1

US Agency for International Development (USAID) / India

Initial Environme

nt Examinatio

n (IEE)

PACE 2.0-Smart Power for Advancing Reliability and Connectivity (SPARC)

Activity/Project Title: PACE 2.0-Smart Power for Advancing Reliability and Connectivity (SPARC)

Solicitation #: N.A.

Contract /Award Number (if known): N.AGeographic Location : India; 386Originating Bureau/Office: USAID/India, Clean Energy and Environment (CLEEO)Supplemental IEE: ☐ Yes ☒ NoAmendment: ☐ Yes ☒ No Programmatic IEE: ☐ Yes ☒ No

DCN and date of Original document: N.ADCN and ECD link (s) of Amendment (s): N.AAmendment No: N.A

Funding Amount: $2,360,000 Life of Project Amount: $2,360,000

Implementation Start/End: FY 2019/ FY 2021Prepared By: Apurva Chaturvedi Date Prepared: April 16, 2018Expiration Date (if any): Reporting due dates (if any): N.AEnvironmental Media and /or Human Health Potentially Impacted (check all that apply)None ☒ Air ☐ Water ☐ Land ☐ Biodiversity ☐ Human Health ☐ Other ☐Recommended Threshold Determination:☒Negative Determination ☒With Conditions☒Categorical Exclusion☐Positive Determination

☐Deferral☐Exemption☐USG Domestic NEPA action

Climate Change□ GCC/Adaptation ☐ GCC/Mitigation ☐ Climate Change Vulnerability Analysis (included)

Adaptation/Mitigation Measures: Not Applicable

1. SUMMARY OF FINDINGS

In accordance with 22 CFR 216(a), environmental analysis/evaluation is required for new projects, programs or activities authorized by USAID. This Initial Environment Examination (IEE) evaluates the Partnership to Advance Clean Energy (PACE) 2.0-Smart Power for Advancing Reliability and Connectivity (SPARC) under the USAID/India Partnerships APS over a period of three years. This activity will support deployment of affordable, clean, reliable, safe and secure energy technologies to support economic development in India by focusing on improving the distribution of power to the consumers.

2. RECOMMENDED ACTION:

i. Categorical Exclusion. Pursuant to 22 CFR 216.2(c)(3), the originator of the PACE 2.0-SPARC (USAID/India CLEEO) has determined that the “core” program activities, which primarily involve the provision of technical assistance to electricity distribution utilities to enhance operational and financial performance, are environmentally neutral (See Table 1) that do not have an effect on the natural or physical environment, in accordance with the stipulation in 22 CFR 216.2(c)(1)(i), and consist of types of interventions entirely within the categories listed in 216.2(c) (2). Therefore the originator recommends they be categorically excluded, falling under the following classes of actions: Education, technical assistance, or training programs except to the extent such programs include

activities directly affecting the environment (such as construction of facilities, etc.), {22 CFR 216.2(c)(2)(i)}; and

Document and information transfers {22 CFR 216.2(c)(2)(v)}.

ii. Negative Determination with Conditions (NDC): A Negative Determination with Conditions is recommended for one of the components, namely “Distribution Sector Investment Planning”. To ensure compliance, the Implementing Partner will prepare an Environmental Management Mitigation Plan (EMMP) focusing on incorporating climate risk analysis in the DISCOM’s planning process and building their capacity to undertake such analysis. The analysis would include understanding the impact of climate changes (such as heat, temperature), weather variability, and extreme weather conditions on the DISCOM’s infrastructure as well as impacts on the energy demand and thus on load. The EMMP will be reviewed and approved by the Mission Environmental Officer (MEO).

iii. Climate Risk Screening: Pursuant to ADS Chapter 201 and Executive Order 13677, Missions must assess climate-related risks and vulnerabilities in all programs and address them as appropriate. As no climate risk assessment was conducted at the Project-Level for the DO2 PAD in which this activity is included, CLEEO conducted an activity-specific climate risk screening which covers all planned interventions and rated the possible climate risks associated with PACE 2-SPARC interventions as either “low” or “moderate.” The initial screening of the project against the climate change effects indicate that the activities do not pose social or environmental risks that need to be further analyzed through additional steps of the identification process. Based on the information, none of the proposed project activities will effect climate change and eco-systems and cause GHG emissions. In fact, the activity is focused on reducing Aggregate Technical and Commercial (AT&C) losses of distribution companies (DISCOMS). There are no demographic and socio-economic aspects of the project that increase the vulnerability of the project to climate change. The components under this activity will result in reduction in energy losses as well as lead to lower GHG emissions from business-as-usual scenario. As a part of the Monitoring, Evaluation & Learning (MEL) Plan, the program partners will monitor improvement in AT&C losses and GHG emissions through the duration of the program. The analysis includes recommendations on how

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climate risks will be addressed during implementation of SPARC, as well as opportunities for strengthening climate resilience, which is available with the USAID/CLEEO office’s design files.3. BACKGROUND AND ACTIVITY DESCRIPTION

3.1 Purpose and Scope of the IEEThe purpose of this IEE is to reflect on the potential environmental impacts of USAID/India’s planned PACE 2.0-SPARC to be implemented over three years (FY2018-FY2021). The document provides an overview of PACE 2.0-SPARC planned interventions and the manner in which they correspond with categorically excluded actions.

3.2 Background

The Government of India (GOI) has committed to making affordable 24-7 power available a top policy priority to meet its annual GDP growth target of eight percent, so the economy can provide jobs to one million Indians entering the labor force each month. This requires power generation to grow by over six percent yearly. Energy security and independence (reducing energy imports and the delivered cost of power) is at the core of this effort. Pursuing reliable, clean and cost-effective power for India is critical to the country’s energy security and continued strong economic growth. The Government of India is taking several measures to reform the power distribution in India. Some of the key measures include the Ujwal Discom Assurance Yojana (UDAY) program to improve utility performance, Integrated Power Development Scheme (IPDS) and Deen Dayal Upadhyaya Gram Jyoti Yojana (DDUGJY) to strengthen electricity distribution networks, Saubhagya scheme to provide last mile electricity connectivity to all un-electrified households in rural/urban/remote areas and National Smart Grid Mission (NSGM) for increased level of automation to bring in higher level of operational efficiencies in the electricity distribution grid.

The Indian Power Sector is in the midst of a paradigm shift as it gears up for a more distributed and consumer centric energy future where two-way power flows and increased intelligence are set to become the norm. The pace of evolution is rapid and utilities now need to gear up to adopt new, holistic approaches to manage the electrical grid of the future. Government of India (GoI) is committed to provide affordable, reliable and quality 24x7 power supply to all by FY 2019. This necessitates reviving the operational efficiency and restoring the financial health of the utilities.

3.3 Description of ActivitiesThe objective of this program is to transform operational and financial performance of electricity distribution utilities by scaling-up the deployment of ‘Smart Power Systems’1 to deliver reliable, cleaner, affordable and quality power connectivity 24x7 to their consumers.

This proposed activity titled PACE 2.0-SPARC, is part of the larger U.S-India Partnership to Advance Clean Energy (PACE) initiative and builds upon the groundwork done in earlier programs like Partnership to Advance Clean Energy-Deployment Technical Assistance (PACE-D TA) Program.The outcomes of the program would directly contribute to improving utility operations and finances through reduction of AT&C losses, optimization of investments, institutional strengthening through capacity building and enhancement of consumer satisfaction and participation. The program will create an enabling environment for opening up and expanding the overall market size in Smart Grid, providing level playing field to all national and global companies. Since US companies are actively undertaking various Smart Grid initiatives, they are therefore in prime position

1‘Smart Power Systems’ includes adoption of greater automation systems including smart grid

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to take the opportunity of being part of the $8 billion Smart Grid market in India2. The proposed activity will be implemented by KPMG Advisory Services Pvt. Ltd. (KASPL). The Ministry of Power (MoP), Government of India is the bilateral partner of USAID for this activity. Strong consultation and handholding support to the stakeholders at Central level (NSGM, EESL) and State level (Discoms, regulator), shall be part and parcel of the program interventions.

The key components of the program along with the illustrative tasks are described below:

Component-1: Distribution Sector Investment PlanningThe power sector in India is facing major disruption. Trends of decentralization, digitalization and decarbonization are increasingly influencing the GoI policies, programs and initiatives. As these trends unfold, power sector is likely to witness large number of new opportunities e.g., embedded generation, retail and wires business segregation, and alternative sale and service propositions. Harnessing these opportunities will require a paradigm shift from traditional ways of planning and business operations to new planning approaches and business models. Such new approaches will need to look at the practical context of the utilities and evolve methods that are likely to work in the Indian power sector context.

With the above-mentioned in view, the focus of this component is to review the existing business planning framework, the existing delivery structures and the mechanism by which investment decision are undertaken, and propose approaches that align with the context of the emerging power sector.

This component also aims to develop scalable and generalizable tools and models that can be applied across various utilities.

The key illustrative activities under this component include:

1. Framework for Distribution Investments The illustrative tasks under this activity include: • Identification of Discom for review of load profiles • Load analysis to understand the nature and characteristics of demand • Climate risk analysis to understand the impact of climate changes (such as heat, temperature),

weather variability, and extreme weather conditions on the DISCOM’s infrastructure as well as impacts on the energy demand and thus on load.

• Review of the current investment approval process at the distribution level• Undertake load analysis to identify opportunities for effective load/peak management• Cost benefit analysis of the proposed options• Internal workshop at the Discom level for obtaining comments, consensus and buy-in• Development of framework for assessment of distribution investments along with user guide • Dissemination of the framework to Discom forums for wider adoption

2. Distribution Franchisee (DF) Models in Emerging Power Sector ContextThe illustrative task under this activity includes: • Identification and selection of DFs for a detailed assessment• Detailed assessment of existing DFs in the country

2 http://economictimes.indiatimes.com/industry/energy/power/smart-grid-market-to-touch-rs-50000-crore-in-five-years/articleshow/51102850.cms

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• Development of new business models • Stakeholder consultations and consensus building• Support in development of relevant guidelines for adoption of models by different states

3. Analytical Tool for Cost-Benefit Analysis for Smart Grid InvestmentsThe illustrative task under this activity includes: • Development of standard methodology for Smart Grid cost-benefit assessment• Survey of open-source cost benefit tools• Consultation with key stakeholders in order to increase the acceptability of the tool• Designing of investment decision support tool (in excel or other open source platform)• Preparation of a user guidebooks and hosting of tool on NSGM portal for access by all

Component-2: Discom Operations ImprovementGoI’s flagship UDAY program aims at restoring the viability of power distribution segment by ushering in a new wave of reforms and efficiency improvement initiatives. The deployment of Automated Metering Infrastructure (AMI) comprising smart meters, communication technologies, and head end systems is considered as a fundamental building block of the distribution value chain that will enable better visibility and control over the operations. The operations improvement and viability at the distribution level can also be improved through mechanisms that enable smooth revenue collections and better receivables management, and allow utilities to have alternative revenue streams that are likely to grow in the coming areas.

The focus of this component is to support identified/specific discoms in the deployment and application of smart technologies, increased digital services and business models to serve new electricity loads, which can act as important drivers toward attaining improved discom operations in future.

The key illustrative activities under this component include:

1. Smart Grid Deployment Support including Analytics Based Products and Consumer Participation SchemesThe illustrative tasks under this activity include: • Selection of state for smart grid deployment support which includes pre-feasibility assessment

and selection of smart grid functionalities, design of project structure including business model, roles & responsibilities, governance mechanism, funding structure, etc. and bid advisory and preparation of bidding documents

• Support in development of analytics solutions/Customer participation schemes• Capacity building and handholding of Discom officials in all critical activities across project

stage

2. Accelerating Adoption of Digital Payments in Electricity Retail The illustrative tasks under this activity include:

• Analysis of existing digital eco-system including payment mechanisms and Discom readiness: • Consumer survey for identifying consumer behavior, adoption patterns and factors inhibiting

uptake of digital mediums

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• Review of good practices covering electricity sector (specific initiatives), as well other sectors nationally and internationally

• Development of strategic roadmap and solutions for transition to a cash-less digital transaction in electricity bill payments

• Technical assistance support to a select Discom and capacity building including digital training of Discom staff

Component-3: Capacity Building, Outreach and Consumer Awareness Building capacity through outreach, training and education is critical for rapid deployment of emerging technologies and processes. This component would undertake a comprehensive outreach and capacity building initiative to overcome the knowledge and skill barriers at various levels. This component would address the knowledge-gap in the integration of advanced technologies in discom operations as well as integration of climate risks in planning of DISCOM’s strategy through training, consultative and dissemination workshops, study tours, etc. It would also aim at engaging with consumers to spread awareness and welcome participation in various new initiatives, such as how AMI and digital payments can help reduce electricity bills and improve discom services.

The key illustrative activities under this component include:

1. Outreach & Communication strategy

• Outreach and communication strategy (with national and international stakeholders) including central and state level regulators, Discoms, civil society etc.

• Facilitation for MoUs/twining arrangements with International Institutes (e.g.: EPRI (U.S.) and National Smart grid mission (NSGM))

• Periodic support in the activities (e.g. expert seminars, discussion groups/threads, webinars etc.)• Smart Grid definition and value proposition for different stakeholders

2. Support in Institutionalization of Smart Grid CourseThe illustrative task under this activity includes:

• Assistance in selection of partner institutes and independent expert trainers - design of selection process, (including selection criteria, EOI/RFP, contracts)

• Empanelment of partner institutes and independent expert trainers- train the trainer workshops• Design of training plan- training calendar, budgeting, feedback forms, etc.

3. International Study Trip; Dissemination/Consultative Workshops and Consumer Awareness

The illustrative task under this activity includes: • Knowledge and logistical support in organizing workshops; international study tour(s); and

other consultative discussions • Consumer awareness and engagement campaigns • Preparation of summary document (s) and feedback

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Leverage: The PACE 2.0-SPARC activity has a total funding of $2,360,000 over three years. It is leveraging and building on existing GOI programs including programs at Energy Efficiency Services Limited (EESL) and is expected to leverage investments of $160,592,000.

Geography and Beneficiaries: The proposed program would operate at the Central level, with the Ministry of Power (MoP), Government of India, to ensure pan-India roll out of the designed interventions. Discoms and states shall be selected in consultation with the MoP. The primary beneficiaries would be Discoms and their consumers. Strong consultation and handholding support to the stakeholders at Central level (NSGM and EESL) and State level (Discoms, regulators), shall be part and parcel of the program interventions.

4.0 RECOMMENDED THRESHOLD DECISIONS AND MITIGATION ACTIONS

Categorical Exclusion and Negative Determination with Conditions (Please refer to the Summary Section).The justification for recommending a determination of Categorical Exclusion for activities under the PACE 2.0-SPARC is due to their nature, such as capacity building, communication & outreach, development planning, training, analyses/studies, and associated technical assistance – all of which are considered environmentally neutral actions. For certain activities, a determination of NDC has been made.

Table 1 below lists the major activities of PACE 2.0-SPARC according to Reg. 216 requirements and recommends Threshold Decisions and environmental compliance actions.

Components and illustrative activities

Effect on Natural or Physical

environment

Threshold decisions and Reg. 216 actions required

1Distribution Sector

Investment PlanningInsignificant

effectNegative Determination With Conditions:

The implementation partner would prepare an EMMP focused on incorporating climate risk analysis in the distribution companies planning process. Analysis will focus on understanding the impact of climate changes (such as heat, temperature), weather variability, and extreme weather conditions on the DISCOM’s infrastructure as well as impacts on the energy demand and thus on load. The EMMP will be reviewed and approved by the Mission Environmental Officer (MEO).

The implementing partner will build the capacity to undertake such analysis through

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Components and illustrative activities

Effect on Natural or Physical

environment

Threshold decisions and Reg. 216 actions required

training and consultative workshops of DISCOMs and sub-partners.

2Discom Operations

Improvement No effect Categorical Exclusion: No action required.

3

Capacity Building, Outreach and

Consumer AwarenessNo effect Categorical Exclusion: No action required.

5.0 MITIGATION, MONITORING & EVALUATION

5.1 Specific ResponsibilitiesAOR (Agreement Officer Representative) will make ensure that environmental conditions set forth in this IEE are met. In addition, the AOR/Activity Manager will ensure that mitigation measures in the IEE are implemented and that adequate monitoring and evaluation protocols are in place to ensure its implementation.

The Development Objective (DO) Team will ensure that environmental compliance language from the IEE is translated into procurement documents and contracts.

The Mission Environmental Officer (MEO) together with AOR will review and approve environmental compliance documentation, conduct spot checks to ensure that conditions in the IEE are met and provide guidance when required.

5.2 Conditions & Implementer Procedures

The implementing partners are encouraged to raise awareness of its staff and the participating DISCOMs on the need for climate risk analysis and its impact of the stakeholder’s performance.

The implementer shall ensure that all activities under this program comply with the conditions established in this IEE. The implementer will notify USAID if activities are found to have unintended consequences or mitigation measures are ineffective. Activities that are not in compliance with approved environmental documentation will be modified or terminated.

5.3 Reporting Requirements

The implementer will regularly report to USAID on and have a section on environmental compliance in its Annual Work Plans. The Final Report will also have a section that will summarize program activities related to environmental compliance and will describe results on environment of program activities.

6.0 LIMITATIONS OF THE IEE

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This IEE does not cover activities involving:

Assistance for the procurement, use or recommendation for use of pesticides

Assistance, procurement or use of genetically modified organisms (GMOs)

Development Credit Authority (DCA)

Procurement or use of Asbestos, Lead, Mercury Containing Materials (ALMCM)

7.0 REVISIONS

Pursuant to 22 CFR 216.3(a) (9), if new information becomes available which indicates that interventions to be funded through PACE 2.0-SPARC might be “major” and their effects “significant,” this determination will be reviewed and revised by USAID/India and submitted to the Bureau Environmental Officer (BEO) for approval, and, if appropriate, an Environmental Assessment will be prepared in accordance with the procedures stipulated in 22 CFR 216. It is the responsibility of the PACE 2.0-SPARC Contracting/Agreement Officer’s Representative (C/AOR) to timely inform the Mission Environment Officer and BEO of any changes in the scope and nature of the approved activities, which may require the revision of the approved Threshold Decision.

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APPROVAL OF ENVIRONMENT ACTION RECOMMENDED

Clearances:

Activity Manager: Date:

Mission Environmental Officer

Apurva Chaturvedi

Date:

Monali Zeya Hazra

Climate Risk Analysis Lead (A)

Regional Environmental Advisor for Central and South Asia and OAPA

Monali Zey Hazra Date:

Date:

Regional Legal Advisor:

Andrei Barannik

Date:

Deputy Mission Director:

Diana Weed

Date:

Approval:

Mission Director:

Ramona El Hamzaoui

Date:Mark A.White

Concurrence: Bureau Environmental Officer (Asia):

Date:

William Gibson

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Attachment-1

Due Diligence on the KPMG Advisory Services Pvt. Ltd. (KASPL) and Energy Efficiency Services Ltd. (EESL) for the PACE 2.0-Smart Power for Advancing Reliability and Connectivity (SPARC) activity

As per the Global Development Alliance (GDA) requirements, a due diligence was conducted in accordance with ADS 204 on the partner KPMG Advisory Services Private Ltd (KASPL) as the implementing partner and Energy Efficiency Services Ltd. (EESL) as the resource partner) under the PACE 2.0-SPARC project to evaluate the risks and benefits.

Per ADS 204.3.9(a), as part of the due diligence investigation of a potential alliance partner, it is essential to investigate what is often called the “triple bottom line”, whether the prospective partner is socially responsible, environmentally accountable and financially sound. Information was gathered from resources such as Factiva, and Dun & Bradstreet through USAID’s Knowledge Service Centre. Desk research was also undertaken by the technical office covering the various aspects of the due diligence. The due diligence covered five areas including corporate image, social responsibility, environmental accountability, financial soundness, and policy compatibility.

Brief summary of the due diligence for each partner respectively is produced below:

1 KPMG Advisory Services Pvt. Ltd. (KASPL)

1.1 Corporate Image/Reputation: KPMG is a global network of professional service firms comprising 174,000 professionals across 155 countries, offering Audit, Tax and Advisory services to clients3. All independent member firms of the KPMG network are affiliated to KPMG International. KPMG in India is the Indian member firm of KPMG International and was established on September 1993. KPMG Advisory Services Ltd., a sub-licensee of KPMG in India, is an Indian private limited company incorporated on 12-October-1999. The KPMG Global Code of Conduct4 outlines the standards of ethical conduct that KPMG requires around the world. The Global Code applies to all KPMG partners and employees.

The professionals leverage the global network of firms, providing detailed knowledge of local laws, regulations, markets and competition. Over 9,600 Indian and expatriate professionals, many of whom are internationally trained are part of the Firm. KPMG in India is currently offering services to over 3,000 national and international clients in India across sectors5

3 https://home.kpmg.com/ee/en/home/about/kpmg-in-estonia/kpmg-around-the-world.html4 https://assets.kpmg.com/content/dam/kpmg/xx/pdf/2018/02/code-of-conduct-2012v2.pdf 5 https://home.kpmg.com/in/en/home/media/press-releases/2017/07/transactions-risk-consulting-business-bmr-merge.html https://home.kpmg.com/in/en/home/about/overview.html

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KASPL has extensive experience of working in the Indian Power sector across the value chain. And have strong connect and reach with the key stakeholders in India as well as globally6. The group brings with it an in-depth sector and domain knowledge and works with clients to enable transformation through the entire lifecycle of the asset. KASPL works closely with leading players in the power and utilities space in the private as well as public sector. KASPL provide advisory services in business unit strategy and corporate strategy formulation, implementation and evaluation, organizational restructuring and institutional design, operations and asset management, effective cost management, tariff modeling and economic consulting7.

In addition to the above, other key notable initiatives of KPMG include: Centers of Excellence (COEs) - KPMG has 19 Energy COEs across the globe which provide

greater access to industry professionals around the globe incl. people/organizations, methodologies, technical, knowledge mgt. frameworks etc.8

Global Power & Utilities Conference, ENRICH and Market Forums – KPMG’s flagship events that brings together global players, ministers, policy makers, regulators, private players, government utilities, investors and sector experts to deliberate on new thoughts/concepts in the energy space. The events are sought after by stakeholders and enables KPMG to connect with a wider Industry to form sector pathways.9

Thought Leadership on variety of areas– ‘RISING SUN 2015’ – Disruption on the Horizon” the latest TL was released by the Power Minister and has been quoted in large no. of publications.10

Government of India Missions– KPMG in India is involved in major reform programs, driven both at the central and state levels. KPMG works as advisors and implementers of some of the largest programs in the country that include ‘Swachh Bharat’ (Clean India), ‘Make in India’, ‘Ease of Doing Business’, ‘Smart Cities’, ‘Digital India’ and ‘Skill India’, amongst others11.

The partner’s credibility can also be endorsed by USAID as it has assisted USAID in its smart grid implementation and capacity building initiatives in India. It was the lead expert agency for implementing the Smart Grid program in the USAID led bilateral program “Partnership to Advance Clean Energy-Deployment (PACE-D) Technical Assistance”.

KASPL is not seeking this partnership for any PR opportunities. USAID and KASPL objectives are closely aligned and this partnership can improve state of power distribution utilities better suited for future energy needs. Moreover, KASPL already has a well-established network within the community of Discoms, policy makers, regulators, smart grid manufacturers etc. and with other development aid agencies engaged in smart grid and Discom’s efficiency improvement.

6 https://home.kpmg.com/in/en/home/industries/energy.html 7 https://home.kpmg.com/in/en/home/services/infrastructure-and-government-services/infrastructure-advisory.html 8 https://home.kpmg.com/ca/en/home/industries/energy/energy-centers-of-excellence.html 9 https://home.kpmg.com/in/en/home/events/2016/10/enrich-2016.html 10 http://pib.nic.in/newsite/PrintRelease.aspx?relid=130518 11 https://home.kpmg.com/in/en/home/services/infrastructure-and-government-services/government-advisory.html

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KASPL is not expecting an exclusive partnership with USAID and understands that the program must follow USAID branding and marketing practices. KASPL complied with press and media coverage rules laid out by USAID in the PACE-D TA program also.

No negative information was found about the company in print or electronic media. KASPL is not involved in any litigation. There is no evidence of tensions between KASPL and the community of Indian power sector stakeholders such as Discoms, Regulators etc. In fact, KASPL is well recognized for its advisory role in the power sector.

1.2 Social Responsibility:As part of its CSR initiatives, KPMG Advisory Services Ltd. has founded Corporate Citizenship program in 2014 with the aim of making a difference and leaving a mark on impressionable lives of leaders of tomorrow through education12. For instance, their Aspire programme benefited over 180 girls across five schools during 2016. Through Enactus, 40 partners and senior staff mentors had the opportunity to guide students from over 50 colleges across the country12.

KPMG has chosen to focus on the Sustainable Development Goal (SDG) 4 – Quality Education, as their global Corporate Citizenship priority. Seeing the critical role that education plays, KPMG has a clear commitment to Lifelong Learning and empowering next generation leaders. Their program range from investments in early childhood development, higher education, entrepreneurship and business skills.

The company has a Health & Safety policy covering health related matters, which are applicable to their operations. The company provides health insurance to all regular employees. Leave allocation is as per industry standards. Training sessions and other forms of written communication are used to inform employees about workplace related health and safety issues.

KASPL has a comprehensive Code of Professional Practice and Conduct to promote lawful and ethical behavior by all employees. Issues covered within the code include professional and personal code of conduct, prevention of sexual harassment at workplace, policy with regard to misconduct, data privacy protection policy, social media policy, diversity and inclusion, etc. KPMG is a signatory of the UN Global Compact since 2002, as well as being a signatory of the World Economic Forum’s Partnering Against Corruption – Principles for Countering Bribery.

The company’s hiring, promotion, job assignment and compensation policies are merit based. It does not discriminate because of race, color, religion, sex, national origin, age or disability. Recruitment of people with disabilities and women is encouraged in the company. KPMG has a Physical Security Policy to provide a safe and secure working environment.

12 https://home.kpmg.com/in/en/home/about/csr-home.html

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KPMG also has policies on performance management and learning & development that encourage its employees to continually acquire and update their professional skills. The company does not employee children. KASPL does not have a union. It is not involved in the manufacture or sale or handling of firearms or narcotics. Copies of all the policies have been provided to the Clean Energy & Environment Office and are retained in the project office.

1.3 Environmental accountability:KPMG is committed towards protecting environment and promoting sustainable practices to reduce its carbon footprint. Advancing sustainability is a key part of their Citizenship strategy and numbers of initiatives have been undertaken at KPMG worldwide. The company monitors and reports its carbon footprint and other initiatives as a part of its Corporate Citizen Reports. At India, KPMG has subscribed to the Global Green Initiative, which focuses on: Energy Saving solutions; Rainwater harvesting; Tree planting; Conservation of indigenous flora; Drip Irrigation and promoting Solar projects.

Although KASPL does not have a specific environment policy, but their commitment has been detailed out by the senior in the corporate citizen report. KASPL promotes environmental sustainability in the adoption of technologies and operating procedures in all parts of the enterprise. The company sets targets for improved environmental performance and regularly monitors the progress towards environment, health and safety targets. These are annually reported in the corporate citizen reports. Copies of the Global and Indian reports have been submitted to USAID. There is a dedicated team within the organization to monitor the progress on its environment and CSR commitments.

The company has an ISO 9001:2008 certification and an ISO 27001:2013 certification. KASPL has not been involved in any lawsuits.

1.4 Financial Soundness:KPMG in India is the Indian member firm of KPMG International and was established in September 1993. It is not a publicly traded company. KPMG Advisory Services Ltd. is an Indian limited liability company incorporated on 12-October-1999. KASPL does not publish an annual report. The company’s financial transactions and revenues are audited annually by certified chartered accountants and no discrepancy has ever been reported.

1.5 Policy Compatibility:Company is not listed in any United Nations sanction lists or United States Government restricted lists. It maintains a transparent account of its operations, revenue streams and human resource management. Its policies are in conformance with Indian laws for private sector enterprises.

2 Energy Efficiency Services Pvt. Ltd. (EESL)EESL is a government owned company established to develop the market for energy efficiency in India. It is the resource partner for the proposed partnership program, PACE-2.0-SPARC..

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EESL is already partnering with USAID under an existing program called ‘Market integration and transformation program for energy efficiency (MAITREE’). The due diligence of EESL was conducted during the award of MAITREE and has been updated..

2.1 Corporate Image/Reputation:EESL was formed in 2009 and has created a niche for itself in the energy efficiency market in India since then. In this short span, EESL has strengthened the market for advanced energy efficient technologies and services13. The company is entrusted with implementing Indian government’s flagship energy efficiency programs. EESL is actively engaged in promoting efficiency in utility operations through their Smart Meter National Program (SMNP).

EESL network with other players in the energy sector are very strong. EESL is a strong brand in India and there is no evident need for it to enter a partnership with USAID to enhance its public relations in India or US.

EESL has a strong reputation in the international community. US Department of Energy, and its national laboratories, have partnered and exchanged information with EESL to devise strategies for enhancing energy efficiency in buildings and appliances. It has long term agreements with government and municipal agencies in India to assist them in implementation of large scale energy efficiency programs. International development agencies like DFID, KfW, GIZ and ADB have partnered with EESL to magnify the impact of their activities in India.

EESL programs and milestones are often covered in the mainstream media. The coverage is mostly positive. There is no evidence of any tensions between EESL and other stakeholders in the community. EESL is not involved in any lawsuits.

EESL and USAID have already collaborated under the PACE-D TA program. Currently EESL is a partner under an existing USAID funded ‘Market integration and transformation program for energy efficiency, MAITREE’. EESL has been diligent in acknowledging USAID contributions to its initiatives on all public platforms. As a government owned entity, it cannot seek any kind of endorsement from USAID for any its activities. There is no evidence that suggests that EESL has used, the technical assistance it has received from USAID under PACE-D TA program or MAITREE, for soliciting additional support for its activities.

EESL is a resource partner which has committed a significant portion of its own resources to the proposed partnership and is not relying solely on USAID resources for implementing the program.

13 http://timesofindia.indiatimes.com/business/india-business/World-Bank-pegs-Indias-energy-efficiency-market-at- Rs-1-6-lakh-crore/articleshow/55212793.cms

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There is no indication from the management that it is anticipating an endorsement from USAID or an exclusive relationship with USAID.

2.2 Social Responsibility:

EESL’s Corporate Social Responsibility policy follows Section 135 of Companies Act 2013. This contains rules on CSR responsibilities. Energy Efficiency Services Limited, is first super ESCO in South Asia. It has been formed with an objective to carry out and promote the business of Energy Efficiency and climate change & to implement energy efficiency projects in Demand Side Measure. The Main focus is to undertake that CSR activities that help to save & conserve energy to create impact on the environment and ecology.

As per the EESL’s CSR policy, activities must focus on women empowerment, health, sanitation, drinking, water, education, and activities contributing towards environment sustainability. EESL has a three member CSR committee consisting of company directors and a CSR cell headed by the Company Secretary. As per the company’s annual reports, EESL has considered applications from different sources to support various activities that fall within the purview of its CSR policy14. The copy of the policy has been submitted to the technical office for record. The company has started reporting its CSR initiative as a part of its Annual Report15.

The company is not involved in the manufacture or sale of firearms or narcotics. EESL’s code of conduct places the responsibility of ensuring a workplace free of discrimination & harassment based on race, colour, religion, caste, age, gender, nationality, origin, disability, veteran status, or any other biases on its directors and senior management personnel. No evidence was found of harassment faced by EESL employees on these issues. EESL has also established anti-fraud and whistleblower policy.

EESL does not support child or forced labor. There are no unions at EESL.

2.3 Environmental Accountability:EESL is already partnering with USAID on its other partnership program called MAITREE. As a part of this partnership, USAID’s implementing partner EDS is already working with EESL in helping them develop an environment policy and framework.

EESL is not engaged in any manufacturing activities. It does procure energy efficient products from third parties. In such cases, the company stipulates stringent standards for energy and environmental performance of equipment purchased for its programs. Environmental sustainability standards to be adhered to are specified in its tender documents. Compliance with these standards is non-negotiable.

14 EESL CSR Policy. http://www.eeslindia.org/User_Panel/UserView.aspx?TypeID=114715 http://www.eeslindia.org/writereaddata/EESL%20Annual%20Report%202015-16.pdf

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EESL maintains and continuously updates publicly accessible dashboards that record the energy savings and GHG emissions averted due to its projects. The company continuously expands its portfolio of services and programs.

Contingency plans for preventing, mitigating, and controlling serious environmental and health damage from their operations, including accidents and emergencies; and mechanisms for immediate reporting to the competent authorities are contained in the contracts drawn between EESL and its clients. EESL assess, and address in decision-making, the foreseeable environmental, health, and safety-related impacts associated of the products installed by it over their full life cycle.

EESL has already applied for ISO 9000 certification and is expected to earn the ISO 9000 certification by last quarter of FY 2017-18

2.4 Financial Soundness:EESL is not a publicly traded company. It is a joint venture of public sector units of Government of India (NTPC Limited, PFC, REC and POWERGRID). Annual and half yearly reports published by EESL are available on the company’s website. Comptroller and Auditors General’s office appoints statutory auditors on a yearly basis for audit of the company’s financial transactions. Revenues and expenditure are also audited by internal and independent secretarial auditors. EESL was formed in 2009 and registered under the Companies Act 1956.

2.5 Policy Compatibility:EESL is not listed in any United Nations sanction lists or United States Government restricted lists. The company follows all environmental, health and safety laws laid down by Government of India. EESL’s code of conduct, human resource management policies, and financial auditing policies are as per the international best practices. In fact they already have a line of credit from KFW, ADB, World Bank.

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Attachment-2Partner Due Diligence Questionnaire: KPMG Advisory Services Ltd. (KASPL)

A. Corporate Image

1. What is the company’s public image? Have there been any tensions between the community and the company?

KPMG is a global network of professional service firms comprising 174,000 professionals across 155 countries, offering Audit, Tax and Advisory services to clients16. All independent member firms of the KPMG network are affiliated to KPMG International. KPMG in India is the Indian member firm of KPMG International and was established in September 1993. KPMG Advisory Services Ltd. is an Indian limited liability company incorporated on 12-October-1999. The KPMG Global Code of Conduct outlines the standards of ethical conduct that KPMG requires around the world. The Global Code applies to all KPMG partners and employees.

The professionals leverage the global network of firms, providing detailed knowledge of local laws, regulations, markets and competition. Over 9,600 Indian and expatriate professionals, many of whom are internationally trained are part of the Firm. KASPL is currently offering services to over 3,000 national and international clients in India across sectors17

KASPL has extensive experience of working in the Indian Power sector across the value chain. Have strong connect and reach with all the key stakeholders in India as well as abroad18. The group brings with it an in-depth sector and domain knowledge and works with clients to enable transformation through the entire lifecycle of the asset. KASPL works closely with leading players in the power and utilities space in the private as well as public sector. KASPL provide advisory services in business unit strategy and corporate strategy formulation, implementation and evaluation, organizational restructuring and institutional design, operations and asset management, effective cost management, tariff modeling and economic consulting.19

In addition to the above, other key notable initiatives of KPMG include:

16 https://home.kpmg.com/ee/en/home/about/kpmg-in-estonia/kpmg-around-the-world.html17 https://home.kpmg.com/in/en/home/media/press-releases/2017/07/transactions-risk-consulting-business-bmr-merge.html https://home.kpmg.com/in/en/home/about/overview.html 18 https://home.kpmg.com/in/en/home/industries/energy.html 19 https://home.kpmg.com/in/en/home/services/infrastructure-and-government-services/infrastructure-advisory.html

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Centers of Excellence (COEs) - KPMG has 19 Energy COEs across the globe which provide greater access to industry professionals around the globe incl. people/organizations, methodologies, technical, knowledge mgt. frameworks etc.20

Global Power & Utilities Conference, ENRICH and Market Forums – KPMG’s flagship events that brings together global players, ministers, policy makers, regulators, private players, government utilities, investors and sector experts to deliberate on new thoughts/concepts in the energy space. The events are sought after by stakeholders and enables KPMG to connect with a wider Industry to form sector pathways.21

Thought Leadership on variety of areas– ‘RISING SUN 2015’ – Disruption on the Horizon” the latest TL was released by the Power Minister and has been quoted in large no. of publications.22

Government of India Missions– KPMG in India is involved in major reform programmes, driven both at the central and state levels. KPMG works as advisors and implementers of some of the largest programmes in the country that include ‘Swachh Bharat’ (Clean India), ‘Make in India’, ‘Ease of Doing Business’, ‘Smart Cities’, ‘Digital India’ and ‘Skill India’, amongst others23.

There is no evidence of tensions between KPMG and the community. In fact, as described above, KPMG is the leading national consultant for each of the priority programs of the Govt. of India and is well recognized for its advisory role in the power sector.

KPMG and its experts have assisted USAID in its Smart Grid programs in India. It was the lead expert agency on Smart grid component of the USAID PACE-D TA program.

2. Has there been anything in the media that would reflect negatively upon the company? If so, how has the company dealt with significant negative publicity?No negative information was found about the company in print or electronic media

3. Are there any pending lawsuits against the company?There is no evidence to suggest that KASPL is or has ever been involved in any litigation.

4. Is the company looking solely for PR opportunities by aligning itself with USAID?KASPL is not looking for PR opportunities as it has been associated with USAID in several projects in the past. USAID and KASPL objectives are closely aligned and this partnership can enable electricity distribution sector innovation to support better performance of distribution utilities (Discoms). Moreover, KASPL already has a well-established network within the community of Discoms, policy makers, regulators, smart grid manufacturers etc. and with other development aid agencies engaged in smart grid and Discom’s efficiency improvement.

20 https://home.kpmg.com/ca/en/home/industries/energy/energy-centers-of-excellence.html 21 https://home.kpmg.com/in/en/home/events/2016/10/enrich-2016.html 22 http://pib.nic.in/newsite/PrintRelease.aspx?relid=130518 23 https://home.kpmg.com/in/en/home/services/infrastructure-and-government-services/government-advisory.html

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5. Is the company only or primarily looking for procurement opportunities or money from USAID?KASPL is not seeking this partnership for money or procurement from USAID. Bulk of the program cost is financed by EESL. This partnership can facilitate expansion of markets for several Smart Grid, EV and utilities’ efficiency improvement technologies that have so far faced multiple barriers to entry in the Indian market. USAID, with its extensive experience in accelerating deployment of clean energy and electricity distribution sector innovation technologies in India, can use its financial and technical resources to strengthen this utilities transformation program.

6. Is the company willing to engage with USAID in a transparent manner without expecting an exclusive relationship (i.e., barring competitors)?KASPL is not expecting an exclusive partnership with USAID.

7. Is the company willing to accept limitations on the publicity (i.e., press and media coverage) of the alliance so as to ensure that USAID is not perceived to be endorsing the company or its products and services?KASPL understands that the program must follow USAID branding and marketing practices. The company complied with press and media coverage rules laid out by USAID in the PACE-D TA program also and is well versed with USAID branding practices.

B. Social Responsibility

1. Is the company primarily involved in the manufacture or sale of firearms or narcotics, i.e., involvement in these activities constitutes a significant share of company’s total portfolio?The company is not involved in the manufacture or sale or handling of firearms or narcotics.

2. Does the company have a good reputation (no serious red flag issue areas), especially in areas of corporate social responsibility (CSR)? In the case of new companies or companies with past CSR troubles, are they committed to instituting/improving a sound CSR policy?As part of its CSR activities, KASPL has founded Corporate Citizenship programme in 2014 with the aim of making a difference and leaving a mark on impressionable lives of leaders of tomorrow through education. For instance, their Aspire programme benefited over 180 girls across five schools during 2016. Through Enactus, 40 partners and senior staff mentors had the opportunity to guide students from over 50 colleges across the country.

KPMG has chosen to focus on the Sustainable Development Goal (SDG) 4 – Quality Education, as their global Corporate Citizenship priority. Seeing the critical role that

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education plays, KPMG has a clear commitment to Lifelong Learning and empowering next generation leaders. Their programmes range from investments in early childhood development, higher education, entrepreneurship and business skills.

3. Does the company have policies barring harmful child labor or forced labor?The company does not employee children.

4. Does the company have a non-discrimination policy governing the hiring and promotion of minorities, women?The company’s hiring, promotion, job assignment and compensation policies are merit based. It does not discriminate because of race, color, religion, sex, national origin, age or disability. Recruitment of people with disabilities and women is encouraged in the company.

5. Is the company accepting of unions or attempts to organize a union?KASPL does not have a union of employees.

6. Does the company have a health and safety action plan for workers, including the handling of hazardous materials and the prevention of environmental accidents?The company has H&S policy covering health related matters which are applicable to their operations. The company provides health insurance to all regular employees. Leave allocation is as per industry standards. Training sessions and other forms of written communication are used to inform employees about workplace related health and safety issues.

7. Does the company have a policy for codes of conduct, labor standards?KPMG has a comprehensive Code of Professional Practice and Conduct to promote lawful and ethical behavior by all employees. Issues covered within the code include professional & personal code of conduct, prevention of sexual harassment at workplace, policy with regard to misconduct, data privacy protection policy, social media policy, diversity and inclusion, etc.

Specifically in relation to anti-bribery and corruption, the Code commits KPMG to: Act lawfully, ethically and in the public interest; Prohibit bribery and corruption by our people; Not tolerate illegal or unethical behavior by our clients, suppliers or by public officials;

and Follow high standards of ethical conduct around the world including aspiring to the ten

principles of the UN Global Compact (including anti-bribery).

KPMG is a signatory of the UN Global Compact since 2002, as well as being a signatory of the World Economic Forum’s Partnering Against Corruption – Principles for Countering Bribery.

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KPMG also has policies on performance management and learning & development that encourages its employees to continually acquire and update their professional skills

C. Environmental Accountability

1. Does the company collect and evaluate adequate and timely information regarding the environmental, health, and safety impacts of their activities?The company collects and evaluates information regarding environmental, health and safety impacts of processes/ activities affecting the health of its employees.

2. Does the company set targets for improved environmental performance, and regularly monitor progress toward environmental, health, and safety targets?The company sets targets for improved environmental performance and regularly monitors the progress towards environment, health and safety targets.

3. Does the company assess, and address in decision-making, the foreseeable environmental, health, and safety-related impacts associated with the processes, goods and services of the enterprise over their full life cycle? Does the company provide the public and employees with adequate and timely information on the potential environment, health and safety impacts of the activities of the enterprise?Company’s activities have a positive impact on the environment, as it is not engaged in the manufacturing of any products. Core business areas of the firm are Tax, Advisory, and Infrastructure Government and Healthcare. KPMG does estimate the environmental impact of products or materials at the workplace.

4. Does the company maintain contingency plans for preventing, mitigating, and controlling serious environmental and health damage from their operations, including accidents and emergencies; and mechanisms for immediate reporting to the competent authorities?In this respect, the company follows international best practices in its operations and workplace. KPMG maintains contingency plans for preventing, mitigating, and controlling serious environmental and health damage at its workplace. KPMG has a Physical Security Policy to provide a safe and secure working environment.

5. Does the company continually seek to improve corporate environmental performance, by encouraging, where appropriate, the adoption of technologies and operating procedures in all parts of the enterprise that reflect environmental best practices? Are its products or services designed to have no undue environmental impacts, be safe in their intended use, and be efficient in their consumption of energy and natural resources? Can they be reused, recycled, or disposed of safely?Yes, KASPL promotes environmental sustainability in the adoption of technologies and operating procedures in all parts of the enterprise.

6. Does the company have a green audit for environmental performance?KASPL does not have a green audit for environmental performance.

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7. Is the company ISO certified?KASPL has an ISO 9001:2008 and an ISO 27001:2013 certification and is also CMMi L3 certified.

8. Does the company have a natural habitats policy? A forestry issues policy?KASPL does not have a natural habitats or forestry issues policy.

9. Is the company free from regulatory lawsuits?KASPL has not been involved in any lawsuits.

D. Financial Soundness

1. Is the company a publicly traded company?. It is not a publicly traded company.

2. Does the company publish an annual report?KASPL does not publish an annual report.

3. Does the company have audited financial statements?The company’s financial transactions and revenues are audited annually by certified chartered accountants and no discrepancy has ever been reported.

4. Has the company been in business for several years?KPMG in India is the Indian member firm of KPMG International and was established on September 1993. KPMG Advisory Services Ltd., a sub-licensee of KPMG in India, is an Indian private limited company incorporated on 12-October-1999

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Attachment-3Partner Due Diligence Questionnaire: Energy Efficiency Services Ltd. (EESL)

A. Corporate Image

1. What is the company’s public image? Have there been any tensions between the community and the company?

Energy Efficiency Services Limited (EESL) was formed in 2009 and has created a niche for itself in the energy efficiency market in India since then. In this short span, EESL has strengthened the market for advanced energy efficient technologies and services. The company implements Indian government’s important energy efficiency programs. It is “one of the main implementation arms of the National Mission on Enhanced Energy Efficiency (NMEEE) as a part of “National Action Plan on Climate Change”.

EESL has a strong reputation in the international community. US Department of Energy, and its national laboratories, have partnered and exchanged information with EESL to devise strategies for enhancing energy efficiency in buildings and appliances. It has long term agreements with government and municipal agencies in India to assist them in implementation of large scale energy efficiency programs. International development agencies like DFID, KfW, GIZ, World Bank and ADB have collaborated with EESL to magnify the impact of their activities in India.

There is no evidence of any tensions between EESL and other stakeholders in the community.

2. Has there been anything in the media that would reflect negatively upon the company? If so, how has the company dealt with significant negative publicity?EESL programs and milestones are often covered in the mainstream media. The coverage is mostly positive.

3. Are there any pending lawsuits against the company?EESL is in not involved in any litigation.

4. Is the company looking solely for PR opportunities by aligning itself with USAID?EESL network with other players in the energy sector are very strong. EESL is a stronger brand in India than USAID. It does not need a partnership with USAID to enhance its public relations in India or US. There is no evidence that suggests that EESL has used the collaboration with USAID under PACE-D TA program for any such purpose.

5. Is the company only or primarily looking for procurement opportunities or money from USAID?

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EESL has committed a significant portion of its own resources to the proposed partnership and is not relying solely on USAID resources for implementing the program.

6. Is the company willing to engage with USAID in a transparent manner without expecting an exclusive relationship (i.e., barring competitors)?EESL is not expecting an exclusive partnership with USAID. EESL and USAID are already collaborating under the PACE-D TA program. EESL has been diligent in acknowledging USAID contributions to its initiatives on all public platforms for this program.

7. Is the company willing to accept limitations on the publicity (i.e., press and media coverage) of the alliance so as to ensure that USAID is not perceived to be endorsing the company or its products and services?As a government owned entity, it cannot seek any kind of endorsement from USAID for any its activities. There is no indication from the management also that it is anticipating an endorsement from USAID.

B. Social Responsibility

1. Is the company primarily involved in the manufacture or sale of firearms or narcotics, i.e., involvement in these activities constitutes a significant share of company’s total portfolio?It is not involved in the manufacture or sale or handling of firearms or narcotics.

2. Does the company have a good reputation (no serious red flag issue areas), especially in areas of corporate social responsibility (CSR)? In the case of new companies or companies with past CSR troubles, are they committed to instituting/improving a sound CSR policy?EESL’s Corporate Social Responsibility policy follows Section 135 of Companies Act 201324. This contains rules on CSR responsibilities. As per the policy, EESL’s CSR activities must focus on women empowerment, health, sanitation, drinking, water, education, and activities contributing towards environment sustainability. EESL has a three member CSR committee consisting of company directors and a CSR cell headed by the Company Secretary. EESL has considered applications from different sources to support various activities that fall within the purview of its CSR policy. This is documented in the annual reports of the company.

3. Does the company have policies barring harmful child labor or forced labor?There is no evidence of EESL supporting child or forced labor.

4. Does the company have a non-discrimination policy governing the hiring and promotion of minorities, women?

24 https://eeslindia.org/writereaddata/EESL%20CSR%20Policy.pdf Page | 25

EESL does not have a non-discrimination policy governing the hiring and promotion of minorities and women.

5. Is the company accepting of unions or attempts to organize a union?EESL does not have a union of employees.

6. Does the company have a health and safety action plan for workers, including the handling of hazardous materials and the prevention of environmental accidents?EESL has a comprehensive Environmental, Occupational Health and Safety and Social (EHSS) manual25. It does provide employees retirement income security benefits.

7. Does the company have a policy for codes of conduct, labor standards?EESL’s code of conduct places the responsibility of ensuring a workplace free of discrimination & harassment based on race, colour, religion, caste, age, gender, nationality, origin, disability, veteran status, or any other biases on its directors and senior management personnel. No evidence was found of harassment faced by EESL employees on these issues. EESL has also established anti-fraud and whistleblower policies26.

C. Environmental Accountability

1. Does the company collect and evaluate adequate and timely information regarding the environmental, health, and safety impacts of their activities?EESL maintains and continuously updates publicly accessible dashboards that record the energy savings and GHG emissions averted due to its projects27.

2. Does the company set targets for improved environmental performance, and regularly monitor progress toward environmental, health, and safety targets?EESL is a public-sector company created for expanding the energy efficiency market by using innovative strategies to circumvent financial, regulatory and institutional barriers. Its targets are frequently set by the government. These could be expansion of services in a new sector, introduction or promotion of a new energy efficient technology or supporting another agency in achieving its environmental sustainability targets. EESL monitors the energy savings resulting from its projects.

3. Does the company assess, and address in decision-making, the foreseeable environmental, health, and safety-related impacts associated with the processes, goods and services of the enterprise over their full life cycle? Does the company provide the public and employees with adequate and timely information on the potential environment, health and safety impacts of the activities of the enterprise?

25 https://eeslindia.org/writereaddata/EHSS%20Manual%20for%20EESL.pdf 26 https://www.eeslindia.org/EN/Home/eesl_policies 27 http://slnp.eeslindia.org/

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EESL assess the environmental impact associated with products and services that it offers to clients. It only offers products and services that are efficient in energy use. Environmental impact of its services and products is conveyed through public platforms.

4. Does the company maintain contingency plans for preventing, mitigating, and controlling serious environmental and health damage from their operations, including accidents and emergencies; and mechanisms for immediate reporting to the competent authorities?Contingency plans for preventing or controlling environmental, health or safety hazard from EESL operations are contained in the legal contract between the company and its clients. EESL is usually responsible for controlling or mitigating these three issues in projects where it is providing services for enhanced energy efficiency. In case of products, this responsibility is transferred to the manufacturer or vendor from which EESL purchases the products.

5. Does the company continually seek to improve corporate environmental performance, by encouraging, where appropriate, the adoption of technologies and operating procedures in all parts of the enterprise that reflect environmental best practices? Are its products or services designed to have no undue environmental impacts, be safe in their intended use, and be efficient in their consumption of energy and natural resources? Can they be reused, recycled, or disposed of safely?EESL does procure energy efficient products from third parties. In such cases, the company stipulates stringent standards for energy and environmental performance of equipment purchased for its programs. Environmental sustainability standards to be adhered to are specified in its tender documents. Compliance with these standards is non-negotiable. These products or their parts are frequently recyclable. The company continuously expands its portfolio of services into new sectors and technologies.

6. Does the company have a green audit for environmental performance?EESL does not have a green audit for environmental performance.

7. Is the company ISO certified?EESL is not an ISO certified company.

8. Does the company have a natural habitats policy? A forestry issues policy?EESL does not have a natural habitats or forestry issues policy.

9. Is the company free from regulatory lawsuits?EESL has not been involved in any lawsuits.

D. Financial Soundness

1. Is the company a publicly traded company?

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EESL is a joint venture of public sector units (NTPC Limited, PFC, REC and POWERGRID) under Ministry of Power, Government of India. It is not a publicly traded company. Shares are owned by these public-sector units.

2. Does the company publish an annual report?Annual and half yearly reports published by EESL are available on the company’s website28.

3. Does the company have audited financial statements?Comptroller and Auditors General’s office appoints statutory auditors on a yearly basis for audit of the company’s financial transactions. Revenues and expenditure are also audited by internal and independent secretarial auditors.

4. Has the company been in business for several years?EESL was registered under the companies Act, 1956 on 10th December 2009 and the commencement of business certificate was obtained on 11th February 201029.

28 https://www.eeslindia.org/EN/investor_zone/annual_financial_reports/ 29 https://www.eeslindia.org/EN/rti/organization_particulars/

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