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 policy and management systems: Candi has a documented global environmental, social and governance (ESG) policy. For Candi India, a number of other policies have been developed including environmental, health and safety (EHS), child labor, and prevention of alcohol and drug use policies. Candi has a documented E&S management system (ESMS), which is commensurate to the risks and aligned with IFC PS1 requirements. Candi has developed standard operating procedures (SOPs) on housekeeping, waste management, material handling, working at height, hot work, working in remote locations, material handling and training management, aligned with WBG EHS Guidelines. For its operations in South Africa, separate environment, health and safety policies have been developed. The company also follows the Occupational, Health and Safety (OHS) procedures as per applicable legal requirements and an OHS file is developed with all procedures and checklists for each site (explained more in PS2). During the site visits in India and South Africa, implementation of policies and procedures on-site was noted to be adequate.
In addition to these policies and procedures, Candi has a documented supplier code of conduct and responsible sourcing visions (both described in PS2 in more detail).
E&S organization: Candi has a Global ESG Head, who is responsible for implementation of ESG policies and procedures for both India and South Africa. In addition, each country has a designated Environment, Health and Safety Manager who report to Country Lead as well as the ESG Head. In India, two assistant EHS managers have also been appointed and the operations in the country has been divided in two zones for EHS monitoring purposes. Additionally, the project development and asset management teams support in EHS management of projects at construction and operation stages, respectively.
Identification of E&S risks and impacts: Candi has the required E&S risk identification procedures in place. For its management systems, Candi has completed an environmental aspect-impact, hazard identification and risk assessment as well as a risk assessment with respect to IFC PSs 1 to 4. These risk assessments are used as the basis for development of procedures.
For any new project, prior to investment decisions, the project development team conducts a site visit which includes a technical review as well as review of basic EHS considerations for the site. Also, any new Engineering Procurement Construction (EPC) contractors are reviewed for their technical and E&S capabilities. The checklist for this review includes requirements on OHS capacity, OHS procedures, prior track record use of sub-contractors and supply chain for the solar modules.
Candi includes technical and non-technical conditions (which may also include safety conditions) for its clients in their proposals and signed contracts. Also, once the EPC is selected and contracted, they are expected to complete a job safety analysis for the site and implement various procedures developed by Candi on-site.
Recently, Candi has also worked on a ground mounted project in India. For such a project, in addition to the assessments conducted above, an E&S impact assessment (ESIA) and E&S management plan (ESMP) was noted to be completed. For any future ground mounted projects, Candi will ensure that the ESIA and ESMP are completed in line with IFC PSs and included with the regular monitoring reports submitted to IFC.
Monitoring and Review: In India, Candi’s EHS team conducts internal audits and inspections of a sample of sites within their zones. Also, audits are conducted through external agencies for a sample of the sites. In South Africa, similar inspections are conducted by the ESG lead and they are supplemented by the authority inspections as required under the legal requirements. Though the audits/inspections were noted to be conducted, there is no tracking of closure/resolution of identified improvement areas. Therefore, as per the ESAP(#), Candi will develop a monitoring mechanism (e.g. a tracker) to record any non-compliances identified in these audits and their resolution by the respective projects teams and EPC contractors.
Candi has defined ESG KPIs, which are regular monitored and reported (internally) for India and South Africa. Candi has an ESG Committee in place, which is chaired by the global ESG head and has senior management from HR, Finance, projects and asset management as the members. The committee also has representatives from some of the investors. A specific ESG committee charter has been developed which describes the governance processes of the committee. The committee meets on a quarterly basis and reviews ESG KPIs, progress on investors/lenders’ action plans as well as implementation of Candi’s ESG procedures.
Emergency Response Plan: As the projects are located within client rooftops/premises, Candi staff, EPC and O&M contractors are expected to comply with the emergency response plans of the clients. In addition, as part of its contractor requirements, Candi has developed an emergency response plan template, which the contractors are expected to use to develop a project-specific plan. Also, the contractors are expected to tie up with nearby hospitals for any emergencies. During the site visit, adequate fire safety equipment and emergency instructions were noted to be provided at the site.
PS2: Labor and Working Conditions
Candi has total 121 employees globally with majority (70) in India. 25% of the employees (globally) and 21% in India are females. The company has a Global Head of People and Culture (P&C). Each country – India and South Africa has a HR team, which reports to Global Head P&C as well as Managing Director of the country.
HR policy, working conditions and terms of employment: Candi has a global HR handbook, which describes company’s policies on basic operational matters (working hours, leave, other benefits), prevention of sexual harassment and grievance mechanism. Also, Candi has a code of conduct, which is signed by all employees, and includes Candi’s commitment to United Nations Global Compact (UNGC) Principles on human rights, labor, environment and anti-corruption. The company is also considering becoming a UNGC signatory.
The company has a self-service HR portal, which provides employee an access to the policies as well as grievance redressal form. HR conducts an onboarding session with the new employees and mandatory training are completed through tasks assigned in the self-service portal.
Non-discrimination: Candi has commitment to non-discrimination in its HR handbook. Also, the code of conduct has a specific commitment on the elimination of discrimination in respect of employment and occupation. Additionally, the Candi in India has developed an equal opportunities policy which focusses on promoting employment for people with disabilities.
Prevention of child and forced labor: In its code of conduct, Candi has committed to elimination of all forms of forced and compulsory labor as well as child labor. Also, Candi in India has a specific child and forced labor policy. During the site visits, no instances of child labor were noted.
Freedom of association: Through its code of conduct, Candi has committed to freedom of association and the right to collective bargaining. Currently, there is no union at Candi.
Grievance mechanism: A documented grievance mechanism is in place and is described in the HR handbook. As per the process, employees are encouraged to have a dialogue with line manager or country lead. In case of no resolution, employees can fill up a grievance form through the HR self-service portal. However, the mechanism does not include provisions of anonymous filing (or keeping the identity of the aggrieved employee confidential) and prevention of retaliation as required under PS2. Therefore, as per the ESAP(#), Candi will need to review and modify the grievance mechanism to include these provisions.
Gender and gender based violences and harassment (GBVH) policies: Candi has committed to increase female employees in its workforce. Also, some of the investors have provided technical assistance to Candi on gender inclusion and an action plan has been agreed under this project. Candi monitors gender disaggregated HR key performance indicators for its employees, which are reported to investors/lenders on a quarterly basis.
Candi has a policy on sexual harassment, abuse and workplace discrimination in the HR handbook. The policy makes commitment to no gender-based sexual harassment or discrimination in the workplace. Employees are encouraged to report any such cases to the local HR representatives OR escalate through an anonymous feedback form through the HR self-service portal, which is received by one of the founders.
In addition to the global policy, the countries can develop their own policy on prevention of sexual harassment (POSH) as per legal requirements. In India, a POSH policy has been developed and an internal complaints committee (ICC) has been formed (with an external members) in line with legal requirements. ICC members have received training on POSH by an external agency. Also, Candi provides regular training to employees, team leaders and managers on POSH. There is a dedicate email ID for reporting any cases of sexual harassment and abuse.
Occupational health and safety (OHS) and third-party workers: The main OHS risks are related to construction and installation operations, which are outsourced to EPC contractors. Typically, the construction and installation timelines are 3-4 months or less.
Candi conducts a review of any new EPC contractors are reviewed for their technical, OHS and supply chain capabilities. The checklist for this review includes requirements on OHS capacity, OHS procedures, prior track record of use of sub-contractors and supply chain for the solar modules. All contractors are expected to sign the code of conduct, which includes requirements on fair working conditions (working hours, compensation), child and forced labor, freedom of association, environment protection and OHS.
In India, EPCs are expected to follow the EPC Partner Guidelines, which explain Candi’s contracting processes in detail and include various documents that the contractors are expected to follow including a detailed OHS package with all SOPs, checklists, reporting formats and emergency response plan. Candi also has specific reporting requirements for its contractors including reporting of accidents, incidents and near-misses. As per the data available, there have been no serious incidents and accidents at Candi’s projects. Only one lost time incident has been reported in the past 2 years.
In South Africa, as required under legal requirements, each site prepares a project OHS documentation file which includes:
- Details of the project
- Candi’s policies (environment, OHS, evacuation, substance abuse
- Licenses of the contractors
- OHS provisions (e.g. induction, training, OHS representatives, fire-fighting equipment, emergency response, first-aid)
- SOPs and checklists (e.g. on roof work, scaffolding, ladders, night work, edge protection, electrical installation)
- Environmental restrictions and waste management
Similar procedures are followed for operation and maintenance (O&M) contractors (used mainly for cleaning of the panels). Candi’s ESG team conducts inspections during construction to ensure compliance with these procedures. Based on the site visits, the implementation of these procedures in both India and South Africa was considered to be adequate and no significant risks were identified. All sites had staircases or ladders for access. The rooftops were provided with safety lines to access all panels. Required personal protective equipment (PPE) like safety harnesses, safety vests and helmets were noted to be provided. Toolbox talks are conducted by the contractors. All visitors and new workers on-site are provided safety induction and required working-at-height training and medical checks are completed before providing access to the roof.
Supply Chain: Candi has developed a Responsible Sourcing Vision, which includes commitments to assess their supply chain for any harmful labor and inclusion of responsible sourcing in the supplier code of conduct. This assessment for solar suppliers is completed through review of publicly available information, any legal restrictions or requirements (e.g. in India) or through information available from industry association. Considering the size of Candi’s business, sourcing of panels being done by the EPC contractors and the size and capacity of EPC contractors, Candi’s (or the EPCs’) leverage is currently limited and therefore, Candi or the EPCs do not conduct any audits or assessments for the suppliers. Based on its desktop assessment, Candi has an approved vendors list for solar panels and the EPCs are required to only source from these suppliers.
As per the ESAP(#), Candi will (a) ensure its procurement policy and supplier code of conduct are aligned with IFC PSs, (b) strengthen the existing supply chain risk assessment to identify high-risk suppliers; and (c) develop a process to monitor and, if required, to audit identified high-risk batteries and solar PV suppliers. Further, contractual clauses will be established for all suppliers to reserve the right to disengage from suppliers found to be in breach of the code of conduct. For identified high-risk solar PV module suppliers, Candi will (i) maintain records related to these purchases and evidence of compliance with the code of conduct; and (ii) obtain representations that, to the best of their knowledge, they and their sub suppliers do not engage in unacceptable labor practices as per Candi´s responsible sourcing vision and code of conduct.
PS3: Resource Efficiency and Pollution Prevention
Candi’s operations are not energy or resource intensive. As the project will result in installation of more solar power generation capacity, the project will result in avoidance of 199,478 tCO2e/year of greenhouse gas (GHG) emissions by displacing grid generation with renewable energy generation.
Regarding environmental management of the site, in both India and South Africa, Candi has developed waste management policies/procedures, which are implemented by the contractors during construction. Also, Candi has signed agreements in India with an electronic waste management agency for disposal of broken/damaged solar panels. Similar agreement is in progress in South Africa.
Candi will ensure that the Diesel Generators financed under the project comply with emission limits specified in the World Bank Group EHS Guidelines.
In addition to the above procedures, for any future ground mounted projects, Candi will need to ensure that environmental management measures defined in the ESMP are implemented.
PS4: Community Health and Safety
Candi’s sub-projects are located within commercial and industrial premises of the clients, therefore, security of the site is managed by the clients. Considering the type of operations, Candi’s business activities are expected to have a limited impact on community health, safety, and security. Candi has an external grievance mechanism in place for any community complaints, which includes a contact email ID for filing grievances. The visited sites had contact details of all relevant site personnel displayed at the site.
