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 Policies and Management Systems: BEPL has implemented HSE (Health, Safety, and Environment), Human Rights, and Biodiversity Policies at the corporate level.
BEPL has a Safety and Health Rules and Regulations, which define requirements for employees, contractors, sub-contractors, vendors, consultants, and visitors. The rules and regulations encompass various aspects, including the project's safety health and environment plan, as well as the contractor's safety committee. It also provides rules for legal compliance with applicable laws related to building construction, electrical installation, environmental management, and labour laws. The rules cover topics such as work method statements, work permits, safe working procedures, and demolition guidelines. It also includes guidelines for the inspection, testing, and certification of equipment and machinery, along with operator requirements and legal obligations. Additionally, noise, illumination, dust, and fumes related measures, health management and medical facility provisions are covered.
The proposed project requires several additional regulatory approvals in accordance with legal requirements and the Environmental Impact Assessment (EIA) for environmental clearance.
As per ESAP #1a and #1b, BEPL will conduct an Environmental and Social Impact Assessment study (ESIA) for the Thane and the second project in line with IFC PSs requirements, and the local regulations. The findings from the ESIA will be included to update the ESAP (if needed).
Identification of Risks and Impacts: The company has implemented a corporate Risk Management Policy that establishes principles for identifying and managing risks. This policy includes a system for overseeing risks, managing material business risks, and implementing internal controls and systems to mitigate these risks. Furthermore, at the corporate level, there is a Standard Operating Procedure (SOP) specifically addressing Hazard Identification and Risk Assessment for construction sites.
Management Programs: For each project, BEPL, in conjugation with the Project Management Consultancy (PMC) contractor, develops an Environmental, Health, and Safety (EHS) plan specifically tailored for project. The EHS plan includes provisions for the deployment and qualification of EHS personnel, with defined roles and responsibilities. It establishes a project EHS committee, outlining their objectives and functions. The plan also includes a dedicated safety budget for EHS activities and monitors compliance with all relevant legal requirements pertaining to waste management, noise control, water usage, and child labor, among others. Furthermore, the plan incorporates Hazard Identification and Risk Assessment procedures and control measures, as well as guidance on traffic management, fire safety at the construction site and labor camp, incident reporting and investigation protocols, and communication protocols. It also addresses labor camp management, covering design, approvals and administrative controls.
Organizational Capacity and Competency: At the corporate level, the ESG Assistant Vice President, who directly reports to the CEO, leads a team consisting of one ESG executive. The team also consists of The National Safety Head, dedicated BEPL site safety head for each site and regional safety managers. The construction safety manual provides specific guidelines regarding the required number of safety managers, safety officers, and safety stewards. It also outlines their respective roles, responsibilities, and the necessary competencies and qualifications for each role. Additionally, the PMC contractor has its own team of safety leads assigned to each construction site.
Emergency Preparedness and Response and Life and Fire Safety: The company has developed a corporate Emergency Response Plan (ERP) specifically designed for construction sites. This plan encompasses various components, including risk assessment, the formation of an Emergency Response Team (ERT), and defined roles and responsibilities for pre-emergency, during emergency, and post-emergency situations. Subsequently, each construction site develops a site-specific ERP in accordance with the corporate guidelines, project-specific requirements, and relevant legal guidelines.
BEPL has developed a Crisis Management Plan, which includes an Incident Command Structure at both the Head Office and project levels. The plan includes guidance for a coordinated response in the event of emergencies or unforeseen situations.
As per ESAP #2, BEPL will update its Emergency Preparedness and Response Plan (EPRP) to factor in climate-related events including heavy rains, flooding, landslide, and cyclone events.
Monitoring and Review: The construction project Key Performance Indicators (KPIs) encompass Occupational Health and Safety (OHS) aspects such as the lost time injury frequency rate, severity rate, number of injuries, and near misses. Additionally, environmental aspects such as energy consumption, water usage, and waste generation data are also considered. These KPIs are shared during monthly business reviews and are monitored and discussed by the Managing Director (MD) and Chief Executive Officer (CEO) with all stakeholders. The environmental, health and safety performance data is reported in the group's CTIL Sustainability report. [https://www.centurytextind.com/assets/pdf/integrated-report/2023-2024.pdf].
As per ESAP#3a, BEPL will establish a procedure to monitor Environmental, Health, and Safety (EHS) compliance on the construction site. This will include reviewing EHS training attendance records, conducting safety awareness sessions for workers, and ensuring contractors' compliance with BEPL's Safety and Health Rules and Regulations. As per ESAP #3b, BEPL will develop an internal monitoring mechanism to review compliance with its labor requirements. This will include the development of a system for conducting sample interviews of workers at the construction site by a member of BEPL's safety/compliance team. It will also involve reviewing and cross-checking third-party records, vendor records, and obtaining confirmation from relevant labor. As per ESAP#3c, BEPL will engage an external consultant to conduct a third-party labor and EHS audit. This audit will also cover the labor camp and will be used to update the internal monitoring mechanism. The audit will be conducted in accordance with local regulations and will align with the International Finance Corporation (IFC) Performance Standards (PSs) and World Bank Group (WBG) EHS guidelines.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures: BEPL has implemented several HR policies designed for its direct employees. These policies include: i) whistleblower policy, ii) prevention of sexual harassment (POSH) policy, iii) reward and recognition policy, iv) employee wellness policies, v) leave policy, vi) maternity and paternity policy, vii) travel policy, and viii) flexi hours policy. These policies are accessible on the company portal and are shared with employees upon joining the organization. Regular training sessions are also conducted for employees to be well-informed about these policies. For contractors and subcontractors, the relevant policies are outlined in the BEPL Safety and Health Rules and Regulations.
Workers' Organization: Currently, there is no workers union in place at BEPL. According to BEPL's management, company does not restrict the formation of employee unions, as the labor laws of India guarantee the freedom of association.
At the site level, Contractor Safety Meetings and Joint Project Committee Meetings are conducted to facilitate discussions on monthly safety activities. These meetings also serve as a platform for communication and collaboration among project stakeholders.
Grievance Mechanism: The company has implemented a whistleblower policy that applies to both direct employees and third parties. This policy allows individuals to report concerns regarding potential violations of the company's code of conduct. At the construction site, laborers have the option to raise their grievances directly with the contractor supervisor or the security guards.
As per ESAP #4, BEPL will establish a procedure at the project site to allow anonymous grievances.
Occupational Health and Safety: BEPL has established a set of Health & Safety Guidelines and Contractual Safety Rules & Regulations. The site safety plan is developed in accordance with these guidelines, providing a comprehensive framework for safety management. Detailed Standard Operating Procedures (SOPs), guidelines, and site work instructions are provided, accompanied by checklists for inspections to maintain compliance. Approved contractors are required by contractual clauses, to align their Site Safety Plans with BEPL's safety requirements. Monthly Management Review Meetings (MRMs) are held at the Head Office, where safety statistics of all projects are discussed. Weekly monitoring involves Project Manager (PM) walk rounds, safety and progress meetings with stakeholders to monitor and review project safety, quality, and progress.
Workers Engaged by Third Party: Contractors are selected by the BEPL operations team, while sub-contractors are chosen directly by the contractors themselves. The contractor selection process includes pre-qualification parameters that assess execution capabilities, safety practices, and quality standards. The company is also in the process of developing environmental and social parameters to be included in the selection criteria.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: BEPL has adopted several measures in its existing projects for resource efficiency. These measures include organic waste composting, provisions for renewable energy, and the implementation of a sewage treatment plant (STP) for the treatment of domestic wastewater, which is then recycled for gardening and flushing purposes.Solar lighting in the open areas, provision of water efficient faucets, energy efficient lighting in each unit etc. Similar measures will be incorporated to the design of the project.
Green House Gas (GHG) Emission: The company conducts a life cycle assessment (LCA) of building materials, which involves reviewing the embodied carbon emissions during construction and operation phases.The estimated GHG emissions upon the completion of the Thane project, is expected to be significantly below 25,000ton carbon dioxide equivalent per year.
Ambient Air Quality: The stack emission maintenance and assessments are carried out bi-annually as per regulatory requirements at the site; where the monitoring data is inline with local regulations and WBG's relevant EHS Guidelines guidance values. These records are monitored and reviewed centrally at the Head Office by the ESG team.
Water and Wastewater: During the construction phase, water is sourced through tankers, and septic tanks are installed for onsite offices. After construction, before the developments are handed over to the owners, water supply is coordinated with local authorities. Typically, water is supplied by local government agencies and/or from on-site bore wells. BEPL also provides on-site water treatment, as required, to ensure that the water quality meets national acceptability standards. Wastewater generated during construction is treated using septic tanks.Existing and planned projects developed by BEPL include the installation of Sewage Treatment Plants (STPs) for the treatment of domestic wastewater. BEPL will monitor the quality of the effluents and ensure compliance with local requirements for the management of liquid effluents for each development.
Waste Management:Waste generated during the construction phase is meticulously managed through segregation and collection at the point of generation. Metal scrap is sold to local companies, while organic and domestic waste is collected by the municipality. Construction debris is temporarily stored at designated points and subsequently disposed of by authorized vendors.Once the projects become operational, domestic solid waste is segregated for further disposal by the municipal agency. Hazardous waste is limited to used oil from generators, both during the construction and operation phases. This waste is collected and disposed by authorized vendors in strict adherence to the regulations established by the local State Pollution Control Boards.
PS4: Community Health, Safety and Security
Transportation of Raw Material: Construction raw materials are transported by road and certain goods/products are transported by air/water. BEPL does not directly transport the materials, which is within contractor's scope; and the company does not own a truck fleet. The government regulations are referred in the contractor's works contract.
Life and Fire Safety (LFS): BEPL adheres to local legal requirements for the design, development, and construction of its housing projects. The housing projects are equipped with various fire safety measures, such as fire extinguishers, sprinkler systems, fire hose/reel systems, fire detectors and alarms, and emergency signage and lighting. During the construction phase, the responsibility for fire safety, including monthly inspections, maintenance activities, and mock drills, lies with the company's operations team; and during the final stages of construction this responsibility is transferred to the facilities management team.
As per ESAP #5a, BEPL will engage with an external life and fire safety consultant to review the structural and life fire safety requirements in the design against the national fire code and if needed, update the design to full fill the gap. As ESAP #5b, upon completion of the construction BEPL will engage with an external life and fire safety consultant to verify the design is implemented as planned.
Security Personnel: BEPL employs unarmed security guards from external security agencies. These security agencies conduct background verifications of guards and provide training on effectively interacting with construction workers and communicating with neighbouring communities.
