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 Management Systems: TRIL is managing the processing zone area and IHCL is managing the hotel facility in non-processing zone. Both companies have established and maintain an Environmental and Social Management Systems (ESMS) and their ESG policies, ESG strategy and ESMS elements are aligned to IFC PS requirements.
Identification of risks and impacts: In compliance to local environment impact assessment (EIA) regulations, TRIL had prepared the environmental impact assessment (EIA) study and obtained environmental clearance (EC) from State Environment Impact Assessment Authority (SEIAA) in April 2009. Later in November 2013, TRIL modified the Ramanujan Intellion Park development plan into two zones – a) SEZ Processing zone comprising of 6 IT Park Building Blocks A to F and one Utility Block, and b) non-processing zone comprising of 112 serviced apartments and one conventional center. Both zones cumulatively added to a total built up area of 665,940 sqm. Based on the amended development plan, TRIL re-applied to SEIAA seeking amendment in EC in Nov 2013. An updated EIA Report was submitted to the regulator in Jan 2021 and an amended EC was issued for Ramanujan Intellion Park development in September 2021.
(Refer:https://environmentclearance.nic.in/TrackState_proposal.aspx?type=EC&status=EC_new&statename=Tamil%20Nadu&pno=SIA/TN/MIS/60318/2018&pid=162662 which includes EIA as attachment).
Management Programs: Both TRIL and IHCL have implemented environment, health and safety (EHS) management plans and programs in the form of documented operational procedures, practices, plans, manuals, audit checklists and training management systems. TRIL has published its ESG Goals 2025 in its ESG Report (https://media.intellion.in/wp-content/uploads/2023/07/ESG_report_FY_2023-Intellion_Offices-by_TATA-Realty.pdf) and the key goals include: increase in renewable energy (RE) usage; zero complaints related to Human Rights issues; and 100% employees trained on Tata code of conduct and prevention of sexual harassment (POSH) policies annually.
E&S Organisation: TRILs Facility Operations Head is responsible for managing environment, sustainability, health & safety, and security aspects while human resources (HR) function is managed by a dedicated administration and HR department staff. The facility management services are managed by a primary Facility Management Contractor who has engaged multiple sub-vendors for managing various functions such as electrical, mechanical, plumbing, housekeeping, pollution & waste management, carpentry, security, gardening etc. The operational team of Facility Management Contractor and its sub-vendors includes a dedicated L&FS management team. As for Taj Hotel facility in non-processing zone, IHCL has instituted an organization of E&S relevant departments such as engineering, /facility management, security and L&FS management that are managed by Corporate Head; Area Director in Country sub-regions; and the facility level team comprising of engineers, technicians and safety & fire safety trained staff with experience in Hotel industry facility management services.
Emergency Response Plan: TRIL and IHCL have established and maintains a documented management program to manage emergency situations in collaboration with appropriate and relevant third parties. The emergency scenarios include natural disasters (seismic and flooding risk), bomb threats, security & terrorist attacks, life & fire safety events, medical emergencies, and events in the basement parking floors especially for women safety etc. Appropriate L&FS infrastructure has been designed, constructed, and maintained as per Indian National Building Code (NBC) and US National Fire Protection Association (NFPA) standards. More details on L&FS risk management provisions and procedures are presented under PS4.
Monitoring and Reporting: Ramanujan Intellion Park has established procedures to monitor, audit, report and review the effectiveness of its management programs, E&S performance as well as compliance with E&S related permit/consent and clearance conditions. Both TRIL and IHCL publish the annual sustainability reports (Refer: https://media.intellion.in/wp-content/uploads/2023/07/ESG_report_FY_2023-Intellion_Offices-by_TATA-Realty.pdf and https://www.ihcltata.com/responsibility/)
PS2: Labor and Working Conditions
TRIL has a team of 12 direct, on-roll, management cadre staff (including three female staff). Its facility management contractor has a team of 26 staff whereas the sub-vendors have deployed a team of around 460 workers. TRIL follows the Tata Group HR policies and procedures that are compliant to local regulations and IFC PS 2 requirements. For managing the hotel facility, Ramanujan Intellion Park has collaborated with Taj Hotel (part of IHCL) to operate the hotel (serviced apartments) that is fully managed by women staff. Taj Hotel/IHCL human resource management policies and procedures are aligned to local regulations and IFC PS 2 requirements. Taj Hotel facility employs 110 on-roll staff (70% are women) and 80 contracted staff (50% women) through three service contractors for proving specific services such as housekeeping (outside and public areas); security and kitchen stewardship (kitchen cleaning and washing).
Employees, including the facility management and sub vendor workers, are provided with employment letters that states the working conditions and terms of employment. The terms and conditions include the terms of minimum wages, weekly off, overtime limits and payments, leave policies etc. All the policies and procedures of TRIL and IHCL are available online for the respective staff to access on the intranet applications and dedicated HR Management Portal. For all staff of TRIL, an online learning management systems portal - Tata Realty E Knowledge Studio (TReKS) is also available.
At Ramanujan Intellion Park including the hotel facility, there are no labor unions operational. According to the senior management, in line with Indian legislations, TRIL and IHCL policies do not prohibit or restrict workers freedom to associate. TRIL and IHCL follows the Tata group commitment in providing equal opportunities in employment and creating an inclusive work environment which are documented in Tata Code of Conduct and presented in more details at: https://www.tata.com/careers/equal-opportunity-statement. Under the human rights aspect, Tata code articulates clearly states that all facilities must not employ children at the workplaces and do not use forced labour in any form. TaTa Group Code of Conduct (https://www.tata.com/about-us/tata-code-of-conduct) is applied at Ramanujan Intellion Park operations and it is enforced on the contractors and sub-contractor teams as well.
Grievance mechanism procedures are in place for TRIL, Taj Hotels, facility management contractor and sub-contractor staff at their respective facility management human resource management team and all the staff and workers at Ramanujan Intellion Park are mandatorily trained and made aware of POSH policy regulations in place at all the facilities in the campus. As part of women safety in the IT Park campus, emergency (SOS) alarms have been installed at many locations, especially in basement floors and isolated locations, in periodic intervals. Women travelling in the night after 8PM are provided with company vehicle whose drivers are trained on POSH and GBVH aspects. In the hotel, no women contract staff are engaged in the night duty.
TRIL and IHCL has instituted a documented occupational health and safety management systems and both TRIL and IHCL report zero accidents or incidents in the zones managed by them within Ramanujan Intellion Park campus.
Workers engaged by Third Party: Ramanujan Intellion Park operations are largely managed by TRILs primary facility management contractor and its 1sub-vendors while IHCL also engages three sub-contractors in the hotel facility. At Ramanujan Intellion Park, facility management contractor is contractually obliged to comply with local labor regulations, TRILs HR policies and procedures, enforce the HR policies on its sub-vendors/supply chain and demonstrate compliance through independent verification of HR compliance. As part of the contract, Ramanujan Intellion Park HR Management has engaged an independent labor auditor who does monthly statutory audit to verify labor law compliance with regards to minimum wages, working hours, overtime periods and payments, payment of due social benefits, leaves and weekly off etc.
Supply Chain: TRIL has implemented its responsible supply chain policies and procedures that align to PS2 requirements. In the hotel facility, the vendor selection, evaluation, performance audits are undertaken by Hotel Management and the Tata Ethics Code is enforced through contractual and annual performance review mechanism.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: Ramanujan Intellion Park purchases power from 3rd party renewable energy (RE) developers and each building has roof top solar power plant installed for a cumulative capacity of 583 kW which generates RE power of about 80,000 units per month (which is about 2% of the demand). In total RITC sources ~70% of total power requirement from Wind and Solar power generation projects.
Taj Hotel sources 85% of its electricity demand from wind energy projects (renewable component) and 15% from public utility. Taj Hotel facility has resource efficiency (water, power, waste) key performance indicators defined, monitored, reviewed and reported as per hotel industry norms with respect to number of guest room nights occupied or floor area in sqm.
GHG Emissions: As per ESG Report for FY22-23, the GHG emissions are far below 25,000 ton carbon dioxide equivalent per year (tCO2e/year).
Water consumption: Ramanujan Intellion Park is recycling its entire treated wastewater and providing fresh water through municipal supply and private water tankers. Ramanujan Intellion Park has implemented rainwater and storm water harvesting systems as well as ground water recharge pits and has been harvesting rainwater for domestic use. Taj Hotel facility provides freshwater through water tanker supplies and by municipal utility. To improve water conservation practices, hotel management has undertaken water audit in 2023 and its recommendations are being implemented.
Air Pollution: Except for diesel generator (DG) sets, there are no other air pollution source at project asset. All DG sets in the campus have been provided with adequate stack heights and wet scrubbers. Emission monitoring indicate compliance to permit conditions and emission guidelines recommended for small combustion facilities in WBGs General EHS guidelines (Refer to Table 1.1.2 - Small Combustion Facilities Emissions Guidelines (3MWth – 50MWth), WBG General EHS Guidelines).
Wastewater: Project asset has installed zero liquid discharge (ZLD) based sewage treatment plant (STP) with advanced, tertiary treatment systems including a Membrane Bio Reactor (MBR). Ramanujan Intellion Park recycles and reuses the entire treated wastewater in sanitary flushing, cooling tower make-up, green belt development and gardening. The hotel facility also has installed and operating a STP using sequential batch reactor (SBR) and ultra filtration system to achieve ZLD. Treated water from STP is used in cooling tower make-up, DG set wet scrubbers, and green belt development.
Wastes: In line with both TRIL and IHCLs waste management policies and ESG strategies, project asset segregates its waste into hazardous, non-hazardous recyclables, organic municipal solid wastes, e-wastes, battery wastes etc. Waste management procedure for each type of segregated waste has been formulated and implemented and all the wastes generated are either recycled, reused through authorized recyclers. The asset has implemented a zero waste to landfill policy. Ramanujan Intellion Park converts the entire organic wet waste into compost manure that is consumed internally.
Hazardous materials: Ramanujan Intellion Park has storage for 460KL of diesel and 1000 kg of LPG Gas. The dedicated gas banks are equipped with gas leak sensor, sensor activated alarm systems, and automatic fire extinguisher systems. The diesel is stored in a double walled (outer concrete and inner non-corrosive steel) underground tank that is periodically checked for leakages and seepages through the fuel level meter. Pest control services is managed by licensed 3rd party agencies and all the pest control chemicals are approved by housekeeping department which does not allow any unauthorized use of pesticides and chemicals that are not approved by local regulations.
PS4: Community Health, Safety and Security
There are no nearby neighborhood residential area surrounding project asset. Stability Of buildings and structure are assessed and independently verified once in 5 years. Multiple industrial equipment’s such as: roof mounted, monorail jib crane system for glass façade cleaning; lifts; escalators; and other lifting tools and tackles are maintained through annual maintenance contracts with original equipment manufacturers. All electro-mechanical equipment testing inventory is maintained along with their testing schedule. TRIL/ Ramanujan Intellion Park also undertakes mid life assessment of asset quality to verify the age, integrity, effectiveness of the assets and replacement strategy.
Project asset campus has four entry and exit gates that are designed to avoid traffic impacts on the local road network. The gates and local access road have adequate space allocated for pedestrian walking and vehicle movement. The utility and service gate for water and fuel tankers and other heavy vehicles are managed for smooth traffic flow during peak office hours. Three levels of parking below grade and two levels of parking above grade (lower and upper stilt level) are provided in each IT Park Building to take care of the parking numbers. No parking in the open and or outside the IT Park campus is permitted.
Life and Fire Safety (LFS) Management: LFS infrastructure and systems meets Indian National Building Code (NBC) and US NFPA requirements (specifically structural design meets US NFPA Standards). Campus area has been segregated into fire zoning with each zone having multiple fire exits. Adequate number of safe assembly points are defined. Fire hydrant systems, comprising of raw water reservoir (both on ground and roof top), fire pumping system, fire hydrant pipelines/vertical risers in and around the buildings, sprinklers and smoke detectors are provided.
The operational team of facility management contractor and its sub-vendors include a dedicated life and fire safety management team under a Fire Safety Manager, Shift Fire Supervisors, Building Fire wardens and fire guards. To ensure that tenants/ occupiers comply with TRILs health and safety and fire safety standards, TRIL conducts regular (quarterly and annual) fire drills and mock demonstrations. The annual fire drills involve the entire Ramanujan Intellion Park and includes government fire service authorities who conduct the session. Additionally, TRIL/ Ramanujan Intellion Park educates the occupiers on mandatory guidelines and house rules for ensuring seamless and efficient fit outs, moving in, and commencing operations. At the hotel facility, mock drills and fire drills including night-time drills are conducted once in a month by Hotel security and LFS management team. There has been no minor or major fire accident at Ramanujan Intellion Park since its inception in 2011.
Security Personnel: About 180 unarmed security personnel (including 20 female security guards) have been deployed at Ramanujan Intellion Park campus through third party security vendors authorized by government. In the hotel facility, authorized security contractor has deployed about 25 security guards under the Facility Security Manager and the team is also trained and made responsible for life & fire safety management. Ramanujan Intellion Park operations team briefs security personnel about policies on child labour and provides training on basic safety, first-aid, fire safety and emergency response. Ramanujan Intellion Park reports no security incident in the past involving security guards, tenants, tenant staff and local community members.
