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
Environmental and Social Assessment and Management System.
Policy: The Project Company has adopted EDC’s overarching policy, which outlines its commitment to protecting the environment, supporting communities, identifying efficient solutions for water/energy use, continual improvement, identifying opportunities to minimize waste, maintaining ISO14001 (environmental management), and aiming to achieve EDGE certification (energy management). Moving forward, the Project Company will develop policies to meet IFC’s PSs, including PS2 requirements, including terms of employment, freedom of association, non-discrimination, fair treatment of migrant workers, proper management of worker accommodation, equal opportunity, zero tolerance for retaliation, and proper management of worker health and safety, and minimum labor standards for workers employed by third parties/contractors (ESAP#1) and polices related to other PSs requirements.
ESMS: EDC’s ESMS is appropriate to the scale and E&S risks and impacts of its operations and seeks to comply with local E&S requirements, including risk and impact identification, management programs and procedures, Emergency Preparedness and Response (EPR), monitoring and evaluation (continual improvement), organizational roles for implementation, training, and Stakeholder Engagement. The client has started preparatory activities to obtain certification for their operational sites for ISO 9001 (quality), ISO 41001 (facility management), ISO 14001, OHSAS 18001 (Occupational Health & Safety), ISO 27001 (information security), and ISO 45001 (Health & Safety).
Identification of Risks and Impacts: Based on Thailand’s Enhancement and Conservation of National Environmental Quality Act (NEQA) (1992), the project does not require an Environmental and Social Impact Assessment (ESIA). However, EDC conducted a site environmental baseline assessment to identify potential historical site contamination. In addition, EDC performed a Threat Vulnerability Risk Analysis (TVRA) to determine the security requirements for data center operations. For the construction phase, the contractor developed an Occupational Health and Safety (OHS) Hazards Identification and Risk Assessment Matrix, which lists all construction activities and their associated hazards.
E&S Management Programs: For the project construction, the contractor developed Construction Phase Environmental and Social Management Plans (CESMPs) to address issues identified by the baseline assessment, including hazard identification and risk assessment (HIRA), construction noise and dust suppression management, traffic management planning, waste and excavation management, occupational health and safety, worker accommodation, site security management, emergency preparedness and response, incident reporting, safety review, work permit system, spill control, etc.
These plans specify technical requirements and procedures for monitoring performance, including internal monitoring and reporting. Central Pattana developed social management plans and conducted stakeholder engagement activities. Going forward, the project will enhance existing E&S plans for construction through a Construction Oversight Management Plan (COMP), in line with IFC PSs and the WBG General EHS Guidelines. This plan will oversee contractor and subcontractor management, worker accommodation standards, transportation safety, visitors and community safety, internal and external grievance mechanisms, and stakeholder engagement throughout the construction of the project (ESAP#2).
Constructed DC will be leased out. The Project Company will develop plans and procedures for oversight management of asset maintenance activities, including E&S management such as HR management, OHS and grievance mechanisms, GBVH, Emergency Preparedness and Response for the asset management provider (ESAP#3) to align with national requirements and IFC’s PSs.
Organizational capacity: Construction E&S actions are implemented by the contractor’s team, led by foremen and safety personnel, with HSE support from the Project Company’s onsite Chief Technology Officer (CTO), cascading to the site-appointed Project Manager and Construction Manager, then supervisors. Central Pattana has a local team that manages social and community activities. The project utilizes a centralized performance tracking system to monitor progress and implementation, including E&S outcomes. Once the data center is constructed, a site management team will be formed to oversee the asset management provider. The Project Company will also assign or designate an E&S staff member to coordinate ESAP implementation and serve as the point of contact with IFC (ESAP#4).
Emergency Preparedness and Response: The construction contractor has developed and maintains EPR plans for fire, landslides, major injury, confined spaces, flooding, and utility loss. The project will comply with national fire regulations and EDC’s requirements for DC operations. The data center design includes active and passive fire suppression systems.
Monitoring and Reporting: The Project has a cascaded reporting system that allows issues from the data center to be escalated in a timely manner to the sponsor’s senior directors, enabling critical matters to be promptly addressed and resolved. Construction contractor prepares weekly progress reports which contain E&S and OHS information, and monthly construction progress reports. These reports are submitted to all parties including EDC and the Project Managers. A third- party provider conducts instrumental monitoring of the environment and produces monthly reports for EDC Thailand (see PS3 below). Moving forward, these reports will integrate key information from the COMP, covering the E&S performance of the construction contractor, subcontractors, and property management companies, with mitigation measures developed to address any shortfalls identified (ESAP#5).
PS2: Labor and Working Conditions
The company has a team of 10 technical experts in data center design, mechanical engineering, construction, and project management. The construction contractor mobilizes up to 40 staff, with staffing levels fluctuating by phase. During the completed excavation phase, the contractor deployed 40 supervisors led by a Project Manager and Construction Manager to oversee excavation activities conducted by 200 subcontractor workers. Currently, 10 supervisors oversee ongoing construction activities conducted by 80 subcontractor workers. Migrant workers from Myanmar and Cambodia are part of the workforce, managed by foremen from their respective countries.
Upon completion, facility maintenance will be outsourced to a specialized company, with total manpower of 38 staff for Phase I and an additional 26 staff for Phase II DC operations.
Human resources (HR) management: EDC provides HR policies and assists the Project Company with recruitment. Employment contracts are signed at the time of employment, defining job description, duration, working hours, salary and allowances, leave entitlements, welfare, probation and notice periods, and training.
Subcontractors, as local companies in Thailand, are responsible for their own labor management in line with labor laws and regulations but will be subject to oversight management plan requirements (ESAP#1). The Project will develop a centralized performance tracking system to evaluate contractors and subcontractor alignment with national labor laws and IFC’s PS2 requirements. This system will cover: 1) written employment contracts for all workers; 2) payroll slips with itemized wages, overtime, and benefits; 3) compliance with minimum age and wage requirements and effective screening procedures; 4) worker accommodation standards compliant with IFC/EBRD’s guidance; 5) effectiveness of Workers’ Grievance Mechanisms; 6) measures to prevent and address GBVH; and 7) no retention of passports or bonded labor among subcontractors (ESAP#6).
Worker’s organization: Although employees are not unionized, the Project Company does not discourage worker organizations or prohibit union membership. No unions are currently established among contractors or subcontractors. The grievance mechanism will be available to all workers, including those engaged by contractors and subcontractors (as per ESAP#6). The Project Company, construction contractor, and subcontractors will not discourage or prohibit the formation of a union should there be interest among the workforces (as per ESAP#1).
Protection of workforce: The minimum age for construction work under international standards and Thai labor laws is 18 years. Subcontractors are required to comply, hiring only those aged over 18. The COMP, in line with ESAP#6, will include procedures for age screening and prevention of forced labor among both employees and contract workers.
Occupational health and safety (OHS): On-site OHS is managed by the construction contractor. EDC requires compliance with specific HSE requirements, based on EDC’s OHS policy and HIRA principles in accordance with ISO 45001. Daily OHS training is provided through Toolbox Talks, reinforced by subcontractor foremen in workers’ native languages.
The contractor has Permit to Work requirements including Hot Work, Working at Heights, Confined Space, Electrical Work, Scaffolding, and Lifting. An incident recording system is established, with no lost time injuries (LTIs) reported since construction commenced in December 2024. The near-misses are duly recorded as unsafe actions and unsafe conditions. Going forward, the project will update its procedures to conduct incident investigation and account for incidents involving transportation, including transportation of people and materials to and from the site (ESAP#7).
Contractor and third-party employees: Construction involves one main contractor and multiple subcontractors. Contractors are selected based on past performance and quality. The company will use its centralized E&S performance tracking system to monitor ongoing compliance by contractors. As part of ESAP#1, a policy on minimum labor standards for third-party workers will be developed.
Migrant Workers: Construction subcontractors engage migrant workers. The company will use the centralized E&S tracking system to ensure migrant workers are employed according to regulations, possess valid work permits, receive regulated salaries and benefits and signed employment contracts, meet legal overtime requirements, are free to leave at any time, and receive all eligible benefits and insurance.
Worker accommodation: Subcontractors are responsible for labor management and worker accommodation. During excavation and structure works (foundation), a workers’ camp was established within the site and decommissioned after structure works concluded. In the current construction phase, workers commute between the site and their base camp in Chonburi Province. This base camp is not solely used for EDC Thailand project but by multiple construction subcontractors to supply workers to multiple other projects and construction sites in Thailand. As per ESAP#6, the Project will develop a worker accommodation standard in compliance with IFC/EBRD “Workers’ Accommodation: Processes and Standards”. The project will regularly inspect workers’ accommodation, enforce compliance with PS2 objectives and report to IFC.
PS3: Resource Efficiency and Pollution Prevention
During construction the project is generating emissions and waste typical to civil construction works including dust; concrete, steel, plastic waste; wastewater and stormwater; and noise emissions. During operations data centers have high electricity and water demand while direct emissions are primarily related to back-up diesel generators.
Resource Efficiency: Evolution DC implements a carbon footprint strategy which focuses on reducing power usage through efficient design, maximizing the use of renewables and offsetting the residual emissions through the renewable energy credits (RECs) and other carbon offset schemes. The Project is expected to be certified as a green data center by the IFC EDGE green building program.
The water required for the Project operations will be provided by the Metropolitan Waterworks Authority (MWA), a state water utility in Bangkok. The Phase 1 datacenter will utilize an air-cooled system which does not depend on water and is primarily reliant on electricity. Phase 2 will be liquid cooled facility and will require around 1,670 m3 per day.
The power for the project will be supplied by the Metropolitan Electricity Authority (MEA), a Thai state enterprise. The project will consume ~565,000 MWh annually at full capacity, while Phase 1 alone will consume around 158,000 MWh.
GHG Emissions: It is projected that under the business-as-usual scenario the annual emissions during operations stage (Phase 1 and Phase 2) considering 75 MW IT load may reach 364 ktCO2 in 2030 from Scope 1,2 &3 emissions. Evolution DC Thailand is actively looking to reduce its energy footprint as part of its sustainable commitments and for efficiency savings. Thus, they signed a Memorandum of Understanding with one of the Thailand’s renewable energy providers targeting 35% of energy to come from renewable energy. While the design for Phase 2 is still being finalized, Phase 1 will include 12 backup diesel generator sets with the capacity of 2 MW each, which will have emissions during the regular checks and maintenance and in cases of power outages. Evolution Thailand will monitor and report annual GHG emissions to IFC.
Pollution Control: For construction of Phase 1, the construction contractor developed a waste management policy which includes waste segregation, recycling and reuse, wastewater treatment and monitoring, dust and noise control measures. A third-party certified company conducts perimeter emissions monitoring of the total suspended particles (TSP) and PM-10, noise, vibration, and wastewater quality Based on the monthly environmental monitoring reports the measurements are in compliance with the national threshold limits. The contractor utilizes water spraying as a dust control measure and will install a soundproof sheet on exterior scaffolding during construction works at height.
During operations emission levels are expected to be in compliance with Thailand national standards and WBG EHS Guidelines. Evolution Thailand will develop construction environmental management plan for Phase 2 and operations environmental management and monitoring plan (EMMP) for Phase 1 and Phase 2 in line with the requirements of PSs and WBG EHS Guidelines. EMMP will describe management of waste (including e-waste and hazardous waste), pollution prevention including noise, vibration, air emissions and wastewater (ESAP #8). EMMP will also include requirements for tenants and the project company including training. Evolution will assess the feasibility of processing for end-of-life hardware in Thailand based on supporting mechanisms and based on such assessment will develop waste commitment targets. The spill prevention measures, including double-skinned diesel storage tanks, will be in place for fuel storage tanks required to operate diesel generators. A waste management provider will manage standard office and domestic waste.
PS4: Community Health, Safety & Security
Community Health and Safety: Although the project is located in an industrial area at the intersection of several roads, there are a residential community, an international school, and a mid-sized motel in immediate proximity to the site; remaining surrounding properties are industrial buildings. To monitor construction nuisances (dust, vibration, noise), monitoring equipment has been installed at key receptor points, and all recorded levels are within permitted limits. Machinery work is restricted to between 8:00 a.m. and 6:00 p.m., with no work on Sundays or public holidays to minimize disturbance. Traffic controllers are present at all times to regulate project-related traffic on the public road adjacent to the site.
Surveys have been conducted in local residential buildings before construction preparation, after excavation, and before construction began. The project site is fenced, but two access points remain unguarded. Access restrictions for authorized entries will be enforced to prevent residents, schoolchildren, and others from accidentally entering the site (ESAP#9).
Life and fire safety (L&FS): Fire hazard considerations are addressed through building specifications, distinguishing different areas. Smoke detectors, heat sensors, and gas suppression systems (nitrogen, argon, or a combination) are used to suppress fire without causing water damage; other areas use fire alarms, smoke detectors, sprinklers, and CO2 extinguishers. The Project Company is responsible for obtaining all fire safety permits before the DC is leased.
Security personnel: The company employs adequately trained, unarmed security guards at the construction site. Security services comply with Thai regulations and aim to ensure site safety, restricting access to authorized personnel only. Currently, three to four unarmed security personnel are stationed at the site and no confrontations with residents have occurred.
