For the three operating sub-projects covered as part of previous investment, environmental assessments confirm that most of the land required for the sub-projects is revenue/private land, there has been no physical displacement associated from the setting up of the sub-projects and its associated utilities and all purchase of land was on willing buyer willing seller basis. Hence, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable to the sub-projects. No tribal land was purchased for the development of the sub-projects and its associated facilities and therefore PS7 (Indigenous Peoples) is not applicable.  No cultural heritage has been adversely impacted as the project sites do not contain any archaeological monuments/sites, or any structure that have paleontological, historical, cultural, artistic or religious values. Hence, PS8 (Cultural heritage) is not considered to be applicable to the sub-projects.

Potential E&S impacts and applicability of all the performance standards will further be evaluated as part of the E&S impact assessment process of any additional sub-projects to be considered under IFC’s financing. The selected sub-projects where proceeds will be directed in future will be agreed with IFC and which should be able to meet IFC PSs.                                                  

This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability. The already identified sub-projects where IFC proceeds are to be used are Category B projects as described in the ESRS disclosure. For any future projects where IFC proceeds will be used, Sembcorp will select only projects with limited E&S risks and impacts that do not result in significant involuntary resettlement; impact on lands to which ethnic minorities maintain collective/ancestral attachment; significant impacts on biodiversity; or significant occupational health and safety risks. Hence, the key risks and impacts will therefore be limited, few in number, site specific, and largely reversible. Any adverse impact can be minimized, avoided or mitigated by adhering to generally recognized international industry performance standards, guidelines, or design project criteria.

Key E&S issue for this investment relates to the Company’s management and monitoring systems to assess and manage E&S risks and impacts from its operations; corporate systems and procedures to manage the E&S risks and impacts associated with the development of sub-projects in compliance with the applicable local regulatory requirements and those of the IFC PSs / good international industry practices (GIIP); assurance of fair, safe and healthy working conditions for employees and contracted workers in line with the legal and PSs requirements and consistent management of occupational health and safety (OHS) policies and practices; monitoring and management of air emissions, waste and wastewater and hazardous materials; emergency response preparedness and response including that for COVID-19 pandemic and community engagement activities related to E&S  commensurate to the risks and impacts associated with the Company's operations.                                                    

Policy:

Sembcorp has a sustainability framework in place aligned with UN Sustainable Development Goals (SDGs) framework. Sembcorp has adopted SDG 7 (Affordable and Clean Energy) and SDG 13 (Climate Action) as priority SDGs and has set targets (renewable energy capacity to 10 GW by 2025, reduce carbon emissions intensity by 25% by 2025, and further significantly reduce absolute  carbon emissions to 2.7 million tCO2e by 2030 and net zero emissions by 2050).

Sembcorp at the group level has an environmental policy reiterating its commitment for low-carbon and circular economy and a health, safety, security and environment (HSSE) policy reflecting the commitment to conduct its operations in a  responsible manner so as to protect the employees, contractors, assets, environment and the communities in which the operations span.

Sembcorp has a grievance management policy and stakeholder and community engagement policy at the group level reflecting the commitment to continuously improve and manage the environmental and social (E&S) performance associated with project activities. Sembcorp has a human rights policy defining the group’s responsibility to ensure the highest respect for human rights and the company’s expectation from its employees (including contractors) and business partners.

Sembcorp has in place a HSSE management system at the group level setting out the framework for implementing Sembcorp’s HSSE policy and continual improvement through the application of consistent HSSE performance standards across all business units and projects of Sembcorp Industries. It outlines the roles and responsibilities of various HSSE team members to fulfil the requirements of the Group HSSE policy. Each of the business units is required to conform to the HSSE guidelines and guidance documents included as part of the management system which covers aspects such as: (i) hazard identification and risk management; (ii) competence, training and awareness; (iii) consultation and communication; (iv) incident reporting and investigation; (iv) occupational health; (v) permit to work; (vi) management of contractors; (vii) emergency preparedness and response; and (viii) HSSE reporting amongst others.

Sembcorp Green Infra Limited (holding company of the three sub-projects) has implemented certified management systems for quality (ISO 9001), environmental management (ISO 14001) and occupational health and safety (ISO 45001).

Identification of Risks and Impacts:

For the three existing sub-projects where IFC’s proceeds will be directed, an ESIA was completed prior to start of construction including the development of an Environmental and Social Management Plan (ESMP). Each of the project sites has developed and is implementing a project specific environment and social management system (ESMS) both for construction and operation phases. In addition to the mitigation measures delineated and discussed in the ESIA, the EPC and O&M contractors also implement project level ESMS covering both construction and O&M activities and which is being satisfactorily implemented at the project site as verified during supervision visit undertaken by IFC.

The ESIAs have assessed impacts and designed appropriate avoidance, mitigation and compensation measures for project-related risks and impacts (across the project life cycle) in accordance with the IFC Performance Standards and GIIP. The ESIAs include Environment and Social Management Plans (ESMPs) that outline the avoidance & mitigation measures for the identified adverse impacts, monitoring and reporting framework and management responsibilities to implement the ESMPs. A summary of the stakeholder consultations and community engagement (undertaken as part of the ESIA) has been provided.

For the existing three sub projects, Sembcorp contractually requires contractors to put in place qualified personnel with appropriate responsibility to implement the ESMP. As part of the contractor oversight procedure developed, periodic monitoring/ review and report of E&S performance for each of the projects is done to the management. The contractual agreement with contractors (EPC and O&M) includes appropriate E&S provisions including putting in place a robust oversight mechanism (deputing personnel, regular monitoring, internal audits and reporting). Apart from this, internal and third-party audits if needed (especially during construction phase) are undertaken to assess compliance to aforesaid requirements.

As included in ESAP item#1, for  sub-projects where IFC’s use of proceeds will be utilized in the future: (i) develop and implement a written screening procedure to formalize the practice of avoiding investing in sub-projects under IFC financing in environmentally and socially sensitive areas i.e., areas where significant involuntary resettlement would be required, or lands to which ethnic minorities maintain collective attachment; and (ii) document the requirement to conduct IFC PS compliant ESIA (including adequate biodiversity surveys and assessments) prior to start of construction.

As included in ESAP item#2, for sub-projects where IFC’s use of proceeds will be utilized in the future,  Sembcorp will update its terms of reference (ToR) for ESIA of sub-projects to align with IFC’s PSs and relevant WBG EHS Guidelines around risk identification and mitigation.  This updated ToR should also include adequate environmental and social baseline studies including such aspects as: economic displacement and livelihood restoration; impacts on ethnic minorities or cultural heritage; community health and safety; biodiversity assessments to identify the presence or absence of listed species and evaluation of potential presence of Critical Natural Habitat (as defined in IFC’s PS6); adequate environmental and social management plans (ESMPs) including, among others, a stakeholder engagement plan, a community grievance mechanism and bird/bat fatality monitoring linked to an adaptive management framework to reduce ongoing risks to avifauna (for wind projects).

Organizational Capacity and Competency:

Sembcorp has a corporate HSSE team and a dedicated HSSE management team at the sub-project level. During construction and operation phase, labor compliance and OHS aspects are primarily handled by the EPC and/or O&M contractors having designated E&S personnel and with supervision by the HSSE team of the sub-project. Sembcorp develops and implements a corporate level training program covering E&S aspects of construction and operations, with a focus on OHS management, emergency planning, environmental monitoring, and stakeholder engagement.

Management Programs:

Management of E&S risks is currently part of the business process with a focus on compliance with regulatory/legal requirements and the corporate E&S approaches of Sembcorp. As part of screening, prior to development of any new project, E&S due diligence is conducted by in-house HSSE team and a summary report prepared with key information, including significant E&S issues, to inform corporate management team and board of directors in the investment decision process. Once the sub-project is approved for development, IFC PS compliant ESIA is required to be conducted through third party consultants. Projects which require ESIAs have sub-project-specific ESMPs that comply with the environmental licensing conditions. These license conditions depend on the stage of project development and on the specific E&S impacts of the project.

Emergency Preparedness and Response:

An emergency response plan developed as a part of each sub-project ESIA is being implemented at the sites to deal with emergencies such as electrocution, fire, fall of structure, medical emergency, civil disturbances, sabotage/vandalism and natural disasters. For emergency response, the Company maintains a community engagement plan and emergency numbers (such as nearest police station, hospital or clinic, etc.) are displayed at the site for use by staff.

Monitoring and Review:

At the sub-project level, E&S monitoring activities are presently focused on compliance with environmental licensing and occupational health and safety auditing activities. In addition, Sembcorp’s corporate HSSE team tracks E&S key performance indicators (KPIs), including but not limited to: regulatory compliance status of all its operations, internal OHS audit results, OHS incidents involving employees and contractors, and waste management (types, quantities and forms of disposal) etc. The KPIs from each relevant sub-project are compiled at corporate level to feed into Sembcorp’s corporate sustainability report (https://www.sembcorp.com/en/media/598034/sustainability_report.pdf) as per the requirements of Global Reporting Initiative GRI-G4 standards.

The Company reports to IFC annually on environmental, social and safety performance of the operations covered as part of IFC’s existing investment via the Annual Monitoring Report.                                                   

COVID-19 Impact: The project has been in operation throughout the COVID-19 pandemic with strict enforcement of protective safeguards. There has been no significant health impact reported due to COVID-19 on the workforce and the company has developed detailed safety guidelines related to COVID which is strictly implemented (e.g. adequate PPE, temperature checks, social distancing and disinfection facilities etc.).

Working Conditions and Management of Worker Relationship:

Sembcorp has a HR policy by way of “Code of Conduct”, the scope of which applies to all the company

employees and is available on the public domain and company intranet. The code articulates the Group’s commitment to acting with integrity and covers issues such as: zero tolerance to retaliation, fair and respectful treatment for all employees, compliance with  applicable labor and employment laws, enforcement of ethical practices, conflict of interests, anti-bribery policies etc and is consistent with PS2 requirements. There is a whistleblowing policy in place to facilitate independent investigation of the reported concern and for appropriate follow up actions to be taken. The implementation of the policy is overseen by an audit committee and it all applies to all employees, part-time/ permanent or contract employees. There is an employee benefits guide which covers amongst others the provisions for medical benefits, life and travel insurance, leave and other benefits and allowance.

There is a group guideline for construction and commissioning, with requirement for Project specific HSSE plan which is required to be implemented at all project sites and incudes the requirement for labour accommodation facilities to be set-up by contractor and which is aligned with IFC/EBRD guidance on worker’s accommodation. 

Workers’ Organization:

Sembcorp is committed to complying with relevant laws of the country related to employees/workers unions/organizations.

Non-discrimination and Equal Opportunity:

Sembcorp is committed to equal opportunity and non-discrimination, which is articulated in its code of conduct particularly in relation to employment, development and reward of employees. The company does not tolerate any form of harassment. In the Letter of Appointments, conditions on compensation, payments, dismissal and prohibition of harassment are documented.

Grievance Mechanism:

Sembcorp has in place a whistle blower mechanism for all aspects covered under the code of conduct including those related to employee grievance on work. There is a grievance management policy in place which is applicable to all operations and compliant with PS 2. The policy covers both internal grievances (covering contractors and contract Employees and primary suppliers and supply chain workers) and external grievances (including community grievances). Grievance mechanism addresses complaints, both formal and informal to avoid escalation into serious grievances and incorporating the provision to raise concerns anonymously.

Protecting the Work Force:

Sembcorp is committed under its code of conduct and has procedures in place to comply with national law, prevent child labor and forced labor.

For future solar project to be developed using IFC’s use of proceed, IFC will engage with Sembcorp to assess how their solar equipment suppliers manage human rights risks.

Occupational Health and Safety:

Sembcorp has HSSE framework in place including HSSE policy and covering aspects such as OHS, safe operation, contractor’s engagement and project level HSSE management. HSSE management covers both employees and contract workers and includes amongst others: institution of OHS committee for oversight of OHS management; training and awareness building on OHS; accident/incident reporting, investigation and corrective action; crisis and emergency response; drug prevention; and security management. The conformance and implementation of HSSE management framework is audited internally and also accredited with relevant OSHAS and ISO standards at each of the sub-projects.

There is a HSSE plan which is required to be implemented at all project sites. HSSE requirements for contractors is documented in a separate procedure manual and contractors are required to develop HSSE plans and submit to Sembcorp for review and approval. Project HSSE targets have been set which include no fatalities, no lost time injuries or illness (LTIR 0.0 per million man-hours worked), total recordable injury rate (TRIR < 0.3 per million man-hours worked), no fire and explosion ad no reportable environmental and compliance incident. HSSE committee monthly safety review meetings are held. Monthly HSSE reporting including details of HSSE KPIs is implemented and copy provided to Sembcorp Group HSSE.

Sembcorp Life Saving Rules (LSR) focuses on 12 site-based activities that carry the greatest potential threat of serious injury or death to people when safety rules are not observed. LSR sets out clear and simple “dos and don’ts” covering activities with the highest potential safety risk. There has been no fatal accident recorded in the last three years at any of the three sub-projects.

Workers Engaged by Third Parties:

Sembcorp has a supplier code of conduct in place which requires the suppliers to comply with the following aspects: (i) compliance with laws; (ii) business ethics; (iii) anti-bribery and corruption; (iv) equality and no discrimination; (v) prevention of modern slavery (including child and forced labour); (v) human rights principles; (vi) freedom of association and collective bargaining; and (vii) workplace health and safety.

Sembcorp undertakes periodic review of E&S performance of its contractors and ensures contractor compliance with labor laws as well as its own HR policies and practices, through its contractor screening and selection process, contract agreements and project site contractor supervision.                                                   

Sembcorp requires that EPC and O&M contractors comply with the environmental license conditions and the requirements of project-specific ESMPs, covering such aspects as fugitive dust from earth moving activities; noise and exhaust from construction machinery; sanitary effluents from worker facilities (typically disposed of via septic systems), and non-hazardous and hazardous solids wastes (typically disposed of through registered contractors or at the local waste disposal facilities in the case of non-hazardous wastes), as applicable.

For the sub-projects under consideration, ambient air quality parameters in the project area are within national standards. Baseline noise levels at nearest habitations exceed the permissible limits (national ambient noise standards) both during day and night- time for some locations. However, this is attributed mostly to the commercial activity and traffic movement in the area. Incremental noise level increases during construction was temporary and limited to the vicinity of the noise generating source, except in case of movement of material through/near habitations or other sensitive receptors. The noise impact assessment for the operation phase indicated that material noise impact on sensitive receptors was not expected due to the project. Each of the sub-projects undertake monthly monitoring of ambient noise level at various distances from the wind turbine (both during daytime and night time) in order to understand the increase in noise levels due to the project operation. Based on the data obtained from these monitoring programs, ambient noise levels are observed to be within national/IFC guideline values at all receptor locations.

Water requirement for the construction stage at each of the project sites was about 20,000 liters per day and is about 1,000 liters per day during the operations phase which is sourced from authorized vendors in the area/region. Domestic wastewater during O&M phases is being disposed through septic tank and soak pits.

Construction waste such as packaging waste, construction debris like small concrete, metal, bins, scraps and debris was collected, stored, segregated and disposed of accordingly. Waste from earthmoving activities and hazardous waste generated from use of heavy machinery /equipment like waste oil, gearbox oil, hydraulic oil, lubricant, cleaning fluids, paints, degreasers and other similar substances was/is being disposed as per the Hazardous Waste (Management, Handling &Trans boundary Movement) Rules, 2016 through authorized entities.

The Company, as a part of contractor oversight, requires the contractors to implement the waste management plan and ensure that the waste generated at the site are securely stored, handled/used with appropriate care and personal protective equipment; segregated; and disposed of in accordance with the local waste management regulatory requirements. It also ensures that transformers do not use PCB containing oils and ozone-depleting substances banned/phased out under Montreal Protocol are not used.

Sembcorp’s corporate sustainability report is prepared as per the requirements of Global Reporting Initiative GRI-G4 standards and performance data for every year (including details on energy use, water use, waste quantity and GHG emissions) is disclosed on company’s website (https://www.sembcorp.com/en/media/598016/2020-performance-data-and-commentary.pdf)                                                  

The sub-projects under consideration are generally away from local settlements and adverse impacts on the local community during project construction and operation to minimize community health and safety risk were included in the ESIA (including traffic planning, managing influx related issues, sourcing water from authorized vendors, appropriate disposal of sanitary wastewater and hazardous waste) and the associated ESMPs (community development, stakeholder engagement). Each of the sub-projects implement an emergency response plan to deal with emergencies such as electrocution, fire, community safety incidents and natural disasters. Emergency numbers are displayed at site at various locations (viz. nearest police station, health center) at the site for use by staff.

The sub-projects allow grazing activity in most part of the site. The transformers are fenced and cables insulated to avoid any electrical hazards. Access to agricultural fields, villages, communities and their networks are not disrupted/hindered. The sub-projects does not hamper the activities or access to the temples/mosques in the project area.

The O&M contractors at each site engage private security contractors which are engaged through an outsourced and authorized security agency. No security related incidents were reported during the construction phase and there have been no incident involving security forces till date as well. The sub-projects require the security agency to implement procedures to ensure that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in avoidance of abusive behavior; security incidents are recorded, investigated and corrective action implemented; bona fide complaints against security personnel are investigated and appropriate disciplinary actions are implemented; and there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel.                                               

The three sub-projects have previously been assessed against IFC PS6 and ESIA did not identify significant biodiversity values, however bird fauna was flagged as key risk. 

22.5 MW Parner project in Ahmednagar district, Maharashtra is located in a modified landscape consisting of strip agriculture, plantations, and villages. The closest internationally recognized area is the Jawaharlal Nehru Bustard Sanctuary [IN159] which is located 20 km to the South.  The sanctuary is severely degraded with populations of the Great Indian Bustard extirped [in 2016]. Other key risks for windfarms in this landscape however consist of soaring birds, being vultures, raptors and waterbirds, including Steppe Eagle (Aquila nipalensis) IUCN EN and the White-rumped Vulture (Gyps bengalensis) IUCN CR.

38 MW project in Mandsaur district, Madhya Pradesh is located in an agricultural landscape considered to be modified.  The closest internationally recognized area is the Gandhi Sagar Wildlife Sanctuary and Reservoir Important Bird Area (IBA) [IN142] which is located approximately 30 km to the north east of the Project.  The IBA contains significant populations of congregatory waterbirds.  Two protected areas coincide with the IBA, however they are located a further 50 km north. Species of interest within the IBA include Lesser Adjutant (Leptoptilos javanicus) IUCN VU, flamingos (Phoenicopterus spp.) IUCN LC and Bar-headed Goose (Anser indicus) IUCN LC.

40 MW Rojmal project in Rajkot District of Gujarat is located within a modified landscape interspersed with irrigation agriculture and villages. The site is not located within any internationally recognized areas or protected areas, with the nearest IBA being located 40 km to the east,  The IBA is the Bhal area that plays host to both IUCN CR/EN listed water birds, soaring birds and bustards.  These species include the Sarus Crane (Grus Antigone) IUCN VU, Lesser Florican (Sypheotides indicus) IUCN EN and Greater Spotted Eagle (Clanga clanga) IUCN VU.  Vultures are also predicted to occur within this landscape.

The project’s operational bird and bat fatality monitoring has not identified significant mortality events due to windfarm operations or along the transmission line, including for the species listed above or other species of conservation concern. As included in ESAP item#3, Sembcorp will undertake a review of the bird and bat fatality monitoring programs conducted at the three sub-projects by a suitably qualified and experienced wind wildlife consultant.  The assessment will review historic and contemporary data in relation to fatalities and make recommendations on the monitoring program as well as the mitigation strategy and any recommended changes will be updated into the Projects ESMS and related documentation for further implementation.

For  projects where IFC’s proceeds will be utilized in the future and which are not defined yet, IFC will require Sembcorp to screen  for biodiversity risks and seek  approval from IFC and only projects considered to be of low or moderate risk will be considered under the investment framework.  In this regard, impacts to critical and natural habitat values are to be avoided, especially in relation to soaring birds, waterbirds, and bustards. Adoption of best practices for mitigation will include the use of project infrastructure that can be adapted to risks and bird and bat fatality monitoring linked to an adaptive management framework to reduce ongoing risks to avifauna.