment is not avoidable, a retrenchment plan based on the principle of non-discrimination, consultation with workers, and compliance with the regulatory requirements.

Grievance Mechanism: Hikal currently does not have formalized grievance mechanism for its employees and grievances are handled through supervisors, HR, and a Works Committee. As per ESAP #4, Hikal shall formalize and document its grievance mechanism in accordance with IFC PS2 requirements and ensure this facilitates anonymous grievance reporting and is accessible to workers engaged by third parties and inform all employees and third party workers as applicable of the established mechanism.

Protecting the Work Force: Considering the nature of Hikal’s business and the workforce, child labor or forced labor is not expected at Hikal’s operation. Hikal ensures that no child/forced labor will be employed by checking age proof documents, adhering to the regulator requirements (e.g., India Child Labour Act) as well as provisions in the Code of Conduct policy as described in the “Non-discrimination and Equal Opportunity” paragraph above.

Workers Engaged by Third Parties: Approximately 28% of staffs working at Hikal are engaged by third party agencies or contractors who perform work related to the core business activities for a substantial period. Hikal ensures adequate management of workers engaged by third parties and regulates their working conditions by strictly adhering to the Contract Labour Act in India. To strengthen its practice related to third party labor working conditions and as per ESAP #5, Hikal shall develop and implement a policy and supported procedures to manage and monitor workers engaged by third parties to ensure this is in a manner consistent with the requirements of IFC PS2.

As for construction contractor management, Hikal has SOP on contractor management program including pre and periodic evaluation. Hikal evaluates contractors based on SOP’s to check whether the contractor has adequate certifications such as ISO14001 / ISO45001, EHS policies and procedures, an EHS committee, use of safety equipment, no use of child labor by checking identification, amongst other. . Inspections and evaluations of contractors are undertaken on a regular basis based on a checklist and records of inspections are adequately kept. When signing a documented contract with contractors, they are noted to include specific provisions such as implementation of the EHS manual, prevention of child labor and compliance with applicable labor law requirements.  

Occupational Health and Safety (OHS): Hikal has established procedures for OHS management which are appropriate to the nature and scale of its business operations and which have been certified to OHSAS 18001/ISO 45001 Standards for both the pharmaceutical and crop protection facilities. A Process Safety Management Manual has been developed based on OSHA 29 CFR-1910:119 (process safety management guidelines) and OSHA 29 CFR-1910:120 (hazardous waste operations and emergency response) to prevent unwanted releases of hazardous chemicals which could expose employees to serious hazards. The manual and OHS practice are further strengthened by Hikal’s various SOPs including that related to hazardous waste handling, handling of chemical spills, operation and inspection of emergency safety equipment, selection and use of PPE, workplace monitoring and others.

Quantitative industrial hygiene exposure assessments have been undertaken considering exposure patterns, hazard rating, airborne risks of chemicals, threshold values, existing engineering controls, etc. Occupational exposure levels (OEL) are defined based on an assessment undertaken by an external consultancy, which are then incorporated into the SOP on Industrial Hygiene, Hazard Communication & Respiratory Protection Program. Workplace environmental monitoring is undertaken by Hikal on a regular basis including chemicals (particulate, gas, vapor), noise, illumination level, exposure to heat and cold, exposure to vibration, and ergonomic hazards. In addition, workplace health assessment and monitoring by an independent consultant (certified industrial hygienist) is also being undertaken mainly covering the powder handling areas (e.g., centrifuge, crystallization, areas of milling / shifting / packing, and the packing material storage) with the methodology including baseline sampling, assessment of operator exposure levels and area sampling. These monitoring results and reports indicate that Hikal’s facilities and operating systems are adequate for handling materials used, and concentration of personal monitoring are either below OEL or the level which requires action.

Engineering controls are also installed to minimize OHS risks including local exhaust ventilation systems (e.g., dust collectors, fume hoods, scrubbers) for all fugitive emissions in the workplace. Regular workplace monitoring is in place based on the SOP on “Inspection of Local Exhaust Ventilation System” to capture potentially toxic contaminants at the source of generation and transport of these materials to an appropriate collection system/scrubber.

As for OHS statistics, incidents/accidents are recorded and maintained on a regular basis as per local regulatory requirements. Incidents/accidents are investigated, and the root cause analysis records are maintained. In recent OHS statistics, no fatal accidents have occurred, and all the reported incidents are either near miss or first aid in the past three years.  During this period there have been a total of 72 hours of lost time across all operations.

An occupational health center is also in place where paramedical staff are available 24 hours a day and there are nearby hospitals for any medical emergencies. Pre-employment medical and periodic (yearly) medical examination are undertaken as per the regulatory requirements.

Supply Chain Risk Assessment & Management: Hikal procures raw materials both from domestic and international markets. To ensure adequate EHS compliance, Hikal has a documented policy on Sustainable Procurement which outlines Hikal’s expectations with regards to ethics, business integrity, human rights, health and safety, environment, the local community and quality of product and operations. In particular, the Policy stipulates Hikal’s explicit commitment to prevention of forced labor and child labor as one of the requirements which vendors must comply with. Vendors are expected to conduct ongoing self-assessments of various aspects of supply chain management based on the format developed by Hikal before entering into agreement with Hikal.

Furthermore, Hikal undertakes supply chain audits to verify EHS compliance and performance of domestic suppliers and is currently planning to expand its audit practice to international suppliers. International suppliers are selected and recommended by Hikal’s customers after their own detailed audit. Domestic supplier audits are undertaken on a regular basis (once in a year) typically using an EHS Vendor Evaluation Checklist composed of more than 50 audit questions. In addition to providing feedback to vendors, findings, along with audit evidence, are compiled into a report which then are shared with Head – EHS and Sustainability at the corporate level as part of the regular monitoring and review process.

Impact of COVID-19 Pandemic on Workforce: Hikal's operations were not stopped due to the COVID-19 pandemic since April 2020. As an essential service provider, Hikal expeditiously took efforts to ensure facility operations while ensuring health and safety of staff. As one of the aforementioned SOPs, the SOP for Handling COVID-19 Pandemic Situation is established, and all relevant health and safety measures have been rolled out across the facilities including in relation to work shift arrangement and telecommuting. Furthermore, additional support has been provided to employees such as extending medical insurance cover to include COVID infections, increased compensation amounts in case of a COVID fatality, employment to eligible family members in case of a COVID fatality, gratitude pay, foods and shelters as needed. These measures have helped Hikal to ensure smooth operations without retrenchment, job cuts, salary and benefit cuts, or changes to contracts.

Resource Efficiency: Hikal is committed to promoting resource efficiency through adopting good international industry practice (GIIP) to achieve energy and water efficiency and promoting climate smart interventions in its business operations. To reduce its overall energy consumption, the Company is undertaking various resource efficiency measures including use of LEDs, sourcing electricity from solar and wind projects, improvements to equipment efficiency (e.g., boilers, motors), rain harvesting, use of reverse osmosis (RO) plant and other measures. These efforts have resulted in a 28% carbon footprint reduction and 17% water footprint reduction in 2020 compared with 2016.  To ensure a coordinated approach to resource conservation the Company will define as associated program at the corporate and facility level which includes formulation of key performance indicators (KPIs) or targets covering energy, water and raw material inputs and other as deemed applicable. Wherever global/national benchmarking data is available, Hikal will make a comparison to establish the relative levels of efficiency. This is addressed in ESAP #6.

GHG Emissions: Hikal calculates its total GHG emissions based on Scope 1 (e.g., use of diesel in DG sets) and Scope 2 (e.g., use of grid electricity). Based on the recent GHG emissions footprint, the total GHG emission is estimated to be approximately 118,364 tCO2e per year. Hikal further aims at 2% reduction per year until 2030 as a long-term target and this is being addressed by projects such as to the use of briquettes (agricultural waste) for use in the boiler instead of diesel; this is one of the activities being supported by IFC’s investment.

As per ESAP #7, Hikal will institute a program of independent GHG calculation covering all facilities. Quantification of GHG emissions will be conducted by Hikal annually in accordance with internationally recognized methodologies and good practice.

Air Emission Monitoring and Ambient Air Quality: Hikal monitors and manages air emissions from its facilities in accordance with the local environmental permit conditions. Review of recent environmental quality monitoring reports indicates compliance with local regulatory standards and WBG EHS Guideline values. The main source of emissions includes power generation (e.g., diesel generators), boilers, process scrubbers and fugitive emissions. Ambient air quality within the facility premises (including continuous online monitoring) and point source air emissions monitoring are in place as per permit conditions including monitoring of volatile organic compounds (i.e., Benzene, Carbon Tetrachloride, Methanol, Toluene, Methyl Chloride, Acetone, Mercaptan, Hydrogen Sulphide). Engineering controls are installed to minimize OHS risks including local exhaust ventilation (LEV) systems (e.g., dust collectors, fume hoods, scrubbers) for all fugitive emission in the workplace, performance evaluations and maintenance of which is undertaken based on Hikal’s SOP on “Inspection of LEV System”. In addition, regular workplace monitoring is undertaken to ensure prevention of workers’ exposure to hazardous substances. Online gas/vapor detectors are provided, as needed, such as combustible gas detectors, hydrogen sensors, ammonia sensors, fire alarm systems, smoke detectors, heat detectors and other.

For ambient air quality, monitoring parameters include PM10, P2.5, sulphur dioxide (SO2), nitrous oxides (NOx), Ammonia, Ozone, Lead, Nickel, Arsenic, carbon monoxide (CO), hydrogen sulphide (H2S), acid mist and volatile organic compounds (VOCs). A sample of recent ambient air quality monitoring indicate that these parameters are either below detection level or the permissible level of the local requirements as well as WBG EHS guidelines. As for stack emission, monitoring parameters include areas of cross section, flue gas temperature, stack gas velocity, rate of discharge of gas, PM, SO2, NOx, CO and VOCs. While limits are not specified as per regulatory requirements for area of cross sections, flue gas temperature, stack gas velocity, rate of discharge of gas and SO2, parameters including PM, NOx, CO and VOC indicate compliance with the local requirements as well as WBG EHS Guidelines.

Ambient Noise: Major sources of noise include the diesel generator, mechanical movements, boiler operation and materials handling. Noise generating equipment is designed, maintained and operated to ensure that noise levels does not exceed permissible level as per the requirements of local State Pollution Control Board (SPCB). Acoustic enclosures are provided for high noise generating machines and a greenbelt has been developed around the periphery of facilities to mitigate noise. Samples of recent ambient noise monitoring indicates compliance with the regulatory requirements and WBG EHS Guidelines of ambient noise parameters at industrial and commercial zones.

Water and Wastewater: Water is supplied by local industrial estate authorities at facilities in Panoli, Mahad, Taloja, and thorough tankers at Jigani. Hikal’s facilities have effluent treatment plants (ETP) and sewage treatment plant (STP) to treat process and domestic wastewater generated from facility operations. Zero Liquid Discharge (ZLD) systems (including reverse osmosis plant, multiple effective evaporator and drying system) or partial water discharge treatment schemes are also installed at some of the Hikal’s manufacturing facilities. (Jigani has ZLD, Panoli is in process of installing ZLD, Mahad and Taloja do not have ZLD.) Treated wastewater through ZLD is reused for cooling tower application and gardening purposes. In addition, sumps are provided for rainwater collection at storm water exits with online monitoring system installed to monitor pH of rainwater to identify potential contamination. Contaminated rainwater is diverted to the ETP’s before being discharged/reused. Wastewater from facilities without ZLD is treated and discharged through Common Effluent Treatment Plant (CETP), a wastewater management system from a cluster of small-scale industrial facilities, managed by regulatory agencies of the respective States.

Hikal monitors wastewater including parameters as per the regulatory requirements such as pH, total suspended solids, total dissolved solids, biological oxygen demand, chemical oxygen demand, nitrogen, ammonia, sulphates, oil and grease, phosphates, Iron, Sillica, Arsenic, Mercury Bioassay, Lead, Cyanides, Phenol. Parameters also cover those recommended WBG EHS Guidelines. Monitoring samples indicate compliance with the local permissible levesl as well as WBG EHS Guidelines.

Hazardous Materials: Various hazardous materials including chlorine, ammonia, solvents and petroleum products are stored on site. These are all stored in appropriate facilities and clearly designated areas as applicable. Hikal has obtained the necessary regulatory permits to handle, store and use solvents and petroleum products such as the Petroleum & Explosive Safety Organisation (PESO) License. All materials have adequate safety measures such as nitrogen blanketing for the solvent tanks, fire extinguishers etc., which are inspected on a monthly basis using the Safety Inspection Checklist. In relation to the QRA as described under PS1, chlorine and ammonia are stored onsite at Taloja and liquid ammonia at Jigani which requires adequate assessment and management based on the QRA. As previously described under PS1 Section, Hikal does not purchase, store, use, manufacture, or trade in products that fall in WHO Recommended Classification of Pesticides by Hazard Class Ia (extremely hazardous) or Ib (highly hazardous) and Class II.

Solid and Hazardous Waste Management: Wastes generated from facilities typically include sludge from the ETP, filter dusts/residues, spent solvents, scrubber wastes, used oil from DG sets, oil contaminated clothes and bio-medical waste. Non-hazardous solid waste and scrap is separated and disposed of in accordance with locally available means of disposal. Recycling and reuse are practiced to the extent possible. Where wastes are not recyclable, materials are disposed to authorized landfills. With regards to hazardous waste, Hikal’s facilities do not have incinerators within the facility premises. Instead, Hikal has a membership to a common incineration facility approved and managed by the regulatory agencies in the respective States.  Hazardous wastes generated from Hikal’s business operation are transported by authorized transporters and disposed to the common incinerators.

In addition, solvent recovery (including toluene and acetone) and recycling is achieved through a distillation process which separates the pure solvent from contaminants. This is achieved through fractionation system using steam, vacuum and the physical properties of the solvents to produce high purity streams from a mixture of solvents. Recovered solvents are reused or disposed to authorized Treatment, Storage and Disposal Facilities (TSDF) of the respective States through authorized contractors.

Infrastructure & Equipment Design and Safety: All manufacturing facilities are located within industrial areas designated for such use by the local government, and infrastructure is constructed in accordance with the National Building Code 2016 in India. The nearest communities to Hikal’s facilities are at least 1km away which is out of the impact areas as defined in the EIA reports and related QRAs.

Road Traffic Safety: Hikal does not operate its own fleet and have a partnership with transport service providers. In addition, Hikal has become a member of NICER GLOBE, a non-profit organization promoted by Indian Chemical Council so as to align the Indian chemical industry with globally acclaimed standards, infrastructure and services for safe and secure transportation. The fleets are equipped with GPS trackers and NICER GLOBE provides emergency services in case of any accidents supported by emergency response teams located every 200 km on defined route covering more than 2,000 km. NICER GLOBE also provides training to all drivers for transportation of hazardous chemicals and products. No major incidents have been reported associated with the transport services.

Community Grievance Mechanism: Community grievances are received and registered by security guards at the facility gate and handled by the respective facility managers, hence, a formalized procedure is not in place. Hikal explained that no grievances have been registered against Hikal’s business operation to date. As ESAP #8, Hikal shall nonetheless develop and implement a community grievance mechanism aligned with IFC PS1 stipulating the process by which individuals may raise grievances including who receives grievances, how and by whom grievance will be resolved, and how the response will be communicated back to the affected party.

Security Personnel: Unarmed security guards are employed through licensed service providers. Training is provided to security personnel on a regular basis by Hikal’s EHS and HR personnel for fire and safety, handling of complainant to register grievances at security gate, and others. There has been no incidents of security and local community conflict in the recent past in any of the company facilities.