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 Management System: Mozark has several established policies relevant to its day-to-day operations, generally developed per the applicable local labor regulatory requirements and permits conditions. There is Mozark Global Environment, Health and Safety Policy that establishes EHS objective, risk management aspects, emergency preparedness and response and is aligned to IFC PS1. However, as per ESAP#1, Mozark shall update the Global EHS policy to include principles of green computing, and other industry good practices for SaaS companies. As part of the ESAP, the company shall also expand their environmental reporting (energy consumption, waste and water management) in all the countries of their operations.
Organizational Capacity and Competency: The CEO ensures that adequate resources are allocated for effective EHS management across all Mozark sites.
The EHS committee, led by the CEO's office, oversees policy implementation and performance evaluation. Local EHS officers are appointed at regional offices to ensure compliance with local regulations and global standards; there is one EHS officer for each of the following regions: India, APAC, US, and EU. The Head of Administration manages compliance with regulatory requirements for the offices (e.g., obtaining No Objection Certificates for fire safety from local fire departments). The HR team manages HR aspects in general. There are administration and HR teams located in India, the Middle East, and the USA. Mozark has approximately four HR members responsible for overseeing its HR practices.
EHS Monitoring and Review: The HR team is responsible for monitoring and internal reporting of HR related indicators. Key performance indicators (KPIs) are reported to senior management on a quarterly and annual basis and include HR-related information (e.g., recruitment and attrition, grievances), regular inspection of life and fire safety equipment and others associated with information security compliance (e.g., certifications status, data breach if any).
Emergency Preparedness and Responses: As Mozark's offices are in leased commercial buildings, emergency preparedness and fire safety are mainly the responsibility of building owners/lessors. Mozark, as per their policy, ensures with the lessor prior to occupying the real estate that the buildings are compliant with the national life & fire safety standards/codes. Mozark’s employees attend the fire drills and emergency response training conducted by the building owners.
Under ESAP #2, Mozark will maintain permits obtained by the building owners from local fire departments or building authorities, inspection records of fire safety equipment, and copies of the Emergency and Incident Response Plan. Records of Mozark employees participating in fire drills will be maintained and reports on drills and training will be shared with senior management as part of monitoring exercise. Additionally, fire marshals for each office space will be identified wherever possible, and their role would be to ensure participation of Mozark employees in the fire drills and training.
PS2: Labor and Working Conditions
As of November 2024, Mozark employs approximately 66 direct employees, which includes 11 females, and 36 contractual employees, which includes 3 females. Mozark operations team has support staff which sit out of the data center/regional offices and are primarily for customer support & resolutions. These employees and contractual staff are located in offices across India (Mumbai and Delhi), France (Paris), The Philippines (Manila), Singapore, and Malaysia.
HR Policies and Procedures: Mozark has documented HR policies and procedures, which are accessible via Mozark's intranet to all direct employees. The terms and conditions of employment, including working hours, salary, and benefits, are outlined in a written appointment letter given to each employee upon joining the company.
Human resource (HR) related policies include (but not be limited to): i) Anti- Bribery and Corruption Policy; ii) Anti-Harassment and Discrimination Policy; iii) Code of Conduct and Ethics Policy; iv) Whistleblower Policy; v) Leave; vi) Employee Grievance; vii) Separation; viii) Compensation and Benefits; ix) Conditions of Employment; x) Medical Benefits; xi) Performance Review; and xii) Training and Development. Through these policies, Mozark has committed to fair, healthy and safe labor and working conditions.
Given the nature of Mozark's business and its workforce, child labor or forced labor is not involved in its operations. The HR team verifies age documentation for new hires. Employees have not yet initiated any activities to form worker’s unions and associations.
As per ESAP #3 Mozark will update the global HR policy handbook to align with IFC Performance Standard 2 and ensure the incorporation of the global HR manual into country specific HR policies.
Non-discrimination and Equal Opportunity: Mozark has its Code of Conduct where it explicitly sets clauses committing to promoting and maintaining a culture of diversity and equal opportunity supported by ethical business practices and regulatory compliance. The Code commits that all decisions on recruitment, selection, compensation, development and promotion are made solely on the basis of a person's ability, quality of experience, behavior and work performance.
Grievance Mechanism: Mozark has a Grievance Redressal Policy that specifies the procedure for direct employees and contractors to raise grievances, as well as the management's procedure for resolving them. According to E&S Action Plan (ESAP) #4, Mozark will update its grievance mechanism in accordance with IFC Performance Standard (PS) 2 requirements to allow anonymous grievances through various channels (e.g., open door policy, intranet, suggestion box), in addition to email, and provide access to its internal grievance mechanism to all employees, including contractors and contractual employees. The updated GRM shall also provide an escalation matrix, and the company shall report the various types of grievances raised and its status.
Prevention of Sexual Harassment: Mozark has established a formal Policy on the Prevention of Sexual Harassment (POSH) under the Anti-Harassment policy within the Global HR policy framework. Additionally, for India, the POSH initiative compliant to Indian regulations has been implemented this year, with training sessions commencing in October 2024.
Retrenchment: Mozark has established a separation policy that addresses various types of separations, including: i) Voluntary; ii) Absconding cases; iii) Involuntary Separation. All separations are in accordance with the terms of employment or as permitted by law.
Occupational Health and Safety (OHS): No accidents, incidents, or injuries have been reported at the office premises in the past 3 years. As per ESAP#5, Mozark to conduct regular training on ergonomics and shall also undertake OHS assessment of the workers especially related to ergonomics and provide a mitigation plan.
Contractors: Mozark’s contractual terms are stipulated within the employment contract. Contractual employees are required to adhere to all IT (Information Technology) protocols, security measures, and confidentiality provisions as specified in their contract. Overtime compensation for contractual employees is calculated based on the number of hours worked, in accordance with the terms of the contract and local legal regulations.
Security Personnel: Unarmed security personnel are deployed at offices through authorized local security vendors. The security personnel are provided with training, which includes basic safety, first-aid, fire safety and emergency response.
