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.
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Policy and Management System. Transvolt has developed the Environmental and Social Management System (ESMS) manual that complies with national regulatory requirements and partially aligns with IFC Performance Standards. This ESMS is applied to all its business operations and contracts, subsidiaries, special purpose companies, and new asset acquisitions and mergers. Transvolt is in the process of obtaining accreditation for ISO 14001 and 45001 certifications and will ensure that the EMS and OHSMS developed as part of the ISO certification align with IFC requirements. Its ESMS articulates a policy commitment to social responsibility regarding stakeholder engagement, a grievance redressal mechanism, gender equality and inclusion, and employee health and safety. Transvolt has developed documented manuals, operational procedures, training management systems, reporting templates, checklists, audit procedures, and monitoring and reporting mechanisms for internal and external stakeholders Transvolt is in the process of developing digital technologies for management systems for acquisitions, operations, maintenance, safety, and compliance for Mira Bhayander, which is being developed as a model bus-depot subproject and will be replicated at all other contracts and subprojects. The ESMS is in the process of being operationalized at all the operational contracts/sites. Transvolt will incorporate the essential components of ESMS into its operations to ensure effective implementation. This includes developing performance indicators, defining resources and responsibilities, and making certain that the ESMS requirements are included in the O&M contracts. Going forward, ESMS is expected to evolve further with the scaling up and extension of Transvolt's business footprints as new types of contracts and business models are added to the portfolio. As ESAP #1 Transvolt will operationalize the ESMS at all the operational sites immediately and, going forward, upgrade and strengthen its ESMS as needed to address the E&S risks and impacts associated with the various types of contracts and business models, including the yet-to-be-covered ETS and e-trucking and urban shuttle services. The company will formally adopt the ESMS at the corporate level, and training will be provided to all staff.
Transvolt will add E&S criteria to its existing process for the evaluation and selection of O&M Contractors that also outlines the due diligence of the contractor’s track record and practices on the labor and working conditions, code of conduct and E&S requirements for the O&M Contractors, E&S contractual provisions, and E&S performance monitoring and reporting mechanism aligned to IFC PS, and the company’s ESMS. The company will develop and implement the contractor management and monitoring procedure to verify and ensure compliance of the contractors with the legal requirements, and the company’s ESMS. Further, Transvolt will strengthen the O&M contracts by integrating E&S contractual provisions that will include (i) the contractor's commitment to comply with the applicable regulations, IFC PS, company’s ESMS, KPIs, E&S management plan, and E&S action plan, (ii) provision of adequate E&S resources for the contract, (iii) monitoring and reporting of E&S performance, (iv) penalties and incentive for E&S performance and (v) implementation of corrective action plans. (ESAP #1)
The review of Transvolt's ESDD reveals that legal compliance with licenses, registration, and NOCs needs to be more consistent across contracts. As part of the ESMS, the company will establish a legal compliance tracker/register at the corporate level to monitor compliance with EHS and labor law requirements for SPVs and contracts across the sites and determine the party responsible for compliance under the contract. It will undertake periodic legal compliance audits of operational sites and depots and secure all the licenses required for the operations under the applicable law. (ESAP #2).
Impact Identification and Assessment. Transvolt has undertaken an Environmental and Social Impact Assessment (ESIA) of the Mira Bhayander Bus Depot in the Mumbai Metropolitan Region (MMR) as required by their ESMS. The bus depots in Transvolt, including the Mira Bhayander depot, are brownfield depots for the charging, maintenance, and parking of buses that do not require a regulatory Environmental Impact Assessment (EIA). Transvolt shall update its ESMS manual in terms of ESDD and ESIA requirements and risk assessment tools to identify risks and impacts in operations on an ongoing basis in all types of contracts, including e-trucking. Going forward and as part of the ESMS, the company will a) undertake the E&S Due Diligence (ESDD) for all new contracts or company acquisitions (both fresh bids/contracts and operational contracts) that will include the E&S audit for the brownfield maintenance depot, b) commensurate ESIA/ for the greenfield depot; c) a third-party labor compliance audit (for operational contracts), and d) OEM supply chain risk assessment against PS2, and physical risk assessment of the depot sites. The company will categorize the new contract acquisitions and associated bus depots based on E&S risks and prepare and implement a time-bound corrective action plans so as to align with IFC Performance Standards and WBG General EHS Guidelines. The company has conducted ESDD for existing GCC and ETS contracts, and will implement the Corrective Action Plans so as to align in a time bound manner as agreed with IFC and submitted the closure report satisfactory to IFC. (ESAP #1). Transvolt will conduct its due diligence prior to taking over sites on concessions and prepare an action plan. This action plan should be duly communicated to the authorities before implementation.
Organizational Capacity and Competencies. Transvolt is a new company; however, its organizational structure consists of a seasoned team of industry experts overseeing its operations and includes a sponsor-level ESG advisor and a senior management-level resource for Safety, Training, and Compliance to design the ESMS and safety system for the company’s EV operations. The company has strengthened its capacity recently by hiring a senior Human Resource (HR) Head and Industrial Relations (IR) resource at the corporate level. At the operational level, a cluster-level EHS resource is hired for Mira-Bhayander and Ulhasnagar. The company is in the process of deploying site/cluster level capacity at ETS and e-trucking contracts. Transvolt will appoint a dedicated senior-level EHS resource to roll out ESMS implementation across the contracts and ESAP compliance. The company will establish an EHS organizational structure with dedicated resources for EHS management across the operations, ESG committee at the Board level supported by the executive Steering Committee The company will train the employees, including drivers and O&M contractors, on the E&S policies and procedures that apply to their work areas. (ESAP # 3)
Emergency Preparedness and Response. As a part of ESMS, Transvolt has developed a standard Emergency Preparedness and Response (EPR) plan that identifies emergency situations, roles and responsibilities, directions for required responses to manage such situations, requirements of periodic drills, training, tie-ups with hospitals, and ambulance services. This standard EPR plan will be tailored for each depot or project. Transvolt is upgrading the EPR plan for Mira Bhayander (Mira Bhayander is a shared facility with a diesel bus operator) in consultation with the diesel bus operator and the government authority. The Mira-Bhayander depot has been found to comply with fire safety standards outlined in the National Building Code 2016. The fire system at the other locations is basic and consists of only the fire extinguishers. The EV buses under GCC contracts have been observed to be equipped with fire extinguishers, a first aid box, a panic button, and emergency exits. The drivers are trained in first aid applications. Transvolt will develop the site-specific onsite and offsite emergency preparedness and response plans to comply with ESMS through a collaborative process with local government agencies and key stakeholders for each contract and associated depots to adequately address accidents and emergencies that may harm people or the environment before handing over the operations to the O&M operator. (ESAP #1)
Monitoring and Review. The company is not required to undertake any E&S information disclosures for regulators. The authorities are responsible for filing annual reports under the regulatory permit requirements for the establishment and operations of bus depots. As a part of the ESMS manual, Transvolt has developed the monitoring and review procedure that involves identifying key performance indicators, monitoring programs, EHS inspections, internal and external audits, and internal and external reporting. Company ESMS is in the process of being implemented, and company will start monitoring its E&S performance for all operational contracts.
Transvolt will annually audit the effectiveness of its ESMS implementation through independent third-party auditors for the first five years following commitment (ESAP #1). After that, it will periodically review and upgrade its ESMS as needed through an independent agency every 3 years. It will identify key performance indicators based on the IFC PS and the company’s ESMS and integrate the monitoring and reporting program into its digital platform to assess E&S compliance and track E&S performance indicators against the IFC PS and the company’s ESMS. It will establish a procedure for regularly setting and updating the E&S targets to ensure continuous improvement and will report the E&S performance to senior management and the Board of Directors of the company.
PS 2: Labor and Working Conditions
Workforce and Working Conditions. Currently, Transvolt has 237 direct employees spread across the SPVs located across different cities. This includes 15 female employees. Roughly 55% of the total workers are drivers, referred to as ‘pilots’ in Transvolt. With the expansion of projects, Transvolt foresees this number to be growing significantly in the next few years. Further, there are indirect workers hired through contractors for security, housekeeping, maintenance, vehicle washing, and tyre-repair. Depending on the feasibility and model for the respective project, Transvolt would hire drivers through external contractor/s.
Human Resource (HR) Policies and Procedures. Transvolt has developed human resource policies covering child labor, forced labor, HSE, equal opportunity, wages and working hours, recruitment, leave, bonus freedom of association, retrenchment, grievances, and other relevant topics. The company has also developed a ‘code of ethics’ that lays down principles on bribery, corruption, conflicts of interest, gifts, and political contributions. Furthermore, a Transvolt employee handbook has been developed, which includes HR policies and procedures on the code of conduct for employees, the code of ethics, the anti-bribery and corruption policy, the prevention of sexual harassment in the workplace, the health, safety, and environmental (HSE) policy, and the whistleblower policy. These HR policies are established at the corporate level and applicable to the staff on Transvolt’s payroll. These policies broadly align with the legal provisions and with IFC Performance Standards. From this larger set of policies, the relevant ones will be applicable for the indirect (outsourced) workers, while some specific areas such as recruitment & separation, terms of employment, wages & benefits etc. will be governed by the respective contractor/s. Transvolt will ensure that these policies are aligned with the applicable laws.
The recruitment process includes a thorough screening of documents, interviews, driving tests, medical fitness tests, police verification and then successful candidates are issued formal employment letters, followed by induction, relevant trainings, issuance of uniform & PPEs. The terms & conditions in the currently issued employment letters will be upgraded in accordance with the company’s latest HR policies and with applicable labor laws. Transvolt will also ensure that the workers hired by the contractors continue to receive their employment letters from their respective employers and that their terms & conditions comply with applicable statutory requirements and are aligned to TV’s policies. (ESAP #4)
Transvolt has developed an overtime policy in line with the permissible legal limits. The policy shall be effectively implemented across the projects and ensure that any worker (direct & indirect) does not work for more than the allowed overtime hours... Transvolt will update the policy to include the relevant provisions related to compensation and working hours of drivers. (ESAP#4) Transvolt will regularly monitor the implementation of the working hours policy for all the projects and contractors.
Transvolt has developed a policy prohibiting child and forced labor and will ensure that the policy is implemented across its operations. The HR policy and the company ESMS will have SOPs to check and ensure zero tolerance for any incidence of child labor and forced labor. (ESAP#4).
Freedom of Association: . The company has developed a corporate level policy on Freedom of Association and shall allow workers to associate and unionize without any threats of retaliation. No recognized workers’ union exists at Transvolt SPVs. Consultations with workers/employees indicated that there has been no attempt from any worker towards unionization.
Retrenchment. The contractual nature of the bus service business makes the sector prone to retrenchment upon termination and expiration of the contract. The company has developed a formal, documented retrenchment policy. The policy states a six step procedure to be adopted in an event of collective retrenchment including consultation, communication, early information, support offered, severance package, review and appeal and responsibilities. The policy covers the basic aspect of a possible retrenchment. In case, there is an actual need for collective dismissal of employees/workers, Transvolt will prior inform IFC with full details of any significant retrenchment in the future, along with a specific plan & support for affected employees.
Non-discrimination and Equal Opportunities: Transvolt as a company prohibits any kind of discrimination amongst its employees, contractors and vendors. This is covered in various forms in the different HR policies on ‘Diversity and Inclusion policy’, ‘Recruitment policy’, ‘Fair and Equal pay policy’.
Grievance Mechanism. The company has established a Grievance Policy that defines a 5-step procedure for reporting and handling of any grievance. Workers awareness about this policy & procedure was noted to be low during the consultations. Further, the company is in process of implementing anonymous grievance reporting in the system. Transvolt has a three-member POSH committee at the corporate level including an independent member. The company will constitute POSH committees and respective SPVs aligning with the requirements.
The company will upgrade its grievance mechanism, establishing two tiers: one at the depot and the other at the corporate level, accessible to all employees, including third-party contract employees. Additionally, it will place suggestion boxes, display boards, and help desks in suitable locations within the depot for employees. The GRM will be included in the induction training of drivers and staff. The company will create awareness of the grievance procedure and the channels/platforms available for engagement. (ESAP #1 )
Occupation Health and Safety. As part of the ESMS manual, the company is in the process of developing standard operating procedures for hazard analysis, job safety analysis, battery maintenance, electrical safety, first aid, personal protective equipment (PPE), incident management, and safety training. Additionally, a driver training simulator has been installed at the Mira-Bhayander depot to train drivers in defensive driving. The company has also established a separate PPE policy for maintenance workers. The company needs to enforce the use of PPE among maintenance workers more rigorously. Furthermore, the company should consider extending the PPE policy to drivers by providing face masks and eyeglasses to safeguard their health.
During the site visits, some construction activities were observed to be undertaken. On an ongoing basis, Transvolt would be required to implement additional safe practices and usage of PPEs as required. Transvolt will ensure that the construction contractor follows the safety standards and executes the construction work with utmost safety and best practices on Environment, Health & Safety and align with E&S management plan for the site. (ESAP # 1, # 2 ). As specified under PS3 section (ESAP #6), Transvolt will construct and provide required amenities and facilities (rest areas, canteen, toilets, training rooms etc.) under the applicable laws for the benefit of drivers and workers.
The company has implemented an incident management system to record accident and incident information, as well as conduct root cause analysis. The OEM is responsible for accident investigation and determining corrective and preventive actions. , No fatalities, lost-time injuries, or fire incidents have occurred in depots or on buses were reported. The company shall develop the format for the Annual Safety Report, which is part of its contractual obligation to be submitted to the authority. Transvolt will ensure the buses and the depot facility comply with safety requirements. The company’s ESMS will include climate-responsive Occupational Health and Safety (OHS) management procedures to mitigate the risks of increased temperatures and heat waves on workers’ health and safety, especially for drivers. The OHS procedures will encompass adequate safety resources, safety committees at the corporate and depot levels, OHS training, provision of PPE, provision of safety functional equipment on buses, regular monitoring, incident management, and OHS performance monitoring (ESAP # 1).
Supply Chain: The project entails an EV bus supply chain, with OEMs constituting the primary suppliers, batteries as tier-2 suppliers, and cells as tier-3 suppliers. Transvolt will be sourcing more than 1000 buses over the next two years directly from OEMs based in India. The LFP chemistry batteries used in the EV buses are assembled in India, with cells imported from China.
Transvolt, being OEM agnostic, will be exposed to different OEMs. The OEM has visibility up to the cell suppliers and manufacturers. During the contract period, the OEMs are and will be responsible for maintaining the EV vehicles, including battery replacement.
Although, in most cases, OEMs may have their own systems in place to manage supply chain risks, As per ESAP #5, the company will (i) evaluate its EV OEMs’ supply chain management systems as a part of its due diligence process and compile information on the OEMs' supply chain practices; (ii) share its supplier code of conduct so that OEMs can align their practices with the code´s requirements, and (iii) monitor the alignment of OEMs’ practices with the supplier code of conduct as a part of its ongoing compliance monitoring activities. Going forward, the company will adopt an approach to procure EVs from OEMs that meet its code of conduct requirements (ESAP #5).
Third-party workers: Transvolt hires indirect workers through contractors in support functions of security, housekeeping, maintenance etc. Transvolt has further plans to outsource O&M operations to external contractor/s across the projects and SPVs. Besides these, the drivers in non-GCC contracts will be also outsourced through contractor/s. Transvolt needs to improve compliance management of these workers with regard to their documentation and practices. As a principal employer, Transvolt will have legal obligations to ensure that all statutory compliance is fulfilled by the respective contractors. In order to ensure full compliance with the regulatory requirements and IFC PS2, Transvolt will develop a Contractor Management System as a part of their ESMS and take requisite measures to ensure adherence to all applicable statutory requirements by the contractors. Transvolt shall contractually oblige the contractor/s to comply with requirements and maintain adequate documentation. Further, Transvolt shall develop systems and mechanisms as a part of contractor management plan applicable to all contractor across the projects. Contractor workers shall have fair access to all necessary infrastructure and grievance mechanism. (ESAP #1). Transvolt will maintain oversight and undertake periodic internal audits to monitor compliance and develop/implement any corrective actions as needed.
For an effective monitoring and improved compliances, Transvolt will undertake independent third-party labor compliance audits for three consecutive years on an annual basis, covering all the functional projects and all workers (both direct and indirect). (ESAP 2)
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. The water is required for bus washing and domestic purposes, which will be provided by the government authorities or counterparties or required to be arranged by the asset SPV as the case may be. The company will implement a system for monitoring water consumption.
Greenhouse Gas (GHG) Emissions. The company’s current portfolio is entirely based on the EV fleet. GHG emissions are expected from using electricity to charge batteries. The company uses electricity from the grid and has yet to integrate the RE source into its energy mix.
Bus Depot Infrastructure and Pollution Control: The primary air emission sources include the DG set. Fugitive dust is expected from the movement of buses at the depot. Wastewater is generated from vehicle washing. It has been observed that the obligations of depot construction vary across different contracts. While Mira Bhayander depot (shared with the diesel bus operator) is the built depot provided by the government authority, the depot at Ulhasnagar, dedicated to the EV GCC contract, is being constructed by the government authority and will be handed over to Transvolt for operation and maintenance upon completion. The obligation to build a depot for the new GCC contract at Nagpur and e-trucking contracts is with Transvolt. The assessment of depots and infrastructure facilities under various contracts reveals that infrastructure, facilities, and amenities needed for the depot operations needs to be upgraded, such as stormwater drainages, inadequate toilets, and an ETP facility where a wet washing facility for buses is proposed. Transvolt will establish minimum standards for the depots regarding infrastructure, amenities, and facilities that comply with applicable laws and good international industry practices. Going forward, Transvolt will assess the depots and their plans against these minimum standards and engage and collaborate with the counterparties during planning and execution to ensure adherence to these standards. Transvolt will develop and implement the action plan (including the timelines and budgets) for the improvement of operational depots conforming to the requirements under applicable law to meet the minimum requirements commensurate to the degree of control and influence. (ESAP # 6)
Hazardous Waste: The authority manages the ETP sludge generated at Mira Bhayander in accordance with the consent conditions. For other locations, the company will manage waste aligned with applicable laws, WBG General EHS guidelines and, the company’s ESMS manual.
Battery Waste Management: The AMC agreement with the OEM covers replacement, buy-back, and battery waste management responsibilities. The OEM is responsible for Extended Producer Responsibility obligations for EVs from FY 2027-28 under the Battery Waste Management Rule 2022. The company shall ensure that the OEMs have Extended Producer Responsibility registration for the lithium-ion batteries used in the electric bus.
PS 4: Community Health, Safety, and Security
Community Health and Safety. The company has developed a screening procedure for drivers to ensure safety and compliance, Drivers are subjected to alcohol breath analysis before beginning their daily duties. The company will develop a comprehensive code of conduct for drivers, equipping them to handle conflict situations on the roads and in the buses. Transvolt is in the process of creating a digital incident reporting, recording, and management system.
EV public buses under GCC are equipped with security cameras, fire extinguishers, panic buttons, and emergency exits, all compliant with government contractual requirements, while passenger grievances are managed through government helpline numbers. The company will conduct reasonable background checks for drivers, provide training on POSH and GBV, and develop a passenger safety and protection policy with provisions for women and children, with detailed plans for specific sub-projects, if relevant.
The company will display its GM at prominent locations to facilitate collection of grievances. In addition, the company will establish a parking policy as part of its ESMS, addressing parking of ETS and other private contract buses and any community safety issues associated with it. (ESAP # 1)
Bus movement, noise, dust pollution, fire, or emergency incidents may impact the community around the bus depots. No incidents have been reported affecting the community so far. The company will prepare and implement a community health and safety plan for depots near residential areas, identifying community health and safety risks and issues, along with corresponding mitigation measures and a management plan; the stakeholder consultation process with the affected community; a formal GRM for receiving, recording, and responding to community complaints; communication of the relevant portion of the emergency response plan to the potentially affected community; and an organizational structure for community health and safety management. (ESAP # 1)
Life and Fire Safety (L&FS): The company has designed and instituted L&FS infrastructure at the Mira-Bhayander EV bus depot according to the Indian National Building and Fire Safety Code requirements applicable to industrial buildings and local fire safety regulations. The L&FS infrastructure includes a fire water reservoir, fire water pumping systems, perimeter and building-wise fire hydrant systems, smoke detectors and fire alarms in offices, fire signage, fire blankets and fire suits, common assembly points, fire manual call points, etc. The fire system at the other locations is basic and consists of only the fire extinguishers. Going forward, all new bus depots will comply with the National Building Code 2016 and NFPA standards (National Fire Protection Association) (ESAP # 6)
Security Personnel. Third-party unarmed security personnel are deployed at the depots. The security personnel are verified for their backgrounds through police verification certificates from security agencies. The company has yet to document a security management procedure. As part of ESMS, the company will develop and implement the security management procedure covering (i) security risk mapping, (ii) security arrangements and organizational structure for security management, (iii) selection of security agencies, (iv) selection and hiring processes of security personnel, (v) training requirements and processes for security personnel, (vi) scope of security services, (vii) code of conduct for security personnel, (viii) equipping security personnel, (ix) monitoring and management of security guards, (x) GRM for complaints against security personnel. (ESAP #1)
