32038 - Eaton Uganda

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Environmental & Social Review Summary

Project Number

32038

Company Name

EATON TOWERS UGANDA LTD

Date ESRS Disclosed

Apr 16, 2012

Country

Uganda

Region

Africa

Last Updated Date

Jun 12, 2021

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Jun 1, 2012
Signed : Oct 25, 2012
Invested : Nov 9, 2012

Sector

Mobile Telephony

Industry

Telecommunications and Technology

Department

TMT, Venture Capital & Funds

Project Description

The project consists of the acquisition, building and maintenance of two telecommunication tower networks by Eaton Uganda. Existing tower sites will be acquired from Orange Uganda Limited and Warid Telecom Uganda Limited in a negotiated sale. Towers will also be built-to-suit over the next two years to support additional demand.

Overview of IFC's Scope of Review

The review of this project consisted of a visit by IFC staff to the project site, to meet with and interview management of Eaton Towers Uganda Limited (the “Company” or “Eaton Uganda”), and to have a first-hand look at operational activities. IFC staff also appraised technical, environmental and social information submitted by Eaton Uganda, including an environmental and social management plan, an employee manual, and a sample employee contract.

E & S Project Categorization and Applicable Standard

While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
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 Eaton Uganda’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in all IFC PSs.

Environmental and Social Mitigation Measures

Eaton Uganda has policies and procedures in place to manage human resources and for the acquisition, design, construction, and deployment of technical sites. 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.

Eaton Uganda 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.

For each potential site, Eaton Uganda 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.

Through its procedures for site selection, Eaton Uganda 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. 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. The National Environmental Management Agency of Uganda requires all potential sites to undergo an environmental impact assessment and obtain the agency’s clearance.

Eaton Uganda’ policies and procedures will ensure that the company manages all relevant functions covered in IFC’s PS2 through PS8. Under IFC’s investment, Eaton Uganda will be required to add any missing 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. Eaton Uganda will always actively monitor compliance with these terms, and will consider terminating any contractor in the event of non-compliance.

Stakeholder Engagement

Eaton Uganda recognizes the importance of community engagement, and is committed to complying with IFC Performance Standards on disclosure and community engagement.

Eaton Uganda 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, Eaton Uganda will commit to post at least one sign is posted at each site planned for construction at least three days prior to construction.

Eaton Uganda 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 Eaton Uganda to engage with community members may be useful, then Eaton Uganda 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.

Broad Community Support

Environmental & Social Action Plan

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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Environmental & Social Review Summary

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Environmental and Social Mitigation Measures

PS 1: Assessment and Management of Environmental and Social Risks and Impacts

PS 2: Labor and Working Conditions

PS 3: Resource Efficiency and Pollution Prevention

PS 4: Community Health, Safety and Security

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