Healthspring basically does not own physical assets.  Primary care clinics and the clinical laboratory are located in leased premises, and occupational health clinics (OHC) are located within spaces of Healthspring’s customers, generally in manufacturing sites in Tier 2 or 3 cities, where no known indigenous community and/or cultural heritage is present within the vicinity of the project locations. Accordingly, PS5 (Land Acquisition and Involuntary Resettlement), PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous Peoples) or PS8 (Cultural Heritage) are not applicable. Healthspring will develop a new clinic site screening & selection process/framework, to evaluate and phase out any site with potential risks around PS5-PS8.

The investment is Category B according to IFC's Policy on Environment and Social Sustainability (2012). The key E&S risks and issues associated with this investment include: (i) Healthspring’s capacity to identify, assess, and manage E&S risks and issues, especially associated with a new clinic site screening & selection as well as operational phase in line with the IFC PS requirements; (ii) Healthspring’s capacity to manage fair, safe, and healthy labor working conditions including gender-based violence and harassment in compliance with the local regulations and the PS2 requirements; (iii) resource efficiency measures; (iv) management of biomedical wastes; and (v) an emergency response including life & fire safety systems at clinics.

IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and the 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.

Identification of Risks and Impacts: Healthspring identifies and manages E&S risks and impacts associated with its operations primarily through compliance with applicable national standards and E&S regulatory permits and requirements (e.g., biomedical waste handling, food & drug administration, pre-conception and prenatal diagnostic techniques, shop registration, operation of medical diagnostics x-ray equipment). Considering Healthspring’s business nature, the size of facilities and that they are typically set-up in leased premises in/near residential areas, formal environmental and social impact assessment is not required for Healthspring’s facilities or its business operations.

E&S Policies and Management System: Healthspring has a documented Health and Safety Policy in which it is committed to the goal of providing and maintaining a healthy and safe working environment, with a view to continuous improvement. Healthspring is certified in line with international ISO 9001:2015 quality, ISO 14001:2015 environmental and ISO 45001:2018 occupational health and safety management systems.

Healthspring has yet to develop its own E&S management system (ESMS) while adhering to compliance with the regulatory permits and requirements. As per ESAP #1, Healthspring will develop and implement an overarching ESMS at corporate level to provide consistent oversight of E&S aspects of its operations. The ESMS will include Indian applicable legal and regulatory requirements and IFC Performance Standards (IFC PS) which shall be communicated to all staff through various channels including intranet, induction session and staff training. The ESMS will incorporate elements including but not limited to: (i) corporate E&S policy (by updating the existing Health and Safety Policy to include Healthspring’s commitment to “Environment” aspect); (ii) E&S due diligence process for risks/impacts identifications and management during new site selection (site screening to evaluate and phase out potential risks around IFC PS5-PS8), preparation (construction, contractor and local community impact managements) and operation; (iii) organizational capacity and competency set-up (e.g., assignment of E&S management personnel at corporate level, training program); (iv) emergency preparedness and response (e.g., fire, evacuation, medical emergency, chemical spillage, natural disaster, regulatory compliance check with facility owners); (v) monitoring and review (e.g., identification of key performance indicators and review/feedback mechanism); and (vi) hazardous material handling (e.g., standard operating procedures [SOP] on chemical handling) as described in detail in respective sections of this ESRS.

Organizational Capacity and Competency: E&S function is typically managed by human resources (HR) department, and a dedicated E&S person has not been engaged at corporate level to oversee E&S across Healthspring’s facilities. At facility level, 10-15 staffs are typically assigned at each primary care clinic, occupational health clinic (OHC) and clinical laboratory which are managed by center managers along with technicians and staffs.

As per ESAP #2, Healthspring will define its E&S organization and nominate an E&S coordinator(s) who will manage E&S aspects at corporate level and oversee facilities. The defined E&S organization will also include roles and responsibilities in line with Healthspring’s policies and procedures, Indian regulatory requirements and IFC PS’s to ensure consistency with good international industry practice (GIIP) performance.

Emergency Preparedness and Responses: An emergency situation associated with Healthspring’s business operations may include risks of fire, structural and power failures, and natural disaster. Healthspring’s offices and facilities are located in leased buildings. Healthspring checks building owners’ compliance with fire safety requirements and permits from the local fire department. Healthspring also checks that fire safety measures, including evacuation map display, emergency exit, emergency lightning, and others are in place. Healthspring currently does not have documented emergency preparedness and response plan (EPRP) for its office, primary care clinics and the clinical laboratory covering various types of emergency situations. OHC is located at Healthspring’s customers facility, hence EPRP is primarily managed by the customers.

As part of ESAP #1, Healthspring will formalize and implement an EPRP for its facilities (office, primary care clinics, clinical laboratory). The EPRP will cover all potential emergencies (e.g., fire, natural disasters, medical emergencies, chemical spillage), describing roles and responsibilities for relevant personnel, training (firefighting and first aid), emergency contact numbers, emergency evacuation route, and others.

E&S Monitoring and Review: Key performance indicators (KPIs) which Healthspring regularly monitors include HR (e.g., prevention of sexual harassment) and occupational health and safety (OHS) (e.g., incident, injury). Review meetings are held once a month coordinated by safety officers at primary care clinics and OHC. AS it will be further discussed under “PS2 – Occupational Health and Safety” section below, critical event reporting and analysis is monitored including such events as needlestick injury and body fluid exposure. As part of ESAP #1, to further strengthen monitoring practice at workplace, Healthspring will formalize and document a procedure to monitor, review and report KPIs including OHS statistics of its employees as well as other indicators as needed. OHS statistics will include lagging indicators (e.g., injury frequency and severity, occupational safety and health administration [OSHA] recordable injuries, near-miss, lost workdays, X-ray exposure level, worker's compensation cost) and leading indicators (e.g., numbers of OHS audits and inspections planned versus conducted, training hours, number of management inspection rounds planned/executed) on top of Healthspring's practice of E&S audit currently in place. These KPIs will be presented to senior managements along with findings and recommendations.

As of May 2022, Healthspring employs approximately 750 direct employees (30% male and 70% female) and 150 contractual employees (70% male and 30% female). There is no third-party workers in Healthspring’s operations.

Human Resources Policies and Procedures: Healthspring has a set of established HR policies which are applicable to all employees including: prevention of sexual harassment; employee grievance process; non-discrimination; occupational health and safety; information security; and compensation and insurance. In addition, two HR policy handbooks are established for Healthspring’s employee: one for staffs at the corporate office, primary care clinics and the clinical laboratory; the other is for staffs working at OHC.

Working Conditions and Terms of Employment: Working conditions such as salary levels, holiday, leave policy and benefits are also stipulated in HR policy handbook including social security benefits (e.g., employees' provident fund, employees' state insurance, accidental insurance, group medical insurance). Employees are provided with a written appointment letter from Healthspring with descriptions of the working conditions and the terms of employment.

Non-discrimination and Equal Opportunity: No significant issues related with non-discrimination or equal opportunity have been raised in recent years, and general code of conduct in HR policy handbook promotes discrimination free work environment.

To further enforce its practice on non-discrimination and equal opportunity, as per ESAP #3, Healthspring will establish a documented policy on non-discrimination and equal opportunity explicitly committing to compliance with relevant Indian regulatory requirements; and the IFC PS2 requirements.

Worker’s Organization: Currently, there is no worker's organization or staff union at Healthspring. According to Healthspring’s senior management, the company 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.

Retrenchment: Healthspring has not undertaken significant collective dismissals in recent years even during the COVID-19 pandemic, and collective dismissals are not anticipated hereafter as well. All possible alternatives to retrenchment will be considered in coordination with employees, if any retrenchment is unavoidable.

As per ESAP #4, Healthspring 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, etc. in line with IFC PS2.

Grievance Mechanism: Healthspring has a documented formal grievance redressal procedure in place. The policy stipulates grievance escalation procedures, grievance committee members, Healthspring’s responsibility (e.g., confidentiality, timeline to resolve grievances), grievance raising channel (email), etc.

As per ESAP #5, Healthspring will update its employee grievance process by providing employees with various grievance raising channels in addition to email (e.g., helpline, complaint box) which also enable anonymous grievance raising.

Workers Engaged by Third Parties: As discussed above, Healthspring does not engage any workers employed by third parties.

Protecting the Workforce: Considering the nature of Healthspring's business and the workforce, child labor or forced labor is not expected at its operation. Healthspring confirms that no child/forced labor will be employed by checking age proof documents, adhering to the regulator requirements, in line with India Child Labour Act.

Prevention of Sexual Harassment: Healthspring commits to zero tolerance for sexual harassment in the workplace in its prevention of sexual harassment 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 Complaints Committee is established to handle and resolve issues related with sexual harassment which also prepares an annual report and submits it to concerned authority.

Occupational Health and Safety (OHS): As described in “E&S Monitoring and Review” section under PS1, major OHS issues in Healthspring’s workplace include exposure of healthcare workers to biomedical hazards such as needlestick and body fluid of patients. To prevent OHS incidence, Healthspring has Occupational Health and Safety Manual which stipulates responsibilities of designated staffs (e.g., safety officer, on-site supervisor), basic Do’s and Don’ts, critical injury protocol, and others. In addition, for facilities where X-ray apparatus is installed, Healthspring obtains certificates (“Registration for Operations of Medical Diagnostic X-ray Equipment”) in compliance with the regulatory requirements (Atomic Energy Act, 1962 in conjunction with Atomic Energy (Radiation Protection) Rules, 2004). Healthspring explained that the concerned staffs are provided with radiation badge to keep permissible level of exposure.

As per ESAP #1, Healthspring will strengthen OHS practices at workplace by establishing formalized documented procedure of monitoring and review mechanism. Furthermore, as per ESAP #6, Healthspring will update its OHS manual by incorporating radiation safety SOP to prevent radiation exposure of the concerned staffs which includes shielding method for controlling exposure, use of personal protective equipment (PPE), acceptable exposure limits for workplace radiological hazards, emergency protocol, and others.

Impact of COVID-19 Pandemic on Workforce: COVID-19 has not significantly disrupted Healthspring’s business operations as it is considered as essential health service provider. Healthspring has not implemented significant changes in terms of reduction of personnel, salary and benefit cuts, or changes to vendor contracts due to COVID-19. Support is provided to employees through regular briefings and contingency measures for preventing COVID-19 risk in accordance with the Ministry of Health’s instructions such as provision of personal protective equipment (e.g., face masks, gloves, sanitizers) at their respective workplace.

Resource Efficiency: Electricity is mainly sourced from the public grid at Healthspring’s office and facilities. Water is soured from public utility and wastewater is discharged into municipal sewage line as wastewater is primarily from domestic purposes (e.g., washroom, kitchen). As part of ESMS to be developed (ESAP #1), Healthspring will conduct an impact assessment to review its wastewater stream, implement monitoring program, and take actions as needed in case the effluent monitoring results exceed Indian legal requirements and/or the World Bank Group Environment, Health and Safety Guidelines limits. Healthspring targets optimizing the use of electricity and water at facilities by using energy efficient LED lighting, regular maintenance of electrical appliances, use of digital method to save films and chemicals for x-ray apparatus, and others.

Greenhouse Gas (GHG) Emission: GHG emissions associated with the Project is estimated to be less than 25,000-ton carbon dioxide equivalent per annum and remain around the same level upon project completion.

Hazardous Materials and Waste Management: Hazardous material handling and waste management are primary issues related with pollution prevention of Healthspring’s business. Hazardous materials include chemicals used in the clinical laboratory dealing with sample assessments (e.g., blood sample test). Wastes typically include domestic wastes, e-wastes, hazardous wastes (e.g., oil and lubricant from DG sets), and biomedical wastes (BMW).

For hazardous material handling, while several chemicals are used in the clinical laboratory such as sodium hypochlorite, reagents and others, material data safety sheet (MSDS) has not been maintained to handle such chemicals. As part of ESAP #1, Healthspring will develop a SOP on hazardous chemicals typically including but not limited to: requirement for accurate MSDS; mandatory checking of labelling of chemicals using globally harmonized system of classification and labelling of chemicals by manufacturer; storage of chemicals in designated storage shed with ventilation, leak detection systems and sprinkler systems and provision of secondary containment in storage areas to contain the material in case of any spill occurrence.

For waste management, the main legislation governing management and handling of waste in India include the Solid Waste Management Rules 2016 and Biomedical Waste Management Rules 2016. Healthspring’s facilities obtain BMW authorization from their respective state pollution control board. Healthspring has established procedures related with BMW management including SOP, checklist and process note. BMW is segregated at source into four categories depending on type of wastes and method of disposal (e.g., plastic contaminated with blood for autoclave, general wastes for municipal collections, sharp waste such as syringe). BMW quantity is kept in record using checklist and collected by authorized contractors for disposal or incineration at designated places.

Community Health and Safety: Healthspring’s operations are mainly primary care where there is no significant risk related to bio/chemical hazard, prevention of contagious diseases and/or increased traffic for product transport, construction activities, etc. Hence, impact on community is expected to be minimal. Helathspring has been implementing procedures and policies for the protection of public health, in line with Indian legislation.

Security Personnel: No security personnel are employed for the operations of facilities (office, primary care clinics, clinical laboratory).

Healthspring undertakes various community relation activities including quarterly newsletter, cardiopulmonary resuscitation (CPR) training for community people, and others. Its website is the primary medium of engaging its stakeholders including vendors, customers, communities, and regulatory authorities. Furthermore, Healthspring displays a website page titled “Everything you need to know about Coronavirus” where it explains symptoms and preventive measures of COVID-19 for public relation activity. The website can be accessed at https://www.healthspring.in/coronavirus.

Healthspring mainly has three community grievance raising channels including direct visit to office and facilities, telephone call and email through its website.

Contact Person: Rajeev Desai

Company Name: Wellspring Healthcare Pvt. Ltd.

Address: Forbes Building, 5th Floor, Charanjit Rai Marg. Fort, Mimbai 400001

Email: Rajeev.desai@healthspring.in

Phone: +91 22 61303434

Facsimilie: N/a