If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.

This is a Category B project according to IFC’s Environmental and Social Sustainability Policy, 2012, as it is expected to have limited potential adverse E&S risks and impacts that are few, generally site-specific, largely reversible, and can be readily addressed through mitigation measures. Key E&S aspects include the company’s system and organizational capacity to identify and mitigate E&S risks and impacts, stakeholder engagement, and grievance redressal mechanism, labor and occupational health and safety (OHS), resource efficiency and pollution prevention during demolition, construction and operations, community health and safety including life and fire safety (L&FS) and road safety.

Environmental and Social Policy & Management System. MREIT has an overarching Environmental, Social, and Governance (ESG) policy outlining the objectives related to resource conservation and efficiency, employee and community relations, and responsible business conduct. The policy outlines key focus areas that include carbon-neutral operations, futuristic buildings, human capital development, community and tenant relationships, health and safety, human rights and ethical conduct, responsible portfolio, and responsible sourcing and supplier engagement.  

MREIT has secured ISO 14001 (Environment) and ISO 45001 (OHS) international management system standard certification for its ESMS. ESMS includes facility management services for all its existing operational assets. It has also prepared a green lease framework collaborating with tenants to pursue ESG objectives jointly. MREIT gets support from its Sponsor’s ESMS to design and construct the new assets. Per ESAP #1, the MREIT will update and adopt its ESMS to new asset design and construction.  

Impact Identification and Assessment. Construction and area development projects in India, including those undertaken by MREIT, fall into the low-risk Category B projects within the national regulatory framework, necessitating environmental clearance from the local State Government authorities for assets with more than 20,000 sqm of built-up area. MREIT conducts the Environmental Impact Assessments (EIAs) for new projects to obtain regulatory approvals. It has completed two EIAs [Building 1 and Building 8] for the redevelopment projects at Mindspace Madhapur, adhering to regulatory requirements. However, MREIT currently lacks a documented E&S due diligence (ESDD) procedure for the new acquisitions and developments, covering the risk assessments per IFC PS requirements. As a part of its ESMS, MREIT will develop and implement an ESDD procedure aligned with IFC PSs for new asset acquisitions, development, and redevelopment. (ESAP # 1). The ESDD procedure will encompass E&S site screening, including climate risk for new locations and procedures for impact assessment and management. 

Organizational Capacity and Competencies. E&S roles and responsibilities are shared by cross-functional committees, including the Executive Committee, comprising of board members and key management personnel reporting to the governing board and working groups responsible for identifying, developing, and monitoring the ESG efforts. In addition, MREIT has constituted a Research and Development Council from the senior management team to research projects to enhance the E&S performance of the assets and mitigate climate risks. The Sustainability Lead Officer heads the ESG team for MREIT at K-Raheja Investment Manager, supported by four assistants. At assets, the complex (property) manager, supported by safety officers, is responsible for compliance and overall E&S performance, including key performance indicators (KPIs). MREIT has also set up an ‘ESG Squad,’ a cohort of employees specially formed to drive the ESG initiatives to achieve the desired outcome and impact. 

Emergency Preparedness and Response. An emergency preparedness and response (EPR) system is in place across all operational assets to respond to accidents and emergencies, including fire, explosions, and safety incidents. MREIT actively maintains the emergency response infrastructure, undertakes regular mock drills and training programs for on-site staff, and communicates its EPR with government authorities. MREIT will update its EPR Procedure to incorporate considerations and responses for climate risks such as cyclones, flooding, extreme temperatures, and heat waves. Furthermore, MREIT will communicate the relevant aspects of the EPR plan for each asset with the neighboring commercial and/or residential communities that could potentially be affected by an emergency at the assets. (ESAP#1) 

Monitoring and Review. As part of its ESMS, MREIT has established monitoring and review procedures, including internal and external audits, to monitor compliance with E&S management programs. MREIT sets and tracks around twenty KPIs on eight focus areas, which include energy consumption and efficiency, share of renewable energy, water consumption, and GHG emissions. E&S performance is reported to senior management on a quarterly basis. 

 Human Resource (HR) Policies and Procedures. The Sponsor’s HR policy applies to all the group companies, including MREIT and its SPVs. The HR policy includes commitments for equal opportunities and nondiscrimination diversity, and REIT workplaces and premises are designed to accommodate differently able employees and visitors for accessibility.  

MREIT maintains an HR Manual that includes policies on business ethics, code of conduct, diversity, equality, and inclusion; prevention of sexual harassment; grievance redressal; and freedom of association and is aligned with Indian labor laws regarding minimum wage, benefits, working hours, shift times, and overtime payment, among others. Its Human Rights policy prohibits child and forced labor directly and through contractors. MREIT conducts regular internal and external audits to verify compliance of local labor law by contractors. There is no structured documented grievance redressal mechanism for the third-party contractor workers. MREIT will broaden the scope of its workers’ grievance redressal procedure to include access to contractor workers and provide channels for receiving anonymous complaints. (ESAP # 3). As a part of its ESMS for design and construction, MREIT will update its labor camp specifications aligned to IFC workers’ accommodation guidelines and ensure its compliance with the construction contractors. (ESAP # 1) 

Occupation Health and Safety. MREIT has adequate OHS Management System procedures to assess and monitor OHS aspects associated with its operations, including an EPR plan, L&FS measures, safety training and emergency drills, and incident management, among others. Per its OHS Management System, MREIT identifies, minimizes, and manages its health and safety risks across all assets. The System includes safety training, both internal and external safety audits, monthly cross-functional safety rounds, safety committee meetings with active worker participation, and strict adherence to a permit-to-work system. Standard Operating Procedures (SOPs) and work instructions, aligned with British Safety Council standards, are also communicated to tenants, emphasizing a shared commitment to safety. Moreover, MREIT has collaborated with tenants to develop Office Occupant fit-out guidelines, encompassing procedures related to fit-out, sustainability, and health, safety, and environmental requirements. In 2023, there were no fatalities, and the lost time injury frequency rate (number of lost time injury cases per million worked hours) was 1.13, which is satisfactory when compared to a good industrial benchmark of 5.5 for rental and leasing services (www.bls.gov). MREIT will upgrade its OHS procedures to include climate risks of increased temperature, heatwaves, and flooding on workers’ health and safety during construction and operation. (ESAP#1) 

Supply Chain: As a part of its ESG framework, MREIT implemented a sustainable procurement policy, which includes a commitment to the Supplier Code of Conduct (SCoC) and emphasizes the local procurement of environmentally friendly and energy-efficient materials. SCoC outlines the requirements related to labor, human rights, and working conditions and addresses aspects such as prohibition of child and forced labor, compliance with working hours and minimum wages, freedom of association, and compliance with all relevant laws and regulations. All new suppliers and contractors are required to agree to abide by the SCoC before empanelment and award of work. Approximately 56% of tier-1 suppliers are already covered under the code. MREIT aims to cover all suppliers under SCoC by 2030. Furthermore, MREIT has also conducted Human Rights Due Diligence to assess human rights violations across business operations and the value chain.

  Resource Efficiency. MREIT has implemented various initiatives to conserve energy in buildings. These include chiller room management systems, variable frequency drives, automatic tube cleaning systems, heat recovery wheels, smart thermostats, sensor-based smart lighting, integrated building management systems, and regular energy audits. 

Greenhouse Gas (GHG) Emissions. The Mindspace project?is expected to emit 69,922 tons of GHG per year (Scope 1 and 2) from its existing and under-construction portfolio of green buildings.? The financed GHG emissions are estimated to be 20,180 tonsCO2e/year. By displacing grid electricity and enhancing energy efficiency, the project is expected to reduce annual GHG emissions by 8476 tons by March 31, 2030.1 

Pollution Control: MREIT has implemented a zero liquid discharge policy and zero landfill waste disposal across all its assets. MREIT incorporated rainwater harvesting and enhanced wastewater recycling plants with Membrane Bioreactor (MBR) technology. All generated waste is diverted to authorized recyclers.  

MREIT’s occupants are contractually obligated to advocate for sustainable alternatives such as reusable bags, straws, and containers to promote a sustainable ecosystem. During the construction phase, MREIT employs measures like high-tech mist blowers, which spray water in mist form to suppress dust emissions and acoustic enclosures. Additionally, noise-generating activities are restricted to daytime hours.

  Community Health and Safety. MREIT has established Emergency Preparedness and Response (EPR) plans at each facility, which are also communicated to government authorities. It has conducted pre- and post-implosion structural assessments of buildings in the impact zone during demolition operations at Mindspace Madhapur. The EPR for demolition was shared with nearby communities in the impact zone. As per ESAP # 1, MREIT will communicate relevant portions of its EPR for each operational asset with nearby commercial and residential communities that could potentially be affected by an emergency at the assets. Furthermore, MREIT will implement a robust traffic management and road safety plan for Mindspace Madhapur to address the impacts of the movement of construction vehicles. 

Life and Fire Safety: MREIT adheres to the US National Fire Protection Association (NFPA) codes for building design along with the Indian National Building Code (NBC) to meet mandatory national fire safety license requirements and client demand. In addition, during the operational phase, annual third-party fire safety audits are conducted against national codes to ensure the highest fire safety standards. 

Security Personnel. The operational assets have a security management system incorporating multilayered electronic measures and third-party unarmed security personnel. The security service provider is responsible for conducting background checks and providing training related to the code of conduct of the security personnel deployed at the site through contractual provisions aligned with industry practices. MREIT will develop and implement the security personnel procedures in accordance with IFC PS4 requirements to include training the security personnel in interaction with affected communities; recording, investigating, and implementing corrective actions for security incidents; investigating and implementing disciplinary action for Bonafide complaints against security personnel; and establishing grievance mechanism for aggrieved members community and employees to address any related concerns. [ESAP # 4]

MREIT has adopted the stakeholder grievance policy applicable to MREIT and all its SPVs, covering both internal (employees) and external stakeholders (customers, community, contractors, suppliers, and government authorities), but its community engagement is limited to corporate social responsibility activities and engagement with the tenants. MREIT, as included in ESAP# 2, will establish and execute a formal structured Stakeholder Engagement Procedure, including a grievance redressal mechanism (GRM) for the community and other stakeholders that would meet the requirement of IFC PS1. The grievance mechanism will ensure that grievances from affected communities and external communications from other stakeholders are responded to and managed appropriately.

Any queries and/or comments about the project may be directed to: 

Company Name: Mindspace Business Parks REIT 

Point of Contact: Mr. Bharat Sanghavi 

Title: Compliance Officer 

Telephone Number: +91-22-28564000 

Email: bondcompliance@mindspacereit.com

Mailing Address: Raheja Tower, Level 8, Block ‘G’, C-30, Bandra Kurla Complex Bandra (East) Mumbai 400051 

Website: https://www.mindspacereit.com/home