This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, as it is expected to have adverse E&S risks and/ or impacts that are limited in scale, few, generally site-specific and readily addressed through mitigation measures, by adhering to good international industry practice (GIIP) procedures, guidelines, and design criteria, as described in the following sections.

Key E&S aspects associated with this project include: (a) company's capacity to formulate and implement an integrated environmental, social, health & safety (ESHS) management system; screen new offices/ acquired assets for E&S risks and impacts; management and mitigation of impacts during construction (mostly renovation) and operation, and; review and manage E&S performance that meets IFC PS 1 requirements, applicable local legal requirements and good international industry practices (GIIPs); (c) corporate level overarching human resource (HR) policies and procedures which can be further calibrated to meet country specific requirements; (d) life and fire safety (L&FS) risks at studios (rented to third parties); and (e) stakeholder engagement and community grievance mechanism.  

 The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. DNEG has a corporate level facility management team at all country locations which manages the environment, health and safety (EHS) aspects of the business operations.

Policy: DNEG will, as part of Environmental and Social Management System (ESMS), will formulate and implement an ESHS Policy that incorporates national standards and IFC PSs. DNEG will as per its ESHS Policy ensure that the O&M contractor and EPC contractor (if any, in future), and the service contractors adhere to its ESHS Policy and ESMS. Further, to effectively implement this ESHS policy, the company will put in place an ESMS for the operation of the project, as indicated under ESAP # 1, which will include: (a) aspect, impact and risk identification; compliance with regulatory requirements; (b) E&S organization, responsibility and resource allocation; training and awareness; (c) management programs, including standard operating procedures (SOPs) for managing EHSS risks and impacts from construction (renovation and refurbishment), operation and maintenance (O&M) activities; (d) incident and accident handling, recording, reporting, investigation and analysis; (e) E&S performance monitoring, recording, reporting and documentation of E&S performance; audit of the ESMS; management review; (f) onsite emergency preparedness and response (EPR) framework; (g) contractor ESHS management and oversight procedure for construction/ refurbishment/ renovation and operations stage activities; (h) Vendor/ supplier code of conduct and a supply chain management (SCM) procedure; and (j) a stakeholder engagement plan including an external grievance redress procedure.

Risk assessment: Typical office space leased for operations in different countries is voluntary (lease/license agreement) for a duration of 12-60 months. The leasing of office assets is undertaken through a process of identification and management of E&S risks and impacts, which is aligned with the regulatory requirements pertaining to operating office spaces. The screening checklist for leasing new offices includes aspects such as building completion certificate, planning permit, mandatory licenses such as lift license, diesel generator (DG) license, diesel storage license, fire license, etc., Chief Electrical Inspector to the Government of State (CEIG) certification and approval from distribution company for grid connectivity (in cases of net metering and gross metering), pollution control board certification, building insurance, compliance to National Building Code (NBC) norms, compliance to statutory & local bylaws, nature of land holding. In terms of fire safety, the screening checklist captures compliance as per the latest National Building Code (NBC) norms, number of fire exits, fire-rated door provided for the fire exit, fire hydrants availability at the floor level, capacity of fire Sump, fire alarms (including smoke detectors, public address system, sprinklers, building management systems) provision for common areas.

In future, in case DNEG choses to acquire assets, it will use the updated E&S screening criteria to be developed as part of proposed ESMS and undertake third-party E&S due diligence (ESDD) including life & fire safety risk assessment to identify gaps against local regulatory requirements including IFC PSs and develop and implement corrective action plan to address these gaps, if any.

Organizational Capacity: The company’s facility management team is currently responsible for ESHS aspects with support from HR, administration, legal and procurement. DNEG will, as part of ESAP # 2, employ appropriately qualified ESHS officer at corporate level. Additionally, as part of the ESMS development, DNEG will put in place an appropriate E&S organization structure for both construction/ refurbishment/ renovation and operation phases comprised of technically qualified, experienced and dedicated ESHS officer.

Management program: DNEG’s facilities team is responsible for operations and obtaining the required permits for which DNEG’s legal team provides support on a need basis. Most of the operations such as housekeeping, electro- mechanical maintenance, security, are subcontracted either through Annual Maintenance Contract (AMC) contracts (ventilation, AC maintenance, temperature and cooling, electrical devices maintenance etc.) or contract for service agreement with third party contractors (e.g., housekeeping, security, pest control etc.). The facility management team has developed standard operating procedure (SOPs) for cafeteria management, physical access, transport facility, travel, security services, housekeeping, solid waste (paper and kitchen waste), maintenance of key utilities (DG set, transformer, UPS, pumps, water chillers, AC unit, electric panels etc.).

Emergency Preparedness: The company has in place an EPR for each of its offices and their implementation is regularly monitored by the facilities team. As part of ESMS (ESAP#1), the company will develop a framework EPR to be used by the respective offices for developing site-specific EPR for upcoming offices.

Reporting & Monitoring: The facilities management team at different office facilities undertake monthly internal monitoring and regular spot checks of the vendors’ performance and in general E&S performance of the facilities. The company has a monthly and annual reporting system for the senior management, to provide updates on the most recent achievements and challenges faced, from a sustainability viewpoint. Compliance forms the basis for all decisions and ensures the company’s actions remain sustainable. 

 As of December 2022, the company employs 9405 people (1740 female and 7665 male), which includes around 13% contracted employees (mostly outside India) usually under long term contracts (over 1 year). The company also has third-party workers engaged through manpower agencies and service contracts of technical, security, and housekeeping services for their sites. There are approximately 350 third-party employees across India operations. The overall female representation in the Company’s offices in India is around 12%, while in other countries it is around 32%. India operations also have 23 trainees (19 Male and 4 female). The Human Resource (HR) department at DNEG has around 164 people (including 95 in India). The HR team is headed by the global HR head and supported by country-level HR managers, business partners, or supervisors for local country offices.

HR policies: Each DNEG operation has a set of HR policies and procedures that set out its approach to managing all types of employees (permanent, consultant, free-lance, fixed-term, etc.) including expatriates in line with the host country’s requirements. DNEG partners with third-party consultants in new countries (where it wants to expand operations), to ensure compliance with local HR regulations. HR policies and procedures are communicated to all company employees during onboarding and posted in the company intranet portal. HR policies include the job description, skills and abilities required for various positions within the company.

Terms of employment: The company’s primary documents regulating labor-related issues include the Employee Code of Conduct, country specific policies/procedures/guidelines and individual employment contracts or letters of appointment. The Code of Conduct outlines the company's commitment to ensure all employees carry out their duties and responsibilities to the highest personal and corporate integrity standards and within the framework of applicable laws and regulations.

Worker protection: DNEG operations do not involve child labour or forced labour, and the company has signed modern slavery statement as per UK Modern Slavery Act 2015. The company as part of HR policy and procedures update will include clear policies on engaging child or forced labour.

Non-Discrimination: Non-discrimination and equal opportunities provisions are broadly covered in the HR policies of all operations.  Globally, DNEG is either a member or has partnered and/ or continues to support multiple organizations (details available at https://www.dneg.com/equity-diversity-and-inclusion/) working on promoting diversity and inclusion in the VFX sector such as ACCESS:VFX, Animated Women UK, The Animation & VFX Alliance of British Columbia, Academy Software Foundation, Lean In, ScreenSkills, Tech + People Network (TAP), Visual Effects Society (VES), Women in Animation (WIA), Women In Leadership Foundation (WIL) etc. DNEG has also been undertaking DNEG’s UK Pay Gap Reporting since 2017 (most recent report available at, https://www.dneg.com/wp-content/uploads/2022/04/Pay_Gap_Report_2021.pdf); though this is limited to UK operations currently. Gradually, the company is working on replicating a series of locally-led programmes to a structured global programme. As part of ESAP # 3, the company will articulate these practices in global non-discrimination policy, and subsequently implement it across all its operations.

Grievance Mechanism: DNEG has an internal grievance mechanism which will be updated as per IFC's PS2 (refer ESAP#3) to (a) clearly define the principles of anti-retaliation and identity protection; (b) include multiple grievance intake points to raise and address allegations anonymously, if complainants prefer; and (c) provision of grievance committee. While some of the operations have a sexual harassment policy incorporated in the local HR policies and procedures, other locations have policies such as bullying and harassment policy. As part of the corporate HR policy update (ESAP#3), the company will develop policies prohibiting gender-based violence and harassment (GBVH).

As part of ESAP #3, DNEG will review and update, existing HR policies across countries to develop overarching corporate level HR policy and procedures aligned with the IFC PS 2 requirements including policies and procedures concerning freedom of association and collective bargaining (in line with the local regulations), workers’ grievance mechanism, child labor, forced labor, retrenchment policy (to include aspects such as commitment to conduct alternative analysis, and that retrenchment would be considered as the last resort or consultation with trade union, if available), non-discrimination, GBVH policy etc. The corporate HR Policies and procedures will broadly capture country specific legal requirements for specific country of operations. Subsequently, DNEG operations in different countries will update the existing HR policies as per corporate HR policies and also meeting applicable local legal requirements.

Occupational Health & Safety (OHS) Management: The company through the third-party contractor (integrated facility management contractor) undertakes air quality monitoring and auditing in working areas (personnel) and operating areas (data centre) for temperature, relative humidity, and particulate matter. In addition, antimicrobial treatment for life escalators, meeting room disinfection etc. are also undertaken by the contractor for all premises.   Fire, emergency, mock drill and basic first aid training is conducted every six months. The company has had zero fatalities over the last three years. As part of ESMS development (refer ESAP # 1), the company will develop the H&S manual to include detailed Hazard Identification and Risk Assessment (HIRA) for all the construction/ refurbishment/ renovation and operations activities (including office spaces, studios, data centre) including mitigation measures, legal register, H&S governance and implementation team (as part of facilities management team) SOPs and associated formats for key OHS hazards and risks and documentation formats to support a safe working environment.

Third party workers: In relation to third party workers, the company ensures that the third parties who engage these workers are reputable and legitimate enterprises and have appropriate systems in place to manage working conditions in line with local regulations. The labour compliances for the third-party workers are articulated in the service contract agreement. As part of the ESMS development (refer ESAP #1), DNEG will consolidate its existing contractor management practices and develop an overarching contractor management system including (but not limited to): identify all compliance requirements under the national labor and employment laws and PS2 covering its third party workers including on terms of employment, minimum age, non-discrimination and equal opportunity, freedom of association, worker accommodation (if any), occupational health and safety; grievance mechanism; etc. and implement procedures (including ongoing monitoring) while ensuring that O&M contract documents include appropriate E&S provisions  to demonstrate compliance with the national laws, PS 2 requirements.

Supply chain: DNEG uses a wide range of suppliers in all locations that supply facilities, training and hardware. The majority of supply chain is focused on utilities, hardware and software purchasing. DNEG Modern slavery statement mentions company’s commitment to continuously improving its practices to identify and eliminate any slavery and human trafficking in its business and supply chains, and to act ethically and with integrity in all its business relationships. In relation to supply chains, as part of corporate level ESMS, (refer ESAP # 1) the company will develop: (a) a Supplier Code of Conduct that covers labor and working conditions, including child and forced labor, freedom of association, non-discrimination, and grievance redressal mechanism; and (b) a supply chain management (SCM) procedure that incorporate the elements of policy and procedures, supply chain mapping, risk assessment and management, corrective measures, training, monitoring, and reporting. The SCM procedure will have provision for supply chain audit of the suppliers, to assess and document risks and impacts especially covering child labor, forced labor and OHS issues at these 3rd party facilities. 

 Resource Efficiency: DNEG operations consumes resources such as electricity, fossil fuel (diesel for backup generators) and water (for domestic needs). Company collects resource consumption data for electricity and diesel for all the office locations. DNEG sources electricity from grid and (for India operations). The company includes annual energy audit (and recommendations for optimization) as part of scope of integrated facility management contractor covering the key areas of energy consumption such as utilities, HVAC and lighting.

GHG Emissions: As per company’s data, for India operations, in FY21-22 its Scope1 emissions (from usage of Diesel) totaled to 43 tCO2e per annum. The company continuously undertakes energy efficiency management including the following initiatives: (a) open access solar power agreement; (b) change of high power consumption equipment like modular air conditioner (AC) and non-AC  and change of ductable/ split AC to multi-split type air conditioner; (c) timely reading of power consumption and floor temperature to ensure efficient temperature control in office areas; (d) installation of light-emitting diode (LED) lights; (e) services contract of AC to ensure optimum power consumption; (f) integrating design efficiency and energy efficiency criteria for procurement of hardware; and (g) procurement and integration of highly efficient hardware, and devices that consume less energy per unit bandwidth.

Pollution prevention: In terms of pollution prevention, Company’s facilities/ offices are connected to the main sewerage system operated and managed by the local authorities/ municipal bodies. The company's operations do not generate significant air emissions. Diesel Generator (DG) set stack monitoring is under the responsibility of the business facility operators. At company operated sites, DNEG regularly monitors the air and noise emissions from its owned sites with the help of third party authorized vendors as per permit conditions. All the DG sets installed have noise attenuators installed. Domestic sewage treated water is discharged into municipal sewerage system.

Wastes: The company generates domestic municipal solid waste, recyclables, e-wastes (such as used electronic equipment, cables, old computers) and hazardous wastes (such as used batteries and used oil) which are managed and disposed in compliance with local regulations. Accordingly, it disposes of the non-hazardous solid waste from its offices and other owned assets through the local municipalities or recyclers/scrap dealers, as per the local regulatory requirements. Electronic waste (e-waste) generated from the operations and are recycled through authorized recyclers, recycling companies and buy back agreements with original equipment manufacturers (OEMs). The company will document updated waste management procedure as part of ESMS development (ESAP#1). Hazardous materials use both during construction and operational phases is very limited. The company handles and stores diesel for the backup power generation. DG set maintenance is undertaken by a third-party vendor, who are responsible for ensuring fuel spill control kits at all diesel storage locations. The company as part of ESMS development (ESAP#1) will include a chemicals management policy and start ensuring secondary containment (up to 110% of tank capacity) at all the sites with DG set operations. The company will update the ESMS manual to clearly document the existing practices related to DG set operations, diesel storage, spill management procedures etc. Pest control operations in office areas, studios are undertaken by licensed pest control specialist operating in the country who comply to local regulations.

 Infrastructure & Equipment Design & Safety: The company has developed a Standard Operating Procedure (SOP) for security and fire evacuation plan for studios owned (and rented to third parties) which includes details on emergency layout, emergency contacts, details of fire-fighting system, roles and responsibility (during normal operations and emergency). Studio are designed and developed by competent engineers, certified by independent civil engineers, and approved by regulatory authorities. The studios include hoists, cranes, temporary steel/other material structures which need to be tested, certified and verified periodically by appropriate structural engineers. There have been no reported incidents in these studios in the last 5 years. During the renting of the studios, the third party (e.g., production house) are expected to ensure that all the requisite safety measures and precautionary measures including but not limited to fire extinguishers, trained personnel and presence of a medical practitioner on set is arranged by the production house or the third party, as applicable, at all times during the shoot.

For existing Studios at Goregaon, as per ESAP # 4, DNEG will engage a competent L&FS professional acceptable to IFC to conduct a risk-based L&FS review (operational and under construction) as per IFC General EHS guideline requirements.  Findings of the review will be used to set a time-bound action plan, if needed, to be implemented by DNEG, and also to introduce systematic improvements on L&FS management at the company level. Further, as per ESAP # 5, the company will, based on the third party L&FS review and review of the existing L&FS practices, develop a set of corporate L&FS documentation including: L&FS management systems complete with L&FS Policy; risk & impact Assessment Procedures; L&FS management procedures; L&FS organisation; L&FS infrastructure for permanent (office), semi-permanent (Studios set for 6-12 months use or more) and temporary spaces (studio set for less than 6 months use), ERP comprising of mock and fire drills, use of construction materials that do not emit obnoxious gaseous emissions when it catches fire, and ensure that DNEG maintains and manages L&FS related records for sites at the corporate level.

Security Personnel: Facilities team is responsible for ensuring security for the offices and studios. Security services cover two key areas, viz. risk management and loss prevention. DNEG has a centralized contract with a third-party vendor responsible for providing security services at all its premises in India. Effectively all DNEG assets and locations are secured through licensed, unarmed, private security service vendors.

The company’s interaction with the communities and other stakeholders is pretty limited. Most of the engagements revolve around negotiations with building owners (on terms of the lease agreement). Aside from the above, there is no active engagement or consultation with the broader community. DNEG engages with the regulators on compliances as well as meeting the local requirements. Company’ engagement also includes partnership and membership of various foundations, associations, etc. As part of ESAP #1, DNEG will develop a stakeholder engagement plan (SEP), to apply to the entire company, including (i) stakeholder identification, analysis, and planning, (ii) disclosure and dissemination of information, (iii) development of an effective neighborhood community grievance mechanism, and (iv) ongoing reporting to affected communities and stakeholders, in a manner aligned with IFC PS1 requirements).

DNEG has an active Corporate Social responsibility (CSR) program aligned to its sustainability commitments. Management.    

  The company will locally disclose the social and environmental information for the project at the following locations: Any queries and/or comments about the project may be directed to: