IFC’s environmental and social due diligence indicates that the principal Performance Standards (PSs) to be applied to this investment are: PS1: Social and Environmental Assessment and Management Systems; PS2: Labor and Working Conditions; PS3: Pollution Prevention and Abatement; and PS4: Community health, safety and security. PS5: Involuntary resettlement issues are not expected to arise in this project, as no manufacturing, launch, or teleport site will be developed if it would involve physical or economic displacement of people. PS6: Biodiversity conservation and natural habitat issues are not expected to arise in this project, as sites will be chosen only in already-developed areas. PS7: Indigenous peoples issues are not expected to arise in this project, as no site is expected to be chosen with local community members from peoples defined as indigenous under PS7. PS8: Cultural heritage issues are not expected to arise in this project, as sites will not be developed where such issues would arise. Nevertheless, a condition of IFC’s investment will be that O3B’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in all IFC PSs.

The key environmental and social issues associated with the Project are management by O3B of its key contractors, particularly their procedures for the management of hazardous materials, waste, and launchings and end-of-life disposal of satellites; and O3B’s screening and selection of teleport sites. The nature of the Company’s operations is such that no major adverse environmental or social impacts are expected to result from the Project, and that it will be possible to avoid or mitigate any limited adverse impacts that might result. As a result, it has been classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects.

O3B commissioned an environmental and social (E&S) assessment of the Project, which reviewed key E&S issues in the Project and recommended a plan that includes action items to enable the Project to comply with IFC Performance Standards, IFC environmental, health and safety (EHS) guidelines, and applicable country law, rules and regulations. At the time of the assessment, O3B did not have many formal policies, procedures, or processes in place, reflecting the newness of the organization. The key issues and how O3B plans to manage them are summarized as follows: Environmental, Health, Safety and Social Management O3B will identify an organizational structure that defines roles and responsibilities for EHS management, and will develop training procedures to support this system. It will develop policies and procedures for E&S performance. These will include procedures to facilitate O3B’s performance of any future high-level initial risk assessments needed of E&S impacts associated with any key component of the project, and to ensure that key contractors have suitable EHS management systems in place. When O3B considers engaging with a contractor or supplier to perform a core function of O3B’s project, O3B will undertake an initial E&S due diligence screening. Through screening of O3B’s supplier of satellites, it was determined that resources utilized are not ecologically sensitive, and low-cost labor is not a factor, so according to IFC Performance Standards, no further EHS management by O3B is needed in the manufacture of its satellites. In agreements entered into by O3B with key contractors for satellite launching, teleport construction and operation, and billing and network operations, O3B will include a contractual responsibility for the undertaking of mitigation measures identified by O3B to comply with IFC Performance Standards. This responsibility will be included in new contracts, and O3B will make commercially reasonable efforts to add such measures to existing contracts through amendments as needed. O3B will actively monitor compliance with these terms, and will consider terminating any contractor in the event of non-compliance. O3B will survey potential teleport operations for EHS compliance, and will follow a screening process that it will develop to analyze E&S impacts, develop mitigation measures, and undertake disclosure of information to and engagement with affected local communities. If E&S impact assessment is required for any teleport site construction or expansion in order to comply with applicable standards, then O3B will review the assessment documentation against IFC requirements prior to the start of construction. O3B will avoid the acquisition or development of any teleport site with sensitive E&S issues, or that would require physical or economic displacement of local community members. O3B will develop a mechanism for monitoring and reporting on the company’s performance against its EHS policies and procedures, and for reviewing its performance for continuous improvements. Labor and Working Conditions O3B has 34 direct employees. For its satellite manufacturing, its supplier is expected to employ about 350 at peak, including those employed by its various suppliers and subcontractors. For its satellite launching, its contractors are expected to employ about 200 at peak, including those employed by its various suppliers and subcontractors. For construction and operation of its teleport sites, O3b will not have any direct employees, but its contracted teleport operator is expected to employee approximately five to fifteen personnel during installation of the O3b equipment, and one during operations. For other contracted services, about 75 are expected to be employed. O3B will develop and implement a human resources policies and procedures that will specify working conditions to comply with IFC Performance Standards, including equal opportunities and non-discrimination in its employment of staff, and a grievance mechanism in case of employee complaints. O3B will perform due diligence to ensure that human resources policies and procedures of its key contractors for satellite launching, teleport sites, and other operational functions are designed and implemented to provide to contractors’ employees a safe and healthy work environment, including appropriate health and safety training, protective clothing and equipment, other appropriate measures for life and fire safety, and mechanisms to manage employee grievances. O3B will require key contractors to implement measures identified by O3B as necessary to comply with IFC Performance Standards by including appropriate terms in contracts, and by monitoring of compliance with those terms. Pollution Prevention and Abatement O3B has a draft management plan for the end of life of its satellites. This plan conforms to NASA Guidelines for Post Mission Disposal of Space Structures. O3B plans to place its satellites in a disposal orbit at their end of life, in accordance with NASA guidelines. Under IFC’s investment, O3B will include conditions in its agreements with its contractors for satellite launch and control and for teleport construction and operations that cover pollution prevention, abatement, and mitigation measures for relevant impacts. These conditions will require compliance with local requirements and IFC Performance Standards applicable to teleport sites and to transporting, launching, and disposing of satellites. For any teleport sites that have generators, as a condition of IFC’s investment, O3B will develop and implement an action plan as needed to add secondary containment structures around fuel tanks as well as spill protection equipment. PS4: Community health, safety and security In launching operations and in any case where a new teleport site will be constructed or an existing site is significantly expanded or altered, O3B will ensure that contractors comply with measures for infrastructure and equipment safety, hazardous materials safety, and emergency preparedness and response as prescribed in PS4. O3B does not presently plan for employment or contracting for armed security services at any of its sites. In the event that armed security guards are hired by any O3B contractor, O3B will include terms in agreements with contractors to provide for the measures to comply with PS4.

O3B recognizes the importance of community engagement, and is committed to complying with IFC Performance Standards on disclosure and community engagement. O3B will post on its website the Social and Environmental Review report commissioned from Mott Macdonald Group Ltd. In any case where a new launch or teleport site will be constructed or an existing site is significantly expanded or altered, O3B will ensure that all relevant information is disclosed to local communities prior to the start of work on the site, and that consultation is conducted as needed. If an E&S impact assessment is required in order to comply with applicable standards, then O3B will ensure that the assessment documentation is disclosed to any affected local communities prior to the start of work on any site. O3B is committed to the resolution of any complaints from community members until they are resolved. It will ensure that each key contractor has in place a grievance mechanism to handle any complaints from community members, and will provide a backup mechanism in case of failure by any key contractor.

Mr. Baker Yanicelli O3b Networks Limited St. John’s Manor Offices Le Neuf Chemin St. John, JE3 4EH Jersey, Channel Islands Tel: 44 774 776 7510 Email: baker.yanicelli@O3bnetworks.com