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. No issue relating to community health, safety and security is expected to arise in this project (PS4). Zain has a corporate commitment to avoid sites where involuntary resettlement would be an issue (PS5). Zain’s ESMP guidelines include procedures for assessing possible new tower sites, including potential impacts on biodiversity and cultural heritage. Zain routinely disqualifies sites that might impact sensitive areas of biodiversity (PS 6) or cultural heritage (PS8). There is no potential for impacts on Indigenous Peoples in this project (PS7).

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); pollution prevention and abatement; biodiversity conservation; and cultural heritage. 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 applicable standards including host country laws and regulations, IFC Performance Standards, and IFC environmental, health and safety guidelines. Zain Iraq’s plans for environmental and social management are summarized as follows: Environmental, Health, Safety and Social Management Since Zain Iraq took over the operations of Iraqna, it has committed to continuous improvement of environmental and social management throughout its operations. Zain Iraq is in the process of establishing a cross-department environmental and social management team identical to those it has established at its operations in Africa. As a condition of IFC’s investment, Zain Iraq has committed to: Use the present written ESMP guidelines and EMS system, as they have already been deployed successfully in 15 operating companies (including the associated training methods) and allow for local legislation, regulations and procedures. . Going forward, Zain will identify risks and impacts relating to each potential site to be acquired or developed, as per the EMSP practice on antenna site selection criteria. It will avoid acquiring or developing any site with sensitive environmental issues or that would require physical or economic displacement of local community members. For each new site, Zain Iraq or a contractor will write up a Site Survey Report, including a Site Acquisition Report that will cover how all relevant environmental and social risks and impacts will be mitigated. These will include visual and noise impact from generators. The company will obtain all relevant permits prior to constructing or operating a tower. Use the existing ESMP EMS system already in place - and adapt, if and when necessary, to the local environment - for monitoring environmental and social performance, and for reporting on environmental and social issues both internally and externally. To support these efforts, Zain Iraq will work with the Zain Group’s environmental and social management team. Evidence will be made available to IFC as needed that all environmental and social risks, impacts, and opportunities are being appropriately managed. Provide appropriate environmental and social training to all relevant staff and management of Zain Iraq. Consider seeking and achieving quality management certification for its environmental and social management processes. Include relevant environmental and social terms in any agreements with contractors, and monitor compliance with such terms. Labor and Working Conditions Zain Iraq has 1345 direct employees and employs approximately 422 contracted workers. Under IFC’s investment, Zain Iraq will implement detailed human resource policies and procedures, designed to ensure that Zain Iraq complies with all applicable local labor laws and regulations, as well as with IFC’s PS2. These policies and procedures will promote the fair treatment, non-discrimination and equal opportunity of its employees, and include written procedures for handling employee grievances. The Company will ensure 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, switching centers, and retail outlets, Zain Iraq will employ appropriate measures for life and fire safety. As is required under Zain’s corporate ESMP, Zain Iraq will provide regular, repeated training courses in defensive driving to employees as needed. Zain Iraq will ensure that contractors’ employees who perform work related to core functions of Zain Iraq for a substantial duration shall be provided a safe and healthy work environment, including appropriate training, protective clothing and equipment, and are not below the legal employment age. Pollution Prevention and Abatement The Company will include conditions in any agreements with contractors that cover pollution prevention, abatement, and mitigation to manage relevant impacts in compliance with the Zain ESMP. These measures will ensure compliance with local requirements for manufacturing, transportation, and operations including hazardous materials management.  Zain Iraq presently has 2408 sites in operation, most of which have fuel storage capacity. Some but not all of these fuel tanks are fitted with adequate secondary containment structures. Zain will institute an ongoing program to inspect the fuel tanks at its sites, for the purposes of identifying those that need require secondary containment. Inspections will be performed by the ESMP coordinator for Zain Iraq, who will undertake the inspections in the context of routine activities and sites visits, which are carried out continuously. As sites requiring the installation are identified, Zain has committed to deploy the necessary containment structures at the rate of at least 50 sites per year. Zain will maintain a log of sites inspected, the findings of the inspection, and the proposed date for deploying secondary containment, if required. Sites with evidence of leaks or spills, if any, will be addressed on a priority basis. As it has done at several of its other operations, Zain Iraq is exploring the possibility of using solar panels and wind to power or partially power the Company’s cell sites. The use of solar panels and wind would be expected to reduce impacts associated with generators and fuel tanks normally used in such a project.

Zain Iraq recognizes the importance of community engagement. Upon acquisition of tower sites, Zain Iraq shall consult with relevant municipalities and district assemblies, obtain required authorizations, and comply with local regulatory requirements and IFC Performance Standards. Zain policy and practice is to follow 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 Zain Iraq to engage with community members may be useful, Zain Iraq will organize such a meeting. It will provide information to community members on electromagnetic radiation as needed, consistent with IFC’s Telecommunications Guidelines. In the seven years that it has operated in Iraq, Zain has established a strong Corporate Social Responsibility program that has drawn on consultations with customers and other stakeholders. Specific programs - many of which relate to provision of medical services in regions of the country impacted by the war – that have been supported by Zain Iraq to date include: Support to the Amar Public Health Program (www.amarfoundation.org), which cares for over 10,000 patients per month at their fully equipped medical facilities across Iraq; renovation of the Children Hall in the Central Pediatric Hospital in Iskan; and sponsorship of the Anti-Poliomyelitis Vaccination Campaign in cooperation with the Health Ministry, which succeeded in vaccinating the majority of children in Baghdad. Distribution of 300 tons of food provisions to thousands of displaced families in 13 Governorates; as well as food provisions and aid to over 400 victims of flood in Qurana. Financial and humanitarian support to 35 families of a large explosion in Jadiriya, which destroyed large 25 houses. Establishment and ongoing support to two mobile medical outpatient units, which offer free medical services to thousands of people around the country; and regular company blood drives, with more than 80 percent of Zain staff contributing, in support of Iraq medical needs. Support to the Iraq Handicapped Association in organizing and hosting a seminar at the Iraqi Center for Democracy. The seminar documented the rights of the handicapped women and children in an attempt to correspond to the UN Geneva Declaration, as well as showed the effects of conflicts on the rights of the handicapped in Iraq. Ongoing support to the Association of the Blind, including the donation of 300 Braille watches and 300 Braille phones; as well as to orphaned Iraqi children, through the sponsorship of the International and Iraqi Orphan Days. Zain sponsors 100 orphans per year, as well as aides over 500 widows with food provisions. Ongoing sponsorship of medical treatment of Iraqis who have been afflicted with serious illnesses or conflict related injuries, including sending 16 patients overseas for medical treatment, covering all travel and medical related expenses.

Dr. Walid Jallo Business Development Director Zain Iraq Limited Baghdad, Iraq Email: walid.jallo@zain.com