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 and Management Programs
The company has embarked on a sustainability focused approach from 2018 and established corporate sustainability and HR policies (aligned to IFC PS2), supported by plant level environment, health and safety (EHS) policies, procedures and systems, that are aligned with corporate policies. The company has established integrated management systems (IMS) based on ISO 9001, ISO 14001, ISO 45001, and ISO 50001 across all their plants. The company has been reporting annually on Sustainability performance at a group level since 2018 using Global Reporting Initiative (GRI) standards, with assurance provided by Deloitte Haskins and Sells LLP.
(https://www.dcmshriram.com/docs/sustainability-report/Dcm-shriram-ltd-sustainabilty-report-2024-25.pdf) and an annual reporting on Business Responsibility and Sustainability Reporting (BRSR)
(https://nsearchives.nseindia.com/corporate/DCMSHRIRAM_16072025155812_BRSRSEINTIMATION2025SIGNED.pdf) for the Securities and Exchange Board of India (SEBI). The chemical plant of DCM in Bharuch is also compliant with Responsible Care (safe management of chemicals) and International Sustainability and Carbon Certification (ISSC). The company has also carried out Product Life Cycle Assessment (LCA) for key plants in Bharuch & Kota and is planning to conduct LCA studies for new facilities including ALCAL plant. The three sugar plants in Loni, Ajbapur and Hariawan in Uttar Pradesh have secured BONSUCRO certification that is a leading global sustainability platform and standard for accelerating the sustainable production and uses of sugarcane,
focusing on climate action, human rights and value in the supply chain. As part of this certification, DCM has established mechanisms for farmer outreach that address their support requirements as well as concerns. A 24x7 call center is operated by DCM for all sugar plants where such queries are handled.
The group has an on-going communication of its EHS policies with all employees, contractors, service providers, third-party suppliers, farmers and stakeholders through different channels of communication. The company’s E&S management systems established and maintained at all the plants were noted to be commensurate with the nature and scale of the project’s E&S risks and impacts of its operations and IFC PS.
Identification of Risks and Impacts
The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards, E&S regulatory permits and IFC PS requirements. The company has carried out environmental impact assessment (EIA) studies based on national requirements and obtained prior environmental clearance (EC) as applicable. The company has been complying with EC conditions and submitting half yearly monitoring reports to the authorities. All the plants of DCM have secured valid consents from the respective State Pollution Control Boards (SPCBs) and other required E&S permits including fire no-objection certificate, hazardous waste authorization, factories license and groundwater abstraction permission as applicable. The company has engaged a third party agency to help in identifying, updating and tracking regulatory compliance based on a web based dashboard. Compliance reports are submitted periodically by the company to the relevant authorities as required under their permits. Based on its IMS, the plants identify environmental aspects and occupational health and safety risks and plan for mitigation measures. The systems were found commensurate to the nature and size of the E&S risks of the DCM operations as well as IFC’s requirements. E&S action plans are proposed wherever gaps
were identified during IFC’s appraisal.
Identification of Risks and Impacts in the Proposed ALCAL Plant
The ALCAL plant does not require a prior environmental clearance according to the Environmental Impact Assessment (EIA) notification, 2006. A Consent to Establish has been secured for the ALCAL plant from the SPCB. The ALCAL plant will use a coal fired boiler to generate steam and a coal fired furnace to generate hot air required for process drying. The coal based boiler and furnace to be installed in the ALCAL plant are designed for emission norms aligned to IFC’s EHS guidelines as per General and Thermal power plant sector. The company will (as part of ESAP #1 (i)) carry out an independent air quality modelling of emissions from coal fired boiler and hot air furnace, using an appropriate model to establish compliance with Indian National Ambient Air Quality standards
(NAAQS) and World Bank Group (WBG) General EHS Guidelines (Table 1.1.1) at plant fence and local community receptors around the site; and implement additional air pollution control measures if required.
To integrate and harmonize various environment, health, safety and social initiatives and management systems of the ALCAL plant, and to demonstrate and track compliance with IFC PS1, the Company will (ESAP #1 (ii)) develop an Environmental and Social Management System (ESMS) document that integrates and collates all their individual management systems and practices. The ESMS will incorporate the following elements: (i) E&S as well as HR policies; (ii) organizational capacity and competency (iii) identification of risks and impacts across its operations; (iv) documented E&S operational manuals, procedures, practices, plans and management programs to comply with regulations, the IFC Performance Standards, and relevant WBG General EHS guidelines; hazardous material and
waste management; (v) labor and working conditions, including oversight of contractors and occupational health and safety; and emergency preparedness and response; (vi) community and stakeholder engagement; and (vii) monitoring and review. The ESMS should also include management of change procedure for new project or expansion activity.
The company has conducted Quantitative Risk Assessment (QRA) and Hazard Operability (HAZOP) studies for specific hazardous chemicals that will be used in the plant (such as chlorine, etc.) handled and stored at their plants using nationally accredited agencies. The QRA study for chlorine pipeline from the chlor-alkali plant to ALCAL plant (2.5km) indicates that the 10-5 per year, 10-6 per year & 10-7 per year, location specific individual risk (LSIR) contours are extending around the chlorine pipeline but within the Jhagadia industrial estate and fall under “As Low As Reasonably Practicable” (ALARP) levels / Acceptable Region (meaning there is a measurable risk zone along the pipeline route). The societal risk frequency and number of fatalities (FN) curve falls in the ALARP region as per risk acceptance criteria for societal risk (meaning that while the risk in not unacceptable, further mitigation is recommended). As part of ESAP #1 (iii), the company will implement the Corrective Action Plan (CAP) recommended by the QRA studies for the chlorine pipeline from DCM’s Chlor-alkali plant to ALCAL plant.
There are no associated facilities (AFs) of the projects covered under IFC’s proposed investment, as defined under IFC PS1. The ALCAL plant will source chlorine gas and hydrochloric acid (HCl) from DCM’s existing chlor-alkali facility in Bharuch to produce aluminum chloride and calcium chloride. The supply is not expected to exceed 10% of the chlor-alkali plant’s total production capacity that will also serve other clients, hence the chlor-alkali plant of DCM is not considered an associated facility. Hydrochloric acid (HCl) required for the Calcium Chloride manufacturing, may also be sourced alternately from other agencies / manufacturing units meeting the supply chain policy of DCM.
As part of ESAP #1 (vi) DCM will conduct a journey risk assessment for safe transport of chlorine tonners (till the chlorine pipeline is commissioned) and HCL from existing Bharuch plant and other suppliers to the ALCAL plant. HAZOP studies were carried out for the chlor-alkali plant in Kota in 2019 through a competent agency and the corrective actions recommended based on gaps observed have been implemented Organizational Capacity and Competency The E&S function at the corporate level is led by a whole time director on EHS, supported by a Senior Manager, Sustainability. This corporate team guides the plant level EHS teams – 27 in Chemicals and Vinyl, at Bharuch, 14 in Chemicals complex, at Kota, 14 in Sugar and Distillery, in UP. Additionally the plant level EHS teams are supported by emergency response teams, fire fighters, first aiders constituted from the employees and workers. A corporate HR Head is responsible for formulation of HR policies that are implemented by HR departments in all the plants. Procurement is at business level function supported by purchase departments at the plant level. All staff responsible for EHS have the appropriate expertise and training to effectively perform their jobs.
DCM has developed an annual training calendar based on a needs assessment which various training courses are conducted for all employees, contractual staff and workers. Annual training personhours for staff and contractors are recorded by the company.
Emergency Preparedness and Response
The company has documented an integrated emergency response plan for their operations at the Kota chemical complex. Site specific dedicated EPRPs are available for the sugar and distillery units. The EPRPs include responses to chemical leaks / exposures, smoke and fire, abnormal operations and controls, natural calamities and medical cases etc. The ammonia, urea and chlor-alkali plants are subjected to emergency mock drills and fire fighting drills on a three to six monthly frequency. The EPRPs are reviewed and updated as needed based on the outcome of the drills and on an annual frequency.
The roles and responsibilities for various teams responsible for evacuation, rescue, firefighting etc. are defined and displayed at various locations across the plants. An offsite emergency response plan is developed through the local district collector’s office for each plant in consultation with other industries in the area. A mutual aid initiative with other industries in Kota and Bharuch sites has been established and implemented. Under this initiative all the industries pool resources in terms of ambulance and fire tender services, human resources, technical knowhow etc. for handling emergencies.
Fire safety systems in the facilities for sugar manufacturing are mainly based on fire extinguishers and fire hydrants with dedicated fire water storage and pumping systems. The distillery operations in Ajbapur and Hariawan also have higher fire safety risks (due to distillery units) and hence have been provided with wet risers for the production floors, sprinkling systems for alcohol storage tanks and water and foam monitors.
All other plant sites are also provided with dedicated firewater storages, fire hydrant system, first aid and firefighting equipment are installed across the plant, all PESO licensed installations are protected with water based system, electrical panels are protected with fire suppressant flooding system, and an inhouse fire tender (in Kota and sugar plants) is available round the clock with dedicated and trained crew. Fire alarm call points, gas leak detectors and alarm systems, evacuation route maps and hose reels have been placed at relevant locations. The compliance team conducts internal audits to ensure implementation of fire safety measures through mock drills. Emergency response teams and workers have been trained in fire safety and operation of fire safety equipment every month including
construction workers.
Monitoring and Review
As part of the corporate EHS management systems across all its plants, the company conducts environmental pollution monitoring (such as ambient air, point source emissions, ambient noise levels, workplace air quality, equipment noise levels, influent and treated effluent, treated sewage) as per permit conditions and key performance indicators (KPIs) such as record of injuries / Lost time incident frequency rate (LTIFR), Life and Fire Safety (L&FS) measures, usage of personal protective equipment (PPE), energy and water consumption, waste generation covering construction and operations. The KPIs are reported to the compliance management team based on internal audits. All incidents are summarized and discussed in the quarterly management meeting and the team analyses the
root causes and implements corrective actions as necessary. All plants of DCM submit a monthly performance report to the Director – EHS which includes highlights, compliance status with all permits, monthly safety performance with details of the incidents, production data and online testing data for air and effluent quality.
External Communication and GRM for Affected Communities
The DCM plants have established a proactive and responsive approach to addressing neighborhood grievances and community concerns. The following measures have been put in place: Continuous Engagement- The Security Department is in regular contact with local representatives, community leaders, and residents to ensure open lines of communication and early identification of any issues; Surveillance and Monitoring - The general area surrounding the plant is kept under constant surveillance, enabling prompt detection of any disturbances or concerns that may arise; and Immediate Response Protocol - Any grievance or complaint received from the neighborhood is immediately addressed through a structured internal process involving relevant departments to ensure timely
resolution and feedback to the complainant. The company has also established and implemented an external grievance redress procedure for its sugar plants that is communicated to local community. The sugar plants also operate a call-center facility (in local language) for providing easy access to local farmers for raising grievances and seeking support. All plants maintain a register of complaints / concerns and resolution status. Sample records were reviewed during IFC’s appraisal and found to be satisfactory. Internal staff concerns include issues related to transport, housekeeping, hygiene in toilet blocks, water spillage, etc. External concerns raised by farmers in sugar plants through the call center facility of DCM, include issues related to support on soil quality testing, seeds, creeper control, foliar spray, farming equipment, banking related queries etc. The queries are tracked and closed based on corrective actions taken and records are maintained.
PS2- Labor and working conditions
As on July 2025, at a consolidated level DCM has 3895 permanent employees and 11555 contractual workers, of which about 95% are male in both categories. At a plant level the sugar business across all plants engages 447 male and 26 female permanent employees supported by 2882 male and 9 female contractual workers (largely during peak crushing season). The Kota complex employs 626 male and 24 female permanent employees supported by 2339 male and 2 female contractual workers. The ALCAL plant will employ 67 permanent employees and 150 contractual employees. About 10% overall staff in ALCAL plant is expected to be female. The present gender diversity at a group level stands at 5% and the company has taken a target to raise it further in the next FY.
DCM has corporate level policies related to E&S / EHS, Human Resources, Human Rights, etc. that are publicly available on their website at https://www.dcmshriram.com/. These policies are applicable across all plants and subsidiaries of the company. DCM has documented HR policies and procedures that are consistent with the national labor regulations and IFC PS 2 requirements and apply to all employees, suppliers and contractors. The company policies mandate non-discrimination and equal opportunity for its on-roll staff, contract staff / contractor workers and 3rd parties. The company has established and implemented HR policies and procedures addressing recruitment based on equal opportunity and zero discrimination, separation, communication of terms of employment, compliance with minimum wages, fair hours of work and double overtime payment, leave management, performance assessment / KPIs, freedom of association and collective bargaining agreement mechanisms,
prohibition of child labor, forced labor, grievance redress mechanism and prevention of sexual harassment. The security personnel at all the plants of DCM operate in 8 hourly shifts and are rotated. If required to work beyond 8h, they are paid overtime as per applicable regulation. Each employee / worker receives a written contract that describes the working conditions and terms of employment,
along with an employee handbook. DCM’s plants require its contractors to comply with national labor laws through specific contract clauses. The company’s HR team monitors the labor contractors’ compliance with applicable labor laws and compliance with related contract clauses, on a periodic basis.
The Kota complex of the company has two unions in Kota that are recognized by the management and have formal collective bargaining mechanisms with employees. Other plants do not have unions, but have mechanisms to address employee demands and concerns. IFC reviewed sample records and minutes of meetings held between management and employees.
The company has a documented grievance mechanism for its internal stakeholders in line with its HR policy and the Prevention of Sexual Harassment of Women at Workplace (POSH) regulation. The grievance mechanism allows for submission of anonymous grievances through suggestion boxes in the company’s plants. This mechanism is also available to the contractors’ workers, and they are included in related training and awareness campaigns conducted by the HR department. The company, through its HR department has also established proactive initiatives at all the plants to identify and resolve concerns and grievances of staff and contractors. The sugar plants have also developed an external community grievance system for the farmers and other local communities, In order to strengthen the existing POSH policy, the company (as part of ESAP #2 (i)) will develop and implement a corporate level dedicated Gender Based Violence (GBV) policy and procedure, building upon the existing POSH Policy to address survivor centric grievance & support system and extend access to the grievance redress mechanism (GRM) to employees, contractors and farmer community engaged by the company.
The company does not have any onsite labour accommodation in any of its plants including the under construction site of ALCAL. Contractors organize accommodation for workers in the nearby area. To further improve compliance with IFC PS2, the Company will (as part of ESAP #2 (ii)) adopt and adapt IFC’s labor accommodation guidelines (Part II: Standards for and management of workers accommodation, Workers’ accommodation: processes and standards, A guidance note by IFC and the EBRD, August 2009) for all future engagement of contractors where
accommodation is provided.
In the company’s sugar plants, contractual labor are engaged for the peak crushing season through a mix of contractors and direct hires. All the permanent and seasonal workers sign a contract with the company with the terms of employment which are aligned with the national requirements and PS2. The policies are explained in the induction and HR portal. The permanent and seasonal workers have legal benefits of provident fund, gratuity and bonus and are covered in the personal accident policies of the company. The attendance is tracked through a punching system and the salary is paid through bank transfer. For seasonal workers, off-season retainer is paid based on the applicable legal requirements of the state for the sector. To prevent use of child labor, the facility collects age
proof documentation at the time of recruitment of the worker. As per ESAP #3 (i), the company will carry out labor compliance assessment audits during crushing season and implement corrective actions as needed, at the sugar plants in Loni, Ajbapur and Hariwan.
Occupational Health and Safety
The company has established occupational health and safety management systems in all its plants, that focusses on identification of hazards and risks, operational control procedures, permit to work, lock out tag out, work instructions etc. The company has established annual health monitoring, mediclaim and insurance policies for al employees and contractual labor.
The company has established an industrial hygiene monitoring program that regularly monitors workplace exposure on the basis of time weighted average and short term exposures, to gases such as chlorine, ammonia, respirable dust in the plants as applicable. Workplace noise levels are also monitored periodically. Sample monitoring results were reviewed during appraisal and found to be aligned to IFC’s norms. The company reported 5 fatalities involving contract labor in some of its plants in FY 22-23 (Ajbapur, Bharuch, Kota and Loni) and 2 fatalities in FY 23-24 (Kota and Hariawan). The investigation root cause analysis reports and corrective actions for these incidents have been reviewed by IFC. DCM has disclosed these incidents in its annual sustainability reports and BRSRs. All incidents/accidents/near-misses are recorded and investigated. Also, as per review of available documentation, regular internal audits are conducted by the internal audit team. EHS performance and implementation of the IMS is discussed in the management review meeting, and any gaps are addressed accordingly. The company has not reported any fatality in 2024-25.
The company has partnered with Dupont Sustainable Solutions (DSS) for chemical plant in Kota and British Safety Council (BSC) for Bharuch, sugar and distillery plants for their process and contractor safety. Experts from DSS & BSC conduct periodic safety training for staff of the company.
Workers engaged by Third Parties and Supply Chain
DCM has recently updated its Supplier Code of Conduct (SCOC) in July 2025 applicable to all its plants, that includes requirements applicable to all their suppliers, vendors and contractors (commonly addressed as suppliers). The revised policy requires all suppliers to prohibit child and forced labor, follow national statutes, ensure fair wages and working hours provide safe and healthy working hours as well as efficient use of energy, waste management, prevention of biodiversity loss, ecosystem protection and anti-bribery / anti-corruption practices. The BONSUCRO standard established in the sugar plants covers similar requirements as IFC PS2, PS3 and PS6 related to supply chain, i.e. compliance with legal requirements, prevention of human rights violation (e.g. forced and bonded labor, child labor), use of Pesticides, which are not in WHO Recommended Classification of Pesticides by Hazard Class Ia (extremely hazardous); or Ib (highly hazardous) and protection and management of biodiversity and eco-system services. Dedicated staff in the sugar plants monitor and implement the procedures established under the BONSUCRO requirements.
Cane crushed by the facility is sourced from the local catchment/command area which is allocated to the facility by the government. Based on the assessment done, the sourcing area is modified habitat already under farming activities. The company has developed and implemented procedures in the sugar plants on supply chain management on human rights and prevention of conversion of natural habitat for plantations. These procedures are integrated into the BONSUCRO system procedures.
While the company’s SCOC requires monitoring of supplier performance against the requirements through regular assessments, the company does not evaluate or conduct supplier audits at present in the chemical and vinyl plants in Kota. As per ESAP #1 (v) Conduct supplier assessment for selecting and retaining primary suppliers based on DCM’s supplier code of conduct (SCOC), in ALCAL plant. Particularly, the company will conduct these assessments for primary suppliers of aluminum, limestone, coal, and chemicals such as hydrochloric acid etc.
As part of ESAP #4 (i), the company will conduct supplier assessments for selecting and retaining primary suppliers in the Chloralkali plant in Kota based on DCM’s supplier code of conduct (SCOC).
PS3-Resource Efficiency and Pollution Prevention
Aligned with its sustainability policy, the company is implementing various initiatives to reduce energy and water consumption. Based on annual energy and water audits the company implements resource efficiency projects in its plants. The company regularly monitors resource consumption i.e., water and chemical consumption, electricity and waste generation and has established KPIs on these attributes.
Resource Efficiency
The company has undertaken specific plantwise measures in process, equipment, material management to improve its resource efficiency. DCM has identified strategic goals for improving resource efficiency and pollution prevention based on the following initiatives: use of non-fossil fuel sources of energy in the energy mix, water conservation and groundwater recharging; and waste minimization; raising awareness on climate change and mitigation measures among stakeholders; identifying nature based solutions for sequestration of CO2 and adaptation and resilience through climate smart agriculture. The company uses about 35% green energy (biomass and renewable) at present at a group level. The coal based boiler and furnace to be installed in the ALCAL plant are designed for emission norms aligned to IFC’s EHS guidelines as per General and Thermal power plant sector.
Air and Noise Emissions
The company monitors process stacks & workplace emissions and ambient air quality at plant boundaries on a monthly basis. Emission control systems on manufacturing process stacks, such as scrubbers, blowers, sprinkling system, bag filters, etc. have been provided as necessary. The emission monitoring reports indicate compliance with applicable legal requirements. All the plants of DCM are compliant with workzone and ambient noise levels and there have been no complaints from external stakeholders.
The ALCAL plant will have emissions from the coal fired hot air furnace and will generate particulate matter (PM), nitrogen oxides (NOx) and sulphur dioxide (SO2) emissions. As part of ESAP #1 (iv), the company will comply with WBG General EHS Guidelines (Table 1.1.2 and other applicable aspects) in the design and operation of the plant. The final process design is presently underway.
The chlor-alkali plant in Kota, is compliant with the ambient, process and workzone air emission levels as per national standards and WBG EHS guidelines.
The sugar and distillery plant emissions from Ajbapur and Hariawan are compliant with the national standards and WBG sector EHS guideline as reported in the E&S action plan and latest annual monitoring report submitted by the company to IFC.
The biomass based boiler in the Loni sugar plant was found to exceed the WBG EHS standards for Sugar industry (50 mg/Nm3). As per ESAP #3 (ii), the company will conduct ambient air quality monitoring at the sensitive receptors near Loni plant and assess that the current emissions are not contributing significantly to the particulate matter (PM) emissions in the air shed, in which case, the emissions upto 150 mg/Nm3 can be considered compliant with the guidelines. If not (based on the result of the monitoring), submit and agree on an improvement plan to meet
the stack emissions guidelines of 50 mg/Nm3 of PM.
GHG Emissions
Company conducted Climate Risk Assessment and disclosure through PWC that provides a comprehensive overview of DCM’s climate-related performance. In FY 2024–25, DCM Shriram formally adopted the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) - now consolidated under the IFRS S2 Climate-related Disclosures Standard issued by the International Sustainability Standards Board (ISSB). DCM completed assurance by independent agency (Deloitte) for Scope 3 inventory for DCM Shriram Ltd. The Scope 3 report has been prepared in accordance with WRI/WBCSD’s Greenhouse Gas Protocol’s Corporate Accounting and Reporting Standards.
The Company has reported its group level GHG emissions (Scope 1 and 2) for FY25 as 32,50,000 tCO2e and 1,89,000 tCO2e respectively. The production specific GHG emissions are reported as 1.02 tCO2e / MT of products manufactured. Going ahead, proposed projects such as ALCAL plant will also be included in the group level GHG emission inventory reporting.
The company implements process and emission control measures to minimize GHG emissions. DCM has also adopted targets towards neutralizing the remaining emissions through carbon offset initiatives, including promoting afforestation projects based on tree plantation initiatives outside the plant sites, The company does not use refrigerants that have been phased out.
Water Consumption
Except sugar and distillery units in Uttar Pradesh (UP), that use groundwater, all other plants of DCM are supplied water through local authority. None of the plant operations fall under water stressed areas declared by the UP State government. Rainwater harvesting schemes have been implemented in all the plants of DCM. Water is treated at the Kota complex to meet the quality requirement for various plant uses. As part of its EHS improvement program, the company has instituted aggressive water minimization and recycling programs at the Kota facility. Annually, rainwater harvesting programs at Kota contribute to a water saving of about 450,000 KL. This has improved water conservation and recharging groundwater, benefiting the local community in the vicinity.
Wastewater Management
The Kota complex of DCM have an integrated effluent treatment plant system that collects wastewater from various plants and treats them to national standards as mandated through approvals issued to the plants. The company monitors only final outlet of the integrated effluent treatment plant (ETP) common in the Kota complex. In the Kota complex, the effluent discharge has been reduced from 550 m3/h in 2006-07 to 213 m3/h in 2024-25, against a statutory limit of 337 m3/h.
Chloralkali Plant
The chloralkali plant in Kota is a zero liquid discharge (ZLD) facility, where the entire process effluent is treated through a system of high rate solids contact clarifier (HRSCC) followed by a multigrade filter (MGF), ultrafiltration and reverse osmosis (RO). The reject from this treatment is reused in the calcium carbide plant for generating acetylene, whereas the permeate is reused in colling towers as makeup water.
Sugar Plants
An ETP has been provided for the sugar manufacturing with a treatment capacity of 1000 m3/day (at Loni), 3000 m3/day (at Hariawan) and 2200 m3/day at Ajbapur. The effluent is treated through a combination of anaerobic and aerobic treatment processes. The treated effluent is used for irrigation on land owned by the company and in press mud and ash composting areas. Additionally, the facilities have agreement with farmers (in an area of about 3 to 4 km) to supply treated effluent for irrigation in their fields. The effluent quality is regularly tested both internally and externally and results were noted to meet the national standards as well as WBG EHS guidelines. More details rekated to existing projects in Ajbapur and Hariawan plants are available on IFC’s disclosure portal
(https://disclosures.ifc.org/project-detail/ESRS/42346/dcm-sugar)
Ajbapur and Hariawan Distillery Plants
The spent wash generated from the manufacturing process of distillery unit is concentrated in Multi- Effect Evaporator (MEE) and burnt in a Slop fired Boiler along with bagasse. The Condensate and other
washings are treated in dedicated Condensate Polishing Unit (CPU) of adequate treatment capacity and the treated water is finally treated through membrane filtration technology and utilized back in process making the distillery unit "Zero Liquid Discharge” (ZLD). Alcohol produced in the Distillery unit is mainly utilized for Petrol blending thereby contributing in reducing carbon foot print by reducing GHG emission.
The sewage generated in Kota complex and sugar plants are separately treated in Sewage Treatment Plants (STP) and utilized for irrigation purposes. The company has implemented rainwater harvesting projects inside the premises as well as off-site around the sites to conserve water and rejuvenate ground water by adopting ponds in the surrounding villages. The company has reported reduction in water consumption of over 60% during the last two decades at the Kota site by adding re-circulating cooling towers instead of once through cooling systems, recycling/reuse of treated effluents, increase in cycles of concentration (COC) in existing cooling towers, integrating water usage across unit process operations etc. In the sugar and distillery plants, the company has implemented interventions related to water management in collaboration with ICAR - Indian Institute of Sugarcane Research and IFC (based on previous investment).
Stormwater Management
To prevent any contaminated stormwater leaving the plant by entering the stormwater drains, the plants in Kota have provided stormwater drain channels, with sluice gates on all exit points. These gates are closed during normal operations. The EHS team monitors and records any leaks / spills throughout the year, particularly during monsoon season. Sampling is also conducted as necessary to monitor any other contamination. Contaminated rainwater from stormwater drain is transferred to buffer tank. The ALCAL plant will also have similar controls on stormwater drains.
Waste Management The company has developed waste management procedures at all its plants including a system of appropriate sorting, handling, storage and disposal which are consistent with applicable legal and IFC PS requirements. All hazardous and non-hazardous wastes are collected for disposal by authorized service agencies specializing in each type of waste. At the project sites visited, all hazardous wastes were noted to be properly labelled and stored in the designated areas.
In the sugar plants of DCM, the main solid waste streams generated at the facilities are paper/plastic/metal waste, fly ash (from the air pollution control equipment such as electrostatic precipitators), press mud (from sugar manufacturing), empty containers of chemicals/oils/paints, used oil, oil-soaked waste and ETP sludge. The facilities sell paper/plastic/metal waste to external agencies. Part of the press mud are composted on-site whereas bulk of the press mud is given to the farmers for use on their fields as manure. In Ajbapur sugar plant the press mud and bagasse is sent to their own compressed biogas plant nearby. Fly ash is used on-site and given to farmers for land filling.
Empty containers are washed and given back to the vendors. ETP sludge (after drying) is used on-site as manure for gardening. Ash from the distillery slop fired boiler is used for manufacturing Potassium Sulfate i.e. Sufate of Potash which is used for soil amelioration due to its rich potash content. ETP sludge is used as manure. Used oil and grease is sold to the authorised recyclers approved by CPCB.
Ajbapur and Hariawan Distillery Plants
Ash generated from Slop boiler is rich in potash and is utilized for soil amelioration. Hazardous waste generated from manufacturing process i.e. (Cotton rags contaminated with oil / chemical) is burned in captive boilers and other hazardous wastes are disposed to PCB authorized agency. Thin slops generated from decanter in grain based process are recycled and residues are dried and sold as cattle feed.
PS4-Community Health, Safety and Security
Infrastructure and Equipment Design and Safety
The company has embedded EHS in planning and designing infrastructure, equipment and technology. Management of Change (MOC) procedure is followed as part of its IMS before any modification in the plants. Process safety planning is carried out along with consultation with relevant stakeholders. QRA and HAZOP studies are required for all major hazardous chemicals, processes and technologies. Pre-startup safety reviews (PSSR) are carried out before commissioning.
Hazardous Materials Management and Safety
The company has established a comprehensive hazardous material management procedure that addresses the handling, storage, management of all hazardous chemicals and products manufactured in their plants. QRA and HAZOP studies are carried out as explained before for all hazardous chemicals. An industrial hygiene program has been implemented by the company to study and mitigate any potential hazardous chemical exposures to their employees and labor.
For the sugar plants, the Company has implemented a dedicated farmer outreach program for raising awareness to enhance sugarcane yield, use non-chemical pest control, and promoting use of bio-compost. This helps in providing better returns to the farming community with increased productivity and also enhances soil fertility and protects and protects the environment from hazardous chemicals.
Security Services.
In the Bharuch and Kota plants of DCM, the company has engaged third party security workers who are unarmed and are also trained in safety management and emergency response. In the sugar and distillery plants in Uttar Pradesh, the company engaged armed guards (from ex-army personnel). The arms are monitored on a daily basis by the plants and both the arms and ammunication are stored in a secured manner in the plant and are not carried by the security personnel. The plant identifies and maintains a risk register for armed security. Security personnel are engaged after a formal background check and police verification.
The company has also established and implemented an external grievance redress procedure that is communicated to local community. As mentioned earlier, the sugar plants also operate a call-center facility (in local language) for providing easy access to local farmers for raising grievances and seeking support. Regular monthly training programs are conducted by the company for security workers on the standard operating procedures for their job including use of force for preventive and defensive purposes, human rights, prevention of sexual harassment and engagement with the local farmer communities.
