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

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012), with potential limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures.
The key Environmental and Social (E&S) issues associated with the proposed equity investment relate to: (i) Update of company’s existing ESMS at the corporate level to ensure consistent E&S oversight across all projects, Special Purpose Vehicles (SPVs), and any future commercial or non-warehousing development activities; (ii) consistent management of labor and working conditions (for direct and third party workers) including occupational health and safety (OHS) standards, prevention of gender-based violence and harassment (GBVH), provision of accessible grievance mechanisms and compliance with national labor laws consistent of IFC PS 2 requirements; (iii)implementation of appropriate waste management practices, along with the management of fugitive dust emissions from construction activities, emissions from diesel generator (DG) sets, and noise generated during construction operations; and (iv) community health and safety

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 company has a group level Environmental, Social and Governance (ESG) Policy that sets out the ESG approach for the group entities including NDR InvIT Managers Private Limited, NDRWPL, NDR Smart, and its Special Purpose Vehicles (SPVs). For operational assets, the policy establishes corporate-level and operations-oriented commitments, with a focus on areas such as energy efficiency, safety protocols, and community engagement for operational assets. For construction stage the policy mentions compliance with statutory clearances, use of safe construction materials, and measures to reduce environmental impacts. Drawing on IFC’s familiarity with the sponsor group from the earlier InvIT investment, NDR Smart will update the ESG policy and the associated procedures including consolidation of existing practices for business operations under its ambit, i.e warehouse construction under various SPVs and warehouse management through PM. The update will include additional detail on systematic E&S risk and impact assessment, structured stakeholder engagement, and processes for continuous improvement, consistent with ESAP #1.
Identification of E&S risks and impacts: The company uses an ESG checklist-based tool to identify environmental and social (E&S) risks for its operations. The checklist covers core compliance areas and provides a basic framework for recording site-level observations and risks . Site selection includes identification and initial screening of potential sites. The company has warehouses ranging between 6,688 and 185,804 sqmt. Factors such as location, accessibility, and surrounding land use, indigenous people lands, cultural heritage are considered while siting of the warehouse. Additional studies, such as topographical and geotechnical surveys, are carried out to assess physical conditions. These inputs inform overall feasibility before site selection. Following site selection, land purchase process starts which includes: (i) verification of ownership through review of land records; (ii) assessment of encumbrances such as mortgages, disputes, or restrictions; (iii) negotiation of terms with landowners and tenants/users and (iii) legal transfer and registration of the land parcel. Most of the land purchased is in industrial areas or on land not currently used for cultivation. As part of the ESMS update, NDR Smart will consolidate and formalize its existing land procurement procedure to confirm that land procurement is voluntary and market-based, with ownership and encumbrances verified prior to acquisition. The procedure will also include a framework to identify and proportionately address any informal land uses that may be affected by the transaction, even where PS5 is not formally triggered. The approach builds on IFC’s previous investment and will be further integrated into NDR Smart’s ESMS to ensure consistent and transparent application across all future SPVs under its corporate oversight.
Once completed, the land parcel is formally integrated into the project planning process. Subsequently a third-party consultant is hired to prepare the site plan- including local building requirement such as local building byelaws, NDR own requirement, relevant NBC requirement, 41001:2018 Facility Management Systems (FMS). Prior to construction, statutory approvals are applied for. These generally include: (i) Land use and zoning permissions; (ii) Environmental clearances, if built up area is more than 20,000 sq m; (iii) Consent to establish from the respective State Pollution Control Board (SPCB); (iv) Building plan approvals; and (v) Safety-related permits, such as fire and structural compliance. Post construction, operation related permits like Occupancy certificate, Fire- No Objection Certificate (NOC), NOC for borewell (if applicable) are obtained by NDR APML and the warehouse is transferred to the NDR InvIT. Once the SPV is transferred, NDR InvIT manages only the common infrastructure and services of the warehouse through NDR AMPL. Tenants at the warehouse are responsible for their own operations, including equipment, E&S management, and compliance with laws and standards, as applicable such as shop and establishment registration, contract labour licenses, and fire NOCs where hazardous or flammable materials are stored in the warehouse.

Environmental and Social Management System: The company has established operational procedures covering key phases of its project cycle, including land procurement and warehouse operations, which collectively form the basis of its environmental and social management approach. Building upon these existing E&S elements and the systems the company will integrate and update existing policies, operational checklists, grievance mechanisms, and contractor management procedures into a an Environmental and Social Management System (ESMS) for consistent implementation across warehouse construction and operations stages. The ESMS will cover land procurement, construction-phase environmental, health, and safety (EHS) management, and oversight of operational warehouses, while ensuring alignment with the IFC Performance Standards (PS), World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines, and Good International Industry Practice (GIIP). The consolidated ESMS will include, at a minimum: (a) consolidation of the existing EHSS policy within the corporate ESMS to ensure consistent implementation across all project phases, SPVs, and future developments; (b) strengthened E&S screening procedures for new sites and asset acquisitions, including assessment of any; and procedures for environmental and social risk assessment, including due diligence and environmental impact assessment (EIA) where required by regulation, (c) hazard identification and risk assessment (HIRA), compliance tracking, and mitigation planning across construction and operational phases ;(d) clearly defined EHS roles, responsibilities, and competency requirements for staff and contractors, supported by structured training programs and standard operating procedures (SOPs) for high-risk activities and site supervision;(e) health, safety, and environmental (HSE) plans for construction and operations, with procedures for incident reporting, investigation, corrective action, and lessons learned; (f) on-site and off-site emergency preparedness and response proportionate to the scale and nature of operations; (g) a contractor management framework addressing EHS and labor compliance, induction and capacity building, supervision, and periodic performance evaluation;( h) stakeholder engagement procedures and a consolidated grievance mechanism accessible to workers, contractors, and communities, building on enhancements initiated under the previous investment; and (i) a management review process informed by internal audits, monitoring results, incident investigations, and stakeholder feedback to support continual improvement. The ESMS will be applicable across all warehousing operations, Special Purpose Vehicles (SPVs), and any future commercial or non-warehousing development activities under its corporate oversight.

Company currently does not have any commercial or residential projects; however, as and when future commercial or residential development projects are considered for development, the ESMS will be updated to meet such requirements. Additionally, ESMS will have provision for separate third party ESDD every time a new commercial or residential project is considered for investment. As part of ESAP #1, NDR Smart will also update and implement site-specific Environmental Management Plans (EMPs) for each warehouse site. These EMPs will address resource efficiency and pollution management including air emissions, noise, and waste in accordance with national legislation, IFC Performance Standards, and the WBG General EHS Guidelines

Organizational Capacity and Training: Company’s corporate structure includes key departments reporting directly to the Chief Executive Officer (CEO): Head of projects, head of legal and compliance, head of Human Resources (HR) and administration, and four zonal heads. Each zonal head is expected to oversee a team comprising project managers, EHS staff, vendor management and procurement staff, Mechanical, Electrical and Plumbing (MEP) lead, and a maintenance team. The actual staffing levels are adjusted depending on the number of active projects in the zone.
During construction, site level staffing typically includes a project manager, construction engineer, site in-Charge, construction supervisor, junior engineer, MEP representative, and an EHS representative (may cover multiple sites). For operational sites, the APML team generally includes one EHS staff and one-two maintenance staff (depending upon the size) per site.
At present, the company has limited in-house Environment, Health and Safety (EHS) and social capacity, with one EHS coordinator covering the southern region. Recruitment of a Corporate Head of EHS/Safety is underway. To strengthen organizational capacity under ESAP #2, NDR Smart will expand its EHS function by appointing dedicated Environmental, Health, and Safety (EHS) specialists at the zonal level (North, East, West, and South) and ensuring adequate EHS staffing at clusters/ sites. In addition, the company will require contractors to deploy trained EHS staff and will monitor their compliance with E&S requirements.

Emergency Preparedness and Response: The company will have provision to develop and implement an on-site Emergency Preparedness and Response Plan (EPRP) for the sites, in line with the framework developed as part of the ESMS (refer ESAP#1). The company will ensure that EPRP is developed and implemented (separately for construction stage and operations stage) for all SPVs. The EPRP will outline site-specific emergency scenarios, with a primary focus on construction-phase risks such as work-at-height, electrical and fire hazards, equipment or vehicle accidents, and extreme weather events. Once sites are transferred to the InvIT, through NDR AMPL, the operations stage EPRP will address operational risks, including warehouse fire safety, maintenance incidents, and community-related events. Tenants will manage emergency preparedness within their own operations, while NDR AMPL will coordinate on common infrastructure and site-level requirements to ensure effective emergency response.

Monitoring & Reporting: As part of ESMS implementation and review, NDR Smart will establish a structured monitoring and reporting system covering all active construction sites. Site-level teams and contractors will provide periodic updates to the Corporate EHS team on safety training, inspections, incident reporting, and grievance resolution. Consolidated progress reports will be reviewed by the Corporate EHS Head and senior management.
Biannual reviews will be conducted jointly by the Project Head, Zonal Head, and Corporate EHS team to evaluate implementation of EHS plans, consider audit and inspection findings, and define corrective measures to address any identified gaps or non-compliances. Supplementary monitoring may be undertaken, as needed, to verify compliance with applicable regulations and standards. Performance findings will be used to inform management decisions and to strengthen the ESMS on an ongoing basis.
As part of ESAP #3, NDR Smart will commission a third-party review of ESMS implementation at construction sites within eight months of its roll-out. The review will be designed primarily as a capacity-building exercise, supporting the company in strengthening contractor management, site-level EHS practices, and corporate oversight systems. The findings will be used to identify lessons and enhance training, supervision, and ESMS implementation processes. A corrective action plan (CAP) will be developed to address any identified gaps, followed by one follow-up review within the following year to verify closure of actions and assess institutional learning. The need for any further external reviews will be determined based on performance outcomes and the evolving risk profile of construction activities

PS 2: Labour and Working Conditions:

The company employs eight staff at the head office and two staff at each cluster level. Most of the employees are actually employed on the rolls of NDR AMPL, which currently employs 33 staff at the head office, 4 at the cluster level, and 154 at the site level AMPL staff get associated/ mapped to the projects during the construction stage itself and are responsible for site-level supervision; further, they continue to support with maintenance post asset handover to NDR InvIT. During peak construction periods for each site (depending upon the project site), the number of contract workers typically ranges from 250 to 300.
Human Resource (HR) Policies and Procedures: The company has an employee handbook which has certain key elements which are consistent with IFC PS 2 requirements. The HR policy is mostly aligned to the applicable national labour law and addresses onboarding probation, confirmation, termination, remuneration, and employee benefits (e.g., medical insurance); non-discrimination, equal opportunity, and prevention of harassment. The employee handbook applies to all direct employees and also contains a section on code of conduct including harassment-free workplace, conflict of interest and non-competition. As part of ESAP # 4, the HR policy will be further updated in line with IFC PS 2 requirement to: (a) update the existing provisions to bring more clarity on the HR policy implementation; and (b) include aspects such as: child labour, forced labour; recruitment process, overtime (OT); retrenchment policy, collective bargaining and freedom of association; Grievance mechanism (GM) with provision for multiple access channels including anonymity, protection again reprisal risk and recourse to law; detailed grievance mechanism under prevention of sexual harassment (POSH) with emphasis on survivor centric approach.

Working Conditions and Terms of Employment: The company provides appointment letters to its employees that clearly set out their terms and conditions of employment, including role and designation, date of commencement, probation and confirmation periods, working hours and leave entitlements, remuneration and benefits, notice period, and reference to applicable company policies.
To promote consistency and fair treatment across the workforce, NDR will require contractors to provide their workers with written contracts that set out clear terms and conditions of employment. This will be implemented through the Contractor Management System (ESAP #5), which will establish procedures for selecting contractors, embedding fair labour and environmental and social requirements in contracts, and monitoring contractor compliance.
Grievance Mechanism (including Prevention of Sexual Harassment): Direct employees have access to a grievance mechanism (GM) with escalation channels up to senior management. Under the ESMS, this mechanism will be consolidated and strengthened to ensure consistency across the business operations including NDR AMPL, and all SPVs. As part of ESAP# 4, the updated GM will be extended to all categories of workers, including third-party and contract workers engaged during construction and operations. It will incorporate multiple access channels, including options for anonymous and confidential reporting, and establish clear procedures for communication, reporting, and tracking of grievances. The grievance mechanism will be communicated to all workers and contractors, and its implementation will be monitored by the Corporate EHS and HR teams, with periodic review by senior management to ensure accessibility, timely resolution, and continuous improvement The company has a grievance mechanism (GM) in place for its direct employees, with defined escalation channels up to senior management. Under the corporate ESMS, this mechanism will be consolidated and strengthened to ensure consistency across the business operations including NDR AMPL, and all SPVs.
As part of ESAP #4, the updated GM will be extended to all categories of workers, including third-party and contract workers engaged during construction and operations. It will incorporate multiple access channels, including options for anonymous and confidential reporting, and establish clear procedures for communication, reporting, and tracking of grievances. The mechanism will include gender-based violence and harassment (GBVH)-sensitive and survivor-centric pathways, consistent with the company’s Prevention of Sexual Harassment (PoSH) policy.
The corporate HR policy will specify the roles and responsibilities of the Internal Committee (IC), ensuring access for third-party workers, clear investigation and resolution procedures, and periodic training and awareness programs for employees, contractors, and IC members. The grievance mechanism will be monitored by the Corporate HR and EHS teams, with periodic review by senior management to ensure accessibility, timely resolution, and continuous improvement.
Worker’s Accommodation: Conditions in worker camps were found to be inadequate in some cases. Issues observed included poor hygiene, limited waste clearance, insufficient sanitation and bathing facilities, lack of drinking water, and no fire safety equipment. In response, the company has drafted a Worker’s Accommodation guideline to improve living conditions and strengthen health, hygiene, safety, and vector-control measures. The guideline will be updated in line with EBRD and IFC guidelines on labour accommodation and integrated into the ESMS under ESAP #1 and will be implemented across all construction sites. Implementation will be supported by regular monitoring and reporting by the Corporate EHS team, including periodic site inspections and reviews of accommodation conditions to ensure compliance with the policy and continual improvement of standards.

Third party workers: The company engages third-party workers through manpower and service contracts for construction, security, housekeeping, and related activities. In certain cases, these contracts are further subcontracted. While contractors are required to comply with applicable labor and occupational health and safety (OHS) regulations, oversight and documentation are not yet fully systematized. Therefore, as part of ESAP #5, Company will update and formalize its contractor oversight practices under the corporate ESMS to ensure consistent management of contractor performance across all sites and SPVs. The updated procedure will include:(a) incorporation of consistent Environmental, Health, Safety, and Social (EHSS) requirements—covering child and forced labor, non-discrimination, terms and conditions of employment, grievance mechanisms (GM), and other applicable provisions—within all contractor agreements, commensurate with the scope of work;(b) structured onboarding and induction for contract workers on EHSS and site-specific requirements;(c) periodic training on EHSS, grievance mechanisms, and Prevention of Sexual Harassment (PoSH) provisions; and(d) regular EHSS reporting and performance monitoring of contractors. As part of ESAP#6, the company will undertake third party labour audit for a sample of two under- construction site to assess gaps against applicable regulations and IFC PS requirement. The company will agree to the CAP and as part of internal capacity building, implement agreed CAP for upcoming sites. Findings from third party audit will be used to further update the contractor management system and implementation strengthened
Occupational Health & Safety: The company has recently drafted a Health and Safety Site Management Plan (HSSMP) intended to apply across construction and operational activities, including contractors, subcontractors, and third-party vendors. The plan defines roles and responsibilities for site management and contractors, and sets out requirements for hazard identification and risk assessment, worker induction and training, use of personal protective equipment (PPE), toolbox talks, safe work practices, and emergency preparedness. It also includes a permit-to-work system for high-risk activities such as hot work, working at height, lifting operations, confined space entry, and electrical works, as well as procedures for incident reporting, corrective action, and emergency response. Initial implementation has started at selected construction sites, where PPE use, toolbox talks, and safety inductions were observed. However, application was not yet consistent across all sites, and documentation of hazard assessments and permit-to-work systems was limited. The HSSMP will be integrated into the company’s corporate ESMS and made a binding requirement under all relevant contracts and subcontracts. The company will ensure dissemination of the plan to employees, site-level management, and contractors, supported by training and awareness programs. Implementation will be reinforced through inclusion in site-level management systems and consistent monitoring and reporting across all projects. Compliance with these requirements, including applicable statutory obligations, will be verified through a third-party review of ESMS implementation covering Environmental, Health, Safety, and Social (EHSS) aspects (refer to ESAP #3)

PS 3: Resource Efficiency and Pollution Prevention:

At the construction sites, the main sources of pollution include fugitive dust emissions from construction activities, emissions from diesel generator (DG) sets, and noise from construction operations. The construction sites will comply with existing regulatory requirements under the Consent to Establish (CTE) from the State Pollution Control Boards and with the environmental monitoring regime that will form part of the Environmental and Social Management System (ESMS) being developed under ESAP #1. Environmental monitoring will include ambient air quality and noise monitoring in line with the National Ambient Air Quality Standards.
Hazardous waste generated during construction primarily consists of used oil and lubricants from DG sets and machinery, along with empty containers and residues of paints, thinners, solvents, adhesives, and chemical cleaning agents. The company has prepared a Standard Operating Procedure (SOP) for Waste Segregation applicable to operational sites managed for NDR InvIT. The SOP outlines requirements for source-level segregation, color-coded bins (including red bins for hazardous waste), safe storage, use of PPE during handling, and disposal through authorized vendors, as well as roles and responsibilities for monitoring, training, and reporting. Implementation has started at operational sites visited , including the use of color-coded bins and safe storage. Implementation will be further strengthened through proper disposal practices, training, capacity building, and integration into the ESMS to support consistent application across all projects For construction sites, the company will develop a waste management plan addressing segregation, storage, collection, and disposal of waste as part of the ESMS under ESAP #1. All hazardous waste generated during construction will be disposed of through authorized vendors in compliance with applicable regulations.

PS 4: Community Health Safety and Security

Given that NDR Smart’s projects are located near peri-urban or semi-rural settlements, construction activities present potential risks to surrounding communities, including dust, noise, and traffic from heavy vehicle movement, . As part of the ESMS under ESAP #1, NDR Smart will prepare and operationalize site-specific Emergency Preparedness and Response Plans (EPRPs),
In relation to warehouse, day-to-day warehouse operations, including tenant-specific safety management, are the responsibility of the tenants, NDR Asset Management’s role is limited to managing common utilities, including the fire hydrant system and related infrastructure in common areas. Tenants enter into lease agreements once warehouse construction is completed, and these agreements remain in place after transfer to the InvIT and NDR AMPL continues to manage only the common infrastructure and services. From safety aspect, the compnay will develop a Life and Fire Safety (L&FS) framework as part of the ESMS (refer ESAP #1). The framework will be aligned with the National Building Code (NBC) 2016, and local fire authority regulations. The framework will be used to develop site specific L&FS plans and will be included as part of ERPR. Company’s corporate office, branch offices, warehouse and construction sites will hire unarmed security personnel through external agency. As part of ESMS development (refer ESAP #1), the company will develop and implement a security management plan guided by the principles of proportionality and good international practice. The plan will include procedures to assess risks related to security arrangements, and to guide the hiring, rules of conduct, training, equipping, and monitoring of security personnel

The company has a Corporate Social Responsibility (CSR) Policy that outlines commitments to community initiatives. At present, stakeholder engagement is largely limited to statutory consultations required for permits and approvals, and there is no formal Stakeholder Engagement Plan (SEP) in place. As part of the ESMS consolidation (refer ESAP #1), NDR Smart will formalize and strengthen stakeholder engagement procedures proportionate to the scale and nature of its project activities These procedures will define how NDR Smart L and its contractors engage with nearby communities during construction on potential impacts such as traffic movement, noise, dust, and labor accommodation, and how information will be disclosed on project timelines and mitigation measures. Stakeholder engagement and grievance management will therefore be implemented as integrated components of the ESMS, ensuring coordinated communication, documentation of stakeholder feedback, and continuous improvement in engagement practices.

Company: NDR Smart Spaces Private Limited
Point of Contact: Raj Srinivasan/Sandeep Jain
Title: CEO/CFO
Telephone Number:+91 9840150686/ +91 9323392777
Email:raj@ndrwarehousing.com/sandeep@ndrwarehousing.com
Mailing Address Old No. 56, New No. 79, Bazullah Road, T. Nagar, Chennai, Tamil Nadu 600017, India
Website www.ndrwarehousing.com

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	NDR Smart will consolidate and operationalize its corporate-level Environmental and Social Management System (ESMS), to ensure consistent application across all SPVs and any future commercial or non-warehousing development. The ESMS will include procedures for site screening, E&S risk assessment, construction-phase EHS management, contractor oversight, stakeholder engagement, and grievance management, aligned with IFC PS and WBG EHS Guidelines. Additionally, ESMS will have provision for separate third party ESDD every time a new commercial or residential project is considered for investment	06/30/2026
2	NDR Smart will appoint dedicated Environmental Health and Safety (EHS) specialists, with at least one assigned to each zone (North, East, West, South) and additional staff at site level. Contractors will also be required to maintain adequate EHS personnel at construction and operation sites to ensure compliance with national regulations and IFC Performance Standards.	04/30/2026
3	Commission a third-party review of ESMS implementation covering Environmental, Health, Safety, and Social (EHSS) , contractor management system aspects across representative construction sites; prepare and implement a Corrective Action Plan (CAP) to address identified gaps	12/31/2027
4	NDR Smart will review and update the Employee Handbook to align with IFC Performance Standard 2 and will include aspects such as: child labour, forced labour; recruitment process, overtime (OT); retrenchment policy, collective bargaining and freedom of association; Grievance mechanism (GM) with provision for multiple access channels including anonymity, protection again reprisal risk and recourse to law; detailed grievance mechanism under prevention of sexual harassment (POSH) with emphasis on survivor centric approach.	07/31/2026
5	Update and formalize the contractor management and oversight system under the corporate ESMS, covering EHSS requirements in contracts, onboarding and training, and periodic performance monitoring	06/30/2026
6	NDR Smart will commission independent third-party labour audit for a sample of two under-construction sites to assess gaps against applicable regulations and IFC Performance Standards.Any Corrective Action Plans (CAPs) identified through these audits will be implemented by NDR Smart for the audited sites and integrated into the management of upcoming projects.	02/28/2026