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.
Environmental and Social Policies: The E&S policies of the JNPA emphasize sustainable and inclusive development reflecting its commitment to sustainability, employee well-being, and stakeholder value. JNPA’s E&S commitment emphasizes compliance with legal and regulatory standards, preventing injuries and environmental damage, reducing OH&S risks, encouraging sustainable growth, and ensuring safe, healthy, and environmentally responsible port operations through continuous improvement and stakeholder involvement. and aligns with the principles of the IFC Performance Standards (IFC PS).
Identification of Risks and Impacts: JNPA follows a structured approach aligned with national regulations to identify environmental, social, health, and safety risks and impacts. All new projects are screened for applicable regulatory clearance requirements such as Environmental Clearance, Coastal Regulation Zone (CRZ) clearance, and approval from the JNPA Tree Cutting Authority. For developmental activities that falls under the purview of national regulations, Environmental Impact Assessment are conducted accordingly. E&S risks are assessed on ongoing basis through regular monitoring of environmental parameters, community needs assessments, stakeholder consultations, and addressing issues like human rights violations, labor relations, and community grievances. Given the limited scale of construction and brownfield nature of the project, a project specific E&S Management Plan is considered adequate. In line with ESAP # 1 and ESAP #2 JNPA will (i) incorporate Environmental, Health and Safety (EHS) Requirements to IFC PS requirements for both construction and operations into tender documents, EPC contracts and operations agreement with Terminal Operators; and (ii) prepare the Construction E&S Management Plan (CESMP) and Operations E&S Management Plan (OESMP) through EPC Contractor and Terminal Operator for Phase 1 and through Project Management Consultant (PMC) for Phase 2.
E&S Management System and Programs: JNPA has operational ESMS accredited to ISO 14001-2015 and 45001-2018 (Valid until 2029) and is aligned with the national regulatory standards requirements and IFC requirement. JNPA’s ESMS incorporates procedures for environmental and social risk identification, stakeholder engagement, grievance redressal, and continuous monitoring in line with IFC Performance Standards. The framework addresses key aspects such as labor and working conditions, resource efficiency, pollution prevention, and community health & safety..The E&S policy commitments are operationalized through a series of programs, procedures, and tools covering among others hazard and risk identification, pollution control and waste management, safety controls, incident investigations, contractor management, and stakeholder engagement.
Organization structure: JNPA has established a decentralized yet coordinated framework for managing E&S responsibilities across its organizational structure for ensuring effective implementation and compliance with sustainability and safety standards. At JNPA, environmental and social (E&S) functions—including environment, safety, fire services, corporate social responsibility (CSR), and social development—are integrated across multiple departments. The Environmental Cell, located within the Port Planning and Project Preparation Department, is responsible for coordinating sustainability initiatives, monitoring environmental compliance, and ensuring adherence to statutory and regulatory requirements. Key operational functions such as Marine Pollution Control, Fire Services, and Occupational Health & Safety (OHS) fall under the Marine Department, focusing on marine pollution prevention, emergency preparedness, and safe port operations. CSR activities and community engagement are managed through a dedicated CSR unit. Additionally, each terminal has its own EHS personnel to ensure compliance within their respective operational areas.
For the shore power project, JNPA’s primary role is to manage contracts and ensure that EHS provisions are effectively implemented. With adequate capacity for contract oversight, JNPA may monitor EHS compliance either directly or through a Project Management Consultant (PMC). It will deploy EHS personnel to oversee E&S compliance and performance of project contractors through construction and operations (ESAP #2).
Emergency Preparedness and Response: JNPA has developed a comprehensive emergency preparedness and response framework to effectively manage operational incidents such as marine oil spills, fires, accidents, and other operational emergencies and safeguard personnel, assets, and the environment. This system is governed by well-defined safety policies and procedures, which are regularly reviewed and reinforced through training and awareness programs. The Marine Department leads emergency preparedness efforts, supported by specialized teams for Marine Pollution Control, Fire Services, and Occupational Health & Safety. These teams are equipped with trained personnel and advanced equipment to respond effectively to emergencies. Preparedness measures include regular mock drills, capacity-building programs, and coordination with external agencies such as the Indian Coast Guard, Maharashtra Pollution Control Board (MPCB), and local authorities. The port maintains key response plans, including an Oil Spill Response Plan with containment and recovery systems, a Fire Fighting Plan, and established communication protocols for incident reporting and escalation.
JNPA operates a dedicated Fire Service, led by the Chief Fire Officer (CFO) and supported by Deputy CFOs and inspectors. This team functions 24/7 in 8-hour shifts and is equipped to handle a range of incidents—from minor oil spill fires to complex chemical and electrical fires—using appropriate suppression methods such as foam, dry chemical powder, CO2, or steam. The port’s fire infrastructure includes a dedicated fire station at the SEZ, equipped with five types of fire tenders, including a multipurpose tender, foam tender, water bowser, and an ambulance. Specialized firefighting equipment and suppression systems are also in place to address diverse emergency scenarios.
Each terminal within JNPA maintains its own Emergency Preparedness and Response Plan, which is integrated into the JNPA’s port-wide Emergency Response and Disaster Management Plans. As part of project implementation, the EPC Contractor (for construction and maintenance activities) and the Terminal Operator (for operational activities) will be responsible for emergency response planning. The JNPA will require the EPC Contractor and Terminal Operator to identify the potential emergencies due to the project and integrate those in the overarching Emergency Preparedness and Response Plan (ESAP #2). The Contractor will be responsible for training relevant staff and implementing the EPRP to ensure effective prevention, preparedness, and timely response to any emergency situations.
Monitoring and Review: JNPA employs a robust compliance management framework, supported by well-defined policies and standard operating procedures, to ensure adherence to applicable regulations. Environmental parameters such as ambient air quality, noise levels, marine water pollution, drinking water quality, and STP effluent are regularly monitored through third-party accredited agencies, in line with statutory requirements. Under its comprehensive risk management framework, JNPA conducts regular reviews to assess risks and opportunities. This includes identification, prioritization, mitigation, and planning of corrective actions. Key findings from these reviews are periodically presented to the Nodal Committee and the Board for oversight and strategic guidance. In addition to environmental monitoring, JNPA tracks social and safety performance through stakeholder engagement, community needs assessments, and grievance redressal mechanisms. Marine water quality and biodiversity conservation are also closely monitored. JNPA communicates its environmental and social (E&S) performance to stakeholders through its annual Sustainability Report [link]. For project-specific activities, JNPA will regularly monitor key E&S indicators covering the relevant ISC PS and WBG Genera EHS Guidelines and EHS Guidelines for Ports and Terminals through site inspections and contractor’s compliance reporting. It will conduct Internal reviews and audits to assess performance and identify areas for continuous improvement (ESAP # 2)
PS2: Labor and Working Conditions
Human Resource Policies and Procedure: JNPA has established comprehensive policies, procedures, and practices to promote fair treatment, ensure safe working conditions, and support the overall well-being of its workforce. These measures are designed to ensure full compliance with applicable labor laws and are in alignment with IFC PS2. The organization explicitly prohibits child labor and forced labor, and actively promotes diversity and inclusion. Its policies ensure equal opportunities and prohibit discrimination based on gender, caste, race, religion, ethnicity, disability, or any other status. To ensure a respectful and safe workplace, JNPA has implemented a Prevention of Sexual
Harassment (POSH) Policy in line with the POSH Act, 2013. Notably, there have been no reported incidents under this policy in the past several years.
Working Conditions and Terms of Employment: JNPA maintains a diverse workforce structure and upholds fair labor practices through formal agreements, inclusive policies, and collaborative engagement with contractors and unions. JNPA’s workforce comprises both direct employees (600 employees) and third-party contracted personnel (750 contracted workers hired through contractors in facility management services) engaged for various operational and support functions. JNPA has formalized its labor practices through a wage settlement agreement (renewed every 3 years) with recognized workers’ unions, outlining terms of employment including wages, benefits, and allowances. Additionally, a tripartite wage settlement agreement among JNPA, the workers’ unions, and contractors governs employment conditions for contractual workers. This agreement covers working hours, leave policies, uniforms, wages, compensation, and benefits. Uniform minimum wages and benefits are ensured for all unskilled workers employed through contractors, while skilled ITI-certified workers receive an additional allowance. The employee well-being measures includes flexible work schedules, health and life insurance, maternity leave, retirement benefits, and group accident insurance.
For the Shore Power Project, a lean workforce is anticipated during the operations phase, comprising fewer than 10 personnel, including JNPA staff, contractors, and terminal operator port workers. The human resource policies of the respective employing agencies will apply to this workforce. JNPA as a part of its contractor management procedure under ESMS will monitor the labor law compliance of the contractor(s) involved in the shore power project. (ESAP #3)
Workers’ Organization: JNPA upholds the right to freedom of association, allowing employees to join and actively participate in workers’ unions. The port maintains a strong and collaborative relationship with its workforce through engagement with four recognized unions, including JNPT Karmachari Sanghatana, JNPT Kamgar Sanghatana, and Bharatiya Mazdoor Sangh (JNPT Unit). Employee representation is embedded in JNPA’s governance structure through a Labour Trustee position on the Board of Authorities. Union representatives participate in board-level decision-making, ensuring that employee perspectives are formally considered in strategic discussions. These representatives are appointed by the Government of India and are elected through a secret ballot process conducted by the Labor Commissioner. Currently, the President and General Secretary of two registered unions serve as employee representatives, providing a direct channel for workers’ voices in the port’s highest decision-making body.
Retrenchment: Following its transition to a landlord port model in 2022, JNPA has withdrawn from direct terminal operations and initiated workforce rationalization measures to align with its evolving operational structure. To support this transition, JNPA introduced a Retrenchment Policy and a Voluntary Retirement Scheme (VRS), aimed at optimizing the workforce in a fair and transparent manner. The VRS was developed in accordance with government guidelines and complies with all applicable legal and regulatory frameworks to ensure that workforce reduction is carried out in a structured, equitable, and minimally disruptive way, while protecting the rights and interests of affected employees. The scheme offered employees the opportunity to voluntarily exit the organization under mutually beneficial terms, providing financial security and support. Approximately 550 employees opted for retirement under this scheme between 2023 and 2025.
Grievance Redressal Mechanism: JNPA has implemented a structured grievance redressal mechanism to effectively address concerns raised by both direct employees and contract workers. The port authority actively engages with its workforce through regular interactions with recognized labor unions, which play a key role in voicing worker concerns. Four workers’ unions are formally recognized by JNPA, and their representatives participate in the Board of Authorities, ensuring that employee issues are addressed at the highest level of governance. In addition to union engagement, JNPA has established formal grievance redressal procedures, including designated communication channels and periodic reviews of agreements with unions. Employees also have access to the Centralized Public Grievance Redress and Monitoring System (CPGRAMS)—an online platform operated by the Government of India for lodging grievances—and to the Central Vigilance Commission (CVC) for whistleblower complaints. A Chief Vigilance Officer is deputed on-site at JNPA to support this function. Terminal Operators maintain their own grievance redressal mechanisms for their respective workers. For issues related to the POSH, both JNPA and terminal operators have established Internal Complaints Committees (ICCs) in accordance with legal requirements. For project-related activities, the GRMs of the EPC Contractor and Terminal Operator will apply to their respective project workers. Additionally, JNPA will ensure that project workers have access to its own grievance redressal mechanism, reinforcing accountability and transparency across all levels of the workforce.
Occupational Health and Safety: JNPA has implemented an OHS management system accredited to ISO 45001, ensuring compliance with national labor laws and international safety standards. A dedicated Safety Manager, supported by Safety Officers, oversees daily monitoring of unsafe acts and ensures adherence to safety protocols. The safety team is responsible for conducting regular training sessions for workers and truck drivers, issuing work permits, and promoting a culture of safety. Key health and safety initiatives include safety observation tours, near-miss reporting, daily toolbox talks, and the establishment of designated safety zones. JNPA also conducts regular risk assessments, safety quality evaluations, internal safety audits, mock drills, and safety awareness programs. Standard Operating Procedures (SOPs) for high-risk operations are periodically reviewed and updated. To support employee well-being, JNPA provides free medical facilities, routine health check-ups, and health promotion campaigns for employees and their families.
Each terminal operator maintains its own OHS system. JNPA conducts annual safety audits of all terminals through the Independent National Safety Council to ensure compliance, identify gaps, and recommend corrective actions. A digital incident management system has been commissioned, requiring all terminal operators to report incidents online. JNPA also investigates incidents occurring at terminals to ensure accountability and continuous improvement. There are no fatalities or lost time injuries reported in last 5 years.
For the Shore Power Project, key OHS risks include electrical hazards associated with high-voltage equipment and operations in wet dock environments. JNPA, through the EPC Contractor and Terminal Operator, will conduct a Hazard Identification and Risk Assessment (HIRA) and develop Operations EHS manual that includes SOPs specifically focused on electrical safety (ESAP #4).
Employee Training: JNPA has established a state-of-the-art Training and Skill Development Centre in collaboration with the Port of Antwerp. The Centre offers a wide range of programs focused on sustainability, Environmental, Social, and Governance (ESG) principles, and role-specific technical and operational skills. For the Shore Power Project, JNPA—through the Original Equipment Manufacturer (OEM)—will provide specialized training to personnel assigned to maintenance and operations. Terminal operators will be required to nominate and maintain dedicated staff for the shore power system to ensure safe and efficient functioning. Mandatory training will include adherence to the Code of Conduct and OHS protocols, ensuring that all project personnel are equipped with the knowledge and skills necessary to operate in a safe, ethical, and compliant manner (ESAP #3).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: As part of its commitment to environmental sustainability, JNPA has demonstrated a proactive approach to resource efficiency and pollution prevention. The port has implemented several initiatives, including water reuse and recycling systems, zero liquid discharge (ZLD) operations, energy efficiency measures, and a shift toward cleaner energy sources. Additionally, JNPA promotes rail-based cargo transport to reduce emissions and environmental impact, aligning with broader decarbonization goals. In 2024, 8% of JNPA’s electricity use came from on-site solar photovoltaics, with the remainder from the grid. The proposed Shore Power Project will source electricity from the national grid. JNPA is also exploring opportunities to increase the share of renewable energy in its electricity mix through power purchase agreements (PPAs) and on-site solar generation. These efforts reflect the port’s strategic direction toward low-carbon operations. JNPA is expected to manage all relevant environmental parameters of the project in line with IFC PS3, ensuring responsible use of resources and effective mitigation of environmental impacts.
GHG Emissions: JNPA has adopted a strategic approach aligned with India’s "Mission Net Zero Carbon" and Harit Sagar Guidelines to reduce greenhouse gas (GHG) emissions. In FY2023-2024, visiting ships accounted for 191,000 tCO2e across the various terminals at the port, with 85,817,000 tons of cargo handled. These emissions consider ship activities at anchor, transit to and from the berth and while at the berth. The proposed project will introduce shore power infrastructure which reduces the need for the vessel to use its auxiliary engine while at the berth. Across Phase 1 and 2, it is expected the vessels will use 119,084 MWh per year, equivalent to 71,272 tCO2e from the engines using 190 g very low sulfur fuel oil per kWh.
Pollution Prevention: JNPA has adopted an Environmental Management and Monitoring Plan (EMMP) that integrates sustainable practices and environmental safeguards into its port operations. The EMMP serves as a strategic framework to minimize environmental impacts associated with cargo handling, storage, and evacuation activities, while supporting JNPA’s goal of achieving “Green Port” status. The plan ensures compliance with applicable national legislation and international standards, including Coastal Regulation Zone (CRZ) notifications and International Maritime Organization (IMO) guidelines. The EMMP covers key operational zones such as berths, cargo yards, tank farms,
and areas under development. It includes provisions for pollution source identification, environmental parameter monitoring, corrective actions for non-conformities, and adherence to statutory requirements.
In alignment with MARPOL regulations, JNPA provides port reception facilities for the disposal of waste oil, bilge water, and solid waste from vessels. Hazardous waste, such as used oil, is managed through authorized vendors, while solid waste is processed at JNPA’s Solid Waste Management (SWM) facility. Sewage is treated through Sewage Treatment Plants (STPs) located at individual terminals and the port township.
From a project-specific perspective, construction and maintenance activities under the Shore Power Project are expected to generate waste streams such as construction debris, cable offcuts, used oils, and electronic waste. These will be managed by the respective contractors in accordance with the project-specific ESMP. The Shore Power Project is anticipated to contribute to a reduction in air pollution by enabling docked ships to switch off auxiliary diesel engines and connect to shore-based electricity. A review of air quality data indicates that current levels of PM10 and PM2.5 exceed national ambient air quality standards. According to JNPA, this is primarily due to ongoing port expansion activities, including land reclamation, internal road construction, and heavy vehicle movement. As a part of CESMP, JNPA will ensure implementation of dust control measures during the construction phase of the project and will monitor air quality baselines and post project implementation improvements in air quality (ESAP # 1).
PS4: Community Health, Safety, and Security
Infrastructure and Equity Design Safety: The proposed Shore Power Project is located entirely within the operational area of Jawaharlal Nehru Port Authority (JNPA) and is not expected to pose any significant risks to community health and safety during the operational phase. However, during the construction phase, potential risks may include restricted site access, increased traffic congestion, noise and vibration, and dust emissions. These risks are localized within the port premises. The construction ESMP for the project will include the mitigation measures to address these issues.
Security: Security within the JNPA port area is managed by the Central Industrial Security Force (CISF), a paramilitary force under the Ministry of Home Affairs, Government of India. CISF personnel, including marine commandos and armed guards (approximately 15% of the force), are deployed at key installations and along the waterfront. CISF operates independently of JNPA and follows its own security protocols, including a code of conduct and grievance redressal mechanisms for handling complaints against security personnel governed by CISF Act 1968 and CISF Rules, 2002. The CISF security protocol is largely aligned with UN Code of Conduct for Law Enforcement Officials and UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials. In addition to CISF, terminal operators maintain their own private security arrangements for their respective operational areas. JNPA does not have direct oversight over CISF operations or the private security protocols of terminal operators. As a part its contractor management procedure, JNPA will ensure that Terminal Operators develop and maintain the security management procedure aligned to UN Voluntary Principles on Security and Human Rights including (but not limited to) risk assessment and mitigation measures, clear rules of engagement for security personnel, training on human rights and appropriate use of force, coordination with public security forces, incident reporting and investigation protocols, and grievance mechanisms for affected communities.(ESAP #2)
