While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

Based on IFC’s current review of the project, there are no identified risks and adverse impacts of the project associated with the requirements of PS 5 (Land Acquisition and Involuntary resettlement), PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7 (Indigenous Peoples) and PS8 (Cultural Heritage).

This is a Category B Project under IFC’s Policy on Environmental and Social Sustainability. The proposed activities involve the large-scale installation and operation of smart meters across nine project packages in 3 districts of Rajasthan. The environmental and social (“E&S”) impacts are expected to be limited, site-specific, and reversible, and can be managed through existing mitigation measures and the application of good international industry practices (“GIIP”).

Key E&S risks and issues relevant to this Project include: (a) the adequacy of the Project SPVs’ environmental and social management arrangements, including reliance on Genus systems and capacity to supervise and ensure effective implementation of environmental, health, safety, and social (“EHSS”) requirements by subcontractors across dispersed project sites; (b) ensuring fair, safe, and healthy working conditions for direct employees and contractor personnel, with attention to labor compliance, occupational health and safety (“OHS”), prevention of gender-based violence and harassment (“GBVH”), and access to grievance mechanisms; (c) management of community health and safety risks, including prevention of accidental exposure to live electricity during meter installation, especially in dense settlements, and ensuring respectful engagement with consumers during household visits; and (d) risks related to consumer communication and stakeholder engagement, particularly the potential for resistance or complaints arising from inadequate information on the transition to smart metering.

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

Policy: The Project SPVs currently do not have standalone EHS policies. EHS management to date has been guided by the procedures and management systems of Genus, which serves as the EPC and O&M contractor and maintains its own corporate EHS policy and management system.
Genus will continue to implement EHS management in accordance with its ESMS on behalf of the SPVs.
As part of ESAP #1, Gemstar, as part of developing the Environmental and Social Management Framework(ESMF), will also develop and maintain a platform-level EHS Policy aligned with national regulations, the IFC Performance Standards, and the World Bank Group Environmental, Health and Safety (EHS) Guidelines for the nine Project SPVs. Each Project SPV will formally adopt the Gemstar EHS Policy, while Genus will continue to implement EHS management in accordance with its ESMS on behalf of the SPVs.

Environmental and Social Assessment and Management System: Genus has developed documented procedures that provide partial coverage of environmental, health, and safety issues. These procedures include: a Construction Environment Management Plan (“CEMP”), originally developed for another project geography; an Emergency Response Plan; and Standard Operating Procedures (“SOPs”) for smart meter installation, covering DT smart meters, feeder smart meters, High Tension Current Transformer (“HTCT”) and Low Tension Current Transformer (“LTCT”) smart meters, as well as single-phase and three-phase consumer smart meters. Supporting tools include inspection checklists, incident reporting formats, and key performance indicator (“KPI”) tracking for induction training and accident reporting.
As part of ESAP#2, Genus will consolidate and formalize these procedures into an ESMS proportionate to the scope and nature of project activities and aligned with national regulations, the IFC Performance Standards, the World Bank Group Environmental General Health and Safety (EHS) Guidelines, and Good International Industry Practice (GIIP) that would apply to Nine Project SPVs only. This ESMS will define policy commitments, risk assessment and management processes, roles and responsibilities, training and incident reporting requirements, contractor management procedures (including screening, monitoring, and grievance access),and emergency preparedness measures (“Genus ESMS”).
Additionally, as part of ESAP#1 , Gemstar, at the platform level, will establish an overarching Environmental and Social Management Framework that references the Genus ESMS and will set out arrangements for oversight, coordination, and reporting. This framework will define governance structures, communication channels, and responsibilities for monitoring and reviewing environmental and social performance across nine Project SPVs.
Genus will be responsible for developing and implementing the operational ESMS, while Gemstar will coordinate and oversee its application to ensure consistent implementation across all Project SPVs. Each Project SPV will adopt and rely on the Gemstar Framework and Genus ESMS for environmental and social management.

Management Program: A review of the Genus smart meter installation SOPs indicates adequate technical detailing related to installation steps and data recording, which include detailed procedures for isolating live lines during installation, consistent application of public safety controls such as barricading, warning signage, or insulated platforms in dense settlements, and systematic verification of earthing and load connections prior to commissioning. The SOP needs further update in terms of certain safety and social measures including adequate prior information and preparation, provisions for emergency response in the event of electric shock or fire .
As part of ESAP #2, Genus will update and implement Management Programs within its ESMS for Rajasthan SPVs to formalize and operationalize existing safety practices outlined in the EPC contractor’s installation SOPs .These will include Electrical Safety Procedure to define verification steps, supervisory oversight, and documentation for isolation, earthing, and back-feed prevention ; and a Public and Worker Safety Procedure focused practical measures such as safe ladder use, insulated platforms where required, and simple visual precautions in public or high-footfall areas., an Emergency Preparedness and Response Procedure addressing electrical accidents, fire, extreme weather events, and social risks such as community resistance, protests, or mob violence; a Community and Consumer Interface Procedure that establishes communication strategies for advance notification, coordination with utilities and local authorities, and safe household visits; and an Occupational Health and Labor Compliance Procedure covering transport safety, safety measures during installation, operations and monitoring; working conditions, labor compliance, gender-based violence and harassment, and contractor and subcontractor compliance with EHSS requirements.
Each procedure will be supported by checklists, reporting, and corrective action processes, and will be subject to continuous improvement through periodic audits, incident reviews, stakeholder feedback, and grievance outcomes.

Organizational Capacity and Competency: The Project SPVs maintain a lean execution team, typically limited to a Chief Project Manager and a Technical Head. Operational capacity is provided by the EPC contractor (Genus), supported by a large, subcontracted workforce engaged through manpower agencies. While Project SPVs retain overall oversight accountability, day-to-day implementation is undertaken by Genus and subcontractor personnel, including field technicians, Assistant and Junior Engineers, and divisional and sub-divisional supervisors. Genus’s head-office staff further support project management, quality control, and EHS functions.
To strengthen coordination and monitoring, as part of ESAP #3 Genus will assign one dedicated EHS Specialist for each DISCOM area (JVVNL, AVVNL, and JdVVNL). These Specialists will conduct field monitoring across all Project SPVs under each DISCOM, verify contractor compliance and implementation of the ESMS, and compile consolidated EHS performance data. Each Project SPV will designate a project representative responsible for EHS coordination, including reviewing Genus’s EHS performance reports, participating in ESMS management reviews, and ensuring that material EHS issues are escalated for management attention. Day-to-day field supervision will remain the responsibility of Genus’s site safety staff.

Monitoring & Reporting: At present, monitoring within the Project SPVs is primarily focused on technical performance and is conducted through systems and procedures established by the EPC contractor (Genus). Installation progress, meter commissioning, and data capture are tracked using mobile applications and SOP checklists, supported by photographic evidence, seal verification, and GPS-tagged records. Project SPVs oversee this process through review of contractor-generated reports and field verification. Quality in-charges from the EPC contractor conduct sample visits to confirm that installation work is carried out in line with approved SOPs and divisional and circle-level managers review field reports submitted by supervisors and technicians. Additionally, consumer communication is currently done through a brief card distributed by the EPC contractor, but this practice is inconsistent across locations and provides only limited details and typically covers meter identification numbers
Oversight of EHS aspects will be strengthened by formally capturing incidents and near misses and verifying contractor implementation of safety procedures. Under the updated ESMS (refer ESAP #2) for Rajasthan SPVs, Genus will expand monitoring and reporting to include EHS performance indicators, structured incident and near-miss registers, and verification of contractor compliance with safety procedures.
Consumer-related queries and grievances will continue to be managed by the respective DISCOMs through their established systems, while Genus will interface with the DISCOMs to address any project-related issues arising during implementation. The SPVs will review EHS, and implementation reports prepared by Genus and participate in management reviews, to maintain oversight of adherence to procedures and support continuous improvement in both technical and EHS performance.

PS 2: Labour and Working Conditions:
Human Resource (HR) Policies and Procedures: Approximately 1,158 personnel are engaged in the Rajasthan smart metering projects. Of these, 211 are directly employed by Genus and 947 are engaged through five subcontractor agencies. Most of the workforce including technicians, installers, O&M staff, security, and warehouse support are engaged by Genus and its subcontractors to deliver EPC and O&M activities for Project SPVs
Currently, the DISCOMs act as the principal employers, and Project SPVs function as the main contractors for smart meter installation and O&M in Rajasthan. Project SPVs have not yet established independent HR policies and procedures. Workforce management therefore follows Genus’ existing HR systems, which cover recruitment and induction, statutory labor law compliance, medical and accident insurance, a POSH policy and committee, a prohibition on child and forced labour, and an employee grievance mechanism. Genus also manages third-party workers through contractual arrangements requiring statutory compliance, payment of wages and benefits, and provision of PPE.
While these arrangements ensure basic legal compliance, they are not yet fully aligned with IFC PS2. Gaps include the absence of leave and holiday entitlements, transparent compensation and separation procedures, equal opportunity and non-discrimination measures, and confidential grievance mechanisms accessible to all categories of workers.
As part of ESAP #4, Genus to update its existing HR policies applicable to Project SPVs to align with IFC Performance Standard 2 and Good International Industry Practice (GIIP). The policies to include an Employee Code of Conduct setting expectations for respectful workplace behavior and a zero-tolerance approach to gender-based violence and harassment (GBVH), applicable across office and field operations, and supported by awareness and training programs. Given the limited staffing of the Project SPVs, the updated HR policies will apply to all personnel engaged under the EPC and O&M contracts with Genus and its subcontractors for the nine Project SPVs. Genus will implement and operationalize the updated HR policies across project activities, while the Project SPVs will retain oversight responsibility to ensure that the policies are adopted and applied consistently by all contractors and subcontractors

Third Party Workers: Most of the workforce for the smart meter program including technicians, installers, O&M staff, security, and warehouse support are third-party workers engaged by Genus Metering Services in its role as EPC and O&M contractor to the Project SPVs. Genus’ contractual arrangements with subcontractors require compliance with statutory labor laws (including Contract Labour Act registration, wages and benefits, ESI, Provident Fund, and Workmen’s Compensation) and provision of PPE.
While these arrangements ensure basic legal compliance, they are yet to fully align with IFC PS2, particularly in relation to systematic monitoring of contractor performance, enforcing standards on non-discrimination and safe working conditions, and ensuring consistent access to grievance mechanisms, including confidential channels accessible to all categories of workers.
As part of ESAP #2, Genus will strengthen contractor management procedures as an integral component of the ESMS for Project SPVs which. will set out procedures for (a) screening of contractors and subcontractors for legal compliance, working conditions, OHS risks, and past track record; (b) incorporation of contractual obligations on labor and EHS standards in all EPC and subcontractor agreements and regular monitoring of contractor compliance with these labor and OHS requirements; (c) periodic supervision and review of contractor performance against Project SPV requirements on labor and working conditions, including assessment of contractual relationships between contractors and their workers; (d) training for all third-party workers on labor rights, safe working conditions, respectful workplace behavior, and GBVH prevention; (e) implementation of corrective actions for any identified gaps, with clear timelines for resolution; and (f) ensuring that grievance mechanisms established by the Project SPVs are accessible to contractor and subcontractor personnel, including confidential and anonymous reporting options

Occupational Health and Safety: The Project SPVs do not yet have an independent OHS framework. At present, OHS practices are governed by the EPC and O&M contractor, Genus, whose existing framework, and SOPs apply to smart meter installation and related activities. These SOPs cover basic requirements such as provision of PPE (e.g., insulated gloves, helmets, safety shoes, and belts for pole work), tool safety, shutdown and work permit requirements, and digital reporting through the WFM application. Training is provided through induction sessions and toolbox talks.
The review indicates that several aspects of OHS are not yet addressed in existing contractor-led procedures. Gaps include inconsistencies in electrical safety practices, insufficient safeguards for work at height, limited public safety measures during installations in residential, commercial, and street-side locations, where work often takes place in close proximity to pedestrians and traffic, minimal emergency preparedness,
Smart meters and related equipment are stored in a central warehouse leased directly by the EPC contractor. Installers and subcontractors collect meters from this warehouse and return unused meters after fieldwork. The warehouse typically has 6-10 staff on site, including supervisors, storekeepers, and handling/security staff. Fire hazards are moderate and relate mainly to the storage of packaging materials (cardboard, plastic wrap, pallets), unsafe electrical wiring practices (such as overloaded extension cords, taped joints, and improvised connections), While the warehouse holds a Fire No-Objection Certificate (“NOC”), there is no systematic monitoring of its validity or of the adequacy of fire safety systems, such as suppression equipment, evacuation provisions, or the availability of trained fire safety personnel on a 24-hour basis. Any future field warehouses are also not yet covered under a consistent fire safety framework.
As part of the ESMS (ESAP #2), Genus will update and strengthen its existing EHS plan and incorporate it within the consolidated ESMS for Project SPVs. The updated plan will serve as the applicable OHS plan for project activities, which the Project SPVs will reference and maintain oversight. The updated plan will include a) systematic hazard identification and risk assessment, strengthened safe work procedures (electrical isolation, earthing verification, barricading, ladder safety), public safety controls, and emergency preparedness for electrical accidents, fire, and extreme weather. Training and awareness programs will be expanded for all categories of workers, including third-party contractors, and structured processes for incident reporting, investigation, and corrective action will be institutionalized and b) Life and Fire Safety (L&FS) framework/guideline, commensurate to the risk, prepared by a suitably qualified L&FS professional. This framework will be aligned with local building codes, fire department regulations, and the National Building Code (“NBC”) 2016, and customized for both central and field warehouses. At a minimum, it will cover fire detection and suppression systems, emergency exits, evacuation drills, training of warehouse personnel, electrical safety (including regular inspection of wiring and elimination of unsafe practices such as taped joints or improvised connections), and periodic review of Fire NOC validity and compliance.
In addition, the Project SPVs will establish provisions for the collection and reporting of OHS data, including Lost Time Injury (“LTI”) indicators. OHS performance will be tracked through defined indicators such as training coverage, incident reporting, inspections, and corrective action follow-up, with regular monitoring and management review to ensure continuous improvement.

PS 3:Resource Efficiency and Pollution Prevention:
Smart meter installation and O&M activities are expected to have a limited direct environmental footprint. The main sources of environmental interaction include packaging waste from new meters, fuel consumption and associated emissions from transport vehicles, and localized air and noise emissions from backup diesel generators used at offices and warehouses. Waste streams primarily comprise thermocol, cardboard, and plastic packaging, as well as used oil from diesel generator(“DG”) sets. Old or displaced meters are handed over to the respective DISCOMs, which retain ownership and responsibility for their reuse, storage, or disposal; therefore, the Project SPVs and EPC contractor do not directly manage e-waste.
Warehouses leased by the EPC contractor operate with basic fire safety NOCs, but environmental housekeeping measures such as segregation of packaging waste, s are not consistently applied. The absolute GHG emissions associated with Project SPV operations are expected to be low and are estimated at approximately 1,329,883 tCO2e/year.
Used oil (from the back-up diesel generator maintenance) will be disposed of through authorized recyclers while old meters will be returned to DISCOMs. As part of its ESMS for Project SPVs(refer ESAP #2), Genus will develop waste management plan for proper segregation, storage, collection, and disposal of waste. Minor, temporary emissions may occur during installation and, at warehouses, from DG sets used during power outages. While such use is expected to be intermittent, Project SPV and Genus will ensure that deploy DG sets comply with emission and noise standards stipulated by the Central Pollution Control Board.

PS 4: Community Health Safety and Security
Smart meter installation is undertaken at consumer premises and on distribution infrastructure located within residential and commercial areas. SOPs presently focus on technical installation and commissioning steps. Provisions for community health and safety are limited, as procedures for barricading or signage in public areas, and advance communication with consumers are not yet formalized. Emergency preparedness measures for electrical accidents, fire, or consumer resistance are also not systematically included in current procedures.
Community interface during installation is managed directly by installers and supervisors. At present, there are no formal procedures either at the Project SPV or Genus level to guide respectful engagement with households. Field-level issues such as restricted access or consumer objections, are reported to the respective DISCOMs as part of routine implementation updates. While DISCOMs operate consumer grievance cells, these mechanisms are external to the Project SPVs/Genus; therefore, any consumer-related issues observed during installation will continue to be routed to the DISCOMs
As part of the ESMS (refer ESAP #2), the Genus will establish a Community Health, Safety and Security Management Plan aligned with IFC PS4 and Good International Industry Practice. This will include: (a) Public safety measures during installation, including coordination with DISCOMs for consumer notification, barricading, warning signage, and safe ladder/insulated platform use in dense settlements’.(b) Emergency preparedness and response protocols covering electrical accidents, fire, and community resistance or mob incidents, with clear coordination mechanisms with local authorities (DISCOM grievance cells, police, fire department),(c) Training for field teams on respectful behavior, GBVH prevention, and conflict management when interacting with consumers and communities.

At present, stakeholder engagement is managed by the EPC contractor on behalf of the Project SPVs. Activities include consumer surveys to inform households about meter installation, distribution of awareness cards explaining smart meter use and providing customer service helpline numbers, and grievance handling through DISCOM-operated grievance cells. Installers and supervisors also engage directly with consumers during installation. While these measures provide a basis for consumer outreach, they are not yet formalized under an Project SPV-led Stakeholder Engagement Plan (SEP), and engagement activities are not systematically documented. Engagement with external stakeholders such as local authorities or community representatives is undertaken on an as-needed basis. A dedicated Project SPV-level grievance mechanism accessible to all stakeholders has not yet been established.
As part of the ESMS for Project SPVs(ESAP #2), Genus will develop and implement,a SEP and a Grievance Mechanism (“GM”) aligned with IFC PS1. The Project SPVs will reference these instruments and maintain oversight of their implementation. SEP will establish structured processes for communication with consumers, local authorities, and other stakeholders, including advance notification, sharing, consultation, and documentation of feedback. The GM will provide accessible channels for consumers, workers, and community members to raise concerns related to installation and O&M activities. Grievances will be received, recorded, and escalated through the EPC contractor, with oversight from the Project SPVs, and resolution tracked against defined timelines. Coordination with DISCOMs will continue for issues under their mandate, such as billing or meter accuracy.
The SEP will also include a Consumer Engagement Program (“CEP”) to raise awareness on smart meters, address consumer concerns, and direct them to appropriate support channels. Since technicians and installers are the primary household interface, the Worker Code of Conduct (ESAP #4) will integrate provisions on respectful consumer engagement, grievance referral, and adherence to engagement protocols.

Company: Gemstar Infra India Private Limited
Point of Contact: Charmy Bhatt
Title: AVP – Legal & Cosec
Telephone Number: +91 022 3540 3071
Email: compliance@gemstarinfra.com
Mailing Address: Gemstar Infra India Pvt. Ltd. Meraki Arena, 901, Opposite Godrej R.K. Studios, V. N. Purav Marg, Chembur East, Mumbai - 400071
Website: https://gemstarinfra.com/

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Gemstar will establish an overarching Environmental and Social Management Framework (ESMF) referencing the Genus ESMS, and, as part of the ESMF, will develop an EHS Policy aligned with the IFC PS. The ESMF will also define governance, oversight, coordination, and reporting arrangements across the nine Project SPVs. Each Project SPV will formally adopt the Gemstar EHS Policy.	07/14/2026
2	Genus will consolidate and formalize existing EHS procedures into a comprehensive ESMS proportionate to the scope of project activities and aligned with national regulations, IFC Performance Standards, WBG EHS Guidelines, and GIIP. The ESMS will define policy commitments, risk management processes, training, incident reporting, contractor management, and emergency preparedness.	10/12/2026
3	Genus will assign one EHS Specialist for each DISCOM area (JVVNL, AVVNL, JdVVNL) to monitor ESMS implementation, verify contractor compliance, and consolidate EHS performance data. Each SPV will designate a Project Representative for EHS coordination and management review participation.	10/12/2026
4	Genus to update its existing HR policies to align with IFC PS2 and GIIP. The policies will apply to all Genus employees and, as relevant, to subcontractor personnel engaged under EPC and O&M contracts for the nine Project SPVs. The Project SPVs will retain accountability for ensuring its adoption and effective implementation across project activities	07/14/2026