28644 - Millicom Tchad S.A.

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Environmental & Social Review Summary

Project Number

28644

Company Name

MOOV AFRICA TCHAD SA

Date ESRS Disclosed

Sep 29, 2009

Country

Chad

Region

Africa

Last Updated Date

Jan 8, 2025

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Dec 10, 2009
Signed : Dec 30, 2009
Invested : Jun 8, 2010

Sector

Mobile Telephony

Industry

Telecommunications and Technology

Department

TMT, Venture Capital & Funds

Project Description

The project consists of the expansion of a mobile cellular telephone network in Chad by Millicom Tchad S.A. (the “Company,”) sponsored by Millicom International Cellular S.A., to enhance the company’s network capacity and geographical coverage. Total capital expenditures under this project are estimated at $64.5 million equivalent. The company plans 180 tower sites to be built in all regions of Chad in the next 3 years.

Overview of IFC's Scope of Review

The review of this project consisted of a visit by IFC staff to the project site, to meet with and interview Millicom Tchad management and to have a first-hand look at operational activities. IFC staff also appraised technical, environmental and social information submitted by Millicom Tchad, including human resources policies and procedures, and Millicom position papers on environmental and social issues.

E & S Project Categorization and Applicable Standard

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; and
PS3: Pollution Prevention and Abatement.

PS4: Community health, safety and security issues are not expected to arise in this project, as the impacts of tower sites do not extend into communities (e.g., security guards do not carry guns).
PS5: Involuntary resettlement issues are not expected to arise in this project, as sites will not be developed if they would require resettlement.
PS6: Biodiversity conservation and natural habitat issues are not expected to arise in this project, as sites are chosen only in already-developed areas.
PS7: Indigenous peoples issues are not expected to arise in this project, as no local community members around sites will be 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 Millicom Tchad’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in all IFC PSs.

This project involves the development of cellular tower sites. The key issues associated with the project are environmental, health, safety, and social management; construction of towers; labor and working conditions (including employee and contractor occupational health and safety); and pollution prevention and abatement. 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.

Environmental and Social Mitigation Measures

The proposed project will upon implementation of the specific agreed measures comply with IFC Performance Standards, and IFC environmental, health and safety guidelines. There is an absence of local regulations applicable to environmental and social issues in Millicom Tchad. The Company’s plans for environmental and social management are summarized as follows:

Environmental, Health, Safety and Social Management

Millicom Tchad has adapted Millicom Group environmental and social policies and procedures to local circumstances. These policies and procedures are in written form, and were being implemented well before IFC’s appraisal.

The Company’s employees perform construction and maintenance of some of the tower sites. For the remaining sites, the Company outsources construction and maintenance to contractors.

To select tower sites, the Company maps potential sites according to the need for signal transmission, and then searches for nearby villages that can provide technical needs and workers. Potential sites are chosen according to where impacts will be lowest. The Company or its contractor writes up a Site Survey Report, including a Site Acquisition Report, which includes coverage of relevant environmental and social issues. Once construction is completed, a transmission trial ensures that the tower meets its objectives.

Contractors are required to sign a supplier code of conduct that includes conditions requiring compliance with applicable standards on ethics and integrity, workers’ rights, workers’ protection, prohibition of child labor, environmental protection, and monitoring and reporting, including monitoring of compliance with the code of conduct. Environmental and social terms are included in contracts, with a provision for termination of a contract in the event of non-compliance. The Company will monitor compliance with these terms.

The Company will always avoid developing any site with sensitive environmental issues, or that would require physical or economic displacement of local community members. Further, Millicom Tchad’s policies and procedures will ensure that the Company manages all relevant functions covered in IFC’s PS2 through PS8.

Labor and Working Conditions

Millicom Tchad has 320 direct employees and a sales force of 8000 indirect employees. Detailed human resources policies and procedures are designed to ensure compliance with all applicable local labor laws and regulations. These policies and procedures will be revised to include written procedures to promote the fair treatment, non-discrimination and equal opportunity of its employees, and to include written procedures for handling employee grievances.

Millicom Tchad ensures that its employees are provided with appropriate personal protective equipment and health and safety training for the type of work in which they are engaged. For all of its offices, operational sites, and switching centers, Millicom Tchad employs appropriate measures for life and fire safety. Appropriate procedures are in place to provide for the safety of drivers of cars owned by Millicom Tchad, and premiums are paid to drivers who comply with procedures. When new employees are hired locally, they are provided training in safety measures.

Retail operations are conducted via a pyramid distribution system, whereby the Company employs representatives for different territories. Most vendors are not Millicom Tchad employees. They manage mostly small leased spaces, often simply a spot on a sidewalk under an umbrella. Company representatives check identification cards of all vendors in order to avoid underage vendors, collecting data electronically which is then reviewed by Millicom.

Three of Millicom’s own office buildings house retail operations, where members of the public enter. Measures to manage life and fire safety include fire exits on each floor, and fire extinguishers refilled every 12 months. Dealers operate fifteen built-up stores. Millicom Tchad will quickly notify IFC of any significant incident (such as a fatality) in any store operated by itself or a dealer.

Millicom Tchad makes commercially reasonable efforts to ensure that contractors’ employees who perform work at tower sites shall be provided a safe and healthy work environment, including appropriate training, protective clothing and equipment, and are not below the legal employment age. This is done by asking contractors to sign a code of conduct, as well as by inclusion of terms in contracts and monitoring of those terms.

Pollution Prevention and Abatement

Millicom Tchad includes conditions in its code of conduct with contractors that cover pollution prevention and abatement. These conditions require compliance with local requirements for manufacturing, transportation, operations including hazardous materials management, and obtaining permits.

Energy needs per station are elevated because ambient temperatures in Chad, among the hottest on earth at their peak, raise requirements for air conditioning at the Company’s tower sites. Nevertheless, the Company’s good design practices help keep Millicom’s average energy usage per tower site at about the industry average. At some sites, the Company uses deep cycle batteries, which leads to a need for only one generator instead of two, and therefore reduces energy usage. The Company is currently testing an alternative energy program involving solar panels to partially power some tower sites.

As a condition of IFC’s investment, Millicom Tchad will develop and implement an action plan to add secondary containment structures around fuel tanks as well as spill protection equipment at all Millicom Tchad facilities no later than the end of 2011.

Stakeholder Engagement

Millicom Tchad recognizes the importance of community engagement. The Company has contributed to the development of a “green belt” in Chad, and to the support of organizations that promote the well-being of women, and handicapped people.

The Company has in place procedures for prior disclosure of the development of new tower sites to local communities. As a condition of IFC’s investment, the Company will commit to post at least one sign measuring at least 8” x 11” at each planned construction site at least three days prior to construction. It will commit to following up on any complaints from community members until they are resolved. If a substantial number of community members complains about the same issue, and circumstances indicate that a meeting for Millicom to engage with community members may be useful, then Millicom will organize such a meeting. Millicom will provide information to community members on electromagnetic radiation as needed, consistent with IFC’s Telecommunications Guidelines. Millicom Tchad is committed to complying with IFC Performance Standards on disclosure and community engagement.

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

Projects

Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Identified Applicable Performance Standards

Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

Environmental and Social Mitigation Measures

Stakeholder Engagement

Stakeholder Engagement

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