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

Because this project involves the expansion and maintenance of Continental Towers’ mobile telephone towers, and sites are chosen only in developed areas where no high risk exists, no major adverse environmental or social impacts are expected to 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 key issues associated with the project are environmental, health, safety, and social (EHSS) management; EHSS screening of new sites; construction at new sites; labor and working conditions (including contractor occupational health and safety); and pollution prevention and abatement. 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 Continental Towers has policies and procedures in place for deployment of technical sites and to manage human resources. As a condition of IFC’s investment, the Company will work to upgrade those policies and procedures, as needed. All these policies and procedures are or will be in written form. They will include procedures for selection, construction, and management of all sites in compliance with IFC Performance Standards and EHSS Guidelines, including procedures for human resources management and management of key contractors. Continental Towers maps potential sites to be acquired or developed according to requests from its clients. Then the company or a contractor identifies and assesses risks and impacts relating to each potential site. Through its procedures for site selection, Continental Towers will always decline to acquire or develop any site with sensitive environmental risks and impacts, or that would require physical or economic displacement of local community members. For each potential site, Continental Towers or a contractor completes a site survey report, which will cover how all relevant environmental and social risks and impacts will be managed in accordance with IFC Performance Standards and EHSS Guidelines. These include visual and electromagnetic impacts and noise from generators in residential and commercial areas, according to applicable standards. To manage visual impacts, the Company camouflages towers and fixtures, using traditional and triangular tower monopoles. Continental Towers’ policies and procedures will ensure that the company manages all relevant functions covered in IFC’s PS2 through PS8. Under IFC’s investment, Continental Towers will be required to add environmental and social terms to its agreements with key contractors when any agreement comes up for renewal or rebidding. These terms will incorporate the requirements of IFC Performance Standards. Continental Towers will always actively monitor compliance with these terms, and will consider terminating any contractor in the event of non-compliance. In each of its countries of operations, Continental Towers hires local employees who are knowledgeable regarding local environmental and social laws, rules, and regulations. Under IFC’s investment, Continental Towers will appoint at least one employee in each country to be responsible for managing and monitoring EHSS issues in contractors’ operations as well as in the Company’s own operations. 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. Labor and Working Conditions Continental Towers has about 50 direct employees. A number of other workers will be employed by companies who develop tower sites on behalf of Continental Towers (n.b., the number of companies who will do such work is unknown, so the number of contract workers employed by this project is unknown as yet.) The Company’s human resources policies and procedures will be improved to ensure compliance with IFC Performance Standards. Under IFC’s investment, Continental Towers will add measures to 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. The Company will establish a reasonable limit on overtime hours, which will all be paid at an overtime rate. The Company will develop a grievance mechanism for employees, with an avenue for appeal of initial decisions. The Company will revise its policies to ensure that no discrimination occurs toward any employee who either suffers from a prior disability, contagious disease, or incurable illness, or develops a new disability, contagious disease, or incurable illness during employment with the Company. Continental Towers will make 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 will be done by inclusion of appropriate terms in contracts and monitoring of those terms. For all of its offices, operational sites, and switching centers, Continental Towers will deploy appropriate measures for life and fire safety. Pollution Prevention and Abatement Continental Towers offers its clients the opportunity to collocate equipment on many of its tower sites. The company also provides products to municipalities that benefit local communities. For example, mounted on a number of tower sites are cameras and lights provide security and lighting to the local community, contributing to the rehabilitation of marginal areas with high crime rates. In some cases, tower sites are adjacent to parks, where they provide lighting for community soccer fields Continental Towers has launched research and development efforts to investigate the possible use of renewable energy to provide power at tower sites. These would make them self sufficient, as well as save energy and reduce greenhouse gas emissions.  Under IFC’s investment, Continental Towers 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. Continental Towers generally does not provide backup power at tower sites, but allows its clients to provide such power. Only about ten percent of tower sites have generators and fuel tanks. Under IFC’s investment, Continental Towers will ensure appropriate noise insulation exists at all tower sites that have generators and fuel tanks. The Company will add insulation where it is missing, to comply with noise limits in IFC’s telecommunications guidelines. For any sites that have generators without secondary containment structure around fuel tanks and/or spill protection equipment, Continental Towers will develop and implement an action plan to add those elements, as a condition of IFC’s investment. PS4: Community health, safety and security Continental Towers does not presently employ or contract for armed security services. In the event that armed security guards are to become ContinentalTowers employees in the future, then the Company 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 Continental Towers, the Company will include terms in agreements with contractors to provide for the same above measures as Continental Towers 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 Continental Towers’ security services, its employees or contractors will address the situation and provide for appropriate resolution, consistent with PS4.

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

Mr. Federico Lorenzana c/o Continental Towers florenzana@mip.com.gt