As per its business philosophy, AHL selects only parcels of land for project development where there would be no physical or economical displacement. AHL purchases land through commercial negotiated transactions directly from the landowners on a willing buyer-willing seller basis or enters into a joint venture with a local partner who has the possession of land. Therefore, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. All proposed affordable housing projects will be developed on land zones under residential areas around major cities, in plots with no associated economic or physical displacement, or impacts to areas with high biodiversity value, indigenous people or cultural heritage. Accordingly, PS6 (Biodiversity Conservation and Sustainable Natural Resource Management), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not expected to be applicable.

The project is Category B according to IFC's Policy on Environmental and Social Sustainability (2012). The key E&S risks and issues associated with the project include: i) adequacy of the E&S management system (ESMS) including impact assessment of design and construction activities; ii) occupational health and safety (OHS) for workers especially during construction including COVID-19 infection control; iii) resource efficiency including recycling and reuse initiatives through green building design; iv) pollution prevention during construction and operation stages; v) land purchase process; vi) life and fire safety (L&FS); and vii) community security, health and safety.

Environmental and Social Assessment: AHL follows local legal requirements for design, development and construction of the housing developments, including the specifications defined on the master plan of each city, the requirements defined by the Ministry of Environment, Forest and Climate Change and the national building code of India (NBC). An accredited architect or engineer endorses the design, including structural and fire safety aspects, before it is submitted for plan sanction by the local zonal authority and to obtain the no objection certificate (NOC). The plan presented needs to be aligned with the building bye-laws of the building regulations defined by the Ministry of Urban Development for each region, where applicable. 

AHL obtains environmental clearance for all its projects prior to start of construction. Form IA is submitted for projects where built-up area is less than 150,000 m2 and environmental impact assessment (EIA) is carried out if the built-up area is more than 150,000 m2 in line with the local regulatory requirements. Prior to hand over of the constructed housings to residents, local authorities perform an inspection and issue an occupancy certificate. 

AHL performs a due diligence of potential land which includes assessment of land use, presence of third parties at the proposed site, review of land titles and legal due diligence. AHL is committed to purchasing land only through willing buyer seller transactions. Also, only land zoned as residential will be purchased for all the affordable housing developments. 

Environmental and Social Management Systems: As per the requirement of the previous IFC investment, AHL has established formal E&S policy including AHL's E&S objectives, commitment to comply with the applicable laws and regulations as well as compliance with IFC Performance Standards. 

Based on the E&S policy, AHL has documented processes to be followed at construction sites in a safety manual which includes details on safety procedures, responsibility of safety officer, safety induction and toolbox talks, safe operation of construction equipment, guidelines for traffic movement, safety audit checklist, accident investigation and format for safety audit. 

In addition, as per the requirement of the previous IFC investment, AHL has developed E&S management system (ESMS) covering procedures for both construction and operation phases. The ESMS includes screening procedure/checklist for assessing E&S risks and impacts associated with the new projects. For this purpose, AHL has developed a set of criteria for site selection as well as an evaluation checklist which will be completed for new potential residence locations. Based on the screening results, AHL makes a decision on approval or rejection of candidate location. Moreover, with the help of the checklist, AHL assesses and summarize key E&S risks and impacts associated with the selected sites (covering requirements of PS 5, PS 6, PS 7 and PS 8) in order to comply with the local regulatory requirements and AHL's corporate standard design specifications. ESMS also covers procedure for land purchase including policy/guidelines in line with IFC's Performance Standard 5.For construction phase, integrated safety manual is in place (covering construction phase related impacts and risks). For operation phase, ESMS covers operation and maintenance of diesel generator sets (backup for power supply), water treatment plant, sewage treatment plant, L&FS systems, solid waste management, storm water drainage, monitoring and reporting, and management review of E&S performance.

Organizational Capacity and Competency: E&S aspects are managed at the corporate level by environmental officer responsible for obtaining regulatory permits of all projects and to ensure compliance with various permits and with oversight by vice president (VP) -operations. At the project level, safety officer is in place who reports OHS aspects to project manager. Safety officer is responsible to ensure that E&S procedures are adequately followed (e.g., regular safety training, safety inspections, accident investigation, preparation of monthly E&S statistics and reports, hygiene of labor camp, monitoring of the safety performance in toolbox meetings and safety committee meetings). Safety officer, together with project manager, is also responsible for addressal of E&S issues and general operations. Recruitment of direct labor force for construction and through contractors is responsibility of assistant general manager -projects. AHL's employees receive regular training on project management, quality, environmental and safety elements. Induction program is provided to all employees and contractors.

Emergency Preparedness and Response: AHL has an emergency preparedness and response system to ensure appropriate response in case of emergency situations. The system consists of: (i) emergency evacuation plans for all residences, listing of emergency contacts, and communication procedures; (ii) emergency equipment, such as fire extinguishers and wet extinguishing systems, in line with NBC requirements and as included in NOC for fire issued by the local fire department; and (iii) semi-annual/annual emergency drills. According to information provided to IFC during the appraisal, for senior living projects, emergency alarm is provided in each of the residences apart from the other fire-protection measures as required under the local regulatory requirements.

Construction sites are equipped with extinguishers, first aid kits and communication mechanisms in case of emergency. AHL has a specific process on maintenance and use of fire-fighting systems which includes a format for inspection of these systems. The process includes requirements on conducting regular fire drills and training on use of fire-fighting systems.

Monitoring & Reporting: For monitoring the EHS performance, monthly compliance meeting is conducted. The compliance committee comprises of deputy general manager - engineering, legal officer, environmental officer, project management engineer from head office and deputy general manager - project, legal officer and project manager at the site. Minutes of the meeting are documented and tracked for completion. At the construction site level, weekly safety audit is conducted by the designated safety officer to identify unsafe practices which are reported to project manager for making necessary improvements. Further quarterly safety audit is conducted by project management engineer for their respective sites. Based on the performance, each site is awarded with a tag (based on an internal criterion: green, yellow or red). Environment management plan (EMP) is developed for each project as part of the regulatory approval process and consist of mitigation measures and environmental monitoring plan for compliance with various environmental regulations. All sites conduct environmental monitoring for parameters as per local pollution control board requirements including ambient air quality, ambient noise, and wastewater quality. Site level monthly reports are submitted to the corporate team which provides data on manpower, number of incidents/accidents/first-aid cases/near misses and E&S induction trainings.

AHL has a total workforce of 900+ direct employees (including the facilities management entity), XX are female employees, a typical proportion of female workers in the construction sector. Approximately 150 to 200 indirect workers are hired through contractors at each construction site to perform specialized construction tasks in the developments. 

HR Policies and Procedures, Working Conditions and Terms of Employment: AHL has a policy manual in place which includes policies on leave (including maternity), domestic travel, transfer, gender equality, increment, loyalty grant and working hours. Appointment letter is issued to each staff which covers details on wages, leaves, benefits and allowance. Hiring and employment practices recognize the principles of non-discrimination and equal opportunity and there was no evidence of child or forced labor in the workforce. AHL is committed to ensure that no child labor is used in its operations. Visits to construction sites and discussions with staff confirmed working conditions to be reasonable, safe and clean. Remuneration is competitively determined by referencing market rates and complies with minimum wage laws. 

Non-discrimination: AHL has a gender equality policy which aims to eliminate discrimination in employment on the grounds of age, gender, disability, race, color, nationality or religion. It also aims to comply with equal opportunity legislations as applicable, and to follow good management practices. As per the policy, all policies and practices of AHL are applied equally to all employees.

Protecting the Work Force: In compliance with local labor laws and the AHL's policy, AHL does not use child labor or forced labor at its construction sites. Contractors are also required to hire employees older than 18 years of age, which is confirmed through collection of documentation of age of workers and controls at construction site gates.

Workers' Organizations and Grievance Mechanism: AHL employees do not belong to workers' organizations or unions, and there has not been such request among the employees. The management team of AHL confirms that they do not prevent employees to organize or participate in workers' organizations. Employees' grievances are managed through the direct supervisor and the regional head. AHL has a procedure in place for handling cases of sexual harassment and a committee has been formed for handling of sexual harassment complaints. Employees grievance mechanism has also been developed as part of the ESMS meeting the PS2 requirements including the provisions on anonymously raising grievances.

Workers Engaged by Third Parties: AHL verifies that companies/personnel contracted to do the construction work are legal entities with a certificate of registration and a labor license issued by the statutory authorities. The contract issued by AHL does not explicitly include clauses regarding labor, workmen compensation insurance and occupational health and safety. Labor accommodation is provided by AHL and includes basic amenities. The ESMS contains a checklist for labor camp facilities including: adequate living/sleeping facilities and space per person; fire safety; potable water that meets national standards; toilets, washing and cleaning facilities; locker/storage facilities; and facilities for management and disposal of garbage, sewage and other waste.

Occupational Health and Safety (OHS): AHL has a documented safety manual which includes safety procedures applicable to all construction sites. All construction site workers, including contractors, are required to have initial safety training prior to starting work. Appropriate safety measures and use of personal protective equipment (PPE) was observed during the site visits. E&S performance monitoring on-site covers use of personal protective equipment, adoption of safe construction practices as well as injury/accident statistics. There have been no accidents involving fatalities at AHL construction sites in last 3 years. 

The ESMS includes a checklist to be followed by AHL for ensuring compliance with E&S requirements and legal requirements on working conditions and non-deployment of child and forced labor. It also includes procedure for monitoring and documentation of E&S performance on-site by AHL and strengthening procedures to record accidents/incidents, investigate them and implement corrective actions.

Impact of COVID-19 Pandemic on Workforce: COVID-19 has not significantly disrupted AHL's business operations, except suspension of construction work during the time of lockdown. AHL 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.

Resource Efficiency: Resource efficiency measures are considered in the design of the proposed affordable housing/ senior living developments. AHL has adopted various measures in its existing projects to ensure resource efficiency such as dual piping system of plumbing for utilizing recycled wastewater in flushing, low flow fixtures in sink faucets, shower heads, and toilets for conserving water, low volume or dual mode flush systems, provision of sewage treatment plant (STP) for treatment of domestic wastewater and to be recycled for gardening and flushing purposes and provision of rain water harvesting system for recharging ground water and collection of rainwater from rooftops. 

AHL uses solar architectural features in the building such as adequate natural cross-ventilation, sufficient daylighting, usage of glass only for windows, covering of roof with reflective china mosaic tiles for lesser heat gains inside the building or using traditional heat insulation process, usage of solar water heater and LED/CFL lights in common areas.

Pollution Prevention: Environmental impacts and mitigation measures during construction and operation are properly identified in the Form IA/EIA (as part of regulatory approval process) and are mainly related to land preparation, air emissions (e.g., heavy equipment, vehicles, generators), noise, sewage from domestic use, visual impact (e.g., publicity and cranes), and waste management. As part of the Form IA/EIA, EMP is prepared for each project for mitigating adverse impacts along with delineation of project and post-project environmental monitoring programs. 

Water and Wastewater: During construction, typically water is sourced through on tankers (purchased water). Post construction, before the developments are handed over to customers, water supply is coordinated with local authorities; water is typically supplied by local government agencies and/or from on-site bore wells and water treatment (as required) is provided on-site by AHL to ensure that water quality meets the national acceptability standards. Wastewater during construction is treated using septic tanks. 

Existing and planned projects developed by AHL include the installation of STPs for treatment of domestic wastewater. AHL will continue to incorporate relevant wastewater treatment systems into the design of the project unless AHL can secure confirmation from relevant authorities of the acceptance of effluents as discharged to the sewage systems. AHL will monitor the quality of the effluents and will ensure compliance with local requirements for the management of the liquid effluents for each development.

Waste Management: Waste produced during construction is segregated and collected at the generation point; metal scrap is sold to local companies, organic/domestic waste is collected by the municipality and construction debris are located temporarily at designated points and as feasible reused for back filling, sub-base work for roads and pavements within the project. The domestic solid waste is segregated and collected in waste chutes for further disposal to the municipal agency once the projects are operational. Hazardous waste is limited to used oil from the generators (both during construction and operation phases) which is collected and disposed by authorized vendors, as defined by the local state pollution control boards. 

During the appraisal, it was observed that waste is handled, collected, temporary stored, transported, and disposed by the municipal waste management authority, or by certified waste management service providers, consistent with the Indian legislation. The care homes have provisions for appropriate temporary storage of waste, thereby preventing contact with clients and unauthorized people and which is then collected by authorized bio-medical waste agency.

Maintaining green areas: The requirement for leaving open/green areas varies from region to region depending upon the prevailing development control regulations in the region. On an average, 40%-50% of the area is left as green area or open space.

AHL typically builds multi-storied units (up to 15 floors) and follows the local legal requirements for design, development and construction of the housing developments and follows the provisions of NBC which covers fire protection standards, drainage, waste disposal, conservation of fuel and energy and accessibility among others. Fire safety consultants are hired to incorporate the fire-fighting requirements and typical fire safety measures including provision for: wet riser system, hose reels, portable fire extinguishers like dry chemical powder, CO2, fire bucket with sand & foam extinguisher, manually operated electric fire alarm system, automatic sprinkler system (required to be installed in basement if area of basement exceeds 200 m2), fire hydrant, yard hydrant, underground and terrace water tank etc. Enough (at least two independent) fire exits and exit signage are required to be provided. Mock drills are conducted to train staffs.

As a requirement of the Indian building bye-laws, local authorities inspect the projects, including fire safety provisions and issue NOC for fire which is renewed on an annual basis after inspection by the local fire department and after ascertaining that the buildings are provided with fire protection measures as per the sanctioned plan. The developments consider the access to basic services such as electricity and water; the projects developed by AHL so far has been in peri-urban areas where such services are granted. 

AHL manages its construction activities in a way to minimize the impacts on neighboring communities. AHL provides clear demarcation of construction areas; restricted access to construction sites; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. Access to potable water is guaranteed to all employees at the worksite and at labor camp. As part of the ESMS, AHL has developed and implemented a documented community grievance mechanism covering a process of receiving and responding to the grievances which meets IFC PS requirements and will be implemented for all the proposed affordable housing and senior living developments.

AHL hires unarmed security guards at the construction sites through external security agencies. The contractors are responsible for background verification of the guards and training the guards on dealing with the workers and neighboring communities. AHL will explicitly review during the selection of the providers of these services their rules of conduct, training and monitoring of their workers to ensure appropriate conduct towards the communities and require them to act within the applicable law.

Contact Person: Mr. Vikash Dugar

Company Name: Ashiana Housing Limited

Address: 304, Southern Park Saket District Centre,  Saket, New Delhi – 110017

Email: vikash.dugar@ashianahousing.com

Phone: +91- 4265 4265

Facsimilie: NA