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.
PS 1: Assessment and Management E&S Risks and Impacts
Environmental and Social Policy & Management System. BIRET has an overarching Environmental, Social, and Governance (“ESG”) policy including Net-Zero and Biodiversity goals with a commitment to environmental stewardship, social responsibility, and ethical governance. These standards align with the principles of IFC performance standards; apply to all SPVs and are implemented across operations
The Environmental and Social Management System (“ESMS”) is applicable for operational assets. It is accredited with ISO 14001 and 45001 certifications. BIRET has retained a 5-star rating from the Global Real Estate Sustainability Benchmark (“GRESB”) for the third consecutive year and has received the highest management score ranking in Asia, demonstrating its sustainability performance in the real estate sector. The management procedures in the EHSS manual are designed to meet national regulations. The assets will upgrade its management system manuals for EHSS (Environmental Health, Safety, and Social) to integrate the IFC Performance Standards and General EHS guidelines (ESAP #1) and climate risk responses to mitigate impacts of flooding, heat waves, increased temperature on workers and environment. The Project assets have developed design guidelines for sustainable workspaces aligned with its ESG commitments, which include reducing carbon emissions, promoting diversity, equity, and inclusion, and upholding the highest ethical standards. In addition, they have developed a green leasing framework to jointly promote and improve the environmental performance of the building and premises. The green clauses allow the parties to work together on sustainability and energy, including retrofits, billing, energy efficiency upgrades, and data sharing
Impact Identification and Assessment. BIRET assets follow its sponsor group Brookfield's policies and procedures for due diligence. Due diligence is conducted by internal experts and third-party consultants utilizing industry-specific sustainability guidelines based on Sustainability Alliance standards of International Financing Reporting Standards (“IFRS”). Various biodiversity and climate risk screening tools, such as Natura 2000, the UNESCO World Heritage List, and Moody's Climate on Demand, are used. All assets in the BIRET portfolio have undergone due diligence through a third party. The ESG baseline is established at the acquisition stage and benchmarked against the IGBC platinum rating and other external and internal standards to identify gaps and prepare an upgrade plan. The design guidelines for sustainable workspace sets targets for each design parameter related to energy efficiency, water efficiency, waste management, building materials, health and well-being, equity and inclusion, external development, and embodied carbon. All its assets are developed and operational (except for one brownfield expansion in Kolkata and land pads in Gurugram, Noida and Kolkata) and have regulatory permits in place such as environmental clearances, No Objection Certificate for fire and consent to operate.
Regarding the brownfield construction in Kolkata, Candor Kolkata One Hi-Tech Structures Private Limited has prepared a regulatory Environmental Impact Assessment (“EIA”) report and obtained regulatory environmental clearance. The building is under construction and is expected to be commissioned by the end of FY 2026. The relevant SPV has appointed a Project Management Consultant(“PMC”) to monitor the construction, including EHSS compliance with its requirements. The relevant EHS General Contract Terms for contractors and OHS guidelines are in alignment with IFC requirements and encompass requirements related to ESG policies, allocation of resources, standard operating procedures for OHS, hazard and impact assessments, the EHS plan, the emergency preparedness plan, the EHS Committee, EHS infrastructure, labor camp specifications, training, personal protective equipment (“PPE”), safety signage, health and safety provisions, waste management, accidents/incidents management, work stoppages, audits, and penalties for non-compliance. The PMC submits the monthly EHS report on contractors' compliance and performance, along with a monthly EHS score rating. Penalties are also levied on contractors for non-adherence, as evidenced by the review of the monthly EHS report. The IFC review of regulatory EIA indicates that the stakeholder engagement plan for the construction phase can be further strengthened. BIRET, through the construction contractor, will prepare a stakeholder engagement plan, including a grievance redressal mechanism for affected communities and construction workers (ESAP#2)
BIRET has conducted a portfolio-level climate risk (physical and transition) assessment and developed key performance indicators (KPIs) for climate risk mitigation. The near-term (2030) and long-term (2040) decarbonization targets have been submitted to the Science Base Target Initiative (SBTi) for validation. Additionally, it is committed to implementing a portfolio-level decarbonization plan. To address physical climate risks, the company has formulated a resilience plan and piloted adaptation measures, including installing floodgates, de-silting external drains, and using pumping systems, demonstrating its commitment to climate resilience. The project is aligned with the adaptation and resilience goals of the Paris Alignment.
Organizational Capacity and Competencies. At the corporate level, BIRET has established a two-tiered governance structure, with a cross-functional board of directors at the Investment Manager with overall responsibility and accountability for all material aspects, including climate change and sustainability. At the board level, the Corporate Social Responsibility and Sustainability Committee, consisting of an independent chairperson and two member directors, has responsibility for the overall ESG vision, strategy, and performance. At the management level, the CEO-chaired ESG Steering Committee oversees all ESG initiatives and interventions related to net zero, decarbonization, diversity and inclusion, CSR impacts, renewable energy procurement, energy efficiency, climate risks, and mitigation measures. The operations team at the asset level is led by a head property manager and supported by customer relationship and leasing staff for overall monitoring, supervision, and management. Operations are outsourced to International Property Consultants (IPC's) at key assets (Candor/Downtown Powai). For such assets, the IPC deputes an Estate Manager and Deputy Estate Manager, along with functional managers such as Building Manager(s), Security Manager, Civil Manager, CRM, Soft Services Manager, supported by executives. Further, IPC appoints third-party subcontractors for housekeeping, horticulture, security, and technical. For the other assets (Rostrum Portfolio), the property operations services are self-delivered and the third-party contractors are directly appointed.
Emergency Preparedness and Response. An emergency preparedness and response (EPR) system exists across all operational assets to respond to accidents and emergencies, including fires, bomb threats, floods, earthquakes, medical emergencies, LPG leakage, fall from heights, chemical spills, etc. The EPR is prepared based on hazard identification and risk assessment, mock drill observations, and incident reports. All assets comply with fire safety regulations outlined in the National Building Code of India and actively maintain the emergency response infrastructure and floor-wise evacuation plans. They also conduct regular mock evacuation drills and training programs for on-site staff and communicate their EPR with government authorities. The Tenants are required to develop an emergency response plan for the leased premises, which is integrated into the overall emergency plan for the asset. Each asset has a dedicated management system for fire and safety, including an organizational structure. An external fire safety audit is conducted annually as against Indian National Building Code, 2016 requirement, which is required every two years. The tenants' premises are internally audited quarterly for fire safety. The EPR is communicated internally to all stakeholders (tenants and contractors) and externally with government authorities.
Monitoring and Review. The monitoring and review system includes monitoring against KPIs, an audit mechanism that provides for both internal and external audits for ISO EMS and OHMS, annual life and fire safety audits, energy and water audits, and various certification audits, as well as customer satisfaction surveys and senior management reviews. BIRET follows a multi-layered compliance mechanism, including an online compliance management tool to monitor asset-level compliances. Management certification audits and other sustainability and safety audits will be aligned with IFC performance standards and WBG General EHS guidelines
PS 2: Labor and Working Conditions
Human Resource (HR) Policies and Procedures. BIRET's commitment to social responsibility, as outlined in its ESG policy prioritizes support of internationally recognized human rights, full compliance with applicable fundamental conventions of International Labour Organization (ILO), and elimination of all forms of child and forced labor, as well as discrimination in employment and occupation, while promoting diversity, equality, and inclusion in the workplace. It's approach extends to providing and maintaining a clean, healthy, and safe environment for employees, contractors, vendors, and other business partners. BIRET also strives to make a positive impact in the communities where it operates, implementing development programs in line with the UNSDGs. BIRET's HR policies apply to all on-roll employees and are administered by the HR department. Although none of the SPVs have workers' unions, freedom of association is recognized in accordance with Indian labour law, Brookfield's Global Human Rights and Anti-Slavery Policy, and the Vendor Code of Conduct.
Through asset SPVs, BIRET engages personnel via third-party agencies appointed by the IPC or directly for facility management services including housekeeping, horticulture, security, façade cleaning, and technical services (electrical, plumbing, HVAC). Recent appraisals of selected site samples showed no evidence of child and forced labor. Additionally, no retrenchment or collective dismissals have occurred among on-roll employees, or agency workers, within the SPVs. Agency workers are governed by contracts and a code of conduct. The governance framework ensures adherence to compliance through a multi-layered approach. IPC corporate-level compliance is the first layer of oversight (for applicable SPV's), followed by compliance audits by third-party labor consultants and corporate-level reviews by BIRET's Legal, Risk, and Internal Audit team. The review of the records indicated the strong implementation of systems, with few minor observations regarding benefits and submissions for outsourced workers. As a part of ESMS, BIRET will continue to monitor the labor and working conditions related to the payments, working hours, submissions, and other statutory benefits for the outsourced staff through contractors in conformity with all applicable labor law requirements (ESAP #1).
Grievance Mechanism. On-roll employees have access to a dedicated email ID and Brookfield's help desk for recording grievances. For agency workers, BIRET follows a structured, four-tier GRM. The first line of grievance is the immediate agency supervisor. The second level is the Estate Manager/Account director from the IPC (wherever applicable). The third level is the Head of Property Management (HPM) for the asset. The fourth level is the central Property Helpdesk, which is staffed round the clock. All grievances follow an escalation matrix to the senior management of BIRET based on resolution timelines. Complaints can also be raised by telephone or email. Suggestions and feedback boxes are also provided for anonymous complaints. In addition, BIRET has a whistleblower policy, which further enhances its ethical governance by establishing secure channels for raising grievances related to ethics and integrity.
Gender-related aspects of operations. No heightened gender-related risk is identified in the operational assets. There is a separate Internal Complaint Committee at the asset and corporate levels for sexual harassment complaints under the Prevention of Sexual Harassment Act of 2013, with two independent members from the agency who have expertise in providing legal advisory and psychological interventions to build an equitable and safe space. BIRET is responsible for providing a safe workplace. Brookfield conducts online training for employees and offline training for third-party contract employees through contractors and IPC. Brookfield maintains a reporting hotline for its employees, vendors, partners, and other interested parties to report concerns or raise any issues anonymously. The hotline numbers are displayed in the lobby and lifts and are accessible to all. As a part of ESMS, BIRET will continue to monitor the gender-related aspects of its operations on an ongoing basis.
Occupation Health and Safety. The asset SPVs have implemented an ISO 45001-certified Occupational Health and Safety (“OHS”) Management System. The OHS manual outlines the policies, organizational structure, and procedures for ensuring regulatory compliance and managing OHS risks and opportunities, supporting a systematic approach to continuous improvement. There exist systems that facilitate work permits, gate passes, help desk services, work order management, incident reporting, inspection scheduling for areas and equipment, asset registry, and preventive maintenance for plant operations. OHS Key Performance Indicators (“KPIs”) tracked include incidents as well as leading and lagging indicators. Since BIRET acquired the assets, there have been no fatalities or major accidents
PS3: Resource Efficiency and Pollution Prevention
Energy Consumption and GHG Emissions. BIRET has set a benchmark of achieving an energy performance index with a Bureau of Energy Efficiency, Government of India (BEE) 5-star rating Most of the assets are BEE 5-star rated. All assets, (except Downtown Powai) have a Building Management System (BMS) to monitor the HVAC, variable temperature, water pumps, power backup systems, etc. As of today, ~40% of the portfolio uses Renewable Energy, and the goal is to achieve 100% by 2027. All assets (excluding North Commercial Portfolio, where benchmarking is in progress) are certified as Green Buildings by the Indian Green Building Council (IGBC). BIRET aims to achieve net zero emissions by 2040 or sooner, primarily through energy efficiency and renewable energy, and address balance residual emissions through offsets. BIRET has agreed to pursue Advanced EDGE / EDGE certification for all assets on a best-effort basis and GRIP advisory for the decarbonization of the portfolio. As reported by BIRET, for FY24 for current assets, the Scope-1 and Scope-2 emissions for the portfolio are 6,500 tCO2e and 43997 tCO2e. The Scope 3 emissions (primarily for downstream leased assets) are 97,571 tCO2e. As a result of the various initiatives undertaken by BIRET, including pursuit of EDGE Advanced certification, the absolute net emissions are estimated to be reduced by around 20,000 tCO2e by FY29 compared to BIRET's existing absolute GHG emissions.
Water Consumption. The assets' water requirement is mainly for domestic purposes, horticulture and cooling towers. The Project assets have set a benchmark for water efficiency by achieving a = 30% reduction in fixture flow rates from the baseline. The water conservation measures implemented include rainwater harvesting by installing permanent infiltration or collection features, wastewater treatment and reuse for landscaping, flushing, and cooling tower makeup water, and integrating design features such as biophilia to reduce water consumption.
Indoor Air Quality. The DG sets for power backup are a source of air emission and are operated as per the permit conditions with requisite emission control measures. All assets are installed with Indoor Air Quality sensors, and the air quality index is displayed in the lobbies and other locations for all occupiers and visitors. The measurements were observed to be within the established threshold values of ASHRAE (American Society of Heating, Refrigeration, and Airconditioning Engineers) standards for Class A commercial office buildings.
Waste management. Except for Downtown Powai in Mumbai, all project assets have captive sewage treatment plants and zero liquid discharge, with treated wastewater reused for flushing, horticulture, and cooling towers. The Downtown Powai buildings are served by a central community STP for Hiranandani Gardens, and treated wastewater is recirculated through a separate pipeline for toilet flushing and horticulture. Waste management in buildings is managed by respective property management teams. The project has installed organic waste composters at all its assets for wet waste treatment. E-waste (lights), battery waste, and hazardous waste (lube oil) are disposed of through an authorized third-party recycler. Plastic bottle-crushing machines are installed throughout the assets and are collected by authorized recyclers.
Hazardous Material Management. Wherever applicable, the assets have diesel storage units with valid PESO licenses.
PS 4: Community Health, Safety, and Security
Community Health and Safety. The SPVs have established Emergency Preparedness and Response (EPR) plans for each of its assets, which are shared with the relevant government authorities. Asset SPVs will communicate relevant sections of these EPR plans to nearby commercial and residential communities that could potentially be affected by an emergency at the assets.
All BIRET assets are located in urban areas with well-developed road networks. The design of the assets ensures planned entry and exit points, minimizing the risk of traffic congestion on adjacent roads. Traffic around the assets is aided by security personnel and traffic marshals. Additionally, external infrastructure improvements have been implemented to ease traffic congestion further.
Life and Fire Safety. The life and fire safety system for the operational assets in the portfolio complies with the Indian National Building Code, 2016 (NBC), wherever applicable, which is equivalent to NFPA standards on fire and life safety installations and operations and maintenance systems except for structural parts. All renovations and modifications, wherever technically feasible, follow the NBC 2016 guidelines. The fit-out guidelines for tenants are also NBC-compliant. The fire safety management system includes infrastructure such as smoke and gas detectors, water sprinklers, fire alarms, fire hydrants, fire extinguishers, smoke dampers, PPE, etc. The fire tenders are maintained where required to address the potential response time delay caused by traffic congestion, as evidenced in BIRET assets in Gurugram. A dedicated fire team is deployed at the assets around the clock, headed by the L&FS manager and the fire officer, along with a squad of firefighters from a third-party agency, to ensure the implementation of fire safety procedures and handle any fire incidents. Escape routes are displayed on all floors and in strategic locations, and assembly points are earmarked. With support from local fire departments, fire safety training and evacuation drills are conducted regularly to ensure preparedness. Stair wheelchairs are also provided at each building for differently-abled persons. The tenant is responsible for the fire system of their premises. The tenants' fire system is integrated with the fire panels of the Brookfield system and is monitored from the command center. BIRET will ensure that all new grounds-up developments follow NFPA standards for L&FS (ESAP #3).
Security Personnel. There exists a security manual as part of its IMS procedure, which addresses operational aspects, as evidenced by the manual review. The manual covers the policy statement, organizational structure, guard qualification requirements, security design, security risk assessment, incident management, and the audit process. The audit includes security infrastructure, the management framework, security operations, security training, security assessments, and audit compliance. The manual also includes the vendor selection criteria checklist. All security agencies are licensed, and IPC's conduct third-party verifications of these agencies prior to hiring. The security agencies also perform police verification for security personnel. There have been no complaints of harassment against the security guards. The grievance redressal contact numbers and email addresses for receiving complaints are prominently displayed at key points throughout the assets.
