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.
Policy: SAGT has a Health, Safety and Environment (HSE) Policy covering the HSE objectives, risk management aspects, compliance with the applicable laws and regulations, training, which is consistent with the principles of IFC’s Performance Standards (PSs).
Identification of Risks and Impacts: SAGT has Standard Operating Procedure (SOP) on risk assessment. The company has identified five fatal/ high risk activities as part of the HSE policy. The hazard risk associated with these high-risk activities and sub activities are identified as part of the individual departmental process. Activity owner conducts the risk assessment in coordination with the HSE department and contractor involved. The risk assessment is done through an online software customized for company operations rolled out since last year. As per the SOP, risk assessment (RAs), are conducted in order to identify and address potential hazards to personnel, property, environment, and Service loss, for: day to day operations; critical operations; new operations/tasks; unusual or non-routine jobs; work on critical equipment; changes to procedures or equipment; prior to the introduction of new critical equipment or procedures; for preparation of complex or special jobs; any operation which require deviation from procedures; and unplanned or unscheduled work. In addition, the company has a work permit system wherein the approval process flows to the head of the department (HoD), commissioning the activity for approval. Once approved, the work flow goes to the respective function and subsequently to the contractors who digitally request permits to work (PTW) followed by approval from the respective HoD, HSE department, Chief Executive Officer (CEO) based on risks and severity of the activity. The PTW are valid for a period of 24 hours to 7 days depending on the nature of the activities and are retained in the system for 3 years.
E&S Management System and Programs: SAGT’s existing HSE Management system primarily includes the key SOPs which has key elements in line with IFC PS requirements, and include standard operational procedures (SOPs), emergency preparedness and response framework, and training management systems etc.; however, the manual requires update to address gaps in the existing SOPs and associated work procedures against IFC PS requirements and findings of APMT annual audit of SAGT. Therefore, as part of ESAP#1, SAGT will consolidate, formalize, and make enhancements, as required to its existing HSE Management system to align the same with APMT standards, and applicable provisions of IFC PS requirements, WBG General EHS Guidelines, WBG EHS Guidelines for Ports, Harbors, and Terminals and GIIP. The HSE management system update will include an overarching manual that consolidates and formalizes existing elements including: E&S management program consolidating and establishing interlinkage of the existing and proposed SOPs and work procedure; EHS risk assessment process covering terminal activities including charging and associated infrastructure; provision for legal register (relating to HSE); EHS staffing and multiple existing EHS committees; training and capacity building of EHS and other staff including third party workers; and reporting, monitoring (internal and external), and management review. HSE management system will include SOPs update to cover aspects such as supplier/ vendor code of conduct; stakeholder engagement and external grievance mechanism (GM); security management plan; internal traffic management plan; waste management; resting area guidelines, and environmental monitoring. The HSE manual update will also factor in the corrective action items as an outcome of APMT annual audit. The SOP update will also focus on incident and accident handling, recording, reporting, investigation and analysis; onsite and offsite emergency preparedness and response (including for fire, spills and mishaps, accidental release of hazardous cargo, medical emergencies and exacerbation during natural hazards awareness including provision for emergency evacuation of all visitors to the terminal building.
EHS Organizational Capacity/Competency: SAGT has an eight-member HSE team including: the HSE head; two senior executives coordinating with the engineering and operations; two junior executives for maintaining HSE data including follows up with the departments and contractor management; and three paramedics, one for each shift. The HSE head reports to the Chief Executive Officer (CEO). The HSE team provides training on an ongoing basis including refresher training and has an established EHS training plan covering SOPs, fire safety, and emergency preparedness for direct staff as well as third party workers. The major contractors also appoint EHS supervisors in their teams. As per ESAP#2, SAGT will ensure adequate HSE resources to support effective implementation of its HSE Management System. This includes training direct and third-party workers, monitoring, root cause analysis, SOP and work procedure update and revision from time to time, addressing corrective actions identified through internal and external (APMT) EHS audits.
Monitoring & Reporting: APMT, which is a shareholder of SAGT, has been handholding SAGT to upgrade the HSE processes and system and undertakes annual HSE audits. HSE team (along with 1 senior management and 1 representative from each of the eight key departments) conducts bi-monthly management safety walks/inspection in the terminal. HSE team also conducts safety walks/inspections with the key department supervisors every two days. SAGT encourages active HSE participation of the employees through Acuizen application accessible to all employees and is used to upload photographs and voice messages upon noticing any safety violation at site The application is linked with a dashboard that keeps track of the various observations and status of the implementation of the corrective actions. The contractors too can independently upload any unsafe acts in the mobile application. APMT has a vessel safety application that is used by SAGT for vessel inspection. Weekly HSE meetings are conducted with the engineering and operations department where implementation status of APMT’s audit recommendations and other recommendations based on ongoing HSE observations are followed up. As part of ESAP#1, SAGT will strengthen its internal HSE monitoring system, The enhanced system will clearly define the frequency of internal monitoring activities, including review of HSE management system implementation, effectiveness of HSE SOPs, and progress on action plans developed through internal processes. It will also incorporate follow-up on findings from the annual APMT audits, particularly those highlighting gaps in material environmental events, lagging and leading indicators, continuous improvement measures, and management monitoring reports. The monitoring parameters shall include lost time incidents and related statistics, workplace conditions, training, solid and hazardous waste, recyclable waste, monitoring of battery health and batteries end of life management, resource use etc. SAGT As part of the annual sustainability reporting (available at: https://www.sagt.com.lk/about-us/sustainability.html) conducts third party assurance audits as per GRI requirements. The sustainability team collects information and data from the respective departments and reports to the senior management on a monthly and quarterly basis.
Management Review: All the observations are reported to the senior management on a regular basis, and the issues are discussed in the monthly OHS committee meeting (involving the departmental heads and HSE and headed by the CEO). In addition, the company has identified nine HSE KPIs (lagging and leading indicators) and the functional teams/departments discuss the lagging and leading indicators on a daily basis. These indicators are reviewed in monthly management committee meetings as well as in OHS committee meetings, both of which are chaired by the CEO who reports to the Board. SAGT’s HSE team also holds a weekly meeting with APMT’s global HSE team on the status of the implementation of the corrective actions based on annual audit findings.
PS2: Labor and Working Conditions
SAGT currently (as of November 2025) employs 688 direct employees (including 678 direct employees and around 10 contractual or project-based employees). The 678 employees include 178 executives and 500 non-executive staff. Female workers account for approximately 6 percent of the direct manpower. In addition, the company engages with multiple (around 40) contractors/service providers (mostly through contract for services) across all processes/verticals including security personnel, lashers, drivers, housekeeping etc., which includes around 800 third party workers. Terminal operations are undertaken on 24x7 hours basis in three shifts.
Human Resource Policies and Procedures: SAGT has formulated a code of business conduct and ethics for employees which among others include an anti-sexual harassment policy. Besides the code of conduct, attendance, whistleblowing & leave policy, aligned with national statutory requirements, have been developed and adopted. In addition to this, SAGT is in the process of further strengthening its HR policies and procedures. As part of ESAP#3, SAGT will update the existing HR manual in line with IFC PS 2 requirements and will include among others; collective bargaining and freedom of association provisions; updated grievance mechanism, updated policy against sexual harassment/gender-based violence and harassment (GBVH). The updated HR manual will be communicated to the employees and will provide training on working conditions and terms of employment as part of employee induction and refresher training from time to time.
Working Conditions and Terms of Employment: SAGT issues appointment letters to all its staff (executive and non-executive staff) which include aspects such as: wages and payments, working hours, rest periods and leave, benefits, overtime, and disciplinary procedures. In addition, the terms and condition of employment for the non- executive staff/ direct workmen of the company is guided by the collective bargaining agreement (CBA) between SAGT and the union. Third party workers’ terms of employment are guided by the contract agreement between the company and the contractors which are in line with the local regulations. In addition, depending upon the nature of the work at the terminal, specific wage board requirements are implemented by the contractors for different categories of the workforce. The terminal shifts are managed through a roaster which includes two-night shifts, two-day shifts followed by two days off for each worker and therefore, the weekly off days are flexible. Apart from the general shift, typically, a shift has 12 working hours including 6-8 hours of work, 1.5 hours of rest/meals/tea and 2.5 hours of overtime (which is paid as per the local regulations).
Non-discrimination and Equal Opportunity, Protection of Workforce: SAGT’s HR policy specifies provision for not employing children (workers less than 18 years of age) or forced labor in its existing operations and includes age verification process using government issued identity cards.
Grievance Mechanism: The company has a grievance mechanism (GM) for the employees which is also defined in the Collective Bargaining Agreement (CBA) with the employees’ union. The GM is communicated to the workers during induction training. Contract/ third party workers (in case of the large contractors) also have access to separate GM which is handled by their parent companies. Further, the whistle-blowing policy provides for both named and anonymous reporting, allowing employees to raise concerns confidentially and without fear of retaliation. The policy also provides access to an independent external Ombudsperson, ensuring impartial review of complaints. SAGT as part of (ESAP#3), will update its GM in line with PS2 provisions which will include: multiple grievance reporting channels including provision for anonymous reporting without reprisal threat, time bound redressal of grievances and maintain records. The company will also strengthen and enhance its procedures (including policy, grievance mechanism procedure) to specifically deal with sexual harassment and other GBVH cases. In addition, the policy against sexual harassment (refer ESAP#3), will be updated with further details on anti-sexual harassment committee roles and responsibility, training and awareness of workers and committee members, investigation procedure, survivor centric approach as part of the investigation and resolution of grievances.
Worker Rest Areas: SAGT has provision of rest areas for the permanent workers and a separate area for the Third party/contractor’s workers in the terminal areas. Basic facilities like beds, shower, toilets and washrooms, canteen and entertainment are provided for the workers.
Workers’ Organizations: SAGT currently has two active worker unions, out of which the recognized union (as per law) more than 40 percent direct worker membership. The union represents only the non-executive staffs/ direct workmen of the company; third party workers are not represented in the union. Members of the unions pay monthly membership fees deducted directly from the salary based on written consent from the members for such deduction. The active union has an annual election to choose the office bearers (executive committee members) through an Annual General Meeting (AGM). The union has a minimum of 4 formal meetings with the management in a year though informally they have a meeting almost on monthly basis. SAGT currently (effective since April 2025) has a CBA with the recognized union (for non-executive staff) valid for 3 years which includes wages, productivity-based incentive scheme and bonuses, work practices, leaves, medical benefits (both outdoor and indoor medical benefits), accidental and life insurances, disciplinary procedure and grievance mechanisms etc.
Third Party workers: Third party workers register attendance through electronic attendance installed by the contractor; however, some of the contractors do not have separate biometric attendance. The third-party workers also have their own workers union (in some cases), and if the union is active as per Sri Lankan laws, then they too have a CBA with their employer which includes clauses related to wages, bonus, scope and timings of works, leaves, insurances etc. The contractor contract with SAGT is typically for one year, which is renewed annually; accordingly, the third-party workers hired by the contractor usually have 1-year contract. These workers are provided with PPE and overalls, besides separate rest areas having basic facilities (toilets, wash and shower areas, beds, entertainment areas, locker rooms etc.). HSE training is expected to be provided by the contractors. The third-party workers have access to onsite medical facilities provided by SAGT in case of any emergency. SAGT currently has a limited contractor oversight which is managed by the respective operational team. The contractors provide evidence of compliance with minimum payment of wages and EPF to the workers. As part of ESAP#3, SAGT will update the existing Contractor HSE Management System to include provision for obtaining an annual written confirmation from contractors providing labour and/or engaging workers for SAGT operations regarding their compliance with applicable labour laws and relevant IFC PS2 requirement, including wages and OHS. In addition, SAGT will review the contractor’s policies and procedures and existing systems in place to assess how effectively the contractual requirements related to labour and working conditions, OHS etc. are implemented. Contractors will be required to provide copies of such policies, which SAGT will retain in its records. Contractors will also be required to provide annual written confirmation on whether such policies are implemented, monitored, and corrective actions from such monitoring are implemented in a time-bound manner. Where gaps are identified, SAGT will address them through routine contractor meetings and require corrective actions to be implemented in a time bound manner and track the completion of corrective actions as part of internal monitoring. In addition, SAGT’s contracts with their contractors will include requirements for them to provide functional and accessible grievance mechanism (including grievances related to sexual harassment and GBVH).
Occupational, Health and Safety (OHS): SAGT has an established OHS system and procedures in place coordinated by the EHS team, which is currently being upgraded in line with APMT standards. SAGT has identified 5 fatal hazards that represent the greatest potential for fatal injuries and their sub activities and have subsequently identified the risks associated with these. The existing SOPs are developed primarily to address these identified risks. Regular OHS training and emergency responses are delivered and will be further continued in accordance with the PS-compliant HSE Management system. SAGT as part of ESAP#1 will ensure that the OHS SOP is updated in compliance with national law/standards, any IFC PSs requirements, and applicable and relevant section of the WBG General EHS Guidelines and WBG EHS Guidelines for Ports, Harbors, and Terminals.
PS 3: Resources Efficiency and Pollution Prevention
Resource Efficiency: The electricity intensity factor of the STS cranes improved by around 8 percent in FY24 due to reduced machine idle time and higher operational throughput even though with increased container volume. The optimized deployment of the existing five twin-lift cranes and planning has resulted in enhanced energy efficiency. The procurement of the new 4 twin lift STS cranes and 30 electric prime movers is expected to further improve energy efficiency.
GHG Emissions: The Project introduces energy efficient, grid-powered cranes and, if procured, electric prime movers that will reduce emissions by about 235 tCO2e per year. Twin lifts cranes allow the same number of containers to be moved with fewer crane moves, compared to the single lift cranes ensuring reduced energy consumption and reduced emissions.
Water consumption: Water for domestic use is sourced through pipes and provided by the National Water Supply and Drainage Board. Water consumption is measured mainly through water flow meters or through estimates based on pump operating time. In 2024/25, SAGT withdrew 52,488 m3 of water from the National Water Supply and Drainage Board (NWSDB), representing a 26% reduction from the previous year. This decrease is primarily due to the identification and repair of water leaks. SAGT ensures water consumption reduction through ongoing identification and repair of water leaks and dissemination of water conservation awareness programs. Plans are afoot to reuse approximately 60 m3 brown water post treatment in the service area and toilet cistern per day. Fire hydrant supply is also managed through piped water supplied by the water board. Bottled drinking water procured from suppliers is provided to all the workers in the terminal.
Pollution prevention: The procurement of 4 new STS having twin lift facilities along with the procurement of electric prime movers, if undertaken, will lead to reduced air pollution. SAGT monitors the air quality through a third party, for the stack of the 3 standby generators, RTG engines and ITV and in 4 different areas of the terminal. Additionally, charging infrastructure will include dual chargers, transformers with 33/11 kV lines, and associated substation equipment which will be constructed and operated in line with applicable regulations and WBG EHS guidelines.
The company has installed oil interceptors, connected to a collecting tank, in the drains near the workshop to prevent mixing of used oil and storm water. Used oil, engine oil and liquid lubricants are stored in drums with secondary containments. SAGT also has a diesel pump/fueling station, storage area and a diesel tank for generators. SAGT maintains a sewage treatment plant and the sanitation waste after treatment is discharged to Colombo Municipal Council drainage system. The drains in the engineering workshop have oil interceptors which are connected to waste oil tanks. Storm water drains in the terminal area leads to the ocean. The wastewater quality is also subjected to tests to ensure that it adheres to the standards before being discharged. SAGT does not allow the disposal of ship-generated effluents and wastes including bilge water, vessel-cleaning wastewater, solid wastes and sewage through its terminal. These services are provided by separate specialized agencies through the shipping agent outside the sea side of the terminal area.
Waste Management: SAGT has a waste management procedure which deals with sorting, handling, storage and disposal which are consistent with applicable legal requirements and WBG General EHS Guidelines and WBG EHS Guidelines for Ports, Harbors, and Terminals. SAGT has obtained a license from the Central Environmental Authority (CEA) for waste management. All hazardous and non-hazardous wastes are collected for disposal by licensed service providers (license given by both Central and Provincial Environmental Authorities). The battery used in the electric prime movers will likely be Lithium Iron Phosphate batteries (also known as LFP battery). The e-waste including battery waste generated from the prime movers will be segregated and stored at site and will be managed either by the original equipment manufacturer (OEM)/ electric prime mover supplier preferably through the Extended Producer Responsibility (EPR) obligations of OEM or as per the applicable legal regulations. SAGT will maintain records of the disposal of Battery waste. If SAGT elects to procure the said electric prime movers, the HSE management system will include update of waste management SOPs including end of life battery management, provision for records on the quantity of waste handled for various waste streams, provision for adequate hazardous materials and waste storage areas, and manifests to be maintained for all waste disposed through vendors.
Hazardous materials management: As part of its existing HSE Manual, SAGT has a SOP related to Hazardous Substances (including dangerous goods) which defines Material Safety Data Sheet (MSDS) and training requirements for the process. The hazardous materials are contained in specialized, certified hazardous material (hazmat) containers by the shipping lines and are handled as per International Maritime Dangerous Goods (IMDG) Code, which governs the maritime transport of dangerous goods and includes proper labelling as per UN Globally Harmonized System. SAGT uses a software-based system (NAVIS) to manage all containers including the ones carrying hazardous substances, brought to the terminal by shipping lines. The software enables SAGT to easily identify, track and segregate the various types of hazardous containers in specific blocks away from each other. As a standard procedure, the containers containing the hazardous materials are stored at the edges of the blocks for ease of movement and containment. SAGT does not store class 1 (explosives) and class 7 (radioactive) containers. The shipping agents and the shipping lines are responsible for release of the stored containers from the terminal (either through transshipment or domestic) and obtain the necessary permissions from the authorities for subsequent movement. Lubricants and gases are stored on site and used for equipment maintenance and repair work. LPG gas cylinders are also stored on site for use in SAGT’s kitchen for cooking purposes. The company displays MSDS in storage rooms, undertakes periodical training/awareness and conducts mock drills besides also upgrading the fire-fighting systems.
PS 4: Community Health, Safety, and Security
Infrastructure and Equipment Design and Safety: SAGT maintains the licenses, necessary permissions and certificates for its existing ship to shore (STS) cranes and the other equipment engaged in operations and undertakes regular inspections. The specifications and the procurement of the new cranes are already approved by the SLPA as per the CA specifications. The company undertakes periodic servicing of the existing STS cranes as per the maintenance schedule through OEM technicians and maintains manufacturer prescribed parts and machinery. SAGT also has SOPs related to operations and maintenance (O&M) of the STS cranes and other equipment, including procedures for managing risks caused due to natural or man-made hazards. The STS cranes are operated by well-trained and experienced operators and are required to undergo periodic training to maintain their permits to operate the cranes (majority of the operators have decades of experience both with SAGT and with international terminals). The operators work for 6 hours during the 12-hour shift; this includes 3-hour work followed by 3 hours of compulsory rest in the resting area provided by SAGT as per applicable laws.
Life and Fire Safety: The terminal has already obtained a fire NOC for the entire concession period from the fire department which conducts annual reviews. Evacuation route maps, assembly point signs, water hose reels and terminal wide fire water pipeline. The terminal relies on the fire brigade maintained by SLPA. SAGT has currently engaged a third-party consultant to update the Life and Fire Safety (L&FS) system in the entire terminal including prepare relevant drawings such as zone wise map of the terminal and replacement of dilapidated fire systems where required. As part of ESAP#4, SAGT will update the L&FS master plan for the project building on changes to existing plans and mitigation measures (identifying major fire risks, applicable codes, standards and regulations, and mitigation measures) in line with GIIP that shall meet the requirement of L&FS guidelines such as local fire codes & regulations and internationally accepted L&FS standard.
SAGT as part of HSE Management system update will include SOP covering guidelines for electric prime movers charging operations which will include: compliance to applicable regulations for electric vehicles, charging and associated infrastructure; work instruction and PPE matrix; do’s and don’ts for charging operations; fire preventions methods in charging station; emergency response plan for electric prime mover’s fire; and, format for periodic internal and external audits. The SOP for electric prime movers will also cover provision for maintenance ensuring continuous checks on charging, preventive and corrective maintenance, and battery management (if possible, with onboard sensors on battery health). Infrastructure such as transformer, substation, charging infrastructure including installation, commissioning and operations (first two years) will be managed by the supplier of transformer, switch gear, etc. who will have their SOPs for installation, commissioning. The operations will be undertaken by SAGT as per the updated SOP as part of the HSE Management system which will also have provision for electrical safety audit of charging and associated infrastructure at regular frequency. The L&FS master plan and ERP will also factor in charging and associated infrastructure to be developed for electric prime movers,
Emergency Preparedness and Response: SAGT has a well-established Emergency Response Procedure (ERP) SOP that details out the various natural and man-made emergencies applicable for the terminal, the scope and responsibilities of the Emergency Response Team (ERT). SAGT has ERT for each of the three shifts with each shift having thirty members headed by the shift duty manager. The HSE team undertakes regular emergency drills for the terminal and conducts training related to implementation of safety measures and specialized incident management on a regular basis. SLPA has a port level ERP document that is not fully accessible to the terminal operator and once any threats are known, the same is activated by the authorities. As part of HSE Management system update, (refer ESAP#4) SAGT will update the existing ERP to include processes for updating/ escalating issues to SLPA during an emergency and specify the standards to be maintained. Besides awareness, the ERP will include provision for briefing on emergency evacuation to be provided to all visitors to the terminal building.
In case of spillage by the ships, the Harbor Master and the marine authorities are responsible for removing the spills. In case of spillage such as spillage due to faulty container, SAGT may obtain the services of SLPA on chargeable basis. The port also follows the International Ship and Port Facility Security (ISPS) code, which is spearheaded by the Sri Lankan Navy. SAGT informs other terminal operators as courtesy, in case of any emergency in the terminal besides informing the SLPA as per the CA.
Community health and safety: Since the project is located within an enclosed terminal area, no significant impacts on the health, safety and security of the local community are present. As noted, the terminal is primarily (around 85 -percent) for the trans-shipment of containers with limited domestic market (around 15 percent) and this trend shall remain same even with capacity increase and thus the associated domestic truck traffic (handled by the shipping agents and the importers) that leaves the port is limited. The road from the port connects with the major highway that leads to the city and outside. SAGT has relevant facilities (rest room, toilets etc.) for the drivers to reduce the risk of drivers' interactions with the community.
Security Personnel: The security to the port is provided by SLPA who controls the entry and exit from the entire Colombo port. SAGT currently employs an external security contractor/agency for providing security personnels for providing security including access to the SAGT terminal area, through the only gate at South end of the terminal. The security staff ensures that all personnels and visitors have a valid SLPA Port entry permit and SAGT entry pass/ID card/passport before entering the terminal. SAGT will adopt a site security management plan in accordance with IFC Performance Standard 4 (ref. ESAP#1), under which the criteria for selection, screening, and training of security personnel assigned to the terminal will be defined and agreed upon with the contracted security service provider.
