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 Policy:
Zetrix AI has developed its corporate environmental policy, sustainability policy, Code of Conduct (CoC), and human rights policy applicable to all the company’s operations. These policies include commitments relating to environmental management and sustainability, health and safety at workplace, legal compliance with applicable national laws and requirements, communication and engagement with stakeholders, which are generally in line with IFC Performance Standards (PS) requirements.
Identification of E&S Risks and Impacts Assessment:
Zetrix AI has a corporate risk management policy and a Risk Management Committee (RMC) in charge of screening and managing risks related to all the company operations and business. The company’s risk identification and management is in line with applicable national laws and requirements. According to the national legislation in Malaysia, the company is not required to undertake an Environmental Impact Assessment (EIA) study for the assets under the project.
As part of ESAP 1, the company will develop a screening procedure and the standard operating procedure for conducting E&S due diligence of potential investments including new development/expansion and acquisition of existing assets against IFC Performance Standards (PS).
E&S Management System and Programs:
The company’s ESMS is generally in line with IFC PS requirements, though it needs enhancing in terms of E&S management capacity including a screening procedure and a corporate E&S coordinator mentioned in the PS1 section. The company has established procedures for environmental and social (E&S) management, which include corporate E&S policies, risk assessment and identification, emergency response plans, and monitoring systems that apply to all operations. Additionally, they have set up a RMC and a health and safety committee. The corporate policies/procedures are available on the company’s internal information system and publicly accessible to all the stakeholders through corporate website (https://www.myeg.com.my/investor-relations/governance).
Organizational Capacity and Competency:
Zetrix AI has a corporate sustainability working group with around 40 staff consisting of RMC members and representatives from corporate departments to oversee, implement and monitor various E&S aspects covering Zetrix AI corporate operations. A dedicated health, safety, and quality management team has been appointed to manage, control and monitor E&S risks for each project site, also overseeing contractors including foreign worker accommodation during construction/renovation activities.
As per ESAP 2, the company will nominate a corporate level E&S coordinator, to oversee and coordinate the implementation of the corporate E&S policies and ESMS and also to track the ESAP progress.
Emergency Preparedness and Response (ERP):
Zetrix AI has a corporate ERP applicable to all the company operation, including the definition of responsibilities and duties of each emergency response team including office and accommodation operations. The ERP consists of a standard operating procedure in case of fire, medical emergency, and emergency reporting procedure. The emergency response team provides relevant emergency training in cooperation with the HR department and relevant committees.
Monitoring and Review:
Zetrix AI has established corporate sustainability objectives, key performance indicators (KPIs) and targets to continuously monitor company’s E&S performance, including accident record, training records, energy consumption and efficiency, environmental management, legal compliance, etc. In addition, the company has developed a regulatory compliance checklist to ensure its business operations comply with both national and international laws and regulations. RMC and representatives from corporate departments are responsible for collecting and reviewing assessment information.
PS2- Labor and working conditions
As of June 2025, Zetrix AI employs approximately 2,000 individuals directly. This workforce is comprised of about 42% women employees. In addition, Zetrix AI employs third-party workers through agencies as discussed below.
Human Resources Policies and Procedures:
The company has HR policies, procedures and an employee handbook which cover: obligations of the workers, working hours, holidays, overtime and payments, leave, disciplinary punishment, termination of employment. As part of ESAP 3, the company will update/develop its HR policies and procedures in line with IFC PS2 to include clear statements for workers' freedom of association.
Working Conditions and Terms of Employment:
All employees are provided with a contract. These contracts include the conditions for employment, working days, hours and overtime work, holiday and leave, disciplinary action, medical examination, insurance program, termination of contract, etc. According to the company’s HR regulations, all employees exceed the minimum age of 18 years.
Workers’ Organization and Retrenchment:
Zetrix AI does not restrict workers from freedom of association. There is no labor union representing employees in the project assets. There are no collective bargaining agreements and no major labor disputes to date. No retrenchment has occurred in the past three years nor is any currently planned.
Non-discrimination and Equal Opportunity:
Zetrix AI has a human rights policy and non-discrimination and equal employment opportunity policy ensuring that all the corporate business operations adhere to relevant regulations and standards as stipulated by the International Labour Organization (ILO) and the universal declaration of human rights including elimination of child labor and forced labor, discrimination and harassment prevention, and gender-based violence (GBV).
Worker Grievance Mechanism:
The company has established a formal grievance mechanism as part of whistle blowing policy defining the process for receiving and addressing complaints, and channels for reporting including e-mail to HR department or audit committee, including the policy of confidentiality, non-retaliation and anonymous reporting applicable to all the employees including contractors. HR department and/or audit committee are in charge of receiving and handling complaints.
Occupational Health and Safety:
Zetrix AI has a corporate risk management policy, safety and health policy applicable to both employees and contractors. The corporate policies cover health and safety compliance, and the provision of safety trainings. The occupational safety and health committee is responsible for the company’s risk management operations, and reports to managements on a quarterly basis.
The corporate health and safety committee also conducts safety meetings and trainings to maintain safety performance. Training programs for employees and contractors include workplace safety, firefighting training, incident reporting and fire evacuation. There are no fatalities that have been reported in the past three years.
Workers Engaged by Third Parties:
The company employs third party agencies to perform activities including office operation supports (around 200 employees), delivery service and construction/renovation for the foreign worker accommodation facilities. The health safety and quality management team and other relevant departments oversee contractors covering safety and legal compliance and corporate policy requirements. Third party workers’ contracts with their agencies require them to follow the corporate code of conduct and policies including human rights and labor protection, non-discrimination, prevention of forced and child labor, wages and benefit etc. As per ESAP 4, design of workers’ accommodation facilities will comply with national building and fire safety codes and IFC / EBRD guidance note on workers’ accommodation: processes and standards (2009).
Supply Chain:
The company has corporate code of business ethics and human rights policy covering respect for human rights, ethical procurement, as well as occupational health and safety, and environmental considerations covering the entire process of product procurement and supplier engagement. The company conducts supplier screenings and requires suppliers to sign acknowledging corporate CoC and policies in consideration of environmental, social, and governance factors to mitigate risks associated with potential negative impacts. The company reviews all the key suppliers (such as office and IT related products/goods) in terms of E&S performance as part of annual supplier evaluation, there has been no issues recognized in the past three years.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency, Greenhouse Gas (GHG) and Air Emissions:
Zetrix AI assesses its operations to enhance energy and water efficiency as per the corporate environmental policies. The facility-level resource efficiency initiatives include installation of LED bulbs, energy management systems for office operations, as well as reduction of paper usage. Total greenhouse gas (GHG) emissions in 2024 were reported to be 1,667 tCO2e (scope 1 and 2).
Electricity is sourced from national grid for all the company operations under the project. The electricity consumption from whole operations was reported to be around 2,490 MWh in 2024. No major air pollutant emission is expected from the company’s operations.
Water and Wastewater:
For the company operations, all the water is supplied from public water supply system. The water consumption from whole operations was reported to be around 100,000 m3 in 2024. Wastewater from office facility operations are discharged to the sewage system except for one worker accommodation site which has a sewage treatment plant (STP) at the project site, periodically monitored by third-party company specialized in STP maintenance in compliance with local regulation.
Waste and Hazardous Material Management:
The company has a waste management and recycling statement and promoting a system of separate collection, storage and reducing disposal. All the waste is collected for recycling/disposal by authorized third-party agencies specialized in each type of waste and the company has appointed licensed E-waste recycling company confirming the licensing from environmental authorities.
PS4-Community Health, Safety and Security
Life and Fire Safety Management:
Zetrix AI assets, including office and accommodation facilities, comply with national regulations and possess fire safety certificates demonstrating that their fire protection systems have been approved by local authorities. Regular inspections are conducted to ensure ongoing compliance for office operations. The company installs fire alarming system for the company facilities including smoke/heat detectors, fire hose reel system with pumps, fire extinguishers, and emergency exits in compliance with local regulations.
Fire Safety Trainings are conducted every year in the headquarters, branch offices and accommodation operations with support from the local fire authorities. There was no fire incident reported in the past three years.
Security Personnel:
Some company facilities including the corporate and branch office premises are protected using contracted unarmed security. The company regularly undertakes internal briefings and provides training for the security personnel including emergency responses.
