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 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

Telecommunications network operations involve a limited number of specific environmental, health & safety and social impacts, which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. Given there are no major adverse environmental or social impacts expected to result from the proposed project, and it is possible to avoid or mitigate any limited adverse impacts that may arise, the proposed investment has been classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects.

All of IFC’s Performance Standards are applicable to IFC investments. However, IFC’s E&S due diligence indicates that the construction and operation activities covered by the proposed investment will have to be managed in a manner consistent with the following Performance Standards: PS 1: Assessment and Management of Environmental and Social Risks and Impacts; PS 2: Labor and Working Conditions; and PS 4: Community Health, Safety and Security.

PS3 (Resource Efficiency and Pollution Prevention) is not applicable as energy supply for Ooredoo’s operations are prioritized, where possible, from the national grid. . PS5 (Land Acquisition and Involuntary Resettlement) is not applicable as Ooredoo leases space on telecommunications towers that are owned and operated by third party telecommunications tower companies. Leases for the telecommunications towers are based on a willing buyer/ willing seller basis. PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources) is not considered applicable given that, due to the limited footprint of the individual towers, no operations are expected to require biodiversity conservation or management of living natural resources. PS7 (Indigenous Peoples) is not considered applicable as although various ethnic groups exist across Myanmar, the construction and operation of telecom towers is not expected to result in the transformation, encroachment or degradation of indigenous community lands. On PS8 (Cultural Heritage), whilst sacred sites are common in the region, no impacts to cultural resources have been identified to date. The company will implement avoidance measures to ensure impacts to sites involving high biodiversity value or significant cultural heritage are prevented at the site selection stages. Similarly a “chance finds” procedure will be applied in the event of discovering cultural heritage resources in the project area.

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.

Ooredoo has developed and implemented a number of components required for an effective Environmental and Social Management System (ESMS). These include an environment policy, an Occupational Health and Safety (OHS) policy which are supported by manuals, handbooks and plans. Similarly, a range of formalized standard operating procedures are in place, which include i) management of construction, ii) working at heights, iii) climbing operations, iv) installation, v) working on rooftops, vi) operation and maintenance, vii) tool box talks, viii) working area protection ix) safe work practices and x) use of personal protection equipment.



The company has in place Master Lease Agreements with two telecommunications tower companies, of which Ooredoo is currently the anchor tenant for approximately 1,400 telecommunications towers. An additional 1,100 towers await construction under the current Master Lease Agreements. Similarly, Ooredoo has in place Master Service Agreements for the maintenance of Ooredoo’s telecommunications equipment and generators. Within all Master Lease Agreements and Master Service Agreements, Ooredoo requires compliance with prevailing national laws and regulations and the requirement to adhere to Ooredoo’s relevant policies guidelines and operating procedures. The Master Agreements also require providers ensure all staff are appropriately trained for the specific required task along with specific requirements ensuring the prohibition of the use of child labor.



With regard to telecommunications towers siting and location planning, Ooredoo initially identifies a 200m diameter “search ring” for the location of each proposed telecommunications tower, based on: (i) meeting Ooredoo’s license commitments regarding city, state, population and geographic network coverage; (ii) marketing goals; and (iii) physical site constraints. Desktop site screening, employing recent satellite imagery and digital contour mapping, considers topography, landscape, built features and environmentally or socially sensitive features. Sites which present potentially challenging access constraints or where signal strength may be impacted are avoided. Similarly, certain types of physical cultural sites are avoided when siting telecom facilities, with minimum setback distances of 50m being employed between religious structures and a proposed facility. In urban contexts, commercial buildings are preferred.



Following the identification of a candidate site (via desktop review) the tower company, in conjunction with the Radio Access Network vendor, conduct a joint site review within the 200m diameter “search ring” to identify and assess three candidate sites. The review considers the ability to obtain land use rights, approvals and permits. During this stage, the landowner of each preferred site is identified and initial discussions are held, with an MOU entered into between the tower company and the land owner in the event that an agreement is
reached. The tower company provides a final site acquisition report to Ooredoo for approval, recommending one preferred site of three candidate sites.



Once selected, additional technical studies are undertaken which include land ownership identification and confirmation. All leases are on a willing buyer, willing seller basis for periods up to 15 years. In the event that a lease cannot be agreed upon the tower company seeks an alternative site.



The tower company is responsible for permit applications and approvals. In rural areas a permit application is lodged with the regional government, accompanied by neighbor consent and a letter of support from a community leader. Per host national law, neighbor consent is required with statements of no objection being obtained from neighbors to the north, south, east and west of the site. Similarly, statements of no objection are required from the township and district. Ooredoo undertakes for self build sites additional checks for land ownership details, building approvals, the structural soundness of buildings for rooftop mounting, and any grievances that have arisen with neighbors or the community.



As a condition of IFC’s investment, the company will augment existing policies and procedures. These revised policies and procedures will form a part of the corporate-wide integrated Environmental and Social Management System (ESMS). The integrated ESMS will consider and ensure that for all Ooredoo operations, environmental and social impacts are assessed and mitigated at an appropriate stage in the project development cycle and are consistent with IFC’s Performance Standards. The revised integrated ESMS will also require the development of an Environmental and Social Management Plan (ESMP) for telecommunications tower construction where Ooredoo is the anchor tenant, 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. Similarly, the ESMS will include provisions to ensure environmental and social impact assessments are undertaken, consistent with IFC’s Performance Standards, for the installation of large scale telecommunications infrastructure, such as optic fiber cable. The revised policies and procedures will be finalized within a timeframe agreed with IFC ensuring individual projects are constructed and operated in a manner consistent with IFC’s Performance Standards and good international industry practice as detailed in the World Bank Group Telecommunications Environmental, Health and Safety Guidelines [ESAP # 1, 2, 4-6].



Ooredoo operates in a diverse number of locations throughout Myanmar. Cons
equently, Ooredoo’s service providers and contractors where Ooredoo is the anchor tenant rely on short-term labor in a variety of locations to deliver Ooredoo’s network portfolio. To manage E&S risk, Ooredoo will retain an appropriately qualified HSE manager who will, as part of IFC’s investment, report directly to an Ooredoo CXO ( [ESAP # 3]. Similarly, and as part of Ooredoo’s ESMS where commercially viable, the company’s future Master Lease Agreements will require each service provider and/ or contractor retains an independent Quality, Health, Safety and Environment (QHSE) team to oversee construction operations. As part of IFC’s investment, Ooredoo will ensure that all contract documents will require all Ooredoo related activities meet the company’s integrated ESMS [ESAP # 3].



Ooredoo currently employs quality supervisors who oversee construction practices at the company’s construction locations. As part of IFC’s investment, Ooredoo will expand the quality superintendent role to include health, safety and environmental aspects. The expanded QHSE superintendent role will be clearly defined in the revised integrated ESMS [ESAP # 1, 3]. Once implemented the QHSE function will i) ensure service providers meet relevant provisions of Ooredoo’s integrated ESMS and ensure implementation of the ESMP as applicable to their respective activities; ii) deliver HSE training to Ooredoo employees, tower and service company labor; iii) include procedures for recording, investigating, reporting and undertaking corrective actions in relation to HSE&S incidents including those involving tower and service company labor are met; iv) monitor HSE&S performance; v) support the management review of the integrated ESMS efficacy and vi) support the HSE manager in the quarterly reporting of HSE&S performance to Ooredoo’ Board of Directors and investors.



Energy supply for Ooredoo’s operations are prioritized, where possible, from the national grid. Where continuous energy supply is not available, diesel power generation is utilized supported by battery storage and back-up to limit the use of night-time noise impacts. No current or future sites contain diesel back-up power generation with storage volumes greater than 1000 liters per site. In the event that a future project location is required to house greater than 1000 liters, the revised ESMS will require that containment systems are incorporated into the site development, consistent with IFC’s General Environmental Health and Safety Guidelines. As part of the revised ESMS, the company will implement maintenance inspection protocols for sites where back-up generation and hydrocarbon storage is present [ESAP # 6].



Ooredoo runs an OHS technical training facility in Yangon, the Learning and Development Centre, where staff receive general OHS training, while specific Ooredoo, tower company and Radio Access Network vendor staff are trained in working at heights and antenna rigging. Ooredoo will ensure tha
t existing training policies and procedures are integrated into the corporate ESMS, ensuring current and future locations of operation are managed using training programs consistent with the HSE risks of the business line activities. Ooredoo will also develop an HSE incentive based program for Ooredoo staff if appropriate, and Ooredoo’s service providers and contractors supported by measurable key performance indicators [ESAP # 5].

Ooredoo currently employs direct employees. Oversight of all direct employment relationships is provided by the human resources function which is managed centrally from Ooredoo’ headquarters in Yangon. Company policies are included in employment contracts and address working conditions, terms of employment, leave, wages and benefits. This information is provided in the form of an employee handbook at the time of induction. All workers are covered by social insurance



Ooredoo has developed a Human Resources Policy and has developed an Employees Handbook, the latter currently under review for Ooredoo management approval. The HR Policy contains non-discrimination and equal opportunity conditions to avoid bias towards gender, health, disability, race or religion. Ooredoo’s staff is comprised of 52% female and 48% male employees, who are compensated equally. Ooredoo employs staff based on merit, with recruitment based on a role profile for each position and the completion of a pre-employment checklist that includes checking age, qualifications and experience prior to offering a position.



Ooredoo ensures that its main suppliers have acceptable human resource policies and practices as specified in contracts. This includes Ooredoo’s Managed Services Supply Agreement expressly prohibiting the use of child labor. As part of IFC’s investment, the company will review and where necessary augment existing HR policies, procedures, and employee manuals in a manner consistent with the requirements of PS 2. The company will ensure these documents are continued to be communicated with workers to ensure the content is clearly conveyed and feedback is collected and considered [ESAP # 5]. The company maintains ongoing communications with staff and as part of IFC’s investment Ooredoo will develop a worker grievance mechanism. - [ESAP # 5].



The Myanmar Labor Organization Law (The Pyidaungsu Hluttaw LawNo. 7 / 2011) which came into effect in March 2012 specifies provisions for workers to establish and join a labor union. At present there are no labor unions set up within Ooredoo. . There have been no instances of major retrenchment in the past and there are no plans by Ooredoo to do so in future.

Ooredoo applies a broad range of health and safety procedures to its operations to protect employees and ensure contractors are undertaking activities to an acceptable standard. As noted previously, all Ooredoo staff are provided with induction safety training, while the company provides specialist safety training based on the roles of different positions upon which staff are examined and internal certification is issued for completing the course. Each technician maintains a log book that is used to record the course, where it occurred, the course date, mark achieved and the signature of the examiner. The log book is also used to record any safety incidents that the staff member is involved in. Safety incidents are investigated by Ooredoo and the contractor
.



Ooredoo will build on its OHS monitoring efforts to develop and implement the following: i) a detailed OHS training and incentive program where appropriate for staff, contractors and their workers with training content consistent with local requirements and good international industry practice; ii) a detailed monitoring and reporting program consisting of the collection of key OHS statistics including near misses, root cause and trend analysis, verification of implementation of corrective actions, and other relevant components; iii) regular audits of construction sites and contractors responsible for construction and maintenance of telecommunications towers; iv) incorporation of OHS related clauses, including performance-dependent payment clauses where appropriate, into contractor/ supplier agreements [ESAP # 5].

Ooredoo’ seeks to educate communities on the hazards associated with the installation of telecommunications infrastructure. As part of IFC’s investment, Ooredoo will incorporate monitoring requirements for Ooredoo’s sites, service providers and contractors to ensure that sufficient demarcation and segregation of work and public areas are in place. During construction, unarmed night watchmen are occasionally employed on a case by case basis. When operational, telecommunications infrastructure presents a lower risk to the public, reduced further by all sites being enclosed by adequate access control measures, including fencing and locked gates. Consequently, security personnel are not required to oversee Ooredoo’s leased sites.



As described in the ESAP and as part of the development of each project ESMP (as defined by the ESMS), Ooredoo will review, and where necessary augment current public safety management practice to ensure a comprehensive community health, safety and security program consistent with the requirements of Performance Standard 4 is implemented [ESAP # 6].

Ooredoo currently leases tower space from telecommunications tower companies. Ooredoo requires its telecommunications tower companies to ensure land lease arrangements are negotiated on a willing buyer, willing seller basis, and similarly for temporary site access. As a condition of IFC’s investment, Ooredoo will develop procedures to cover public disclosure prior to the construction of any new Ooredoo location or any other free-standing facility [ESAP # 4].

As part of IFC’s investment the company will also develop and implement a community grievance mechanism relating to the operation of existing tower sites and construction activities. . As part of IFC’s investment, Ooredoo will review existing processes to ensure consistency with IFC’s Performance Standard 1 [ESAP# 4]. Ooredoo will continuously make available information to local community members on electromagnetic radiation from tower sites as needed, consistent with IFC’s Telecommunications Guidelines.

The company has employed a range of community engagement initiatives, focusing on health, education, women, youth empowerment, and tele-connectivity. The total company budget for such activities is up to $60 million over ten years. Specific programs include: funding the health non-governmental organization PACT (US) to run health diagnosis and treatment in specific rural villages; an education program in Yangon for youth shop workers who do not have access to education; improving 55 libraries with the provision of tablets and free data downloading; and the development of banking and agricultural development applications.

Ooredoo Myanmar
MICT Park, Building No.10, Block 2, Myanmar Info-Tech, Hlaing Township, Yangon, Myanmar.
Email: mailto:Info@ooredoo.com.mm

Broad Community Support is not applicable for this project

Ooredoo Myanmar(34170) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Ooredoo will review and, as required, develop and implement per IFC’s Performance Standards and guidelines: i) corporate level E&S Policies; ii) a corporate level integrated Environmental & Social Management System (ESMS) iii) supporting Standard Operating Procedures	31-Dec-2015	Completed	Completed	2/17/2016
Identification of Risks and Impacts: As part of the integrated ESMS, Ooredoo will develop and/ or formalize and implement: i) an Environment and Social Management Plan; ii) Cultural Heritage Management and Chance Finds procedures; iii) Emergency Preparedness and Response plan; iv) requirements for undertaking environmental and social impact assessments.	31-Dec-2015	Completed	Completed	2/17/2016
Organizational Capacity and Competency: i) The company will expand existing quality supervisor roles to include health, safety and environment aspects with roles and responsibilities to be clearly defined in the integrated ESMS and supporting Standard Operating Procedures; ii) Retain a corporate HSE manager, supported by adequate financial and staff resources, reporting directly to Ooredoo’s COO; iii) Ooredoo will ensure that service providers and contractors retain sufficient QHSE staffing capacity. The requirements will be defined in bid documents and subsequent legal agreements.	31-Dec-2015	Completed	Completed	2/17/2016
As part of the integrated ESMS, Ooredoo will formalize grievance mechanisms for affected communities and notifications of work procedures, to be adopted by service providers and contractors. The grievance mechanism will be supported by a 24hr call-center.	31-Dec-2015	Completed	Completed	2/17/2016
As part of the integrated ESMS, Ooredoo will review and, as required, develop and implement: i) an overarching HR policy consistent with IFC’s PS 2 for Ooredoo’s workforce, with supporting procedures. Ooredoo will communicate these documents with workers (direct or subcontracted) to ensure that the content is clearly conveyed and feedback is collected; ii) a program to monitor Ooredoo employee and service providers work practices including documentation of worker ID and age information, to ensure compliance with all child and forced labor provisions of PS2; iii) integrate and implement a detailed QHSE Superintendent training into existing training programs; iv) a detailed OHS training and incentive program for staff, service providers and their workers with training content consistent with host national requirements and good international industry practice; v) a detailed monitoring and reporting program consisting of a collection of key OHS statistics including near misses, root cause and trend analysis, verification of implementation of corrective actions, and other relevant components for all Ooredoo and its service provider activities; vi) undertake regular audits of construction sites and contractors responsible for the construction and maintenance of telecommunications towers by both Ooredoo QHSE staff and EPC contractor independent QHSE staff; vii) incorporation of OHS related clauses, including performance-dependent payment clauses, into all future service provider and contractor agreements; vii) worker Grievance Mechanism for all Ooredoo staff, service provider and contracted labor.	31-Dec-2015	Completed	Completed	2/17/2016
As part of the corporate QHSE management system, Ooredoo will review, and where necessary augment current public safety management practice requirements for its service providers and contractors with specific requirements for access control to construction sites and maintenance inspection protocols.	31-Dec-2015	Completed	Completed	2/17/2016