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
Environmental and Social Management System: AirTrunk maintains global management systems that are aligned and certified against ISO 9001, 14001, 27000, and 45001 (quality, environmental, information security, and OHS) standards. Its corporate Safety @ AirTrunk Management System (SAAMS) provides an ISO 45001 aligned framework for managing health and safety risks across data centers, development projects, and office environments throughout the Asia Pacific Japan region. SAAMS encompasses a suite of procedures, including hazard and risk management, training and competency, chemical management, incident management, contractor management, emergency preparedness and response, and broader assurance processes that guide operational control. All contractors, subcontractors, and outsourced/service providers must adhere to AirTrunk’s integrated ESMS requirements.
To ensure that global consistency is maintained, existing AirTrunk group-level ESMS will be formalized and localized to the Project level to explicitly demonstrate alignment with IFC Performance Standards (2012) and the World Bank Group General EHS Guidelines (2007). This will include update of E&S policies to reflect IFC requirements and development of a stakeholder engagement plan, and transport and construction traffic management and plan (see ESAP #1).
Identification of risks and impacts: Under national regulations, the Project did not require Environmental Impact Assessments (EIAs) or permits, as they are not prescribed activities. Nonetheless, the Project conducted E&S assessments, including baseline soil, water, and air quality data collection, before construction. Risk identification is conducted using multiple tools and registers, including enterprise risk registers, reviews of environmental aspects and impact assessments, hazard identification processes, and project-level and site-level systems, with risks evaluated based on likelihood and consequence. For the construction of JHB2, the construction-specific Environmental Management Plan (EMP) sets out a construction-phase environmental risk assessment process under which environmental risks are identified through formal assessments undertaken during the preparation of Construction Area Plans.
Management Programs: The main contractor prepares a risk-based EMP to manage key construction risks and impacts. This includes environmental monitoring where required (e.g. for dust, noise, spills, or water pollution risks). Air quality monitoring is conducted in accordance with Malaysian standards. Based on the outputs of the review, ESMS management and monitoring programs, and monitoring procedures for consumption of natural resources (see PS3), waste management (including e-waste and other hazardous waste), air emissions, effluents, and noise will be updated to meet IFC Performance Standards and the World Bank Group General EHS Guidelines (see ESAP #2).
Organization Capacity and Competencies: During project development (construction and through to commissioning) senior EHS Manager oversees the Main Contractor's compliance with the Projects EHS requirements. Once the site is commissioned, the EHS oversight shifts to a Safety Lead for Operations, who reports to the Safety Manager for Operations. The Safety Lead is supported by six global Safety Operations team members reporting to the Head of Safety.
Emergency Preparedness and Response: The Project has an Emergency Management Manual based on a risk assessment that covers all major scenarios and defines roles and responsibilities, response and escalation procedures, equipment, and evacuation protocols. Life and Fire Safety standards are set in accordance with the service agreement with the future client. The local firefighting agency has approved JHB1’s active and passive fire suppression systems.
The Main Contractor maintains an ERP that covers all likely emergency scenarios per the Project's Emergency Management Manual.
PS2: Labor and Working Conditions
As of December 2025, JHB1 has 31 employees with approximately 16% of the workforce female. All on-site construction and outfitting activities are performed by subcontractors. Subcontractors hire migrant workers in accordance with national regulations. The workforce during peak construction of JHB1 (approximately 1,980 workers) includes Vietnamese, Chinese, Indonesian, Nepali, and Bengali nationals.
Human Resources Policy and Procedures: The Project has established Human Resources (HR) policies and procedures that comply with host-country labor laws and the requirements of IFC Performance Standard 2. These include provisions on non-discrimination, equal opportunity, prohibition of child and forced labor, and prevention of harassment, including sexual harassment and gender-based violence, applicable to all staff and workers, including contractors. Grievance and complaints process including anonymous and confidential options are present.
AirTrunk maintains group-wide HR, workplace conduct, human rights, and grievance policies, which establish minimum labor standards across its operations, and provides jurisdiction-specific employment contracts, benefits, and procedures to ensure compliance with local legal requirements. Project HR policies will be updated to include Freedom of Association and the right to collective bargaining (see ESAP #3).
Working Conditions and Terms of Employment: The Main Contractor does not provide worker housing; subcontractors arrange all accommodation. The Project will ensure that subcontractors provide certified workers accommodation that meets minimum standards for safety, hygiene, space, water, sanitation, ventilation, and access to basic services, safe and clean, with adequate facilities (washing, laundry, kitchens/canteens, secure storage, and dedicated sleeping location), and not restrict freedom of movement (see ESAP #4).
Given the reliance on subcontracted migrant labor and the inherent exposure to forced labor and recruitment-related risks in the sector, the Project will implement minimum contractor labor and working condition standards in accordance with IFC Performance Standard 2 (see ESAP #5). To include recruitment safeguards, contract transparency, worker rights awareness, and access to multilingual grievance mechanisms.
Occupational Health and Safety: The Main Contractor is required to comply with the specific HSE standards outlined in OHS policies and manuals, including Hazard and Risk Assessment (HRA). The Main Contractor integrates OHS screening into the subcontractor tendering. All new subcontractor workers and owners must attend an OHS training course at the Main Contractor’s training center before accessing the work site. The training covers high-risk work activities, safety signage, and proper conduct and PPE use, and is offered in multiple languages. The Main Contractor’s staff also inspects all subcontractor-provided PPE and work actions for compliance.
The Main Contractor’s HSE teams (supervised by the Project’s HSE Director and site-based managers) collect monthly incident statistics from each site. Safety observations, near-miss, and accident data are collected. Permit To Work requirements (classified as #1 Class Works), including Hot Work, Working at Heights, Confined Space, Excavations, Electrical Work, and Lifting. There is an HSE Manual, Project Safety Standards, and Class One Practice for the main types of work.
Workers Engaged by Third Parties: AirTrunk (and the Project) requires all contractors and subcontractors engaged on the project to comply with applicable labor, employment, immigration, and OHS laws as well as AirTrunk’s Supplier Code of Conduct, Human Rights Policy, and workplace conduct requirements. Contractors are responsible for the recruitment, employment, and management of their workforce, including migrant workers, and for any labor agencies used. To strengthen oversight of subcontractor labor practices, the Project will expand its monitoring of the Main Contractor to include minimum labor controls for contractors (as per ESAP #5) and establish a structured process for monitoring, auditing, and documenting contractor and subcontractor compliance (see ESAP #6).
Supply Chain: Based on IFC’s review, AirTrunk’s Supplier Code of Conduct aligns with IFC PS1 by setting clear E&S expectations for suppliers and requiring risk identification, management systems, audits, and continuous improvement. It also contains provisions on human rights, labor, environmental performance, and grievance mechanisms to support supply chain due diligence.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: Based on AirTrunk’s information, both JHB #1 and JHB #2 campuses are estimated to consume approximately 4,468 GWh and ~910 million litres of water per annum at 100% utilization. No ozone depleting substances are used in the dry cooled halls in JHB1.
AirTrunk's portfolio average annual operating Power Usage Efficiency (PUE), to the financial year end of 30th June 2025 is 1.32. The anticipated PUE for JHB1 and JHB2 will be below the industry standard of 1.5.
The project energy provider is the state operator TNB, with a renewable supply of 30 MW of solar power via a private power purchase agreement from a solar farm and 1 MW of solar on each data center roof.
AirTrunk’s sustainability report outlines its public commitments focused on decarbonization, resource efficiency, and responsible business conduct. The Project targets net-zero Scope 1 and 2 emissions by 2030 through energy efficiency and scaling renewable energy in partnership with customers. Separately, AirTrunk has additional commitments to further address embodied carbon in new builds, improve water resilience, and advance biodiversity conservation.
GHG Emissions: Datacenters are energy-intensive facilities. The project is expected to consume approximately 4,468 GWh of electricity per annum at 100% utilization, with the majority of this sourced from the national grid. Based on this electricity demand, IFC estimates that the project’s total GHG emissions will be approximately 1.5 million tCO2e per year, driven almost entirely by purchased electricity. As such, the client will be required to report annually on GHG emissions and reduction strategies on a per m² basis as part of the annual monitoring report.
At JHB1 and JHB2, approximately 99% of emissions are Scope 2 emissions from grid electricity, while ~1% are Scope 1 emissions associated with diesel use for backup generators and refrigerant losses. Emissions from JHB1 are expected to decline as rooftop solar and a 30 MW private power purchase agreement come online. AirTrunk also plans to annually offset residual Scope 1 emissions with in-market carbon credits.
Pollution Prevention: AirTrunk requires that each site implement a waste management plan to minimize waste, reduce landfill disposal, and increase reuse and recycling. As per the requirements of the integrated ESMS and this PS, the Project will, moving forward, quantify, monitor, and reduce electronic waste (e-waste) generated from operations, maintenance, and equipment replacement (as per ESAP #2).
PS4: Community Health, Safety and Security
The project is in an industrial park, with community clusters as close as 50 meters from the park boundary. The Main Contractor’s ESMS mitigates community health risks by monitoring noise and dust to ensure compliance with national standards. Security for JHB1 is unarmed and provided by outsourced labor service providers, in accordance with the Project policies. Subcontractor worker accommodations are near urban areas. As part of risk management, the Project will require the Main Contractor to implement preventive measures to identify and mitigate potential sexual or gender-based violence, through training and awareness-raising on cultural differences and social issues (see ESAP #7).
