Based on IFC’s current review of the project and the ESDDs, there are no identified risks and adverse impacts of the project associated with the requirements of PS 5 (Land Acquisition and Involuntary resettlement), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage); PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) related impacts are low because of the depot location in urban areas and modified habitat, which will be managed through better water management under PS3. However, these Performance Standards may be triggered if and when they apply at any of the 32 depots, under the proposed investment. Additionally, as future projects are proposed for investment (under Investment 2), they will also be reviewed against Performance Standards 1 through 8.                                                     

 This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability (2012), as it is expected to have adverse E&S risks and/ or impacts that are limited in scale, few, generally site-specific and readily addressed through mitigation measures, by adhering to good international industry practice (GIIP) procedures, guidelines, and design criteria, as described in the following sections.

The key E&S issues include (i) the company's management and monitoring systems to assess and manage E&S risks and impacts from its operations (bus depots as well as on route bus operations); (ii) consistent management of labor and working conditions (for direct and third party workers) including compliance and Occupational Health and Safety (OHS) policies and practices, prevention of sexual harassment and Gender Based Violence (GBV) in its operations and with commuters, road and traffic safety, and any potential supply chain exposure to forced or child labor risks.; (iii) monitoring and management of waste, wastewater and hazardous materials including end of life battery management; (iv) life and fire safety risk management associated with charging infrastructure, buses, and battery (at depots and on route bus operations) and emergency preparedness and response; (v) client’s stakeholder engagement and grievance mechanism related to E&S aspects.

PS1: Assessment and Management of Environmental and Social Risks and Impacts 

Policy: GMPL has an ESG policy as part of the Environmental and Social Management System (ESMS) which is broadly aligned with IFC’s Performance Standards (PSs) and will be implemented for GMPL proposed investment and GEPL operations (as applicable). In addition, GMPL has Integrated Management System (IMS) policy (Quality, Environment, Occupational Health & Safety and Energy) including quality management system (ISO 9001:2015), environmental management system (ISO 14001:2015), occupational health and safety management system (ISO 45001:2018) and energy management system (ISO 50001:2018); this policy commits to safeguard environment, promotes resource efficiency, healthy and safe work environment, continued improvement to safe work practices, protection of employees including contractors, business partners, service providers, visitors and other stakeholders at large from any harm.

Identification of E&S risks and impacts: GMPL has a process in place for undertaking desk-based E&S screening of all depot sites (prior to bidding) and site level E&S screening was done for sample of the upcoming B2G depots. As part of ESAP#1, for the proposed B2G depot sites to be managed and operated by new SPVs, GMPL will conduct an Environmental and Social Due Diligence (ESDD) for each depot, develop and implement a Corrective Action Plan (CAP) aligned to IFC PS requirements, EHS Guidelines, and applicable regulations. GMPL dedicated Projects team typically try engaging with the authorities early in the process soon after letter of award (LOA) is issued, and engage with authorities on selection of depots identified by authorities; this process also includes effective coordination on finalizing depot layout, other support to authorities, agreeing on punch list items to be completed by authorities during construction, and preferably before depot handover.  In this regard, GMPL will use ESDD findings before taking over the depots, to clearly ascertain both authority and GMPL responsibility related to construction and operations stage requirements. GMPL will ensure that the depots once handed over by authorities will comply with the findings of the depot specific recommendations in the ESDD report as applicable.

Environmental and Social Assessment and Management System: GMPL has IMS manual and corporate level ESMS covering the entire life cycle of the Project from planning phase, construction phase, project operations to project closure. The corporate ESMS. developed has key elements which are in line with IFC PS requirements, and includes pre-bid screening and preliminary site screening, regulatory framework, Hazard Identification and Risk Assessment (HIRA) for construction and O&M, SOP for O&M, skill matrix, training and capacity building, reporting and monitoring mechanism, contractor management, Environmental Management Plan (EMP), Stakeholder Engagement external Grievance Mechanism frameworks, Traffic and Road Safety Management Plan, Emergency Response and Preparedness Framework (including Bus Enroute), and Community Health and Safety (H&S) Management. The third-party ESDD, labour DD and H&S DD findings (commissioned for existing B2G operational e-bus concessions but outside the scope of the proposed investment; and B2C concessions which are in the scope of investment), informed the understanding of on-ground implementation challenges and the need to update corporate ESMS including additional SOPs. As part of ESAP#2, GMPL will update and adopt the corporate Environmental and Social Management System (ESMS), relevant to its business activities and operations and aligned to IFC PS requirements, applicable WBG EHS Guidelines, and incorporating gaps identified as part of third-party ESDD, labour DD and H&S DD. GMPL ESMS update among others will include: (a) provision for third party ESDD for any upcoming sites under B2G or B2C; (b) a detailed legal compliance register and compliance checks for all depots and bus route operations. The register will incorporate the CA requirements in respective states, permitting and licensing requirements; and (c) develop minimum standards for depot infrastructure, facilities and amenities required under applicable laws and good international industry practices (GIIP) for B2G sites and B2C sites. The minimum standards will be used to assess compliance and operational readiness of depots prior to site handover from respective authorities to GMPL SPVs. The minimum standards will be used to develop and operate B2C depots in line with the applicable regulations. For B2C this will include end point locations. 

GMPL B2G SPVs will be provided with depot sites and will have varied levels of infrastructure, and existing legal compliance related to registration/ licenses under various acts and regulations may vary across depots. The CA for each of the depot sites will further have key EHS related requirements stipulated. The legal register for existing sites was not updated to include the latest regulations such as Central Electricity Authority (Measures relating to Safety and Electric Supply) Regulations 2023, E-Waste (Management) Rules 2022 and Battery Waste Management Rules 2022. A separate ESDD for each depot site (before the site handover to SPVs) (refer ESAP#1) will capture these requirements and GMPL as part of required  ESAP# 3, GMPL for upcoming identified PMES and NEBP B2G SPVs will apply and obtain the required permits, registrations and licenses under the applicable Acts, but not limited to, Factories Act, Principal Employer Act, Fire NOC, Motor Vehicles Act, Central Motor Vehicles Rules, Contract Labor Act, BOCW Act and Environment Protection Act.. GMPL will further ensure that each depot site develops a detailed compliance register (using the sample legal register as part of the corporate ESMS), incorporating the CA requirement, multiple permits and licenses and requirements stipulated therein, applicable ESDD CAP recommendations for depot operations, and depot specific ESDD gap closure recommendations among others. In addition to the legal compliance register, depots will apply and obtain the required permits and registrations/licenses under the applicable Acts. GMPL has also adopted legal compliance software named Legatrix to track compliance requirements at each depot level, which will be replicated for the upcoming operations.

GMPL has commissioned third party ESDD, H&S DD and labour DD covering GMPL (corporate) and GMPL’s existing depot operations (sample B2G and B2C sites) that are similar to the depots in the project scope. These gaps mostly relate to ESMS implementation, corporate EHSS monitoring, legal register gaps including update/application of permits and implementation of the permit conditions. and the Corrective Action Plan (CAP) developed as the outcome of multiple DDs will be used for depot level E&S improvements as part of GMPL corporate level ESMS, as well as upcoming B2G operations and B2C operations. As part of ESAP# 4, GMPL will review and implement recommendations as covered in the specific Corrective Action Plan (CAP) prepared as an outcome of the third-party Environmental and Social Due Diligence, Labor Due Diligence, and Health and Safety Due Diligence which are relevant to GMPL upcoming SPVs and existing B2C activities and operations, in agreement with IFC. As part of CAP implementation for existing B2C operations, GMPL will ensure that pending compliances are updated, and compliance conditions are met as per the ESDD findings for all B2C operational sites.

Before, any flow of fund for B2C operations (5 depots, 300 buses), GMPL (as part of ESAP #5) will ensure that all the B2C sites comply with applicable E&S legal requirements, address all the gaps identified in the third party ESDD and labour DD (including other depot specific non-compliances), implement the CAP recommendations (as applicable) for the  B2C sites and will commission separate third party EHS and Labour compliance audit (covering all B2C sites) to verify compliance. In case of major gaps (especially related to labour and working conditions), GMPL will undertake subsequent audits to confirm compliance of all B2C sites.

Organizational Capacity and Training: The corporate EHS team currently includes an EHS Head at the corporate level supported by EHS Manager Corporate. GMPL has provisioned for one EHS officer and one Driver / Coach Captain (CC) trainer per SPV in case of B2G business wherein each SPV may have 3 – 5 depots. In B2C case each depot has one EHS Manager and one Coach Captain Trainer.  As part of ESAP#6, GMPL will under B2G (for the upcoming SPVs) hire qualified EHS and HR/ IR staffing to lead and manage ESMS implementation. The roles and responsibility related to depot level permitting, compliance to permitting conditions, contractor management system will be adequately captured in the roles and responsibility of EHS and HR staffing. Further, GMPL will designate qualified operations staff to oversee day-to-day EHS operations at the depot level. In addition, the company will strengthen the corporate level EHS team including adding additional EHS resources and ensuring rigorous monitoring of the sites to oversee ESMS implementation. GMPL will enhance the scope of the ESG committee to review EHS integration as depots roll out progresses and provide support to the depot operations for successful ESMS implementation in line with IFC PS requirements. The proposed EHS training for workers engaged in operations (as part of existing operations practice), including the ongoing driver training provisions, will be implemented for the upcoming depot operations.

Emergency Preparedness and Response: Emergency Preparedness and Response Framework (EPRF) has been developed as part of the ESMS manual at the corporate level. GMPL will develop and implement Emergency Preparedness and Response Plan (EPRP) during construction including installation and commissioning of the charging infrastructure, depot operations and bus route operations. As per ESAP#7, GMPL will develop/update existing emergency preparedness and response framework at corporate level and implement emergency preparedness and response plans for proposed B2G sites and existing B2C sites during construction, bus route operations including site-specific emergency response procedures for depot level emergencies including community unrest and workers’ protest and the enroute emergencies such as medical emergency with driver, medical emergency with passengers, security incidents  and community unrest. Separately, GMPL as per the CA requirement, will ensure that all staff are given clear instructions in line with the Plan, including training to deliver public address announcements in a way that avoids causing an alarm and that instils confidence in passengers.

Monitoring & Reporting: The existing operations for GMPL has provision for monthly E&S reporting covering aspects such as:  manhour worked/ lost, enroute incidence, in-depot incidence, environmental monitoring, near miss, fire incidence, violations, work permits, mock drills, day/night inspections, trainings (internal and external), toolbox talks, route risk assessment, EHS committee meetings, and external stakeholder engagement. GMPL also has provision for a weekly management review which includes safety updates covering E&S reporting aspects.

GMPL ESMS has provision for internal EHS Monitoring and audit to include weekly EHS inspection and survey by EHS manager, quarterly EHS Audit by process team at corporate level including regulatory compliance, Safety audit on an annual basis for B2G and submission to Authority; however, these need to be formalized and strengthened further with additional EHSS resources at corporate level (refer ESAP#6). As part of ESAP#2, GMPL will further update the E&S monitoring requirements, especially regular tracking of the compliance register, including labour and working conditions for direct as well as contract/ third party workers. GMPL will implement an E&S monitoring and auditing procedure that covers regular inspections, internal and external audits and senior management reviews to ensure ESMS implementation as well as compliance with relevant legal requirements, IFC PS and applicable WBG Environment Health and Safety (EHS) Guidelines at depot sites.

Depots/ sites under GMPL will be commissioned/ operationalized in phases depending upon the status of the signing of the CA, readiness status of sites (i.e. site handover by authority post depot level construction as per CA requirements). As part of ESAP #8, GMPL will undertake external monitoring of sample sites (proposed B2G sites and existing or additional B2C sites) by a competent third-party, (a) on a six-monthly basis for the first one year; (b) annually from second year to assess ESMS implementation, and compliance with E&S requirements for the next 4 years. Subsequent monitoring requirements to be decided based on ESMS implementation status. Further, GMPL will have provision for additional monitoring, as required from time to time.

PS2: Labor and Working Conditions

HR management structure combines corporate oversight with site level implementation role to streamline operations and ensure HR policy and procedure compliance. At the corporate level, GMPL has Human Resources (HR) vertical for functions like policy alignment, corporate recruitment, workforce management, payroll, employee well-being programs, and handling corporate-level employee relations while the Industrial Relations (IR) vertical IR, worker relations, training, policy implementation and legal compliance across depots. Local HR/IR coordinates with the corporate HR team to ensure that the local HR practices follow the broader GMPL policies and local labour laws. The corporate office ensures consistent HR policies, such as adherence to labor regulations, employee grievance, Prevention of sexual harassment (PoSH) and compensation across the complete Greencell mobility operations.  Local HR teams manage day-to-day payroll processing and attendance tracking; however, final payroll consolidation and disbursement are centralized at the corporate office. The corporate office reviews, approves, and disburses payroll after verifying compliance with established procedures and obtaining necessary approvals from the respective heads of each business unit. The existing workforce of GMPL includes: on-roll employees, Fixed Term Contract (FTC) and apprentices under National Apprenticeship Promotion Scheme (NAPS) and National Apprenticeship Training Scheme (NATS); and third-party workers- either through service contractor or manpower agencies. Existing manpower (off roll and on- roll) is around 5500 while additional manpower requirement for GMPL operations will be around 8000, out of which GMPL own staff will be less than 100, while the remaining workforce will include third party workers mobilised under Annual Maintenance Agreement (AMC) for e-buses and charging infrastructure, security, bus operator (including drivers) and other small AMC contracts.

Human Resource (HR) Policies and Procedures: Majority of existing GMPL policies developed cover company/ on-roll staff.  GMPL follows model standing order (as per Industrial Employment Standing Orders Act, 1946) and other labour laws specific to state for workers. There are few other policies for off roll workers (contractor management policies) which are also made applicable for on roll fixed term contract (FTC) and apprentices. GMPL, as part of ESAP#9 will (a) adopt, update and implement the existing corporate Human Resource policies (as applicable for different categories of workforce) in line with all IFC PS 2 requirements covering: working conditions and terms of employment; prohibition of child labour, forced labour and discrimination; grievance mechanism; PoSH; collective bargaining and freedom of association; retrenchment; and (b) Incorporate the updated human resources policies in contractual E&S agreements with all suppliers and labor contractors. GMPL (corporate/ platform) updated HR policies will be adopted and implemented by each of the depots.  

The company had commissioned a third-party labour due diligence (DD) of GMPL corporate platform, and sample existing depot operations sample depots under B2G (outside of the project) and B2C operations. As part of ESAP#2, GMPL will implement the labour corrective action plan (CAP) which among others includes interventions on improved and fit for purpose contractor management, improved  access to GM for contract workers, clarity in terms and conditions of employment, ensure validity of legal permits/ licenses by adopting a robust legal register and monitoring system, compliance to labour regulations etc. as applicable based on labour DD across GMPL depots including development of stipulated policies and procedures.

Working Conditions and Terms of Employment: GMPL will ensure that all employees receive appointment letter clearly articulating terms and condition of employment in line with updated HR policies and procedures.

Grievance Mechanism: The existing GM policy covers all on roll employees and direct workers of company. GMPL will as part of ESAP#9, update the existing GM inclusive of anonymous option for reporting grievances, access for third party workers, GBVH sensitive channels, and detailed procedure for communication/ reporting/ tracking.

Prevention of Sexual Harassment (PoSH): The corporate HR policy on PoSH meets the legal requirement including formation of the Internal committee (IC), resolution of grievances. Training on POSH policy and procedures was found to be conducted at corporate level and at site level; however, more focus is required for third party workers awareness. GMPL will update and adopt the corporate HR policy related to PoSH (refer ESAP#9) with further details on Internal Committee (IC) roles and responsibility, access to third party workers, training and awareness generation of workers (including third party workers) and IC committee members, investigation procedure, survivor centric approach as part investigation and resolution of grievances.

Retrenchment: The company policies on retrenchment indicate that the company complies with the host country regulations should there be a situation requiring retrenchment. As part of ESAP#9, the company will update the retrenchment policy to include provision for retrenchment plan preparation in cases where retrenchment cannot be avoided, and should reflect GMPL consultation with workers, unions, or other stakeholders in line with local law. Given that 95% of workforce is contractual the key requirement is to comply with the applicable labour regulations.

Worker’s Accommodation: The company does not envisage accommodation facility at the upcoming depots/ sites during operations. Resting areas and canteen though mostly available in existing depots need to be improved; GMPL will ensure adequate resting areas and canteen for upcoming depots to workers (drivers, maintenance crew, etc).at depots including access to sanitation facilities. As per ESAP#2, the company will put in provision for amenities such as resting areas, cafeteria / canteen available to workers (drivers, maintenance crew, etc.).

Third party workers: The company engages third party workers (through manpower contract/ service contract) for depot operations, charging infrastructure maintenance, O&M of buses (including drivers/ coach captain), security, and housekeeping, tyre maintenance, battery maintenance among others. In some cases, these contracts will be further sub-contracted. As part of ESAP#2, the contractor management system will be further updated to include: mapping of the contractors/ sub-contractors and deployed manpower associated with each of the contractor; compliance records and legal compliance monitoring (related to labour and working conditions and OHS); internal monitoring of the contractor performance (frequency of monitoring should be determined on the basis of risk profile of contractors). GMPL will ensure that contractor management system is implemented, contractor management becomes the responsibility of the contract holders (user department) with compliance monitoring and assurance implemented by the EHS Officers and HR/IR teams (as per ESAP#6), and dedicated manpower is assigned for implementation and monitoring of the contractor management system implementation. GMPL contractual agreements with contractors will mandate E&S compliance with applicable labour regulations, GMPL policies and procedures including IFC PS requirements. GMPL will establish a GM to address the concerns of third-party workers.

Occupational, Health and Safety (OHS): The corporate ESMS includes Hazard Identification and Risk assessment (HIRA) for construction and Operation and Maintenance. The activities identified in the ESMS HIRA include Cable trench maintenance activities, HT/LT panel maintenance work, machine operations, work at height during windshield replacement, loading and unloading of materials, EV and other vehicle operations in depot and outside the depot, bus enroute, depot construction activities, and manual handling of office equipment. Apart from this each depot site was observed to have developed Depot specific HIRA including aspects such as bus charging, Micro Controller Unit (MCU) replacement, battery unloading process, HV Battery Handling process, battery coolant change, charger socket installation, battery Cooling System, battery compartment smoke detector, Hazardous Waste Handling, tyre air pressure check- inflation & deflation, route survey (Separate Vehicle), Route Survey through EV Bus and operation-list of High Risk activity to name a few. GMPL depot sites as part of ISO 45001:2018 certifications, has developed SOP for O&M activity. However, HIRA needs to be updated to cover bus washing, ETP/Water recycling plant operations and handling of chemicals in store. As part of ESAP #2, the HIRA will be strengthened to include aspects such as bus washing, ETP/Water recycling plant operations and handling of chemicals provision. Site specific HIRA will be developed for all the upcoming sites specific to different work zones within the depot and appropriate signages, highlighting the risk assessments and safety instructions will be displayed in respective work areas. The approved risk assessments should be communicated to all impacted workers in operations phase. GMPL hires an external/third party for conducting road accident investigation which includes analysis of probable causes and identification of root causes, summary of probable causes and finally recommendations.  The company will maintain records of Lost Time Incident Frequency Rates (LTIFR) across depots. 

Supply Chain: GMPL will be sourcing Electric vehicles and charging infrastructure from multiple companies. For the proposed project the key suppliers envisaged are: (a) OEMs under consideration are EKA and Volvo Eicher. GMPL also is in discussions with other OEMs; (b) Charger suppliers considered are Star charge and Exicom chargers. The supplier CoC provides for compliance with labour regulations and supply chain policy includes compliance with applicable labour laws etc. As part of ESAP #10, GMPL will (a) update the supplier code of conduct; (b) evaluate OEMs’ standards and key components of their supply chain management systems and document it as part of its due diligence process; c)  GMPL will share its corporate vendor code of conduct with the OEMs to clearly set its expectations regarding the expected standards to be applied in the supply chain. The obligation for OEMs to be aligned with GMPL’s code will be reflected in contractual clauses and declarations / representations from OEMs. Assessing the alignment or equivalency of OEMs’ systems with GMPL’s corporate code will be part of GMPL’s ongoing compliance monitoring activities; in case the OEM’s code of conduct is deemed to be stricter than GMPL’s code of conduct, then the OEM’s code of conduct should prevail.  

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: The water requirement at depots will be for domestic consumption and for bus washing. The water is proposed to be sourced [through tankers or through municipal supply, as applicable for respective depots] and stored in underground water tanks (capacity depending upon need). The source of water for the sites will be confirmed as part of the ESDD for each proposed depot (refer ESAP#1). The depots will install water meter and maintain log book to record daily water consumption.  The company proposes using Light Emitting Diode (LED) lights at the bus depot and the electric chargers to be installed are designed to have higher efficiency. The company will continue to explore opportunities to improve energy efficiency across its operations and expand its renewable energy footprint.

Greenhouse Gases (GHG) Emissions: The Project supports the introduction of 2,381 electric buses and associated infrastructure.  The annual electricity demand of the buses is 196 million kWh resulting in emissions of 119,331 tCO2 per year when the buses are recharged from India’s grid.  In the base case, a diesel bus fleet of equivalent size would emit 154,509 tCO2e per year. Therefore, the switch to electric buses leads to emissions reductions of 35,178 tCO2e per year. The coolant used in the buses is R410 A which is not an Ozone Depleting Substance (ODS).

Air & Noise Emissions and vibration impacts: The key source of air emissions is related to back up Diesel Generator (DG) set (if required), and fugitive dust emission from vehicular movement. The depots will comply with the existing regulations (Consent to Operate from State Pollution Control Board) as well as the environmental monitoring regime as part of the ESMS. Environmental monitoring will include ambient air quality monitoring in compliance with the national ambient air quality standards.  Noise will be generated at the depot from operation of compressors, DG Set (when operated), day-to-day activities and other maintenance activities at the depot, and vehicular movement. The DG set will be provided with acoustic enclosure. The company will further undertake ambient noise monitoring to ensure noise levels are within prescribed limits. Any concerns related to environment, health and safety or vibration impacts to nearby communities will be addressed through GM (refer ESAP#11).

Wastewater Treatment: The domestic wastewater generated from the depots will be treated through a septic tank followed by soak pit. The company will generate process wastewater from its bus washing operations. The water from the washing activity will be treated through an Effluent Treatment Plant (ETP) of adequate capacity (as per State Pollution Control Board (SPCB) requirements). Some of the existing depots may have provision for ETP or may require to be constructed by GMPL; this will be confirmed during the specific ESDD to be undertaken for each proposed depot. The ETP treatment process will be as per specific SPCB requirements and will include provisions such as bar screen for separation of floating materials, oil skimming for oil and grease removal, provision for removal of suspended particles, provision for tertiary treatment comprising of ozonator, multigrade sand filter, activated carbon filter. The entire treated water will be re-used for washing along with raw water. Wastewater at both inlet and outlet of ETP will be monitored to comply with applicable regulation and WBG EHS guidelines and will follow the environmental monitoring plan as per ESMS.

Waste management: The depots will generate hazardous waste such as used or spent oil, empty barrels/containers/ liners contaminated with hazardous chemicals /wastes, contaminated cotton rags or other cleaning materials and Chemical sludge from wastewater treatment. The depots will document all categories of hazardous waste generated as part of their operation and store them properly with adequate labelling and secondary containment and ensure disposal through authorized vendors in line with the local regulations. Sludge collected from the ETP will be taken to sludge filter press for removal of water and will be disposed through authorized vendors. Waste tyres will be re-treaded and re-fitted till the time tyres are serviceable or replaced by the tyre companies as per agreement. The battery used will be likely Lithium Iron Phosphate batteries (also known as LFP battery) or any advanced chemistry in future (except any Cobalt based chemistry). Used UPS batteries will be managed by buy back mechanism. The e-waste  including battery waste generated from the buses will be segregated and stored at site or these may be used as second life in energy storage projects and will be managed by the original equipment manufacturer (OEM)/ electric vehicle supplier private limited as per the Extended Producer Responsibility (EPR) obligations of OEM who in turn will maintain records of the vendor appointed for disposal of Battery waste. The other waste streams such as paper, cartons, plastics, and iron scrap will be disposed of through third-party recyclers.

Hazardous Chemicals: The depots store chemicals such as lubricant, coolant, paints, varnishes, lacquers, and thinners and some housekeeping chemicals, many of which are flammable.

As part of ESMS update (refer ESAP#2), the company will update and implement the site-specific environmental monitoring and management plans (EMP) for each depot operations covering all resource efficiency and pollution aspects such as noise, vibrations, air emissions, wastewater, hazardous chemicals, and wastes generated from the Project, consistent with national law, requirements of IFC PSs and WBG General EHS Guidelines. The plan while detailing out chemical management will have provision for chemical incident and accident prevention and control procedure that offers specific guidance for storage, transportation, transfer, handling, and disposal of chemicals including: inventory management of chemicals along with name, quantity and place of storage; Material Safety Data Sheet (MSDS) display for the chemicals (at the place of storage); provision for secondary containment trays for containers with hazardous chemicals; and spill kits for spill management. Similarly, waste management will have provision for records on the quantity of waste handled for various waste streams, provision for adequate hazardous materials and waste storage areas (for depot sites), and manifests are maintained for all waste disposed of through vendors. 

PS4: Community Health, Safety and Security

Infrastructure and equipment design and safety:  Office buildings in designated high seismic zones will be designed, built, and certified or approved by competent authorities and will form part of GMPL screening during site/ depot handover by the authorities. E-bus to be mobilised for operations under GMPL will need certificate for compliance under the Central Motor Vehicles Rules (CMVR) 1989 issued by International Centre for Automotive technology (ICTA), as is the practice for other concessions and verified during appraisal. The certification confirms that the base model complies with the provisions of the CMVR as amended up to date, and is verified based on the use of specific components/ parts/ assemblies etc. GMPL puts this responsibility on the OEM/ bus supplier.

Life and Fire Safety: Charging infrastructure and other electrical infrastructure and depot operations: For chargers, the suppliers are mostly Star Charge, Exicom and other established companies. In case of chargers, the charging activity is carried out by electricians of bus Operator, and the maintenance is carried out by charger supplier as they execute a separate charging maintenance agreement with charger supplier. Sample charging infrastructure review during appraisal was found to be adequate and no material gaps were identified. Fire license/ No Objection Certificate (NoC) is usually under the scope of GMPL for B2G operations and will typically include fire safety measures including fire extinguisher, manual call points, fire alarm panel, smoke detectors and hydrant system. For B2C operations, the company will be responsible for fire NoC and provisioning fire mitigation measures as per the license.

E-Bus Safety: The bus model and safety requirements in the e-bus will vary with each CA. GMPL will ensure that buses provided through its supplier will meet the requirements stipulated in CA with respective authorities and confirmed by each authority during trial run and buses will be onboarded once approved by authorities. The sample e- buses reviewed as part of the appraisal had extensive emergency provisions including key components on the roof, anti-pinch Sensors for passenger doors, emergency exits, driver-operated emergency switches, fire extinguishers and including Fire Detection & Suppression System (FDSS) kits, surveillance cameras, SOS buttons, and an Automatic Vehicle Location System (AVLS) for real-time monitoring. GMPL SOP for maintenance ensures continuous checks on charging, preventive and corrective maintenance, and battery management with onboard sensors and GPS tracking. Electric buses are equipped with safety features to protect the batteries and prevent issues in case of emergencies, including a battery cut-off switch to isolate the battery from the main system, and a cooling system to maintain optimal battery temperature.

For B2C operations, GMPL has AIS 140 devices (Vehicle Tracking, Emergency request, video surveillance, Data transmission). B2C operations has its own Control Command Centre (CCC) at the depots and has features to receive passenger SOS. SOS buttons were provided near every row of seats. In addition, safe driving behavior monitoring using Intelligent Telemetry Management System (ITMS) is in place to track coach captain behaviors such as fatigue / yawning, distractions, harsh acceleration, harsh breaking, and over speeding. In the B2G model, the SOS feature will remain under the purview of Authority (including its own CCC as per CA provisions), while GMPL’s CCC of SPVs will receive only driver over speeding alert.

Transformers, substations, charging infrastructure including installation, commissioning and operations will be managed through O&M agreements with third party, who will have their SOPs for installation, commissioning and operations. However, as part of ESAP#2, GMPL will update its electrical safety standard operating procedures and practices including electrical installations, charging infrastructure installation, commissioning and operation in line with local regulations and applicable industry standards and monitor the installation, commissioning, and operations as part of ESMS monitoring.

Traffic Safety: Route Safety Assessment: As per the current practice, GMPL has developed a SOP for conducting route survey for route risk assessment (RRA) with a scope to identify any risk associated with a route. As per the procedure, SPV head shall be responsible for conducting the route survey once the route details are received from the Authority. Subsequently, a cross functional team comprising of employees from the operations team, risk assessment team, IT and business excellence team conduct physical route surveys, and prepare a route survey report. The Intelligent Technology Management System is accordingly configured by the IT and the respective schedule incorporated. RRA was observed to be conducted at all the existing depots visited during ESDD. GMPL will ensure that route safety assessments are conducted for upcoming operations.

Further, GMPL complies with the CA and applicable regulatory requirements related to bus drivers which include aspects such as: valid driving license and experience in driving heavy transport vehicle for at least 3 years; not blacklisted from operating heavy commercial vehicle; no pending cases related to fatal accidents or traffic violations; driver receive a combination of classroom instruction and behind-the-wheel instructions. GMPL has a dedicated trainer and a simulator for each SPV (including 4-5 depots) in B2G model, and 1 dedicated trainer and simulator for each B2C depot. GMPL will replicate similar provisions for the upcoming project going forward (refer ESAP#2).

Gender Based Violence and Harassment: In both B2G and B2C operations, the passengers are not allowed to the depot locations. Depot related GBVH issues are handed through IC committee as per POSH provisions stipulated under law (refer PS 2 section). In B2G operations, the passengers traveling in buses can be exposed to GBVH risk where GMPL has limited leverage. In B2C operations too, the passengers can be faced with similar GBVH risk. The company as part of ESAP#4, will develop specific guidelines and procedure pertaining to GBVH, which will include (a) provision for display of helpline numbers; (b) training of drivers/ coach captain and cabin host (in B2C operations) on sensitivity to GBVH issue, and immediate measures to be taken including pressing of SOS button, and information sharing with CCC to mobilise support through local authorities on priority; (c) provision of camera footage and other evidence (as required) sharing as per the need and request of authorities. 

Security Personnel: Similar other operations under GMPL existing B2G and B2C operations indicate that depots typically engage unarmed security personnel through agreement with security contractors registered under Private Security Agencies (Regulation) Act, 2005 which includes aspects such as personal hygiene, physical security, material movements, mob control, firefighting, first aid etc. At B2C depots, the security contracts were directly with the SPV where as in B2G the agreement was either with SPV or subcontracted with Bus operator/ contractor. As per ESAP#2, the company will develop security management plan in line with the requirements of IFC PS 4 which will be guided by the principles of proportionality and good international practice and include procedures to: ensure hiring, rules of conduct, training, and monitoring of security personnel; train security personnel to exhibit appropriate conduct towards depot workers and driver; and to receive and resolve grievances about the security arrangements and acts of security personnel.                   

 The External stakeholders for GMPL operations include shareholders, driver and other worker union/ collectives regulators, government agencies & local Authorities, service providers and suppliers, media, community, NGOs, and public at large. GMPL ESMS includes a stakeholder engagement framework which covers stakeholder identification, mapping and analysis; stakeholder engagement methods; frequency of engagement; dissemination of Grievance Mechanism (GM); and information disclosure through company website, annual reports, social media outreach etc.  In B2G, as per CA, SPVs are expected to maintain the complaint register on each e-bus to receive passenger grievance if any. In B2G, grievances in case of bus related issues are handled by GMPL; however, SOS messages are routed to authority for necessary action which involve coordination with local authorities such as police, fire department, disaster response, etc. In the case of B2C, there is a separate customer experience division in GEPL for handling customer / passenger grievance. Cabin host also has provision for logging passenger grievances through mobile application. Also, there is provision of customer care center (third party – Cogen based out of Mumbai) and online login of complaints via NeuGo website and sometime complaints/feedback are also reported from social media platforms. In case of serious issues requiring local authority intervention, the CCC is updated to support coordination with local authorities along the route. Grievance records raised by customers from January 2025 to May 2025 for B2C operations were made available for review; additional documentation required includes remedial measures and closure records. As part of ESAP# 11, GMPL will implement a stakeholder engagement plan (SEP) and external GM at depot level (considering nature of B2G and B2C operations and clearly outlining role of authorities in intracity operations and local authorities such as police, fire department, district hospitals etc. role in B2C operations) aligned to the corporate stakeholder engagement framework and IFC PS requirements, including (i) stakeholder identification, analysis, and planning, (ii) disclosure and dissemination of information; and (iii) commuters/public grievance mechanism including records of grievances and closure of grievances, and (iv) reporting to stakeholders such as authorities, commuters, and road users. All the sites will be expected to record details of stakeholder consultations at the depot level.

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