The NXST portfolio comprises of developed assets that are in the operational stage. No land acquisition is envisaged. IFC's E&S appraisal also did not come across any past land acquisition or resettlement issues. Hence PS 5 is not triggered for the project. The project is not expected to have any adverse impacts on biodiversity, Indigenous Peoples or cultural property. Accordingly, PS6 - Biodiversity and Sustainable Management of Natural Resources, PS7 - Indigenous Peoples, and PS8 - Cultural Heritage are not applicable to the Project.

              This is a Category B project according to IFC's Environmental and Social Sustainability Policy, 2012. The project only includes operational assets and does not include greenfield construction or asset development. Key E&S risks and issues associated with this project include: the company's E&S management system and organizational capacity to identify and manage E&S risks and impacts, stakeholder engagement, grievance redressal mechanism, labor compliance and working conditions including management of contractors and third-party workers, energy and water consumption, life and fire safety (L&FS), and GBVH risks in all assets. 

      Environmental and Social Policy & Management System. NST has adopted a suite of environmental, social, and governance policies at the corporate level. These policies cover climate change adaptation and resilience, energy and emissions, net zero emissions, waste management, water management, employee well-being and development, health and safety, stakeholder engagement, and human rights. These policies are implemented across operations and apply to all stakeholders, including employees, business partners, and vendors. The policies are largely aligned with IFC performance standards requirements.

NXST has developed an Environmental and Social Management System (ESMS) that covers operational aspects.  The EHS manual outlines management procedures for operational aspects such as health and safety, electrical safety, access control, fit-outs, waste management, water management, energy management, etc. The EHS manual is designed to meet national regulations. Per ESAP#1, NXST will update the ESMS, which will include (a) EHS manual in line with applicable IFC PS and WBG General Environmental, Health and Safety (EHS) guidelines (b) Environmental and Social Due Diligence (ESDD) and screening procedure for new acquisition, covering risk assessment against the IFC Performance Standards (PS), and WBG General EHS guidelines including climate, labor compliance and GBVH and child abuse risks;

NXST has also developed a green lease framework to pursue ESG objectives collectively with the retailers and tenants. This framework includes clauses related to ESG data sharing, sustainable monitoring, integration of green and IGBC-compliant materials in fit-outs, and cooperation in water conservation and waste management programs to enhance ESG performance. NXST claims to have achieved 100% green leasing.

Impact Identification and Assessment. NXST has acquired all the developed and operational assets. It is responsible for complying with the conditions stipulated by regulatory authorities for environmental clearance (EC) and consent to operate (CTO). NXST will ensure and monitor compliance with statutory E&S and labor requirements for all applicable assets. Per ESAP #2, NXST will maintain a legal compliance register on an ongoing basis.

To manage risks and impacts on an ongoing basis, NXST has developed the Hazard Identification and Risk Assessment (HIRA) guidelines that identify and assess the risk in building operations and maintenance in structural integrity, mechanical and electrical systems, HVAC, etc, and provide control measures and monitoring mechanisms. When conducting due diligence for new acquisitions, NXST considers E&S factors such as regulatory compliances and gaps in applicable conditions, evidence for contamination and spills at the target asset sites, review of any past event and historical uses, along with water and energy management, fire safety, and waste management; While these factors are important, they are used for establishing the baseline and benchmarking for the ESG performance and formulating an action plan to meets benchmark standards, which are reflective of the best-performing assets within the portfolio. As part of the updated ESMS, NXST will develop the benchmark E&S standards for the acquired assets aligned with IFC PS and WBG General EHS guidelines that encompass the minimum stack height of the DG set, standards for air emissions, effluent standards, illumination standards, etc. (ESAP) #1)

Organizational Capacity and Competencies. NXST has a five-tier ESG Governance Framework. This includes two board-level committees: a risk management committee and an ESG committee supported by the Apex ESG Committee, comprised of the CEO and the corporate functional head. There is also an ESG Steering Committee headed by the ESG Head, responsible for implementing the ESG roadmap for NXST, and a Task Force comprising cross-functional teams at the asset level to implement the ESG goals. At the corporate level, there is a designated ESG Head. At the asset level, the overall responsibility lies with the Centre Director, who is supported by a dedicated fire safety executive and a functional head responsible for monitoring the EHS performance of utilities.

Emergency Preparedness and Response. An emergency preparedness and response (EPR) system exists across all operational assets to respond to accidents and emergencies, including fires, explosions, bomb threats, and safety incidents. All assets have fire safety provisions that are compliant with the National Building Code of India and actively maintain the emergency response infrastructure and floor-wise evacuation plans. The assets also conduct regular mock evacuation drills and training programs for on-site staff and communicate their EPR with government authorities. The review indicates that fire and emergency training programs are adequate. The tenants are required to develop the emergency response plan for the leased premises, which is integrated into the overall emergency plan for the asset. No major fire incidences or other emergencies have been reported. NXST will update its EPR Procedure to incorporate considerations and responses for climate risks such as cyclones, flooding, extreme temperatures, and heat waves. Furthermore, NXST will communicate the relevant aspects of the EPR plan for each asset with the external stakeholders who could be affected by an emergency (such as fire or explosion) at the assets.

Monitoring and Review. The monitoring and review system includes internal and external audits, senior management reviews, and annual sustainability reporting (https://www.nexusselecttrust.com/esg#ESG-Report). External audits are conducted annually for water and energy, every two years for fire, and every three years for waste. Internal audits are performed periodically to assess non-compliance and violations of food hygiene, fire safety and labor compliance. All retail and office assets are covered under the internal audits.

Additionally, third-party mystery audits (anonymous audits) are conducted bimonthly for all mall assets to assess mall services, including customer interaction, hygiene, housekeeping, lighting, ambiance, and the environment. NXST has developed a risk management matrix with targets and triggers for key indicators and tracks environmental and reputational risks. The environmental risks monitored include carbon emissions (Scope 1 and 2), waste generation and disposal, physical climate risk, and water consumption. NXST assesses its ESG (Environmental, Social, and Governance) performance through the Global Real Estate Sustainability Benchmark (GRESB).

  Human Resource (HR) Policies and Procedures. NXST has implemented a Human Rights Policy outlining principles for upholding human rights, including child and forced labor, human trafficking, diversity, equality, non-discrimination, freedom of association, collective bargaining, fair compensation, and flexible working hours. This policy applies to NXST's business activities and employees, who are on its own payroll. NXST requires its contractors to comply with the statutory requirements and Nexus's Vendor Code of Conduct on E&S aspects.

Additionally, NXST has established an employee well-being and development policy focusing on employee health, development, engagement, remuneration, diversity, inclusion, and non-discrimination. These policies are detailed in the employee handbook, which applies to on-roll/direct employees and cover areas such as selection and recruitment, onboarding, working hours, leave, remote work, travel, medical insurance, compensation, separation, employee grievances, diversity and inclusion, human rights, stakeholder engagement, equal opportunity, and policies for persons with disabilities. The HR policies comply with national labor law and are broadly aligned with IFC PS2 requirements. The HR department is headed by a Chief HR Officer (CHRO), and each mall has its dedicated HR resource. The HR team is supported by labor consultants who assist NXST in monitoring labor compliance and conducting internal audits of outsourced agencies. NXST has adopted HR management system for human capital management, payroll, and workforce management.

The HR policies, Code of Conduct, compliance manual, and other related documents are reinforced through general communication (available on NXST's intranet through the “People Strong” HR management system) and targeted education and training programs. The agreements with agencies and contractors govern applicable policies and procedures for contract workers, with the Code of Conduct and compliance manual integrated into their contracts. Vendors and their onsite supervisors are responsible for communicating these policies and procedures to contract workers.

At the hotel, the operator manages the HR function by deploying a team separately. This hotel HR team reports to the country/global HR function of the operator and is not related to NXST. Therefore, NXST currently does not have any direct oversight of HR-related aspects at hotel level. The hotel deploys workers through outsourced agencies, including security, housekeeping, kitchen cleaning, laundry attendants, etc. The existing HR policies and procedures at the hotel mostly cover on-roll employees and rely on the respective contractors to manage their workers. A few gaps were identified in areas like payroll management, grievances, workers' records, and training. Unlike the setup at malls, the contractors at the hotel are not subjected to labor compliance audits by external consultants. As part of the E&S risk and compliance management framework for third-party operated hotels, NXST should ensure the development of a system to manage, review, and improve the HR matters for outsourced agencies at the hotel (ESAP #1)

Furthermore, per ESAP #1, as a part of ESMS, the Client will develop and implement the E&S risk and compliance management framework for third-party managed assets like hotels, which will include (a) developing contractor management procedures for hotels and similar such assets to ensure regulatory and IFC PS compliances, especially labor law compliance, (b) integrating labor compliance audit and GBV risk assessment in due diligence of new hotel acquisitions and incorporating corrective action plans in the contractual agreements with the hotel operator; and (c) establishing a formal reporting mechanism for third party managed assets to receive information on incidents involving fatalities, major accidents, fire incidents, labor strikes, protests, GBVH and child abuse incidents, and complaints under the Prevention of Sexual Harassment (POSH) Act. (d) developing a collaboration platform for engaging with hotel operators and management contractors of third-party managed assets to collectively pursue key E&S objectives (such as GBV, labor compliance, and life and fire safety).

Workforce and Working Conditions. NST has 500+ on-roll employees (19% female) and over 3,000+ contract workers hired through third-party contractors (agencies) by the asset SPVs to perform facility management jobs. The outsourced functions include housekeeping (cleaning, gardening, and pest control), food court, parking, security, and technical (electrical, plumbing, HVAC). According to the company's information, there has been no retrenchment or collective dismissal of employees, including contractual employees, in any of the assets after acquisitions. The appraisal process on selected site samples did not reveal any incident of child labor or forced labor.  As the asset owner and principal employer of the hotel, the asset SPV will ensure compliance with the applicable labor laws to avoid any reputational and regulatory risk.  The review of labor data and interviews with the mall and hotel workforce revealed gaps and inconsistencies in working hours and payment of overtime wages for outsourced workers. NXST will prepare a road map for all its assets (malls and hotels) to ensure compliance with applicable requirements for outsourced workers, particularly regarding overtime work and linked compensation. (ESAP #3).

Grievance Mechanism. The Manager's GRM applicable to direct employees includes a dedicated email ID for grievance reporting, which is received in the CHRO's inbox and then shared with relevant team members for resolution. The Grievance Redressal Committee (GRC) is established at each mall and is headed by the CHRO. Contract workers can report complaints to their direct reporting managers or the GRC. Suggestion boxes are installed, but not in all malls. NXST will develop a formal GRM procedure for contracted workers to receive, handle, and resolve complaints, including anonymous complaints for both malls and hotels. (ESAP #4)

A separate POSH Internal Complaint Committee (ICC) is constituted at both the corporate level and at each mall to address complaints related to sexual harassment and other forms of GBVH. The ICC also includes an independent member from a local non-governmental organization (NGO). Furthermore, the whistleblower policy allows for raising concerns about malpractices.

Gender-based Violence and Harassment (GBVH) and Child Abuse Risk. IFC's appraisal of GBVH and child abuse risks in the hotels and malls confirms that several formal HR policies (human rights policies, diversity, equality, and inclusion), code of conduct, social responsibility programs are in place, and mechanisms, processes, and procedures exist to promote the safety and well-being of employees. Both entities - the Nexus Select Mall and the Hotel Operator - have POSH policies on women's safety that meet the requirements of the POSH Act, 2013, and offer regular internal GBVH capacity building and training to employees, as well as interns, apprentices, seasonal, and part-time workers. Both entities have also designated HR personnel (at the corporate and local levels) responsible for overseeing and handling GBVH reports. Company-managed online communication portal and grievance mechanisms exist and offer online or in-person reporting options. However, gaps are identified in terms of the lack of comprehensive language on child safeguarding, no referral pathways for GBV survivors, no referral protocols, inconsistent work with contractors and suppliers to prevent GBVH and child abuse, and lack of clear collaboration between NXST and hotel operators in addressing GBVH and child safeguarding. As a part of ESMS, NXST will strengthen the GBVH policy and procedure to assess and manage the GBVH risks in its business operations (ESAP # 1). Per ESAP # 4, NXST will develop and implement the GBVH   and Child Safeguarding Plan for the malls and hotels (through the hotel operator) to address the above gaps. The plan would include (a) a commitment to child safeguarding in policies and the code of conduct, (b) external and internal communication, training, and awareness for employees, third-party contractors and suppliers, as well as visitors and customers on GBVH and child safeguarding prevention policies, procedures and reporting, (c) establishing a safe and confidential referral pathways and referral protocols for GBVH survivors, (d) coordination mechanism with tenants and management contractors to develop and implement the GBVH and child safeguarding actions, which may include leveraging the existing collaboration mechanism and extending its tenant engagement platform to include hotel operators and management contractors.

Occupation Health and Safety. The company has established an OHS Management System that includes OHS policies and safe work procedures, risk assessment and mitigation procedures, accident and incident analysis, EPR plans, life and fire safety measures, safety training and emergency drills, and incident management. All the assets in the portfolio are fire safety compliant, conforming to the National Building Code 2016. The PPE kits, medical first aid kits, fire extinguishers, and electrical safety devices are provided at each asset and are accessible to all employees. NXST has established an OHS Committee of employees, management, and agency workers. No fatalities, loss of time, or injuries have been reported at any of the assets in the portfolio in the last three years. As a part of the updated ESMS, NXST or the asset SPVs will upgrade their OHS management procedures to include and control measures for increased temperature, heatwaves, cyclones, and flooding on workers' health and safety. (ESAP#1)

Energy Efficiency: NXST has adopted a dedicated Energy and Emissions Policy that provides guiding principles for effectively managing and reducing energy consumption and greenhouse gas emissions arising from its operations, as well as for the efficient utilization of renewable energy. All assets are green building certified by the Indian Green Building Council (IGBC), with 87% certified at platinum standards. Some assets have achieved 5-star certifications from the Bureau of Energy Efficiency (BEE). The key energy efficiency measures implemented include smart lighting, improved cooling tower efficiency, and the innovative, eco-friendly terracotta wind tunnel at the retail asset in Chandigarh, which reduces atmospheric air temperature. The SPT for the SLB includes a commitment to achieving EDGE certification for all new acquisitions.

GHG Emissions: NXST is committed to achieving Net Zero emissions by 2030. It has adopted a dedicated Net Zero Policy and developed a decarbonization strategy demonstrating its commitment to sustainability. The combined Scope 1 and 2 GHG emissions reported in its ESG report were 46,239 tCO2e in FY 2024. Its Scope 3 emissions of 83,596 tCO2e in FY 2024 represent the highest share at 84%, from the Downstream Leased Assets (tenant energy consumption).

Water Efficiency: The water requirements in retail mall operations are for drinking, sanitation, housekeeping, food courts, and running critical systems like cooling towers and firefighting. The primary water source is the municipal water supply, supplemented by groundwater at a few malls. Some of the measures implemented for water efficiency include rainwater harvesting, a smart water supply network comprising leak detection systems, automatic meter readings, smart irrigation, water audits, and water-efficient operations. Additionally, as part of its CSR initiative, NXST is implementing the “Lakes of Happiness” initiative, rejuvenating lakes that recharge groundwater and aiming toward water neutrality.

Pollution control: Retail mall operations result in air emissions from DG sets used for power backup, sewage generation from domestic water use, and solid and hazardous waste generation. The DG sets are installed with the stack as per regulatory requirements and comply with the IFC General EHS Guidelines.  The sewage is treated on-site in the sewage treatment plants. The treated wastewater is used for toilet flushing, landscaping, and cooling towers. All the malls have achieved zero liquid discharge. The mall is responsible for waste management—collection, segregation, storage, and disposal. The wet waste is treated in the on-site organic waste composter. The dry waste is sold to authorized recyclers. E-waste such as bulbs, battery waste, and hazardous waste (lube oils) is disposed of through a pollution control board-authorized agency.                                                  

        Community Health and Safety. NXST has established Emergency Preparedness and Response (EPR) plans for each asset, which are also communicated to government authorities. The retail assets manage traffic around them through security and traffic marshals.

Life and Fire Safety. NXST has developed a fire safety management system that includes the organizational structure for fire safety, a fire detection and suppression system, gas leakage detection in every kitchen, 120-minute fire-rated fire exits, fire hydrants, quarterly fire drills with the fire brigade team, fire training, first aid training, evacuation plans, and an emergency response team comprising employees (both on-roll and contract workers), tenants, and retailers. In addition, third-party fire safety audits are conducted every two years against national codes to ensure the highest fire safety standards. NXST runs the Fire Ambassador initiative, providing fire safety training to the adjacent residential societies.

All the acquired assets in the NXST portfolio have been developed, and operational buildings were originally designed for the National Building Code of India fire safety compliance. After the acquisition, they were turned around and upgraded to IGBC Gold or Platinum and NBC 2016 standards and comply with the WBG General EHS guidelines on life and fire safety (generally aligned with NFPA requirements) 

Security Personnel. The operational assets have a security management system incorporating multilayered electronic measures and third-party unarmed security personnel. The security service provider is responsible for conducting background checks and providing training related to the code of conduct for the security personnel (which includes behavior training and interaction with customers) deployed at the site through contractual provisions aligned with industry practices. The existing GRM covers aspects related to security personnel.

   NXST has adopted the stakeholder engagement policy applicable to all its SPVs, covering internal (employees) and external stakeholders (customers, communities, contractors, suppliers, and government authorities). Community engagement relates to corporate social responsibility activities, the Fire Ambassador initiative, and engagement with customers, tenants, and employees based on the centrally developed ESG calendar. NXST, as included in ESAP# 1, will develop and implement a procedure that includes an asset-specific stakeholder engagement plan and a grievance redress mechanism (GRM) for the community that meets the requirements of IFC PS1. The grievance mechanism will ensure that grievances from affected communities and external communications from other stakeholders are handled appropriately.

  NXST will locally disclose the E&S information for the project at the following locations: Any queries and/or comments about the project may be directed to:

Company Name: Nexus Select Trust

Point of Contact: Chirag Singhal

Title

Telephone Number

Email :chirag.singhal@nexusmalls.com

Mailing Address: Embassy 247, Unit no 501, Lal Bahadur Shastri Marg, B Wing, Vikhroli West, Mumbai, India 400083

Website: www.nexusselecttrust.com