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: Environmental and Social Assessment Management Systems (ESMS)
Environmental and Social Management System (ESMS): SISL has an Environment, Health, and Safety (EHS) policy outlining the objectives related to the assessment and management of EHS impacts, emergency response, compliance with applicable legal regulations, safe working conditions, waste management, and internal and external communications, which is implemented through an ESMS that comprises following key elements (i) identification of E&S risks and impacts (ii) E&S management programs and procedures (iii) organizational capacity (iv) emergency preparedness and response (v) monitoring and review and (vi) stakeholder engagement in line with IFC PS 1 requirements. The company has secured ISO 14K1 (Environment) and ISO 45K1 (OHS) certifications for all its existing operational DCs and will extend these certifications to the proposed expansion subprojects at Chennai and Rabale and future subprojects. Additionally, the Company has obtained ISO 50K1 (Energy Management) certification for its two operational DCs with plans to extend this certification to other operational DCs and upcoming DC subprojects demonstrating systematic approach for sustainable building practices and energy management. The Company’s Human Rights policy aligns with the UN's Guiding Principles on Business and Human Rights.
Identification of E&S Risks and Impacts: SISL has a procedure for comprehensive E&S risk assessment and employs a compliance-driven approach for E&S impact identification and mitigation. The regulatory environmental clearance process in India for building construction like the ones normally undertaken by the Company may or may not require full-scale E&S assessments depending on the size of the development. For the Chennai (Proposal #: SIA/TN/INFRA2/407480/2022) and Rabale (Proposal #: SIA/MH/INFRA2/ 504527/2025) sub-projects, the Company has prepared and submitted environmental impact assessment studies and management plan documents based on which environmental clearance has been received in May 2023 and December 2025 respectively. The E&S study and environmental clearance documents are disclosed on the regulator website (https://parivesh.nic.in/newupgrade/#/trackYourProposal) which can be reviewed using the proposal numbers referred to above.
Organizational Capacity and Competency: The corporate-level E&S function is led by SISL’s CTO with additional support from the corporate-level Security, Safety, and Admin Head. An EHS Manager is appointed for each DC, with support from a dedicated fire officer and 24x7 fire marshal during the operations phase. Additionally, construction contractors are mandated to deploy EHS personnel for effective management of EHS issues at the site during construction. Furthermore, SISL engages an independent Project Management Consultant to monitor and supervise the construction of DCs, including E&S compliance. As part of IFC investment conditions and as per agreed ESAP#1, the Company will assign a qualified corporate-level E&S Manager, who will be responsible for the implementation of the EHS Policy and ESMS at corporate as well as project level (DC assets).
Emergency Preparedness and Response: SISL adheres to the US National Fire Protection Association (NFPA) codes for building design and equipment along with the India’s National Building Code (NBC) to meet mandatory national fire safety license requirements. An emergency preparedness and response (ERP) system is in place across all operational DCs to respond to accidents and emergencies including fire, explosions, and safety incidents. The Company actively maintains emergency response infrastructure and undertakes regular mock drills and training programs for on-site staff. During the construction phase, the main contractor’s construction phase ESMS and ERP is relied on which is reviewed and approved by the project management consultant and SISL. Based on climate risk assessment, increase in ambient temperature, heavy rainfall and flooding events are foreseen at the Project sites. As part of IFC investment conditions and as per agreed ESAP#2, SISL will update its construction and operational phase Emergency Response Plan and occupational health & safety (OHS) management procedures to cover extreme weather events such as heatwaves and flooding due to heavy rainfall as potential risks to workers.
Monitoring and Review: SISL has established procedures to monitor and measure the effectiveness of the management program, as well as compliance with permitting conditions at each of the DC assets. As part of its ESMS, the Company has well-established monitoring and review procedures to monitor the compliance of the EHS management programs. SISL tracks Key Performance Indicators (KPIs) across twelve material topics in ESG consideration which include energy efficiency, share of renewable energy, water consumption, and GHG emission. SISL has also established internal inspections and external auditing systems to track performance on environmental, social and governance (ESG) aspects. SISL’s corporate management receives periodic ESG performance reviews based on the monitoring program and the Company publishes its ESG performance in the form of multiple reports on its website (Refer: https://sifyinfinitspaces.com/data-center/sustainability/).
PS 2: Labor and Working Conditions
Human Resource Policies and Procedures: The Company, as of December 2025, has about 282 direct workers and 47 off-roll workers for building management systems, IT support, electrical and air conditioning technicians. There are about 950 third party contracted workers for critical service management during the operations phase. The Company follows Sify Group human resources policies and maintains a Human Resources (HR) Manual that includes policies on business ethics; code of conduct, diversity, equality, and inclusion (DEI), and prevention of sexual harassment, and is aligned with Indian labor laws regarding minimum wage, social benefits, working hours, shift times, and overtime payment, among others. These policies, outlined in accordance with local labor law requirements and corporate standards, are applicable to the direct employees. The Company’s Human Rights policy explicitly prohibits child and forced labor, both directly and through contractors. As per information provided by the Company, the standard Contractor EHS Agreement provides for third-party contractors to comply with local labor law provisions. The Company conducts regular internal and external audits to verify the compliance of local labor law by contractors. As part of IFC investment conditions and agreed ESAP#3, the Company will integrate IFC PS2 labor and working condition requirements in its existing external audit program and undertake such an audit at the Chennai and Rabale sub project sites when construction work is under progress. The external audit scope shall include construction contractor labor accommodation standards as per IFC guidelines (https://www.ifc.org/content/dam/ifc/doc/mgrt/workers-accomodation.pdf), labor regulatory compliance for both SISL on-roll workers and off roll third party contracted workers, construction and operations and maintenance (O&M) phase OHS practices review, and IFC PS2 requirements (such as SEAH risks, grievance redress mechanism (GRM), prohibition of child and forced labor).
Grievance Mechanism: The Company’s grievance redressal policy, redressal committee, and process are in line with IFC PS 2 requirements. The structured grievance redress mechanism covers all the direct employees of SISL, and complaints can be recorded through multiple modes (emails, smartphone application, direct supervisor reporting, and anonymous). SISL has an internal complaints committee (ICC) to address gender-based violence and harassment (GBVH) related complaints at the central corporate and regional office levels in line with local prevention of sexual harassment (POSH) regulation. The Company reports that no grievances including POSH related grievances were received in the last 3 years. As part of IFC investment conditions and as per agreed ESAP#4, the Company will formulate gender-based violence & harassment (GBVH) related risk management systems that meet GIIP standards at the Company level and implement and monitor these GBVH risk mitigation systems and procedures at each DC assets. The Company will use internal resources or procure the services of a local GBVH consultant, if required, to formulate, institute and train the relevant Project stakeholders on GBVH Risk Mitigation and Management Systems.
Occupational Health and Safety (OHS): The Company has adequate OHS Management System procedures to assess and monitor OHS aspects associated with its operations, including an emergency response plan (ERP), life and fire safety (LFS) measures, safety training and emergency drills, and incident management, among others. The Company’s operational DCs are already covered under ISO 45K1 certification, showcasing strong commitment to OHS. This certification will also be extended to all new projects. Further, the Company maintains and provides personal protective equipment (PPEs) that includes arc suit and fireman suit to the workers including third-party contract workers. The track record of zero lost time injury frequency and total recordable injury rate for the last 3 years reflects the effectiveness of the Company’s OHS management systems.
Supply Chain: SISL has formulated and established a supply chain management system that is in line with IFC PS requirements. SISL has formulated and enforces its comprehensive Supplier Code of Conduct that covers the critical risk areas including labor practices – Prohibition of child and forced labor, fair wages, reasonable working hours; Human rights – Protection against discrimination, promotion of freedom of association; Occupational health and safety – Ensuring safe working conditions, emergency preparedness, and hazard mitigation among others. As part of its SCM systems, SISL undertakes ESG Due Diligence and Supplier Audits to identify improvement opportunities among its suppliers.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: SISL is not dependent on ground water for water requirement during construction and operations of DC. The Company implements multiple energy and water efficiency plans, programs, and performance metrics, including continuous monitoring of resource efficiency metrics such as Power Usage Effectiveness (PUE) and Water Usage Effectiveness (WUE) using Building Management System on 24x7 basis and complying to ASHRAE data center standards. The Chennai 02, Noida 02 and Rabale T5 DC assets of the Company are Indian Green Building Council (IGBC) Platinum rated for sustainable building design, development and operations.
On water resource conservation, SISL measures and reports its Water Usage Effectiveness (WUE) - a key metric in the data center industry that measures water quantity used in liters per unit of IT energy in kWh. A lower WUE signifies better water efficiency. All the DC assets built by SISL except for Noida 1 DC project site, use air cooling technology so as to conserve water usage in DC project operations. In FY 2025, SISL reports that it achieved a Water Usage Effectiveness (WUE) of 1.805. SISL has integrated sustainability principles in line with emerging global industrial practices to support the growing demands of AI-driven workloads that consume significantly more power than traditional computing. SISL has adopted technological solutions such as advanced cooling technologies including rear door heat exchangers, direct-to-chip cooling systems, and liquid immersion cooling systems. SISL has also adopted advanced water conservation solutions such as Zero Liquid Discharge (ZLD) systems, rainwater harvesting systems, and automatic tube cleaning (ATCS) systems of soft cleaning ball technology to maintain condenser tube efficiency. Most of SISL’s data centers have ZLD-based waste-water treatment facilities to reuse recovered water for cooling, flushing and landscaping purposes.
GHG Emissions: SISL estimates and reports its GHG emissions every year in various E&S disclosure reports published on its website (https://sifyinfinitspaces.com/data-center/sustainability/). SISL has targeted a 29% reduction in GHG emissions for FY 2026 with DC asset-wise renewable energy goals defined for compliance. The RE Goal roadmap is aligned with the United Nations Sustainable Development Goals (SDGs) and India’s Net Zero commitment. As per SISL’s FY25 Annual Sustainability Report, corporate operations resulted in GHG emissions (Scope 1 and Scope 2) of 300,800 tCO2e/year in FY24-25. On average, SISL operations generate GHG emissions of 1600 tCO2e/year (Scope 1 and Scope 2) per MW of DC operations. To reduce GHG emissions, the Company is increasing the share of Renewable Energy (RE) power in its energy mix.
Pollution Control: The Company has procedures for waste management, including e-waste management, and batteries waste management in line with the requirements of PS3. The spill prevention measures, such as double containment and spill sensors, are in place for fuel storage tanks required to operate Diesel Generator (DG) sets at the DCs. The Company is designing all the upcoming and new DCs aiming to be without uninterruptible power supply (UPS-less) to avoid challenges associated with batteries and waste batteries disposal. Moreover, measures like low-emission DG sets and zero liquid discharge are adopted to reduce air emissions and effluent discharge in line with permit conditions.
PS 4: Community Health, Safety and Security
Security Personnel: The DCs have a robust security management system in place incorporating multilayered electronic measures along with third-party unarmed security personnel. The security service provider is responsible for conducting background checks and providing necessary training related to the code of conduct of the security personnel deployed at the site through contractual provisions aligned with industry practices. As part of the requirements of ESAP#4, SISL will include the entire security organization deployed at asset level as a key stakeholder and undertake GBVH related training and capacity building of the security team including third party security contractor’s personnel.
