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
Identification of E&S Risks and Impacts
The Project was subject to local regulatory approvals for construction and operation. All pipelines and associated facilities were not subject to local Thai E&S assessments as they are exempt under local laws and were designed and constructed between 2015 to 2022 and are currently operational. The Company does have an Environmental and Social Management System (ESMS) and E&S policy frameworks that apply to all project components. The ESMS however has not identified and managed all E&S risks and impacts with gaps in potential community impacts, management of contractors and suppliers. The ESMS and associated mitigations will require rectification to fully comply with IFC PS.
Environmental and Social Policies and Management Systems:
East Water at a corporate level has policies and procedures that apply to their facilities, including valid certification for ISO 14001:2015 (Environmental Management System) and ISO 45,001:2018 Occupational Health and Safety certification for all facilities operated. The EMS is named by East Water as a “Quality, Safety, Health and Environment Management System” (QSHEMS). This QSHEMS is accompanied by a Human Resources Management Manual, Safety, Occupational Health and Working Environment Policy and Supply Chain Management Policy. The Company has a system to supervise and audit operational and maintenance contractor’s E&S commitments. These policies and procedures generally comply with IFC requirements; however, gaps have been identified including related to monitoring of ongoing risks with contractors and their workers. To ensure consistency with and to comply with IFC PS and World Bank Group (WBG) EHS Guidelines and Good Practice Notes (GPN), the Company is to review and update the QSHEMS (ESAP #1). Further discussion on these gaps is elaborated below.
E&S Organization Capacity:
At a corporate level, East Water maintains the QSHEMS that is overseen by a committee that reports to the company’s Board. There are dedicated staff at a Corporate and provincial level that oversee the day-to-day implementation of the QSHEMS and OHS requirements, including proactive monitoring of the implementation of the documents. Contractors and East Water staff are responsible for monitoring and maintenance of the pipelines and associated facilities. Specialist contractors are used for specific tasks, such as pipeline repairs or pump maintenance. East Water’s Human Resources (HR) department supports the implementation at a site level by providing training on key E&S risks during induction as well as refresher training for staff. Contractors are responsible for induction and training against their own documentation.
Emergency Preparedness and Response:
East Water relies on the Business Continuity Management (BCM) manual and Business Continuity Planning as mechanisms to manage emergency situations. A specific Crisis Management Plan (CMP) has also been prepared to ensure preparedness when managing incidents and emergency situations. These documents are socialized amongst the workforce, and there are various mechanisms in place to train and implement activities. These include regular fire drills and measures to manage hazardous chemicals. Related Safety Standard Operational Procedures (SSOP) have also been developed, including for chemical spill emergencies and hazardous waste management. The SSOPs have been developed in accordance with Thai government regulations and have involved local authorities in drills. A safety risk assessment was undertaken in 2024 across East Water’s operations and did not identify any significant risks that would impact communities.
Monitoring and Review:
East Water monitors E&S risks through a corporate and site level monitoring program focused on regulatory compliance, E&S, labor, OHS and emergency response. ISO certification audits are also undertaken on an annual basis to determine compliance with the QSHEMS and OHS management policies. E&S and OHS data is collected on monthly basis at facility level and is reported in the annual Sustainable Development Report. Worker and Occupational Health and Safety data is collected monthly. Contractors are required to provide reports on safety however there is no current proactive auditing of contractors against East Water’s E&S requirements. To manage compliance of contractors with E&S and OHS requirements, East Water is to conduct regular random audits of contractors (ESAP #2).
PS2: Labor and Working Conditions
Human Resource Policies & Procedures:
The regular employees of East Water include 227 people (as reported in 2024). The gender ratio is 48% female and 52% male. Three personnel were identified with disabilities and specific measures were implemented to ensure the workplace was suitably equipped. Contract workers number 506 persons of which, 13% are female and 87% are male. These contract workers include security guards, maids and gardeners at project facilities as well as project contractors undertaking maintenance activities across various facilities. Migrant workers were not identified within the workforce, including contractors, however there is a chance that migrant workers may be employed from time to time by contractors. East Water will therefore ensure that all contractors are aware of and include requirements in legal agreements on their obligations for migrant workers, including ensuring fair treatment, safety standards, and compliance with labor standards regarding working hours, wages, and benefits consistent with Thai laws (ESAP #3).
East Water’s Human Resources Management Manual (HRMM) is applied to their direct employees and contractors. The Manual includes provisions to manage terms of employment, hours of work, wages, overtime, compensation, performance assessment, promotion, collective bargaining agreements and worker rights under Thai law. The Company submits annual compliance reports to the Thai Labor Department on an annual basis and is subject to occasional audits.
The Company has a whistleblowing policy and grievance mechanisms, with employees encouraged to share their concerns, suggestions, or complaints with senior staff. Complaint channels are monitored, and each report is documented and submitted to management. There are various channels for the submission of anonymous grievances. There have been no recent worker related grievances made by East Water staff or contractors. No unions represent employees at the Project; however, the company does allow freedom of association for workers to form unions which is included within the HRMM.
Gender Based Violence Prevention:
East Water maintains human rights commitments, including undertaking risk assessments for operations and maintaining a register of risks. Commitments on human rights risks focus on child and forced labor, gender equality and harassment. The HRMM has specific requirements to reduce risks related to sexual harassment and discrimination. The Company maintains a whistleblower mechanism and a complaint handling mechanism to manage risks, including with sub-contractors and suppliers. Specific reference to gender-based violence and harassment risks and management are included within East Water’s Human Resource Management Manual.
Human Rights, Child Labor and/or Forced Labor:
East Water maintains human rights commitments across its E&S and OHS documentation referring to human rights and management of risks of child and forced labor within the organisation. The approach is consistent with IFC PS. The Company also maintains a Supplier Code of Conduct, that includes a cross reference to the Companies’ Human Rights Policy requires that child and forced labor risks are to be managed by contractors.
Occupational Health and Safety and Third-Party Employees:
East Water maintains policies on employee welfare management and supervision that manages material risks to human safety in the workplace. The policy covers employee welfare medical, insurance and OHS and is overseen by a Workplace Welfare Committee. Relating specifically to OHS, as previously outlined, East Water maintains an ISO 45,001:2018 Occupational Health and Safety management system. The Policy includes site-based risk assessments, training and competencies, operational safety control mechanisms to manage risks and specific standard operating procedures and work statements for high-risk work environments and tasks. East Water monitors workplace safety and reports on metrics. The Lost Time Injury Frequency Rate (LTIFR) is currently 2 hours per 1,000,000 hours worked, which is slightly lower than the incident rate as recorded by the US Bureau of labor Statistics for water utilities (2.1 hours per 1,000,000 hours worked). Risk assessments and investigations are currently undertaken and reported to senior management and the Board as well as included in the Annual Report. Personal protective equipment (PPE) is provided to staff across all facilities. Safety activities are applied including incident reporting and investigation, annual health check-ups, safety training and communications. East Water requires that contractors comply with their policies and procedures and manages OHS risks of contractors through self-reporting and proactive audits. No serious incidents have occurred in the previous 12 months. Contractors manage their own training requirements related to OHS and community health risks. The Project enables only appropriately qualified personnel to attend work sites.
Supplier Management:
East Water has in place a Supplier Management Procedure that includes measures to pre-qualify suppliers, establishing contracts, managing transition between suppliers and rectifying compliance if it arises. Suppliers mainly consist of electronic equipment, consumables and equipment which is sourced from contracts locally and from East Water’s corporate supply contracts A complementary Guideline for Procurement includes requirements for companies to comply with East Water’s commitments on OHS and labor risks.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency:
East Water has an Environmental Policy and specific targets to reduce energy and pollution with their business. These targets include identifying alternative energy sources for the supply of energy and to reduce the amount of general and hazardous waste generated as well as greenhouse gas emissions. Solar energy has been installed across several of East Water’s buildings and existing air conditioning equipment has been retrofitted to reduce power consumption.
Water Supply:
East Water is supplied raw water from nine reservoirs and storages in the same provinces of Eastern Thailand where East Water operates (known as the Eastern Economic Corridor, or EEC) with a total allocated capacity of 330 million cubic metres (MMC) per year. Water allocation is done as per the Water Resource Act, B.E. 2561 (2018) based on an initial review by the RID and the final allocation by the National Water Resources Committee. The EEC is a water deficit region dependent of water transfers from other regions. The Government of Thailand has identified 38 projects that are expected to add 872 MCM by 2037 of which several are already under implementation and expected to bridge the water deficit by 2027 The implementation of the remaining projects will increase the water availability in the EEC region to meet the projected water demand over the medium to long-term
Solid waste and hazardous material management:
Solid waste is generated at offices as well as hazardous wastes and sludges from water treatment facilities and waste materials from the maintenance of all facilities. Hazardous wastes are transported and managed by licensed hazardous waste companies and domestic wastes are disposed at municipal facilities. Chemicals at all project facilities including water treatment chemicals (chlorine), oils and greases and herbicides are kept on site with Material Safety Data Sheets (MSDS) and within appropriate storage areas. The QSHEMS currently refers to “waste management” however it lacks detail on the requirements and procedures needed to comply with IFC requirements. The QSHEMS will need to be updated to ensure compliance with the relevant WBG EHS Guidelines, including monitoring waste and hazardous material management (see ESAP #1).
Air and noise emissions:
Air emissions mainly occur from the use of diesel-powered back-up power supply using Gensets at office facilities. These are operated on test or during emergency situations. Noise emissions primarily relate to noise from air conditioning units, which are placed on the external walls of buildings. Both air and noise emissions meet Thai standards for the operations of this equipment, however the operation and monitoring of noise emitting equipment will need to comply with WBG EHS Guidelines and is to be updated in the QSHEMS (see ESAP #1).
Climate Risks:
IFC’s review identified a low level of project E&S risks and impacts resulting from a changing climate, including extreme heat and potentially, wildfires. The average annual total emissions are estimated at 23,185 tCO2/year.
PS4: Community Health, Safety and Security
Infrastructure and Equipment Design, Life and Fire Safety:
Life and fire safety is managed through East Water’s QSHEMS and has various commitments and requirements related to life and fire safety. Required permits from Thai authorities and coordination with relevant local government agencies are embedded into the system. All project components and associated facilities have been built according to Thai building standards using reputable suppliers of equipment. The system used to manage fire risk at pumping stations and water treatment plants includes a fire alarm system, a hydrant and sprinkler system as well as fire extinguishers placed throughout the facilities. Fire extinguishers installed include both dry and wet types to match the risks. Regular fire drills and monthly inspections are undertaken of all fire control devices and systems. Work procedures and training on the use of the fire system is included in both induction training and regular updates for all staff.
Traffic Impacts and Transportation Safety:
Traffic risks associated with the East Water are low. Traffic generated by the operation of the water network and the facilities run by East Water is low with low risks of transportation safety. The use of trucks and machinery by East Water and contractors is covered by the QSHEMS that includes measures related to safety of vehicles.
Community Health and Safety:
Community health and safety risks are low, however, there are several industrial and residential areas adjacent to pipeline routes. Water pumping stations and water treatment works are fenced and located in isolated areas within industrial estates and adjacent to reservoirs or canals.
Security Personnel:
The Company maintains security personnel outsourced to a security company for offices, the water treatment plans and pumping stations. There currently no security measures used for the pipeline as it is buried. There are no firearms in use by security personnel. There is specific training for security staff related to community risks, including respecting those entering the site as well as measures for managing risks associated with escalation.
