NephroPlus management program includes operational policies and procedures that are implemented at the facilities level by facility managers who report to the company?s management on a periodic basis. If monitoring results indicate nonconformance with standards or deviations from established benchmarks, appropriate corrective or preventive actions are initiated. While the existing system is adequate for the present scale of operations, as NephroPlus continues to grow rapidly, it will need to augment its management capacity by assigning additional staff and resources to provide continued oversight of its environmental and social performance across many states in India. 

National and Local regulatory requirements do not require NephroPlus to conduct a formal environmental and social impact assessment study for setting up its dialysis centers. However, as a part of permitting process for the setup and operation of healthcare facilities, the Company is required to assess and revise its designs/plans for various activities such as management of biomedical waste, fire safety and power back up etc., so as to comply with the stipulated requirements? thereby mitigating some key environmental and safety related impacts. Accordingly, NephroPlus has standardized design and safety features, which are adopted while designing all new facilities.

To ensure consistent service quality and safety standards across its network of dialysis centers, NephroPlus has developed several detailed operational manuals and procedures that conform to international best practice for the health sector. Standard operating procedures (SOPs) for tackling infectious spills, management of work related injuries, waste management, emergency response & contingency plan, fire prevention and control, etc. have also been developed by the company. Local regulatory requirements applicable to the Company operations vary across states in India. To keep track of compliance with permit conditions and regulatory requirements with respect to emissions and biomedical waste handling and disposal, the Company will maintain a legal commitment register for each facility and will develop a process for continual monitoring of compliance. 
	
Human resources are managed effectively at NephroPlus through the Human Resources Department. Training of staff is done on a routine basis in compliance with local regulations and is summarized in training manuals available to the staff. Facility managers are responsible to ensure that employees are adequately trained to perform their work safely and provide a high quality of service. Subcontractors are contractually obliged to have adequately trained workers and comply with NephroPlus' corporate standards.  NephroPlus has a monitoring program for health and safety that are managed in compliance with local regulations. Internal audits of health and safety procedures and of the facilities are conducted periodically with oversight of senior management.  Reporting requirements are consistent with national laws and regulations, and are used for continual improvement of training programs especially in health and safety.

As part of the Environmental and Social Action Plan (ESAP), NephroPlus will implement an Environmental and Social Management System (ESMS) to provide consistent oversight of environmental, social and health and safety for all its operations and sub-contracted tasks/labor. The ESMS will include a series of procedures, work instructions, and reference documents which, when combined with the findings of the E&S assessments, comprise a program of mitigation and performance improvement measures and actions necessary to effectively manage E&S risks and impacts of projects the Company undertakes.  Also, as part of the ESMS implementation program, NephroPlus will designate an individual on the management team of the Company to ensure continued compliance with company policies, procedures and regulatory requirements, and ensure consistency with good international industry practice for ESHS performance, including IFC Performance Standards and applicable guidelines. At the operational level, responsibility for the management of environment, health, safety and social performance will be assigned to a senior level staff at each of the facilities operated by NephroPlus. These positions will be adequately resourced and have overall responsibility for implementation of strategies, policies, standards, compliance, and management initiatives related to environmental and social matters at the Company.