PS1: Social and Environmental Assessment and Management System
PS2: Labor and Working Conditions
PS3: Pollution Prevention and Abatement
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 WM Gaza’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in all IFC PSs.

As this project involves a second investment by IFC, with expansion of Wataniya’s operations into Gaza following the Company’s development of operations in the West Bank under IFC’s first investment, and new sites will be 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 E&S issues involve labor and working conditions, including employee and contractor occupational health and safety. 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:

PS1: Social and Environmental Assessment and Management System
Wataniya will improve the written policies and procedures that it developed for the West Bank to manage deployment of technical sites and human resources, and will apply its improved policies and procedures to the Company’s operations in Gaza. These policies and procedures will include procedures for selection, construction, and management of all sites in compliance with IFC Performance Standards and EHSS Guidelines, including procedures for management of Wataniya employees as well as management of key contractors.

WM Gaza will outsource construction of new tower sites and security services to reputable companies with high quality management standards. WM Gaza will include environmental, health and safety terms in all new contracts for its outsourced construction and security services, and will monitor compliance with those terms. WM Gaza staff will supervise contractors’ compliance with the environmental, health and safety management terms. WM Gaza will require improvement in the event that non-compliance is identified, and will consider terminating any contractor in the event of non-compliance.

WM Gaza will map potential sites to be acquired or developed. Then the company or a contractor will identify and assess risks and impacts relating to each potential site, in accordance with IFC Performance Standards and Telecommunications Guidelines. These include visual and electromagnetic impacts and noise from generators in residential and commercial areas, according to IFC’s standards. The Company will take into account public perception about aesthetic issues from the Company’s consultations with local communities during the siting process of antenna towers.

The Company will ensure prior disclosure of the development of new tower sites to local communities, as site conditions warrant. Through its procedures for site selection, WM Gaza will always decline to acquire or develop any site that would require physical or economic displacement of local community members.

WM Gaza’s policies and procedures will ensure that the company manages all relevant functions covered in IFC’s PS2 through PS8. The company will always obtain all relevant local permits prior to constructing or operating a tower.

PS2: Labor and Working Conditions
WM Gaza has about 6 direct employees, expected to be 147 in 2012, 160 in 2013, and 177 in 2014. It expects to have about 200 indirect employees by 2014, including dealers, distributors, and franchisees. Its human resources policies and procedures will ensure compliance with IFC Performance Standards. For all of its offices, operational sites, switching centers, and retail outlets, appropriate measures for life and fire safety will be included in Wataniya Palestine’s policy and procedures.

The Company has a safety committee, and it ensures that each WM Gaza employee has a training plan. Repeated safety violations lead to dismissal. Emergency action plans are provided to each employee. Under IFC’s investment, WM Gaza 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.

The Company has a policy that limits overtime hours, which will all be paid at an overtime rate. The Company has in place a grievance mechanism for employees, which includes an avenue for appeal of initial decisions. The Company has a policy of equal opportunity regardless of marital status, ancestry, religion, gender, age, national origin, or handicap.

WM Gaza 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 that none are below the legal employment age. This will be done by inclusion of appropriate terms in contracts and monitoring of those terms.

PS3: Pollution Prevention and Abatement
Under IFC’s investment, WM Gaza 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. The Company will monitor compliance with such conditions, and will ensure compliance with PS2 and IFC’s Telecommunications Guidelines.

Under IFC’s investment, WM Gaza 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, WM Gaza will develop and implement an action plan to add those elements, as a condition of IFC’s investment.

PS4: Community Health, Safety and Security
WM Gaza will obtain security services from a contracted provider. By written agreement with the contracted company, it is required to comply with IFC Performance Standards. Management of guards is performed from a control room in WM offices, with guards stationed at high risk sites to provide support. WM Gaza’s procedures require guards to escalate any incident to their superior, who may report it if necessary to local official police department. The security company or WM will be in direct contact with local government officials, in the process of screening security employees. Security guards will always wear uniforms.

WM Gaza recognizes the importance of community engagement. The Company is committed to support and sponsor many local activities, especially in sports, education and culture, with an emphasis on childhood development.

For acquisition of tower sites, WM Gaza will consult with relevant municipalities or local village councils and obtain required authorizations. Special Seminars by authorized and qualified persons are prepared to be held in the areas where public resistance is expected to raise up the people awareness in GSM system. The Company will continuously make available information to community members on electromagnetic radiation from tower sites as needed, consistent with IFC’s Telecommunications Guidelines.

WM Gaza will further develop the Company’s policy and procedures for disclosure of relevant information to local community members relating to construction of new sites, to IFC’s satisfaction. WM Gaza 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 WM Gaza to engage with community members may be useful, then WM Gaza will organize such a meeting.

Mr. Fadi Ashayer
Wataniya Palestine Mobile Telecommunications Company
Tri-Fitness Building
Sateh Marhaba, Al Bireh
PO Box 4236
Palestine
Tel: +970 (0) 2 241 5000
IR@wataniya.ps