IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Identification of Risks and Impact: Sunteck follows the local legal requirements for design, development, and construction of the housing developments, including the specifications defined in master plan of each city and the requirements defined by the Ministry of Environment, Forest, and Climate Change (MoEFCC) and the National Building Code of India (NBC).
E&S Policies and Management System: Sunteck has a documented environment, social and governance (ESG) policy recognizing the impact that the real estate sector has on both society and the environment. In the policy, Sunteck endeavors to environmental protection, sustainable procurement and material sourcing, stakeholder relations and responsibility, fair and safe labor practice and others, details of which are described in depth in the respective sections of this ESRS.
Sunteck's environment, health and safety (EHS) manual & safety plan, SOP & class 1 risk management plan describes the processes to be followed through planning and implementation of its projects including monitoring and reporting, safety measures, emergency preparedness and response.
As ESAP #1, Sunteck will update the planning section of its EHS manual & safety plan, SOP & class 1 risk management plan to formalize E&S due diligence (ESDD) procedure to screen, assess and manage E&S risks & impacts for housing construction projects by incorporating Sunteck's existing standard procedures, the regulatory requirement in India as well as the IFC PS requirements. Sunteck will also update its policies relating to land procurement, which will include procedures/processes to address involuntary resettlement, if applicable.. Sunteck will undertake ESDD, to evaluate the projects versus IFC PS requirements, including land procurement, for future projects to be financed by IFC. Sunteck will share TOR and ESDD report with IFC.
Organizational Capacity and Competency: E&S aspects are managed by Head of Health, Safety, Environment, Quality (HSEQ), HSEQ committee, ESG Steering Committee, Liasoning Team and HR team at corporate level who are responsible for obtaining regulatory permits of projects, ensuring compliance with both internal and external requirements, and consolidating reporting information from site level. ESG working committee meeting is held fortnightly at corporate level to discuss any E&S aspects. At site level, EHS officer undertakes day-to-day implementation of E&S practices managed by site supervisors who are responsible for overall E&S at site. This includes performance monitoring based on which proactive measures and corrective actions are undertaken for enhanced health and safety.
Emergency Preparedness and Response: Emergency preparedness and response plan (EPRP) is available for both head office and sites prepared by corporate EHS team with consultation with respective sites. The EPRP plan includes potential emergency situations, first aid, emergency evacuation, mock drills, record keeping and others.
The EPRP will address the following aspects (but not limited to): specific emergency response procedures; trained emergency response teams; emergency contacts and communication systems/protocols; procedures for interaction with government authorities; stationed emergency equipment and facilities; protocols for the use of the emergency equipment and facilities; clear identification of evacuation routes and muster points; emergency drills; decontamination procedures and record keeping.
E&S Monitoring and Review: Sunteck’s EHS manual and safety manual includes monitoring and measurement of EHS performance. Based on the monitoring plan, EHS officers and site supervisors undertake site level monitoring. Monitoring parameters includes general safety aspects (e.g., use of machinery, fire extinguisher inspections), occupational health and safety statistics (e.g., near-miss, injuries, fatalities), daily housekeeping, construction material stacking, environmental parameters (e.g., ambient air and noise), energy and material consumption (e.g., diesel, cement, electricity, water) and others. Based on the monitoring outcomes, various meetings are held at site level such as monthly HSE committee, staff safety meeting, and contractor safety meeting. At corporate level, HSEQ & ESG committee in consultation with respective department heads, sets up the performance criteria for various function / departments / projects locations
As ESAP #2, Sunteck will formalize a procedure to regularly conduct a third-party assessment to evaluate E&S-related compliance at construction sites to check the compliance with Sunteck’s EHS manual as well as the IFC PS provisions. For IFC funded projects, Sunteck will also submit those assessment reports with action plans to fulfill the gaps versus EHS manual and IFC PS provisions (if any) to IFC, as part of annual monitoring report.
PS2: Labor and Working Conditions
As of May 2022, at group level, Sunteck employs approximately 500 direct employees (70% male and 30% female) and approximately 20 third-party employees (30% male and 70% female).
HR Policies and Procedures: Sunteck has a set of established HR policies including HR manual; whistle-blower; code of conduct; supplier code of conduct; non-discrimination and equal opportunity; prevention of sexual harassment; human rights; safety manual; and manuals and procedures related with CC management as described in detail in respective section of this ESRS.
Working Conditions and Terms of Employment: Sunteck has a formal HR manual which explains its organizational structure and hierarchy, and working conditions and terms of employment (e.g., on boarding, induction, working hours, attendance, leave, notice period, termination) which are in line with the regulatory requirements in India. In addition, Sunteck provides statutory benefits including employees' provident fund and employees' state insurance. Employees are provided with a written appointment letter with descriptions of the working conditions and the terms of employment.
Worker's Organization: There is no worker's organization or staff union in Sunteck. According to Sunteck's senior management, Sunteck does not restrict the formation of employee unions in compliance with legal requirements as the Constitution of India provides for freedom to assembly and association.
Non-discrimination and Equal Opportunity: Sunteck has a set of policies related with non-discrimination and equal opportunities (e.g., Code of Conduct, Human Rights Policy, Board Diversity Policy). Human Rights Policy is also applicable not only to Sunteck's employees but also suppliers, business partners and other relevant stakeholders.
Retrenchment: Sunteck has not undertaken collective dismissals in recent years even during the COVID-19 pandemic, and collective dismissals are not anticipated hereafter as well. As per ESAP #3, Sunteck will establish a policy on retrenchment which commits to avoiding layoffs, suspension or termination and consider alternative measures as much as possible. The policy will also stipulate procedures to be followed when employee separation is undertaken such as notice period, exit interview, salary adjustment, in line with IFC PS2.
Grievance Mechanism: There is a whistle-blower policy in place to raise concerns of any violation of legal or regulatory requirements, incorrect or misrepresentations of any financial statements and reports, etc. As its current practice, Sunteck's employees’ approach to HR team in person or via email when raising grievances. Upon receiving grievances, HR team engages concerned department(s) and/or senior managements for resolution depending on the nature of grievances. In addition, an online grievance redressal mechanism has been established which is applicable to all the stakeholders including Sunteck's employees.
As ESAP #4, Sunteck will update its employee grievance mechanism (SOP) in line with the IFC PS2 provisions including (but not limited to): detailed time bound steps upon receipt of complaint; grievance raising channels in addition to email (e.g., helpline, complaint box) to allow anonymous reporting; and procedures for documentation, analysis and reporting of grievances received. Sunteck will also make this formal grievance mechanism accessible to workers engaged by third parties, contractors, suppliers and all the other stakeholders. For IFC-funded projects, such grievance mechanism in line with the IFC PS1 provisions will be made available to local communities for any residual impact associated with land procurement (if any).
Prevention of Sexual Harassment: Sunteck commits to prevention of sexual harassment in its policy pursuant to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 as well as Sexual Harassment to Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013. The policy prohibits any verbal, written, provocative behavior or physical harassment and internal committee is established to handle and resolve issues related with sexual harassment.
Protecting the Workforce: Human Rights Policy and Supplier Code of Conduct are in place to comply with applicable laws and regulations on salaries/wages, working hours, working conditions, prevention of child labor and forced labor. Contractors are also required to hire employees older than 18 years of age as per Child Labour (Prohibition & Regulation) Act, 1986 and Rules, 1988which is confirmed through collection of documentation of age of workers and controls at construction site gates.
Workers Engaged by Third Parties: There is a Construction Contractors (CCs) selection procedure in place which Sunteck follows to select and verify that CCs are legal entities with applicable certificates of registration and a labor license issued by the statutory authorities. CCs are required to include provisions on implementation of EHS manual (and consequences of non-compliance), prevention of child labor and compliance with applicable labor law requirements in line with the Sunteck's EHS manual. Labor accommodation is also provided in close proximity to construction sites by CCs for which facility requirements are defined in the EHS manual. As for suppliers, supplier code of conduct is in place to prevent child labor and forced throughout the supply chain. Sunteck utilizes external consultants to monitor contractors' compliance with the statutory requirements where any violation is reported to project management consultant team at site.
Occupational Health and Safety (OHS): CCs are required to develop their own safety manual at sites based on Sunteck's EHS manual. Sunteck EHS manual cover key activities expected at construction sites including excavation, dangerous works (e.g., hot work, confined space entry, work at height), construction vehicle, scaffolds and work platform, heavy equipment, use of personal protective equipment (PPE), and others referring to applicable standards and safety codes. All the workers at construction sites, including visitors, are provided with safety induction prior to entering into sites with PPE provided. Trainings (e.g., induction training, toolbox training) are provided to workers on a regular basis to achieve safe work environment. In case of accident/incident, investigation is undertaken with detailed analysis, and corrective actions.
Impact of COVID-19 Pandemic on Workforce: COVID-19 has not significantly disrupted Sunteck's business operations, except suspension of construction work during the time of lockdown. Sunteck has not implemented reduction of personnel, salary and benefit cuts, or changes to vendor contracts due to COVID-19. Employees were supported through regular briefings and contingency measures for preventing COVID-19 risk in accordance with the Ministry of Health's instructions such as provision of PPE (e.g., face masks, gloves, sanitizers) at their respective workplace.
PS3: Resource Efficiency and Pollution Prevention
Sunteck follows the requirements by EIA, Environmental Clearance (EC) as well as its internal policies and manuals, implement mitigation measures, and undertake environmental monitoring, which are in line with the IFC PS requirements.
Resource Efficiency: In its housing projects, Sunteck implements energy saving measures including rainwater harvesting, use of solar hot water, low water flow fixtures, solid waste composting plant, use of LED and others. In addition, for many of its housing projects in the past, Sunteck has obtained Excellence in Design for Greater Efficiencies (EDGE) pre-certifications, a green building standard and international green building certification system aimed at making buildings which are more resource efficient. Sunteck plans to obtain the EDGE/equivalent certification for the future projects as well.
GHG Emission: Sunteck monitors Scope 1 and Scope 2 GHG emissions for residential and commercial development projects and discloses the monitoring outcome in its ESG Report at https://www.sunteckindia.com/esg.php. The recent record in FY2021-2022 indicates that the total amount of Scope 1 and Scope 2 GHG emissions was 1,300-ton carbon dioxide equivalent per annum and upon project completion, GHG is expected to remain around that level.
Air Emission Monitoring and Ambient Air Quality: During the construction, primary sources of air pollution are dust from construction activities, emission from diesel generators (DG) sets and vehicles. Water is sprayed on roads at regular intervals to minimize dust due to vehicular movement and wind blowing. DG sets and vehicles are regularly maintained in good conditions and have a pollution check certificate to conform to applicable air emission standards. Vehicles carrying excavated soils and construction materials are covered to minimize dust during transportation.
Ambient Noise: Noise control measures are undertaken as planned in EIA to comply with the prescribed standards. During night-time the noise levels measured at the boundary of the building are within the permissible levels (75 dB (A) during daytime and 45 dB (A) during nighttime) to comply with the prevalent regulations. Vehicles hired for bringing construction material to the project site are regularly maintained and operated only during non-peak hours.
Water and Wastewater: During construction, water is supplied by third-party companies through use of water tankers and municipal water is supplied for residential and commercial buildings upon project completion. Ongoing and planned residential projects are installed with sewerage treatment plants (STPs) for treatment of wastewater. STPs are equipped with moving bed biofilm reactor process. The majority of the recycled/treated water is used for flushing and others.
Solid and Hazardous Waste Management: The majority of wastes generated during construction are non-hazardous such as construction debris, steel scrap, and miscellaneous waste (e.g., gunny bags, wooden boxes, paint cans, aluminum waste). The wastes generated at construction sites are segregated, reused for various activities such as backfilling and levelling where applicable, or disposed through authorized vendors and/or municipal agencies. Hazardous wastes, such as spent oil, are handled as per applicable legal requirements and disposed through agency authorized by the local pollution control boards.
PS4: Community Health, Safety and Security
Infrastructure & Equipment Design and Safety: Sunteck follows the local legal requirements for design, development, and construction of housing developments, including the specifications defined on master plans of each city, the requirements defined by MoEFCC and NBC.
Road Traffic Safety: Road traffic safety is managed by material suppliers and contractors. As ESAP #5, Sunteck will update its EHS manual and/or safety manual to include traffic safety management requirements in line with “the World Bank Group Environmental, Health, and Safety Guidelines (General): 3.4 Traffic Safety” which needs to be incorporated into the road traffic safety plan, to be developed by suppliers and contractors.
Security Management: Sunteck hires unarmed security guards at construction sites through external security agencies. Security agencies conducts background verification of guards and provide training on dealing with construction workers and communication with the neighboring communities.
