Environmental and Social Management System

DESIGNED & DEVELOPED BY ECOFAV SERVICES PRIVATE LIMITED

Adani Green Energy Limited

Rev.: 1.0 Date: 28 May 2019
 Document Information
Title ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM
Number AGEL.ESMS
Owner DEPARTMENT OF ENVIRONMENT, HEALTH, AND SAFETY
Type MANAGEMENT SYSTEM Public

History of The Document

Reviewed By Reviewed By
Prepared / Description Approved By
Version Date [Manager – [Corporate Approved On
Revised By of Change [Head – EHS]
EHS] Social Expert]
SANJAY AMBUJ VARUN INITIAL
1.0 28-MAY-2019 RAJIV JAIN 28-MAY-2019
SHARMA MISHRA SHRIVASTAVA ADOPTION

//ORIGINAL //ORIGINAL //ORIGINAL

Signature
SIGNED// SIGNED// SIGNED//

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ESMS Plan May 2019, Rev. 1.0
Contents
1. Environmental and Social Management System Description 6
1.1. General Requirements 6
1.2. ESMS Documentation 9
1.3. Change Management 13
2. Policy 13
3. Identification of Risk and Impacts 14
3.1. Legal and Other Requirements 14
3.2. Social and Environmental Aspects and Impacts, Risk Assessment, and Risk Management
Planning 14
3.3. Occupational Health and Safety Hazard Identification, Risk Assessment, and Risk
Management Planning 14
4. Management Programs 15
4.1. Environmental, Social, and Health & Safety (ESHS) Objectives and Targets 15
4.2. ESHS Performance Improvement Management Program/Management Plans 15
4.3. Operational Controls 15
4.3.1. Operational Planning Process 15
4.3.2. Management of Social and Environmental Impacts 16
4.3.3. Control of Contractor Operations 16
5. Organizational Capacity and Competency 16
5.1. Structure and Responsibility 16
5.2. Training, Awareness, and Competence 18
6. Emergency Preparedness and Response 19
7. Monitoring and Review 20
7.1. ESMS Records 20
7.2. Monitoring and Measurement 20
7.2.1. ESMS Monitoring 20
7.2.2. Regulatory Compliance Verification Audits 21
7.2.3. ESHS Performance Measurements 21
7.3. Non-conformance Reporting, Corrective and Preventive Action 21
7.4. Internal ESMS Audits 22
7.5. Management Review 22
8. Stakeholder Engagement 23
8.1. Stakeholder Analysis and Engagement Planning 23
8.2. Disclosure of Information 24
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 8.3. Informed Consultation and Participation 24
8.4. Indigenous Peoples 24
8.5. Private Sector Responsibilities under Government-Led Stakeholder engagement 24
9. External Communications and Grievance Mechanisms 24
9.1. External Communications 24
10. Ongoing Reporting to Affected Communities 25

Table 1: ESMS Plan-References for Structure and Content...................................................................... 6

Table 2: Management Plans - General Applicability Over Project Life Cycle ........................................ 11
Table 3: Renewable Energy Project SOP's .................................................................................................. 12

Figure 1: ESMS Document Hierarchy ............................................................................................................ 9

Figure 2: ESMS Management Organizational Chart – AGEL .................................................................... 17

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ESMS Plan May 2019, Rev. 1.0
Glossary of terms
AOP Annual Operation Plan
BMP Best Management Practice
CEO Chief Executive Officer
COO Chief Operating Officer
CPAR Corrective/Preventive Action Request
CSR Corporate Social Responsibility
DPR Detailed Project Report
EHS Environmental, Health and Safety
EPC Engineering, Procurement, and Construction
E&S Environmental and Social
ESDD Environmental and Social Due Diligence
ESIA Environmental and Social Impact Assessment
ESHS Environmental, Social, Health, and Safety
ESMS Environmental and Social Management System
GIIP Good International Industry Practice
HSE Health, Safety, and Environment
IFC International Finance Corporation
AGEL Adani Green Energy Limited
OHS Occupational Health and Safety
PS Performance Standards
PPE Personal Protective Equipment
SOP Standard Operating Procedure

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 1. Environmental and Social Management System Description
1.1. General Requirements
In keeping with the requirements of International Finance Corporate (IFC) Performance
Standard 1, “Assessment and Management of Environmental and Social Risks and Impacts” (PS
1), Adani Green Energy Limited (AGEL) has established an Environmental and Social
Management System (ESMS) for its business activities. The ESMS is embodied in this ESMS
Plan and a series of supporting Management Plans and Standard Operating Procedure (SOPs).
These documents will be activated and periodically updated at appropriate points to ensure
that the ESMS remains responsive to changing environmental, human health and safety, and
other social management needs, as well as provide a level of detail that is commensurate with
available resources and the nature of the activities being conducted. Collectively, the ESMS
Plan and its supporting documents constitute a flexible management approach that is based
directly on PS 1 and can readily accommodate the changing needs of the Project. This ESMS
Plan and its supporting documents consort existing Health, Safety, & Environmental
Management System of AGEL.

The ESMS Plan will apply over the entire project life cycle and associated activities, which is
generally defined as three sequential phases:

A. Construction and development of renewable energy project and electric power transmission
infrastructure
B. Renewable energy project operations
C. Renewable energy project decommissioning, site restoration and closure

As noted in Table 1, in addition to the requirements of PS 1, ESMS Plan contents also consider
applicable elements of:

• the IFC Performance Standards (PSs)1;

• the ISO 14001 Environmental Management System2 Standard; and
• the ISO 45001 Occupational Health and Safety (OHS) Management System3 Standard.
1
See
https://www.ifc.org/wps/wcm/connect/c8f524004a73daeca09afdf998895a12/IFC_Performance_Standards.pdf?MOD
=AJPERES
2ISO 14001:2015, Environmental Management Systems – Requirements with Guidance for Use; International

Organization for Standardization, Geneva, Switzerland, 2015. ISO 14001 is considered as a GIIP only. References to this
standard should not be construed as a commitment to undertake third-party certification.
3ISO 45001:2018, Occupational Health and Safety Management Systems – Requirements with Guidance for Use;

International Organization for Standardization, Geneva, Switzerland, 2018. ISO 45001 is considered as a BMP for OHS
program management, as well as for its structural and contextual compatibility with PS-1 and ISO 14001. References to
this standard should not be construed as a commitment to undertake third-party certification.

Table 1: ESMS Plan-References for Structure and Content

Corresponding ISO Corresponding

ESMS Plan Applicable IFC Performance
14001:2015 ISO 45001:2018
Sections/Subsections Standard 1 requirements
requirements requirements
1.0 Introduction
Requirements, item 5, Page.
1.1. ESMS Description 4.3, 4.4 4.3, 4.4
7

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 Corresponding ISO Corresponding
ESMS Plan Applicable IFC Performance
14001:2015 ISO 45001:2018
Sections/Subsections Standard 1 requirements
requirements requirements
1.2. ESMS Requirements, item 5, Page.
4.4 4.4
Documentation 7
1.3. Change Requirements, item 5, Page.
4.4 4.4
Management 7
Requirements, item 6, Page.
2.0. Policy 5.2 5.2, 10.3
7
3.0. Identification of Risk and Impacts
3.1. Legal & Other Requirements, item 7, Page.
6.1.3 6.1.3
Requirements 7-8
3.2. Social and
Environmental Aspects,
Requirements, items 7-12,
Risk Assessment, and 6.1.2 6.1.2
Page. 7-9
Risk Management
Planning
3.3. Occupational
Health and Safety
Hazard Identification, Requirements, items 7-12,
N/A 6.1.2, 6.1.4
Risk Assessment, and Page. 7-9
Risk Management
Planning
4.0. Management Programs
4.1. Environmental,
Social, and Health & Requirements, items 13-16,
6.2, 6.2.1, 6.2.2 6.2, 6.2.1, 6.2.2
Safety (ESHS) Page. 9-10
Objectives and Targets
4.2. ESHS Performance
Improvement
Requirements, items 13-16,
Management 10.3 10.3
Page. 9-10
Program/Management
Plans
4.3. Operational Controls
4.3.1. Operational Requirements, items 13-16,
8.1 8.1
Planning Process Page. 9-10
4.3.2. Management of
Requirements, items 13-16,
Social and 8.1 N/A
Page. 9-10
Environmental Impacts
Social and Environmental
4.3.3. Control of Management System,
8.1 8.1.4
Contractor Operations Element (14), “Management
Program”, Page. 9-10
5.0. Organizational Capacity and Competency
5.1. Structure and Requirements, items 17-19.
5.3 5.3, 7.1
Responsibility Page. 10-11
5.2. Training, Awareness Requirements, items 17-19.
7.2, 7.3 7.2, 7.3
and Competence Page. 10-11

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 Corresponding ISO Corresponding
ESMS Plan Applicable IFC Performance
14001:2015 ISO 45001:2018
Sections/Subsections Standard 1 requirements
requirements requirements
6.0. Emergency
Requirements, items 20-21.
Preparedness and 8.2 8.2
Page. 11
Response
7.0. Monitoring and Review
Requirements, items 14, 24.
7.1. ESMS Records 7.5.3 7.5.3
Page. 9, 12
7.2. Monitoring and Measurement
Requirements, items 22-24,
7.2.1. ESMS Monitoring 9.1, 9.1.1 9.1.1
Page. 11-12
7.2.2. Regulatory
Requirements, items 22-24,
Compliance Verification 9.1.2 9.1.1
Page. 11-12
Audits
7.2.3. ESHS
Requirements, items 22-24,
Performance 9.1.1 9.1.1
Page. 11-12
Measurement
7.3. Non-conformance
Requirements, items 22-24,
Reporting, Corrective 10.2 10.2
Page. 11-12
and Preventive Action
7.4. Internal ESMS Requirements, items 22-24,
9.2.1, 9.2.2 9.2.1, 9.2.2
Audits Page. 11-12
7.5. Management Requirements, items 22-24,
9.3 9.3, 10.1, 10.3
Review Page. 11-12
8.0. Stakeholder Engagement
8.1. Stakeholder
Requirements, items 26-28,
Analysis and 7.4.1, 7.4.2, 7.4.3 7.4.1, 7.4.2, 7.4.3
Page. 13
Engagement Planning
8.2. Disclosure of Requirements, items 29,
7.4.1, 7.4.2, 7.4.3 7.4.1, 7.4.2, 7.4.3
Information Page. 13
8.3. Informed
Requirements, items 30,
Consultation and 7.4 7.4
Page. 13
Participation
Requirements, items 32,
8.4. Indigenous Peoples 7.4.3 7.4.3
Page. 14
8.5. Private Sector
Responsibilities under
Requirements, items 33,
Government-Led 6.2.1, 6.2.2, 7.4.3 6.2.2, 7.4.3
Page. 14
Stakeholder
Engagement
9.0. External Communications and Grievance Mechanisms
9.1. External Requirements, items 34,
7.4.3 7.4.3
Communications Page. 15
9.2. Grievance
Requirements, items 35,
Mechanisms to 6.2, 6.2.1, 6.2.2 6.2, 6.2.1, 6.2.2
Page. 15
Affected Communities
10.0. Ongoing
Requirements, items 36,
Reporting to Affected 7.4.3 7.4.3
Page. 15
Communities
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 1.2. ESMS Documentation
The overall hierarchy of documents that comprise the ESMS is depicted in Figure 1.

Figure 1: ESMS Document Hierarchy

The functions fulfilled by each level of documentation are summarized as follows:

• The highest-tier document in the ESMS is represented by this ESMS Plan, which
describes the overall structure, requirements, and content of the management system,
as well as the organizational structure, key management responsibilities, and the
specific functions fulfilled by other categories of system documents. Unless noted
otherwise, the ESMS Plan and its supporting documents are intended to apply only to
the areas, facilities, and activities that constitute the AGEL Project. These are expected
to include:

• Construction and development of renewable energy project and electric power

transmission infrastructure
• Renewable energy project operations
• Renewable energy project decommissioning, site restoration and closure

The ESMS Plan will be periodically reviewed and updated in response to the changes that
will occur in various phases of the Projects life cycle. It is the primary reference for the
overall design and contents of the ESMS and is meant to serve as a key communication tool
in the presentation of the ESMS to lenders, regulatory authorities, and other external
parties.

The ESMS Plan will be supported by a suite of Management Plans, which are focused on the
management or mitigation of the specific environmental and social issues or impacts
generally associated with one or more phases of the Project. Management Plan content will
depend in significant part on the design assumptions and details contained in and the
results of the Updated Environmental and Social Impact Assessment Report and/or other
modes of project information.

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 A general list of the Management Plans likely to be required over all phases of the Projects
and their general applicability over the life of the projects is presented in Table 2. The
general scope and purpose of each Management Plan are briefly summarized as follows:

I. Management Plan 1: Occupational Health & Safety Plan

This plan addresses all aspects of occupational health and safety on the Project, with
emphasis on the identifying required safety behaviors, preventive/protective measures,
and the routine implementation of SOPs to minimize the potential for accidents, injuries,
and illness to the AGEL and contractor workforce. The Occupational Health and
Safety/Accident Prevention Plan will be updated to specifically address the OHS aspects
of a specific renewable energy project and electric power transmission infrastructure
development, operations in advance to permit ample time for workforce training.

II. Management Plan 2: Emergency Preparedness and Response Plan

This plan will be designed to minimize the potential for accidents and emergency
situations involving the construction operations, and/or the renewable energy project’s
physical structures or operational practices. The Emergency Preparedness and Response
Plan will address the minimum safety requirements, as well as appropriate GIIPs drawn
from the international organizations, and other sources.

III. Management Plan 3: Construction Management Plan

This plan will be developed by AGEL’s Engineering, Procurement, and Construction (EPC)
contractor, and will describe the overall organization and management of the major
construction phase of the Project, from initial earthworks through the construction and
commissioning of the renewable energy project’s, fuel storage areas, workshops, man-
camp, waste management facilities, roadways, and other infrastructure.

IV. Management Plan 4: Waste Management Plan

The Waste Management Plan will contain requirements for periodic inspections of
respective materials, collection, segregation of incompatible and materials, the condition
of warning or access control signage, and the functionality or readiness of personal
protective equipment (PPE), fire suppression and other emergency systems.

V. Management Plan 5: Transportation Management Plan

This plan addresses the management of truck/ freight wagons on the AGEL Project site
road, as well as staff travel to Project sites via crew bus or light vehicles. The plan will
address rules of the road, travel security, illegal or undesirable human influx into the
Project concessions, sharing of maintenance responsibilities with other road users, and
other requirements.

VI. Management Plan 6: Stakeholder and Community Relation Management Plan

This plan describes the methods AGEL will use to engage the workforce, affected
communities, and other potential stakeholders directly affected by the specific project
activity, and to ensure that relevant environmental and social information is disclosed and
disseminated through appropriate outreach and communications procedures.

VII. Management Plan 7: Visitor Management Plan

This plan addresses specific concerns on minimizing and ensuring the health and safety
potential for uncontrolled/controlled entry of the peoples to the project area, especially
during renewable energy project and electric power transmission infrastructure

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 construction and operations, and provides specific strategies and procedures to minimize
the risk.

VIII. Management Plan 8: Environmental and Social Monitoring Plan

This plan will be designed to capture all of the specific monitoring needs identified in
individual Management Plans and supporting SOPs; it will provide for the development and
maintenance of a spreadsheet documenting the planning, execution, and reporting actions
associated with the environmental and social monitoring requirements that will apply over
the construction, operation, decommissioning/closure phases of the Project.

IX. Management Plan 9: Biodiversity Management Plan

This plan will require need-based surveys of flora and fauna to monitor potential changes
to the biodiversity profile of the Project in the construction, operational phase. It may also
require ongoing monitoring for the presence of key indicator/potentially endangered
species which may require adjustments in operating practices or other measures to
protect affected habitat or otherwise minimize potential impacts.

Table 2: Management Plans - General Applicability Over Project Life Cycle

MP Plan Title Construction Operation Decommissioning

I Occupational Health & Safety Plan
II Emergency Preparedness and
Response Plan
III Construction Management Plan
IV Waste Management Plan
V Transportation Management Plan
VI Stakeholder and Community
Relation Management Plan
VII Visitor Management Plan
VIII E & S Monitoring Plan
IX Biodiversity Management Plan

All Management Plans will be organized for effectiveness in implementation, and, as

appropriate for the subject matter, will include:

• a clear statement of objectives or purpose;

• a brief discussion of the relationship to the overall structure and purpose of the Project
ESMS;
• regulatory or GIIP references, as applicable;
• roles and responsibilities of key personnel;
• specific measures, procedures, or practices (with detail either included or invoked by
references to SOPs, other Management Plans, or other documents) to prevent or
mitigate the environmental or social issues or impacts that are the primary focus of a
given Management Plan;
• training requirements (see Section 5.2);
• inspection and/or monitoring requirements associated with Plan implementation,
including cross-references to non-conformance resolution processes (see Section 7);
and
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 • any external or internal reporting requirements.

Modifications may also be required to incorporate the results of regular environmental,

social, and health and safety (ESHS) risk reviews as discussed in Sections 3.2 and 3.3. All of
these changes and modifications will be controlled within the context of this ESMS Plan as
described in Section 1.3.

It should be noted that development and finalization of all Management Plan substantially
depend on details that will be finalized in project DPR/ESIA Reports/business terms with
regulatory authorities/ financial institutions as well as the availability of staffing,
appropriate resources. Advance implementation of preliminary versions of selected
Management Plans and/or SOPs may be authorized in response to specific project needs
directed by the Head - EHS, Manager - EHS and/or Corporate Social Expert, as noted in
Section 5.1.

The ESMS Plan and the various Management Plans will be supported by a suite of Standard
Operating Procedures (SOPs). SOPs are written specifically to guide AGEL workers and
(when invoked by contract, all or in part) contractor personnel in the day-to-day
performance of specific field or office activities required by the upper-tier plans. SOPs will
be developed with a level of detail commensurate with the phase of the project, the
complexity of the task, current staffing levels, and the capabilities and experience of the
workforce. SOPs may support one or several Management Plans and one or several Project
phases.

A list of the SOPs to support this ESMS Plan is presented in Table 3.

Table 3: Renewable Energy Project SOP's

SOP Designator SOP Title

AGEL.PROCEDURE.01 Document and Record Control
AGEL.PROCEDURE.02 Field Inspections
Identification of Non-conformances and
AGEL.PROCEDURE.03
Respective Action
AGEL.PROCEDURE.04 Training and Development
AGEL.PROCEDURE.05 Grievance Management
AGEL.PROCEDURE.06 Use of Personal Protective Equipment
AGEL.PROCEDURE.07 Emergency Preparedness Plan
AGEL.PROCEDURE.08 Transportation Safety
AGEL.PROCEDURE.09 Handling of Hazardous Materials
Recognition and Reporting of Incidents, Illness and
AGEL.PROCEDURE.10
Safety Hazards
AGEL.PROCEDURE.11 Identification of Legal and Other Requirements
Determination of Environmental and Social Aspects
AGEL.PROCEDURE.12
and Significant Impacts
AGEL.PROCEDURE.13 Management Reviews
AGEL.PROCEDURE.14 Water and Waste Water Management
AGEL.PROCEDURE.15 Site Security
AGEL.PROCEDURE.16 Hazard Identification and Risk Assessment
AGEL.PROCEDURE.17 Archaeological Chance Find

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 Additional SOPs required for the long-term implementation of the ESMS Plan and
Management Plans may also be developed and issued at any time in accordance with
AGEL.PROCEDURE.01, “Document and Record Control.”

1.3. Change Management

It must be emphasized that in order for the ESMS to be effective in actual practice, the
overall complexity and level of detail provided in the Management Plans and their
supporting SOPs must be commensurate with AGEL’s level of employment, the availability
of qualified personnel resources, the overall complexity and significance of the
environmental and social risks associated with the activities being conducted, and the
financial and other business management resources that are available during the associated
Project activity, and phase. SOP preparation, review, approval, controlled distribution, and
update requirements are defined by AGEL.PROCEDURE.01, “Document and Record Control.”
Latest approved versions of all levels of ESMS documents will be subject to controlled
distribution in accordance with AGEL.PROCEDURE.01, “Document and Record Control.” All
Management Plans and SOPs will be subject to review and approval by the Head - EHS,
Manager – EHS and/or Corporate Social Expert prior to issuance.

2. Policy
The AGEL policies are defined consecutively as Appendix A, Appendix B, Appendix C,
Appendix D, Appendix E, Appendix F and consist of:

▪ Integrated Management System Policy

▪ Vigil Mechanism / Whistle Blower policy
▪ Human Resources Framework Policy;
▪ Stakeholder and Community Engagement Strategy; and
▪ Human Rights and Community Relations Policy
▪ Corporate Social Responsibility (CSR) Policy

The Head – EHS, Manager – EHS and Corporate Social Expert have key roles in ensuring proper
policy implementation at all levels of the organization, through the administration of this ESMS
Plan and the various monitoring measures described herein. Taken in combination, these
policies emphasize open communication and consideration of the social and environmental
interests of affected communities and residents, regulatory authorities, the AGEL workforce,
and other stakeholders. The suitability and effectiveness of these policy statements will be
evaluated at least annually as part of the management review process described in Section 7.5.
Policy contents will also be communicated to the Project workforce through periodic human
resources, social, environmental, and OHS awareness training (see Section 5.2), and by
distribution and posting of the policy documents in key locations at AGEL’s headquarter
locations in Ahmedabad, the project sites, and other facility locations.

Project contractors will also be advised on applicable policy requirements (including but not
limited up to offering accidental insurance, medical fitness test at the time of employee joining,
providing applicable PPE’s, etc.) through their individual procurement documents, as noted in
Section 4.3.3. Copies of these policies will also be distributed in response to specific requests
for information, or as may otherwise be directed by Project management.

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 3. Identification of Risk and Impacts
3.1. Legal and Other Requirements
The AGEL will maintain the understanding of the full scope of legal and regulatory requirements
that apply to all phases of the project life cycle, as well as any associated planning, operating,
monitoring, or reporting requirements. Prior to the initiation of the construction phase of the
project, however, procedure AGEL.PROCEDURE.11, “Identification of Legal and Other
Requirements” will be implemented in order to provide guidance for routinely integrating
required permitting actions into the advance planning and scheduling of construction, and
operations activities, as well as new (if any) activities that may be initiated in those phases. This
understanding will be considered in the risk and impact evaluation process described in Section
3.2. AGEL.PROCEDURE.11 will also provide for the development and regular update of a Project-
specific register of regulatory requirements that is based on the regulatory setting defined in
the project planning document, as well as other voluntary lender and industry-specific standards
that AGEL may choose to adopt for the Projects (e.g., applicable IFC performance standards and
industry-specific guidelines). AGEL.PROCEDURE.11 will also require that the Project establish
and maintain access to appropriate information sources as the means to identify new or
modified regulatory requirements or changes that may affect any phase of Project operations.

As noted in Section 7.2.2, after the initiation of the construction phase, the Project’s regulatory
compliance status will be subject to an internal verification audit on at least on a half-yearly
basis. Any compliance issues that may be detected in the verification audit process will be
formally resolved in accordance with AGEL.PROCEDURE.03, “Identification of Non-
conformances and Respective Action”

3.2. Social and Environmental Aspects and Impacts, Risk Assessment, and Risk Management
Planning
Initial identification of the social and environmental aspects and potential impacts associated
with renewable energy facility development, operations, decommissioning and closure
operations will be documented separately for each project activity. The potential environmental
and social impacts that will be identified through the ESIA’s or any other source of records will
be reflected in the Management Plans, listed in Table 2 and described in greater detail in Section
4.3.2.

The social and environmental impacts so identified will be summarized and documented in a
project-specific list or register, which will be evaluated on at least on a half-yearly basis. The
input provided by local/external stakeholders will also be identified and specifically considered
in the evaluation of social and environmental aspects and impacts. Any necessary changes in
the aspects/impacts register will be reflected in appropriate modification or additions to the
Project’s Management Plans or other performance improvement measures, as discussed in
Section 4.3.

3.3. Occupational Health and Safety Hazard Identification, Risk Assessment, and Risk
Management Planning
As noted in Table 3, AGEL having a group of OHS-related SOPs to address predicted hazards and
OHS risks. Work area-specific risks that will need to be addressed as the Project progresses will
be evaluated and documented in a periodically updated register of risks and mitigation
measures, in accordance with AGEL.PROCEDURE.10, “Recognition and Reporting of Incidents,
Illness and Safety Hazards.” The results of this periodic evaluation will form the basis of the
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 OHS component of an ongoing performance improvement program, which will be implemented
at the start of major construction and is further described in Section 4. In the meantime,
hazards or unsafe conditions that may be observed will be documented and reported as noted
in AGEL.PROCEDURE.10, “Recognition and Reporting of Incidents, Illness and Safety Hazards”
and will be investigated and considered, as appropriate, in updates or additions to affected
Management Plans. Should additional SOPs be required to address newly observed conditions
or other Management Plan needs, they will be developed in accordance with
AGEL.PROCEDURE.01, “Document and Record Control.”

4. Management Programs
4.1. Environmental, Social, and Health & Safety (ESHS) Objectives and Targets
At the start of the construction phase of the Projects and on at least an annual basis thereafter,
performance objectives and targets will be set in an effort to further minimize or mitigate the
environmental and social impacts described in Section 3.2, as well as any identified OHS hazards
and risks as discussed in Section 3.3, over and above the measures that may already be in effect
in existing Management Plans or SOPs.

4.2.ESHS Performance Improvement Management Program/Management Plans

At the start of the construction phase of the Projects, AGEL will also begin to implement an
annual social, environmental, and OHS performance review and improvement process that
updates (or generates new) Management Plans to mitigate specific impacts or undertake
specific performance improvements, based on the performance objectives and targets
discussed in Section 4.1.

AGEL.PROCEDURE.01 requires that technical guidance and appropriate scheduling information

be provided for each performance improvement activities. Current regulatory requirements (see
Section 3.1) and communications from external stakeholders (see Section 8.1) will also be
considered in the process of preparing and updating individual Management Plans. Progress
toward the completion of the improvement actions so defined will be monitored as described in
Section 7.2.1 of this ESMS Plan. Final review and approval of specific performance improvement
actions will be conducted as part of the annual management review process described in
Section 7.5.

4.3.Operational Controls
4.3.1. Operational Planning Process
Prior to the operational phase of the Project, AGEL will establish and begin to implement an
Annual Operation Plan (AOP) under the direction of the Head - Projects. The AOP will address
the general scope of the anticipated renewable energy project’s operations over the next
planning year. AOP preparers will specifically consider the impacts and management and
mitigation measures noted in the project ESIA/ESDD/Any document containing relevant
information and the performance improvement plans discussed in Section 4.2. The draft
document will be submitted for evaluation by the Project Manager to the Head – Projects, Head
- EHS and other management staff in order to ensure that regulatory and stakeholder issues
and general feedback on environmental, social, and OHS performance are properly considered
in the long-range planning of renewable energy project operations, as well as any extension (if
any) operations. When approved, the AOP will form the general framework within which
monthly and weekly operational planning meetings will be conducted. Operational instructions
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 will typically be generated as the output of such meetings and distributed to supervisory and
other personnel as necessary to guide ongoing renewable energy project’s operations.

4.3.2. Management of Social and Environmental Impacts

As noted in Section 4.2 and Table 2, a series of detailed Management Plans will be developed
to address those areas of project operations for which the ESIA/ESDD will indicate potentially
significant environmental and social impacts, or could potentially occur in one or more phases
of the renewable energy project life cycle. Where necessary, these Management Plans will be
supported by SOPs. All such documents are subject to periodic evaluation, refinement, and
update in response to changing regulations, process changes or improvements, or other change
requirements, in accordance with the processes described in Section 1.3.

The specific environmental impacts associated with any field investigation or construction
activity that involves a surface disturbance will be identified, documented, and appropriately
mitigated. Field activities near any significant find shall be set back at least 10 meters unless
other setback considerations are directed by regulatory authorities. Also, as discussed in
Section 3.2, at the start of the construction phase, the Project will also commence an annual
evaluation of the OHS hazards and risks associated with its operations, in accordance with
procedure AGEL.PROCEDURE.16, “Hazard Identification and Risk Assessment.” The results of
this evaluation may prompt OHS performance improvements as described in Section 4.2, or
updates or additions to the SOPs or Management Plans listed previously. Hazardous or unsafe
conditions that may be observed in the course of the Project are to be documented in
accordance with AGEL.PROCEDURE.10, “Recognition and Reporting of Incidents, Illness and
Safety Hazards” investigated, and, if appropriate, also considered in updates or additions to the
Management Plans and/or SOPs. Additional procedural controls may be established for newly
observed conditions, as appropriate, in accordance with AGEL.PROCEDURE.01, “Document and
Record Control.”

4.3.3. Control of Contractor Operations

AGEL techno-commercial staff will coordinate with the Manager-EHS and Corporate Social
Expert as necessary to ensure that appropriate environmental, social, OHS, and safety
behavioral controls are included in the service/purchase orders or contracts issued to suppliers
and contractors, in accordance with AGEL’s standard procurement processes. AGEL policy,
Management Plan, or SOP requirements may be invoked directly without modification, or
selected requirements may be invoked as appropriate for the nature of the procurement and
the capabilities of the contractor; contractor training needs will be defined as appropriate. In
the construction and operations phases, special contractual controls applicable to suppliers will
be described in the Emergency Preparedness and Response Plan, and other Management Plans
as required. Other appropriate contractual requirements will be invoked to ensure that the
delivery of materials and equipment or other contractor operations at the project sites do not
negatively impact the regulatory compliance status of the Project or compromise the
effectiveness of the ESMS. Contractor staff may be requested to participate in emergency
response drills or other training exercises, at the discretion of the EHS Coordinators; any such
participation requirements will be incorporated in the governing procurement document.

5. Organizational Capacity and Competency

5.1. Structure and Responsibility
Figure 2 depicts AGEL’s organizational structure;
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 Figure 2: ESMS Management Organizational Chart – AGEL

All AGEL employees, contractors, subcontractor are individually and collectively responsible for:

• Working safely, within the guidelines and requirements established by this ESMS Plan, its
supporting Management Plans and SOPs;
• supporting the environmental, social, and OHS policies established for the AGEL Project (see
Appendix A, Appendix B, and Appendix E) in the day to day performance of their work;
• Notify their supervisors, the Engineers, or the Environmental, Health, and Safety Officers (EHS
Coordinator) of any observed spills, equipment malfunctions, unsafe or unhealthy situations,
improper environmental practices, worsening trends, or other issues that could represent
nonconformance with the requirements this ESMS Plan or its supporting Management Plans or
SOPs.

Other specific responsibilities associated with the key positions noted in Figure 2 are
summarized as follows:

• Head - EHS: The AGEL’s EHS head, has overall responsibility for successful completion
of Project activities, operations in the manner described in this ESMS Plan and the
supporting Management Plans and SOPs described herein. The Head - EHS also
assumes a lead role in the investigation and resolution of any community relations issues
that may occur in the course of the Project.

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 • Project Manager: The Project Manager is responsible for overseeing day-to-day
clearance and/or construction/operation activities. These duties include the review of
construction reports to monitor progress and issues encountered, and in assisting the
Environmental and Health and Safety Coordinators in the timely resolution of any
observed health, safety, and environmental (HSE) issues.
• Manager - EHS: The Manager - EHS is responsible for the administration of AGEL’s ESMS
management system and will participate in the review, approval, and as necessary,
update or modification of this ESMS Plan and supporting Management Plans and SOPs
in response to changing project conditions. The Manager - EHS will also provide
management support to the Engineers and the EHS Coordinator as necessary to ensure
proper implementation of ESMS planning requirements.
• Corporate Social Expert: The Corporate Social Expert in coordination with Head – EHS,
Manager – EHS, will be responsible to develop/revise and to avail the Stakeholder and
Community Relation Management Plan to the site management. He/she will be
responsible for working with the project development and land procurement teams to
act as an interface between the project and affected communities. He/she will Work in
coordination with the Head – EHS, Manager – EHS, Site EHS Coordinator/s to ensure
effective engagement and consultation with people living/working close to or within the
project area and wider affected communities. He/she will be working with the project
management to maintain good community relations and address community concerns
as they arise and agree with measures to respond to grievances in liaison with the wider
project team and grievance committee.
• EHS Coordinator: The EHS Coordinator will be responsible for the regular monitoring of
project activities to ensure continuing compliance with this ESMS Plan; see Section 7.0.
The EHS Coordinator will provide input to periodic EHS monitoring reports, and may also
conduct focused inspections of specific environmental or social/community relations
issues at the request of the Project Manager and/ or Stakeholder Relationship Officer.
• Engineer: The Engineers will be responsible for their reporting authorities for assisting
in special environmental tasks, as well as the regular monitoring of project activities to
ensure continuing compliance with this ESMS Plan. Special assignments may include
advising the construction team on applicable World Bank/ IFC requirements, best
management practices for stockpiling of topsoil and erosion control, reviewing
engineering designs for environmental compliance, and monitoring resolution of
corrective actions from ESHS audits. The Engineer may provide input to periodic EHS
monitoring reports.

5.2. Training, Awareness, and Competence

The AGEL’s workforce will be provided with appropriate types and levels of training in
accordance with AGEL.PROCEDURE.04, “Training and Development.” Training subjects and
methods will be selected that are commensurate with the characteristics of routine and
emergency work assignments, as well as any OHS hazards or environmental and social
impacts that may be associated with such assignments. Training methods will be selected
based on job descriptions and the experience and qualifications of the employee. At a
minimum, all employees and new hires will receive awareness training that (as appropriate
for the phase of the Project and relevant to their role and responsibilities) addresses:

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• AGEL’s community relations and IMS policies and commitments (see Section 2.0);
• AGEL’s human resources framework policy and associated disciplinary procedures (see
Appendices B, C);
• the primary social and environmental aspects of the project activity, their significant impacts,
and the measures that must be employed to manage or mitigate such impacts;
• the primary workplace OHS hazards likely to be encountered, and how to avoid such hazards or
mitigate their risks or effects (the risk register developed under AGEL.PROCEDURE.16, “Hazard
Identification and Risk Assessment” will help in this regard); and
• any significant regulatory or community stakeholder concerns that must be considered in day-
to-day operations (see the complaint records required by AGEL.PROCEDURE.05).

Refresher training will be provided to all staff on at least an annual basis. Additional training in
the specific requirements of the plans and procedures that support the ESMS will be provided,
as appropriate for individual work assignments. Specific training requirements applicable to
suppliers or contractors will be defined within the context of their individual contracts or
purchase orders as discussed in Section 4.3.3. All site visitors will be escorted and required to
complete an ESMS briefing on arrival at any project site.

6. Emergency Preparedness and Response

The Emergency Preparedness and Response Plan will apply to all phases of the Projects and is
designed to minimize the potential for accidents and emergency situations involving the
construction activities, and renewable energy project’s physical structures or operational
practices.

The Emergency Preparedness and Response Plan will be developed in conjunction with the
other Management Plans developed for specific construction, operation and
decommissioning/closure phase activities (see Section 4.2), and will be reviewed and updated,
as appropriate, on at least an annual basis. The Emergency Preparedness and Response Plan
will identify key emergency-related roles and responsibilities and will provide direction on
required responses to operational or environmental emergencies. The Emergency Preparedness
and Response Plan will also be supported by several key SOPs, including:

• AGEL.PROCEDURE.04, “Training and Development”;

• AGEL.PROCEDURE.06, “Use of Personal Protective Equipment”
• AGEL.PROCEDURE.10, “Recognition and Reporting of Incidents, Illness and Safety Hazards”
• AGEL.PROCEDURE.15, “Site Security.”
• AGEL.PROCEDURE.16, “Hazard Identification and Risk Assessment”

The Emergency Preparedness and Response Plan will also contain requirements for periodic
tests and drills to ensure that necessary response actions are understood by AGEL’s designated
site rescue team, other project staff, contractors, and, as appropriate for the given location,
community emergency response personnel. In addition to the emergency notification
requirements addressed in the Emergency Preparedness and Response Plan, the circumstances
and response actions associated with any significant spills, releases, accidents, near-misses, or
other emergency situations for which the AGEL’s Project Activity has direct responsibility will
be documented and investigated, and appropriate corrective and preventive actions will be
taken in conformance with Section 7.3 and AGEL.PROCEDURE.03, “Identification of
Nonconformances and Respective Action.” Preventive actions in such cases will require a
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 mandatory review of the adequacy and effectiveness of the Emergency Preparedness and
Response Plan and its supporting procedures, and subsequent updates as warranted by the
results of the review.

7. Monitoring and Review

7.1. ESMS Records
Records generated as output from the implementation of the ESMS Plan and its supporting
plans and procedures will be filed and maintained by administrative staff under the direction of
the Manager - EHS, in accordance with procedure AGEL.PROCEDURE.01, “Document and
Record Control.” AGEL.PROCEDURE.01 defines records organization, retention, and storage and
retrieval requirements, as well as access control and other requirements designed to preserve
the accessibility and integrity of records.

7.2. Monitoring and Measurement

7.2.1. ESMS Monitoring
Specific ESMS monitoring considerations may be addressed in individual Management Plans
and supporting SOPs. However, a comprehensive Project Environmental and Social Monitoring
Plan will also be developed to capture all of the specific monitoring needs identified in these
documents and the final project ESIA/DPR. The Environmental and Social Monitoring Plan will
provide for the development and maintenance of a spreadsheet documenting the planning,
execution, and reporting actions associated with the environmental and social monitoring
requirements that will apply in the construction, operation, decommissioning/closure, and post-
closure phases of the project. The sources of these requirements may include:

• Environmental and social monitoring protocols established by the Project as a result of

ESIA or any other relevant activities;
• additional environmental, social, and OHS monitoring parameters that may be identified
by the other Indian regulations;
• progress monitoring requirements associated with the performance improvement
process described in Section 3.2; and
• other specific environmental or social monitoring requirements established by individual
Management Plans.

With respect to environmental monitoring, maps depicting monitoring locations, as

appropriate for the construction phase of the Project will be included in the early iterations
of the Environmental and Social Monitoring Plan. Appropriate updates shall be made as to
the Project proceeds from construction to operation, and decommissioning/closure.
Specific sampling and monitoring SOPs and required laboratory analytical procedure
requirements will be invoked by reference.

Non-conformances noted in monitoring activities will be resolved through the corrective

and preventive action process discussed in Section 7.3. The Environmental and Social
Monitoring Plan will also describe the preparation and independent review, approval, and
issue of an annual performance monitoring report. Consideration of the annual performance
monitoring report results will represent a major component of the management review
process described in Section 7.5.

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 7.2.2. Regulatory Compliance Verification Audits
No later than one year after the commencement of the construction phase (and annually
thereafter), the Manager – EHS will request a detailed verification of Project compliance
with applicable regulations. Audits may be conducted by AGEL personnel or qualified
contractors, subject to functional independence, training, and qualification requirements.
The current versions of the regulatory requirements list developed in accordance with
Section 3.1 will be used as a primary reference for the audit, and audit results will be
considered in any subsequent updates. Any non-conformances will be promptly
documented and resolved as required by Section 7.3 and AGEL.PROCEDURE.03,
“Identification of Non- conformances and Respective Action.”

7.2.3. ESHS Performance Measurements

After the initiation of the construction phase, the Project will conduct an annual evaluation
of OHS hazards and risks, in accordance with AGEL.PROCEDURE.16, “Hazard Identification
and Risk Assessment” Per AGEL.PROCEDURE.03, evaluated documents will include
corrective and preventive action records generated for significant near-misses and/or
accidents that occurred in the previous year, as well as the number of OHS training sessions
conducted, the number of staff trained in comparison to the average annual employment
level, and records of specific physical improvements to infrastructure made to correct OHS
deficiencies or other OHS-related purposes. The results of this evaluation will form the basis
of the OHS component of the performance improvement program described in Section 4.2,
and will also be reported to management as part of the performance data required by the
management review process discussed in Section 7.5.

7.3. Non-conformance Reporting, Corrective and Preventive Action

All AGEL’s staff are responsible for bringing suspected non-conformances, or releases of
potentially hazardous wastes or materials, or other existing or potential emergency
situations to the immediate attention of their supervisor or the Engineer or the EHS
Coordinator, who will forward such information to the Manager - EHS for evaluation. In
addition to the specific response actions that may be required by individual Management
Plans or the current Emergency Preparedness and Response Plan (see Section 6.0), such
situations will be promptly evaluated, documented, and thoroughly investigated, and
appropriate management actions will be taken in accordance with the corrective and
preventive action processes described in AGEL.PROCEDURE.03, “Identification of Non-
conformances and Respective Action.”

In addition to direct observation, the requirements of AGEL.PROCEDURE.03 will also be

invoked for the resolution of non-conformances identified through external stakeholder
communications (see Sections 8.1 and 9.1); periodic regulatory compliance verifications
(see Section 7.2.2); annual internal ESMS audits (see Section 7.4); or external inspections
or audits conducted by or at the request of regulatory agencies or other external
stakeholders.

Non-conformances are defined as conditions that AGEL can control or substantially

influence that:

• are contrary to AGEL’s IMS and Community Relations Policy commitments (see Section 2.0 and
Appendix E);

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• can be classified as accidents or significant near-misses;
• violate a legal or regulatory requirement, or represent a worsening condition that could result
in a violation if not corrected;
• could potentially result in negative environmental or social impacts; or
• represent a lack of conformance with this ESMS Plan or its supporting Management Plans and
procedures.

If a non-conformance is judged to exist, Corrective/Preventive Action Requests (CPARs) will be

initiated and tracked until closure in accordance with AGEL.PROCEDURE.03. CPAR documents
and tracking logs are considered to be key ESMS performance records and will be maintained
as described in Section 7.1 and AGEL.PROCEDURE.01, “Document and Record Control.” CPAR
information will be routinely evaluated, as appropriate, in the planning of regulatory compliance
verification audits, internal ESMS audits (see Section 7.4), and management reviews (Section
7.5).

7.4. Internal ESMS Audits

After the start of the construction phase, a comprehensive internal audit of the functionality
and effectiveness of the ESMS will be performed at least half-yearly. Audit procedure will be is
based on a combined environmental/quality, social management system auditing standard that
is cited by both ISO 14001, ISO 45001 and IFC PSs. Audit responsibilities will be assigned to
properly qualified personnel and/or independent contractors or consultants who are
functionally independent of the operational areas being audited. Additional audits may be
performed at the discretion of AGEL’s senior management. Any non-conformances detected in
the audit process will be resolved in accordance with AGEL.PROCEDURE.03, “Identification of
Non-conformances and Respective Action.”

7.5. Management Review

After the beginning of the construction phase, an SOP will be developed to guide the
performance of a comprehensive annual internal management review of the overall suitability
and effectiveness of the AGEL’s ESMS, in accordance with AGEL.PROCEDURE.13, “Management
Reviews.” Such reviews will involve the independent examination of several layers of
environmental, social, and OHS performance information developed through the routine
implementation of this ESMS Plan and its supporting Management Plans and SOPs. This
information will be assembled by or at the direction of the Head - EHS, and will include:

• open and closed CPARs generated from the reporting of environmental, social, or OHS-
related non-conformances, periodic regulatory compliance audits, monitoring trends or
results, internal ESMS audits, or inspections or evaluations that may have been conducted
by regulatory agencies, lending institutions, or other external organizations;
• known or potential environmental and social issues and the concerns of interested parties,
as documented in current communication logs and supporting correspondence (see
Sections 8 and 9 and Appendix E, “Human Rights and Community Relations Policy”);
• the current version of the AOP that addresses the projected scope of the next year’s
development and/or operations (see Section 4.3.1);
• environmental, social, and OHS performance monitoring results, or other reports or
information collected to assess progress towards the completion of specific mitigation
measures or performance improvement actions;

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 • reports from previous management reviews conducted in accordance with this Section; and
• other pertinent information

This information will be evaluated against the requirements of the current versions of AGEL
policy documents (see Appendix A, B, C, D, and E) and the current regulatory requirements
register (see Section 3.1). Any anticipated changes in regulatory compliance requirements,
facility changes, organizational changes, or new directives that potentially affect the company's
environmental, social, and/or OHS management practices will also be considered.

The management review will be documented in report format, and, as appropriate, will include
specific recommendations for ESMS improvements, the update of the AOP, external sharing or
publication of annual monitoring report results, or other appropriate management actions. It
will be presented to AGEL’s Chief Executive Officer (CEO) for final review and approval.
Recommended performance improvement tasks will be documented that address any required
ESMS Plan, Management Plan, or SOP updates; policy modifications; external communications;
or other appropriate improvement actions.

If previously undetected non-conformances are observed in the management review process,

they shall be documented and resolved as discussed in Section 7.3.

8. Stakeholder Engagement
8.1. Stakeholder Analysis and Engagement Planning
AGEL, wherever do it's business activities, will ensure;

• continuous engagement and consultation with the various stakeholder groups; and
• sponsorship of appropriately beneficial community development projects.

AGEL will carry these themes forward through its “Stakeholder and Community Engagement
Strategy”, which will be managed within the context of this ESMS.

The strategy will be applicable during all the phases of the project activity. General protocols
for documenting and managing complaints from external stakeholders will be managed in
accordance with AGEL.PROCEDURE.05, “Grievance Management”, in order to ensure that any
external stakeholder complaints or inquiries detected are documented and brought to the
attention of management and properly considered as the Stakeholder and Community
Engagement Strategy/Management Plan.

Several SOPs will also be used in support of the ‘Stakeholder and Community Engagement
Strategy/Management Plan’ and ‘Visitor Management Plan’; these may include:

• AGEL.PROCEDURE.15, “Site Security”, which addresses general site security issues, as well
as appropriate actions to be taken in direct encounters with individuals or groups engaged
in any disturbance or other activities that may occur throughout the project’s life cycle;
• AGEL.POLICY.04, “Stakeholder and Community Engagement Strategy”, which may be
invoked as the means of communicating specific health and safety concerns associated
with Project activities; and

AGEL.PROCEDURE.10, “Recognition and Reporting of Incidents, Illness and Safety Hazards”, which
will include guidance on reporting the proximity of planned activities to indigenous groups, or other
inhabitants or transients encountered in the Project area.
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 8.2.Disclosure of Information
As noted in Section 8.1, AGEL having a comprehensive “Stakeholder and Community
Engagement Strategy” that contains the social management themes reflected in the
January 1, 2012 version of PS 1 (IFC, 2012), including specific requirements for the disclosure
of Project information. Should individuals be directly encountered in the field,
AGEL.PROCEDURE.15, “Site Security” requires that all such contacts be documented and
appropriate hazard avoidance measures are implemented.

8.3. Informed Consultation and Participation

As noted in Section 8.1, AGEL having a comprehensive “Stakeholder and Community
Engagement Strategy” that incorporates the social management themes reflected in PS 1
(IFC, 2012), including specific requirements for informed consultation and participation.
Pursuant to Stakeholder and Community Engagement Strategy/Management Plan
requirements, community information and consultation meetings will be periodically
conducted. Should either community information and consultation meeting or any
community health and safety awareness meetings result in specific concerns or information
requests, they will be documented and referred to management for appropriate follow-up in
accordance with Appendix D, “Stakeholder and Community Engagement Strategy.”

8.4. Indigenous Peoples

As noted in Section 8.1, a comprehensive Stakeholder and Community Engagement
Strategy/Management Plan will be implemented that will incorporate the social
management themes reflected in PS 1 (IFC, 2012). Based on the information provided, it is
unlikely that the requirements of Section 32 of PS 1 (which require obtaining “Free, Prior,
and Informed Consent”) will apply. However, should field encounters result in specific
complaints or information requests, they will be documented and referred to management
for appropriate follow-up in accordance with Appendix D, “Stakeholder and Community
Engagement Strategy.”

8.5. Private Sector Responsibilities under Government-Led Stakeholder engagement

As noted in Section 8.1, if and when found necessary at the end of AGEL, an appropriate
Stakeholders engagement will be planned (in conjunction of the host government or
independently), implemented that will incorporate the relevant management themes
reflected in section 33 of PS 1 (IFC, 2012).

9. External Communications and Grievance Mechanisms

9.1. External Communications
As noted in Section 8.1, a comprehensive Stakeholder and Community Engagement Strategy
will be implemented on sites prior to the start of construction activities. The Stakeholder
and Community Engagement Strategy will be incorporated as per accordance with Appendix
D, “Stakeholder and Community Engagement Strategy.”

Grievance Mechanism to Affected Communities

As also noted in Sections 8.1 and 9.1, a comprehensive Stakeholder and Community
Engagement Strategy will be implemented on every site prior to the start of major
construction activity. The Community Engagement Strategy will incorporate
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 AGEL.PROCEDURE.05, “Grievance Management” for the management of all external
communications with affected communities, including those that constitute actual
grievances.

10. Ongoing Reporting to Affected Communities

As many of the Management Plans discussed in Section 1.2 will not be fully implemented
until AGEL authorizes initiation of construction, renewable energy project’s development
activities, formal reporting to affected communities on the overall effectiveness of the
Management Plans will occur at the end of the first year of
construction/development/operational activities. Reporting requirements will be included
in the Project Stakeholder and Community Engagement Strategy.

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