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.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
E&S Policies and Management Systems: CLINT has integrated CapitaLand’s environmental management system (EMS) with its occupational health and safety (OHS) management system to form an integrated Environmental, Health, and Safety Management System (EHSMS). The EHSMS is certified to ISO 14001 (Environmental Management System) and ISO 45001 (Occupational Health and Safety Management System) Standards, and generally in line with IFC PS requirements.
Risk and Impact Identification: CLINT's principal business objective is to hold completed, income-producing properties and not construction of business parks. Where CLINT acquires the completed business parks, the environmental and social impact assessment for the greenfield construction under the local regulations has been already undertaken at the time of original construction, prior to CLINT’s acquisition. In case of redevelopment and construction, CLINT carries out the relevant environmental and social impact assessment, as applicable. CapitaLand's Sustainable Building Guidelines (SBG), aligned with IFC PS, require the completion of an Environmental Health Safety Impact Assessment (EHSIA) before any acquisition or development activity. The EHSIA involves a thorough analysis of the project's potential impacts on the surrounding environment, considering indicators such as biodiversity, air quality, noise, connectivity, and cultural heritage.
The company maintains registers for Master Hazard Identification and Risk Assessment (HIRA), as well as registers for identifying environmental aspects and impacts for operational and construction projects. CapitaLand utilizes a comprehensive Internal audit checklist, which is prepared in accordance with local regulations and CapitaLand guidelines, that covers various areas such as safety, civil, electrical, maintenance, documentation, signage, and carpentry (wood working).
Organizational Capacity and Competency: CLINT has various corporate teams, including health and safety team, legal team, business development team, and human resources (HR) team, which are responsible for obtaining regulatory permits, monitoring and taking actions for compliance with internal and external requirements, and consolidating reporting information from site level. The sustainability committee oversees the development and implementation of CLINT’s sustainability objectives and strategies. At each IT park, there is an EHS officer and a business development team, responsible for the day-to-day implementation of E&S practices, however, there is no corporate level EHS coordinator. As per ESAP #1 CLINT will nominate a designated EHS coordinator at the corporate level.
Emergency Preparedness and Response Plan: The company has an emergency response preparedness manual (ERPM) that covers the procedures with roles and responsibilities, checklist and plans for the foreseeable emergency scenarios, including, earthquake, flood, cyclone, heavy rain, pandemic, fire, power failure, bomb or terrorism threat, leakage/explosion, spills, and civil disturbance. The ERPMs is tailored for each park, with detailed risk assessment and response procedures.
E&S Monitoring and Review: The company has a real-time tracking platform for the monitoring of environmental metrics such as energy and water consumption, carbon emissions, and waste generation. Occupational health and safety incident data is collected at the park level and shared with the corporate health and safety head on a monthly basis. E&S performance is reported to senior management on a quarterly base, through performance reports and management review meetings.
PS2: Labour and Working Conditions
As of December 31, 2023, the trustee manager has around 21 employees , all of them are in Singapore and CLINT employs 5,000 workers at the parks. The 5,000 workers include interns and contractors that provide cleaning/housekeeping and security services at its properties.
HR Policies and Procedures: CLINT’s Employee Handbook applies to all employees. The handbook includes policies such as a code of conduct, terms of employment, equal opportunity policy, and a grievance mechanism that addresses the prevention of sexual harassment, which are generally in line with IFC PS2 requirements.
Working Conditions and Terms of Employment: CLINT has a formal HR manual that outlines its organizational structure, hierarchy, and working conditions and terms of employment (e.g., on boarding, induction, working hours, attendance, leave, notice period, termination). In addition, employees receive written appointment letters that detail their working conditions and terms of employment.
Worker’s Organization: CLINT adheres to Indian Labor Law, which allows its employees to be represented by trade unions. This provides a platform for employees to address industrial disputes. Although currently, there are no unionized workers in any of the IT parks, CLINT has included its commitment to Freedom of Association as a part of its sustainability report.
Non-discrimination and Equal Opportunity: CLINT has an equal opportunities policy that prohibits discrimination and harassment of any kind. This policy applies to all aspects of employment, including recruitment, promotion, termination, layoff, recall, transfer, leaves of absence, compensation, and training.
Retrenchment: CLINT has not conducted collective dismissals in the recent years and does not anticipate any future collective dismissals. The company has a termination of employment policy that covers resignation, termination, retirement, and death.
Grievance Mechanism: CLINT has a whistle-blower policy in place to address concerns related to legal or regulatory violations, financial misrepresentations, and other issues. Currently, employees and contractors raise grievances in person, or over the phone. Superiors who receive complaints escalate them to their superiors for resolution. Additionally, the internal and external stakeholders can raise grievances via an email, this includes anonymous complaints.
Prevention of Sexual Harassment (POSH): CLINT commits to prevention of sexual harassment in its policy which prohibits any verbal, written, provocative behavior or physical harassment. There is an internal committee, established to handle and resolve issues related with sexual harassment. CLINT carries regular training on POSH for its employees; and the third-party contractor agencies conduct training on gender-based violence and harassment for the contractual employees. As per ESAP #2, CLINT will review its training materials for gender-based violence and harassment, for further upgrades and customization for all levels of workers in its business parks. For example, training materials to include more diverse scenarios and examples relating to all levels of workers (such as housekeeping and security, etc.)
Protecting the Workforce: CLINT’s HR Manual includes commitment for the prevention of child labor and forced labor.
Workers Engaged by Third Parties: The company outsources functions such as security, cleaning, housekeeping, front desk and reception management, and X other functions, to third-party contractors. CapitaLand has implemented the CapitaLand Supply Chain Code of Conduct Initiative regarding salaries/wages, working hours, working conditions, prevention of child and forced labor. Contractors are required to hire employees who are older than 18 years of age, and CLINT verifies the implementation through documentation checks. The initiative also includes health and safety aspects.
Occupational Health and Safety (OHS): CLINT has implemented a Property Management Health and Safety manual that applies to all operational projects, covering various aspects of health and safety , including commitment, targets, controls, methods, and management. It also outlines roles and responsibilities and includes standard operating procedures (SOPs) for personal protective equipment , fire prevention, hazardous waste disposal, and emergency preparedness. CLINT also has an OHS manual specifically for construction projects, which covers key activities and safety measures. Workers receive safety induction and regular trainings, and accident/incident investigations are conducted with corrective actions implemented. For 2020-2023, there are no recorded fatalities and/or significant injuries.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: The Trust’s direct energy consumption includes fuel consumption for emergency genset testing and diesel generators. Indirect energy sources consist of traditional grid energy, off-site solar farms, and energy generated from solar rooftop installations in International Tech Park Bangalore, International Tech Park Chennai, CyberVale, CyberPearl, aVance Hyderabad, Building Q1 and aVance Pune. The company has installed 705 MWh of rooftop solar panels.
Green House Gas (GHG) Emission: CapitaLand monitors GHG emissions for all the IT parks and discloses the monitoring outcome in its Sustainability Report at https://investor.clint.com.sg/misc/CapitaLand-India-Trust-AR2023_SR.pdf. The report for financial year ending 31 December 2023 indicates a total of 37,282-ton (Scope 1 + Scope 2) carbon dioxide equivalent emission per year.
Air Emission Monitoring and Ambient Air Quality: Air emission and ambient air quality is inline with local regulation requirements, World Bank Group’s relevant Environmental Health and Safety Guidelines guidance values and CLINT EHS manual.
Ambient Noise: CLINT has a noise monitoring and control procedure in place that defines measures to manage the noise in line with local requirements in order to prevent CLINT staffs, workforce and neighbours from noise-induced health hazard as well as to protect the environment from noise pollution.
Water and Wastewater: Water for the IT parks is sourced from municipal supply and tankers. The company has Sewage Treatment Plants (STPs) at all operational parks and plans to expand them for demolition and redevelopment projects. Additionally, all IT parks have implemented a zero liquid discharge system. Recycled and treated water from the STPs is used for non-potable purposes.
Solid and Hazardous Waste Management: CLINT has a waste management policy in place. Waste generated at operational IT parks is segregated at the source and collected in designated waste collection areas. It is then disposed of through authorized vendors and/or municipal agencies. A construction waste management policy is also in place. Hazardous chemicals are limited to housekeeping and maintenance chemicals and CLINT has material safety data sheet and SOPs in place for handling and management of hazardous materials.
PS4: Community Health, Safety, and Security
The IT parks have office buildings that are occupied by tenant companies with electronic access. The guests have access through security gate. In addition to this, some of the parks have shopping malls, residential hotels, restaurants which are accessible to public.
Infrastructure and Equipment Design and Safety / Life and Fire Safety (LFS): CLINT adheres to local legal requirements for the design, development, and construction of its IT Parks. This includes complying with the specifications outlined in the master plans of each city, as well as the requirements set forth by MoEFCC (Ministry of Environment, Forest and Climate Change) and NBC (National Building Code). CLINT’s Office Park buildings are fitted with fire, emergency signage, emergency lighting, portable fire extinguishers, sprinkler systems, FM200 gas systems, fire hose/reel systems, fire detectors and alarms, and other measures as determined by local regulations. The company is responsible for fire safety in the general common areas and conducts monthly inspections, maintenance activities and also mock drills. Contracts with tenants require the tenant to perform inspection, testing and maintenance (ITM) of LFS systems, including emergency power generation systems, in accordance with local regulatory requirements.
Security Management: CapitaLand employs unarmed security guards from external security agencies. These security agencies conduct background verifications of guards and provide training on effectively interacting with construction workers and communicating with neighbouring communities.
