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 project involves the installation of telecommunications equipment on existing buildings and telecommunications towers in urban and peri-urban areas, and possibly the construction of some new telecommunications towers in peri-urban areas after the project first covers urban areas. The key issues associated with the project are environmental, health, safety, and social management; construction of towers; labor and working conditions (including employee and contractor occupational health and safety); and pollution prevention and abatement. The nature of the Company’s operations is such that no major adverse environmental or social impacts are expected to result from the project, and that it will be possible to avoid or mitigate any limited adverse impacts that might 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.

While most of the specific facilities to be developed in this project have not yet been defined, the expectation is that the principal Performance Standard (PS) to be applied to this investment are PS1: Social and Environmental Assessment and Management Systems and PS2: Labor and Working Conditions.

PS3 through PS8 are not expected to be applicable in the small operations of Afrimax’s headquarters. They are expected to be applicable in the operations to be developed in Rwanda and Uganda, and as such will be managed by Afrimax according to the principles of PS1. A condition of IFC’s investment will be that Afrimax’s operations shall consider all relevant social and environmental risks and impacts, including issues covered in PS1 through PS8.

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.

Under IFC’s investment, Afrimax will appoint at least one person at its headquarters and at least one person in each country in which it has substantial operations to be an environmental coordinator, who will be responsible for implementing the Company’s E&S policies and procedures. One of those officers will oversee the development of a social and environmental management system (“SEMS”) for Afrimax. All such officers will be qualified for their work, will obtain training as needed, and will contribute to the preparation of an annual environmental monitoring report for IFC.



An initial SEMS document has already been drafted by Afrimax, but it is mainly a statement of policy, and needs to be significantly expanded with procedures written for Afrimax employees to follow.



Using Afrimax’s SEMS, social and environmental review will be performed in advance of the development of all new Afrimax facilities. This social and environmental review will be appropriate to the nature and scale of each facility, and commensurate with the level of social and environmental risks and impacts in the relevant facility. This review will ensure that the operations with which it is involved will comply not only with all applicable social and environmental laws and regulations of the host country in which the operations are located, but also with IFC’s Performance Standards.



Afrimax will not proceed with any facility that cannot be expected to comply with applicable standards. Afrimax will supervise the social and environmental risks and impacts as they unfold in all of its operations for the duration of its involvement.



At any new tower site that Afrimax develops, it will install either a double-hulled fuel tank or some other type of secondary containment, such as a berm, which will be able to contain at least 110% of the capacity of those fuel tanks. It will also install fuel spill protection equipment at each site and noise insulation around each generator, consistent with IFC’s Telecommunications guidelines. Afrimax will deploy solar or wind or hybrid energy solutions wherever possible.



Afrimax will screen potential key suppliers, vendors, and contractors to ensure that they are well-established companies with solid track records in quality management and labor compliance. Afrimax will select only those who will use documented procedures consistent with IFC and local standards.



Afrimax plans to recycle wherever possible, including ensuring proper disposal of all electronic waste, such as telecommunications devices, batteries, cables, and chargers.



Afrimax will include E&S terms in its agreements with key contractors, vendors, and suppliers. It will tailor those terms to the circumstances of each country in which it operates, and to be consistent with IFC and local E&S standards. The terms will cover topics including labor and working conditions, and materials and waste management. Afrimax will monitor compliance with thos
e terms and require improvement in the event that non-compliance is identified.



Afrimax’s policies and procedures will ensure that the Company manages all relevant functions covered in IFC’s PS2 through PS8. E&S monitoring and reporting from various country operations will be consolidated into an annual report to IFC.

Afrimax has developed an Employee Handbook that contains policies and procedures relating to labor and working conditions. Under IFC’s investment, Afrimax will be required to add a limit on hours worked per week, documentation of a mechanism for handling any worker grievances, and an indication of policies and procedures that apply equally to core, long-term contracted employees, in compliance with IFC Performance Standard 2.



Afrimax will include terms in its agreements with core, long-term contractors regarding labor and working conditions as applicable. It will tailor those terms to the circumstances of each country in which it operates, and to be consistent with IFC and local E&S standards. The terms will cover topics including health and safety training, and health and safety management. Afrimax will monitor compliance with those terms and seek improvement in the event that non-compliance is identified.



Afrimax will ensure that its own employees as well as employees of any core, long-term contractors are provided with appropriate personal protective equipment and health and safety training for the type of work in which they are engaged.

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

Afrimax will develop and implement procedures for public disclosure prior to the construction of any new Afrimax tower or other facility, by posting at least one sign at each new construction site at least three days prior to the start of construction. The Company will continuously make available information to community members on electromagnetic radiation from tower sites as needed, consistent with IFC’s Telecommunications Guidelines.

Afrimax will be 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 Afrimax to engage with community members may be useful, then Afrimax will organize such a meeting.

Mr. Rob Philpott
Chief Financial Officer
Afrimax Limited
Lakeside House
1 Furzeground Way Stockley Park Heathrow,
UB11 1BD United Kingdom
Tel: +44 20 3051 2856

Broad Community Support is not applicable for this project

Current client performance is aligned with applicable Performance Standards and EHS Guideline requirements. No ESAP is required