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 Systems: The Company has established and maintains an environment and social management systems (ESMS), since November 2019, that is appropriate for the nature and scale of its business operations. The ISO 14001 and ISO 45001 standard certified ESMS are designed commensurately with the level of environmental and social risks and impacts associated with various types of RE project developments including: utility scale, ground mounted solar projects, rooftop solar and wind-solar hybrid (WSH) projects. The ESMS incorporates the relevant elements, as required under Para 5 of IFC PS1.
CMES has formulated and implemented E&S related policies such as environment, social, and health & safety policies since July 2021. The environmental, social and governance (ESG) roadmap is outlined on its website - https://www.cleanmax.com/esg. The E&S policies envision to meet Environment and Social (E&S) requirements in line with IFC Performance Standards along with compliance to host country regulations and international conventions, as applicable.
Identification of Risks and Impacts: The Company implements a structured risk identification and impacts assessment process for each renewable energy project that is aligned to IFC PS requirements. Based on preliminary screening and internal categorization (A, B1, B2, C), Cleanmax commissions appropriate third-party studies- Environment and Social Impact Assessment (ESIA) for high to moderate risk A/B1 categories, E&S due diligence (ESDD) for brownfield acquisitions (and a focused ESIA/ESMP if no prior ESIA exists), and Independent Environment Examination (IEE) for moderate to low risk B2 category projects with escalation to ESIA if sensitivities are found while low risk Category C is managed internally using checklists and a generic E&S Management Plan (ESMP). The layered risk assessment process confirms final categorization and informs ESMP actions which are reviewed by the Corporate ESMS Steering Committee before investment decisions.
For all three Eligible Projects preliminarily screened as low to moderate risk for IFC funding, the Company has undertaken independent ESIA studies based on IFC Performance Standards, applicable WBG EHS guidelines, and local regulations. Company has also agreed to disclose a redacted version of ESIA reports for IFC funded Eligible Projects on its website whose weblink details will be presented in this ESRS document as soon as it is uploaded. IFC reviewed the ESIA reports for Eligible Projects, and the excerpts of the review assessment are presented below.
1.50MW Wind Solar Hybrid (WSH) Project at Honawad, Karnataka: Independent ESIA study was undertaken in May 2025 for the proposed 159MW larger wind-solar hybrid project cluster in the Bijapur and Belgaum districts of Karnataka wherein IFC funding will be limited to 50MW of the larger WSH Project. ESIA report has assessed that IFC PS 1 to 4 and PS 6 will be applicable to this project development. About 33 WTGs of each 3.3MW capacity are proposed for the wind part. Each WTG will require about 6 acres of land parcel and another 400 acres is required for developing the solar component of the larger project. ESIA documents that the Company has followed willing lessor-willing lessee approach to access the land parcels for a 30 year lease period. The proposed WSH Project will transmit power at 33/220 kV Kakamari pooling sub-station, and subsequently to the Athani 220/110/11 kV Substation. The aerial distance between proposed project land and grid substation is approximately 39 km. The land area required for constructing 39km long Transmission Line (TL) will be limited to the area required for the foundation of pylons and land leasing process was ongoing at the time of ESIA studies.
ESIA report has presented the operational noise modeling study results and shadow flicker analysis on nearby sensitive receptors. It concluded to state that majority of the receptors are found to be farm structures (Pump house, resting room, agricultural storage) and hence the impact is expected to be moderate. However, as few receptor structure usage could not be verified on-site due to lack of access, ESIA study recommended for verification during project construction phase as there could be potential residential use of these structures. Hence, the operational noise modeling and shadow flicker risk analysis must be re-validated to verify compliance with the requirements of WBG EHS Guidelines for Wind Energy Projects. Biodiversity risks for this project are described under PS6 section of this ESRS.
2. 68MW Solar Project at Jagalur in Karnataka: The Company has proposed to develop a larger 300 MW solar power plant cluster in Jagalur Tehsil, Davanagere District, Karnataka over 2100 acres of land
parcel in which IFC financing will be limited to 68MW of the larger cluster to be identified during IFCs on-site appraisal assessment post IFC commitment. In Phase I about 325 acres in Kamandalgondi and Salahalli will be developed, with power evacuated to a 220 kV pooling substation at Salahalli and connected to the 400/220 kV KPTCL substation at Hiremallanahole through a 7km long, 33 kV HT transmission line. Company commissioned an independent ESIA study in August 2024. ESIA concluded that no major E&S impacts are anticipated due to project development, or ecologically sensitive areas were identified within the study area, though two reserve forests lie within 10 km radius (Anaburu ~6.94 km NW and Mallurahalli ~7.19 km NE). Stakeholder consultations indicated community support and required land parcels being secured through a willing lessor–willing lessee approach and no indigenous community members land parcel identified for development. Overall E&S impacts are expected to be low to moderate and manageable through mitigation design. Key risks relating to land, water availability, air/noise, biodiversity, and worker/community health and safety are addressed through a project specific E&S Management Plan (ESMP) developed as part of ESIA report.
3. 300MWac Solar Project at Bikaner, Rajasthan: The Company has proposed to develop a 300 MWac solar power plant at Village Bangrala, Tehsil Chhattargarh, District Bikaner, Rajasthan (Bikaner IV) over 1500 acres of land parcel identified as private farm lands. The power will be evacuated through a new 13km long, 220 kV transmission line to Bikaner IV grid substation. Company commissioned an independent ESIA study in April 2025 which was concluded in December 2025. ESIA concluded that no major E&S impacts are envisaged and no ecologically sensitive areas were identified within the study area. Land leasing process was underway when the ESIA study was commissioned and the stakeholder consultations indicated community support and land being secured through a willing lessor–willing lessee approach and no indigenous community members land parcel identified for development. Overall E&S impacts are expected to be low to moderate and manageable through mitigation design. Key risks relating to land, water availability, air/noise, biodiversity, and worker/community health and safety are addressed through a project specific E&S Management Plan (ESMP) developed as part of ESIA report.
As part of the IFC investment requirements and as per agreed E&S Action Plan (ESAP#1), for the IFC funded eligible projects that could be located within the larger project clusters discussed above, based on IFC review of sub-project specific ESIA reports, ESMPs and on-site appraisal assessment of each sub-project, Company agrees to revalidate the E&S impact assessment study, if required and strengthen the Construction and Operational phase Environmental and Social Management Plans (ESMP) specifically covering operational noise, blade throw and shadow flicker risks from wind turbines, additional biodiversity baseline assessment, post construction bird fatality monitoring, preparation of a biodiversity management plan (if required), transmission line design & construction, climate risk mitigation, ambient environment monitoring and other site-specific E&S risk aspects, as required.
Further, Company agrees to update and strengthen its ESMS specifically related to preliminary screening tools and the ESIA process it follows including a more robust Terms of Reference for ESIA studies, guidelines/Terms of reference related to biodiversity impact assessment and biodiversity management plans (particularly for avifauna/bats, seasonal coverage, transmission line alignment/design, and post-construction bird fatality monitoring) as part of ESAP#4 requirements.
Management Program: Cleanmax has established documented management programs within its ESMS, including manuals, operational procedures, training management systems, templates/checklists, audits, and monitoring & reporting mechanisms. Core generic instruments include a Code of Conduct and Contractor HSE requirements that are contractually binding, a Construction HSE Management Plan with Standard Operating Procedures (SOPs), an O&M Asset Management System manual, and internal HSE audit guidelines. Project teams develop site-specific method statements for each phase based on ESIA-recommended ESMPs in coordination with Engineering Procurement and Construction (EPC) contractors, supported by periodic workforce training and lifecycle monitoring. The ESMS also requires a structured E&S training program with onboarding and refresher sessions covering key topics such as ESMS procedures and checklists, occupational health and safety, fire safety, emergency preparedness, operational training, HR induction, PPE use, driver safety, and implementation of ESMPs/action plans, with additional training introduced as needed throughout the project lifecycle. In FY26 the company delivered 115,918 manhours of EHS training across its entire operations.
Organizational Capacity and Competency: The key corporate functions supporting ESMS implementation include HSE, Quality, HR, Land Acquisition/ Procurement and CSR functions. Cleanmax implements its ESMS through the dedicated corporate functions and a four-tier E&S structure—from the Global Head of ESG/EHS to regional and site HSE leads and contractor safety supervisors—with clear roles and authority defined covering both construction and O&M phases.
Emergency Preparedness and Response: Emergency preparedness at each RE project site is guided by the Corporate ESMS, requiring site-specific emergency plans for construction and O&M phases that define scenarios, roles (Emergency Control Team), evacuation and shutdown procedures, communications and external coordination, equipment and facilities, and routine drills/audits with post-incident investigation and corrective actions.
Monitoring and Review: The Company ESMS requires monitoring and reporting of ESMP/ESAP commitments and compliance, overseen by the Corporate ESMS Manager with site-level ESMS/HSE personnel during construction and the plant manager during operations, including inspections, internal audits, records management, periodic investor reporting, grievance tracking via the Stakeholder Engagement Plan, and formal ESMS performance reviews. EHSS team responsible for ensuring ESMP/ESAP and other study commitments are implemented across the project lifecycle, and EHSS team led by the corporate ESMS Manager is also responsible for providing regular performance reports to the ESMS Committee. CleanMax also discloses its operation-wide E&S performance through GRI-based, independently assured Sustainability Reports and Business Responsibility and Sustainability Reports (BRSR) as per local listing regulator guidelines. As part of its monitoring element, Company has agreed to strengthen its bird carcass surveys and environmental monitoring based on IFC appraisal inputs under ESAP#1 requirements.
PS2: Labor and Working Conditions
As on FY26, the Company employed 631 direct employees and 337 fixed term employees that are on third party payrolls besides the construction and operational phase third party contractor workers across its RE assets. Female participation excluding the contractor workforce is about 15% out of the 968 total employees.
Human Resource Policies: The Company has established documented human resource (HR) policies that apply to both direct employees and fixed term staff. The HR policies comprising of human rights policy, employee code of conduct, grievance redressal policy, equal opportunity policy for people with disabilities, corporate policy on prevention of sexual harassment (POSH), whistle blower policy, and learning and development (L&D) policy are largely aligned to local labor regulations and PS2 requirements. The HR policies commit to prohibiting child and forced labour, ensuring safe working conditions, preventing discrimination, providing equal pay, respecting freedom of association, and paying at least legally mandated minimum wages. The HR Manual sets out benefits, entitlements and employment terms for direct employees, all of whom receive written employment contracts. These expectations are extended to consultants through the Code of Conduct. The human resource management system (HRMS) further recognizes Company’s role as principal employer for contract labour welfare and requires labour and occupational health & safety (OHS) risks to be managed through contract provisions, oversight, and ongoing monitoring.
Collective Bargaining and Freedom of Association: The Company Human Rights Policy recognizes workers’ rights to freedom of association and collective bargaining and references the ILO Declaration on Fundamental Principles and Rights at Work. There are no labour union currently operating at Company facilities.
Grievance Mechanism: The Company has an employee grievance policy allowing grievances to be submitted by email or through anonymous grievance boxes at project, regional and corporate offices. Grievances are escalated through the site or administrative level, a designated Grievance Officer and a corporate Grievance Committee, with resolution timelines prescribed. As part of IFC investment conditions and agreed ESAP#2 requirements, Company agrees to update its grievance mechanism related procedures to meet the requirements of Section 4 of the Industrial Relations Code, 2020. The Company will revise the current grievance policy to: (i) identify qualifying establishments and constitute legally compliant grievance redress committees (GRC), (ii) establish a centralized grievance database covering direct and third-party workers, (iii) define responsibilities and reporting requirements, (iv) monitor resolution timelines and recurring issues, and (v) retain evidence of closure. Contractors meeting the statutory threshold will be contractually required to establish compliant GRCs, and all contractor workers will have direct access to Company grievance escalation channel.
Company has an established policy and procedural framework to address prevention of sexual harassment risks in its operations as per the regulatory requirements. Due to multi-asset operations across the Country and due to extensive contractor/subcontractor use, remote field operations, community and stakeholder interfaces, and land interactions, the Company will strengthen its POSH risk management systems going beyond the regulatory requirements and attempting to adopt good international industry practices (GIIP) to address GBVH/SEAH/CP risks. As part of agreed ESAP#3, Company will develop and operationalize an IFC-aligned GBVH/SEAH/CP Risk Management System covering the entire Company operations. The updated GBVH risk management system will provide broader GBVH coverage, survivor-centered response, confidential reporting and referral pathways, anti-retaliation, contractor/supplier requirements, investigation and case management protocols, and senior oversight/monitoring.
Occupational Health and Safety: Cleanmax has established an occupational health and safety (OHS) management framework covering hazard assessment, high-risk activities, contractor safety, emergency preparedness, incident investigation, training, and internal auditing. The Company has instituted appropriate safety organization across all its project sites. The OHS management systems require project-level training for contractor and subcontractor workers and maintenance of training records. Its implementation is verified through an internal monitoring system which includes site inspections, review of incident records, training evidence, and worker interactions. Additionally, site EHS team carries out regular internal safety audits, safety observations and monitors & reports on various safety performance aspects. Based on the OHS monitoring documents, Cleanmax reports that its operations in last two years had zero recordable work-related injuries and fatalities and have reported 9.8 million safe manhours in FY26.
Workers Engaged by Third Parties: Company engages multiple contractors for construction and operational phases of its solar projects. The wind projects are constructed and operated by original equipment manufacturers (OEM) of wind turbine generators (WTG). Company applies its HR principles and practices to its suppliers, vendors and contractors through its “Supplier Code of Conduct”, that is included in the enforceable legal agreements. Through its site management team, the Company enforces supplier code provisions such as legal compliance, health and safety of workers, human rights, prohibition of child/forced/bonded labor practices, non-discrimination, prevention of sexual harassment, wages and working hours. Contractor payroll compliance team at Company corporate undertakes internal monthly audit of contractor payroll compliances through desk-based document reviews and on-site verification. Under the ESAP#2 requirements for strengthening the contractor management, the Company will prepare and maintain an establishment-wise labour legal register and compliance matrix covering its offices, construction sites, and operational assets. The Company will implement a risk-based PS2 labour audit program for direct and third-party workers, including review of worker recruitment records, payroll, statutory benefits, contractor licenses, access to grievance mechanism, worker accommodation and OHS performance. Findings will be risk-rated, assigned to responsible functions, tracked to closure and periodically reported to senior management. Audits shall include confidential interviews with representative samples of workers, including migrant, female, and contractor workers.
At its construction sites, Company provides rented guest house accommodation for direct employees in the neighborhood community settlements. Contractors depending on project site, might set-up labor accommodation camps, as part of their scope. Company's ESMS includes a Worker Accommodation Plan, setting out applicable legal and IFC/EBRD standards. Contractor compliance is intended to be monitored through asset-level EHS staff inspections. Under the ESAP#2 requirements, the Company will strengthen the enforcement of labor accommodation standards through an asset-level audit protocol covering pre-occupancy approval, inspection frequency and responsibilities, evidence requirements, confidential worker interviews, compliance checks for occupancy, water, sanitation and fire safety, corrective-action timelines, closure verification and formal close-out.
Supply Chain: The Company maintains a supply chain policy and risk management system as required under IFCs previous investment in Thailand. The Company's supply chain management framework policies comprise of procurement policy, supply chain guidelines, third party due diligence guidelines and vendor code of conduct. The supply chain framework prohibits child labor, forced labor, related abuses, and unsafe work environment at supplier locations and establishes a risk-based due diligence framework for vendor selection and monitoring. For the IFC funded RE projects, Government of India regulations on solar PV module sourcing are applicable. Government regulations mandate sourcing solar modules mainly through the regulator Approved List of Models & Manufacturers (ALMM) framework. Under the IFC investment agreement, Cleanmax agrees to undertake due diligence of ALMM listed Indian module manufacturers as per its supply chain framework requirements and share its assessment with IFC. This will include solar PV supplier E&S screening and monitoring including basic traceability system of raw materials, supplier compliance monitoring, contractual provisions for supplier engagement or disengagement or remedy in case of noncompliance with the code of conduct.
PS3: Resource Efficiency and Pollution Prevention
The Company's ESMS has established a Resource efficiency and Pollution Prevention procedure, aligned with IFC PS3 requirements. The procedure applies across design, construction, commissioning, operation and decommissioning and focuses on resource efficiency, wastewater control and waste management.
GHG Emissions: Considering the approximately 3.4 GW of RE projects to be refinanced or developed, it is expected that the larger Project will avoid approximately 3,694,469 tCO2eq/year on average over its lifetime. The estimate is based on available operational data and proxy emissions factors. As the project progresses based on actual power generation figures, the company will estimate the GHG emissions reduction and report to IFC as part of its annual E&S performance monitoring report. GHG emissions arising out of Company business operations have been reported in the Annual Sustainability Reports published on its website (Refer: https://www.cleanmax.com/esg). In FY26, Company reports that it has achieved zero GHG emissions under Scope 1 consecutively for the last 3 years since FY2024 and 3310 tCO2e/year of GHG emissions under Scope 2.
Water: Resource consumption in RE plants is expected to be minimal, with the main resource of note being the water required during construction phase and for cleaning the solar PV modules during operational phase. Company estimates water requirement at about 3.5 to 4.5 cum/MW/cleaning cycle in its ground mounted solar plant sites. In the eligible projects identified for IFC financing, the water requirement is either met through on-site authorized borewells or from authorized private water tankers. As part of water conservation efforts and towards its goal to achieve 100% water neutrality in its operations by 2030, Company has implemented responsible water management, particularly in water-stressed regions, through reducing consumption, increasing reuse, and replenishing groundwater. Key measures implemented include water neutrality assessments, rainwater harvesting and recharge pits/ponds, water metering, and adopting low/no-water module cleaning technologies and semi-robotic dry cleaning which is used at 92% of solar project sites of the Company.
Pollution Prevention: During construction, minor and insignificant pollution of air, noise, water and soil media is anticipated which are mitigated through pollution prevention and control measures as per site-specific ESMPsprepared as part of ESIA reports. During the operational phase, other than minor amounts of sanitary wastewater, no other environmental impacts are anticipated in solar projects. Appropriate facilities for collection, treatment and disposal of sewage (septic tank and soak pit) both during construction and operation phases are provided. Pollution aspects are managed in line with Corporate ESMS requirements and site-specific E&S Management Plans.
Under the current Project, IFC financing includes a small component of wind in the Honawad wind solar hybrid project. In the wind energy projects, to manage the operational noise and shadow flicker risks, Company ESMS has documented procedures and mitigation guidelines covering Aerodynamic & Mechanical Noise from WTGs, Operational Shadow Flicker Exposure, Community Complaints (Noise/Flicker), Community Engagement & Transparency and Compliance Assurance aspects through the project lifecycle. In line with the ESMS requirements, the ESIA process for the Honawad wind solar project, includes detailed assessment of operational noise and shadow flicker assessment and preparation of site-specific mitigation plans that are integrated into project design and development plans. As discussed under PS1, the noise and shadow flicker analysis needs to be re-validated for compliance with requirements of WBG EHS Guideline for Wind Projects vis-a-vis sensitive receptors, if any, which might be impacted due to project development. Under ESAP#1 requirements, Company agrees to revise and update its ESIA, site specific ESMPs covering the noise and shadow flicker risk aspects before project development.
Wastes: As per ESMS requirements, each site is required to develop documented waste management plan to be implemented as part of Site HSE Management Plan during construction and O&M phases of the project. As per the waste management procedures, typical waste streams identified include hazardous and non-hazardous wastes such as damaged solar panel wastes, e-waste, battery waste, hazardous wastes, domestic solid waste, recyclable wastes, scrap metal wastes, timber & general packaging wastes, waste cables (electrical installation), and burnt/used transformer oil/sludge. The waste is managed in line with Company's Zero Waste to Landfill approach, supported by a structured waste hierarchy that prioritizes avoidance, reduction, reuse, recycling, and responsible disposal in line with permit conditions.
PS4: Community Health, Safety and Security
Community H&S Risks: In the wind energy projects, to manage the operational noise and shadow flicker risks, Company ESMS has documented procedures and mitigation guidelines covering Aerodynamic & Mechanical Noise from WTGs, Operational Shadow Flicker Exposure, Community Complaints (Noise/Flicker), Community Engagement & Transparency and Compliance Assurance aspects through the project lifecycle. The guideline provides for instituting wind-impact-specific grievance mechanism and Wind Impact Monitoring Committee (comprising of Project Team, Village Panchayat and nearby residents) at the Project site. The Community meetings are to be conducted quarterly/semi-annually with full disclosure of noise data, curtailment logs, and mitigation actions. As part of compliance assurance ESMS requires that annual internal audit of noise and shadow flicker compliance is undertaken. The ESIA process discussed under IFC PS 1 documents the baseline and impact assessment through modelling studies as required under WBG Guidelines for Wind Energy Projects and the same will be re-validated as part of IFCs on-site appraisal.
Infrastructure and Equipment Design & Safety: The Company applies Good International Industry Practice (GIIP) across design, construction, and operations in its RE projects. In wind projects, the Company deploys typically 3.3 MW wind turbine generators (WTGs) with 156 m rotor diameter and 140 m hub height in states such as Karnataka and Gujarat. The WTGs are sourced from regulator-approved original equipment manufacturers (OEMs) that hold valid Type Certificates from accredited agencies and are designed & certified to IEC 61400 standards and engineered to complex Indian meteorological conditions. At Honawad project, ESIA documents that Blade throw risk is mitigated through setback distances maintained at twice the hub height, redundant overspeed protection, continuous condition monitoring, and robust structural design of blades and root joints to IEC load cases with verified fatigue/ultimate margins.
Traffic Impacts and Transportation Safety: Specifically in wind projects, as part of the Project planning and ESIA studies, the Cleanmax Project Team along with WTG OEM undertakes a Comprehensive Route Survey and Risk Assessment critically evaluating operational risks such as: physical clearance, structural/ground load capacity of roads, bridges and culverts, geometric constraints, aerodynamic & wind load during transportation, and traffic & public safety. In solar projects, as per Company ESMS requirements, each site develops and implements a site-specific, traffic management procedures as part of the Site HSE Management Plan. The traffic management plan covers aspects such as safe traffic route planning, traffic timings, speed restrictions, vehicle fitness, safe driver, and heavy vehicles such as lift trucks and those with tail lifts are to be thoroughly examined by a competent person. As part of on site appraisal, these risk aspects will be re-assessed and the project ESMP will be updated as part of ESAP#1 requirements.
Security Personnel: Company deploys unarmed security personnel at its RE plant sites. Security team engaged by the Company is outsourced to licensed security contractors under the Private Security Agencies (Regulation) Act, 2005 which requires a state-issued license to operate, mandatory police background verification for guards and supervisors, and prescribed training for guards (including physical fitness, fire safety, and emergency response). Security contractors are contractually required to comply with Company's vendor code of conduct and other social policy commitments. The Company's community grievance mechanism to be instituted at each project site through its life cycle covers in its scope the grievance risks associated with security team deployment.
PS5: Land Acquisition and Involuntary Resettlement
In all the three eligible projects identified for IFC financing, the ESIA studies have documented the land leasing process and the status based on stakeholder consultations including land owner consultations as discussed under PS1. The Company primarily relies on voluntary, land purchase and long-term leasing process (typically 25-30 years lease period) based on willing landowners for developing its RE projects. The RoW is obtained for the high voltage Transmission Lines through one-time payment / annual lease rentals to affected land owners as per the applicable statutory guideline.
ESIA reports which mostly covered the solar park components, documented that IFC PS 5 requirements were not applicable, due to voluntary, market-based transactions adopted in the projects identified for IFC financing. The ESIA reports of the three eligible Projects were prepared when the land acquisition process for solar park component was partially completed and RoW procurement process for transmission lines were yet to start. Therefore, the actual number of land owners/lessors for leased land and for TL RoW is currently not known and will be confirmed later in updated ESIA report annexures. The ESIA reports recommended to carry out comprehensive assessment of economic displacement on land owners and tenants/share-croppers and agricultural labourers whose livelihood was linked to agricultural use of the private land acquired, if applicable. Under ESAP#1 requirements, the client has agreed to re-validate the ESIAs and update with current land parcel status of the final project footprint and based on IFCs on-site appraisal assessment, agrees to update its management plans, as required.
Company followed its published (https://www.cleanmax.com/policies-disclosures) land acquisition policy and land acquisition procedural framework formulated as part of its Corporate ESMS. Under IFC investment and as per ESAP#1 requirements, Company will review and re-validate the land leasing process including the land leased/acquired for associated facilities (such as transmission line, pooling substation) during the planned on-site appraisal by IFC, land leasing related grievance mechanism instituted in order to re-validate the land leasing risks as documented in the project ESIA reports in line with IFC PS 5 requirements In case of gaps, the company will undertake supplementary assessment and mitigation plan preparation (RAP and/or LRP as applicable) in line with IFC PS 5 requirements.
Under the IFC investment and as per agreed ESAP#4 requirements, Company will review and strengthen, its ESMS if required, with regards to land purchase and leasing procedures specifically addressing: long-term land leasing policy framework in line with PS5 requirements, identifying and addressing any risks of any economic displacement and loss of livelihoods on the leased lands, and the process of assessing fair lease value taking into account the productivity of land. The land acquisition procedures shall also incorporate impact or restriction access to common property resource (CPR) assessment and restoration requirements and harmonize the provisions governing use of land aggregators by establishing robust PS5 controls, including voluntariness verification, stakeholder engagement records, fair compensation assessments, and periodic audits of aggregator-managed transactions. The land process shall also establish a grievance mechanism at the stage of land procurement and extended to operations stage (wherein the lease payment continues for the complete life period of the project) with procedures for receiving, tracking, resolving, and monitoring grievances related to land transactions, compensation, livelihood impacts, and restrictions on access to resources.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
The Project consists of three (3) eligible projects for IFC financing: Bikaner Solar project (450MWdc) in Rajasthan; Jagaluru Solar Project (64 MW out of 300MW project cluster); and the Honawad solar and wind hybrid project (50MW only in a 159MW larger cluster), both of which are in Karnataka. The Rajasthan project is in the Deserts and Xeric Shrublands EcoRegion and the projects in Karnataka are in the South Deccan Plateau Dry Deciduous Forests EcoRegion. These ecoregions are dominated by dry scrubland habitats and desert landscapes that have predominately been cleared of vegetation.
Screening of the Projects' risks based on biodiversity studies and online sources indicate low to moderate risks for both solar projects. The Bikaner project is in an area of modified habitat consisting of an agricultural landscape and is outside of sensitive Great Indian Bustard (GIB) (IUCN CR) areas. There are no protected areas (PA) or Key Biodiversity Areas (KBA) in the vicinity. During surveys, both Steppe Eagle (Aquila nipalensis) and Egyptian vulture (Neophron percnopterus), both IUCN EN, were detected. Both species as well as migratory waterbirds that also occur in this landscape would be susceptible to potential risks from impacts from the transmission line. The Jagaluru Project is also not in or near to any PAs or KBAs and is outside of the known population of GIB and Lesser Florican (LF) (Sypheotides indicus) IUCN CR in Karnataka. There is the potential for migratory water birds and eagles within the landscape, however. To understand risks for both projects, under ESAP#1 requirements, further desktop and consultation with experts and officials is to occur to understand the risk of the transmission line route. Bird Flight Diverters (BFD) are to be installed along lengths identified as high risk. Post Construction Fatality Monitoring (PCFM) is to occur following installation as per ESAP #1 requirements.
For the Honawad Project, this site is adjacent to an existing wind/solar project. Initial biodiversity surveys did not identify significant biodiversity risks and screening of the site based on on-line sources indicate a moderate risk, with the potential for both water birds, soaring birds and bats which may pose risks from strike with wind turbines. This site is also not near to any PAs, KBAs nor important habitats for GB and LF within Karnataka. As part of the Project ESIA re-validation agreed with the Company as part of ESAP#1 requirements, further biodiversity surveys are required to characterize risks and impacts. Prior to operation, a Biodiversity Management Plan (BMP) that outlines measures to reduce risks of the windfarm as well as PCFM is to be prepared as part of ESAP #1 requirements. Under ESAP#4, Company will strengthen biodiversity risk assessment and management related capacity building and training of its E&S organization.
