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
Environmental and Social Policy and Management Programs
NTT Group has established a Sustainability Policy in October 2022 applicable to all its country operations. The policy addresses issues related to governance, risk, and planet initiatives such as net-zero targets, transition to renewable energy, technology solutions focused on protection and regeneration of biodiversity, and circular design to reduce waste and carbon emissions. The NTT Group level obtained Ecovadis certification (international sustainability assessment platform on environmental impact, labor, and human rights standards, ethics, and procurement practices), an internationally recognized assessment platform that rates businesses' sustainability based on four key categories: environmental impact, labor, and human rights standards, ethics, and procurement practices. Data is procured from data centers across all the countries for this assessment and certification.
The NTTGDC has established an Environment, Health, and Safety (EHS) policy outlining the objectives related to the identification and assessment of impacts, health, and safety, air emissions, environmental protection, emergency response, compliance with applicable legal regulations, safe working conditions, sewage and waste management, internal and external communication which are consistent with principles of IFC PS. These policies are communicated to all employees and contractual staff and the management is committed to provide adequate resources on an ongoing basis to achieve effective and continuous E&S performance, aimed to meet IFC PS and General EHS guidelines.
NTTGDC has established certified systems based on the Plan, Do, Check and Act (PDCA) approach on quality, environment, occupational health and safety, energy, business continuity and information security management (ISO 9001, ISO 14001, ISO 45001, ISO 50001, ISO 22301, and ISO 27001 / IEC 20000). These systems are implemented in all the data centers of the Company. The Company has published a Sustainability Report in 2024 for the group level operations (https://www.nttdata.comhttps://www.nttdata.com/global/en/about-us/sustainability/report).
Based on these systems the Company has developed system operating manuals addressing regulatory requirements, risk identification and mitigation measures. Going ahead, all new DCs (supported by IFC’s investment) will comply to a minimum gold standard certification under Indian Green Building Council (IGBC). The Company has developed a Green Building Manual, addressing requirements to be fulfilled for DCs compliant with IGBC norms, including screening for site selection.
The Company, as included in ESAP #1, will develop an overarching E&S Management System document, collating all its existing E&S policy and management practices to demonstrate alignment with the elements of IFC PS. The ESMS will provide reference to consolidated construction and operation phase environmental and safety management plans and standard operating procedures. These should also address organization structure for construction, labor compliance management, contract worker accommodation, grievance management, stakeholder engagement and contractor management. The ESMS will be further strengthened to include policy, procedures as well as training on Gender based Violence and Harassment (GBVH) and grievance redressal.
Identification of Risks and Impacts
The Company identifies E&S risks and impacts at multiple stages in the development of its data centers. Before the construction stage E&S risks are identified in a threat and vulnerability assessment during the land selection and subsequently as part of the EIA studies undertaken to secure regulatory environmental clearance for the DCs.
During operational phase, the Company identifies environmental aspects and OHS risks on an ongoing basis as part of its ISO systems. 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 requirements.
The Company engages a third-party system to identify and track EHS legal compliance and has secured all the applicable approvals, clearances and permits and maintains periodic regulatory filings for its DC construction and operations. All DCs funded by IFC are presently under construction and have secured environmental clearances from respective State authorities, except for one facility that is under process. The operating DC that is being considered for reimbursement of capex, has also secured environmental clearance and other regulatory approvals as applicable.
Organizational Capacity and Competencies
The E&S organizational structure for India operations of NTTGDC, is guided by Senior Director, Safety and Security, supported by India Operations EHS Head, 2 Senior EHS Leads, and 5 EHS Officers. On construction sites of data centers, an India Construction EHS Head reports to the Senior Director, Safety and Security, and is supported by 4 Senior EHS team leads by regions, and 4 EHS specialists. Each construction site has an associated safety officer. The Senior Director, Safety and Security, reports to the Group EHS Head of NTT. The total E&S strength is 17 including construction and operations. In addition, staff are designated as emergency response team members and trained on firefighting and first aid.
Emergency Preparedness and Response
The Company has developed and documented an emergency preparedness and response plan for its operations at all data centers. The EPR plan includes natural as well as operational emergencies in the context of their data center locations. The roles and responsibilities for various teams responsible for evacuation, rescue, firefighting etc. are defined and displayed at various locations across the facilities. Fire alarm call points, evacuation route maps and hose reels have been placed at many locations. The compliance team conducts internal audits to ensure implementation of fire safety measures. Staff and workers, including construction workers (through contractors), have been trained in fire safety and the operation of fire safety equipment every month.
All data centers of NTTGDC are designed based on the National Building Code, 2017 including life and fire safety (L&FS) provisions. The L&FS system is established at all data centers including hydrant lines, water sprinklers, smoke and heat alarms, NOVAC flooding system for server and battery rooms. Periodic mock drills and audits are carried out to verify system readiness, and corrective actions are implemented. The company carries out six monthly L&FS audits at all data centers through third party agencies as well as internal resources. Corrective actions are identified and implemented based on these audits.
Monitoring and Review
The Company has also established a centralized automated monitoring system based on real time control for all operational parameters in the DCs including water, energy, DG, L&FS alarms, data security etc.
As part of the corporate EHS management, the Company monitors these key performance indicators (KPIs) such as generator stack, ambient and indoor air emissions, record of injuries / lost time incidents, L&FS measures, usage of personal protective equipment (PPE), energy and water consumption, waste generation covering construction and operations. The KPIs are reported on monthly basis to the management. All incidents are summarized and discussed in the quarterly management meeting and the teams analyse the root causes and implements corrective action. In the Company’s operations so far there have been no fatal or lost time incidents.
The Company closely monitors resource consumption i.e., water consumption, electricity (including renewable component) and chemical usage. Company monitors emissions from power generator stacks and domestic wastewater before and after treatment and the monitoring results were noted to comply with the national emission standards and environmental consent conditions.
The Company’s E&S management systems were noted to be commensurate with the scale and E&S risks and impacts of its operations; and the implementation at the project level to be robust based on virtual appraisal.
External Communication and Grievance Mechanism
The Company does not have a formal policy to receive, assess and respond to any external communication including concerns / grievances. However, the security personnel are trained to handle any communication from external stakeholders and report it to management for further action. Since the data centers do not pose a significant risk to local community, the Company has not established a dedicated grievance redress mechanism for affected communities. Except during emergencies, the Company does not require to report to local communities in proximity to the DCs.
PS2: Labor and Working Conditions
Working Conditions and Management of Worker Relationship
NTTGDC has adopted NTT’s Group policies on HR code of conduct and human rights, that are consistent with IFC PS 2 elements. Each staff receives a written contract that describes the working conditions and terms of employment, and an employee handbook is also provided.
In line with NTT Group policy on Human Rights, NTTGDC reported that it does not prohibit the freedom to associate and workers right to form and join workers organization. The Company encourages non-discrimination, diversity and inclusion, fairness and equal opportunity when engaging its on-roll staff. NTTGDC’s direct / on-roll employees are covered under group insurance policy including annual health monitoring. NTTGDC prohibits engagement of child, forced labor practices through specific contract clauses in agreements. Going ahead, NTTGDC will introduce a formal oversight system to track contract labour compliance. (Refer ESAP #2)
As of March 2025, the Company employs 4051 persons (3706 men and 345 women) in Indian DC operations of which 2491 (more than 50%) are contract workers. Additional contractual workforce is also deployed on construction sites of new DCs based on the requirement. The data center visited by IFC during appraisal engaged 670 workers (all male). The contractor has implemented an EHS system and monitors near misses and first aid cases. No lost time incidents have been reported on the construction site till date. The drinking water facility and provision of sanitation will be further strengthened to align with local regulatory norms. At project sites, construction contractors engaged by the Company organises temporary workers housing camps near the construction site on a lease basis. NTTGDC will formulate specifications for labor camp in their contract agreements.
Workers Engaged by Third Party
The Company engages multiple civil, mechanical, electrical and plumbing contractors and subcontractors during construction of DCs. During operational phase, contractual workforce is deployed for site housekeeping, maintenance and security of the DCs.
NTTGDC requires its contractors, during both construction and operational phases, to comply with national labor laws and insurance requirements, as stipulated through specific contract clauses. Contractors are responsible for ensuring full adherence to labor compliance obligations, including the implementation of a Grievance Redress Mechanism (GRM) and the provision of relevant trainings.
The Company will conduct periodic audits to verify contractors’ compliance with HR and labor regulations, the effectiveness of the GRM, and the quality and frequency of trainings delivered and take necessary corrective actions. NTTGDC will also extend the scope of its Prevention of Sexual Harassment (POSH) policy to cover all contractual workforce engaged in its data center facilities.
As indicated in ESAP #2, NTTGDC will develop a contractor management procedure as part of their ESMS (refer ESAP #1) and periodic oversight on all contractual staff, including labor accommodation guidelines for all under construction sites of DCs supported by IFC. Also, as part of this procedure, NTTGDC will conduct internal audits on EHS and Labor compliance based on terms of reference (ToR) agreed with IFC for construction sites of the investment DCs and then annually during operational phases.
Grievance Mechanism
The Company has a documented grievance mechanism under an initiative called as “Speak-Up policy” for its employees. The Company is compliant with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH) and has not reported any cases in the last year. The Company has established an Internal Complaints Committee (ICC) at corporate level having representation from all DC sites, and an external member from civil society organization working in this subject.
The grievance mechanism allows for submission of anonymous grievances based on suggestion boxes. The Company will place suggestion boxes in areas that are not monitored by CCTV. NTTGDC will make contractual workers include in related training and awareness campaigns conducted by HR department. At present, these functions are the responsibility of the respective contractors based on their agreements. (Refer to ESAP #2)
Gender Based Violence (GBV) / Sexual Exploitation, Abuse and Harassment (SEAH)
The ESMS (Refer to ESAP #1) will be strengthened to include policy, procedures as well as training on Gender based Violence and Harassment (GBVH) and grievance redressal.
Occupational Health and Safety
In addition to the OHS procedures for its staff implemented as part of ISO 45001, the Company has also established internal guidelines on High Risk Activities Management Plan for its vendors. The guidelines address all high risk activities undertaken in the data centers as part of routine operations and maintenance such as energy isolation, working at height, accessing confined spaces, hot work, handling hazardous materials, lifting and rigging, emergency response, working in high noise and extreme temperature zones, etc. The Company also follows a permit to work system for such high risk activities. Besides minor injuries, no major reportable incident or fatalities have been reported in the data centers operated by NTTGDC. For construction sites, the Company incorporates OHS requirements into its contractor agreements. The Company will monitor the contractor’s OHS performance regularly through site inspections and review of submitted reports. (Refer ESAP #2)
Supply Chain
Company has established a supplier code of conduct (SCOC) applicable to suppliers, contractors and business partners. Vendor checks (including OEM suppliers of which 90% are domestic) are carried out before engagement by procurement team. Aspects such as child labor, forced labor and EHS policy systems of vendors are assessed for selection. Applicable clauses are included in the supplier agreements and are monitored periodically on a three year period based on the long term contracts. During IFC’s appraisal, sample evaluation record for a supplier for visual display solutions and high-end power systems for telecommunications was reviewed and found to be satisfactory.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency
Aligned with its sustainability policy, the Company is implementing initiatives to reduce its energy and water consumption. NTTGDC carries out resource efficiency improvements initiatives on water, energy and waste management. The Company has undertaken projects related to rooftop solar, adiabatic misting for chiller efficiency improvement, replacement of existing condenser units with higher efficiency condensers, preventing air leakage from data halls, optimization of air handling units etc.
The Company monitors its Power Utilization Efficiency (PUE), in terms of ratio of IT energy consumption against total energy consumption. Operational initiatives have been identified to improve the PUE.
In line with NTT Group’s Sustainability Policy, NTTGDC is committed to using technology solutions focused on the protection and regeneration of biodiversity in all locations of Company’s operations, by 2025. The Company has committed to incorporate circular design in its data centers by 2026, to reduce waste and carbon emissions. The Company also plans to adopt where possible, energy efficient initiatives such as liquid immersion server technology. The Company uses near field communication (NFC) based efficiency / energy monitoring for servers which is more efficient than the conventional methods.
Company uses only air-cooled chiller systems except water-based cooling system in an older DC in New Delhi. DCs require water for domestic purposes only and need about 41 cum/d for a typical DC. No hazardous chemicals (except diesel for power generators and cleaning chemicals) are used by the Company.
LRQA was engaged by NTT Group to provide independent assurance of its greenhouse gas (GHG) emissions inventory (GHG Assertion) for the financial year April 1, 2023 to March 31, 2024, against the assurance criteria below to a limited level of assurance and materiality of the professional judgement of the verifier using ISO 14064 - Part 3 for greenhouse gas emissions. The Company is committed to report on GHG inventory for their global level on an annual basis
The data centers financed by IFC will have improved PUE as compared to the current average PUE. Additionally, the new datacenters are expected to use electricity from renewables to meet their energy needs in line with the Company’s existing practice. The Project will result in an additional installed capacity of data centers of 105.6 MW.
Pollution Prevention
The Company’s operations involve construction and operation of data centers in urban / peri-urban areas and does not result in generation of significant quantities of wastewater, wastes and emissions that cannot be managed.
Electricity is sourced from National or State grids including renewable energy. NTT Group has committed to 100% renewable energy in all data centers by 2030, and in offices and facilities by 2035. NTT Group has also pledged for net-zero emissions across operations (Scope 1 and 2) by 2030, and value chain (Scope 3) by 2040.
Water required for the DC construction is sourced from authorised water tankers or provided through public supply. Water required for DC operations is sourced from local public supplies. All DC sites are provided with standalone raw water purification and sewage treatment plants to collect and treat all domestic wastewater to applicable standards before discharging to public sewers.
The Company uses oil-free stepdown transformers in all its DC sites. The Company does not use R22 or other refrigerants that have been phased out.
The Company has management procedures for hazardous / electronic waste and non-hazardous waste including a system of appropriate sorting, handling, storage and disposal which are consistent with applicable legal requirements. All hazardous and non-hazardous wastes are collected for disposal by authorized public service agencies specialized in each type of waste. Records were reviewed by IFC during appraisal and found to be satisfactory.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety
The company designs their data centers based on the National Building Code, 2017 including Life and Fire Safety considerations. Infrastructure design and equipment procurement processes include review of health and safety aspects. Going ahead, all new DCs (supported by IFC’s investment) will comply to a minimum gold standard certification under Indian Green Building Council (IGBC). The Company has developed a Green Building Manual, addressing requirements to be fulfilled for DCs compliant with IGBC norms.
Community Health and Safety
The data center business model operates in urban and peri-urban areas, mostly in commercial areas. The DCs do not pose any significant risk to local communities in terms of emissions, pollution or hazards. During the site screening and initial threat and vulnerability assessment the Company identifies immediate neighbors and their activities in terms of risk mitigation required. The Company avoids proximity to sensitive receptors (environmental and social). During emergencies, the Company’s EHS teams will coordinate with neighbors for any joint mitigation to be carried out as needed.
Security Personnel
The Company engages third party contractual workforce for security management, that is registered under the local regulation for private security. Security personnel are engaged after a background check that includes police verification. Based on the nature of the data center business, security is required at various locations besides the main gate entrance.. These security personnel are deployed in shifts as needed based on the DC layout and capacity. The security personnel are not armed and are also trained on behavior and etiquette, emergency response, firefighting, first aid and prevention of sexual harassment. Procedures have been established for staff and visitor management, emergency response and incident management in the data centers.
