environmental and social risk management procedures

SSEPL-EHS-01 | Revision: 00

SunSource Energy Environmental and Social Risk Management Procedures

Confidentiality The information contained in these documents is confidential and only for the information of the intended recipient and may not be used, published or redistributed without the prior written consent of SunSource

SunSource Energy | SSEPL-EHS-01 | Revision: 00 P a g e | 2

Risk Assessment Procedure Matrix

Purpose

Risk Assessment provides a structured approach to identify & manage the hazards and risk face during

various project activities. This should be accordance with host country’s law as well. All site activities

are listed & hazards associated with these activities should be identified. They are further evaluated

on 5/5 matrix of Severity & probability as shown below:

Scope

This procedure will be applicable during the design, construction, pre-commissioning, commissioning,

operation and de-commissioning of all projects.

Responsibility

Project Manager and EHS manager will ensure the adequate risk assessment has been done prior to

activity starts and adequate mitigation plan is in place to overcome any of risk.

Risk Matrix 5 X 5

Probability

Rating

Probability

Severity

1 2 3 4 5

Negligible Minor Moderate Major Extreme

5 Almost Certain 5 10 15 20 25

4 Likely 4 8 12 16 25

3 Possible 3 6 9 12 15

2 Unlikely 2 4 6 8 10

1 Rare 1 2 3 4 5



Note - Risk Level Categorization

Risk Rating Color Code Risk Level

20 to 25 Very High

10 to 19 High

4 to 9 Medium

1 to 3 Low

Reference – OHSAS

Host Country’s laws and regulations

In addition to wherever indicated in this document, the host country’s laws and regulations shall be

applicable to the following aspects:

Initial review procedure for environmental and social implication of a project

E&S management systems, framework and interventions in place

Legal obligations with regards to environmental and social assessment

Operating framework of the project in compliance with the E&S guidelines

Allowance to employees and workers to form unions and ensure non-impedance of their rights to

resort to judicial remedy

1.1 Procedures: Environment & Social Risk Management

1.1.1 Resource Efficiency and Pollution Prevention

Purpose

This document contains the procedures SunSource Energy will employ to address the issue of pollution

prevention and abatement on account of its projects or activities to achieve best outcomes

Scope

This procedure will be applicable during the design, construction, pre-commissioning, commissioning,

operation and de-commissioning of all projects & will be accordance with host country’s law as well

Responsibility

In design stage, the design engineer is responsible for ensuring:



Rain water harvesting and ground water recharge is designed and developed as part of project plans

Rain water harvesting and ground water recharge designs are incorporated in the construction drawings, technical specifications and contract documents

In construction phase, the site engineer is responsible for implementation

Site In charge and Safety Supervisor will be responsible for the following activities:

Management of onsite waste generation associated with construction works to help avoid

excessive generation where practicable;

Maintaining of all records of waste type which are construction waste and debris, hazardous

waste;

Liasioning with State Pollution Control Board approved vendors for disposal of hazardous

waste generated;

Renewal and Management of Buy Back Agreements for defunct solar panels with the

Manufacturers;

Demarcation of area within the module area for keeping of segregated wastes;

Labelling of the drums containing hazardous wastes like used oil;

Maintaining of receipts for hazardous waste management records;

Notifying in case of any activity that may generate a large amount of waste to allow

appropriate controls to be put in place to manage waste generated; and

Ensure safe transportation of defunct solar panels as per specified procedures.

Performance Criteria

Site Specific Waste Management Plan;

Rain Water Harvesting Design with pits and water collected;

Recharge of ground water recharge;

Records of water consumption;

Records of monthly generation of hazardous and non-hazardous wastes; and

Energy consumption per MW on monthly basis

Construction Traffic Management Plan-Site Specific

Activities

Water and Waste Water Management

Site supervisor shall inform the Safety Supervisor for water requirements during construction

and operation phase.

Water will be utilized efficiently at construction and operation phase to reduce the amount of

wastewater generation.

Site-In Charge shall take care not to discharge any waste water into any other natural stream

and surrounding land.



It shall be ensured that identified drainage system shall be provided of various types of waste

water streams and shall not be allowed to mix. The various streams of waste water shall be

domestic sewage water, storm water and wash out water generated from cleaning of solar

panels.

Water meter shall be provided at the inlet and outlet of various waste water streams. Records

of water meter readings shall be maintained.

Adequate arrangement for treatment and disposal of waste water shall be carried out.

Domestic sewage shall be treated through septic tank and a soak pit arrangement during

construction phase of the project;

Site in charge of respective project sites shall install water meters in conformity with the

standards laid down by the Indian Standards Institution for the purpose of measuring and

recording the quantity of water consumed. These records shall be maintained for verification

from time to time.

Provision will be made for rain water harvesting during operation phase of the project.

Monitoring of ground water recharge on quarterly basis;

Undertaking quarterly water audit to monitor the water usage and measures to reduce others’

consumption of water from the same resource.

Resource efficiency of the project will be assessed on monthly basis by using checklist.

Following points to be checked before starting the work for drainage for roof top solar projects:

Location, size of the drainage shall be as per the approved drawings.

Inspection chamber pits and pipes shall be as per drawing/specifications.

Sand, water and cement shall be mixed as per the ratio indicated in drawing & specification.

Joints shall be done as per drawing/specification.

Drainage shall be water tight.

Water should not have logged in the drainage.

Proper slope of the drainage shall be ensured.

If gratings are provided it shall be as approved specifications.

1.1.2 Solid Waste Management

Type of waste generated

The waste will generate from construction activities like site clearing, levelling etc. Other categories

of waste will be produced daily and comprise of the following:

Scrap metal;

Soil waste;

Food waste from kitchen premises of labour camps;

Construction debris; and

Sewage from temporary toilets;



The construction and decommissioning phases will require the use of hazardous materials such as

diesel or petrol to cater the fuel equipment and vehicles and maintain equipment. The following

hazardous wastes will also be produced from construction activities.

Oily rags;

Used oil and oil filters - from generators or vehicle maintenance; and

Scrap and packaging material.

Operations and maintenance of the PV power facility is not expected to generate any significant

amount of waste. PV panels, array enclosures and inverter/transformer enclosures will not produce

waste during operation except the following:

Defunct solar panels;

Broken solar panels generated during cleaning and other maintenance activities;

Fuel requirements like greasing, transformer oil etc.

Used oil; and

Oily rags

Waste Handling and Hazardous Material Management

Fuel will be stored on site in temporary aboveground storage tanks and will be stored in

a locked container within a fenced and secure temporary staging area;

Trucks and construction vehicles will be serviced off site;

All concrete mixing be undertaken on impermeable plastic lining to prevent

contamination of the soils and surrounding areas;

Food waste and other refuse are to be adequately deposited in sealable containers and

removed from the kitchen frequently to avoid accumulation;

The use, storage, transport and disposal of hazardous materials used for the project will

be carried out in accordance with all applicable regulations;

All hazardous waste to be disposed off to SPCB approved vendors;

Material Safety Data Sheets for all applicable materials present on site will be readily

available to on-site personnel;

All construction debris will be placed in appropriate on-site storage containers and

periodically disposed of by a licensed waste contractor;

The construction contractor will remove refuse collected from the designated waste

storage areas at the site at least once a week;

It is proposed that the Module Developer will supply the required temporary ablution

facilities and be responsible for the removal and treatment thereof; and

Empty fuel containers will also be stored at a secured area designated for scrap and sold

to authorized vendors. All packaging material will also be collected at the storage area

and sold to scrap dealers.



A designated area needs to be demarcated within the module premises for storage of

defunct and broken solar panels with restricted access and on impervious surface during

operation phase;

All fuel storage should be equipped with secondary containment and spillage trays;

It is to be ensured that authorization for hazardous waste storage and generation has

been taken from SPCB;

All used oil is required to send off to SPCB approved vendors and recyclers; and

Transportation of defunct solar panels is required to be undertaken as per the procedures

specified by the Manufacture of Solar Panels.

1.1.3 Air Emission Management

Sprinkling of water is to be carried out to suppress dust from construction, stock piles and

transport movement.

Stock piles are covered and storage areas provided with enclosures.

Stock piling and storage of construction material will be oriented after considering the

predominant wind direction.

Open burning of solid waste or packaging material will be strictly prohibited.

Vehicles engaged for the project will be required to obtain “Pollution under Control”

(PUC) certificates.

Sufficient stack height needs to be provided to D.G. sets as per CPCB norms;

SunSource shall take all the possible measures to avoid all kind of emission from

transportation and transportation shall be carried out in covered vehicles.

SunSource is required to document reduction in Green House Gas Emissions due to each

project and same is required to be documented at corporate level.

1.1.4 Noise Emission Management

Noise Level Monitoring (part of quarterly monitoring)

Safety Supervisor will identify measure and record the noise level at various locations of site.

Minimize noise exposure of personnel by Engineering and Administrative Controls or by

providing proper PPE.

Noise level for continuous 8hrs exposure shall not exceed 85 (dB)A in day time and 80 (dB)A

in night time;

The frequency of noise level monitoring shall be at least once in every three months at every

project site;

If required, necessary support shall be provided by concerned safety officer for monitoring

and control the noise level at site.



1.1.5 Traffic Management

Safety Supervisor will finalize the transport route for transportation of raw materials and solar

panels;

The proposed site will provide sufficient areas for car parking, ensuring that the movement of

private vehicles is segregated from construction and delivery vehicles;

During site constructions security guards will be on site 24/7 to support the site management

in traffic management and vehicle control;

Drivers will be properly instructed on vehicle speed, traffic sign and its meaning and parking

space allocated within site;

Additional and temporary parking areas may need to be added during the peak period within

the site;

Safety Supervisor will document a ‘Construction Traffic Management Plan’ detailing

construction vehicles, details of roads, traffic routes to be taken and detailed instructions to

be provided to the vehicle operator.

Record Keeping/ Outcome

Monthly Waste Records

Monthly Water records

Details of harvested rain water utilized on monthly basis

Quarterly audit report

Documented Annexure III: Resource Efficiency and Pollution Prevention

Reference

Hazardous Waste Authorization (hazardous Waste Management Rules, 2016)



2. Procedures: Social Risk Management

2.1 Land Acquisition and Involuntary Resettlement

Purpose

To purchase or acquire land as per the legal and statutory requirements of state, applicable land/ solar

policy, governing land procurement in India in a free, fair and transparent manner.

Scope

The procedure covers the procedures for land identification and screening of the land parcel during

site selection and on Land acquisition and Involuntary Resettlement on - Indigenous Peoples. Since

Indigenous Peoples may be particularly vulnerable to the loss of, alienation from, or exploitation of

their land and access to natural and cultural resources, the SunSource requires the Client to engage in

FPICon with the affected Indigenous Peoples if activities under the Project would: (a) have impacts on

land and natural resources subject to traditional ownership or under customary occupation or use; (b)

cause relocation of Indigenous Peoples from land and natural resources subject to traditional

ownership or under customary occupation or use; or (c) have significant impacts on Indigenous

Peoples’ cultural heritage. In these circumstances, the SunSource requires the Client to engage

suitably qualified and experienced independent experts to assist in the identification of these

activities’ risks to and impacts on Indigenous Peoples. This will be as per host country’s law as well.

Responsibility

Social/Admin Officer, Social Manager& Head Execution: Solar Farm

Identification of suitable land parcels for the different types of projects post technical assessment

carried out by the project team;

Due diligence of title & obtaining necessary sanctions/approvals related to procurement of subject

land & minimizing the risk factor;

Liaison with local bodies and authorities as and when required;


Land Procurement process

Site selection

Assessment of site through land screening checklist

Activities

The broad steps to be followed in land procurement for a typical Solar Utility Scale Project are:

Land identification and assessment of site from solar radiation;

Collection of Forest Boundary Maps/Village Maps and Revenue records;

Assessment of liability of any livelihood restoration or involuntary resettlement, if any;



Inform the village Panchayat and /or Gram Sabha about the process of taking possession and

the GR process

Negotiation and Price Fixation;

Disbursement of compensation

Verification of documents-aggregator;

Purchase of land;

Clear title report;

Sale deed in name of SunSource Energy;

The management will issue a land screening report based on the assessment of the broad points as

follows:

Land Identification Procedure

HOD-PROJECT & EHS should ensure that land for the project is finalized after going through the

following procedures:

Identification of land need and mapping of property;

Assessment of land and site inspection;

Stakeholder Consultations;

Identification of site and its mapping

After selection of land based on solar irradiation data, the management will identify the type

of land; whether it is revenue land/ private land/forest land/ government land;

For revenue land, all the land records are required to be checked by engaging a third party

consultant. The applicability of land purchase policy will be assessed which has been rolled

out by different states in order to acquire private land only for infrastructural projects in the

State in consensus with the land owners (title holder);

The title holders of the land will be verified;

For private land, the land shall be screened for presence of indigenous people.

SunSource is required to ensure that resettlement undertaken on their behalf meets host

country’s laws.

SunSource will take an active role during the preparation, implementation and monitoring of

the process of disbursement of compensation in case of application of land consent policy and

should coordinate with the relevant government authorities those aspects of the process that

can be facilitated more efficiently;

Assessment of Land and site inspection

SunSource Energy will only follow the principal of ‘willing buyer-willing seller’ for purchase of

private land;



The following conditions should apply for deciding the compensation for land parcel to be

acquired

o Land markets or other opportunities for the productive investment of the sales income

exist;

o The transaction took place with the seller’s informed consent; and

o The seller was provided with fair compensation based on prevailing market values.

o Compensation to be decided with due regards to host country’s laws

Compensation for land and other assets should be calculated at the market value plus the

transaction costs related to restoring the assets;

SunSource will avoid the engagement of third party brokers, land consolidators, aggregators

and will ensure fair property transactions;

SunSource Energy will avoid forest lands, forest buffer lands, coastal lands subjected to CRZ

regulations, wetlands, productive farm lands (farm lands that are used for more than one

cropping season in a year), lands with physical encumbrances, lands prohibited by

central/state/local regulations, lands belonging to indigenous peoples (Scheduled Tribes) and

vulnerable community (scheduled castes and others). As a principle, SunSource Energy will

prefer waste scrub lands, barren lands and lands that were not used/ not fit to be used for

any other purpose over any other lands in an order of precedence.

SunSource will ensure no force eviction of land has been made.

Land sellers/their family members will be offered employment opportunities only if found

eligible and feasible. If the land seller is: women heading the family, widow, vulnerable

community member, landless person etc. SunSource Energy will prioritize any employment

opportunity, if available, to these groups over others.

For government land, land procurement and associated compensation will be paid on

verification of title holder and receipt of consent;

In case of any objection raised during notification period (of fifteen days) by any land owner

(dispute on the ownership), the District Collector would not acquire the land;

SunSource should collaborate with local government authorities in the distribution of

compensation payments. Those eligible for compensation should be given advance notice of

the date, time and place of payments via public announcement. Receipts should be signed by

all those receiving compensation payments and retained for auditing purposes;

Site will be inspected for presence of any household, presence of any natural drain, or loss of

access to common property resource;

Certificate of conversion of land for non-agricultural use of the proposed land as per Section

109 of Land Reforms Act.

The private land shall be procured within the framework of “The Right to Fair Compensation

and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013” (LA Act

2013) and the state policies on procurement of private land.



Stakeholder Consultations

SunSource Energy should identify and consult with individuals and communities that will be

displaced by land acquisition and/or restrictions on land use as well as host communities who

will receive those who are resettled, to obtain adequate information about land titles, claims,

and use.

It will be ensured during consultations that all land owners have provided their consent

voluntarily and have not done so under any force or pressure and al cases of ‘no consent’ will

be bring under notice for applicability of Land purchase policy;

Various Mitigation Plans

Mitigation plans to address the impacts associated with land procurement and acquisitions in line.

Restoration Resettlement Plan

Solar power project requires large parcels of land for placement of panels which can lead to physical

and economic displacement. Resettlement is involuntary when it occurs without the informed consent

of the displaced persons or, if they give their consent, without having the power to refuse

resettlement. Following steps are required to be followed in case of involuntary resettlement:

Clear possession of land;

Obtain permission for setting of Solar Project;

Sites that would require physical displacement (relocation of residences) should be avoided

wherever possible; site selection should furthermore aim to avoid or minimize economic

displacement (e.g. loss of croplands, businesses or other livelihood sources);

Project-related eviction should conform to host country’s laws and be conducted in a manner

consistent with the objectives of this Performance Standard in case of unavoidable

resettlement;

Compensation for lost land and assets should be paid prior to the client taking possession of

this land or assets and where possible people should have been resettled at their new sites

and moving allowances paid to them;

Compensation for land and other assets should be calculated at the market value plus the

transaction costs related to restoring the assets; and

A Resettlement Action Plan should be prepared for any project that results in physical

Displacement i.e., projects that involve the relocation of people from their homes.

Projects that entail land acquisition and leads to economic displacement of people, a Livelihood

Restoration Plan is required to be prepared.

Outline of a Resettlement Action Plan

An action plan will be formulated to meet the requirements.

Description of the project: General description of the project and identification of the project

area.



Potential impacts: Identification of

o The project component or activities that give rise to resettlement;

o The zone of impact of such component or activities;

o The alternatives considered to avoid or minimize resettlement; and

o The mechanisms established to minimize resettlement, to the extent possible, during

project implementation.

Objectives and studies undertaken: The main objectives of the resettlement program and a

summary of studies undertaken in support of resettlement planning / implementation, e.g.,

census surveys, socio-economic studies, meetings, site selection studies, grievance

mechanism, E&S exclusion list, E&S risk management, initial review of E&S implication of

project, E&S management systems and interventions in place, application of FPIC (Free Prior

Informed Consent) of indigenous people, legal obligations with regards to environmental and

social assessment, project operation, proximity to conserved / protect area.

Regulatory framework: Relevant laws of the host country, client policies and procedures,

performance standards.

Institutional framework: Political structure, NGOs.

Stakeholder engagement: Summary of public consultation and disclosure associated with

resettlement planning, including engagement with affected households, local and/or national

authorities, relevant CBOs and NGOs and other identified stakeholders, including host

communities. This should include, at a minimum, a list of key stakeholders identified, the

process followed (meetings, focus groups etc), issues raised, responses provided, significant

grievances (if any) and plan for ongoing engagement throughout the resettlement

implementation process.

Socioeconomic characteristics: The findings of socioeconomic studies to be conducted in the

early stages of project preparation and with the involvement of potentially displaced people,

including results of household and census survey, information on vulnerable groups,

information on livelihoods and standards of living, land tenure and transfer systems, use of

natural resources, patterns of social interaction, social services and public infrastructure.

Eligibility: Definition of displaced persons and criteria for determining their eligibility for

compensation and other resettlement assistance, including relevant cut-off dates.

Valuation of and compensation for losses: The methodology used in valuing losses to

determine their replacement cost; and a description of the proposed types and levels of

compensation under host country’s law and such supplementary measures as are necessary

to achieve replacement cost for lost assets.

Magnitude of displacement: Summary of the numbers of persons, households, structures,

public buildings, businesses, croplands, churches, etc., to be affected.

Entitlement framework: Showing all categories of affected persons and what options they

were/are being offered, preferably summarized in tabular form.

Livelihood restoration measures: The various measures to be used to improve or restore

livelihoods



Resettlement sites: Including site selection, site preparation, and relocation, alternative

relocation sites considered and explanation of those selected impacts on host communities.

Housing, infrastructure, and social services: Plans to provide (or to finance resettles'

provision of housing, infrastructure (e.g., water supply, feeder roads), and social services (e.g.,

schools, health services); plans to ensure comparable services to host populations; any

necessary site development, engineering, and architectural designs for these facilities.

Grievance procedures: Affordable and accessible procedures for third-party settlement of

disputes arising from resettlement; such grievance mechanisms should take into account the

availability of judicial recourse and community and traditional dispute settlement

mechanisms.

Organizational responsibilities: The organizational framework for implementing

resettlement, including identification of agencies responsible for delivery of resettlement

measures and provision of services; arrangements to ensure appropriate coordination

between agencies and jurisdictions involved in implementation; and any measures (including

technical assistance) needed to strengthen the implementing agencies' capacity to design and

carry out resettlement activities; provisions for the transfer to local authorities or resettles

themselves of responsibility for managing facilities and services provided under the project

and for transferring other such responsibilities from the resettlement implementing agencies,

when appropriate.

Implementation schedule: An implementation schedule covering all resettlement activities

from preparation through implementation, including target dates for the achievement of

expected benefits to resettles and hosts, and implementing the various forms of assistance.

The schedule should indicate how the resettlement activities are linked to the implementation

of the overall project.

Costs and budget: Tables showing itemized cost estimates for all resettlement activities,

including allowances for inflation, population growth, and other contingencies; timetables for

expenditures; sources of funds; and arrangements for timely flow of funds, and funding for

resettlement, if any, in areas outside the jurisdiction of the implementing agencies.

Monitoring, evaluation and reporting: Arrangements for monitoring of resettlement

activities by the implementing agency, supplemented by independent monitors to ensure

complete and objective information; performance monitoring indicators to measure inputs,

outputs, and outcomes for resettlement activities; involvement of the displaced persons in

the monitoring process; evaluation of the impact of resettlement for a reasonable period after

all resettlement and related development activities have been completed; using the results of

resettlement monitoring to guide subsequent implementation

Livelihood Restoration Plan

A major challenge associated with urban resettlement is the restoration of wage-based or enterprise-

based livelihoods that are often tied to location (such as proximity to jobs, customers and markets).

Compensation for economic displacement resulting from land acquisition will be made promptly in



order to minimize adverse impacts on the income stream of those who are displaced. In cases where

land acquisition affects commercial structures, affected business owners will be provided:

the costs of re-establishing commercial activities elsewhere;

the net income lost during the transition period; and

The costs of transferring and reinstalling plant, machinery, or other equipment.

The Resettlement and/or Livelihood Restoration Plan will provide a clear indication as to how directly

affected households and communities (including host communities) will be involved in an ongoing

process of organized, iterative consultation throughout the process of resettlement planning,

implementation and monitoring.

Outline of a Livelihood Restoration Plan

Description of the project: General description of the project and identification of the project

area.

Aim and Objectives: Detail the aim of preparation of LRP and need to provide livelihood

restoration options for the people affected by land acquisition as a result of upcoming project.

Specify objectives which include identification of feasible livelihood restoration options,

alternative economic activities and implementation schedule for activities and programms.

Identification of Project Affected Population and Assets: this section will describe people

who have been affected by the land acquisition for the project. Land acquisition in a project

might lead to displacement for the local communities. Physical displacement is defined as the

actual physical relocation of people resulting in a loss of shelter, productive assets or access

to productive assets (such as land, water, and forests) whereas the economic displacement

refers to an action that interrupts or eliminates peoples’ access to productive assets without

physically relocating the people themselves.

Legal Framework for acquisition of land and compensation process: This section will provide

the legal background and legislative process with respect to land acquisition and displacement

occurred due to the project. The section will commence with a framework of the national

legislation relevant to the Project, with specific reference to the key sections of each law that

is applicable. A summary is then will be provided on land acquisition and compensation policy

and procedure.

Assessment of Potential Impacts: During Construction and Operation Phase:

o During construction, involuntary resettlement, possibly leading to economic

displacement may occur during construction for the following categories of people:

o Persons who are using the land plots which have been or will be acquired for the

project, but who are not owners of land, and whose crops may be affected by

construction.

o Detail an entitlement matrix explaining affected persons, Number of affected

properties / households / amount of affected land and entitlement assigned to them

by SunSource Energy. It can be Cash compensation for all affected crops at full



replacement cost, Reinstatement of land and Livelihood restoration assistance, in

case compensation alone is not sufficient to enable them to restore their livelihoods.

o During Operation phase, there will be minimal or no economic displacement.

Description of Mitigation Measures and Entitlements: Provide a description of certain

measures to mitigate land acquisition related impacts. Timely information to users of land of

when construction is planned to begin and consult and agree with them on the process by

which lost crops and damages will be compensated (e.g. valuation of affected crops, location

of offices where affected people will be able to submit their requests, payment of cash

compensation to their SunSource accounts, etc.)

Stakeholder Engagement: Regular and on-going engagement with stakeholders is a key to

effective livelihood restoration planning and implementation. SunSource Energy will directly

engage with the affected people and other key stakeholders or engage a third party. A full list

of affected stakeholders identified which includes information on their associated roles and

responsibilities in relation to the Project, and specifically, land acquisition and economic

displacement will be furnished.

o SunSource Energy is required to ensure that affected people understand the land

acquisition procedures and know what to expect at the various stages of the

transaction (e.g., when an offer will be made to them, how long they will have to

respond, grievance mechanism, legal procedures to be followed if negotiations fail).

Grievance procedures: Affordable and accessible procedures for third-party settlement of

disputes arising from economic displacement; such grievance mechanisms should take into

account the availability of judicial recourse and community and traditional dispute settlement

mechanisms. SunSource Energy keep a grievance log of all Project related grievances, clearly

marking those related to land acquisition to enable monitoring of this process.

Institutional Arrangements: An institutional framework will be designed as the interface for

all stakeholders involved in LRP implementation, allowing for close cooperation between

SunSource Energy on behalf of a third party, if any, implementing agencies, the land affected

people and the local community at large around the proposed project.

Monitoring and Reporting: Outlining key performance indicators and frequency of

measurement for disbursement of compensation and livelihood restoration measures that

have been implemented will be developed and regularly updated. SunSource Energy will

generate reports on the progress achieved with the implementation of the LRP. These reports

will consolidate the information on compensation and livelihood restoration measures,

consultations measures, information on negotiations and results, provision of assistance to

vulnerable groups, grievance management, etc. Independent third party compliance

monitoring will also be carried out to check the compliance of implementation of

compensation and livelihood restoration.

Budget and Costing: A summary of the LRP budget including land acquisition and

compensation for loss of assets as well as livelihood restoration activities will be provided. The

budget line items will be organized in capital cost items and operational cost items.



Over and above E&S exclusion list, E&S risk management, initial review of E&S implication of

project, E&S management systems and interventions in place, application of FPIC (Free Prior

Informed Consent) of indigenous people, legal obligations with regards to environmental and

social assessment, project operation, proximity to conserved / protected area, child labor /

forced labor, employment rules, workers union allowance, non-impedance to judicial remedy

by project stakeholders, hiring conduct equipment and training of security personnel.

Reporting

SunSource Energy will commission an external completion audit of the Resettlement Action

Plan/ Income and Livelihood Restoration Plan to determine that the provisions of the Plan are

met.

SunSource Energy will retain qualified and experienced external experts (those not involved

in day to day implementation or supervision) or qualified NGOs to verify monitoring

information for projects with significant impacts and risks.

SunSource Energy will prepare semi-annual monitoring reports that describe the progress of

the implementation of resettlement activities and any compliance issues and corrective

actions, with the involuntary resettlement monitoring indicators agreed at the time of

approval of RAP.


A land screening report

A resettlement Action plan with Cost Estimate sheet for Replacement Cost

A livelihood Action Plan

Third Party LRP/RAP Completion Audit

Minutes of Meeting with Stakeholders

E&S risk management

initial review of E&S implication of project

E&S management systems and interventions

legal obligations with regards to environmental and social assessment if any

Reference

Procedure on Site Screening

Environment and Social Impact Assessment (ESIA) undertaken for project

Management Plans - including RA possibly RAP. LRP, SEP, IPP and Grievance Redressel procedure



2.2 Chance Find Procedure

Purpose

These procedures help in conserving physical cultural resources and promoting the equitable sharing

of benefits from the use of cultural heritage in business activities whilst screening impacts and risks

associated with environmental and social aspects due to project activities.

Scope

This procedure is applicable to all Projects managed by SunSource & will be accordance with host

country’s law as well

Responsibility

Social Manager: The Social Head both at the corporate level and at site level shall conform to

below procedures post discussions with the Project Head and corporate heads, in case any

chance find has been ascertained during construction/O&M stage of the plant. He/she is

required to adhere to host country’s laws and intimate pertinent government officials as

prescribed by legal requirements. The social head is required to brief the Project head on

actions taken to address chance find incidents.

Admin/Liaison officer: The Admin Officer is required to assess social risks concerning physical

cultural resources that may be encountered for ongoing project activities, address the same

as per measures prescribed procedures presented below and report the same to the Social

Head for further action.


Stakeholder analysis

Grievances received

Disclosure of information

Activities

The environmental and social risks and impacts identification process should determine

whether the proposed location of project activity is in areas where cultural heritage is

expected to be found, either during construction or operation phases.

Suspension of Work: The initial procedure when such sites are found aim to avoid any further

damage. The following steps and reporting structure must be observed in both instances:

o The person or group (identifier) who identified or exposed the burial ground must

cease all activity in the immediate vicinity of the site;

o The identifier must immediately inform his/her supervisor of the discovery;

o Admin-liaison Officer/ Social Manager must ensure that the site is secured and control

access; and



o Admin-liaison Officer/ Social Manager must then inform the relevant local authority

and called immediately;

The procedure typically requires chance finds not to be disturbed until an assessment by a

competent expert is made and avoidance, minimization or mitigating measures are

developed.

Consultation: If a project affects any cultural heritage, the Social Officer shall consult with

Affected Communities who use, or have used within living memory, the cultural heritage for

long standing cultural purposes. The Social Officer through consultations will identify cultural

heritage of importance, and incorporate into the community’s views while reporting the same

to the Social Head.

Consultation will also extend to involvement of the relevant national or local regulatory

agencies that are entrusted with the protection of cultural heritage. A report on the same will

be submitted to the Social Head regarding ‘chance find’;

Legally protected cultural heritage areas are important for the protection and conservation of

cultural heritage, and additional measures are needed for any projects that would be

permitted under the applicable host country’s law in these areas.

In circumstances where a proposed project is located within a legally protected area or a

legally defined buffer zone, ESMS implementation committee, shall meet the following

requirements:

o Comply with defined national or local cultural heritage regulations or the protected

area management plans;

o Consult the protected area sponsors and managers, local communities and other key

stakeholders on the proposed project; and

o Implement additional programs, as appropriate, to promote and enhance the

conservation aims of the protected area.

Community access: When any of project site contain cultural heritage or prevents the access

to previously accessible cultural heritage sites being used by Affected Communities, ESMU

shall allow continued access to the cultural sites or provide an alternative access route, subject

to overriding health, safety and security considerations;

Whenever ESMS implementation committee encounters tangible cultural heritage that is

replicable and not critical, it will apply mitigation measures that favour avoidance;

Most cultural heritage is best protected by preservation in its place, since removal is likely to

result in irreparable damage or destruction of the cultural heritage. shall not remove any non-

replicable cultural heritage, unless:

o There are no technically or financially feasible alternatives for removal;

o The overall benefits of the project conclusively outweigh the anticipated cultural

heritage loss from removal;

o Any removal of cultural heritage is conducted using the best available technique.

Once the report on ‘chance find’ is submitted to the Social Head, the Social Head will assess

the situation and accordingly brief the Project head of the same. The Social Head shall be



responsible to inform the local authorities of the chance find and brief the project team at the

site level of the outcome. Once the situation has been settled, the Social Officer is to submit

a report on the proceedings and outcome of the situation to the Social Head for

documentation purpose;

The Social Head shall monitor the progress of implementation of the Chance Find Procedure

by the Admin officer; and

A Chance Find Report highlighting the siting of chance find shall be submitted by the Admin

Officer to the Social Head. Reporting formats as presented in appendices below shall be used

by the Social Head. It should comprise of following:

o Location of the discovery;

o Description of the heritage found;

o Estimated weight and dimensions;

o Temporary protection implemented.

Relevant findings will be recorded in Annual Monitoring Report and Implementation

Completion Reports (ICRs) of the procedure will assess the overall effectiveness of the

project’s cultural property mitigation, management, and activities, as appropriate.

Further Suspension of Work During this 7-day period, the local authority may be entitled to

request the temporary suspension of the work at or in the vicinity of the discovery site for an

additional period of up to, for example, 30 days.


Chance Find Report



2.3 Labour & Working Conditions and Community Health and Safety

Purpose

This document contains the procedures which SunSource Energy will employ to address the

requirements of Labor and Working Conditions and health and safety for its projects or activities to

achieve outcomes.

Scope

This procedure will be applicable for construction, pre-commissioning, commissioning, operation and

de-commissioning of a project & will be accordance with host country’s law as well

Responsibility

Safety Supervisor and Admin Officer of SunSource Energy will review the quality of campsite and the

facilities provided by the contractors during the construction and establishment of campsite. Survey

of campsite will be undertaken to understand the status of various facilities, record of workers and

hygiene.


Coverage of labour issues in project specific ESMP;

Adherence to ESMP,

External an internal monitoring reports

Accordance with host country’s law if any

Activities

Safe Working Conditions and Health & Safety of community. Assess labor and working conditions of Project workers & health and safety risks to local communities in the area of the Project. Implement measures should be made to ensure Project workers have safe and healthy working conditions, as well put in place measures to prevent accidents, injuries, and disease caused by the Project. Ensure the relevant occupational health and safety provisions of global recognized standards, such as the EHSGs and, as appropriate, industry-specific EHSGs, to the Project. Document and report on accidents, diseases and incidents. Ensure preventive and emergency preparedness and response measures to avoid, or where avoidance is not possible, minimize adverse risks and impacts of the Project on the health and safety of local communities.

Child Labor and Forced Labor. To protect children from jeopardy to their health, safety or morals, ensure that children under the age of 18 should not be employed for work under the Project. However, if the host country’s laws or regulations of the country in which the Project is located provide, in conformity with the International Labour Organization’s Minimum Age Convention, 1973, that children at least 16 years of age may be employed for such work on condition that their health, safety and morals are fully protected and that they have went through adequate specific instruction or Job Specific training in the relevant of activity, such children may be employed, but only in conformity with these laws and regulations. In such cases of employment of children under the age of 18 under the Project, conduct an appropriate risk assessment, together with regular monitoring, of their health, safety, working



conditions and hours of work. Ensure that, in connection with the Project, there is no work or service not voluntarily performed that is exacted from an individual under threat of force or penalty (including any kind of forced or compulsory labour, such as indentured labour, bonded labour or similar labor-contracting arrangements, or labour by trafficked persons)

Labor Management Relationships in Private Sector Projects. While doing work in private sector Projects, ensure that a labor management system for Project workers, which includes the following, is in place for the Project, consistent and relevant with host country’s law:

(1) Specific and written terms of employment made available to Project workers in an accessible manner; (2) Timely payment for Project work; (3) adequate rest duration; (4) Notice of termination should be given timely of the working relationship; (5)Ensure Employment on the basis of the principle of equal opportunity, fair treatment and non-discrimination; (6) compliance with host country’s law relating to workers’ organizations and collective bargaining; (7) An adequate grievance mechanism for raising Project workplace concerns that: (a) does not impede access to other judicial or administrative remedies that might be available under law or through existing arbitration or mediation procedures, or substitute for grievance mechanisms provided through workers unions or collective agreements; (b) involves an goof level of management and addresses concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned, without any delay; and (c) Ensure confidential complaints to be raised and addressed; and (d) Ensure suitable system designed to inform Project workers of the grievance mechanism at the time of hiring, and make it easily accessible to them.

Workplace Safety. When the Project includes new buildings and structures that will be accessed by members of the public, consider the incremental risks of the public’s potential exposure to operational accidents or natural hazards, including extreme weather events. Where technically and financially feasible, apply the principles of universal access to the design and construction of such new buildings and structures.

Road Safety. Ensure Identification, evaluation and monitoring of traffic and road safety risks to Project workers and affected communities throughout the Project life-cycle, develop measures and plans to address them, and incorporate technically and financially feasible road safety components into Project design, where applicable, to prevent and mitigate potential road safety impacts to the surrounding communities. If the Project involves operating construction and other moving equipment on public roads or if the use of Project equipment could have an impact on public roads or other public infrastructure, implement measures to avoid the occurrence of incidents and injuries to the public associated with the operation of such equipment. Undertake a road safety audit and implement measures to address identified risks and impacts wherever is feasible. Ensure road safety training to Project workers on

driver and vehicle safety, and ensure regular maintenance of all Project vehicles (owned or

leased).

Security Personnel. In the process where Project workers are assigned to provide security to safeguard the Client’s personnel and property (Project security persons), assess risks posed by these security arrangements to persons within and outside the Project site. During making such arrangements, apply the principles of proportionality and good international practice, and comply with applicable law relating to hiring, rules of conduct, training, equipping, and monitoring of Project security workers. Ensure Implementation of measures designed to Project security workers limit their security actions exclusively to preventive and defensive purposes, in proportion to the nature and extent of the threat. The Client may disclose



security arrangements for the Client’s facilities to the public, subject to overriding security concerns.

Ensure reasonable inquiries has been done to ensure that Project security workers are not implicated in past abuses; train them adequately (or ensure that they were properly trained) in carrying out of security actions, and appropriate conduct toward Project workers and affected communities; and require them to act within the applicable law. Review all allegations of unlawful or abusive acts of Project security workers, take appropriate action to prevent recurrence and, where necessary, report unlawful acts to the relevant authorities.

Setting up of labour camp

The contractor will work out arrangements for setting up his facilities during the duration of

construction and share the following information with SunSource Energy:

Activities to be carried out in the site;

Environmental mitigation measures to be undertaken to prevent land, air, water and noise

pollution;

Detailed layout plan for development of the construction and labour camp that shall indicate

the various structures to be constructed in the camp including temporary, drainage and other

facilities

The arrangements will be verified by SunSource Energy through implementation of labour camp

inspection checklist.

Capability

The contractor shall have the following members in his team:

An administrative/ HR person

An identified campsite manager/in charge

Registration

The consultant shall have registration under the Building and Construction Workers Act and License

under the Contract Labour (Regulation and. Abolition) Act, 1970.

Facilities for workers

The housing standards to be provided for the labour camp as per ILO Worker’s housing requirements

delineated in Paragraph 19 of the General Principles should relate in particular to--

The minimum space per person or per family as expressed in terms of one or more of the

following, due regard being had to the need for rooms of reasonable dimensions and

proportions:

floor area;

cubic volume; or



size and number of rooms;

The supply of safe water in the workers' dwelling in such ample quantities as to provide for all

personal and household uses;

Adequate sewage and garbage disposal systems;

Appropriate protection against heat, cold, damp, noise, fire, and disease-carrying animals,

and, in particular, insects;

Adequate sanitary and washing facilities, ventilation, cooking and storage facilities and natural

and artificial lighting;

A minimum degree of privacy both--

o as between individual persons within the household; and

o for the members of the household against undue disturbance by external factors; and

Where housing accommodation for single workers or workers separated from their families is

collective, the competent authority should establish housing standards providing, as a

minimum, for--

a separate bed for each worker;

separate accommodation of the sexes;

adequate supply of safe water;

adequate drainage and sanitary conveniences;

adequate ventilation and, where appropriate, heating; and

Common dining rooms, canteens, rest and recreation rooms and health

facilities, where not otherwise available in the community.

The contractor shall provide free of cost in the camp site, temporary living accommodation to all the

migrant workers employed by him for complete construction/maintenance work is in progress. A

minimum area of 4m2 per person shall be provided. The rooms of labour shall be well lighted and

ventilated.

Drinking Water

The contractor shall provide for a continuous and sufficient supply of potable water in the camps. The

contractor shall identify suitable community water sources for drinking.

Washing and Bathing Facilities

In every site, adequate and suitable facilities for washing clothes and utensils shall be provided and

maintained for the use of contract labour employed therein. Separate and adequate bathing shall be

provided for the use of male and female workers. Such facilities shall be conveniently accessible and

shall be kept in clean and hygienic conditions.

Toilets Facilities

Sanitary arrangements, latrines and urinals shall be provided in every work place separately for male

and female workers. The arrangements shall include:



A latrine for every 15 females or part thereof (where female workers are employed).

A latrine for every 10 males.

Every latrine shall be under cover and so partitioned as to secure privacy, and shall have a proper door

and fastenings. Where workers of both sexes are employed, there shall be displayed outside each

block of latrine and urinal, a notice in the language understood by the majority of the workers “For

Men Only” or “For Women Only” as the case may be.

Medical and First Aid Facilities

Medical facilities shall be provided to the labour at the construction camp. A separate room for

medical check-ups and keeping of first aid facilities should be built. The site medical room should

display awareness posters on safety facilitation hygiene. First Aid Box will be provided at construction

campsite and under the charge of a responsible person who shall always be readily available during

working hours. He shall be adequately trained in administering first aid-treatment. Formal

arrangement shall be prescribed to carry injured person or person suddenly taken ill to the nearest

hospital. The first aid box shall contain the following or as per host country’s law and guidelines as

well

6 small sterilized dressings

3 medium size sterilized dressings

3 large size sterilized dressings

3 large sterilized burns dressings

1 (30 ml) bottle containing 2 % alcoholic solution of iodine

1 (30 ml) bottle containing salvolatile

1 snakebite lancet

1 (30 gms) bottle of potassium permanganate crystals

1 pair scissors

Ointment for burns

A bottle of suitable surgical antiseptic solution

In case, the number of labour exceeds 50, the items in the first aid box shall be doubled.

Provision of Shelter for Rest

The work place shall provide four suitable sheds, two for meals and two for rest (separately for men

and women). The height of the shelter shall not be less than 3.0m from the floor level to the lowest

part of the roof. These shall be kept clean.



Record Keeping (Leave/Wages/etc)

To ensure that there is no conflict of the migrant labour with the host communities, the contractor

shall issue identity cards to labourers and residents of construction camps. Also the following register

shall be maintained by contractor:

Register for Overtime

Name of building worker

Father’s/ Husband’s name

Sex

Designation/ Nature of Employment

Date on which overtime worked

Total hours of overtime worked

Normal rates of wages

Overtime rate of wages

Overtime earnings

Date on which overtime wages paid

Remarks if any

Register of Wages

Name of workers

Designation/Nature of work done

No. of days worked

Daily rate of wages

Basic wages

Dearness allowances

Overtime Others

Other cash payments (nature of payment to be indicated)

Total Deductions, if any (indicate nature)

Net amount paid

Register for Advances

Name of worker

Father’s/Husband’s name

Designation/ Nature of employment

Wages period and wages payable

Date and amount of advance given

Purpose(s) for which advance given



No. of instalments by which advance to be repaid

Date and amount of each instalment to be repaid

Date on which last instalment was repaid

Remarks

Wage Book

No. of days worked –

No. of units worked in case of piece rated workers –

Rate of daily/monthly wages/ piece rate –

Amount of overtime wages –

Gross wages payable –

Deductions, if any, on account of the following:

o fines:

o damage or loss:

o loans and advances:

o subscription towards provident fund:

o subscription towards the Building Workers Welfare Fund

o any other deductions e.g. subscription to co-operative society or

account of loans from co-operative society/housing loan or contribution to any relief fund as

per

Provisions of clauses of the Payment of Wages Act or for payment of any premium of Life

Insurance Corporation.

Net amount of wages paid

Trainings

The construction contractor will assign an in charge for the campsite, who will ensure proper facility

to the workers, delivery of welfare measures and documentation of wages.

The campsite in charge will be trained/ have previous experience in:

Handling and managing labour camp

Labour related laws and issues

Communication

The construction contractor shall communicate the status of campsite and facilities at site to

SunSource Energy on a monthly basis. Any issue of significance which can lead to stoppage or delay of

work shall be immediately reported to SunSource Energy.

A grievance redressal mechanism for employees shall be put in place for the workers, such that all

complaints are received by an identified site officer and efforts are made to address them in a specified

period of time. Any unresolved or escalated issue shall be brought into the notice of SunSource Energy.



Labour Camp Monitoring

Assessment of accommodation needs of construction labor engaged at site shall be undertaken by

SunSource. Construction workers living in labor camps provided by contractor may encounter

discomfort due to poor living conditions at the site. Hence, the workplace shall be inspected for

general hygiene and living conditions, but not limited to the following:

General living conditions;

Accommodation Requirements;

Sanitation and toilet facilities;

Food and canteen facilities;

Drinking water facilities;

First aid facilities and services;

Entertainment and recreational facilities;

Grievance reported by workers;


The documents to be reviewed will include:

Wage Records

Grievance Record

Medical Records of workers

Labour monthly audit report during construction report;

Reference

Adherence to Legal regulations permits received;

ILO Workers' Housing Recommendation

2.4 Stakeholder Engagement and Information Disclosure

Purpose

Formal consultations with the affected community for solar power shall begin during site selection.

The community will be able to provide an appropriate feedback on the potential impacts only if they

have information about the project and associate activities to ascertain the impacts on them.

It is also aimed at establishing a robust information disclosure and participation mechanism for

communication of relevant environmental and social information to relevant stakeholders, and

especially to those directly impacted from the projects such as the host communities, labor,

contractors and other local stakeholders.

Scope

The scope of this procedure includes:

Stakeholder Identification and Analysis;



Information Disclosure;

Stakeholder Consultation;

Grievance Management;

Reporting to Stakeholders

& will be accordance with host country’s law as well

Responsibility

Social/Admin Officer:

identifying individuals, groups, local communities and other stakeholders that may be affected

by the project, positively or negatively, and directly or indirectly, particularly those directly and

adversely affected by project activities, including those who are disadvantaged or vulnerable;

identifying broader stakeholders who may be able to influence the outcome of the project

because of their knowledge about the Affected Communities or political influence over them;

identifying legitimate stakeholder representatives, including elected officials, non-elected

community leaders, leaders of informal r traditional community institutions, and elders within

the Affected Community;


Stakeholder analysis

Grievances received


Activities

Engagement will be based on the timely dissemination of relevant project information, including the

social and environmental impacts and risks of the project identified in the Assessment and proposed

mitigation measures, in languages and methods preferred by the affected communities.

Stakeholder Identification and Analysis:

SunSource Energy will establish a methodology, including systematic processes, stakeholder’s views

in decision-making to be considered to identify and map its stakeholders and to manage the

relationship between them (taking into account the extent to which it already has means for doing

this) in ways that build accountability to stakeholders and enhance overall performance. It will

communicate the stakeholder map to its stakeholders as provided in.

There are groups of people and social groups who form stakeholder for biomass power project at

different levels may be described as following:

people and social groups who will be directly or indirectly influenced by the Project, (biomass

cultivators, farmers)



people and social groups who participate in implementation of the Project (cultivators,

Panchayats etc),

People and social groups who have a possibility to influence and make decisions on

implementation of the Project.

Stakeholder Consultation

SunSource Energy shall ensure that all project information is disclosed and explained to the

communities, and sufficient time is allocated for them to consider the issues.

Consultation will be inclusive of various segments of the affected community, including both

women and men, and accessible to the disadvantaged and vulnerable groups within the

community.

This consultation should be inclusive of Project design, mitigation and monitoring measures, sharing

of development benefits and opportunities on a Project-specific basis, and implementation related

issues. The SunSource requires the Client to engage in meaningful consultation with stakeholders

during the Project’s preparation and implementation phases, in a manner commensurate with the

risks to, and impacts on, those affected by the Project. Consultation is required for each Project is

normally more elaborate for Project with: (1) significant adverse environmental and social impacts;

(2) Involuntary Resettlement; or (3) impacts on Indigenous Peoples, the SunSource may participate in

consultation activities to understand the concerns of the affected people and to ensure that it should

address such concerns in the Project’s design and ESMP or ESMPF (as applicable). SunSource ensures

that the Client includes a record of the consultations and list of participants in the environmental and

social assessment documentation. Sharing and disclosure of environmental and social assessment

reports, ESMPs, ESMPFs, resettlement plans, RPFs, Indigenous Peoples plans and IPPFs, or any other

approved forms of documentation

Negotiation and Partnerships:

Negotiations with stakeholders wherever required will be entered into in “good faith,” that is,

conducted with an open mind, a willingness to engage in the process, and a genuine desire to

build solutions and to reach agreement. Negotiations will be transparent, considerate of the

available time of the negotiating parties, and shall deploy negotiation procedures and

language readily understood and agreed to by all parties. Partnership in community

development activities (schools, hospitals, roads etc.) will also be explored as part of

negotiations

Grievance Management:

SunSource Energy will establish grievance mechanism prior to construction and operations to

the end of the project;

SunSource Energy will also establish and maintain an organizational structure with authority

and responsibilities for the community liaison function. The grievance redress mechanism will

be transparent, gender responsive, culturally appropriate and readily accessible to affected

persons, including Indigenous Peoples communities at no cost and without retribution.



Reporting to Stakeholders:

SunSource Energy will provide periodic updates to the affected communities at least annually

on the implementation and progress on the specific items in the Action Plan that involve

ongoing risks to or impacts on affected communities. All amendments and updates to the

Action Plan materially change impacts to affected communities will also be disclosed to

communities. Information will also be made available to affected communities in response to

community feedback or grievance and as a means to further involve the affected community

in the social and environmental performance of the project.

Grievance Redressql and Management

A grievance redressal mechanism will be developed for SunSource Energy wherein any

grievances from the stakeholders (at site level) relating to any issues that might arise from the

project activities shall be managed by the Social Officer based at the Site Office and he/she

will be assisted by the Social Manager and Site In-Charge

The complaints will be escalated to the higher level if the lower level fails to address the

grievance to the satisfaction of the complainant.

Receiving and Registration of Complaints:

Stakeholders notifies the company via the Social Officer on the concerns and issues relating

to the project activities;

Secured Grievance boxes shall be placed at specific public place within the community and

within the facility area, the site office and at the facility entrance.

If the stakeholder wishes to remain anonymous, he/she can write down the grievances and

drop it in the available complaint boxes in Grievance Redressal Form.

Once a complaint has been received it shall be recorded in the complaints log register or data

system.

Assessment and Addressal of Complaints:

The Social Officer will open the complaint boxes every week (7) days and informs the Site-In-

Charge;

The grievance will be assessed to determine if the issues raised by the compliant fall within

the mandate of the grievance mechanism or not;

During the assessment of complaints, the team (the Site-In-Charge, Safety Supervisor and

Social Officer) will gather information about the key issues and concerns and helps determine

whether and how the complaint might be resolved.

The issues will be registered by the Social Officer who will take 5 working days to screen and

assess the grievance. If the complaint seems to require intervention then it will be considered

for further action, otherwise it will be rejected and the same will be communicated to the

concerned complainant by Social Officer.



If the complaint is found valid, the scope of issue and level of compensation would then be

negotiated between the complainant and the representatives of the Company (the Site-In-

Charge, Safety Supervisor and Social Officer)

If the complaint cannot be resolved by discussion and negotiation, or if the complaint is not

found valid by the Company, the complainant can appeal his/her case within 10 working days

of the verdict and the complaint goes to the Corporate Level (Social Manager and HR Head)

for a resolution of the matter. The Corporate level shall respond within 10 working days to the

compliant.

The complaint shall be re-investigated and a meeting shall be held with the complainant by

the Social Manager and HR Head. If the complaint is found to be not valid, the complainant

can approach the legal courts. The grievances shall be responded by the Social Head within 20

working days from the time of appeal.

The entire procedure is to be recorded by the Company. A grievance record register shall be

maintained at the site office and monthly reporting of the grievances shall be sent by the

Social Officer to the Social Manager based at the Corporate Office.

The Social Manager will report directly to the Managing Director and he sends a compiled

report every quarter on all activities to be supervised by him to the Managing Director.

The Grievance Record Register shall record all the grievances brought to the notice of the

Social Officer and action taken therein. The written record of grievances will include the

following details –

o Name of the Complainant (not required if the complainant requires to be anonymous)

o Date of complaint

o Nature of complaint

o Follow up action undertaken

o Final result

o Date of communication of decision to complainant

o Implementation of decision

o Appeals, if any

The grievances Redressal mechanism (GRM) will be documented in English, Hindi and local

language and copies will be kept at the project site office and corporate office.

The GRM will also be displayed at the notice board at the site level.

The Social Officer will inform the stakeholders about the grievance mechanism from time to

time and make it easily accessible to them.

o All the relevant contact numbers will be made available to the stakeholders. The

mechanism will address concerns promptly, using an understandable and transparent

process and provide timely feedback to the concerned stakeholders.




In order to involve stakeholders and to maintain an open communication process during the entire life of

the project, the aim of disclosing information should be and should form part of Stakeholder Engagement

Plan;

To provide the stakeholders a schedule for the meetings and information on activities related

to the project activities along with the mechanism for their feedback.

To enhance the knowledge of the stakeholders about the facility, the changes being

incorporated and the expected performance.

To publicize the company’s commitment in ensuring the best practices in terms of

environment protection and health and safety for workers and contractors.

To make the stakeholders aware about the grievance Redressal mechanism so that the

feedback of the public can be accounted for and accordingly addressed.

To gather information on the requirements of the communities for future planning of CSR

activities and assess the impact of the CSR activities on the communities by asking the

feedback/ suggestions of the communities.


Stake holder Engagement Plan

Grievance Redressal

SunSource Energy’s schedule and record of stakeholder engagement;

SunSource Energy’s record of discussions with recognized stakeholder representatives,

respected key informants, and legitimate representatives of sub-groups (e.g., women,

minorities).

Minutes of Meeting with various stakeholders

CSR Plan of Activities

Quarterly reporting on the Progress of the stakeholder consultation

Quarterly reporting on the CSR activities carried out

Maintenance of Grievance Record



Annexure I: Environment and Social Screening Checklist-Ground Mounted Solar Projects

Site Name: _________________________________________________________________________

Location: ________________________________________________________________________

Approach: _________________________________________________________________________

Nearest Airport/ road/ railway network:

_________________________________________________________________________

S.No Assessment of Environment &

Social Features

Presence/

Status in &

around the site

(10kms)

Direction from

the site

Remarks/

Description

Physical Environment

1 Topographical conditions

2 Surface water resources

3 Erosion prone stretches

4 Drainage pattern/conditions

Biological Environment

1 National parks/ wildlife sanctuary

2 Reserve/protected forests

3 Presence of endangered species

4 Presence of any migratory routes

5 Presence of large trees and its

species

Social Environment

1 Presence of any cultural heritage site

and its access

2 Land acquisition of private land

3 Involuntary land taking resulting in

loss of income; livelihood

4 Any loss / reduction of access to

traditional dependent communities

(to areas where they earn for their

primary or substantial livelihood).



S.No Assessment of Environment &

Social Features

Presence/

Status in &

around the site

(10kms)

Direction from

the site

Remarks/

Description

5 Presence of Indigenous / vulnerable

communities

6 Possible conflicts with and/or

disruption to local community

7 Presence of settlements/built- up

environment

8 Sensitive receptors

9 Availability of drinking water

resources

10 Presence of Underground utility

lines like electricity lines, pipelines

for gas, etc

11 Presence of Defence Installations /

Airports

12 Damage to existing infrastructure,

public utilities, amenities etc.

13 Agricultural land parcels / land

fertility levels

Overall E&S risk rating (low, medium and high) as assessed by the supervisor = Low/ Medium/ High

Signature of Safety Supervisor: ______________________________________________________

Date: ____________________________________________________________________________

environmental and social risk management procedures

Documents