| Performance Standard | Description and Potential Impact | Mitigation |
|---|
| PS 3. Resource Efficiency and Pollution Prevention | Key risks are related to management of E-waste, hazardous materials, and resource efficiency given the need to control temperature and humidity in data center and provide uninterrupted supply of energy to the data equipment. Other risks are related to management of waste and hazardous materials during installation of network infrastructure and equipment, construction of new facilities, maintenance activities. | IFC due diligence in Phase 1 will cover key issues and specific provisions in line with IFC PS3 will be recommended for inclusion in the draft Project Agreement, such as:
-GIIP for energy saving, energy storage and backup
-Selection criteria for procurement of equipment to avoid use of harmful materials.
-Waste management plan for E-waste, packaging waste, and construction waste.
- Standard operating procedures to prevent pollution during construction, installation of the network infrastructure, laying of cables. |
| PS 4. Community Health, Safety and Security | Risks are associated to health and safety, of the communities, including traffic and pedestrian safety, when constructing new facilities, installing telecommunication equipment, laying the cables, and performing maintenance activities. If considered, risk from private security arrangements by the Concessionaire. Additionally, the use of buildings rooftop as base for infrastructure could potentially damage the integrity of the structure, affecting residents and owners. There is also Life and fire safety (LFS) risk, particularly in data centers, associated with:
-Inadequate measures in terms of project design on LFS
-Emergency preparedness and response measures | IFC due diligence in Phase 1 will cover key issues and specific provisions in line with IFC PS4 will be recommended for inclusion in the Project Agreement, such as:
-Pedestrian safety and traffic management plan
-Code of conduct for security service provider
- Design for data centers and offices meeting local building codes and LFS regulation and in accordance with industry specific LFS code which represent GIIP. |
| PS 2. Labor and Working Conditions | -Poor management of occupational health and safety risks resulting in poor practices.
-Poor HR practices resulting in informal recruitment practices, incidents of forced or child labor and issues around unfair or lost wages, benefits, discrimination, and gender-based violence and harassment, particularly among women, immigrants, or other vulnerable groups. | IFC will advise on the inclusion in the draft Project Agreement of specific provisions to manage risks associated to occupational health and safety, labor, and working conditions in general, such as:
-HR policies and procedures including non-discrimination in recruitment, gender inclusivity in the workplace, workers rights and protection, workers code of conduct, anti-sexual harassment policies, workers grievance mechanism, and management of third-party workers.
-OHS system to manage potential impacts associated with workers health and safety, and obligations of contractors and suppliers. |
| PS 1. Assessment and Management of Environmental and Social Risks and Impacts | E&S risks of this Project are limited and manageable through the application of a management system and standard operating procedures. Key risks are linked to (i) the installation of telecommunication infrastructure from an occupational health and safety perspective and in relation to disruptions in the urban settings (ii) use of third-party infrastructure (existing/newly built) (iii) construction of data centers / offices, (iv) electronic waste management, (v) energy inefficiency at data centers, (vi) community health and safety, and (vii) management of security forces (if any).
A lack of transparency and engagement with stakeholders could affect the Project. | The Due Diligence during Phase 1 will include an assessment of key E&S risks associated to the Project, a confirmation of the applicable Performance Standards (at this stage PS5 to PS8 are not considered applicable), and a PS-aligned mitigation strategy. IFCs E&S consultant will work with IFCs technical consultant so that the final design of the network proposed by the technical consultant is aligned with the PSs and CAPEX and OPEX estimates consider any major E&S related costs.
IFC will advise the Client to avoid sites for data centers/ offices that require land acquisition and involuntary resettlement and, where not possible, IFC will advise to meet PS5 and will provide criteria for site selection in case sites will be identified by the concessionaire.
Based on the results of the DD, IFC will recommend specific provisions in line with IFC PS for inclusion in the draft PPP contract, such as:
-Development of ESMS consistent with IFC PS1
-Stakeholder engagement throughout the phases of the project
-Development of community grievance mechanism |