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 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 IHS’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in all IFC PSs.

This project involves the expansion and maintenance of IHS operations and acquisition of existing telecommunications towers. The key issues associated with the project are environmental, health, safety, and social (EHSS) management; EHSS screening of towers to be acquired; 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, IFC environmental, health and safety guidelines, and applicable country law, rules and regulations. The Company’s plans for environmental and social management are summarized as follows: Environmental, Health, Safety and Social Management IHS has environmental and social policies and procedures for its Nigerian operations, and under IFC’s investment will work on adapting those policies and procedures to be implemented in managing its operations in other countries to reflect local circumstances, as needed. All these policies and procedures are or will be in written form. They will include procedures for site selection, construction, and management, including human resources management and waste management. IHS 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, IHS or a contractor will write up a site survey report, which will cover how all relevant environmental and social risks and impacts will be mitigated. These will include visual and electromagnetic impacts and noise from generators in residential and commercial areas, or elsewhere according to applicable standards. Under IFC’s investment, IHS will add soundproofing around generators if it is missing to comply with noise limits in IFC’s telecommunications guidelines. Through its procedures for site selection, IHS will practically 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 follow all processes and fulfill all requirements according to the timeframes required by local authorities to obtain all relevant permits prior to constructing or operating a tower. IHS’s policies and procedures will ensure that the Company manages all relevant functions covered in IFC’s PS2 through PS8. Under IFC’s investment, IHS will be required to add environmental and social terms as needed to its agreements with key contractors when any agreement comes up for renewal or rebidding. IHS will always actively monitor compliance with these terms, and will consider terminating any contractor in the event of non-compliance. Labor and Working Conditions IHS has 700 direct employees and uses about 150 contracted employees. Detailed human resources policies and procedures are designed to ensure compliance with all applicable local labor laws and regulations. These include procedures to manage employee grievances. IHS 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, IHS employs appropriate measures for life and fire safety. IHS will make commercially reasonable efforts to ensure that its 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 will be done by inclusion of appropriate terms in contracts and monitoring of those terms. Pollution Prevention and Abatement Under IFC’s investment, IHS will include conditions in its agreements with construction contractors and suppliers that cover pollution prevention, abatement, and mitigation measures for relevant impacts. These conditions will require compliance with local requirements for manufacturing, transportation, operations including hazardous materials management, and obtaining permits. Similar measures will also be taken in the Company’s own operations in Nigeria as well as in its other countries of operation. IHS will always install noise insulation around new backup generators, and under IFC’s investment will add insulation where it is missing, to comply with noise limits in IFC’s telecommunications guidelines. The Company uses battery power as backup for electricity needs at some of its tower sites, and it is conducting pilot tests aimed at reducing the use of diesel-powered generators. The Company is also testing several alternative energy solutions that, if viable, will be deployed throughout its network. For those sites that have generators, as a condition of IFC’s investment, IHS will develop and implement an action plan to add secondary containment structures around fuel tanks as well as spill protection equipment. PS4: Community health, safety and security IHS does not presently employ or contract for armed security services. In the event that armed security guards are to become IHS employees in the future, then IHS will screen applicants, train new hires on the use of force, and implement other appropriate measures, as prescribed by PS4. In the event that armed security guards are contracted by IHS, the Company will include terms in agreements with contractors to provide for the same above measures as IHS would take with its own employees, and monitor for compliance with such terms. For example, in the event that any grievance arises from local community members in relation to IHS’s security services, its employees or contractors will address the situation and provide for appropriate resolution, consistent with PS4.

IHS recognizes the importance of community engagement, and is committed to complying with IFC Performance Standards on disclosure and community engagement. IHS has procedures for engagement with local communities prior to the development of any new site. As a condition of IFC’s investment, IHS will commit to post at least one sign is posted at each site planned for construction at least three days prior to construction. IHS 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 IHS to engage with community members may be useful, then IHS will organize such a meeting. IHS will always provide information to community members on electromagnetic radiation from tower sites as needed, consistent with IFC’s Telecommunications Guidelines.

Mr. William Saad Managing Director IHS Nigeria Plc 19 Bishop Aboyade Cole Street Victoria Island Lagos, Nigeria Telephone: +234 1 280 0790 Fax: +234 1 2800791