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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a Category B corporate investment as per IFC’s Environment and Social Review Procedure. Existing telecommunications towers are considered to have limited environmental and social impacts. Protelindo’s medium-term growth strategy is focused toward the development of additional telecommunications towers throughout Indonesia.

Key risks and issues related to this investment include the Company’s capacity to: i) undertake adequate social and environmental assessment commensurate with the impacts of the Company’s projects during both construction and operations phases including the assessment of potential cumulative impacts; ii) manage the social, environmental, health and safety performance of its contractors in accordance with good international industry practice; iii) ensure fair, safe and healthy working conditions during construction and operations for direct employees as well as for the contract workers; iv) ensure proper handling of hazardous materials, and management of air emissions, wastewater, solid and hazardous waste during construction and operations; v) ensure appropriate management of the impacts of construction and operations on local ambient air quality, community health, safety and security and consult and engage with potentially project-affected communities; and vi) minimize adverse impacts of construction and operations on the natural flora and fauna in accordance with local requirements and IFC Performance Standards.

Environmental, social, health and safety issues that require ameliorative measures are included in the Environmental and Social Action Plan (“ESAP”) and will be addressed by the Company. E&S issues relating to the investment are summarized below along with specific information on how potential impacts and risks are addressed by the Company. Upon implementation of the featured mitigation measures described below and in the attached ESAP, the project will comply with environmental and social requirements, namely the laws and regulations of Indonesia, recognized good international industry practice, and IFC’s Performance Standards on Social and Environmental Sustainability.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Protelindo currently operates an integrated Health, Safety, Environment & Quality management system that is organized to comply with ISO 9001, ISO 14001, and OHSAS 18001. Existing policies cover health and safety in the work place including environmental considerations. Similarly, the Company currently has in place a number of procedures to manage the acquisition, design, construction, and deployment of technical sites.



Protelindo 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 the assessment process the Company ensures that potential impacts of the project are identified and addressed for the project life cycle, and are used to prepare specific control plans containing identified mitigation measures.



Protelindo currently plans and implements training programs according to national regulatory requirements. These include aspects such as the identification of workplace hazards, the use of personal protective equipment and collective protection equipment, working at heights, confined space entry, and the roles and responsibilities of employers and employees. Protelindo also requires that employees and subcontractors have formal education and experience appropriate for the assigned functions and provides induction training covering aspects such as the technical competencies of the assigned work activity.



As a condition of IFC’s investment, the Company will work to augment existing policies and procedures. These revised policies and procedures will form a part of a revised corporate-wide Social and Environmental Management System that will consider and ensure Environmental and Social impacts are assessed and mitigated at an appropriate stage in the project development cycle consistent with IFC’s Performance Standards of all prospective projects and/ or acquisitions. This will result in the development of an Environmental and Social Management Plan (“ESMP”) for each new project setting out: i) measures to mitigate adverse direct and/ or cumulative impacts; ii) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; iii) organizational and financial resources for carrying out the measures; iv) an implementation schedule for these activities; and v) an appropriate incentive structure (including provisions for reward and penalties) to ensure plans are implemented.



To achieve this, Protelindo will engage a qualified third party consultant to develop a corporate Social, Environmental, Health and Safety Management System (“SEMS”), which will be finalized within a timeframe agreed with IFC, to ensure that its individual projects are constructed and operated in a manner consistent with host country requirements, IFC’s Performance Standards and good international industry practice as detailed in IFC’s Environmental, Health and Safe
ty Guidelines.



With regard to Protelindo assets, including contracted and sub-contracted resources, Protelindo will implement procedures for: i) ensuring that contractors deployed by each project company meet relevant provisions of Protelindo’s SEMS and ensure implementation of the ESMP as applicable to their respective activities; ii) HSE&S training of Protelindo employees and contract labor; iii) procedures for recording, investigating, reporting and undertaking corrective action in relation to HSE&S incidents including those involving contractor and sub-contractor labor; iv) periodic monitoring of HSE&S performance; v) management review of SEMS effectiveness and implementation of measures for system upgrade; and vi) annual reporting of HSE&S performance to Protelindo’s Board of Directors and investors.



To provide additional oversight at Protelindo corporate level to manage the medium-term asset and capacity growth strategy, Protelindo will appoint an appropriately qualified individual, supported by adequate financial and professional staff resources, who will have overall corporate responsibility for the development and implementation of the SEMS. Similarly, contractors retained to deliver the projects will deploy the necessary resources required by the Company SEMS.



Energy supply for Protelindo’s tower sites is predominantly sourced from the national grid. At a limited number of sites (<5% of the existing portfolio) back-up power generation is in place. Whilst diesel volumes are limited to <1000 litres per site, the Company will seek to install containment measures for existing sites where hydrocarbon storage is required consistent with IFC’s General Environmental Health and Safety Guidelines. As part of the revised management system, the Company will implement maintenance inspection protocols for sites where back-up generation and hydrocarbon storage is present. Similarly, the revised management system will require that containment systems are included for all future site developments where hydrocarbon storage >1,000 litres/ site is required.



Protelindo will ensure that existing training policies and procedures are fully integrated into the corporate SEMS, ensuring current and future assets are managed using training programs consistent with the HSE&S risks of the business line activities. This may include, but not necessarily be limited to, occupational health and safety risks such as: excavation safety; confined space entry procedures; electrical safety; working at heights; fall prevention and rescue; hazardous materials management; and general accident prevention training. Similarly, Protelindo will establish an internal communications program whose objective is to disseminate corporate policies and practices starting with a standardized induction program covering HSE&S aspects relevant to the individual job description.

Protelindo currently employs approximately 600 direct employees. Oversight of all employment relationships is provided by the human resources function which is managed centrally from Protelindo’s headquarters in Jakarta. The employment of all office based staff in Jakarta is consistent with Indonesian Labor Laws (Law No. 13/2003). As required by law, Company policies are included in employment contracts and address working conditions, terms of employment, and wages and benefits. This information is provided in the form of an employee handbook at the time of induction. Protelindo upholds and recognizes workers’ rights to form and to join workers’ organizations of their choosing.



Protelindo will make reasonable efforts to ensure those 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, Protelindo will deploy appropriate measures for life and fire safety.



The minimum employment age at Protelindo is 18 years. Protelindo ensures that hazardous or harmful forms of child labor or forced labor are not employed directly or by subcontractors through verification of relevant documents. Per Indonesian Law employment relationships recognize the principals of non-discrimination and equal opportunity. Employees have the right to freedom of association and have the opportunity to collectively represent to the management any issues or grievances that they may have. Protelindo will seek to formalize existing worker grievance mechanisms as part of the Company SEMS.



Although Protelindo has been in compliance with applicable regulatory requirements, there is variance between the Company’s regulatory obligations when compared to IFC Performance Standard 2 and IFC EHS Guidelines on Occupational Health and Safety (“OHS”). As part of the agreed ESAP and SEMS development, Protelindo will review and develop an implementation plan to achieve internationally acceptable standards for OHS for its employees and sub-contractors. The Company will take corrective measures to enhance its training programs, and implement standard operating procedures that specifically seek to mitigate OHS risks during land clearing, related preparatory work, and construction. It is anticipated that the Company''s occupational health and safety performance will achieve consistency with applicable IFC policies and guidelines for the sector only after recommendations from the external consultant are implemented.

Protelindo recognizes the importance of community engagement, and is committed to complying with IFC Performance Standards on disclosure and community engagement. Under IFC’s investment, Protelindo will be required to post at least one sign at each new site at least three days prior to the start of work.

The Company operates a grievance mechanism relating to the operation of existing tower sites and construction activities. A 24-hour call center is staffed by 13 staff across three shifts per day. Complaints are logged with follow-up procedures in place to close out concerns in a time-specific manner.

Protelindo will continuously make available information to community members on electromagnetic radiation from tower sites as needed, consistent with IFC’s Telecommunications Guidelines.

For inquiries and comments about the project please contact:

Mr. Adam Gifari
President Director
PT Profesional Telekomunikasi Indonesia
Menara BCA, 55th Floor
Jl. M.H. Thamrin No.1
Jakarta 10310, Indonesia
Phone: +62 21 23585500
Fax: +62 21 23586446

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Designate an appropriately qualified individual supported by adequate financial and professional resources with overall HSE & S corporate responsibilities or retain qualified consultant to fulfill role in a full time capacity until permanent hire is completed.	07/01/2013 12:00:00 AM	Completed	Completed	10/01/2013 12:00:00 AM
Retain qualified independent third party environmental and social consultant to augment existing corporate level SEMS policies and procedures per IFC Performance Standards, guidelines and Good International Industry Practice (GIIP), including: a) Revise existing Health Safety, Environment and Social (HSE&S) Policies b) Corporate and site level HSE&S Management Plans and/or Standard Operating Procedures c) Revise corporate design standards for hazardous materials storage for all future assets d) Revise site maintenance SOPs for sites with existing hazardous materials storage e) Waste Management Plans identifying the type and quantity of waste streams generated at Protolindo assets (projects or operation) along with available disposal routes, treatment and reuse f) Land acquisition screening mechanism for assessing environmental and social aspects for new assets g) Grievance Mechanism: to be communicated locally to potentially affected communities for existing and future projects, containing a complaints procedure defining who is responsible for receiving complaints, processes followed for recording and acting on complaints and process for following through, communicating and closing complaints h) Chance Finds Procedure to address impacts to, and protection of, cultural property encountered during project activities	09/01/2013 12:00:00 AM	Completed	Completed	02/17/2014 12:00:00 AM
Upgrade HR and OHS policies and procedures (to include HSE&S procurement and contractor HSE&S monitoring)	09/01/2013 12:00:00 AM	Completed	Completed	02/17/2014 12:00:00 AM