Key E&S risks and issues related to this Project include the Company''s systems, capacity and staffing to ensure that its operations are undertaken in a manner consistent with IFC PSs; screening of potential new tower sites; site construction and disclosure to local communities; fair, safe and healthy working conditions for the Company''s staff as well as the contractors'' workforce; utilization of equipment and operational practices that maximizes conservation of energy; management of air emissions; solid and electronic/hazardous waste disposal; and mitigation of risks and impacts on community health, safety, security including those due to transport infrastructure.
The Company has presented plans to address the E&S impacts and risks to ensure that the proposed Project will, upon implementation of the specific agreed measures, comply with the E&S requirements including the host country laws and regulations; and IFC’s Performance Standards. The information about how these potential impacts will be addressed by the Company is summarized in the paragraphs that follow.
The Company successfully implemented the Environmental and Social Action Plans (“ESAP”) and additional corrective action plans when the need arose for them in these investments; and regularly reported to IFC on its EHS compliance, as per the respective investment agreements.
PS1: Social and Environmental Assessment and Management System
IFC’s assessment considered the Company’s management of its environmental, health and safety performance in the establishment and operation of its facilities; compliance with national and local permit requirements; and the Company’s engagement with local communities as well as its suppliers, regarding EHS performance and corporate social responsibility (“CSR”).
- Environmental Assessment and Management Systems:
GP 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.
GP 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, GP 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, GP 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.
GP’s policies and procedures will ensure that the company manages all relevant functions covered in IFC’s PS2 through PS8. Under IFC’s investment, GP will be required to include environmental and social terms to its agreements with key contractors when any agreement lacking such terms comes up for renewal or rebidding. These terms will incorporate the requirements of IFC Performance Standards. GP will always actively monitor compliance with these terms, and will consider terminating any contractor in the event of non-compliance.
GP has established Integrated Management System (“IMS”) as per ISO-14001 and OSHAS-18001 standards. While GP has not opted for a third-party certification for this IMS, an external audit conducted by one of the “big-four” international audit firms confirmed that Occupational Health and Safety Management System (“OH&SMS”) has been designed and implemented as per OSHAS-18001 standards and adequately addresses key risks.
The audit also confirmed that the Environmental Management System (“EMS”) has been designed according to ISO-14001 and is under implementation. Accordingly, legal and other requirements have been compiled and environmental aspect and impact registers for the entire operations have been developed. Environmental management programs have been developed based on significant aspects and impacts.
Going forward, GP will adopt IFC Performance Standards on Social and Environmental Sustainability as part of applicable legal and other requirements in its IMS. GP will also update its existing management system(s) to include procedures for screening of future network development projects against IFC PS6 to PS8 and relevant EHS Guidelines. In this context, GP will assess at minimum, any potential impacts on critical habitat/biodiversity hotspots (including those due to transportation of network equipment and construction activities), indigenous people and cultural heritage.
- Organization and Training:
GP’s HSSE department at corporate level has 19 full time senior level staff, comprising doctors and environmental and safety professionals. This department has the responsibility to create, execute and retain HSSE culture in GP and its value chain (vendors and business partners). HSSE team is responsible for occupational health and safety assurance, including safety risk assessment, accident/incident investigation, mitigation plans and HSSE audits. This department also conducts HSSE training programs for employee awareness and provides emergency medical protocol and in-house medical consultancy.
In this context, at operational level, GP has clearly articulated the roles for “Owner” and “Performer”. As such, while HSSE department is the owner department for EHS activities, it works with “performers” all across the Company for various relevant activities.
- Monitoring and Reporting:
While GP’s HSSE team reports to Chief People’s Officer (“HR”), GP HSSE Management Committee (comprising management team members and HSSE Head) and GP Board HSSE Committee (comprising two Board members and HSSE Head) also have an oversight function for HSSE issues. GP regularly sends report to Telenor (its Norwegian JV partner) on EHS information for its own operations and EHS details for its vendors and progress on Climate Change related initiatives. GP externally reports key EHS related information through its annual reports and its website.
To support day to day operations and decision-making, GP has instituted HSSE monitoring and reporting procedures and Key Performance Indicators (“KPIs”) both internally as well as externally. The KPIs include, for instance: Lost Time Injury Frequency (“LTIF”), No. of staff who have completed HSSE training, Work related fatal accidents, Injury Absence Frequency, Sickness Absence Frequency, Long–term Supply Chain Compliance Indicator (“LTSC”), Supply Chain Supplier Conduct Principle (SCP) Risk etc. The monitoring and reporting functions and KPIs are integrated in Company’s Management Information System (“MIS”).
PS2: Labor and Working Conditions
GP has around 4952 employees all over the country, of which approx. 2700 work in new corporate headquarters in Dhaka.
- Human Resource Policy, Management
GP has implemented HR policies and procedures which are in line with the local regulations and IFC PS2 requirements, and cover aspects such as terms of employment, non-discrimination and equal opportunity, and an employee grievance mechanism.
GP conducts a comprehensive employee survey annually to obtain feedback from its employees on how they perceive their working environment, the Company’s leadership and culture.
GP provides several benefits to its employees as a part of its employee welfare program. In-house medical facilities, annual medical check-up, hepatitis-B vaccination program, day care centers of international standards for employees at corporate headquarters and special sick leave for (stressed) employees working at customer care center are some of the examples.
In addition to its own staff, GP also ensures safety and welfare of the contractors employees. This includes Occupational Health and Safety (“OHS”) training and management program (described below) and group insurance program for contract drivers.
- Occupational Health and Safety:
Pre-employment medical checks are mandatory for all employees. In addition, GP’s medical team conducts specific medical tests depending on job profile, such as hearing related check up for customer care employees or ergonomics related check-up for staff working in administration / finance departments. HSSE team also conducts audits and inspections for food and water served in the cafeteria in the corporate headquarters.
In the past two years, GP has made extensive efforts to improve the safety management and performance of its own operations as well as that of its vendors and suppliers, to bring them at par with international best practices. GP’s safety management efforts include: Risk assessment, Personal Protective Equipment (“PPE”) management, Safety audits/inspections, Incident and accident reporting (including near misses; as well as proactive reporting of any undesired circumstance that have potentiality of causing injury or damage) with the help of intranet-based tool and SMS hotline, Accident/incident investigation and Safety training and awareness (e.g. over 95% staff have completed online safety training, and nearly 30% workforce participated in fire safety training and fire drill).
As a result of all these efforts, there have been steady decline in the safety related incidents as well as near misses over the past three years, with zero fatal and reportable accident in GP operations and its value chain during 2011.
- Suppliers / Contractors:
The Company puts great emphasis on supplier and business partners'' HSSE culture development as a part of its Business Assurance program. Accordingly, more than 1,050 (i.e. over 90%) vendors and business partners have already signed Agreement on Responsible Business Conduct (“ABC”) covering Supplier Conduct Principle (“SCP”) on HSSE aspects. GP is in process of signing such agreements with the remaining suppliers and hopes to cover 100% vendor base within the year 2012.
To help vendors comply with its requirements, GP has developed a web-based EHS risk self-assessment tool. The reports produced by this software form the basis of GP’s one-to-one engagement with the suppliers for developing action plans.
To ensure suppliers’ compliance with ABC, GP has developed monitoring tools, such as: questionnaires and review of procurement documents, Business Assurance formal audit, and onsite unannounced inspections.
Transportation, tower climbing and billboard vendors in GP’s value chain pose significant safety risks, hence the GP focuses more of its HSSE efforts, such as training, on partners involved in these activities. During 2011, GP conducted more than 60 training sessions for its business partners, attended by more than 2,000 participants.
In addition, GP’s work on tracking and monitoring of SCP Risks in 2011, helped in identifying nearly 400 types of potential risks in the value chain. The Company has successfully mitigated over 95% of risks through proactive actions.
PS3: Pollution Prevention and Abatement
The construction and operation of the Project will not require the use of significant quantities of hazardous materials.
- Management of Resources:
As a part of its “Building a Greener Network “ program, GP has launched several initiatives to transform its network and office building to environmentally friendly solutions, and to reduce carbon emissions by saving energy and fuel consumptions from its entire operation.
Here, GP’s major initiatives include: (i) Network Modernization Project where 7,500 Base Transceiver Stations (“BTS”) were modernized in 2011; (ii) Reduction in core sites and locations by 2014; (iii) Replacing air conditioners by DC Ventilation Systems; and (iv) Deploying Green Office building solutions at GP headquarters, such as glass wall for natural lighting; energy saver lighting fixtures; energy optimization through load sharing and balancing, energy efficiency by co-generation system; water re-use and treatment; and rain water harvesting.
- Management of Wastes and Emissions:
As a part of its EMS at corporate level, GP has developed standard operating procedures (“SOPs”) for waste management. Accordingly, it disposes of the non-hazardous solid waste from its offices and BTSs through the local municipalities or recyclers/scrap dealers, as per the local regulatory requirements.
Diesel generators at BTS and tower sites are the primary sources of air emissions. GP regularly monitors the air emissions from these generators with the help of vendors to ensure that the emissions comply with regulatory permissible limits.
Under IFC’s investment, GP 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, GP will develop and implement an action plan to add those elements, as a condition of IFC’s investment.
Electronic waste (e-waste) generated from the operations – and especially due to network modernization projects – has been securely stored in the Company’s warehouses. GP is currently in the process of getting necessary permits to send this e-waste to Singapore for recycling and proper disposal by licensed recycling companies.
- Greenhouse Gases:
GP’s environmental roadmap aimed to promote a low-carbon society, and GP''s first priority is to take responsibility for the excess of CO2 emissions generated by its own operations. As such, as a part of its Climate Strategy, GP has set a target of reducing 40% of its carbon emission within 2015 from the business as usual situation considering 2008 as the baseline.
This reduction will consist of network power reduction program, network modernization, internal initiatives, green base transmission stations, and energy saving initiatives in office buildings and transport fleet.
To deal with the energy crisis of Bangladesh, GP had long been taking different initiatives to ensure uninterrupted services to its customer. Since 2007, GP has been implementing renewable energy project to operate off grid sites with green energy in a business viable mode. At present GP has 50 sites running on solar power and has plans to run total 160 solar sites by end-2012.
GP’s estimated GHG emissions in 2011 were 175,000 tons of CO2e. It has a target to reduce its GHG emissions to 167,000 tons of CO2e by 2015, in spite of the proposed network expansion and business growth.
PS4: Community Health, Safety and Security
- Vehicular Traffic Safety:
The main impact of GP’s operations on the nearby communities is due to vehicular movement and potential for traffic accidents. For this reason, GP’s administration and transport department handles the transportation vendors very carefully and strictly. A total of 850 drivers are responsible for driving either GP’s own vehicles or the hired vehicles. As per GP’s HSSE procedures, drivers are screened and trained by GP before the vendors can assign them to drive GP vehicles. Once assigned to GP, suppliers cannot change drivers assigned to GP without notification. Moreover, most of the vehicles in GP’s fleet are enabled with Geographical Positioning System (“GPS”). GP has installed a state-of-the-art fleet monitoring and control room to track the movement and operating parameters of this GPS-enabled fleet.
- Emergency Preparedness:
While the impacts on the nearby communities due to GP’s operations are expected to be minimal, it has developed detailed emergency response plans for its operations – and especially for its corporate headquarters. Accordingly, Emergency Evacuation Representatives (“EER”) have been nominated for various GP premises nationwide. Around 1,000 portable fire extinguishers have been installed in GP premises and vehicles. Maintenance and monitoring of fire detection system and emergency evacuation drills are regularly conducted. GP’s HSSE team also provides 24X7 emergency security support (e.g. in case robbery, hijack) together with emergency security and travel alerts for its employees.
Security personnel are contracted from reputed security firms and they do not carry firearms. Security guards are trained about their interaction with the community.
