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.
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
Policy, Environmental and Social Management System (ESMS) and Management Program: TVS Emerald has a management system, generally integrated as Total Quality Management (TQM) from the TVS group and is being replicated for the business operations of the TVS Emerald. The company has a process map and guidelines such as E&S rules for contractor and/or for different work orders, contractor worker accommodation, general procedure for materials storing & stacking etc. In addition, certain checklists, such as induction training, workers screening, toolbox meeting, first aid room inspection, labour accommodation inspection, accident report, near miss reporting, mock drill, work stop notice, safe to start work, work permits (confined space, hot work, electrical work, height work), are available.
As part of IFC investment and agreed environmental and social action plan (ESAP #1), TVS Emerald will develop an ESMS covering both construction and operation phases, in line with national standards and IFC PSs (from PS1-8), building upon the existing E&S procedures in the TQM. TVS Emerald will contractually require the construction and service contractors to adhere to its E&S Policy and ESMS. ESMS will also include additional management programs, referring to standard operating procedures (SOPs) for managing E&S risks and impacts from construction, and operation and maintenance (O&M) activities.
Impact and risk assessment: TVS Emerald performs a due diligence of potential land plots which includes review of land titles by a legal firm, survey details, applicable byelaws, land use, land zonation, conversion status and nearby sensitivities (such as any drainage, high tension line, village roads/cart road, graveyards, defense area, dumping yard, Sewage Treatment Plant (STP) etc.). TVS Emerald purchases land through willing buyer seller transactions as all the transactions are market based, voluntary in nature and commercially negotiated directly from the landowners. Also, only land zoned as residential under the development/master plan of Chennai, Bangalore (and nearby urban locations such as nearby municipal corporation or municipality) will be purchased for the proposed housing developments. As per ESAP item#1, ESMS will include a screening procedure/checklist for assessing E&S risks and impacts associated with the new projects and that will be completed for each new potential residence location covering requirements of IFC PS1 and PS 3-8 as well as a specific land acquisition policy/ guideline for potential land purchases, in line with IFC PS5 requirements.
TVS Emerald obtains relevant permits such as environmental clearance (EC) from state environment impact assessment authority for all its projects prior to start of construction.
Organizational Capacity and competency: The company has a dedicated TQM team which works with the various departments to develop standard operating procedure (SOP), method statement and checklist. The regulatory permits for all projects are obtained by liaison department of the company, which is also responsible for ensuring compliance with various permits. E&S aspects are managed at the corporate level by an E&S Manager who is responsible for supervising all the projects construction phase and co-ordinates with Safety Officer at each site. The Safety Officer along with the Project team at site is responsible to monitor that E&S procedures are followed, conduct regular safety training, safety inspections, accident investigation and oversee the contractor’s safety team. The Safety Officer also oversees tool box meetings and site safety committee meetings. Each of the construction contractor is required to have safety coordinator(s) and adhere to TVS Emerald’s E&S procedures as well as EHS plan submitted by the contractors. As part of ESAP#1 requirements, the corporate ESMS will further specify the roles and responsibilities including specific monitoring and reporting checklist to be followed by corporate E&S manager and safety officers as well as responsibility towards monitoring E&S performance of the contractor, including labour camp accommodation, GBVH where relevant, emergency preparedness and response plan implementation. The company is responsible for management/ maintenance of their building typically for a period of one year or more depending upon the agreement. The O&M work for the limited period is typically provided through third party agencies through a service agreement and is overseen by the facility management team.
Emergency Preparedness: TVS Emerald has a corporate level emergency preparedness manual for epidemic / pandemic / endemic, cyclones and heavy rains. At the site level, the EHS plan submitted by the contractor, includes emergency preparedness plan with emergency contact numbers, details of emergency response team, and key procedure to be followed in case of flood/cyclone and epidemic, electrocution etc. Per ESAP #1 requirements, the corporate level emergency preparedness manual will be updated to include coverage of additional emergency risks such as fire/ explosion, earthquake, collapse of structure, guidance on detailed content for the emergency preparedness and response plan for the Projects and will be linked to ESMS. The site level emergency preparedness plan for each construction site will be updated in line with the corporate emergency preparedness manual to include resources to combat emergency, duties of emergency coordinator and fire and safety coordinator as well as other details and the implementation will be regularly monitored as part of the ongoing EHS monitoring at sites.
Reporting & Monitoring: Environmental monitoring is conducted at all construction sites include monitoring of ambient air quality, ambient noise, soil, drinking water and wastewater quality and monitoring reports are submitted to the regulatory authority. At the construction site, weekly inspection is conducted by the designated project safety executive to identify unsafe practices which are then reported to the Project Manager for making necessary improvements. There is a site level Safety Committee in place comprising of the Project manager, safety executive, project contractor and contractor’s safety executive. Each of the construction site submits monthly reports to the corporate E&S manager/safety officer which includes data on manpower, number of incidents/accidents/first-aid cases/near misses and EHS induction trainings. Environmental monitoring during operation phase will be limited to stack emissions of diesel generator and treated wastewater from Sewage Treatment Plant (STP).
As per agreed ESAP# 2, TVS Emerald will conduct a third-party review of EHS, and labour measures, for all the proposed construction projects through an external consultant (acceptable to IFC) to evaluate the implementation of the procedures developed as part of ESMS As part of the evaluation, the implementation of the land purchase process for the specific development will also be reviewed in line with the land acquisition policy/guidelines developed as part of the ESMS. The evaluation will focus on compliance with respect to TVS Emerald’s relevant ESMS requirements and EHS rules for the contractor and will identify any improvements to be implemented within an agreed reasonable timeline.
PS2: Labor and Working Conditions
As of March 2025, the company directly employs 285 people (41 female and 244 male); in addition to limited manpower on retainer (~13) engaged to support multiple functions including legal, finance, design, and HR. Further, 79 workers (33 female and 46 male) are hired through manpower agencies mainly for tele-calling, customer relationship management. There are around 40 security staff hired through service contract. There are third party contract workers for construction projects (~2230), wherein the workforce number is variable depending upon the number of ongoing projects. At the time of the appraisal, Company had a portfolio of six ongoing construction projects and three completed projects where facility management services are provided. HR department at TVS Emerald has five team members led by an HR head.
HR policies: Most of the HR related policies and procedures follow the TVS group policies and procedures which includes processes such as hiring, onboarding, training & competency development, knowledge management, performance management, departure process. As part of ESAP# 3, TVS Emerald will update and develop (as required) HR policies and procedures in accordance with IFC PS2 provisions related (but not limited) to: non- discrimination, policies for prevention of child and/or forced labour, an internal mechanism for employee complaints/grievance redress (covering contractors and anonymous grievances); prevention of sexual harassment; Freedom of Association (FOA) and non-retaliation. The company will make a copy of the HR manual/handbook available to each employee and communicate it to employees through refreshment and on boarding training. The company will require the construction and O&M contractors to implement HR policies and procedures that comply with the national laws and IFC PS2.
Terms of employment: The company provides joining letter to direct employees; similarly, manpower agencies provide appointment letter to their employees, which articulates the terms and condition of employment including various benefits including contract period, leave, ESIC, PF, Gratuity, insurance. The third-party employees are guided by the company policy as per the appointment letter which includes - public holidays, timings, shift-timings, attendance recording, reporting structures, working hours, dress code, leave entitlement, discipline, security requirements, work ethics, etc
Non-Discrimination: Though, the company does not have a documented policy on non-discrimination, consultation with employees indicated no discrimination faced in employee selection, performance appraisal, growth or in the day-to-day operations.
Worker protection: In compliance with local labour laws, TVS Emerald does not use child labour or forced labour 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. This is further included as part of agreement with the contractor.
Grievance Mechanism: Most of the grievance reported is through verbal channel and no written records of grievances are available. As part of ESAP #3 requirements, TVS Emerald will update its HR policy and procedure to include an internal grievance redressal mechanism to address and resolve grievances of the employee including contract workers and allowing for anonymous reporting of the grievance.
Collective Bargaining and Freedom of Association: TVS Emerald currently does not have any union and there have not been such requests among the employees. The management team of TVS Emerald confirmed that per local labour legislation, employees have freedom of organization and can participate in workers’ organizations.
Occupational Health & Safety (OHS) Management: TVS Emerald’s own operations are generally limited to office work and construction contractors are engaged on project sites. TVS Emerald has documented EHS rules for contractors applicable to all construction sites. The contractor is required to submit an EHS plan within 15 days of issuance of purchase order and to deploy safety coordinators who coordinate with the TVS Emerald Safety Officer. All construction site workers, including contractors, are required to have initial safety training and induction prior to starting work. There have been no significant injuries and fatalities on TVS Emerald construction sites in the last three years. The project team conducts monthly site level safety meeting including joint inspection. The contractor safety executive also conducts monthly EHS audit. Additionally, the TVS Emerald internal quality audit team conducts quarterly audit of sites including EHS aspects. The ESMS to be developed (as per ESAP item #1), will include procedure and checklist for reporting, monitoring and documentation of EHS performance on-site by the company including the contractor EHS plan implementation and strengthening procedures to record accidents/incidents by its personnel and contractors, investigate them and implement corrective actions.
Third party workers: The company mostly employs contract workers for the construction stage. Agreement with the construction contractor includes requirement for the contractor to adhere to statutory labour laws and regulations (including amongst others requirement of minimum wages, non-deployment of child and forced labour, overtime and workmen compensation). Labour accommodation is usually provided by the construction contractors outside the project site and a manual for labour camp accommodation has been developed by TVS Emerald which will be implemented by the construction contractors.
As part of ESAP #1, the company ESMS will include formulating and enforcing labour accommodation standards that are in line with IFC worker accommodation standards, 2009 (Ref: https://www.ifc.org/content/dam/ifc/doc/mgrt/workers-accomodation.pdf). The company will also develop a contractor management system to require and monitor contractor/service provider to comply statutory labour requirements (such as related to working hours, minimum wages and overtime payment) and IFC PS2 provisions, and to allow service provider/contractors’ employees to access to TVS Emerald’s internal grievance mechanism. This will include checklist to be followed by TVS Emerald for ensuring compliance with legal requirements on working conditions and non-deployment of child and forced labour including monitoring of the labour accommodation at the construction sites. The contractor management system will factor in the findings and corrective actions, if any as an outcome of the third-party evaluation of the construction sites (refer ESAP # 2).
PS 3: Resources Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas (GHG) Emissions: The company reviews the feasibility for resource efficiency at the concept stage including usage of energy efficient devices; cross ventilation; shades; daylight factor etc. The company has a plan to achieve EDGE certification for IFC funded projects.
Resource efficiency measures on site and/or incorporated into design includes use of pumps operated with variable speed drive (VSD); mechanical ventilation design for basement based on input from carbon monoxide sensor; installation of Light emitting diode (LED) lighting for common areas; outdoor lighting timer installation for external lighting; use of variable voltage variable frequency (VVVF) for lift operations; and bidirectional meter which can generate electricity when connected to the grid. TVS Emerald has also adopted various measures in its existing projects to ensure resource efficiency such as dual piping system of plumbing for utilizing recycled wastewater in flushing, provision of STP for treatment of domestic wastewater and to be recycled for gardening and flushing purposes and provision of rainwater harvesting system for recharging ground water and collection of rainwater from rooftops. Considering project’s limited footprint as housing project, GHG emissions of the project are expected to be less than 25,000 tons of carbon dioxide equivalent emission per year.
Pollution prevention: The construction site is regularly sprayed with water and construction materials are covered with sheet to avoid spread of dust particles. The noise and ambient air quality levels are monitored and confirmed within national standard limits. The backup diesel generator is enclosed type, with noise attenuators installed, to meet national noise and air quality standards.
Water and Wastewater: During construction, ground water as well as treated wastewater from STPs is utilized as per guidelines provided by State Pollution Control Board (SPCB) which is further treated at site to ensure construction water quality as needed. Water during the operation stage is usually supplied by local government agencies or through borewells (in case piped water supply is not available) and water, as required) is treated on-site to ensure that water quality meets the national acceptability standards. Wastewater during construction phase is disposed off in septic tanks. STPs are provided during operation phase, and treated wastewater is re-used for flushing and gardening purposes and meets the statutory requirements as set by SPCB. Excess treated sewage is discharged into municipal sewerage system, if required. The company also ensures recharge pit and recharge well along with the water drainage system for ground water recharge.
Wastes: Waste produced during construction is segregated and collected at the generation point; metal scrap is recycled by authorized 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 sent for further disposal to the municipal agency once the projects are operational. The company also provides composting system to reduce domestic food waste, and the generated compost is then used for gardening purposes. Hazardous waste is limited to used oil from the generators, paints, lubricants and cleaning chemicals for maintenance (both during construction and operation phases) which is collected and disposed by authorized vendors, as defined by the local SPCB.
PS 4: Community Health, Safety, and Security
TVS Emerald follows the local legal requirements for design, development and construction of the housing developments including the specifications defined in the Master Plan, National Building Code of India (NBC) and requirements stipulated by the Ministry of Environment, Forest and Climate Change (MoEF&CC) which covers fire protection standards, drainage, waste disposal, conservation of fuel and energy and accessibility among others. As a requirement of the State regulatory by-laws, local authorities inspect the projects, including fire safety provisions and issue the “No Objection Certificate” for fire. During IFC appraisal visit to completed and new project sites, the fire-protection measures that are in place included fire extinguisher, hose reel, fire alarm, emergency exit, dedicated fire water storage with provision of jockey pumps.
As per ESAP # 4, TVS Emerald will ensure that for each of the proposed housing projects under IFC funding, a qualified fire safety professional will certify that the design meets the requirements of the Indian National Building Code (NBC) requirements and requirements approved by the appropriate authority providing fire NOC / fire license for the project. Additionally, for each of the proposed housing projects, a suitably qualified fire safety professional will conduct a review as part of the project completion test at the time of life and fire safety (L&FS) systems testing and commissioning and certify that construction of these systems has been carried out in accordance with the accepted design. Should the certification have any findings and recommendations, it will be used to establish a Corrective Action Plan (CAP) and TVS Emerald will implement the CAP in a time frame.
Further, as per ESAP #5, to ensure the correct and safe operation of the L&FS systems after the handover of the facilities to registered residential societies, TVS Emerald will develop a detailed program (Operational Manual) for efficient operation & maintenance (O&M) of L&FS systems installed in the facilities (i.e. Technical Annex) that will be attached to the house owners contracts and once the completed projects are handed over to the Resident Welfare Association (RWA) formed for each project. The plan includes the frequency, procedure for the inspection, testing and maintenance of L&FS systems and the required performance (KPIs) based on Indian codes.
To minimize the impacts on neighbouring communities, TVS Emerald provides clear demarcation of construction areas; restricted access to construction sites; information on movement of vehicles; proper illumination of areas; and provision of safety information to visitors and people residing in the projects while construction is being completed. As part of the ESMS proposed to be developed (ESAP #1), TVS Emerald will develop and implement a documented community grievance mechanism, i.e., a process of receiving and responding to the grievances which meets IFC PS requirements and will be implemented onsite for all the proposed housing developments under IFC funding.
Security Personnel: The company hires mostly 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 neighbouring communities. As indicated in ESAP item #1, the ESMS will include corporate security management protocol and will include procedure for deployment of security personnel, training on community engagement, GBVH and grievance management that will be implemented by security agencies.
