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
E&S Policy and Management Programs
GFL group has established a corporate Environmental Policy as well as Occupational Health and Safety Policy which is applicable to GFCL EV. GFCL EV has implemented management systems certified based on ISO 14001 (Environment), ISO 45001 (Occupational Health and Safety), EcoVadis (Resilient, Sustainable Supply Chains), ISO 20400 (Sustainable Procurement Standards) and Responsible Care by International Council of Chemical Associations (ICCA) for improving safety in chemical management in line with PS 1 requirements.
The group has an on-going communication of its EHS policies with all employees, contractors, service providers, third-party suppliers, and stakeholders through different channels of communication. The company’s E&S management systems established and maintained at Jolva plant were noted to be commensurate with the nature and scale of the project’s E&S risks and impacts of its operations.
Identification of Risks and Impacts
The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and associated requirements. GFCL EV site is in a designated industrial zone of the Gujarat Industrial Development Corporation (GIDC). An Environmental Impact Assessment (EIA) was conducted for GFCL EV along with Quantitative Risk Assessment (QRA) and Hazard Operability (HAZOP) studies using nationally accredited EIA consultants for obtaining prior environmental clearance. The EIA studies were carried out based on a regulator approved terms of reference (TOR). The EIA study has assessed E&S impacts in a radius of influence of 10 kms and identified mitigation measures. There are no associated facilities (AFs) of the project as defined under IFC PS1. The EIA does not address stakeholder engagement and external communication requirements to address community risk during hazardous chemical transport. These non-compliances are addressed in Environmental and Social Action Plan (ESAPs #1 and #2) in the following discussions.
Link to the EIA report for both GFL as well as GFCL EV projects at Jolva: https://environmentclearance.nic.in/DownloadPfdFile.aspx?FileName=UGz6Prf6nHeZWUlR3cmDMm3xBGA632Fd6F5V3rynDy6yHk10wLVuNc+oFjiOBHjMCveuG23Txdt05AqtGL1FSFBZ4kmlZfl3Es6hxVP/17gY5SLo1iotZNORZbHW1TBmS7uBqLQ9a9qDsOX6QhB0CQ==&FilePath=93ZZBm8LWEXfg+HAlQix2fE2t8z/pgnoBhDlYdZCxzVPEh4a7F53Cae7tleKGoXIDiA7chYePNgRJpehWx3dLsaLaee8RS5VxBvVdCAnIMg=
GFL obtained EC vide no, SEIAA/GUJ/EC/5(f)/562/2022 dated 17/02/2022 from the Gujarat State Environmental Impact Assessment Authority (SEIAA) for manufacturing synthetic organic chemicals with capacity of 84493.1 MT/Month at the Jolva site. Subsequently, Environmental Clearance (EC) was obtained from the SEIAA to share manufacturing responsibilities between GFL and GFCL EV on 10th March 2023:
SEIAA/GUJ/EC/5(f)/333 and 334
https://environmentclearance.nic.in/DownloadPfdFile.aspx?FileName=0UJx/AVzfn7n/N1Onux0PBUXuwt7GshnnLJ1aXbBKAT9Kj3J+vmeEYqQRJvKsknISAoro98vntWkgswzpg3iHmZE6FK1zBbA8kYX4canHxQ=&FilePath=93ZZBm8LWEXfg+HAlQix2fE2t8z/pgnoBhDlYdZCxzWYSktLmWVaXKfetCrs6kw3DoGTia+2sdXMwhPpplwBWruBjKVYi4lT84sunafOeWE=
All necessary regulatory approvals and permits have been obtained by the company.
As part of its EHS management systems, the company has carried out identification of environmental aspects and hazards based on which risks have been determined. For significant EHS risks, the company has identified appropriate operational controls and management programs to mitigate the impacts. Going forward, GFCL EV will incorporate IFC Performance Standards into its E&S management system (refer ESAP #1 below).
To integrate and harmonize various environment, health, safety and social initiatives and management systems of GFCL EV, and to demonstrate and track compliance with IFC PS1, the Company will (ESAP #1) develop an Environmental and Social Management System (ESMS) document that integrates and collates all their individual management systems and practices. The ESMS will incorporate the following elements: (i) policy; (ii) identification of risks and impacts; (iii) documented E&S operational manuals, procedures, practices, plans and management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement; and (vii) monitoring and review.
In order to improve the process safety during storage and transport of AHF, (ESAP #2) the company will carry out the following actions for the entire Jolva site (GFL and GFCL EV): (i) update the quantitative risk assessment (QRA), Hazard Operability (HAZOP) and Barrier Health Management (BHM) study reports incorporating IFC’s inputs on technical improvements such as using proper methodology, including node drawings and risk ranking in HAZOPs, assigning responsibility for implementation of actions, updating risk registers based on HAZOPs, as required by IFC in the QRAs and HAZOP studies, and (ii) develop Layers of Protection Assessment (LOPA) and Safety Integrity Level (SIL) studies during operational phase, through competent third party agency with relevant experience.
Organizational Capacity and Competency
The E&S organizational structure involves an integrated team of corporate level (GFL) as well as GFCL EV plant level personnel totaling 16 persons. The Health, Safety and Environment Functional (HSEF) team at Jolva is led by a Senior General Manager reporting to the unit head, supported by operational safety heads for GFL and GFCL EV. These are in turn supported by personnel on operational safety, training coordinators, H&S excellence and governance managers, two fire services officers, and one sustainability officer. In addition to this, project safety and process safety managers supported by process safety engineers manage process and equipment safety. A corporate level HSEF Head has oversight of the entire E&S function across the plants of GFL.
GFL has established a corporate health and safety (H&S) steering committee that has 11 subcommittees on workplace safety and process safety management, which are being led by corporate sponsors comprising unit head and functional heads. The company carries out HR and labour compliance periodic internal inspections and annual audit through a competent 3rd part agency and implements corrective actions.
GFCL EV has prepared an annual training calendar based on which various training courses are conducted for all employees, contractual staff and workers. Annual training manhours for staff and contractors is recorded by the company. External communication and engagement measures have been proposed as part of ESAP #5 to address external stakeholders and community for transport of hazardous chemicals, such as AHF.
Some corporate functions related to human resources (HR), environmental health and safety (EHS), information technology (IT) are also shared between the two facilities, based on allocation of specific roles and responsibilities. At the corporate level, GFL’s Sustainability head is responsible for overseeing E&S / sustainability initiatives across the company operations with a focus on resource efficiency, waste reduction and GHG emissions as well as implementing GFL’s Corporate Social Responsibility (CSR) program and sustainability reporting.
Emergency Preparedness and Response
GFL and GFCL EV have documented an integrated emergency response plan for their operations at the Jolva site. The EPRP includes responses to chemical leaks, smoke and fire, abnormal operations and controls.
The roles and responsibilities for various teams responsible for evacuation, rescue, firefighting etc. are defined and displayed at various locations across the facilities. An offsite emergency response plan is developed through the local district collector’s office in consultation with other industries in the GIDC area. A mutual aid initiative under the GIDC office enables all industries to pool resources in terms of ambulance and fire tender services, human resources, technical knowhow etc. for handling emergencies.
The Jolva site plant premises are provided with dedicated firewater storages, fire hydrant system as per Indian Standard (IS) 13039, first aid and firefighting equipment are installed across the plant as per IS 2190, all PESO licensed installations are protected with water based system as per IS 15015, electrical panels are protected with CO2 flooding system as per IS 6382, and an inhouse fire tender is available round the clock with dedicated and trained crew. Fire alarm call points, evacuation route maps and hose reels have been placed at relevant locations. The compliance team conducts internal audits to ensure implementation of fire safety measures through mock drills. Emergency response teams and workers have been trained in fire safety and operation of fire safety equipment every month including construction workers.
A risk of community exposure was identified due to AHF transport over 13 kms from the Dahej plant of GFL to GFCL EV. The company has undertaken mitigation measures to address this risk. This aspect has been addressed under PS4 in further detail.
Monitoring and Review
As part of the corporate EHS management systems, the company conducts environmental pollution monitoring (such as ambient air, point source emissions, ambient noise levels, equipment noise levels, influent and treated effluent, treated sewage) as per permit conditions and key performance indicators (KPIs) such as record of injuries / Lost time incident frequency rate (LTIFR), Life and Fire Safety (L&FS) measures, usage of personal protective equipment (PPE), energy and water consumption, waste generation covering construction and operations. The KPIs are reported monthly to the compliance management team based on internal audits. All incidents are summarized and discussed in the quarterly management meeting and the team analyses the root causes and implements corrective actions as necessary. Soil samples are collected on an annual basis within 1 km of the plant and assessed for fluoride content and other parameters of contamination based on local regulation requirements and WBG General EHS Guidelines.
The eleven subcommittees under the corporate H&S steering committee mentioned above address areas such as process safety, security, communication, standard rules and procedures, pollution prevention, emergency response, contractor safety, occupational health management, product safety and incident investigation. The Managing Director and Chief Executive Officer of GFL meet with the corporate H&S steering committee monthly to review performance and provide directions.
PS2: Labor and Working Conditions
As on March 2025, GFCL EV has 390 employees of which 10 are women. During construction phase the company has 1229 contractual workers of which 1153 were male and 76 were female. GFL has a total of 541 employees out of which 143 persons are shared with GFCL EV for services related to commercial, effluent treatment plant (ETP), health, safety and environment function, information technology, projects and technical services.
GFL has corporate level policies related to E&S / EHS, Human Rights, etc. that are publicly available on their website at https://www.gfl.co.in/Company_Policies.php. These policies are applicable across all subsidiaries of GFL, including GFCL EV.
GFCL EV has documented HR policies and procedures that are consistent with the national labor regulations and IFC PS 2 requirements and apply to all employees, suppliers and contractors. Each employee / worker receives a written contract that describes the working conditions and terms of employment, along with an employee handbook. The company’s HR team also monitors the labor contractors’ compliance with applicable labor laws and compliance with related contract clauses, on a periodic basis.
The company does not have a worker’s union at present and the management does not discourage freedom of association or collective bargaining. The company policies mandate non-discrimination and equal opportunity for its on-roll staff, contract staff / contractor workers and 3rd parties. The company has developed a gender sensitivity guidance manual that addresses equal opportunity, diversity and inclusion principles and their staff is trained on this basis. The company has developed a relocation policy for enabling movement across their manufacturing plants. Company’s HR policies prohibit engagement of child, forced or bonded labor practices.
The company has established proactive initiatives to identify and resolve concerns and grievances of staff and contractors. These include HR Buddy, Ethics line, Suggestion box, Plant HR Representative Officers (PHRRO) who visit once a week to all plants and engage with the staff and workers. For contractual staff there is a works committee and social performance team established to oversee contractor resource management.
The company has a documented grievance mechanism for its internal stakeholders in line with its HR policy and the Prevention of Sexual Harassment of Women at Workplace (POSH) regulation. The grievance mechanism allows for submission of anonymous grievances through suggestion boxes and HR Buddy system of the company. This mechanism is also available to the contractors’ workers, and they are included in related training and awareness campaigns conducted by the HR department.
GFCL EV requires its contractors to comply with national labor laws through specific contract clauses. The labor engagement practices, and statutory documentation maintained by the contractors are subjected to labor audits undertaken by an independent third-party agency. Sample reports reviewed by the IFC indicate compliance with relevant laws and regulations.
The company did not have any onsite labour accommodation during the construction phase, and contractors organized accommodation for workers in the nearby area of Bharuch town.
To further improve compliance with IFC PS2, the Company will (ESAP #3) develop formal policies on retrenchment, freedom of association, and labour accommodation standards in line with IFC guidelines (Part II: Standards for and management of workers accommodation, Workers’ accommodation: processes and standards, A guidance note by IFC and the EBRD, August 2009)
Occupational Health and Safety
The company has formulated a health and safety policy and has developed its Corporate EHS manual based on Hazard Identification and Risk Assessment (HIRA). Workplace noise and air quality monitoring records are well within the applicable standards. EHS team collects the incident statistics such as LTIFR and reportable incidents based on GIIP, monthly. GFL’s group level LTIFR for 23-24 was 0.68 which is in line with chemical industry average as per OSHA standards. In the last 2 years there have been no fatal or reportable accidents in GFCL EV. The company has set a target to achieve zero accidents for FY25-26 across its project sites. GFCL EV will report incident statistics such as LTIFR and reportable incidents with IFC in the annual monitoring template.
On December 29th, 2024, a fatal accident occurred in the Dahej facility of GFL (@13 km from the Jolva site of GFCL EV) due to exposure to chloromethane gas, causing 4 deaths. In September 2025 there were two incidents in the Ranjitnagar plant of GFL. One of these incidents resulted in 2 deaths and 10 injuries, whereas the second incident resulted in complaints of dizziness and eye discomfort. The company has prepared an interim investigation reports on the incidents that were reviewed by IFC. To better understand the root cause of the incidents and identify systemic corrective measures to prevent risks in similar processes in GFL and GFCL EV, the company will (ESAP #4) engage a competent third-party agency (such as DSS or equivalent) to conduct an independent technical investigation into the incidents at Dahej & Ranjitnagar to provide observations and recommendations on preventive and corrective measures.
The company has also carried out QRA using the internationally accepted DNV PHAST software, HAZOP and BHM studies and the results have been used to understand the probability of credible risk scenarios, plan safety controls and monitor the health of safety barriers. Based on the QRA carried out for the site operations, if any building / control room is within 1E-3 contour of location specific individual risk (LSIR), protection methods then the company will take precautions such as provision of blast proof wall for explosion risk, ventilation shutdown and maintenance of positive pressure during emergencies to minimize toxicity risk. Workplace noise levels monitored by the company on a periodic basis were found to comply with applicable regulatory requirements for industrial areas.
The company has partnered with Dupont Sustainable Solutions (DSS) for their process safety. Experts from DSS conduct periodic safety training for staff of GFL and its subsidiaries. To strengthen the process safety implementation in their operations, GFCL EV will (ESAP #5) engage a third-party competent agency for conducting a process safety audit in the Jolva plant to assess the company’s system against GIIP, maturity assessment of the process safety framework and provide recommendations for corrective actions based on 29 CFR 1910.119, OSHA PSM for chemical industries.
Workers engaged by Third Parties and Supply Chain
GFL has established a sustainable procurement policy applicable to all its subsidiaries, that includes supplier / vendor assessment and is applied to all their suppliers and contractors. The selection criteria check on compliance (including child and forced labour and occupational health and safety) of the suppliers and vendors. GFCL EV has a digital contract labour management system that documents and records all activities from their selection to work completion.
Supply Chain
The company undertakes the following process for their approved suppliers for Raw Materials & Packaging Materials: Onsite audit once in two years for approved vendors of raw materials, packaging materials and operations; vendor premises, their records and facilities are checked with respect to environment, health and safety for their employees, contractors and visitors, based on GFL’s code of conduct. Sample records reviewed during the site visit were aligned to IFC’s requirements related to child and forced labour and occupational health and safety.
PS3: Resource Efficiency and Pollution Prevention
Aligned with its sustainability policy, the company is implementing various initiatives to reduce energy and water consumption. Based on annual energy and water audits the company implements resource efficiency projects in its plants. The company regularly monitors resource consumption i.e., water and chemical consumption, electricity and waste generation.
Resource Efficiency
GFL has set specific commitments, goals, and targets with defined timelines as part of their Net Zero Roadmap. GFL aims to achieve Net Zero emissions by 2050, with a more immediate target of reducing our Scope 1 and 2 emissions to Net Zero by 2040. Additionally, GFL is committed to involving their supply chain in this vision, ensuring they align with the Net Zero goal by 2050. In the next five years, GFL plans to increase the renewable energy usage by 10-20% and reduce waste landfilling and incineration by 10%, based on the 2021 baseline Air and Noise Emissions. At present the company has a 25% share of renewable energy sourcing through the national grid.
GFCL EV does not consume any fossil fuels to generate electricity or steam. Electric power from GIDC grid is the main source of energy used for operations. Diesel generators are only used as emergency back up to maintain safe conditions during any power outage. Steam produced by GFL’s coal-based boiler at their Jolva site, is supplied to GFCL EV for product drying.
Air and Noise Emissions
There are no major air emissions / pollution from the company’s operations as the plant does not burn any fossil fuels except for backup power generation. Air dispersion modelling was carried out at the EIA stage using AERMOD to understand plume behavior and ground level concentrations due to process emissions of particulates, sulphur dioxide, nitrogen oxides and carbon monoxide. Based on this study, the incremental ground level concentrations were predicted to be below the ambient air quality standards and WBG General EHS standards on air quality. A vulnerability analysis was also carried out in the EIA on the maximum credible accident scenario and worst-case scenario to understand community exposure and vulnerability due to chemical releases. Recommendations were proposed to avoid and control the risk outcomes.
GFCL EV monitors process stack & workplace emissions and ambient air quality at plant boundaries monthly. The emission monitoring reports indicate compliance with applicable legal requirements and WBG General EHS Guidelines. Emission control systems on manufacturing process stacks, such as scrubbers, blowers, sprinkling system, bag filters, etc. have been provided in GFCL EV.
GHG Emissions
The Company calculates its GHG emissions (Scope 1, 2 and 3) which are aggregated with those of the Sponsor’s other subsidiaries and published in its Integrated Annual Report (https://www.gfl.co.in/upload/pages/GFCL-Integrated_Annual_Report_2023-24.pdf).
The Company set up production capacity of 2,700 tons of Li-ion battery components at its India facility in 2024, leading to Scope 1 & 2 emissions of 9,663 tCO2e. By 2029, production capacity at the India facility will expand to 152,100 tons of components, with expected Scope 1+2 emissions of 544,354 tCO2e per year.
The company implements process and emission control measures to minimize GHG emissions. GFCL EV has also adopted targets towards neutralizing the remaining emissions through carbon offset initiatives, including promoting afforestation projects based on tree plantation initiatives The company does not use refrigerants that have been phased out.
The company will (ESAP #6) prepare inventory and report on GHG emissions under Scopes 1 and 2 specific to GFCL EV operations using internationally accepted methodologies.
Water Consumption and Wastewater Management
The company receives water from GIDC and has large capacity reservoirs built on site to store the raw water which is used post treatment. The total water requirement of GFL and GFCL EV is about 2713 ton/day. Company has installed a rainwater harvesting system along with other initiatives such as utilisation of ultrafiltration and reverse osmosis reject water in cooling towers, chilled water circulation through secondary pump, installation of lower head capacity pumps, installation of variable frequency drive (VFD) systems in process plants, etc.
The company has developed wastewater treatment plants for domestic sewage as well as process effluent. GFCL EV treats 500 ton/day for primary & high fluoride content in its ETP (A) using Fenton’s reaction method and sends the treated effluent for final treatment to ETP (B) of GFL (3000 ton/day). The combined final treated effluent is sent to GIDC’s Central ETP (CETP) for deep sea discharge through GIDC’s pipeline. GFL’s effluent is reported to be less than 4% of total industrial effluent being discharged by GIDC.
The monitoring reports for the combined final treated effluent indicate compliance with the local legal limits as well as the limits specified in the WBG General EHS Guidelines and the Sector guidelines for Large Volume Inorganic Compounds.
Domestic wastewater is treated by the sewage treatment plant and released to the public sewage system for further treatment. Hazardous waste sludge is produced from the treatment systems, which are removed regularly and collected by State licensed agencies. All monitoring results were noted to comply with the national emission standards and consent to operating conditions.
To prevent any contaminated stormwater leaving the plant by entering the stormwater drains, the company has provided three types of precast reinforced cement concrete stormwater drain channels, with 3 sluice gates on all exit points. These gates are closed during normal operations. During Monsoon on rainy days, the HSE team keeps vigil and monitors and records pH, every 2 hours. Sampling is also conducted once a day to monitor any other contamination. Contaminated rainwater from stormwater drain is transferred to ETP Guard Pond (capacity 2000 KL), via nearby effluent pits / chambers from where the contamination is detected.
Waste Management
The company generates different categories of non-hazardous and hazardous waste from their operations at Jolva. In 23-24, the company reported hazardous waste disposal by landfilling (586 MT), co-processing / incineration (487 MT) and reutilization through recycling (761 MT) resulting in 68% of the hazardous waste is co-processed and recycled.
The company has developed waste management procedures including a system of appropriate sorting, handling, storage and disposal which are consistent with applicable legal and IFC PS requirements. All hazardous and non-hazardous wastes are collected for disposal by authorized service agencies specializing in each type of waste. At the project site, all hazardous materials were noted to be properly labelled and stored in the designated areas.
Efforts have been made by the company to convert hazardous waste such as (spent) hydrochloric acid into byproducts through in-house research and regulatory approvals.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety / Life and Fire Safety
The company follows a safety-by-design concept in planning and designing infrastructure, equipment and technology. Management of Change (MOC) procedure is followed before any modification in the plant. Process safety planning is carried out along with consultation with relevant stakeholders. QRA, HAZOP and BHM studies are required for all major hazardous processes and technologies. Pre-startup safety reviews (PSSR) are carried out before commissioning using a cross-functional safety team.
Hazardous Materials Management and Safety
Storage and transport of hazardous chemicals such as AHF is one of the high-risk activities carried out by the company. QRA studies have identified low risk under credible worst-case scenario to the community in the vicinity of the plant. The location specific individual risk (LSIR) and societal F-N (frequency of event against number of fatalities) curve in the QRA study indicate that there is no unacceptable risk for communities outside of the industrial site. The site also stores and handles hazardous chemicals such as chlorine and nitrogen in small quantities for which regulatory approvals have been obtained and operational control procedures implemented by the company. Air dispersion modelling was carried out at the EIA stage using ALOHA to understand plume behaviour from various scenarios of chemical releases.
For transportation of hazardous chemicals such as AHF, the company has carried out a quantitative risk assessment based on DNV Phast and conducted a journey risk management based on the route. The study concludes that location specific individual risk (LSIR) contours for 10-1 to 10-5 per year were observed for the scenarios considered. LSIR risk contours were observed for 10-6, 10-7 and 10-8 were observed in acceptable range. Similarly, the frequency-number (F-N) curve derived in this study indicated that societal risk for the overall population exposed to AHF dispersion scenario due to leakage is below the “As Low As Reasonably Practicable” (ALARP) levels based on GIIP.
To control the risk of community exposure to AHF during its transport from Dahej facility to the Jolva facility, they have appointed a third-party competent agency to escort all chemical transport consignments, with real-time tracking and emergency response capability. Double walled MS steel ISO tankers pre-approved by PESO, with a capacity of 18 tons, are used for the transportation of AHF. Operating procedures have been developed and implemented for safe transport operations that address escort requirements, speed limits, designated halts, driver training, etc. The company has obtained public liability insurance for its onsite chemical storage and transport for handling any community compensation during emergencies.
Currently about 1 ISO tanker of AHF is required per week. Based on the company’s production plans, this frequency is expected to increase to 3 ISO tankers per week by end of 2025 and up to 10 ISO tankers per week by end 2026. The company indicated that it is also considering commencing manufacturing of AHF at the Jolva site by December 2026 to avoid the risk in its transport from Dahej.
The company will (ESAP #7) develop and implement an external communication and stakeholder engagement plan for communities around the site and along the route of hazardous chemical (AHF) transport that could be exposed to potential chemical (AHF) leak or releases.
The company will (ESAP #8) discontinue sourcing AHF from Ranjitnagar (150 km) and procure the chemical only from their Dahej plant. The procurement of AHF from Dahej will follow recommendations from the QRA for chemical transport, emergency response procedures, services of the 3rd party transport safety services and associated regulatory compliance.
Security Services
The facility has engaged third party security workers who are unarmed and are also trained in safety management and emergency response. Regular monthly training programs are conducted by the company for security workers on the standard operating procedures for their job including human rights and engagement with the communities. The total site deployment includes 6 supervisors and 22 guards in the day shift and 3 supervisors and 17 guards in the night shift. The security staff work in 8 hourly shifts.
