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
Rondo has an “Environmental Commitment Policy” stating its adherence to comply with EHS applicable local requirements. The company manages the environmental and social (E&S) risks and impacts related to its business activities by adhering to applicable national standards and complying with E&S regulatory permits. Rondo developed both an environmental management plan and an injury and illness prevention program (IIPP) for its office and R&D activities in Alameda, California, in line with California regulations. The company is currently developing procedures that will form the Rondo Integrated Management System, covering environmental, health and safety aspects and impacts of its activities.
For its Alameda facilities which the company has occupied since 2021, an environmental impact assessment was not required by local regulations because it is located in a light industrial park established in 2020 and no additional assessments should be required as the company currently has no plans to expand its operations at this site. According to the integrated management system, future projects will undergo an E&S risk screening to determine the appropriate level of E&S risk identification including whether a formal E&S impact assessment (ESIA) is necessary. Since Rondo's main business activity is to provide batteries to third party industrial clients, the extent of E&S risk identification will depend on Rondo's role in the project and should be limited to identifying a set of predetermined construction and/or operational health and safety procedures to be implemented by Rondo's contractors and/or its clients.
The IIPP, currently under development, defines the organizational structure, roles and responsibilities, training, provision of safety equipment, and contractor management. It also defines instruments for evaluation and risk management, planning and procedures (e.g. project safety plans, health and safety, management of change, contingency planning), implementation and monitoring, and auditing and reviewing.
Rondo’s E&S team is comprised by a Quality, Health and Safety (QHSE) Head, reporting the Chief Operating Officer and supported by a Senior Manager for QHSE for construction and Managers for EHS, and document controls. The HR function is lead by the VP of people, reporting to the CFO.
At the Alameda R&D facility, the duties and responsibilities of teams involved in evacuation, rescue, firefighting, and related tasks are clearly outlined and posted at various points throughout the facility. Fire alarm call points, evacuation route maps, and fire extinguishers placed in key locations. The HSE team undertakes regular drills to ensure that emergency protocols are being followed for all possible emergencies. Additionally, employees receive regular training on fire safety procedures and the use of firefighting equipment.
To monitor EHS Performance at the R&D facility, Rondo maintains a Quality and E&S Learning Dashboard that rigorously tracks related KPIs, and highlights areas for improvement, reported to Senior Leadership. Additionally, EHS management performances is periodically monitored through the various safety meetings and inspection plans through: inspections ranging from daily to annual, yearly EHS audits, quarterly safety committee meetings, Weekly Safety Meetings (at each battery project site and for Alameda HQ). The company's Environmental and Social (E&S) management systems were found to be appropriately aligned with the scale of its operations and the associated E&S risks and impacts, with adequate implementation observed at Rondo R&D facilities. Nevertheless, as part of ESAP #1, Rondo will expand the scope of its ESMS to manage risks related to the construction and operation of the batteries when they are under Rondo’s operational control.
PS2: Labor and Working Conditions
Rondo currently has 133 full-time service providers, of which 33 are female. Rondo provides an employee guide that outlines all aspects of the employer-employee relationship, which are consistent with national labor laws and PS2 requirements. Every worker receives a written contract detailing their working conditions and employment terms. The employee manual outlines Rondo's commitment to being an Equal Employment Opportunity (EEO) employer. It also details the anti-harassment policy and complaint procedures, clearly defining behaviors that will be considered harassment.
When engaging construction firms, Rondo ensures that their terms and conditions comply with relevant labor regulations. Moving forward (ESAP #1), Rondo will require construction and O&M contractors to have a management system to address occupational health and safety (OHS) risks, to offer a grievance mechanism for workers, and to comply with applicable labor laws and IFC PS2. Rondo has developed a contractor's EHS performance questionnaire, used to monitor performance and undertake screening in the selection process. Going forward, Rondo will include the EHS performance as part of the criteria for contractors' pre-qualifications (ESAP #3).
The company upholds workers' rights to freedom of association and allows them to form and join labor organizations. Its policies promote non-discrimination and ensure equal opportunity for all employees. Nevertheless, it will include such protections when engaging with contractors (ESAP
#2). Rondo has established a grievance mechanism (Employee Grievance Process) for its employees. While the mechanism is confidential, it will be enhanced to allow for the submission of anonymous complaints and will be extended to contractors' workers as well (ESAP #4).
As previously mentioned, the company has established a Health, Safety, and Environment (HSE) policy and implemented an Injury and Illness Prevention Program (IIPP) for its R&D facility in Alameda. It has a Goal Zero safety program in place with a focus on safety assurance including PPE, Safe behaviors, and periodic training for employees. To assess IIPP effectiveness, Rondo undertakes periodic EHS Management System Audits, and develops corrective action plans based on audit findings. The Environmental, Health, and Safety (EHS) team compiles monthly incident statistics from both the Alameda facility and battery project sites, covering first aid cases, near misses, and road accidents. Over the past two years, there have been no fatal accidents and no lost time injuries. The EHS team has developed Job Hazard Analysis (JHA) for key activities at their R&D facilities.
Rondo has prepared a Human Rights Protection Policy, committing to adhere to United Nations Guiding Principles on Business and Human Rightsand endorsing and promoting the protection of human rights for their employees and the communities where they operate, and for suppliers and contractors. This policy is in the process of being implemented and includes requirements for contractors to uphold human rights standards on its operations, states Rondo's commitment to provide training and access to a grievance mechanism for all relevant stakeholders, and to report on the progress and effectiveness of the implementation of the Policy. Currently, terms and conditions in Rondo purchase order include general reference to actable supplier conduct. Going forward, Rondo will develop an implementation plan for its Human Rights Protection Policy and will develop and implement a supply chain management system, including a due diligence process to assess and monitor primary supplier's child labor, forced labor risks and OHS risks (ESAP #5).
PS3: Resource Efficiency and Pollution Prevention
Rondo batteries are manufactured from cement, concrete, steel and heater wires. Additionally, Rondo has an inventory of hazardous materials used on the facility, which are mainly cement additives and solvents. Rondo's pollution prevention and control policies are laid out on its environmental management plan, which focuses on waste management and hazardous waste management used on its Alameda R&D facility, which describes how it should be minimized, reduced, recycled (if applicable) and disposed. At battery project sites, waste generated is mostly packaging and construction-related waste. These are managed in alignment with client's site specifications, in line with local requirements. Rondo will include contractual obligations, when applicable, with construction contractors so that waste and hazardous waste is adequately managed and disposed for future projects (ESAP #2).
Rondo operations are primarily aimed at greenhouse gas emission reductions from steam generation. Rondo batteries will substitute fossil fuels by renewable energy or from the grid when prices are low. Rondo's annual GHG emissions from its R&D and manufacturing activities are estimated at 7,400 tCO2eq for scope 1, 2 and 3.
PS4: Community Health, Safety and Security
Rondo's battery is inherently safe, as there is no degradation of storage capacity or depth-of-discharge issues typically associated with electrochemical batteries. In case of a power loss, Rondo's heat batteries can vent passively. All materials used to build Rondo's batteries are conventional. Rondo projects are undertaken at client's industrial facilities. The primary risk posed to the community health and safety relates to transportation of materials and equipment to project sites. Thus, as part of Rondo project design, Rondo will assess transportation risks and will require construction contractors to implement a road safety and logistics management plan (ESAP#2).
Rondo contracts with a security service provider unarmed security personnel for its Alameda facility. Security guards conduct regular fire-watch guard to monitor the building for fire, vandalism, and break in. Additionally, guards undergo training sessions covering standard operating procedures for their duties, including human rights, emergency response and community
engagement.
