While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are site specific, largely reversible, and readily addressed through implementation of good international industry practice (GIIP) and development and implementation of an Environmental and Social Management System (ESMS) consistent with IFC Performance Standard 1 for the InvIT and its portfolio of SPVs. Key E&S issue and risks associated with the project include: i) formalization and operationalization of the borrower’s existing ESG Policy into an ESMS across incoming and operating warehouse assets; ii) monitoring and review of warehouse level E&S performance and regulatory compliance, including applicable environmental health and safety permits and statutory requirements; iii) accessibility and effectiveness of grievance mechanisms for workers, contracted labor, and neighboring communities; (iv) oversight of third-party contractors and service providers, including housekeeping, security, and facility maintenance personnel operating in common areas; (v) life and fire safety management for multi-tenant warehouse facilities and emergency preparedness and response; and (vi) operational environmental risks including wastewater treatment and disposal (STP operation), solid waste management, and diesel generator emissions.

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

NDR Warehousing Private Limited (the Sponsor) has adopted a corporate Environmental Social and Governance (ESG) Policy, and Sustainable Developmental Goals (SDG) commitments which apply to the following group entities: i) NDR InvIT Trust (the Infrastructure Investment Trust, a listed entity); ii) NDR InvIT Managers Private Limited (the Investment Manager); iii) NDR Asset Management Company Private Limited (the Project Manager); and iv) multiple SPVs owned by the Trust. The ESG Policy draws on several national and international reference frameworks, including National Guidelines on Responsible Business Conduct (India), UN Sustainable Development Goals (UN SDGs), and World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines. As part of ESAP#1, the ESG Policy will be updated to reference the IFC Performance Standards (2012) as an applicable reference framework. The ESG Policy sets out group-level environmental and social commitments.
NDR organizes its ESG approach around four pillars: i) Environment; ii) Occupational Health and Safety (OHS); iii) Social and Community Related; and iv) Governance. The principles at the core of NDR’s ESG Policy commitments inform the design of the NDR Environmental and Social (E&S) Checklist used to screen new assets proposed for acquisition by the InvIT. This E&S checklist supports review of key E&S considerations such as statutory approvals, OHS practices, and land-related aspects. However, documented procedures for systematic risk identification, assessment, mitigation planning, and monitoring across the InvIT portfolio are not yet fully formalized. Therefore, as part of ESAP#2, the NDR InvIT will develop (including consolidation of existing relevant E&S procedures) and implement a formal Environmental and Social Management System (ESMS) consistent with IFC PS requirements, WBG General EHS guidelines, local regulations, and Good International Industry Practice (GIIP). The updated ESMS will include: (i) formal procedures for comprehensive E&S risk identification and assessment including screening of new assets, E&S due diligence (as required), acquisition due diligence, portfolio-level risk screening; (ii) documented EHS operational manuals, Standard Operating Procedures (SOPs)/ Frameworks and associated checklist such as waste management, security management, traffic management, monitoring utility level resource consumption, and regulatory compliance etc.; (iii) training and capacity building of EHS and other staff; (iv) emergency preparedness and response, including life & fire safety; (v) stakeholder engagement and community grievance mechanism; and (vi) reporting, monitoring, and management review. As limited construction activities are carried out by SPVs within the InvIT as part of expansion of warehouse assets, the ESMS for the InvIT will also factor in construction related E&S impacts.
The NDR InvIT Trust’s assets are managed by the Investment Manager (IM) who makes investment decisions and appoints the Project Manager (PM). The PM or AMPL is responsible for day-to-day operation and maintenance (O&M) of the warehouse assets and administration of lease agreements with tenants. Regional Asset Supervisors employed by APML oversee implementation of EHS measures related to common infrastructure and operational activities under the InvIT’s control and report operational observations to the corporate ESG Coordinator. The InvIT, as part of ESAP#3, will establish separate EHS monitoring checklist for limited construction activities and for operating warehouses in line with the updated ESMS for InvIT operations.
The ESG Coordinator conducts periodic EHS reviews at the asset level, and reports monthly to the Regional Business Heads, the Chief Executive Officer (CEO), and the InvIT Board and Compliance Officer. These arrangements provide operational oversight; however, procedures and reporting protocols will be further formalized as part of the ESMS (ESAP#2).
NDR InvIT has Emergency Preparedness and Response Plan (EPRP) at each warehouse. These plans specify the actions to be taken in the event of emergencies such as fire incidents or serious injuries. NDR provides induction training and refresher courses on emergency procedures for staff and contractors. First aid kits are available at all sites, and access to ambulances is pre-arranged. Emergency preparedness includes coordination with local emergency services and periodic facility-level drills. E&S risks associated with climate variability differ across the geographic locations of the InvIT assets, with flooding identified as a relevant physical risk at certain sites. Warehouse design incorporates stormwater drainage provisions and consideration of local drainage characteristics. Additional measures related to stakeholder engagement and grievance mechanisms are addressed in the relevant sections of this ESRS and associated ESAP actions.

PS2 – Labor and Working Conditions

At the time of IFC’s review in September 2024, the NDR InvIT had only 21 fulltime staff (5 female / 16 male). The IM and PM added another 159 staff (7 female / 152 male) providing contractual operational and maintenance (O&M) services to the NDR InvIT. The company has established basic policies and procedures to address labor and working conditions, including aspects related to wages, leave, non-discrimination, prevention of sexual harassment, and occupational health and safety (OHS), largely in line with applicable national regulations. New employees and contractors receive induction training covering relevant company policies and site safety requirements. The company has recently developed a Health and Safety Site Management Plan (HSSMP) and is in the process of strengthening its contractor management and labor oversight practices under the corporate ESMS. No cases of fatalities or major incidents have been reported to date.
NDR has established grievance and redressal policies covering (i) unitholders/investors (through the IM, including the Stakeholders’ Relationship Committee and SEBI SCORES platform), and (ii) “other stakeholders,” which explicitly include internal stakeholders (employees and workers, including contractor/third-party workers) and external stakeholders (communities, affected parties, contractors, works contract workers, and other interested parties). At the warehouse level, grievances are raised verbally or in writing with leasing, operations, or compliance teams, with escalation to the Corporate ESG Committee for unresolved matters.
For worker-related grievances, including contracted workers engaged at InvIT-managed facilities, as per ESAP#4, the grievance mechanism will be strengthened to support accessible channels and anonymous reporting, and to strengthen documentation and tracking of grievances and outcomes. Grievances pertaining to sexual harassment are managed according to the Prevention of Sexual Harassment Policy. NDR management communicate and organize trainings on this policy that prohibits unwelcome behaviors that constitute sexual harassment in the workplace and provides a framework for prevention and redressal processes. Complainants and any person providing information or any witness are to be protected from retaliation.
Third-party contractors are engaged by AMPL for construction, security, housekeeping, and maintenance activities. Contractors typically hire workers from surrounding communities as well as migrant workers. Where migrant workers are engaged, accommodation is arranged and managed by the contractors. NDR InvIT, through AMPL, supervises contractor compliance with contractual labor, OHS, and worker accommodation requirements. To support oversight of such arrangements, NDR InvIT as part of ESAP#5, will develop and implement the Worker Accommodation Checklist consistent with the IFC–EBRD Workers’ Accommodation Guidelines (2009) and will be incorporated into the ESMS developed under ESAP#2. NDR InvIT is expected to manage labor and working conditions aspects within its operational control, including oversight of contractors and service providers engaged at InvIT-managed facilities, consistent with IFC Performance Standard 2. As part of ESAP#6, NDR InvIT will commission an independent third-party labour and working conditions review at a representative sample of warehouse facilities and SPVs, especially including locations where construction or expansion activities are undertaken under AMPL supervision, to assess compliance with applicable national regulations and IFC Performance Standard 2 requirements. Any corrective actions identified will be implemented and integrated into contractor and service-provider management procedures.

PS3 – Resource Efficiency and Pollution Prevention

NDR’s InvIT’s role is limited to O&M of common infrastructure and shared utilities and does not extend to operational processes within tenant-controlled areas; NDR InvIT’s role is therefore limited in scale compared to tenant industrial and logistics activities. Louver vents, High Volume Low Speed (HVLS) fans, sky lighting, and insulation design solutions further reduce common-area energy consumption. Water consumption is minimized through rain harvesting and the reuse of treated wastewater for landscaping and in restrooms. The company has installed rooftop solar power at one of its warehouses and is planning to install more in the future. NDR has also planted more than 25,000 trees in and around their warehouse properties.
Operational warehouses include sewage treatment plants (STPs) to manage domestic wastewater generated from common facilities such as restrooms and support areas. Treated wastewater is reused within the facility for non-potable purposes. Solid waste generated from common facilities is segregated at source and managed in accordance with the Solid Waste Management Rules, 2016. Organic waste is processed through on-site composting arrangements, while recyclable waste is handed over to authorized vendors. Sludge generated from STPs treating domestic wastewater is non-hazardous; it is dewatered and shall be reused for landscaping/manure application where permitted by local regulations, with handling and disposal arrangements managed through authorized service providers. The only other wastes InvIT manage are limited amounts of organic and packaging materials collected during housekeeping activities in common areas.
Warehouse operations may also utilize backup diesel generator (DG) sets for emergency power supply and are operated as part of shared utilities managed by AMPL; emissions from such equipment are limited in duration and subject to applicable regulatory standards. In addition, individual tenants may install and operate DG sets for their own operational requirements. Emissions associated with tenant-owned equipment remain the responsibility of the respective tenants in accordance with applicable regulatory requirements, while NDR InvIT manages only DGs associated with common infrastructure.
The facilities comprise Grade-A warehousing and logistics parks where only storage, distribution, and limited ancillary/light industrial activities are permitted. Some tenants may operate equipment such as small boilers within their leased premises. Such installations are owned and operated by the tenants, who are responsible for obtaining applicable statutory permits and complying with environmental regulatory requirements.
Occasionally, tenants may temporarily place maintenance-related wastes (e.g., used oil or similar materials) in shared or common areas. As part of ESMS implementation (ESAP#2), NDR InvIT will establish procedures prohibiting storage of such materials within common areas, including communication of requirements to tenants and coordination, where necessary, for removal and disposal through authorized handlers in accordance with applicable hazardous waste management regulations.
Resource consumption and pollution from NDR InvIT’s tenants’ business activities, for example energy and water consumption, solid waste, and emissions from customized cooling systems and cargo trucks, are the responsibility of tenants operating within leased premises. NDR’s Green House Gas (GHG) emissions are expected to be less than 25000 tonnes Co2 equivalent. These emissions come primarily from energy used for onsite sewage treatment, operation of fire safety systems, and common area lighting. The Trust does not currently measure gross warehouse GHG emissions, i.e. including all tenants’ Scope 1 and 2 emissions. However, the company is considering approaches to support voluntary tenant-level energy efficiency and reporting initiatives. As part of ESMS implementation (ESAP#2), NDR InvIT will formalize procedures for monitoring utility consumption, waste handling, and regulatory compliance for common infrastructure across operating warehouses.

PS4 – Community Health, Safety, and Security

NDR integrates siting and safety engineering criteria in their building designs to manage natural risks like earthquakes, wind, flooding, landslides, and fire. Warehouse design and operation follow applicable building codes and fire safety requirements, including provisions consistent with the National Building Code (NBC) 2016 and local fire authority approvals. This includes implementing measures for fire prevention and response, such as using fire-resistant materials and installing effective fire alarms and suppression systems. As part of ESMS (ESAP#2), NDR InvIT will develop a Life and Fire Safety (L&FS) framework, and Emergency Preparedness and Response Framework (EPRF) with provision for site-specific EPRPs covering operational and limited construction phase. The framework and associated plans will address potential scenarios such as fire, electrical incidents, vehicle accidents, and extreme weather events, and will include coordination with local emergency services. The EPRP will include procedures for tenant coordination on emergency response, fire safety interface, and communication of site-level safety requirements.
NDR’s InvIT warehouse locations are within peri-urban and industrial areas located near transport corridors and logistics clusters. Construction activities and warehouse operations may generate community-level risks including traffic movement of heavy vehicles, noise, and dust. As part of the ESMS (ESAP#2), NDR InvIT will implement site-level procedures to communicate construction schedules, vehicle movement, and safety precautions to nearby communities and adjacent land users. To deal with increased traffic, traffic management measures will be implemented, including designated entry/exit routes, speed controls within premises, signage, and coordination with local authorities, where required.
NDR InvIT warehouses are located within industrial and peri-urban areas where surrounding communities, road users, and visitors may interact with site activities. Potential community health and safety risks primarily relate to vehicle movement at entry and exit points, emergency incidents such as fire within warehouse units, and interactions with security personnel and contractors. Currently, these risks are addressed through facility-level measures, including fire and life-safety systems in common areas, access control at site gates, and emergency response procedures maintained at each warehouse. Coordination with local fire and emergency services is undertaken where required. As part of ESAP#2, the InvIT will formalize these practices within the InvIT ESMS, including documented procedures for community communication, incident notification, and management of security and traffic interface risks. A stakeholder GM accessible to nearby communities will be operationalized under the ESMS to allow community members to raise concerns related to noise, dust, traffic, safety, or security, and to ensure tracking and resolution of complaints.
NDR provides two security guards at each warehouse. These guards are unarmed and trained to protect personnel, property and assets. Recruitment involves detailed background and qualifications checks. Security services are provided through third-party agencies. Under the ESMS, NDR InvIT will develop and implement a security management procedure consistent with GIIP, including training, code of conduct, and oversight of security personnel (ESAP#2). The tenants often hire their own additional security to control access to their leased spaces and operations. Tenant activities are confined to leased premises.

NDR stakeholder engagement activities are currently limited and primarily operational and compliance-based rather than structured under a formal stakeholder engagement framework. For operating InvIT warehouses, engagement with external stakeholders generally occurs through site-level interactions, tenant coordination, and communication with local authorities when operational matters arise. NDR also maintains a Corporate Social Responsibility (CSR) program supporting community initiatives. A formal Stakeholder Engagement Plan (SEP) proportionate to the operational risk profile has not yet been established. Information disclosure is currently limited to corporate-level website communication and case-specific site interactions, which does not fully meet IFC PS1 requirements for systematic engagement with project-affected people.
The NDR GM is designed to ensure that all interested stakeholders are fully informed of the options to file grievances within NDR InvIT and their rights to escalate, if they are not satisfied with the response. The GM assigns clear roles and responsibilities to the IM, and ESG Committee, and includes monitoring, reporting and evaluation on grievances received, and outcomes delivered. However, awareness and accessibility of the external GM at the warehouse level remain limited. To further strengthen and formalize external stakeholders access to the GM, NDR will publicly disclose grievance contact information at each warehouse facility (ESAP#7). In addition, the InvIT level ESMS to be developed under ESAP#2 will include stakeholder engagement framework (SEF) proportionate to warehouse operations and provision for documented site-specific SEP in line with SEF. The site-specific SEP will address communication with nearby communities regarding operational activities such as vehicle movement, emergency situations, and site-level concerns, and will establish processes for receiving, recording, and responding to external stakeholder complaints.

NDR InvIT Trust
Sandeep Jain
Chief Financial Officer
+91 22 26101040
sandeep@ndrinvit.com
NDR InvIT Trust, Ground Floor, KHIL House CTS No. 54, Village Bamanwada, Vile Parle (East), Mumbai - 400 099, Maharashtra, India
https://www.ndrinvit.com

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	NDR will update its ESG Policy to incorporate IFC's Performance Standards (PS) on Environmental and Social Sustainability (2012) as an applicable reference framework in their ESG Policy and revise the guiding principles of their ESG Policy and Framework accordingly.	02/17/2025
2	NDR InvIT will develop: (i) separate EHS Checklist for construction activity undertaken by portfolio SPVs in line with the InvIT ESMS; and (ii) EHS Checklist for monitoring and reviewing the InvIT assets’ EHS performance during operations and maintenance.	02/17/2025
3	NRD will revise the existing workers grievance mechanism to allow for anonymous complaints to be raised and addressed.	02/17/2025
4	NDR will adopt a Worker Accommodations Checklist consistent with the IFC – European Bank for Reconstruction and Development (EBRD) Guidelines on Workers' Accommodation: Processes and Standards (2009) .	02/17/2025
5	NDR will strengthen its information disclosure and grievance handling mechanism and display details for reporting grievance at the main gate of each NDR InvIT warehouse gate identifying the contact information for the appropriate site manager, along with applicable GM escalation options.	02/17/2025
6	NDR InvIT will formalize and implement a corporate Environmental and Social Management System (ESMS) NDR InvIT will develop (including consolidation of existing relevant E&S procedures) and implement a formal Environmental and Social Management System (ESMS) consistent with IFC PS requirements, WBG General EHS guidelines, locals regulations, and Good International Industry Practice (GIIP) and applicable across its SPVs and operating warehouse assets. The updated formalized ESMS will include: (i) formal procedures for comprehensive E&S risk identification and assessment including screening of new assets, E&S due diligence (as required), acquisition due diligence, portfolio-level risk screening; (ii) documented EHS operational manuals, Standard Operating Procedures (SOPs)/ Frameworks and associated checklist such as waste management, security management, traffic management, monitoring utility level resource consumption, and regulatory compliance etc.; (iii) training and capacity building of EHS and other staff; (iv) emergency preparedness and response, including life & fire safety; (v) stakeholder engagement and community grievance mechanism; and (vi) reporting, monitoring, and management review. As limited construction activities are carried out by SPVs within the InvIT as part of expansion of warehouse assets, the ESMS for the InvIT will also factor in construction related E&S impacts.Within approximately one year of ESMS implementation, NDR InvIT will commission an independent third-party review of ESMS implementation across representative operating warehouses and prepare and implement a corrective action plan to address identified gaps.	12/31/2027
7	NDR InvIT will commission an independent third-party labour and working conditions review at a representative sample of warehouse facilities and SPVs, including locations where construction or expansion activities are undertaken under AMPL supervision, to assess compliance with applicable national regulations and IFC Performance Standard 2 requirements. Any corrective actions identified will be implemented and integrated into contractor and service-provider management procedures.	04/28/2026