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 Policies
TVS InvIT Trust identify and manage the E&S risks and impacts associated with their business operations to ensure compliance with applicable national and state regulations. TVS ILP, as Project Manager (PM) of the InvIT trust, is responsible for the design and implementation of the E&S policies and programs required to comply with applicable E&S regulations. TVS Environmental, Social, and Governance (ESG) and Environmental, Health, and Safety (EHS) policies identify the core E&S objectives and principles that guide their business practices and those of the TVS InvIT Trust. These E&S policy commitments define reducing environmental impacts, promoting social well-being, ensuring safe and healthy work environments for all, and upholding ethical governance standards as key corporate priorities. To further align their E&S policies with IFC Performance Standards (PS), TVS will incorporate IFC PS into their ESG and EHS policies (ESAP#1). Key aspects of IFC PS include commitments on identification of E&S risks and impacts, prevention of gender-based violence, and land acquisition, among others.
E&S Management System (ESMS)
The E&S Covenants included in IFC’s Policy Agreement with the TVS InvIT Trust require the Investment Manager (IM) to ensure continuous implementation of the InvIT ESMS to assess and manage the InvIT’s E&S performance in compliance with applicable E&S law and IFC PS. The TVS InvIT Investment Manager (IM) uses the various E&S policies and procedures that comprise the ESMS to assess potential E&S risks and impacts that could result in any legal, regulatory or reputational risks. TVS InvIT ESMS covers all TVS InvIT business activities involved in managing TVS InvIT warehouse common areas and associated services. All elements of the ESMS apply to all TVS InvIT employees, others apply to contractors, tenants, and visitors.
TVS ILP Manager delegate the day-to-day implementation of their ESMS to the Heads of Projects assisted by EHS staff at the asset level. The corporate Head of the Environment, Health and Safety (EHS) Department provides additional E&S supervision and training across the portfolio of TVS assets.
Monitoring and Review
The InvIT’s Board of Directors has created a Risk Management Committee responsible to identify and manage the financial, operational, and ESG risks, among others of the InvIT’s business activities. This Committee monitors Investment Manager’s E&S performance and reviews the effectiveness of the InvIT E&S management programs. IFC’s review of the TVS InvIT’s ESMS found it to be not fully commensurate with the level of the project’s E&S risks and impacts. For this reason, TVS will develop and add an E&S site screening process in the ESMS to assess the eligibility of potential warehouses for to include in the InvIT Trust and revise their E&S tools for monitoring and reviewing the E&S performance of the InvIT assets during operations and maintenance (ESAP#2).
Organizational Capacity and Competency
The TVS InvIT Trust’s assets are managed by the Investment Manager (IM) who makes investment decisions and appoints the Project Manager (PM). The PM maintains existing InvIT warehouses and administers the InvIT’s special purpose vehicle (SPV) warehouse asset level lease agreements with their tenants. Regional Asset Supervisors who work for the PM monitor individual TVS InvIT warehouses’ ESG performance and report to the TVS ILP EHS Head. This EHS Head also audits ESG compliance at the asset level and reports monthly to the GM – Head of Projects, the Chief Executive Officer (CEO), and the InvIT Board and Compliance Officer. These reports include updates on key EHS monitoring variables including fire safety system maintenance and training, OHS incidents, water and energy consumption, etc. These organizational arrangements include sufficient capacity to adequately assess and manage the E&S risks and impacts of the TVS InvIT’s business operations.
Identification of Risks and Impacts
E&S risk and impact identification covers internal and external risks specifically faced by the InvIT, including regulatory compliance, stakeholder engagement, labor and working conditions, and all other events that can have an adverse impact on the achievement of TVS InvIT’s business objectives.
Sexual harassment and Gender-Based Violence (GBV) present another source of potential project-related risks that TVS InvIT will need to mitigate. TVS’ draft Prevention of Sexual Harassment (POSH) policy seeks to establish and maintain a work environment in which all individuals are respected and treated with dignity and does not tolerate any form of discrimination or harassment. This Policy is intended to meet the provisions of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013”. TVS will revise their POSH policy to provide an anonymous complaint intake mechanism, and relevant mitigation measures to prevent GBV among their workers, tenants, contractors and affected communities (ESAP#3). TVS management will organize trainings on this policy that prohibits unwelcome behaviors that constitute sexual harassment in the workplace, and provide a detailed framework for prevention, and redressal processes. Complainants and any person providing information or any witness, are to be protected from any form of retaliation.
Emergency Preparedness and Response
Each TVS InvIT warehouse has a site-specific Emergency Response Plan (ERP) based on the TVS ILP corporate ERP. These plans specify the actions to be taken by key first responders in the event of an emergency including fire incidents or serious injuries. TVS provides induction training and refresher courses on emergency procedures for staff and contractors. First aid kits are available at all sites, and access to ambulances is pre-arranged. Collaboration with local authorities and community engagement, including drills and information sessions, ensure readiness and minimize risks. E&S risks associated with climate changes are variable across the many geographic locations of the InvIT assets. Overall, flooding is the greatest risk. To mitigate this risk, TVS has adapted the location selection criteria in their land acquisition policy, and built storm drains to channel flood waters to surrounding natural streams.
PS2 – Labor and Working Conditions
At the time of IFC’s review in January 2025, the TVS InvIT Trust and its SPVs had 144 fulltime staff (36 women / 108 men). TVS ensures compliance with regulations governing wages, leave, non-discrimination, sexual harassment, child labor, and occupational health and safety (OHS), etc., by implementing, monitoring, and evaluating relevant corporate Human Resources (HR) programs and safety protocols. TVS HR policies cover the terms of employment, non-discrimination and equal opportunity provisions, workers grievance mechanism, and Occupational Health and Safety (OHS), among others. IFC appraisal assessed these policies and programs and found them to be broadly compliant with statutory requirements and IFC PS.
All employees and contractors sign legally binding written contracts. New employees and contractors undergo induction training that includes an overview of the company’s E&S and HR policies, relevant regulations, and their specific E&S-related roles and responsibilities. These inductions cover TVS commitments on wages, benefits, working hours, and leave, how the company provides equal opportunities to employees and promotes diversity & inclusion, and does not tolerate discrimination on account of gender, race, religion & personal preferences etc. Staff and contractors receive regular refresher courses and updates to stay informed about new regulations and good industry practices. Continuous improvement comes from post-incident analysis and feedback. No cases of fatalities or Lost Time Injury (LTI) cases have been reported since February 2020.
TVS grievance mechanism (GM) for workers is applicable to third party contractors. The GM defines grievances as any concern or complaint raised by any staff or contractor employee affected by either real or perceived impacts of the company’s operations and communicated to the staff during induction and refresher trainings as well as their staff communications.
Responsibility for implementing the grievance mechanism rests with the project, permitting, and E&S departments. The Internal Grievance Officer/Project Team present at each asset, collects grievances on-site, communicates with contractors and complainants; maintains the means of grievance communications; participates in the investigation and resolution of the grievances; monitors and evaluates the resolution on-site; and communicates the findings to Senior Project Manager. TVS will revise this internal grievance mechanism to allow for anonymous complaints to be raised and addressed (ESAP#4).
Workers Engaged by Third Parties
TVS warehouse tenants participate in joint fire safety trainings. TVS also organize health check-ups with tenant workers. TVS ask tenants to report on their EHS indicators including OHS incidents. However, this is voluntary, and few tenants respond to monthly monitoring requests. Tenants are legally responsible for accidents and incidents that occur in their leased premises.
TVS Contractor & Visitor Management Plan) defines the control measures for managing environmental and safety hazards and risks associated with contractors and visitors to TVS ILP offices, construction, and operations sites. This Plan commits TVS to i) conduct risk assessments to identify the environmental, safety and health risks related to work performed by, contractors and visitors, and to identify the controls required to manage these risks; and ii) establish and maintain processes to identify and periodically verify contractors’ compliance with applicable legal requirements. While IFC PS1 is explicitly identified as a reference document for this Plan, it is not clear how all the applicable requirements of PS2, PS3, and PS4 are integrated into TVS ILP contractor E&S risk assessments and performance audits. For this reason, TVS will revise their Contractor and Visitor Management Plan to include assessment of contractor E&S performance consistent with both statutory requirements and all applicable IFC PS (ESAP#5). The TVS InvIT Trust are expected to manage all other labor and working conditions features of the proposed project consistent with PS2.
PS3 – Resource Efficiency and Pollution Prevention
TVS InvIT’s warehouse management activities do not consume significant quantities of water or energy, nor do they generate significant quantities of wastes or emissions. TVS InvIT warehouses are EDGE certified and designed to reduce their carbon footprint, conserve energy, and promote sustainable building design, construction and maintenance practices. All warehouses incorporate energy-efficient design, water management systems, and green belt development. Louver vents, High Volume Low Speed (HVLS) fans, sky lighting, and insulation design solutions further reduce TVS warehouses’ energy consumption. Water is recycled through rain harvesting and the reuse of treated wastewater for landscaping and in washrooms. TVS InvIT plans to further reduce energy and water consumption at its operations by upgrading to EDGE certification standards for all of its existing portfolio, installing solar panels on up to 8 million sq.ft. of roof top spaces, completing a Green House Gas emission baselining process, and identifying additional measures to reduce its carbon footprint.
The hazardous waste that the TVS InvIT Trust produces is sedimentary sludge from the warehouse sewage treatment plants (STPs). This waste is disposed by authorized third parties. The only other wastes TVS manage are limited amounts of organic and packaging materials collected during housekeeping activities in common areas. TVS InvIT’s Green House Gas (GHG) emissions are well below 25000 tonnes Co2 equivalent. These emissions come primarily from energy used for onsite sewage treatment, operation of fire safety systems, and common area lighting. Resource consumption and pollution from TVS InvIT’s tenants’ business activities, for example energy and water consumption, solid waste disposal, and emissions from customized generators, cooling systems, and cargo trucks, are not in TVS’ scope of control. TVS do not currently measure gross TVS warehouse GHG emissions, i.e. including all tenants’ scope 1 and 2 emissions. However, they plan to work with and support their tenants’ decarbonization objectives in the future.
PS4 – Community Health, Safety, and Security
The proposed project is expected to have limited impacts on the health, safety, and security of any communities. This is largely because the proposed warehouses to be acquire are all existing facilities in peri-urban and industrial areas with limited immediate proximity to any residential areas or public services. TVS InvIT warehouses are located in the industrial suburbs of 16 Tier II Indian cities, including Thally and Madurai in Tamil Nadu, Vijayawada in Andhra Pradesh, and Cuttack in Odisha, among others.
TVS take measures to ensure the health, safety, and security of the communities in which they operate. This includes implementing safety protocols at its facilities, conducting regular safety drills, and providing health and safety training for employees and contractors as well as tenants. TVS InvIT’s corporate tenants recruit their own workforce and provide transportation from the surrounding areas, so there are limited inflows of migrant workers. To deal with increased traffic, TVS have supported local governments to widen and improve municipal roads. They also work with staff and contractors to promote safe driving practices.
TVS integrates siting and safety engineering criteria in their building designs to manage natural risks like earthquakes, wind, flooding, landslides, and fire. This includes implementing measures for fire prevention and response, such as using fire-resistant materials and installing effective fire alarms and suppression systems. TVS provide two security guards at each warehouse. These guards are unarmed and trained to protect personnel, property and assets. Recruitment involves background and qualifications checks. The tenants often hire their own additional security to control access to their leased spaces and operations within the wider TVS InvIT warehouse. Going forward, TVS will to manage community health, safety, and security dimensions of the proposed project consistent with PS4.
PS5 - Land Acquisition and Involuntary Resettlement
TVS InvIT Trust’s Acquisition Policy provides an eligibility framework for acquisition of assets for inclusion in the InvIT. The Invit will only acquire land with pre-existing operational warehouses installed. These warehouses are developed by TVS ILP on land which is either privately owned or leased on a long-term basis from government entities either directly or through aggregators. Prior to acquisition, these assets must be screened for E&S risks and impacts, in accordance with the ESMS of the Investment Manager. TVS ILP land acquisition due diligence process generally complies with PS5. TVS purchases of private lands are conducted on a willing buyer – willing seller basis, with no possible recourse to judicial expropriation in the event of unsuccessful negotiations with landowners. However, TVS land procurement due diligence does not currently assess PS5 applicability under Government managed compulsory procedures, or situations requiring evictions of people occupying land without recognizable usage rights. TVS will revise their land procurement due diligence process to include the scope of applicability of IFC PS5 (ESAP#6).
