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 Vodafone Ghana operations do not extend into communities (e.g., security guards will not carry guns). PS5: Involuntary resettlement issues are not expected to arise in this project, as sites will not be developed if they 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 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 Vodafone Ghana’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in all IFC PSs.

This project involves the expansion, upgrade, and maintenance of Vodafone Ghana operations. 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.

The proposed project will upon implementation of the specific agreed measures comply with IFC Performance Standards, and IFC environmental, health and safety guidelines. The Company’s plans for environmental and social management are summarized as follows: Environmental, Health, Safety and Social Management Vodafone Ghana will adapt an existing set of environmental and social policies and procedures so that they will reflect IFC’s Performance Standards. Vodafone Ghana uses Vodafone group environmental and social policies and procedures tailored to reflect local circumstances. All these policies and procedures are or will be in written form. They include procedures for site selection, site construction, waste management, and human resources management. They will apply to all the company’s operations, including tower, cable, and retail operations. Vodafone Ghana maps potential sites to be acquired or developed according to the need for signal transmission. Then the company or a contractor identifies and assesses risks and impacts relating to each potential site. For each potential site, Vodafone Ghana or a contractor writes up a site survey report, which covers how all relevant environmental and social risks and impacts will be mitigated. These include visual and electromagnetic impacts and noise from generators. Through its procedures for site selection, Vodafone Ghana will always avoid acquiring or developing any site with sensitive environmental issues, or that would require physical or economic displacement of local community members. The company will always obtain all relevant permits prior to constructing or operating a tower, cable site, or retail operation. The company plans 400 tower sites and 5 retail operations (including internet cafes) to be acquired or built in the next two years. Under IFC’s investment, potential leased sites for any new retail operations will be screened for life and fire safety issues, and Vodafone Ghana will continuously ensure that adequate fire exits and fire extinguishers are available and operational. Vodafone Ghana’s policies and procedures ensure that the company manages all relevant functions covered in IFC’s PS2 through PS8. Environmental and social terms are included in agreements with key contractors, with a provision for termination of a contract in the event of non-compliance. Vodafone Ghana will always actively monitor compliance with these terms. Labor and Working Conditions Vodafone Ghana has 2375 direct employees and uses 100 contracted 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 reflect IFC Performance Standards, and will include procedures to promote the fair treatment, non-discrimination and equal opportunity of its employees, and to manage employee grievances. Vodafone Ghana 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, Vodafone Ghana employs appropriate measures for life and fire safety. Appropriate procedures are in place to provide for the safety of drivers of cars owned by Vodafone Ghana. When new employees are hired locally, they are provided training in safety measures. Vodafone Ghana makes commercially reasonable efforts to ensure that contractors’ employees who perform work at tower, cable, and retail 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 inclusion of appropriate terms in contracts and monitoring of those terms. Pollution Prevention and Abatement Vodafone Ghana includes conditions in its agreements with construction contractors and suppliers that cover pollution prevention, abatement, and mitigation measures for relevant impacts. These conditions require compliance with local requirements for manufacturing, transportation, operations including hazardous materials management, and obtaining permits. Similar measures are also taken in the company own operations. As a condition of IFC’s investment, Vodafone Ghana will develop and implement an action plan to add secondary containment structures around fuel tanks as well as spill protection equipment at all Vodafone Ghana facilities.

Vodafone Ghana recognizes the importance of community engagement, and is committed to complying with IFC Performance Standards on disclosure and community engagement. Vodafone Ghana has procedures for prior disclosure of the development of any new sites to local communities. As a condition of IFC’s investment, Vodafone Ghana 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. Vodafone Ghana is committed to following up on any complaints from community members until they are resolved. If a substantial number of community members complain about the same issue, and circumstances indicate that a meeting for Vodafone Ghana to engage with community members may be useful, then Vodafone Ghana will organize such a meeting. Vodafone Ghana will always provide information to community members on electromagnetic radiation from tower sites as needed, consistent with IFC’s Telecommunications Guidelines.

Questions or comments can be directed to: Mr. Randell Hato Chief Financial Officer Ghana Telecommunications Company Limited Head Quarters, Telecom House, Nsawam Road Private Mail Bag 221 Accra- North, Ghana Telephone: +233 20 200 7141 Fax: +233 21 238 478