Living in the Age of Disasters: From Multilateral to Bilateral Aid

Living in the Age of Disasters: From Multilateral to Bilateral Aid


In July 2013, I wrote an article titled The Business of Disasters in my column (w)Health Check ((W)Health Check | Kapil Khandelwal KK). The idea in the article was to encourage the corporate sector in India to innovate business models to manage disasters. (see the text of the article below). The world in the second decade of the twenty first century has witnessed all the types of disasters conceivably possible that has left behind deaths and devastation. A lot has been spoken and written on biological disaster during and post Covid-19 pandemic. The ability to impact these threats is beyond control of the people and more in the hands of the healthcare systems managed by the relevant Governments around the world. We should now discuss on the Geophysical and Hydro-Metrological Disasters where there is still lack of understanding.

The organizational set up and confidence in the multilateral agencies has definitely been dented. What alternatives does the world have now to face the incoming disasters?

Global Maps of Geophysical and Hydro-Metrological Disasters

The global map of Geophysical and Hydro-Metrological Disasters provides that not the regions around the world are at mortality risk of such disasters.

Global Map of Mortality due to Floods and Earthquakes
Global Map of Mortality due to Floods and Earthquakes

There are many prediction models available to inform where these disasters will hit next with a fair amount of accuracy. Therefore, unlike biological disasters which are hard to predict before they strike, there is a measure of preparedness that is possible to manage Geophysical and Hydro-Metrological Disasters when they strike. Still the multilateral agencies have not been preparing to meet these eventualities.

Lessons from Recent Disasters

Biological Disaster: Covid 19 Outbreak

During the Covid-19 outbreak, we have witnessed how global multilateral organisations like the World Health Organisation (WHO) were incapable of dealing with the situation that the then US President Donald Trump decided to pull out of the WHO as its major sponsor. Moreover, the manner in which the WHO approved the covid vaccine and its effectiveness is now out. As a result countries like India has to suffer in releasing its vaccine to its own people or supply it globally. Months later release of other countries vaccines, did India supply its more effective vaccine to over 100 countries on bilateral basis. But the delay India faced by WHO for approval of its vaccine lead to flooding of ineffective vaccines.

Geophysical and Hydro-Metrological Disaster

Recently earthquakes and floods which have hit several countries, the multilateral agencies such as International Red Cross were not capable enough to handle the devastation. As a result, many countries have responded to the disaster based on their relations with the devastated country. Turkey earthquake is an example. We still do not know what is going to happen. But major first responders to such countries were on bilateral basis. Here also India responded to Turkey’s request by sending its National Disaster Response Force (NDRF) teams. It’s another issue that Pakistan did not allow Indian aircraft passage through its airspace to reach Turkey faster.

Rise of Bilateralism and Its Risks

Since late 2010s, the financial support received of the member countries to the multilateral countries has been gradually reducing. They have been stretched to maintain their administrative budgets versus funding disaster management operations.

The additional capacity for disaster management which strikes countries in one stroke of nature, lies with other countries in limited measure as multilateral agencies are not adequate enough to handle to situation. These capabilities when aggregated would barely be sufficient to manage the crisis through the disaster. Let’s also understand that bilateral aid and support by other countries is motivated by diplomatic relations and ties. The current Turkey and Syria earthquake demonstrates this vividly. Turkey got the majority of the bilateral aid and support while Syria was not. Another example is the great floods in Pakistan where India’s aid was not requested nor India provided it. Moreover, much of the aid that Pakistanis received was never delivered to the people suffering. This acerbates the plight of the people suffering in these disasters. Therefore geo-political considerations come into play to support disaster management bilaterally. This brings to the point of the risks of rising bilateral flow of disaster management aid, support and services to countries in disaster. Some of these include:

  • Bilateral aid and support may come with the strings and expectation of support to the doners by the receivers in international politics, trade and commerce at a later stage
  • The aid and support may not be fairly distributed across the political boundaries which are impacted
  • Like many aid projects that I have worked in Africa, end abruptly as soon as the crisis is stabilized. The longer-term rehabilitation is not considered in bilateral aid and support. The same may be true in current Turkey-Syria earthquakes.
  • These incidents also become an opportunity to debt trap the countries which are financially and economically week. Pakistan is a case in point after the floods to Chinese debt-trap.
  • The checker board of international diplomacy in such circumstances may create more tensions for the donors in the future when other countries compare the situation in their own backyard when it had occurred and who stood up to support them bilaterally.
  • Political unrest in the donor countries over bilateral support to other countries provided.

Given these risks, would it not be prudent to organize private enterprise business models with innovative financial models to sustain these businesses (see my article below). These were initial thoughts in 2013 by me. But given the frequency of disasters the world and its countries are facing, it become evident that rather than expecting bilateral aid and support, the fully life cycle of disaster management can be managed by private enterprises with full disclosures and accountability. Many ESG and impact funds would definitely invite such ideas of such private enterprises.

Article: The Financials of Disasters

It is time for the corporate sector to take over disaster risk management and disaster medicine in India


Probably the greatest concentration of pilgrims in any region in the world occurs in India’s mountain regions of Himachal Pradesh, Uttaranchal and Uttar Pradesh, where 9.3 million pilgrims each year arrive at the major entry point into the Pahari region. Between 2001 and 2010, the number of visitors to the state rose nearly 200 percent to 30.3 million. Major Hindu shrines located in the state, about 70 percent of the tourists who visit the state visit religious sites. However, last months pilgrim disaster in Uttarakhand with the search and rescue operations for the pilgrims needs to be reviewed. With large-scale politicking, drama and oneupmanship by the political parties in the aftermath of the disaster, requires an assessment on the failure of the government in providing services in such situations and leaves me wondering on the areas where different business models can be operated by the private sector in the health and well being of people in such situations.

1.       Sequence of a disaster: “befores”, “durings” and “afters”.

2.       Triggering events and coupling causes.

3.       Large-scale damage to human life and environment.

4.       Large economic costs.

5.       Large social costs.

6.       HOT (human, organizational and technological) and RIP (regulatory, infrastructural and preparedness) factors.

7.       Multiple stakeholder involvement and conflict.

8.       Immediate and longer-term responses.

9.       Crisis resolution attempts.

10.    Focus on symptoms not causes.

What is Disaster and Disaster Medicine?

A disaster is not a “crisis” in the traditional meaning of the word – a situation in which important decisions involving threat and opportunity have to be made in a particularly short time – rather, disasters involve management procedures which must be maintained and management problems coped with under conditions of major technical emergency involving threats of injury and loss of life. (See Box). There are two types of disasters – natural and technological disasters. Natural disasters include three specific groups:

  • Hydro-meteorological disasters. Including floods and wave surges, storms, droughts and related disasters (extreme temperatures and forest/scrub fires), and landslides and avalanches.
  • Geophysical disasters. Divided into earthquakes and tsunamis and volcanic eruptions.
  • Biological disasters. Covering epidemics and insect infestations.

The technological disasters comprise three groups, which are:

  • Industrial accidents. Such as chemical spills; collapses of industrial infrastructures; explosions; fires, gas leaks; poisoning; radiation.
  • Transport accidents. By air, rail, road or water means of transport.
  • Miscellaneous accidents. Collapses of domestic/non-industrial structures; explosions; fires.

The effects of theses disasters can be view on health and well being from five different perspectives. These include:

  • preparedness and availability of medical and health facilities, services, personnel and equipment;
  • immediate casualties and deaths caused by the disaster;
  • secondary illness and deterioration of health conditions following the disaster;
  • destruction or damage to medical and health centres and services;
  • response capability of the health services and the capacity for post-disaster recovery.

The response to health problems of such magnitude, under adverse and literally catastrophic conditions, cannot be sufficient with mere emergency medicine or just the provision of relief. Disasters, particularly the one in Uttarakhand are not merely very large accidents; they involve complex public health issues and health management problems at a time when the normal coping mechanisms are disrupted or even out of action. In recent years, the health profession has, to this end, developed new approaches and a new discipline now referred to as “disaster medicine”.

Disaster Medicine is the study and collaborative application of various health specialties – e.g. paediatrics, epidemiology, communicable diseases, nutrition, public health, emergency surgery, military medicine, community care, social medicine, international health – to the prevention, immediate response, humanitarian care and rehabilitation of the health problems arising from disaster, in cooperation with other non-medical disciplines involved in comprehensive disaster management.

In case of floods like that in Uttarakhand the risks of infectious diseases and of malnutrition are real, and the necessary personnel, medicine and supplies should be geared to those needs.

Different Business Models and Opportunities Addressing Disasters in India:

With the occurrence and intensity of disasters increasing in India, there are several business models that we can look as. This is not an exhaustive assessment of the opportunities, but an initial map that can be used to build on to the same.

Pilgrimage Travel/Health Advisory Services

There is no risk rating and advisory services in India that provides travellers with information in the risk rating at different times of the year or on a general travel situation. There are no personalized services that provide information and questions to pilgrims health, security, medical information such as vaccination requirements, infectious diseases common in destinations, food and water safety, and tips on staying healthy while on pilgrimage. Also there are no travel information on emergency medical and other support services. Private weather forecasting and advisory business models do exists. This can be an extension to their business.

Personalised Emergency Medical Care and Evacuation

Membership based services for providing emergency medical care and evacuation is the need of the hour.  The services should include evaluation, airlifting, trauma management from the disaster. The services should be followed by consistent protocols with coordination and rapid. One of the areas where a centralized control room which can co-ordinate with the victims and their family members is an essential part of the service. In case of international pilgrims, the service should provide assistance with passport documentation and visa clearances during emergencies, so that the border transits can be smooth.

Specialised Hospitals near the Disaster Zone

With the intensity of disasters increasing in occurrences, there is an opportunity for setting up small specialized hospitals that can cater to the disasters in a specialized way and can be an extension for the supply chain and logistics to the operations in the disaster zone. These hospitals can provide medical equipment, pharmaceuticals, and medical consumables to remote site support.

Medical College in Disaster Medicine in India

There are several institutes of excellence in India that provide courses and degrees in disaster management. However, like the US where there is a board of disaster medicine with special curriculum and licensure of working professionals in this field of medicine, there is no medical college or National Center of Excellence in India providing UG or PG courses. India can well be served by this branch of specializing doctors from a recognized Center of Excellence in Disaster Medicine.

A Public-Private Corporation for Disaster Risk Management

India is one of the countries that consistently ranks amongst the top-5 countries in the world where most of the disasters strike. The lack of faith in the state government of Uttarakhand by the faithful devotees of other states and independent operations by individual state governments to search, rescue and airlift the victims itself gives rise to the business of disaster risk management that could be outsourced to an independent company by these state governments rather than political oneupmnship! On a serious note, other countries that are as disaster prone as India such as Phillipines have used public-private partnerships to disaster risk management using community participation and consistently reduced disaster risks year on year! This will not only create employment opportunities in the community, but also infrastructure and logistics to handle risk mitigation measures on a real time basis.

Some Interesting Business Models in Place

There are some very interesting business models in place for disaster risk management around the world in operation. Some of the ones that need a mention are as under:

Reuters Alertnet:

AlertNet is a free humanitarian news service run by Thomson Reuters Foundation covering crises worldwide. The award-winning website provides news and information on natural disasters, conflicts, refugees, hunger, diseases and climate change.

International SOS:

International SOS is the world’s leading medical and travel security services company. Their enterprise services help organizations protect their people across the globe. Our teams work night and day from more than 700 locations in 76 countries.

Doctors Without Borders

Médecins Sans Frontières (MSF) is an international medical humanitarian organization created by doctors and journalists in France in 1971. Today, MSF provides independent, impartial assistance in more than 60 countries to people whose survival is threatened by violence, neglect, or catastrophe, primarily due to armed conflict, epidemics, malnutrition, exclusion from health care, or natural disasters. MSF provides independent, impartial assistance to those most in need. MSF also reserves the right to speak out to bring attention to neglected crises, challenge inadequacies or abuse of the aid system, and to advocate for improved medical treatments and protocols. In 1999, MSF received the Nobel Peace Prize.

Reflecting Forward

The events that have unfolded in the face of disasters in India require execution and not politicking. It is time private enterprise take over where Government has failed to deliver just like main stream healthcare to the masses, it is time for taking over Disaster Risk Management and Disaster Medicine in India.

Budget 2022: When is Healthcare’s Amrit Kaal Coming?

Budget 2022


On 1 February 2022, our Hon. Finance Minister presented her fourth budget in the Parliament and introduced the “Amrit Kaal” in Point 4 of her speech, “we are marking Azadi ka Amrit Mahotsav, and have entered into Amrit Kaal, the 25-year-long leadup to India@100. Hon’ble Prime Minister in his Independence Day address had set-out the vision for India@100.”

Point 5 of the Budget Speech outlined the vision for Amrit Kaal, “By achieving certain goals during the Amrit Kaal, the government aims to attain the vision. They are:

  • Complementing the macro-economic level growth focus with a micro-economic level all-inclusive welfare focus,
  • Promoting digital economy & fintech, technology enabled development, energy transition, and climate action, and
  • Relying on virtuous cycle starting from private investment with public capital investment helping to crowd-in private investment.

The Finance Minister has envisioned to develop ‘sunrise opportunities’ such as artificial intelligence, genomics, and pharmaceuticals to assist sustainable development and modernise the country. However, this is more on the supply side industrial development. But the core issue of healthcare infrastructure is not addressed. Envisioning the Indian population which we would like to be a healthy one by 2047 when we enter India@100. I believe that Budget 2022 missed out a huge opportunity in envisioning Healthcare 2047! Here are my reasons.

Current Undergoing Transformation in Healthcare

The country has undergone a tough time during the pandemic. The Government has played its enabling role in ensuring the supply chain disruptions with China does not lead into a health crisis of sorts. On the other hand, the funding of Covid-Vaccine and immunization has ensured that the country emerges quickly into an endemic phase of Covid pandemic. While this was going on, there was strengthening and upgrade of the digital health infrastructure. The pandemic has also taught lessons to the private healthcare delivery ecosystem to restructure their business models and ensure that there is a push toward lower costs healthcare delivery models. These transformations have demonstrated India’s resilience in its healthcare systems to face emergency situations like the current pandemic.  

India’s Amrit Kaal’s Population Demographics

As the chart below demonstrates that India’s population by 2047 will be shifting towards middle age bulge. Over 300 million (~19% of the total population) will be senior citizens by 2047. Our dependency ratio will be around 40%. These 40% will be in the tax paying bracket which will provide the then Finance Minister in 2047 the revenues to spend for different welfare programs including healthcare.

India's Population Pyramid Shifts to 2047
India’s Population Pyramid Shifts to 2047

Lessons from Elsewhere in the World

In early 2000, I was involved in restructuring the healthcare systems of Saudi Aramco. Being the largest oil producer in the world, the company had been underfunding the pension and healthcare benefits of their employees who were going to be retiring in the future. The financing of these healthcare benefits created a financial crisis of sorts which have to be funded.

USA has also being facing such challenges when its baby boomers have now become unproductive senior citizens and their total healthcare bill is currently 18% of their GDP.

Vision for India’s Amrit Kaal Healthcare Delivery to Avoid Maha Kaal

As per current estimates, our country requires USD 400 billion of investments in healthcare infrastructure on our current demography to meet the global norms. There are no allocation in the current National Infrastructure Pipeline (NIP) funding for healthcare. Therefore much of the investment will be private sector driven in the future for healthcare infrastructure.

Such experiences elsewhere in the world remind me that our Amrit Kaal in 2047 does not end up as Maha Kaal of our Amrit Kaal where we would have to look up to Indian Gods who were invoked to end the situation. There have been several demands in the last few budget to accord infrastructure status to the healthcare industry. The current budgetary allocations to healthcare all though increasing has not been sufficient to build capital formation for healthcare infrastructure in the country. From the current 2.5% of GDP, there needs to broaden the spend on healthcare. We need the real picture of the input and outputs in healthcare. With the current GST regime of zero tax on healthcare services, we are not able to gather the real value of healthcare in the country and healthcare should be under minimum GST slab so that there is pass through benefits of the inputs that are set off. This will lead to a lot of transparency and provide real hard estimates of healthcare spend of the country.

Assuming by 2047 our dependency ratio will be lower than today. Which means that the total taxpaying population in 2047 may be same as today or even lower. There needs to be a plan to ensure that current taxes from the current population who will become senior citizens by 2047 will be underfunded like in the examples that I have mentioned below, leading into a budgetary crisis.

In all earnest, given the current constraints the current budget 2022 could do so much for healthcare. But now that the Amrit Kaal is out of the bag, there needs adequate focus to healthcare to avoid healthcare Maha Kaal in 2047 when we enter India@100.

Our Recommendations on the Working Group Report on Inclusive Regulatory Framework for Social Stock Exchange (SSE) in India

Cover Letter to SEBI Social Stock Exchange Working Group

Shri Ishaat Hussain

Chairman, SEBI Social Stock Exchange Working Group

Plot No. C 4-A , G Block, SEBI Bhavan, Bandra Kurla Complex, Bandra East,

Mumbai – 400051

Dear Sir,

Re: Our Recommendations on the Working Group Report on Social Stock Exchange (SSE)

At the outset we would like to congratulate you and the working group and the SEBI team along with the external agencies that have worked on drafting the regulations for the SSE for the nation. We believe that a SSE would lead to widening the investor base and also bring to fore the impact investments into this country. We had been involved in discussions with SEBI even before the formation of the working group and provided inputs on what should be the nature of the regulations to guide the investments in the healthcare industry in India.

We are India’s first healthcare infrastructure fund under SEBI AIF-II regulations. We propose to list our fund as a Healthcare REIT. We have therefore focused our note on the issues with respect to healthcare only. As healthcare is a social infrastructure, we and our limited partner and investors believe that a regulation from the SSE and its inclusive definition would go a long way in bringing to the fold of the investment ambit healthcare infrastructure which is being operated under trusts and societies. In addition, we believe that the measurement of impact for healthcare is not only primary but also secondary level. As part of our note we have outlined our recommendations which would be inclusive in nature and would appreciate be considered into the working draft recommendations.

Our review and recommendations for the draft regulations are under the following heads:

  1. All encompassing definitions of operators/players in the social sector
  2. Increased definition of scope of impact which are acceptable by ESG and impact investors
  3. Sustainability and limitations of grants and aids for social projects
  4. Wider inclusion of Alternative Investment Funds (AIF) and relaxations of various limitations under SEBI AIF Regulations
  5. GST waivers and set offs for the social sector like healthcare infra
  6. Regulations for social sector ventures for social credit rating
  7. Sale and lease back for infrastructure under the trusts and societies for asset monetization
  8. Listing and trading norms for wider market participation on the SSE including market making
  9. Participation of CSR funds into healthcare infra
  10. Special purpose vehicles (SPVs) listing of healthcare PPPs with community and social impact
  11. Regulations for pivoting from for profit to not for profit and vice versa and exit for failed ventures
  12. Other regulatory issues

Further, this note may not have been possible during the times of Covid, with inputs and efforts put in by our limited partner who are multilateral agencies, impact and ESG funds, sovereign

funds and several family office investors from India and abroad. We would like to also mention the efforts of our legal counsels Khaitan & Co, Mr. Siddharth Shah, Mr. Divaspati Singh and Mr. Anindya Roy who have worked in compiling the recommendations together into this note. Along the way, I had spoken with several institutions and industry bodies, both in impact and healthcare, in the country for their views. I thank them for their candid views and observations in framing the guidance to this note.

Once again, thank you all for your time and contributions to giving this nation a strong and robust social investment regulations, guiding path and the way forward. I would appreciate if we can be given a chance to discuss the various points outlined in our note.

Awaiting your response.

Stay Safe

With Warm Regards,

Kapil Khandelwal

Toro Finserve LLP

Managing Partner


The establishing of the Social Stock Exchange in India (SSE) is a positive step in the creation of a vibrant capital markets for the social sector. The Working Group Report published by SEBI for the public consumption and response has been reviewed by us and we offer our feedback which we have taken from our investors (some of them are impact and global multilateral funding agencies). We would like to offer our recommendations and inputs for consideration.

Healthcare in India with focus on the Charities and Impact Organisations      

India lags behind on several parameters on SGD-3. One of the reasons is the lagging investments in healthcare infrastructure and spending. On the issue of donor led spending, the participation by donors and external agencies in healthcare has increased from 0.01% of GDP in 2009 to 0.03% of GDP in 2016. The overall healthcare investments through PE/VCs in India is around USD 5.3 bn till June 2018 making it the third largest sector after ICT and BFSI sectors.

Of the total hospital beds in India, 40% of the hospital beds in India are provided by Government (and allied organisations), approximately 5% of the beds are charitable and or subsidized in medical colleges teaching hospitals. A large proportion of these charitable beds are in urban areas which are provided by for profit sector in lieu of concessional land. A recent press report stated that in Mumbai around 89% of the charitable beds earmarked for not-for-profit remained unoccupied during Covid-19.

An article publish in VC Circle by Toro Finserve LLP estimated the healthcare spend on the BoP in India which could translate through the social ventures servicing this population is estimated to be around $1 trillion by 2025 across all products and services for healthcare. The expected healthcare investments to be around $275-350 billion in infrastructure gap funding. The addressable social ventures that would qualify to be listed on the SSE would potentially deliver an annual turnover to be around $5 billion on a conservative basis.

The above estimates would remain elusive unless an inclusive regulatory framework is adopted for the social stock exchange in India and is an attractive proposition for our impact and ESG investors from abroad which is attractive for them to participate.

Over and above, the impact to SGDs and incremental social healthcare capacity creation in India, an inclusive regulation will also lead to:

  • Direct and indirect employment in the healthcare and allied infrastructure creation sector
  • Provision of long-term, perpetual capital to the healthcare infrastructure development
  • Economies of scale of many operators platforms to take them to IPOs and provide investor liquidity
  • Increased investment in newer innovation and clinical solutions to provide healthcare cheaper, better and faster
  • Adequate investment in technology to provide digital health and create smart hospitals
  • Reduced costs and improved quality of healthcare delivery to the masses without any burden on the healthcare operators to repay bank and NBFC debts
  • Creating of Healthcare REIT/InvIT as a separate investment asset class for channelising domestic and foreign investment which has been lagging for the last 4 years despite positive policy initiatives

Inclusive Regulatory Framework for Social Stock Exchange

Our review and recommendations for the draft regulations are under the following heads:

  1. All encompassing definitions of operators/players in the social sector
  2. Increased definition of scope of impact which are acceptable by ESG and impact investors
  3. Sustainability and limitations of grants and aids for social projects
  4. Wider inclusion of Alternative Investment Funds (AIF) and relaxations of various limitations under SEBI AIF Regulations
  5. GST waivers and set offs for the social sector like healthcare infra
  6. Regulations for social sector ventures for social credit rating
  7. Sale and lease back for infrastructure under the trusts and societies for asset monetization
  8. Listing and trading norms for wider market participation on the SSE including market making
  9. Participation of CSR funds into healthcare infra
  10. Special purpose vehicles (SPVs) listing of healthcare PPPs with community and social impact
  11. Regulations for pivoting from for profit to not for profit and vice versa and exit for failed ventures
  12. Other regulatory issues

All encompassing definitions of operators/players in the social sector

The current definitions as given in the report delineates between not for profit and for profit. There are no shades of grey (hybrid models of business) in the draft regulations.

We would like to submit that the definition of a social enterprise should ideally, seek to select a class or category of enterprises that are engaging in the business of “creating positive social impact”. It is our belief that the definitions should be all-encompassing requiring all social enterprises, whether they are FPEs or NPOs, to state an intent to create positive social impact, to describe the nature of the impact they wish to create, and to report the impact that they have created; and the differentiation should not be solely on the criteria of muted returns. There can be various hybrid models created by combining characteristics of both an FPE and an NPO. In our view, the current distinction as provided in the report does not afford enough flexibility to encompass all such possible models. The parameters of what constitutes a ‘positive social impact’ should be inclusive in nature and only by taking such a holistic view of the SSE could we hope to address the issue of the funding gap that this mechanism is expected to resolve. Given the ambiguity around the definitions, the SSE regulations must provide standard definitions to determine whether the model will predominantly provide space for non-profits or for-profit organisations or other hybrid structures.

For example, even schedule VII of the Companies Act uses the words “activities which may be included by companies in their Corporate Social Responsibility Policies” to indicate a list of exhaustive items which may be consider within the ambit of CSR activities by companies. In comparison, both the SASIX in South Africa and Singapore’s Impact Investment Exchange – prescribe social impact to be measured by the outcome in the community and not on muted returns.

In our view, the SSE should have a clear definition of what constitutes a ‘social cause’ and a ‘socially responsible’ act. The definition should also be dynamic to accommodate events that may emerge, such as Covid-19, or cyclone, that would require area-specific funds. We would further submit that the SSE should allow the listing of various assets encompassing a wide array of sectors such as healthcare, education, food, healthcare assets, colleges, schools, minimum development goals etc. This would inject a much needed impetus to overall social development by providing additional fund raising options in these sectors. It would also allow existing investors to offload their assets by listing on the SSE and utilise the money for other viable purposes ensuring a wholistic growth in the economy. Therefore, it is our submission that the ambit of social impact should be kept as broad as possible delineating between FPEs and NPOs, in order to truly enable holistic social development.

Increased definition of scope of impact which are acceptable by ESG and impact investors

Investment into healthcare social infrastructure not only creates bed capacity for population health management and impacting SGDs, but creates various axis of social impact for the Indian economy. These include the following when considering the direct and indirect impact of investment in healthcare infrastructure development that have been accepted by many of our ESG and impact investors as benchmarks:

Table deleted from here due to confidentiality reasons

We therefore submit that the scope of primary and secondary impact to the community needs to be defined into the draft report

Sustainability and limitations of grants and aids for social projects

During my work with the health and ICT Ministers’ Panel for Africa, one of the key fundamental drawback felt by the Governments was that 95% of the projects initiated by donors through grants and aid failed to sustain themselves through the self-funding by the communities once the donor’s grants and aids completed their tenure. The issues project completion and impact post grants and continued funding became very critical. Another issue was the measurement of the impact post exit of the donors. Social healthcare infrastructure project need sustainable upfront funding which need to be closed else projects would not complete

Hence, the scope of grants and aids should be tied to the overall project costs and operations till viability is establish. The regulations need to provide tighter norms for projects funded through grants and aid and not be allowed to kick off till funding closure is announced.

Wider inclusion of Alternative Investment Funds (AIF) under SEBI Regulations

The current draft talks about the AIF -1 Social Venture Capital. As India’s first healthcare infrastructure fund, we are registered under AIF- 2 regulations. We propose to exit the investments we make in for profit and not for profit and select hybrid models with impact in hospital infrastructure, we would like to understand the split between and investment criterial for listing of Social Healthcare REITs on SSE and for profit healthcare REITs on the NSE. We have evaluated the Singapore model. It creates flexibility on price discovery and is not so water tight.

It is submitted that even Category II AIFs may invest in social sectors and cause overall social impact and therefore even such AIFs should be allowed to be listed on the SSE. Here it is our submission that the regulators should consider either designing a general framework of pooling for this purpose which will apply across all regulations, whether AIFs (Cat1, 2 or REITs), or in the alternative create a special class of AIFs for social impact. from a regulatory point of view, that a new category of AIF structured similar to a ‘social venture fund’ may be introduced – the criteria for determination of which would correlate with its positive spillover effects on the economy. Such new class of AIFs should have the benefits of pooling coupled with the flexibility of investing in an identified asset and should be free from the limitations of diversification norms otherwise applicable to other AIFs.

AIFs have the potential to become the best source of additional capital to undertake the desired projects in the social sector given the overwhelming need for additional capital in such sectors in India. To reiterate, under the SEBI AIF regulations, Category I and II Alternative Investment Funds are prohibited from investing more than twenty five percent of their investible funds in one Investee Company. Which is restrictive in itself in the context of social upheaval as it does not provide the flexibility to invest more capital in a single project as may be required. We would humbly request for this restriction to be relaxed in case of a Cat I or Cat II AIF which is eligible to be listed on SSE or provide an exemption from the aforementioned 25% limit to the new category of AIFs specifically designed for this purpose.  

GST waivers and set offs for the social healthcare infra

The current draft has discussed on tax holidays and waivers for social ventures and their investors under the Income Tax Act. Social healthcare infrastructure also attracts GST across the value chain which is being incurred by the social healthcare ventures. However there is zero GST on healthcare for the final services being delivered to the community and is currently not offsetable. As a result the entire burden falls on the social healthcare venture operator and its donors if the final services to the community is fully subsidized.

From the social healthcare infra creation, in the current Goods and Services Tax (GST) regime of charging non-offsetable tax on rent from social healthcare operators makes the cost of funding prohibitive and reduces the net fund in hands of hospital operators to create incremental bed capacity by almost 20% in the country. GST on rent is virtually not offsetable because healthcare operators are exempt from charging GST to its patients / customers and that therefore, is a major roadblock for hospital operators to raise long-term affordable finance to create additional bed capacity in the country. Adequate policy measures need to be introduced to streamline the GST regime for financing healthcare infrastructure through sale and lease back transactions in India in line with bank and NBFC debt which do not attract any GST tax on financing healthcare infrastructure.

We submit that GST offset on the healthcare and allied services increases the burden to the operator and donors and needs to be removed as part of the tax recommendations in addition to the direct taxes recommendations provided by the draft regulations.

Regulations for social sector ventures for social credit rating

Banks and NBFCs do not consider the social and community impacts while providing debt finance to social sector healthcare operators. Our Healthcare REIT/InvIT model considers and ensures these impacts while investing into social sector healthcare operators through the sale and lease back modus of financing healthcare infrastructure. A change in the rating methodology for social sector infrastructure like healthcare is required to be considered for social healthcare ventures.

We therefore submit that the draft should recommend setting of separate rating guidelines for social ventures in India by the credit rating agencies for various instruments being used by the social ventures

Sale and lease back for infrastructure under the trusts and societies for asset monetization

As per our industry estimates around INR 75,000 crs of healthcare infrastructure is the dry gun powder that needs upgrade and expansion funding is residing on the trusts and charitable societies in India. These healthcare operators are currently financing their growth by using funds raised via:

  • Loan Against Property (Hospitals) from Banks (cheaper, limited amount, short tenure, not for debt averse operators)
  • Land Acquisition / Development finance from a Financial Investor (expensive and limited)

A new model of financing growth for such operators has opened up since SEBI announced the REIT / InvIT regulations (cheaper, cleaner and control neutral). This enables the hospital operators to monetize its “dead” hospital infrastructure assets and raise perpetual capital to fund its future growth opportunities. This is done via sale-lease back model where the operator sells the hospital infrastructure to a professional property investor while also signing a long-term lease to ensure business continuity. This enables the property investor to earn rental income while it provides the Hospital Operator with perpetual and affordable source of capital and becoming asset-lite – a win-win situation for all parties concerned.

REITs also have certain listing limitations under the current regulatory regime – which should be relaxed in the event they become eligible to be listed on the SSE. The SSE should also enable debt, equity or perpetual debt instruments to be listed through SPV structures.

Listing and trading norms for wider market participation on the SSE including market making

Under the current AIF regime, units of close ended AIFs are allowed to be listed on stock exchanges subject to a minimum tradable lot of one crore rupees. In light of our recommendation for a separate category of AIFs, the listing for such category of AIFs should be allowed with the minimum tradeable lot for such AIFs being made smaller, in region of 10 – 15 lakhs instead of the more cumbersome 1 crore requirement. The AIF may also hold assets directly, i.e. hospital assets through a single AIF and units of such AIF will get listed. It is humbly submitted that an SPV created for such purposes is listed then in additional to equity listing, perpetual bond listing should also be allowed at the SPV level.

Participation of CSR funds into healthcare infra

Please note that the same asset that engages in ‘for profit’ ventures to initiate social impact may also consider raising CSR money at a ‘for profit’ bond / equity interest.  It is submitted that clear guidelines should be introduced on how CSR funds can be deployed via SSE.

Under the current CSR regime (as per the Companies Act) there is no provision for one company’s CSR monies to be combined with and added to monies of other companies CSR, i.e. there is no concept of pooling and/ or co-participation under the current regime. For example, if the resources of various companies could be pooled together in partnership with the government and other creditable NGOs, the impact could be manifold. Where NGOs and corporates can bring in quality, but scaling is possible only with the involvement of the government. This co-participation may be in the form of cash or in the form of valuable knowledge sharing / experience or personnel that one company may benefit from others. Smaller companies may benefit greatly from such overall changes to the regime given the 5 percent limit on overheads stipulated by the government. Smaller CSR spenders can only deploy a limited amount in the form of administration expenses and hence the sample size of projects they can invest in are much lesser in number and quantity. This often leads to sub-optimal allocation of funds, with a disconnect between capital deployment and on-ground realities.

Therefore, while the CSR regime currently encourages collaboration between companies to help avoid duplication of managerial efforts, infrastructure, personnel amongst other factors, it does not explicitly mention / allow ‘pooling of funds’. We humbly submit that a minor modification in the act could address this aspect. We believe that pooling CSR spends of companies can unlock a myriad number of opportunities in addressing India’s most pressing challenges in the social sector.

SPVs listing of healthcare PPPs with community and social impact

As member of the Planning Commissions’s PPP Committee for Healthcare Infra under UPA -1 chaired by Dr. Hamied and Haldea, several recommendations were given to fast track PPP in Healthcare. However, the issue of concessioning and operating costs of providing community healthcare to the masses has been the bone of contention. The recent Orissa PPP bids front ended by IFC has failed to elicit bidders due to the same reasons.

There is an approximately $45 billion of healthcare infra assets which are sitting on the books of Central and State Governments and Private and Social Sectors. Many of these require funding for upgrading and expanding their infra. Various archaic regulations and other operations bottlenecks are preventing investments flows into these existing healthcare infra from Indian and foreign LP investors as the PPP policies have failed to garner interest.

The current National Infrastructure Pipleline published in Dec 2019, shows a committed pipeline of $2.5 billion which is only through Center and State Governments. A gap of 99% of what needs to be invested for India to meet global norms for healthcare infra supply. Unlike roads which is hogging over 80% of NIP’s committed investments, healthcare infra is gestational. Therefore, there is a weak and lagging healthcare infra investment in India leading to demand gaps. Many of our multilateral funding agencies who are also LPs in our fund would like to participate in the social healthcare.

Innovative SPV structures need to be created where the concessions can be funded by the multi lateral agencies and ESGs for the impact to the communities while the Central and State Governments exit their assets to private operators. These SPVs can be listed on the SSE and actively traded or subscribed to by these LPs.

The government should consider creation of such hybrid impact models involving private-sector partnerships to provide critically-needed health infrastructure.  For profit models may be considered even in this sector which is lagging behind for want of funding from interested LPs. The bid evaluation process in PPP / concession agreements may be relooked at in order to require more concrete bids showing higher levels of commitment from lenders and to eliminate bids that are not in line with commercial projections. An alternative may be for governmental bodies to exit foible projects and letting the operator / agencies pool / fund the concessions through SPV structures. Such SPV structures with underlying PPP projects may be listed on the SSE platform for turnaround and subscribed to by willing investors thereby achieving a turnaround of otherwise stagnant developmental projects.

Regulations for pivoting from for profit to not for profit and vice versa and exit for failed ventures

There have been many instances in the past where social healthcare ventures in trusts which could not be sustained by the promoters and settlers of the trust/societies (see case study) to for profit business models due to various business models, strategic and sustainability issues. The current regulations are fairly prohibitive and do not consider pivoting from not for profit to for profit business models as a going concern. The current draft does not consider these scenarios nor make any recommendations on these exits.

We request that the draft regulations look into provisions for pivoting the business models from for profit to not for profit and vice versa and frictionless exit regulations need to be drafted for a going concern scenarios.

We would like to further submit that LPs should be allowed to exit in the event social ventures are not sustainable for their businesses. Otherwise such models become less lucrative and newer LPs may not participate in such models given the inflexibility around it. Therefore, there is a need to provide a flexible mechanism to allow LPs to exit, be it from a ‘non-profit’ to a ‘for profit’ model or vice versa.

Other regulatory issues

Thin capitalization rules

SPVs / acquisition companies are set up in India to raise money (through debt or equity) for the purposes of financing the said acquisition. While restrictions on debt financing of acquisitions still exist, India has seen a steady increase in the use of innovative financial instruments to fund such acquisitions. Thin capitalisation refers to the situation in which a company is financed / leveraged through a relatively high level of debt compared to equity.

Current IT Act provisions restrict the payment of interest by an entity to its ‘Associated Enterprise’ to the extent of 30% of its earnings before interest, taxes, depreciation and amortization (EBITDA) or interest paid or payable to associated enterprise, whichever is less.

In view of the non-deductibility of the interest expense beyond the de minimis threshold as stated above, investors investing through perpetuity debt instruments, do not have access to such an exemption. It is our humble submission that this exemption be allowed for SPVs with a higher debt component, which are eligible to be listed on the SSE satisfying all relevant criteria.

Flexibility in order to get CSR funding

In the event an FPE is converted into a NPO, such organization should be allowed access to CSR funding and this should be expressly mentioned under the SSE regulations.

Relaxation on listing requirements of REITs

We request that the current considerations which are otherwise applicable around listing of REITs be relaxed to an extent in the event of such REIT being eligible to be listed on the SSE. Such considerations include restrictions on minimum subscription amounts (INR 50,000), minimum tradable lots (200), minimum value of such REIT assets (i.e INR 500 cr) etc. The restrictions for example, may disallow listing of REITs focussed on the hospital sector on the SSE in the event such minimum criteria are not met. Relaxation of these norms would allow for a more holistic growth of the sector by allowing much wider participation and garnering more interest from investors. Similar to our recommendation in relation to AIFs, the regulator may also consider carving out a separate type of REIT for this purpose.

Case Studies for Consideration

Deleted from here for confidentiality reasons



Fostering widespread engagement among investors will be vital to raise adequate capital to fund projects in social sectors. Some of the suggested incentives will be important for both market participants willing to invest and social purpose organisations which are willing to get listed. The wide-reaching economic impact of COVID-19 has resulted in a surge of areas where investments can be made. As envisaged, in order for SSE to be a platform to facilitate raising of capital in such sectors for them to recover and turn-around from the crisis, these measures would only assist in driving more engagement from the relevant market players and ensure that the objectives behind formulation of SSE is met. We therefore request your kind consideration around the suggested recommendations outlined in this note.