JCM Power. The Environmental and Social Governance (ESG) Policy

Transcription

1 JCM Power The Environmental and Social Governance (ESG) Policy 21 St. Clair Avenue East Suite 500 Toronto, Ontario, Canada M4T 1L

2 Contents 1. Our Corporate Vision and Mission Our Core Values ESG Performance Standards... 3 Local ESG Performance Standards JCM s ESG Commitments Implementing the ESG Approach... 6 Organization... 6 Planning and Implementing... 6 Monitoring... 6 Reviewing... 7 Auditing... 7

3 1. Our Corporate Vision and Mission Our Purpose: Advancing the Clean Energy Age. Our Mission is to accelerate social, economic and environmental sustainability in growth markets through the development of renewable energy. 2. Our Core Values 1 P a g e

4 Sustainability 5X (financial, people, partners, environment, social): JCM Power is committed to five pillars of sustainability, namely: 1. Engagement with the community and developing lasting relationships with community leaders 2. Being good stewards of the local environment 3. Crafting long term financial win-win arrangements with our partners 4. Creating mutually beneficial partnerships with all stakeholders 5. Developing work life balance and fostering career growth with our staff Act Like an Owner JCM Power encourages its employees to be conscious of the impact of the company s decisions on investors, project stakeholders and community members. Where possible, our team mitigates risk through thorough strategic planning, and remaining up to date on current issues and market trends. Our financial team monitors our capital closely and prudently allocates capital to our various projects. Love What We Do Together JCM Power fosters an environment of teamwork and collaboration. We enjoy our work and appreciate it is for a larger purpose than ourselves. Each day we engage in meaningful work tackling one of humanities greatest challenges. Recognize and Respect Team Members JCM Power treats all employees fairly in terms of recruitment, progression, remuneration and conditions of work irrespective of gender, race, colour, language, disability, political opinion, age, religion or national origin. We enforce policies such as maintaining transparency and inclusivity through active listening and information sharing. Where possible, we improve each other through two-way feedback on a daily basis. Courage to do the Right Thing JCM Power encourages its employees to be leaders in the office and in the renewable energy industry. Our employees are required to complete an anti bribery and corruption training course and report unethical business practices. Pride in Execution 2 P a g e

5 At JCM Power, we take pride in delivering tasks on time and on budget. We trust our team members to take ownership over their work and deliver work to the highest quality standards. See and Seize Opportunities JCM values a team that is adaptable to changing environments, policies, regulations stakeholders and strategies. Where possible, JCM is constantly looking to evolve its business by adopting innovative solutions through new technology, finding new markets, building creative partnership structures, and business models. Continuous Learning and Improvement One of our founding principles is to remain open to new concepts. We create an environment that is cohesive to growth as our leaders coach others and our team remains coachable. Through our open environment, we foster a community of transparency and employees seek and share industry best practices. We use mistakes as lessons learned. Ask for help when you don t know! 3. ESG Performance Standards JCM s ESG objectives are: to identify and evaluate environmental and social risks and impacts in all projects; to promote improved environmental and social performance of clients through the effective use of innovative management practices; and to ensure that we build strong relationships with local communities. ESG Performance Standards In order to achieve sound environmental and social performance, JCM Power will adhere to a number of international policies and best practices. First and foremost, JCM follows the local laws and regulations required under each jurisdiction in which we develop, own or operate a renewable energy and/or transmission projects, including laws on host country obligations under international law. JCM abides by international labour standards and ensures that any partner, investee or other stakeholder will follow the same standards. JCM also ensures that its anticorruption and bribery policies are adhered to in every host country which conform to the big three regulators based in the UK, US and Canada. JCM applies International Finance Corporation (IFC) ESG performance standards to all of its projects. For clarity, the Performance Standards 1-8 developed by the IFC, establish the requirements of any project throughout JCM s investment period: Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts Performance Standard 2: Labor and Working Conditions Performance Standard 3: Resource Efficiency and Pollution Prevention Performance Standard 4: Community Health, Safety, and Security 3 P a g e

6 Performance Standard 5: Land Acquisition and Involuntary Resettlement Performance Standard 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources Performance Standard 7: Indigenous Peoples Performance Standard 8: Cultural Heritage JCM engages reputable third party international consultants to help ensure that we are adhering to these standards. JCM Power takes into account the impact of its operations on the local community and seeks to ensure that potentially harmful occupational health and safety, environmental and social effects are properly addressed and monitored. With consultative workplace structure in place, JCM provides opportunities for employees to present opportunities to Senior Management, and report any incidents that do not comply with ESG best practices and core values. 4. JCM s ESG Commitments JCM is committed to responsible investment and creating a positive sustainable impact for all of JCM s projects. In order to achieve our Purpose and Mission, JCM has developed the following ESG commitments: 1. Environmental Protection 2. Community Engagement and Stakeholder Consultation 3. Foster Long Term Relationships Founded on Inclusive Growth 4. Invest in Community-Driven Development 5. Be a Leader in Corporate Governance Commitment Objectives Operational Approaches Environmental Protection Community Engagement and Stakeholder Consultation - Ensure the minimum amount of disruption to environment and local ecology - To the extent possible make the net impact of the project neutral to the environment - Ensure the project is viewed positively by the community throughout the life of the project - Assess and minimise any negative environmental impact arising from construction and operations. Impacts should include not only impacts on habitat and wildlife, but also visual impacts, impacts related to the disposal of equipment, impacts from ancillary facilities and cumulative impacts - promote the rehabilitation of the environment wherever possible (i.e. to the extent trees are cut down, others should be replanted) - protect and minimize the impact on local ecosystems, habitat and wildlife - encourage the efficient use of natural resources - Minimize any adverse socio-cultural impact from land acquisition, project construction and operations, ancillary features and cumulative impact - Initiate a scoping study early in development to see affected individuals - Hire a Community Liaison Officer so any for grievances can be voiced and CDPs may be developed 4 P a g e

7 Foster Long Term Relationships Founded on Inclusive Growth - Train, educate, and employ locals when possible to ensure the local workforce sees benefits from having the project in their community - Regular contact with local leaders, State officials and regulatory agencies - Provide locals jobs during construction and operation - Build capacity through employment - Provide education/training programs when possible - Ensure equal opportunity amongst women and men Invest in Community- Driven Development - Provide relevant investments and infrastructure to communities in which we operate - Design Community Development Plans through stakeholder engagement and active consultation with locals - Focus on areas of highest need (i.e. water, healthcare, education, access to electricity) - Ensure each project has a sufficient budget for upfront set up costs and ongoing operations for the life of the project Be a Leader in Corporate Governance - To ensure honesty, integrity, fairness and respect in all JCM business dealings - To treat all JCM employees fairly and to respect their dignity, wellbeing and diversity - To be objective, consistent and fair with all JCM stakeholders - To minimize any adverse sociocultural impact from JCM s operations - To ensure that JCM makes a meaningful and significant contribution to the communities in which it operates - To work towards full compliance of JCM investments with the International Labour Organization Fundamental Conventions and with the UN Declaration of Human Rights - Comply with all applicable laws - Deal with regulators in an open and cooperative manner - Prohibit all employees from making or receiving gifts of substance in the course of business - Prohibit the making of payments as improper inducement to confer preferential treatment on the company, its agents or advisers - Properly record, report and review financial and tax information - Only use information received from its partners in the best interests of the business relationship and not for personal financial gain by any employee - Invest/partner in businesses which uphold high standards of business integrity and honesty - Prohibit contributions to political parties or political candidates - Require Employees, partners and investees to go through necessary training and sign the Anti-Bribery / Anti- Corruption Policy. - Pay wages which meet or exceed industry or national minimums and are sufficient to meet basic needs - Treat their employees fairly in terms of recruitment, progression, terms and conditions of work and representation - Allow consultative work-place structures and associations which provide employees with an opportunity to present their views to management 5 P a g e

8 5. Implementing the ESG Approach In order to achieve its ESG commitments, JCM has developed and implemented a structure comprising policies, organization, planning and implementation, monitoring, reviewing and auditing. During the planning phase, JCM conducts an environmental and social due diligence process, which will identify risks and impacts at a point in the future when the physical elements, assets, and facilities are reasonably understood. Organization Martin Ritchie, the Chief Risk Officer of JCM s Senior Management team, is responsible for ensuring the ESG commitments are met. JCM appoints regional heads that are responsible for overseeing the Developers and the day-to-day implementation of JCM s ESG commitments. She/he reports to the full JCM Management team during the Monthly Project Update meetings. Each Developer implements the ESG commitments at a project level with the guidance of international consultants. Planning and Implementing As an integral part of the project and investment appraisal process, JCM assesses the extent to which the investment is consistent with JCM s ESG commitments through the following process: 1. If JCM proceeds with an investment, JCM will develop an ESG implementation and impact assessment plan for each project to promote JCM s ESG commitments; 2. JCM will assist investee/partner companies in developing action plans to ensure compliance and address areas of non-compliance with JCM s ESG policies; 3. JCM encourages the managers of investee/partner businesses to adopt and implement its own ESG policies particularly where the business entails specific risks; 4. JCM works with the managers of investee/partner businesses to achieve continuous improvement in ESG Monitoring JCM identifies and monitors the risks and impacts of our projects at each phase of development. The monitoring process will consider all relevant environmental and social risks and impacts of the project, including the issues identified in Performance Standards 2 through 8, and those who are likely to be affected by such risks and impacts. JCM also considers the net positive benefit of renewable energy projects on the local environment and communities. The following steps are guidelines that JCM Power adheres to: 1. Monitor that occupational health and safety measures are carried out in accordance with international standards (e.g. IFC guidelines); 6 P a g e

9 2. Monitor that adverse impacts from construction and operations of our projects (e.g. erosion and sedimentation, waste disposal, hazardous materials) are being mitigated in accordance with international standards (e.g. IFC guidelines); 3. If applicable, monitor that any cultural heritage that may be found or affected during construction is treated in accordance with IFC P.S. 8; 4. Respond to and record community grievances; 5. If applicable, monitor adverse impacts to habitat and species impacts in accordance with IFC P.S. 6 and/or the Project s biodiversity management plan; 6. If applicable, ensure that temporary worker housing is constructed and maintained in accordance with IFC standards 7. Ensure that restoration of any disturbance during construction has occurred; Reviewing JCM Power has internal operational systems in place to review and enhance performance in line with best practices. Summaries of performance and development impacts are included in reports for funds and stakeholder partners for each region in which JCM is investing. Auditing JCM Power audits the implementation of the Commitments on an ongoing basis. 7 P a g e

10 JCM ESG FRAMEWORK Project Development Cycle Greenfield Development Project Permitting Financial Close Construction Operation Screening Scoping/Impact ESG Plan JCM ESG Framework - Location - Biodiversity - Technology - Social Impact - Stakeholder identification/ engagement - Potential Impact/Risk Analysis -Mitigation Proposal - Definition of who, what, when to manage impact - Planned activities to mitigate risk captured in Mitigation Plan - Ongoing monitoring - Proof of compliance Project Development Cycle Greenfield Development Project Permitting Financial Close Construction Operation Investee Asset/Evaluation Asset Lifecycle Management Plan ESG Implementation Sustainable Exit Planning JCM ESG Infrastructure Framework - Evaluate Project s compliance with JCM s Development Framework and Project Implementation and Monitoring Plan -- Ensure that an ESG Plan is prepared and implemented for full life cycle of the asset - Implementation of ESG Plan -Ongoing monitoring and measuring - Ensure that ESG Plan and practices are successfully transferred to long-term owners - Continuous dialogue with stakeholders to ensure ESG commitments are met 8 P a g e