This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible, and readily addressed through existing mitigation measures and good international industry practices (GIIP). Most of these E&S impacts occur only during the brief construction period. For example: air quality and noise impacts, community safety impacts from the temporary influx of project vehicles and non-resident workers, occupational health and safety (OHS) risks for workers, contractor management, resource efficiency, and waste management. During operations, the main E&S risks and impacts are related to stakeholder engagement and biodiversity management.

FPE manage labor risks in their solar panel supply chain through an internal process to evaluate and monitor their supplier’s compliance with FPE E&S policies, including on human rights. This process involves adherence to a Supplier Code of Conduct (CoC), labor related clauses in purchase orders, as well as supplier mapping and traceability analysis. The CoC authorizes FPE to audit supplier and sub-contractor compliance and requires FPE suppliers to monitor that their own suppliers and sub-suppliers also comply with the FPE Supplier Code of Conduct. IFC will implement additional relevant contractual provisions in the project loan agreement.

All land for open access panel installation has been or is being acquired on Willing Buyer / Willing Seller basis with no option of recourse to judicial expropriation. Site visits and interviews with landowners and community members in the project areas confirmed that no third-party tenants or sharecroppers are adversely affected by these transactions.

Critical Habitat (CH) screening suggests that there is a limited probability that four Open Access sites could partially meet IFC Performance Standard (PS) No.6 Biodiversity CH applicability criteria. Therefore, FPE will adopt a precautionary approach and develop site specific Biodiversity Action Plans (BAP) to ensure net gain for CH species (Great Indian Bustard, Lesser Florican, Jerdon’s Courser) through collision and electrocution mitigations and community-based habitat conservation.                                                 

  In 2021, FPE redesigned their Environmental and Social Management System (ESMS) with the help of a leading international E&S consulting firm. The E&S policies and procedures defined in the ESMS guide FPE to comply with national E&S regulations and the requirements of additional reference frameworks including IFC Performance Standards (2012) and World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines. FPE Environmental and Social Management System (ESMS) is broadly appropriate for the nature and scope of this project, and mostly consistent with IFC Performance Standards (PS). Limited gaps and proposed mitigations are discussed in the Environment and Social Mitigation Measures and Environment and Social Action Plan (ESAP) sections below. 

FPE ESMS framework is designed to identify E&S risks and impacts associated with project lifecycle stages. It provides guidelines for E&S management programs, emergency response plans, a grievance redressal mechanism, and disclosure and internal reporting of E&S performances. FPE monitor and report on their E&S performance by tracking key indicators such as number of female staff, hours of training provided, Metric tonnes of CO2 averted, among others. FPE screen their suppliers and contractors using an ESG checklist. This checklist captures questions pertaining to labor and working conditions, Occupational Health and Safety (OHS), and other core E&S impacts and risks. FPE also has a corporate Contractor Health and Safety management plan that instructs and monitors contractor adherence OHS good practices.

FPE E&S performance demonstrates their strong capacity and commitment to identify and manage the E&S risks and impacts associated with their renewable energy business activities. FPE E&S policies and asset level reports reviewed by IFC show that FPE plan, implement, monitor, evaluate, and improve their E&S policies and performance in line with good international industry practices. For example, FPE prepare detailed E&S Screening reports for all proposed investments, and Environmental and Social Impact Assessments (ESIA) for their larger, more complex Open Access (OA) projects. Completed ESIAs for OA projects in Tamil Nadu and Andhra Pradesh are available in the Client Documentation section of the IFC Projects Disclosure Internet site. Ongoing ESIAs for projects in Karnataka and Gujarat will be completed by 30 November 2022.  

FPE has a dedicated Environment, Social and Governance (ESG) department whose job is to ensure that: i) all company activities are consistent with the ESMS, ii) E&S due diligence and ESIA reviews are conducted and incorporated into company decision-making and implementation processes, and iii) progress and adherence to ESMS implementation and applicable E&S management plans is monitored and reported on. ESG issues are embraced by FPE Board members, the founding directors, and staff whose corporate vision is to develop their business in ethical ways and with minimal adverse E&S impacts.   

One key issue that is not currently well integrated in the FPE ESMS is identification and management of the E&S risks and impacts of wind energy. FPE solar / wind hybrid project in Gondal, Gujarat is the company’s first wind energy project, and therefore IFC recommended that FPE update their ESMS based on the WBG Wind Energy EHS Guidelines (2007) (ESAP#1). These Guidelines identify wind energy specific E&S risks and impacts and advise on support effective E&S management of wind energy related noise, shadow flicker, and species mortality, among others.   

Another PS-related gap identified by IFC is the lack of updated site-specific Emergency Preparedness and Response (EPR) plans for all OA sites. FPE, in collaboration with relevant third parties, such as hospitals and fire departments, will prepare EPR plans that explain how FPE will respond to accidental and emergency situations to prevent and mitigate harm to people and/or the environment (ESAP#2). This preparation will include provision of equipment and resources, designation of responsibilities, and periodic training to ensure effective response.                                                 

  In 2021, FPE had a total workforce of 294 permanent employees, of which 14% were women. Total indirect jobs created during this time, including suppliers and contractors, was 4098. FPE did not layoff any workers during the Covid19 pandemic, but rather increased existing medical coverage. All FPE employees, their spouses, and their children, are covered by the company’s medical insurance policy.

Fourth Partner Energy (FPE) have documented Human Resources (HR) policies and procedures that are consistent with national labor regulations and IFC PS 2 requirements and apply to all employees. Each worker receives a written contract and induction training that describes the working conditions and terms of employment, as well as key company policies such as Occupational Health and Safety (OHS), the internal Grievance Redress Mechanism (GRM), and Supplier Code of Conduct, among others. FPE also conduct regular training and drills on OHS topics and emergency preparedness. 

FPE does not prohibit the freedom to associate and workers right to form and join workers organizations. Company policies encourage non-discrimination and equal opportunity for staff and contracted workers. FPE’s HR policies prohibit engagement of child, forced or bonded labor. The company’s HR team also monitors labor contractors’ compliance with applicable labor laws and related contract clauses. The Company’s whistleblower policy set up protections in the investigation process that include confidentiality and periodic monitoring & review.

On Occupational Health and Safety (OHS), FPE have an Audit department that encourages active reporting of unsafe acts, unsafe conditions, near-miss, incidents & accidents, and that helps to mitigate inherent risks and prevent recurrence. In 2021, there were a total of only 3 workplace related accidents.             

Despite having successfully implemented all the above-mentioned labor and working conditions related policies and programs, IFC due diligence identified some evidence of FPE contractors’ non-compliance with overtime provisions on wages and maximum number of daily working hours. FPE will conduct a labor audit of a representative sample of their OA and RTS projects at construction and operations phases and address any compliance gaps in contractor performance (ESAP#3).

 FPE renewable energy production activities are not resource intensive, nor do they result in significant quantities of wastes or emissions. Despite the limited nature and scope of their resource consumption and pollution related impacts and risks, FPE is implementing initiatives to reduce energy and water consumption and waste production. These initiatives are developed consistent with FPE ESMS corporate plans and procedures, and include steps to increase the share of renewable energy in their consumption mix, replacing wet cleaning of solar panels with robotic dry cleaning, and recovery and reuse of packing materials, among others.

One area where FPE agree that they can continue to improve is waste management. For example, not all FPE operations currently employ good international industry practices for appropriate storage, handling and containment practices, and training programme for solid and hazardous wastes. For this reason, FPE will prepare site specific waste management plans to collate all information on the generation of different waste streams and create action plans to reduce waste and contamination (ESAP#4).                                                  

  FPE project related business activities are expected to have a limited impact on community health, safety, and security. Rooftop solar assets are mounted on existing commercial and industrial facilities with little or no impacts on surrounding communities. Open access sites present potentially greater risks from road safety, migrant workers, and security personnel, especially during construction. To mitigate these risks at each project site, FPE engage with local communities on environment and social impacts throughout the project cycle. These engagements have included health check-ups for contractor workers and community members, and training on road safety, first aid, fire control. Security guards are unarmed and participate in training sessions on emergency preparedness and response.

FPE have developed an emergency response framework that defines key roles and responsibilities as part of their corporate-level Environmental and Social Management System (ESMS). However, due to the many environmental, social and administrative differences across all OA type project sites, FPE will prepare site specific Community Health, Safety, and Security (CHSS) plans to manage road safety, dust from vehicles, worker influx, exposure to disease, and security personnel (ESAP#5).                                              

  Rooftop solar projects will have a negligible impact on biodiversity due to their installation on existing commercial and industrial buildings. Ground mounted open access (OA) sites present a potentially more significant biodiversity risk profile. Critical Habitat (CH) screening of all project financed OA sites suggests that critical habitat values may exist for three of the sites related to the critically endangered Great Indian Bustard (GIB) and Lesser Florican (LF). The three sites include Atharga (Karnataka), Gondal (Gujarat) and Pavagada (Karnataka).  For these reasons, IFC advised FPE to adopt a precautionary approach and develop a Biodiversity Action Plan (BAP) to ensure net gain for CH species through the use of bird diverters on transmission lines and community-based conservation.  Existing projects and low-risk new projects will also require their Conservation Management Frameworks to be updated to comply with PS6 (ESAP#6).                                                    

            Not Applicable                                       

           Not Applicable                                        

FPE ESMS includes a Stakeholder Engagement Framework (SEF) to guide their stakeholder engagement activities in the form of Stakeholder Engagement Plans (SEP) applicable throughout the project cycle, from planning and preconstruction through decommissioning. The SEF advises FPE on how to conduct stakeholder mapping and analysis and recommends appropriate engagement methods and monitoring and reporting processes, among others. For example, FPE publish an Annual Sustainability Report based on Global Reporting Initiative (GRI) guidelines available here https://www.fourthpartner.co/impact-reports.html.

FPE make effective use of social media to engage online with stakeholders counting over 52,000 followers on LinkedIn and Facebook. FPE operate dedicated helplines for stakeholders to report violations of a) health, safety, or environment norms and b) ethical norms. These helplines are managed directly by the identified Head of Health, Safety, and Environment, and Head of operations respectively. FPE stakeholder engagement activities currently enable and support many local communities in crucial ways that improve communities’ access to energy, healthcare, education, and financial inclusion.

As of October 2022, FPE Stakeholder Engagement Plans (SEP) for the five OA sites are either incomplete or out of date. FPE will complete site specific SEPs for the OA sites tailored to the characteristics and interests of all affected communities (ESAP#7). SEPs will include a grievance mechanism and measures to encourage participation of especially vulnerable or disadvantaged people. SEPs will also be commensurate with the projects’ risks and impacts, and phases of development.                                                   

  Fourth Partner Energy Pvt. Ltd.

Fourth Partner House, Plot No. N46, House No. 4-9-10,

HMT Nagar, Nacharam, Hyderabad, Telangana – 500076

Email - esg@fourthpartner.co | Website - www.fourthpartner.co