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: Leap India has an Environment, Health and Safety (EHS) Policy that includes commitments to comply with applicable laws, provide safe working conditions, prevent pollution, conserve resources, and continually improve performance. The policy defines responsibilities for management, employees, and contractors, and covers training, communication, incident reporting and periodic review. As part of ESAP #1, the Company will update the EHS Policy to:(i) includes its applicability across all SPVs and associated Projects; and (ii) include explicit commitments on community health and safety, contractor oversight and emergency preparedness.
Environmental and Social Assessment and Management System: Leap India operates an Environmental and Social Management System (ESMS) supported by corporate procedures such as EHS Policy, Human Resources (HR) manual, land Procedure, third-party due-diligence procedure, and various Integrated Management System (IMS) procedures (such as aspects & impacts identification, corrective action and management review) aligned with ISO 9001/14001/45001 requirements. While the ESMS provides an overarching framework, several E&S related Standard Operating Procedures (SOPs) reside in the IMS, and the two systems are not yet fully integrated, creating challenges for effective implementation and monitoring of the EHS procedures. While the existing ESMS and IMS have key elements of management system as per IFC PS 1 requirement; the ESMS and the existing SOPs need updation (including new SOPs in few instances) covering Project lifecycle and associated activities. Therefore, as part of ESAP #1, the Company will consolidate the ESMS and IMS into a single management framework. The ESMS update will include strengthening of existing SOPs and development of new SOPs covering project lifecycle and associated activities in line with IFC PS requirements, applicable WBG EHS Guidelines, and applicable regulations.
Risk Assessment: Site selection is guided by Leap India’s Policy on fair and transparent acquisition of land. The company land screening includes screening for rail and road connectivity, availability of utilities, land-use compliance, E&S sensitivities (including the presence of forest land or other restricted areas notified under applicable legislation), and overall Project development feasibility. Once the land is shortlisted, the company undertakes legal due diligence including title verification, non-encumbrance checks, field verification and stakeholder consultations with land owners and local authorities. The land is procured through a voluntary willing-buyer, willing-seller process. Following land procurement, the SPV obtains statutory permits such as building-plan approval, Consent to Establish (CTE), fire and electrical-safety clearances, railway approvals (as applicable), and labour registrations. The ESMS requires identification of E&S aspects and impacts for development, operations and decommissioning (through ), however, this is not yet consistently applied across all SPVs. Under ESAP #1, Leap India will adopt a uniform E&S assessment process for all new Projects and will update the existing land policy in line with IFC PS requirement.
Organizational Capacity and Competency: Leap India has an established but evolving organizational structure for managing environmental, social and occupational health and safety (E&S/OHS) requirements across its silo portfolio. At the corporate level, the E&S function is anchored under the Chief Project Officer (CPO), supported by a three-members Environmental Social and Governance (ESG) team including Senior Manager and Assistant Manager. These roles collectively oversee compliance with ESMS/IMS procedures, support project execution, coordinate with lenders and regulators on EHS matters, monitor E&S risks and drive implementation of EHS/SOP requirements across sites. At operational sites, implementation is routed through Terminal Managers of the respective SPVs, who oversee day-to-day operations, contractor supervision, and EHS implementation with periodic support from the corporate ESG team. Site teams also include mechanical and electrical engineers, quality-control personnel and administrative staff; however, their contributions to E&S risk management are not yet integrated into a formal competency framework.
To strengthen capacity in a manner proportionate to the portfolio scale, Leap India will, as part of ESAP #2, adopt a regional, portfolio-based EHS oversight model. Under this model, (i) the Company will appoint adequate staffing (regional EHS officers) to cover clusters of new sites, with each officer responsible for a cluster of sites within a given state or geographic region. The regional EHS officers will oversee both construction and operational sites within their assigned state or region.; (ii) during construction, deploy site-level EHS Officer at each new project site, responsible for day-to-day monitoring, sub-contractor coordination and compliance with statutory labour and OHS requirements. Leap India’s regional EHS Officers will provide oversight, monitoring, and technical support to the site team to ensure that EHS measures during construction and commissioning are effectively implemented and (iii) strengthen cross-functional coordination between EHS, engineering, operations, quality control and fumigation vendors so that domain-specific risks such as grain-dust explosion prevention, fumigation safety, confined-space hazards, emergency response and rail-interface safety are systematically reflected in risk assessments, SOPs and training programs.
Management Program: The company maintains legal register for each of the Projects to primarily track the validity of the permits and licenses. The legal register will be updated (as part of ESAP#1) to include the specific conditions stipulated in the permits/ licenses including CA. The ESMS currently does not include construction specific E&S management plan, or HSE plan and specific EHS requirements are not articulated in the contract agreement. Therefore, as part of ESAP#1, the company will develop at least a generic construction stage ESMP (including waste management, environmental monitoring etc.) and specific HSE plan to be implemented by EPC contractor, which will be included as part of the EPC agreement. The company will ensure the implementation of these plans across all Project construction sites through regular oversight and monitoring.
The ESMS outlines management programs for key E&S and OHS risks for operations; however, the risk assessment needs update, and additional SOPs need to be developed. In cases where SOPs exist, there is opportunity for effective implementation and consistent implementation across Project sites. Some of the key aspects which will require to be adequately captured in the SOPs include dust explosion hazards, fumigation, resource-efficiency and pollution-prevention procedures, emergency response procedures and traffic management. These gaps will be addressed through the ESMS update under ESAP #1.
Monitoring & Reporting: The company undertakes internal EHS monitoring on an annual basis covering all the existing operational sites. The internal monitoring currently focus on general compliance and will need to be strengthened to cover operational risks such as grain-dust explosion controls, confined-space entry (CO2 detection), fumigation safety (e.g. phosphene exposure and containment), fire-system performance, contractor labour compliance and rail-interface risks. The internal monitoring also need to include permit conditions stipulated under multiple permits and licenses such as CTE, Consent to Operate (CTO), Fire, CA requirement etc. As part of the ESMS update under ESAP #1, Leap India will strengthen its internal monitoring by standardizing inspection tools, integrating permit-condition monitoring, formalizing contractor oversight and establishing a structured corrective-action tracking and implementation system.
Subsequent to ESMS/ IMS updation, as part of ESAP #3, the Company will undertake: (i) Construction phase: third-party independent review of sample of under construction hub Project sites (minimum 2) to assess ESMS implementation. (ii) Operations phase: Third party independent review of a sample (minimum 4) operational facilities (mixture of hub and spoke) within one year of commencement of operations. The review will evaluate compliance with the updated ESMS and site-specific ESMPs, identify gaps, and recommend corrective actions. The gaps identified through third-party review will be closed in a time bound manner across all the under construction and operational project sites. Based on the findings and severity of gaps, the company will have provision for subsequent third-party annual supervision review till the gaps in ESMS implementation are adequately addressed. Additionally, the review findings will inform ESMS and associated SOPs update including update of the training modules and training program to strengthen staff capacity for effective ESMS implementation.
Supply Chain: Wheat grain stored at the silo facilities is supplied directly by the Food Corporation of India (FCI). FCI undertakes all upstream procurement of wheat from producers and markets across the country and allocates grain to the respective SPVs for storage and handling under the terms of the Concession Agreements. The SPVs have no role in the procurement, sourcing, or upstream supply-chain management of wheat.
PS 2: Labour and Working Conditions:
Human Resource (HR) Policies and Procedures: Leap India, along with its subsidiary (Mahanadi) has a strength of 225 employees, with about 50% of the staff at corporate office and remaining at the SPVs across the country. Female employees are only at the corporate office constituting 9% of the total employee strength. At Project sites, the average number of regular employees remain below 15. Additional manpower (approximately 30-50 workers) through external contractors is hired for loading or unloading of food grains, which generally happens for 1-2 days in few months. Construction for a new project is undertaken through EPC which hires specialized sub-contractors for civil work, electrical work, silos erection etc. At the peak of construction activities, the worker strength would go up to 120.
HR policy: Leap India has a documented HR manual stating the company policies on human resource management, employment work conditions. These policies are applicable for all employees deployed at corporate office or the SPVs. The HR manual covers various topics, including but not limited to onboarding, probation, compensation, performance management, training & development, transfer, separation, leaves, working hours and holidays. The policies align with the local regulations and most of the PS2 requirements. Employee code of conduct is included in the HR Manual and covers the aspects of integrity, conflict of interest, intellectual property, adherence to rules and disciplinary procedure. Employees were largely noted to be aware of most of the company policies and expectations.
Protecting the Workforce: Leap India has established policies covering the aspects of child labor, forced labor, harassment, equal opportunity and no discrimination. The company does not employee anyone below the age of eighteen years.
Terms and condition of employment: The terms and conditions of employment are communicated through the appointment letters to each employee. Minimum wages are ensured for all employees, and office works in a single shift from 10:00 am to 6:30pm. Weekly offs, leaves and other benefits are provided as per statutory provisions, Medical insurance is provided by the company for all employees. During the construction phase, the project team is provided with temporary accommodation facilities. These are generally rented places in nearby areas. An EHS checklist has been developed recently to ensure minimum safety standards at such facilities.
Grievance Mechanism: Grievance mechanism procedure at Leap India includes provision for a grievance committee, a time-bound, step wise approach for redressal of any grievance raised by any employee. A dedicated email and suggestion boxes are provided for intimation of employees’ concern. The mechanism allows to appeal the decision of grievance committee. The policy is extended to contractors and third-party employees. The company has a documented policy on Prevention of Sexual Harassment (POSH) as per the local regulations. The policy document describes the scope, objective, roles & responsibilities, procedure for lodging & receiving a complaint, resolution process with suggestive timelines and other important aspects of enquiry. The company has recently reconstituted the POSH committee and is focussing on strengthening the policy implementation. Review suggests that no grievance has been received by the company in the past. The company will conduct refresher trainings amongst the employees and third-party workers on the grievance mechanism and anti-sexual harassment policy to create awareness about the mechanism as per ESAP #4. Going forward, the company will also document all grievance/s raised by the employees and share the details with IFC in annual monitoring reports.
Workers’ organisation: Leap India has not established any policy on ‘freedom of association’. Additionally, one clause in the appointment letters require employees to obtain management approval prior to joining any professional organisation. As per ESAP#5, the company will establish a formal policy on freedom of association aligning with the IFC Performance Standard and include it in the HR manual for employees’ awareness. New policy shall supersede the clause mentioned in the appointment letters. This should also include removing any restrictions to joining association or union of their choosing.
Retrenchment: The company reportedly has not undergone any retrenchment or lay-off in the past and has no such plans in near future. Company needs to hire more staff and employees for the upcoming projects. Leap India commits to adhere to statutory and PS2 requirements for any retrenchment, if any, in the future.
Third Party Workers: Leap India relies on and utilizes services of third-party workers both during the construction and operational phases (for loading/unloading work, security and for silos-operations) of the project. These contractors are managed locally by the Project team.
Leap India has developed a vendors’ code of conduct stating the requirements on business ethics, statutory compliances, and workers’ well-being. During the appraisal, gaps were identified with regards to the overall contractor management and monitoring of the implementation of code of conduct and other labor compliances like payroll records, working hours etc.As per ESAP #6, the company will establish and implement a robust contractor management system to ensure that all contracted workers' terms and conditions meet national legal requirements and PS2 requirements, particularly regarding contracts, wages, working hours, overtime payment, and other statutory benefits. Additionally, requirements and guidelines for workers’ accommodation, GBVH prevention, OHS should be developed under the system. The contractor management system should also include a process for regular monitoring of contractors and closure of any identified gaps.
Occupational Health and Safety: Leap India manages OHS risks at its silo facilities through the EHS Policy, IMS procedures and site-level practices that apply to both construction and operations. Existing controls include PPE usage, silo-entry protocols, on-site fire-fighting systems, fumigation procedures and emergency-preparedness arrangements. The company has developed Hazard Identification and Risk Assessment (HIRA) for some of the activities; however, this requires further strengthening to adequately capture all the activities and associated risks. Therefore, as part of ESAP#7, the company will update the HIRA to adequately cover key construction and operations hazards such as manual unloading and debagging undertaken by third party workers (with associated ergonomic and repetitive-lifting risks), grain-dust explosion and other fire hazards, working at height, mechanical and electrical safety, fumigation-related exposure, and interactions between workers and mobile equipment, lifting operations, silo erection, working at height, hot work, and excavation.
Preventive-maintenance gaps (e.g., non-operational fire pumps, moisture ingress at electrical panels) were observed, and contractor OHS oversight not fully structured, especially during short-duration loading/unloading activities. As part of ESAP#8, the Company will commission independent H&S review covering one current operational hub facility (with railway siding), and one under-construction site. The review will include design, construction (as per approved design) and operations procedure (and implementation) against national OHS regulations, CA requirements (including dust-hazard analysis and NFPA 61-provisions), IFC PS and applicable WBG EHS Guideline. The findings will inform necessary updates to design, engineering and process controls for upcoming facilities, and strengthen Company’s OHS systems, including strengthening of HIRA, construction and operational risk assessments, and enhancing of SOPs for high-risk tasks such as fumigation safety and fire-and-explosion mitigation measures associated with grain-dust hazards. The company will address the gaps as an outcome of H&S review in a time-bound manner across all the sites with provision for gap closure verification.
PS 3:Resource Efficiency and Pollution Prevention:
Leap India manages resource-efficiency and pollution-prevention aspects through its ESMS/IMS procedures, site-level practices and operational controls for silo facilities. Energy use is primarily associated with aeration, conveying, dust-collection systems and general facility operations. The Company reports on installation of energy-efficient motors, aeration fans and LED lighting at operational locations and is exploring renewable-energy options such as solar lighting and rooftop solar for upcoming projects.
The absolute GHG emissions associated with Project SPV operations are estimated at approximately 173.9 tCO2e/year. Water is sourced mainly from borewells. Sites maintain groundwater-abstraction permissions and water-consumption records, and rainwater-harvesting structures have been implemented at operational facilities as part of water-conservation measures, with similar measures planned for upcoming facilities.
Air-quality management during grain handling is supported by dust-collection systems installed at operational facilities, with periodic maintenance undertaken. Annual ambient-air monitoring indicates compliance with applicable regulatory standards and the WBG General EHS Guidelines. Fumigation-related emissions are managed through a documented fumigation SOP covering silo sealing, gas-concentration monitoring and controlled degassing carried out by certified operators. Noise monitoring is undertaken periodically and was observed to comply with applicable regulatory requirements and the WBG General EHS Guidelines. Site housekeeping, and stormwater drainage help to prevent pollution and pest risks.
Waste streams include grain sweepings, mixed solid waste and hazardous waste generated during fumigation. Fumigation residues (aluminum-phosphide ash) are collected and removed by fumigation vendors; however, disposal records confirming that receiving facilities are authorized hazardous waste handlers are not currently maintained, representing a gap in traceability. As outlined under management program, the procedures will be strengthened to include (i) integrate resource-efficiency and pollution-prevention procedures (air quality, water use and conservation, wastewater and stormwater control, waste and hazardous-materials management, noise management); (ii) ensure traceable documentation and verification of hazardous-waste handling, including fumigation residues; and(iii) require preparation and implementation of site-specific Construction and Operational ESMPs for all upcoming silo and railway facilities, ensuring that environmental procedures are translated into project-level controls. These measures will align with IFC Performance Standard 3 and the WBG General EHS Guidelines.
PS 4: Community Health Safety and Security
Equipment structure and design: Engineering design and construction of silo facilities are undertaken in accordance with the technical specifications and safety requirements set out in the CA. Steel silos are erected through panel-by-panel assembly, followed by installation of roof structures, aeration floors, discharge systems and associated mechanical and electrical components. Mechanical systems such as conveyors, elevators, grain-cleaning equipment, dust-control units, automation systems and firefighting networks, and where applicable, railway siding infrastructure are constructed as part of the Project facility setup. Prior to commissioning, each facility undergoes testing and independent verification of structural integrity. While the CA does not require periodic structural or pressure testing, facilities are required to be maintained in line with GIIP. Leap India will incorporate routine inspection and preventive-maintenance measures into its updated ESMS (refer ESAP#1), with further enhancements informed by the independent H&S review under ESAP #8.
Traffic Management: During both construction and operations, community-level risks may arise from the movement of heavy vehicles transporting construction materials, equipment and grain. Traffic control at existing silo facilities is guided by site-specific Traffic Management Plans (TMPs) that define designated routes, speed limits, signage and vehicle-check procedures. Community interfaces are limited at many sites due to internal roads and controlled access; however, the level of interaction with public roads varies, particularly where site entry points connect directly to public roads or where construction-phase vehicle inflows are significant. The Company will update and standardize the TMP (as part of ESMS update) to :(i) identify segments of public roads where community risks may occur due to truck movements;(ii) define controls such as speed management, signage, safe turning-radius design and contractor-vehicle oversight and (iii) integrate traffic-safety considerations into construction and operational planning.
Food Safety: Silo operations include quality-assurance steps designed to preserve the safety of food grains handled under the concession. FCI conducts joint sampling and quality testing at the time of receipt to confirm compliance with prescribed food-safety standards. Debagging and cleaning take place within enclosed process towers equipped with dust-control systems, reducing contamination risks during handling. Following cleaning, grain is transferred to steel silos fitted with aeration, ventilation and automated temperature and humidity monitoring systems that maintain safe storage conditions and prevent spoilage. These controls, together with fumigation carried out by certified operators, help safeguard food quality throughout storage and dispatch, thereby reducing risks to consumers and downstream communities.
Fumigation & Community Safeguard: Silo fumigation is conducted within enclosed structures; however, there is potential for community exposure, if gases are not properly contained or if degassing is carried out under unfavorable meteorological conditions. Fumigation of stored grain is carried out inside sealed silos by certified operators following a documented SOP which needs further strengthening, and therefore the fumigation SOP will be updated (refer ESMS update) to incorporate safety controls, including: (i) defining buffer-zone requirements; (ii) conducting meteorological checks prior to venting; and (iii) establishing clear communication protocols for situations where fumigant concentrations or dispersion patterns may pose a risk to off-site receptors.
Emergency Response and Disaster Management Procedure: Emergency Response and Disaster Management procedures are in place and outline roles, communication protocols, evacuation measures and coordination with local emergency services. These procedures support the management of general emergency situations; however, several high-risk scenarios with potential on-site and off-site (community) relevance are not yet fully addressed. As outlined under the management-program update, the Company will update its Emergency Preparedness and Response procedure to align with IFC PS4 requirements, ensuring that high-risk, operation-specific scenarios (including those with potential community impacts) are adequately addressed.
Security Management: Security at silo facilities is provided by licensed third-party agencies. Security personnel are unarmed; no firearms or other weapons are used at any facility. Guard duties are limited to access control, theft prevention and basic patrolling. Security staff receive basic site-orientation and safety instructions; no use of force has been reported.
