The Company has direct exposure to third party suppliers for sourcing agro-commodity which trigger supply chain related requirements under PS2/PS6. On the other hand, considering that (i) the business operation is primarily a wholesale of agro-commodities;(ii) the Company is not undertaking any greenfield developments nor any construction activities; (iii) the Company's facilities are on lease basis without owning any farmland itself; and (iv) the majority of its facilities are located within commercial / industrial areas, the issues and risks envisaged by PS5: Land Acquisition and Involuntary Resettlement PS7: Indigenous Peoples and PS8: Cultural Heritage are not expected for this investment.

This is a Category B project based on IFC's 2012 Policy on Environmental and Social Sustainability. The E&S risks and issues associated with this project are limited, site-specific, and can be readily addressed through generally accepted mitigation measures described in this document. The Company is aiming for sustainably managing its sourcing, warehousing and processing operations in compliance with applicable national legal and regulatory requirements, IFC's Performance Standards (PSs), WBG EHS Guidelines (General and Food & Beverage Processing) and its own corporate policies.

Key E&S risks include: (i) implementation and efficiency of Environment / HR / OHS / Food Safety / Supply Chain management systems across its direct (warehouses) and sourcing operations, including functions' competency/capacity, compliance with legal/regulatory permit requirements, assignment of OPEX/CAPEX for addressing corrective action plants (CAPs) – including COVID-19, Gender/GBV risk assessment/management; (ii) fair and safe working conditions for workforce (direct and outsourced labor); (iii) water and energy use/efficiency, including GHG emissions at warehouses; (iv) ambient/point source air emissions, wastewater collection/treatment, and solid/hazardous waste management; (v) emergency planning and response, including L&FS and refrigeration system (e.g., ammonia use); (vi) PS2/PS6 supply chain risk assessment of fruits and vegetables, dairy products and grains from its direct and indirect suppliers, including traceability and risk screening using digital system; (vii) road safety management system aligned with ISO 39001; and (ix) community engagement and grievance mechanism: (x) land acquisition, including any legacy.

Environmental and Social Policies: The Company has a set of Environment, Health and Safety (EHS) policies in place, which is also applicable to all its subsidiaries, including Energy Management, Water Management, Waste Management, Occupational Health & Safety (OHS) Management, Prevention of Sexual Harassment, and Employee Grievance Redressal. The policies commit to prevent or eliminate undesirable EHS risks and impacts which may result in injuries / loss of lives and damage to environment throughout the Company's business operation. The policies states that this will be achieved through strict adherence to all applicable legal & statutory requirements and propagating their commitment to all employees, suppliers, customers, service providers as well as neighbors in community. The Company is also in process of formalizing and codifying its EHS policies, procedures and management practices, including its Supplier Code (by updating SOP on vendor selection), supply chain risk assessment and management, and food safety management system (as part of ISO22000 certification process) to be aligned with the IFC PSs and WBG EHS Guideline requirements, as described in the respective sections of this ESRS. Practices based on these updated policies at facility levels will be regularly monitored and reviewed by the Company's senior management. (please refer to “PS1. EHS Monitoring and Review” below).

Identification of Risks and Impacts: Environmental Impact Assessment (EIA) study is not required as per the Indian EIA notification (2006) for any of the Company's facilities (i.e., collection centers, distribution centers, dairy and food processing facilities). The Company does not have any development plan for greenfield facility, and its current facilities are all on a lease basis. Accordingly, the Company has an established Manual of Standard Operating Procedure (SOP) to evaluate, screen and document any proposed facility before entering into a lease agreement. The E&S-related components of the SOP covers, but not limited to, fire safety, electrical safety, structural requirements, waste handling & disposal, opportunity for rainwater harvesting, and basic safety & sanitation. Assessments associated with other risks and impacts are also undertaken, including food safety management (“EHS Management Program” under PS1); sourcing (“Supply Chain Risk Assessment & Management” under PS1); and road safety (“Road Traffic Safety” under PS4) as described in the respective sections. Such practices enable the Company to conduct its business effectively and efficiently while securing adequate EHS performance and eliminating risks associated with facility management.

While environmental certificates or permits are not required for collection centers and distribution centers, Consent to Operate (CTO) from the State Pollution Control Board (SPCB) is required for dairy and food processing facilities. CTOs for these two facilities are currently under renewal process. In case of acquisition of other business during the lifetime of IFC financing, The Company will undertake an EHS due diligence for such operation, consistent with IFC's PSs prior to close its acquisition process. EHS due diligence report will be reviewed and approved by IFC.

EHS Management Program: The Company has a Food Safety Management System (FSMS) in place with Hazard Analysis and Critical Control Point (HACCP) approach, which is applicable to activities of procurement of agro-commodities, inspection, handling, sorting, grading packaging, storage and trainings related to food safety aspects. The FSMS is being presently strengthened by the Company's effort to achieve ISO22001:2018 FSMS certifications. The Company has already partnered with a third-party certification organization and is preparing for ISO22001:2018 at two of its major distribution centers. The work is in progress for carrying out internal audit, floor preparation, internal trainings, documentation, etc. Final audit is expected to be completed by December 2021. FSMS Manual is also being prepared and will be rolled out across all Company's facilities.

The Company has also initiated steps to establish a comprehensive Integrated E&S Management System (ESMS) aligned with IFC PSs and WBG EHS Guidelines (General and Food & Beverage Processing) requirements, with the technical support of external consultant. Tentative timeline for finalizing this Integrated ESMS is December 2021. While the primary focus of the Company's current management system is on ensuring traceability of product supply and food safety from collection to delivery, the development of comprehensive Integrated ESMS will further strengthen the Company's commitment towards a structured and performance-based EHS/Sustainability framework. Of specific attention in strengthening its current system include, but not limited to: (i) compliance with regulatory requirements; (ii) risks and impacts identifications process, including FQMS; (iii) supply chain management; (iv) emergency preparedness and response; (v) OHS management, including risk assessment; (vi) EHS monitoring, including definition of KPIs; (vii) road safety management; and (viii) senior management monitoring and review (ESAP#1 & #2). For its raw material sourcing, the Company is implementing a farmer engagement program called “Outgrow” scheme to promote adoption of Good Agriculture Practices (GAPs) and yield productivity of its farmer supply base. The scheme is based on a model of clusters under a cluster leader who reports to the Company's procurement manager. The farmers who own farmlands under Outgrow scheme are technically supported on key farming activities, such as soil and water quality test on farmland, agrochemical inputs advisory, packaging practice, etc. Advisory on use of fertilizer and pesticides ensures the prohibition of use of banned chemicals in accordance with India Ministry of Agriculture Guidelines and World Health Organization (WHO) Class Ia and Ib pesticides. During the cultivation period, the Company's agronomy team monitor the crop on a regular basis and work with farmers to ensure that the crop is being cultivated as planned.

Organizational Capacity and Competency: The Company's key corporate EHS functions overseeing its entire business operations are mainly divided into two command structure, namely i) HR & Operations Team; and ii) Loss Prevention Team. The HR & Operations Team, through set up of a EHS Review Committee (ERC) and Workplace Safety Forum, reviews report escalated from facilities and fields on employees' health and safety aspects daily to ensure the compliance with the Company's policies and procedures. Issues are further escalated to senior managements for their review and incorporated into evaluation as part of monthly HR Operations agenda. On the other hand, the Loss Prevention Team oversees safety inherent to structural and property risks. Fire safety officer review and reports risks and takes a lead to implements mitigation measures. Issues are also escalated to senior managements monthly. At facility level, EHS committee is established who oversees E&S needs within premises headed by facility management.

Going forward, the Company shall appoint qualified individuals (at the minimum 5) who will oversee managing and implementing the aforementioned Integrated ESMS currently being developed, particularly for its direct operations and for overseeing supplier engagement activities and ensuring compliance against the Company's Supplier Code (see “Supply Chain Risk Assessment & Management” under PS1). This staff shall also have responsibility to ensure that all environment (as stipulated in CTO for dairy facility and food processing facility) and OHS standards are maintained through active monitoring and establishment of EHS Key Performance Indicators (KPIs) at the Company's direct operations (ESAP#3).

EHS Training: Employees are provided with trainings both by internal and external teams including emergency drills, L&FS, Occupational Health and Safety (OHS) including use of PPE, and first aid on a regular basis as described in respective sections. Upon completion of the Integrated ESMS in December 2021, the Company will significantly strengthen its EHS/Supply Chain training plan to ensure effective/timely implementation of its updated policies/Code and procedures. Based on the Integrated ESMS, the Company shall develop EHS Training Plan for the Company's direct operations and supply chain management investing into integration of new staff. The Company may also consider having external consultancy to ensure effective/timely implementation of the training. (ESAP#4)

Emergency Preparedness and Response (EPR): An emergency situation associated with the Company's business operations may include risks of fire, structural and power failures, and natural disaster. Emergency Reaction Team is organized to deal with any emergency situations at all facilities. Facilities are licensed and equipped with fire safety system in compliance with Indian regulations. Fire safety officer audits facilities to ensure compliance with design, building codes, construction, and State Fire Department regulations. Fire safety trainings are conducted both by in-house safety team and external agency on a regular basis. In addition, the Company has emergency food recall procedures in place. All food products passing through the Company's facilities are tracked through batch numbers with traceability to point of origin with food recall procedures within the FSMS. As for chiller system of storage room at distribution centers, R-404A cooling gas is used as refrigerants. The gas was originally developed as a replacement for CFC as eco-friendly gas but is being phased out globally including India because of its Global Warming Potential in excess of 2500 (although the use of R-404A is not prohibited). Leakage in large quantities in a closed environment may poses a danger of oxygen deficiency, and exposure can cause eye & skin irritation. As such, adequate emergency preparedness including ventilation is required. Going forward, to strengthen its EPR, the Company shall formalize a SOP for ERP to be rolled out across all Company's facilities as part of its Integrated ESMS currently being developed (ESAP#5). This should include, but not limited, to potential L&FS incidents, leakage of refrigerants from chiller system, serious workplace accident, traffic accident, and severe weather alerts.

Impact of COVID-19 Pandemic on Workforce: The Company's operations were not stopped due to the COVID-19 pandemic. As an essential service provider, the Company expeditiously took efforts to ensure facility operations at the same time of ensuring health and safety of staff working there. COVID Emergency Response Team was established to initiate various measures including allocation of employees across different shifts, enabling safe transport arrangements, and provision of basic sanitation measures and meals within premises. Famers under Outgrow scheme were also provided with masks and gloves. These measures have helped the Company to ensure smooth operations without any interruption due to the COVID-19 impacts.

EHS Monitoring and Review: As part of the development of its aforementioned Integrated ESMS, the Company will develop and implement a set of EHS KPIs to ensure to monitor resource use and OHS leading and lagging indicators (see also “Occupational Health and Safety” under PS2) at its direct operations. These KPIs will be consolidated on a monthly/quarterly operational dashboard which will be presented to senior managements along with findings and recommendations for review and assignment of OPEX/CAPEX, as required. Annual EHS performance audits will be carried out by the Company's EHS functions.

Regarding agro-commodity quality assurance (QA), the Company's FSMS stipulates monitoring and review undertaken by QA team. Periodic audits are implemented to ensure that all collection points and distribution centers are adhering to required standards for food quality and handling. The outputs from these audits are used to evaluate performance with additional training or measures taken, as needed. In addition, daily workplace audit is undertaken using checklist mainly from workplace hygiene perspective (e.g., room cleanliness, floor and pathway safety, washroom cleaning, functioning & conditions of equipment). Workplace monitoring by EHS committee, fire drills, trainings provided to employees, incident reporting, and energy and water consumption are also periodically monitored and reviewed as described in relevant sections.

Supply Chain Risk Assessment & Management: The Company directly sources its fresh fruits and vegetables products (fruits and vegetables) from 5,000 third-party farmers, including smallholders (approx. 120 farmers), a network of Farmer Producer Organization (approx. 1,350 farmers), aggregators (approx. 780 farmers), and farmers under Outgrow scheme (approx. 3,000 farmers).The Company and farmers conclude written agreement when entering into the Outgrow scheme where conditions and requirements for both sides are stipulated for successful implementation. Although the Company currently does not have a documented Supplier Code outlining its requirements toward third-party suppliers, it has initiated the drafting and implementing SOP on vendor selection and approval for procurement, which is also expected to be expanded to all farmers and integrated into the aforementioned Integrated ESMS. The aim of the SOP is to standardize process of new vendor selection, approval, induction process in procurement where vendors are checked based on traceability and selection criteria.

Going forward, the Company shall establish a Supplier Code as part of its Integrated ESMS by updating the current draft of SOP on vendor selection, ensuring that the Code is aligned with the relevant Indian labor regulations and IFC PS2 and PS6 supply chain requirements (e.g., prohibition of child and forced labor, prevention of significant safety issues) with specific provisions tailored for each supplier (e.g., direct farmers, FPOs, aggregators). This Code shall be communicated to all the Company's staff interacting with third-party suppliers and displayed at all collection centers and Company's other facilities providing channels for workers to register any treatment that violates this Code (ESAP#6).

The Company's agronomic staffs who have direct relationship with farmers under its Outgrow scheme have opportunities to directly observe farmers in terms of working conditions (e.g., prevention of forced / child labor, OHS practices) from time to time, yet this oversight monitoring is not systematically established. As a result, such monitoring opportunity is not sufficient to ensure prevention of supply chain risks for primary producers, particularly through FPOs and aggregators as traceability of agro-commodity is only for post-harvest. As the Company does not currently have established mechanism in place to systematically monitor and review working conditions of farmers, the situation exposes the Company to potential direct and reputational risks.

Going forward, as part of the Integrated ESMS under development and expected to be completed by December 2021, the Company shall establish a Supply Chain function and verification mechanism to: i) identify and evaluate risks associated with child labor, forced labor, physical and/or chemical OHS hazards of farmers, and impacts on natural habitats at farms in in its supplier base ; ii) implement and monitor them on a regular basis; and iii) take corrective measures where needed in accordance with the IFC PS2 and PS6 supply chain requirements and good international industry practice (GIIP). As part of the mechanism, the Company will regularly undertake a series of random audits of its contracted farmers in order to verify the degree of farmers' compliance with the Supplier Code requirements, including independent verification annually (ESAP#7). To ensure that the established Integrated ESMS (ESAP#1), EHS Training (ESAP#4), and supply chain management system (ESAP#7) are adequately implemented, the Company shall monitor their implementation once they are established and report the progress status to IFC on a quarterly basis during the first year after development. (ESAP#8)

As of August 2021, the Company employs approximately 1,300 direct staffs (90% male and 10% female employees), the majority of which is full-time employees. In addition, there are approximately 700 third party employees / contract workers. The majority of these staffs are based in Chennai and Bangalore where the Company has the corporate office and two of the major distribution centers. Attrition rates have been over 20% in the past few years which is generally aligned with trends in the Company's business sector. Observation indicates attrition rate is relatively high in sales roles but low in non-sales functions.

Human Resources Policies and Procedures: The Company has a set of HR policies and procedures in place which comply with the national labor regulations of India. All core components stipulated in International Labor Organization (ILO) conventions are included within the policies and procedures including: recruitment; promotion; probation, disciplinary process; grievance redress; benefits and entitlements including overtime rates; and prevention of sexual harassment (trainings on prevention of sexual harassment provided on a regular basis).HR policies and procedures are established at corporate level and rolled out across the Company's facilities. EHS committee is established at facility level, headed by each facility manager to ensure adequate implementation of HR practices and compliance with the respective requirements. HR Manual is provided to all employees and various trainings are provide including induction. Grievances from employees, including any sexual harassment, are handled through the grievance policy and mechanism. On top of EHS monitoring at workplace, monitoring of labor service providers is also undertaken to verify that payment of salaries, social insurance contributions, contracts and ages of workers are complied with the national labor standards. Going forward, to meet the IFC PS2 requirements, the Company shall update the HR policies by establishing policies on Workers' Organization and Workers Engaged by Third Parties as described in the respective sections below.

Working Conditions and Terms of Employment: The Company complies with the requirements set by the national labor regulations, including minimum wage, working schedule, overtime, holidays, social security benefits (e.g., Employees' Provident Fund, Employees' State Insurance), employee separation, and others. All workers are required to work a 48-hour working week with distribution centers operating at three shifts 24 hours per day. Overtime is paid for workers at two times normal rate and is capped at 56 hours per week. Shifts are 8 hours with one-hour break.

Workers' Organization: HR policies and procedures do not include any references to right for use of collective bargaining, yet this is an inferred right under the Labor Law of India. As previously described, to meet the IFC PS2 requirements, the Company shall update its HR policies by expressing commitments to employees' right to form and join workers' organizations of their choosing without interference and to bargain collectively. These rights will be explained to workers during the Worker Induction Workshop (ESAP#9)

Non-discrimination and Equal Opportunity: The Company has HR policy and procedure which include non-discrimination in accordance with the labor regulations of India, clearly declaring that recruitment process shall not discriminate any person on the basis of disability, gender, age, community caste or religion.

Retrenchment: As Policy on Employee Separation, the Company commits to avoid layoffs, suspension or termination and consider alternative measures as much as possible. The policy clearly stipulates procedures to be followed when employee separation is undertaken such as notice period, exit interview, salary adjustment, etc.

Grievance Mechanism: An established procedure is in place to provide a mechanism to employees where they can raise grievances arising from daily work. The mechanism is applicable not only to direct employees but also third-party employee / contract workers ensuring anonymous grievance raising. The procedure stipulates escalation flow, time limitation, committee appointment, records keeping and confidentiality. Grievance Committee is established and composed of 4 members appointed by CEO which has overall responsibility for redressing grievances raised from employees working with respective personnel. Grievances are dealt with in stages; first stage with reporting manager, second stage with HR Head, and third stage with CEO. Record keeping is also required, including nature of the grievance, written grievance statement, action taken with reasons for it to be taken, and written statement of the decisions.

Protecting the Work Force: The Company explained that it verifies the age of all employees at the time of employment. All applicants are required to present their age proofs to recruitment staff during the application process. Proof of age is verified through identify card checks with copies retained on file. The Company's HR team also applied checks for contracted workers requiring the labor service provider to submit both a copy contract for the worker and proof of identity and age.

Life and Fire Safety: As preciously described in “Emergency Preparedness and Response” under PS1, facilities are maintained as required by the local regulations. Fire safety officer audits facilities to ensure compliance with design, building codes, construction, and State Fire Department regulations. Fire safety trainings are conducted both by in-house safety team and external agency on a regular basis.

Workers Engaged by Third Parties: According to the recent statistics, 35% of the Company's workforce supplied by labor service companies. It is stated within the HR function that monitoring of labor service providers is undertaken to verify that payment of salaries, social insurance contributions, contracts and ages of workers are complied with the national labor standards. To further strengthen the Company's practice on managing workers engaged by third parties, the Company shall establish a policy and procedure to take commercially reasonable efforts to ascertain that the third parties who engage these workers are reputable and legitimate enterprises and have an appropriate ESMS, including compliance with applicable Indian labor and OHS requirements (ESAP#10).

Occupational Health and Safety (OHS): The Company has OHS Policy in place to ensure the prevention of workplace accident or injury and to provide healthy and safe workplace environment to its employees and contractors at all its operations. Overall employee and workplace safety is ensured by the HR & Operations team at corporate level, and information related with OHS is escalated from facility managers at each location. Major OHS risks associated with the Company's daily business operations are handling and movement of heavy weights (15-20kg), unloading, and packing. Basic moving machinery (e.g., conveyors) is also present. To prevent accident or incident from such OHS risks, workers at facilities are provided with personal protective equipment (e.g., safety boots, safety goggles and dust mask). Trainings are also provided by in-house team on semi-annually covering topics such as stress management, product knowledge, first aid, and health & safety at workplace, supported by trainings provided by external experts on quarterly basis. To ensure that these activities are adequately undertaken, EHS committee is established at each facility who oversees OHS needs within premises and conduct monitoring through audits with support from inhouse and external team. EHS checklist of monitoring covers items such as: i) compliance to life and fire safety needs; ii) basic electrical safety review; iii) emergency response plans; iv) compliance to material handling; v) compliance to use of PPE along with detailed evaluation points for each aspect. Rating, observation and corrective measures are provided based on monitoring. Following the development of the Integrated ESMS, the Company is expected to ensure that each facility will have an updated OHS risk assessment covering all health and safety risks associated with its activities within premises. The Company is recording their incidents and defining improvements, as found necessary. There is currently no classification of the severity of the accidents in line with WBG EHS guidelines. The Company will benefit further from updating their current incident investigation process to ensure root causes are determined and resolved for each accident.

Going forward, to further strengthen OHS practice at workplace, the Company shall formalize a procedure to monitor, review and report key performance indicators (KPIs) related with OHS statistics. These statistics should include lagging indicators (e.g., injury frequency and severity, OSHA recordable injuries, near-miss, lost workdays, worker's compensation cost) and leading indicators (e.g., numbers of OHS audits and inspections planned versus conducted, training hours, number of management inspection rounds planned/executed) on top of the Company's practice of EHS audit checklist currently in place. This procedure should also include a mechanism for classification of accidents (e.g., fatality, lost time incident, MTC), incident investigation process (compliant with WBG guidelines), a format incident investigation report (ESAP#11)

For Disclosure:

Resource (Energy and Water) Efficiency: The Company is committed to promote resource efficiency through adopting good international industry practice (GIIP) to achieve energy and water efficiency and promoting climate smart interventions in its processing and warehousing operations. To reduce its overall energy consumption, the Company is undertaking various resource efficiency measures including use of LED, installation of solar panels, use of electric vehicles for last mile delivery, GHG offsets by tree plantation, reuse of treated wastewater, and others. In recent estimates, the Company consumed approximately 1,100,000 kWh of electricity from grid and 11,000 kL of water per annum for its business operations.

Going forward, as part of annual monitoring report to be submitted to IFC, the Company shall monitor use of resources for dairy facility (electricity and water consumption per milk processed) in light of industry benchmark against WBG EHS Guidelines (“Table 3: Resource and Energy Consumption” in Dairy Processing Guidelines).

GHG Emissions: The Company calculates its total GHG emissions based on Scope 1 (e.g., use of diesel in DG sets), Scope 2 (e.g., use of grid electricity) and Scope 3 (e.g., logistics and waste related emissions). Based on the recent GHG emissions footprint, the total GHG emission is estimated to be approximately 2,500 tCO2e per year.

Air Emission Monitoring and Ambient Air Quality: The source of air emission at the Company's facilities are mainly from the Diesel Generator (DG) sets. DG sets are primarily used as back-up during power failures and is seldom used (less than 500 hours per year). All DG sets are of ISO standard and regularly serviced by vendors to ensure the air emissions are within the permissible limits. DG sets are supplied by vendors with Confirmation of Approval (COP) issued by Central Pollution Control Board (CPCB) for the emission limits. As such, environmental monitoring of air emission is not being undertaken.

Water and Wastewater: The Company's major water consumption is for domestic purpose at distribution centers, including washing of crates. In-house wastewater treatment system is installed at some large distribution centers where 100% of wastewater is treated and reused for domestic, gardening and ground water recharge. At other facilities where wastewater recycle is not yet in place, wastewater is disposed through trucks from municipal corporation, which at a regular frequency arrives and picks up wastewater. This is further taken to the common treatment facilities of the local municipal bodies. Therefore, wastewater is not discharged from any of the Company's facility into public sewer system. As such, environmental monitoring of wastewater discharge is not being undertaken. Going forward, the Company is building capacity toward achieving zero liquid discharge. As to date, treated wastewater reuse share is approximately 16.5% of the total water intake, which is expected to go up to 30% by the beginning of 2022.

Solid and Hazardous Waste Management: Wastes generated from the Company's business operations is limited domestic waste and food fruits & vegetable dumps, and hazard wastes are not generated. Generated wastes are segregated at source and store at designated locations. All fruits & vegetables dump is either disposed through authorized local municipal bodies or given to animal feeding (e.g., cattle, pig) through appropriate channel partners, such as Blue Cross of India.

Environmental Monitoring: While environmental impacts are limited at distribution centers and collection centers, dairy and food processing facilities are required to obtain Consent to Operate (CTO) as per the State Pollution Control Board (SPCB) requirement considering the environmental impacts associated with these facilities. These dairy and food processing facilities are required to comply with conditions stipulated in the CTOs including emission, discharge and waste generation amounts (i.e., compliance with limiting standards),yet, such environmental monitoring of which is not currently undertaken to verify that the facilities' operations are in compliance with the conditions because 1) emission is only from DG sets which are regularly monitored and maintained, 2) wastewater is 100% recycled or disposed by authorized contractors (i.e., no discharge), and 3) reporting to authority is not required. To ensure compliance with regulatory requirements, the Company has agreed to undertake environmental monitoring at facilities where CTO is required, including WBG EHS Guidelines (General and Food & Beverage) and take corrective actions if non-compliance is observed to ensure that all environmental parameters are within the permissible level (ESAP#12).

Road Traffic Safety: The Company does not operate its own fleet and have partnership with 30 transport service providers on daily, monthly, or ad-hoc basis as per supply requirements. While 6 collection centers are located close to village due to its business nature (farms supplying agri-commodity to the Company), the majority of distribution centers are located within commercial / industrial areas, with a few exceptions of small distribution center located out of commercial area. The general agreement between the Company and fleet suppliers covers clauses related with health and safety including: i) drivers' license and quality to drive the assigned vehicle; ii) valid vehicle safety certificate and pollution certificate; iii) age of vehicles; and iv) fleet service providers' commitment to obey road traffic laws and speed limits. While primary responsibility of road traffic safety is at service transport service providers, the Company also has its own practice to further ensure health and safety of drivers. For example, the cCompany has fleet management safety check in place including checks on fleet vehicle licensing and quality. In addition, regular health check-ups are provided to drivers for their eyesight and other vitals through health camps. Going forward, to further strengthen the practice and mitigate impacts of road transport, the Company should update SOP on vendor selection to include a selection and performance review of transport service providers in line with the WBG EHS guidelines and ISO 39001 (ESAP#13).

Security Personnel: Unarmed security guards are employed through external service providers. The security guards monitor workers entering and leaving premises and verify data on visitors and delivery truck drivers.

Community Grievance Mechanism: As a mechanism for external communications, communities around the facilities can raise grievances or complaints through channels of email or telephone as disclosed on the Company's website, or directly visit facilities. The Company explained that they have not received any significant grievances regarding their business operations from neighboring communities till date.

Out of 50,000 farmers from which the Company sources agro-commodities, 3,000 farmers are engaged in Outgrow scheme for fresh produces covering approximately 1,214 ha of farmland owned by farmers. The biodiversity review based on IBAT and GFW (assessment based on shapefiles of 20km radius of the collection points for Outgrow farms and 10km radius from FPO & aggregator locations for non-Outgrow farms) analysis confirmed that the majority of sourcing from farmlands is located in consolidated agricultural lands and/or not located in recently deforested areas.

However, the screening has identified that it is possible that one FPO/aggregator is located within a Protected Area (PA). Furthermore, there is the potential for other farms to operate within PAs as two FPOs/aggregators are located within 10km of these areas. The Company shall undertake a site level assessment of these locations to ensure that they are legally permissible within these areas.  A database of farms operating within PAs shall be prepared for these FPOSs/aggregators, noting the location, boundary and ownership details of farms. The farm currently identified within the PA shall be excluded from supply until further analysis is completed. This database shall be updated on a regular basis, and where any farms additional farms are found to operate in PAs, they shall either be required to undertake a site-level assessment (as described above) and be excluded from future supply until the assessment has been completed. (ESAP#14)

Regarding the potential for impact to natural and/or critical habitats by the farms within the supply chain, analysis has also identified that there is a low risk of potential conversion based on data obtained from Global Forest Watch for the years 2020-2021. This analysis indicates that there is a low background level of clearing within the landscape within 20km of aggregators/FPOs and hence the risk to conversion is low. However, to better understand the farms within the supply chain and to enable better communications as part of the Supplier Code, the Company will be required to conduct regular analysis of land conversion risks in areas where the farms are located. (ESAP#15)

The Company will develop and implement a Supplier Code and procedures for supply chain management covering the PS6 requirements of biodiversity/natural habitat management. (ESAP #7) (See also “Supply Chain Risk Assessment & Management” under PS1 for risk assessment associated with the Project). As part of this Code, the suppliers will be required to acknowledge that they will be required to not impact natural and/or critical habitats nor operate within KBAs or PAs without a site-level assessment.