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.
PS 1: Assessment and Management of Environmental and Social Impacts
BGPL will develop and implement an Environmental Social Health and Safety (EHSS) policy (as part of ESAP#1) to align the project’s E&S performance with national regulations, EDF Group practices, and IFC Performance Standards. The policy will cover among others, environmental practices, Occupational Health and Safety (OHS), labor practices, respectful engagement with customers and communities, and contractor management. The policy will be shared with employees, contractors, and suppliers who will be supported by training programs.
BGPL is currently in the process of putting in place operational structure for project operations including at BGPL level and concession level. In alignment with operational structure, as part of ESAP#1, BGPL will develop an ESMS, in line with the regulatory requirements, IFC PS requirements, relevant WBG EHS Guidelines, and GIIP. The ESMS will, at a minimum, include: (i) EHS Policy; (ii) Identification of environmental, health and safety, and social (EHS&S) risks associated with smart meter installation, Operation and Maintenance (O&M) activities, warehouses operations; (iii) sample legal register for concessions; (iv) appropriate E&S organization, ensuring clear roles, responsibility allocation, training, and monitoring mechanisms; (v) Standard Operating Procedures (SOPs) such as OHS plan (Safe work procedure, PPE, etc.) electrical safety, road safety management, management of hazardous materials and wastes, supply chain/ vendor code of conduct, contractor management system, security personnel procedures, life & fire safety framework etc; (v) accident and incident reporting, investigation, and corrective action mechanisms, ensuring all workplace incidents, near misses, and safety breaches are documented, analyzed, and addressed to prevent recurrence; (vi) internal and external reporting and monitoring mechanism; (vii) emergency preparedness and response framework covering warehouses, installation, O&M activities; (viii) training and capacity-building programs based on training need assessment for all employees, contractors, and subcontractors; (ix) framework for stakeholder engagement and grievance mechanism; and (x) management review. BGPL with operational support from its main contractor will ensure that ESMS is implemented across all concessions and relevant ESMS requirements are articulated in contract agreements.
The risk assessment framework as part of ESMS (ESAP Item #1) will adequately capture EHSS risks associated with field installations, technician travel, warehouse operations, and materials handling and will inform SOP preparation and implementation to adequately address identified EHSS risks.
BGPL has established a working group to support the development of the ESMS and associated procedures based on EDF policies and procedures. To ensure ESMS implementation, as part ESAP #2, BGPL will appoint a dedicated Environmental Health and Safety (EHS) Specialist at the corporate level and will require the EDF-IN Contractor to maintain adequate EHS staffing at the concession level to ensure that BGPL SPVs operate in compliance with applicable regulations and IFC Performance Standards.
As part of ESAP #3, BGPL will ensure that an on-site Emergency Preparedness and Response Plan (EPRP), in line with the framework developed as part of the BGPL ESMS (refer ESAP#1), is developed and implemented for all concessions covering at minimum: (a) smart meter installation, operation, and maintenance activities; and (b) warehouses. The EPRP will outline potential site-specific emergency scenarios, including electrical hazards, fire risks (including occupants of the building/structure), community protests, road accidents involving technicians, and climate-related emergencies, along with appropriate response measures.
Monitoring will cover safety training, inspections, incident reporting, and resolution of grievances. BGPL will have an oversight committee (consisting of representatives from both Actis and EDF IN) (refer ESAP Item #1), responsible for the periodic review and supervision of BGPL’s EHS Plan. The committee will convene biannually to assess the EHS plan implementation, review audit findings, and take appropriate corrective measures to address any identified gaps or non-compliances. Additionally, the committee shall have the authority to seek updates from sub-contractors on the EHS plan execution and conduct supplementary monitoring as required to ensure adherence to EHS regulations and standards. Performance findings will inform management decisions and be used to continuously strengthen the system.
PS 2: Labour and Working Conditions
BGPL HR policies will also draw upon EDF global policies. BGPL will have a lean organization and most of the employees will be hired through EDF IN. As part of ESAP #4, BGPL will develop its HR policies and procedures in line with applicable regulations and IFC PS 2 requirements, which among others will duly cover terms and condition of employment; equal opportunity and non-discrimination; prevention of child labor and forced labor; freedom of association and collective bargaining; retrenchment; access to a grievance mechanism with anonymous channel for registering grievances; avoidance of Gender Based Violence and Harassment (GBVH) (especially factoring in survivor centric approach, non-tolerance to reprisal and retaliation, anonymity as desired, multiple channels for registering grievances); and worker accommodation (as applicable).
The terms and condition of employment will include aspects such as: employee classification; recruitment, appointment, probation, pre-employment health check; transfer, promotion, performance evaluation; working hours, overtime, shift system, leave; discipline, conduct and punishment; remuneration and allowances of employees, insurance; medical treatment; provident fund, gratuity, bonus, compensation (death/ physical incapacitation); resignation/termination/retirement; and organization level trade union rights. Additionally, as part of HR policy, BGPL will develop an employee Code of Conduct covering respectful workplace behavior, including zero tolerance for gender-based violence and harassment (GBVH) at workplace (smart meter installation sites), and will be communicated across all levels of staff and contractor personnel. BGPL along with EDF IN (as primary contractor) will implement these policies for all the workers. BGPL and EDF IN will communicate these policies to all workers and ensure training and awareness programs.
In addition, (as part of ESAP#2) BGPL will assign a Human Resources (HR) focal point at the BGPL level to oversee the implementation of HR policies in alignment with IFC Performance Standard 2. Similarly, adequate HR staffing will be ensured at project concession level.
EDF IN may subcontract some of the operations including smart meter installation, O&M, security and warehouses. Contractors and intermediaries will be required to follow similar standards, and contract provisions will be reviewed to ensure consistency with PS2 requirements. BGPL through EDF IN will develop and implement contractor management system (as part of ESAP#1) applicable for its complete operations which at minimum will include: (a) screening process for contractor/sub-contractor to include working conditions and OHS related risks, track record legal compliances of contractor/sub-contractor; (b) contractual obligations on contractors or intermediaries (EHS and labour); (c) periodic supervision of their performance vis a vis the BGPL’s labour and working conditions, as applicable; and reviewing the relationship and type of contract between contractor/sub-contractor and workers; (d) training for all third party workers to explain labor and working conditions for activities (including behavioral and safety training including GBVH) as applicable; (f) regular monitoring of the contractor’s legal compliance, and EHS requirements; and (g) ensuring corrective actions (in case of any identified gaps), are agreed with the vendors/suppliers/contractors and implemented in a time bound manner.
Occupational Health and Safety: BGPL will adopt and implement OHS procedures aligned with national regulations as part of its ESMS (ESAP Item #1). These procedures will be implemented through its main contractor and will cover aspects such as: (a) job safety analysis (JSAs) and safe electrical handling during smart meter installations including PPE usage, tool box talk (TBT) etc; (b) Training on hazard identification and incident response; and (c) Emergency preparedness and response protocol for field operations. Field workers involved in meter installation will be provided with job-specific training, including safe access to residential premises, use of personal protective equipment (PPE), and respectful engagement with consumers (to avoid people protest/hostile behaviour etc.).
With rising temperatures expected, and increased probability of heatwaves, workers (especially in the field operations) may face heightened risks of heat-stress, exhaustion, and heat-related illnesses, especially during extended heatwaves and working outdoors. BGPL as part of OHS plan will put in specific procedures associated with extreme heat or high temperatures and will include measures such as: alternative working schedules which may include starting work earlier in the day, reducing working hours, or introducing more frequent breaks to prevent heat exhaustion; structured work-rest cycle, allowing workers to take more frequent breaks in shaded or cool areas during the hottest parts of the day; ongoing training for workers on the risks associated with climate change.
BGPL will as part of the ESMS and specifically OHS plan (refer ESAP#1) develop recruitment criteria to ensure that candidates involved in the installation and O&M of smart meters have relevant experience in electrical wiring of buildings, transmission lines, stationary machines, and related equipment. Candidates should have prior experience in installing, maintaining, and repairing electrical infrastructure and should minimum hold an acceptable certification or course such as approved by the National Council for Vocational Training (NCVT).
The company as part of ESAP #1, will put in provisions for collection and reporting of OHS data including LTI. OHS performance will be tracked through defined indicators covering incident reporting, inspections, and implementation of corrective actions. Monitoring of OHS performance will include defined indicators such as training coverage, incident reporting, and corrective action follow-up.
PS 3: Resource Efficiency and Pollution Prevention
Operations stage water requirement is limited to domestic consumption and will be sourced from municipal water supply/ tankers. The electricity for offices will be sourced from the grid and will have DG sets for power back up. The environmental footprint of BGPL’s operations is expected to be limited during routine service delivery; however, the installation and commissioning phases will generate specific environmental risks, particularly related to waste management and localized emissions (back up DG set for office and warehouses). Waste generated will include: (a) packaging waste, such as thermocol, cardboard, and plastic; (b) Used oil from back up DG sets. The reduction in tonnes of carbon dioxide equivalent (TCO2e) associated with smart meter installation has been estimated to be 1.8 million TCO2e over the investment period. This figure focuses on the reduced/ more efficient energy usage by customers. This has been calculated as follows: #smart meters installed x average annual kWh per consumer x 2.5% reduction per consumer x emission factor. BGPL’s own GHG footprint is expected to be minimal but will also be calculated during the first year of the investment.
Used oil (from the back-up diesel generator maintenance) will be disposed of through authorized recyclers while old meters will be returned to DISCOMs. As part of its ESMS (refer ESAP #1), BGPL will develop waste management plan for proper segregation, storage, collection and disposal of waste. Minor, temporary emissions may occur during installation and, at warehouses, from diesel generator (DG) sets used during power outages. While such use is expected to be intermittent, BGPL will deploy diesel generator (DG) sets that comply with emission and noise standards stipulated by the Central Pollution Control Board.
PS 4: Community Health Safety and Security
BGPL’s project involves the installation of smart meters at residential and commercial premises, which requires technicians to work in close proximity to households and may sometimes involve work on live circuits. These activities may pose localized community health and safety risks, particularly in high-density or informal urban areas. The OHS plan (as part of ESAP#1) will therefore include: safe installation practices, precautionary signage or barriers, advance consumer notification to minimize risk to residents and bystanders.
As the shift to smart meters may lead to changes in billing or collection practices, BGPL will assess the potential for consumer dissatisfaction, including the risk of escalated public response in some areas. These risks will be addressed through proactive communication and engagement strategies developed in coordination with the DISCOM. BGPL will adopt a Worker Code of Conduct (refer ESAP# 4) to guide respectful technician behavior during in-home visits. Training will be provided on appropriate engagement with women, children, and vulnerable groups. Supervisors will monitor conduct, and any grievances will be addressed through established procedures.
In relation to warehouse safety, BGPL will develop a Life and Fire Safety (L&FS) framework as part of the ESMS (refer ESAP #1). The framework will be aligned with the National Building Code (NBC) 2016, and local fire authority regulations. It will apply to all BGPL and contractor-operated warehouses and distribution centers. Periodic audits will be incorporated into the ESMS to maintain compliance. BGPL operations require frequent movement of the technicians for meter installation services. Similarly warehouse operations across the concession area will require frequent movement of the vehicles. Additionally, technician team is expected to use their own two- wheelers. The company as part of the ESMS (refer ESAP # 1), will develop road safety procedure associated with movement of vehicles (four and two-wheelers), and working around the road traffic movement and train the personnel on those rules/ measures to ensure staff and community safety.
The corporate office, concession office and branch offices, warehouse, will hire unarmed security personnel through external agency. The company as part of the ESMS development (refer ESAP # 1), BGPL will develop and put in place a security management plan guided by the principles of proportionality and good international practice and include procedures to: assess risks posed by security arrangements; ensure hiring, rules of conduct, training, equipping, and monitoring of security personnel.
