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

Telecom 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.

The project proceeds will be used for meeting business requirements including payment towards spectrum that may be auctioned by DoT in future and for general corporate purpose. The key issues associated with the project are the implementation of policy and application of environmental, health, safety and social management; and labor and working conditions, including employee and contractor occupational health and safety. These can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. As a result, it has been classified as a Category B project according to IFC’s Policy on Environmental and Social Sustainability.

PS3, PS4, PS5, PS6, PS7 and PS8 are not considered applicable given the nature of the company’s operations

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.

ICL has adopted a safety, occupational health and environment policy for management of environment, health and safety and social issues/aspects linked to its establishment and operations. Apart from this there are issue/aspect specific policies including those for human rights, CSR, training and scrap disposal which outline the company’s approach to dealing with such issues. Standard operating procedures and processes (like those for acquisition, design, construction, and deployment of technical sites, safety management, child and forced labour, sexual harassment, waste disposal, training etc), have been developed to ensure effective implementation of these policies.



The company relies on the contractor system and processes especially in case of management of passive infrastructure like land, shelter, tower structure; diesel generator (DG) set operation, among others. These are largely outsourced to reputed providers/companies like Viom, Indus Towers, GIL etc. Management of active infrastructure (mobile equipment, hardware technologies etc) is also mostly outsourced to specialized vendors like Nokia, Eriksson, and Huawei, among others. All the contractors/suppliers/business partners have to adhere to “code of conduct for ICL’s suppliers, vendors and partners”, which includes clauses linked to labour, human rights, non-discrimination, health & safety, environment including waste management in accordance with state and national laws. ICL’s role is mainly limited to monitoring and ensuring compliance to the specified conditions.



Typically the impacts associated with the sector include those on account of visual impacts, electromagnetic field (EMF), structural safety, noise (from generators in residential and commercial areas) and air emissions. Impact mitigation/management measures for these issues typically include camouflaging towers and fixtures, providing sound barriers where noise levels exceed prescribed limits, monitoring EMF, undertaking structural stability tests on a periodic basis, monitoring air emissions and ensuring proper disposal of scrap and wastes.



ICL has gradually moved away from the concept of purchasing/leasing land for construction of passive infrastructure facilities like towers, shelters, DG set operation yards etc. Most of these are now co-located/shared in the infrastructure providers/companies (like Viom, GIL, Indus) who in in turn charge monthly/annual fees for use of these infrastructure and facilities. As a procedure for site selection, ICL declines 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 has mapped its key internal and external stakeholders, which include employees, adjudicators, courts, licensors, industry associations, regulators, network operators and subscribers. The company formally engages with its stakeholders through industry meetings, feedback programmes and fiel
d based discussions to identify and work towards addressing concerns/grievances and meeting their expectations. In order to promote inclusive growth, the company encourages its partners to employ physically challenged people at its call centers. The company also encourages employment of women at its service centers. ICL’s CSR strategy focusses on education, healthcare, sustainable livelihood, infrastructure development and social change. The company engagement programmes (like “Behtar Zindagi” and “son of soil” aim to create awareness amongst communities (on aspects like agriculture, weather forecast and advisory, livestock management, inland and coastal fisheries etc) and promote rural employment (through engagement of rural day to day sales operations in villages).



ICL’s initiatives to reduce its resource use, conserve non-renewable energy sources, improve efficiency, and decrease the Greenhouse Gas (GHG) emissions from its mobile network operations and other business activities includes use of a) solar hybrid technology; b) hydrogen fuel cell hybrid technology; c) outdoor hardware; d) low power network hardware; and e) shared telecom infrastructure. The company promotes better carbon management, reuse of hardware and providing e-bill facility for its consumers. The above initiatives are aimed at reducing carbon emissions, reducing energy consumption, and reducing overall environmental footprint. The company handles and disposes waste (including hazardous waste) through registered vendors. Compliance on EMF radiation related regulation is another business priority at ICL. The company has made significant monetary investment in the purchase of EMF monitoring equipment and is compliant with existing DoT regulations. The company is proactive in policy development and public education initiatives led by the Cellular Operators Association of India (COAI) on the issue of EMF. A senior company official also heads the sub-committee on EMF. ICL has strengthened the internal systems and processes to meet EMF compliance guidelines. Resources for meeting compliance have been appointed in all the circles. The company has been working with COAI on the EMF portal as specified by DoT.



The company has adopted a “sustainability” agenda and endeavors to follow sustainable business practices balancing its economic growth with environmental and societal interests. To achieve this aim, the company has a) adopted a sustainability policy/vision, b) put in place a sustainability cell (managed by a sustainability manager reporting to the management) and a governance structure (with specific committee to oversee the policy implementation); c) set up systems to collect collect/generate data on identified sustainability indicators with an aim to benchmark and set/achieve performance improvements targets and d) initiated internal reporting to the committee on a quarterly basis on the progress made on these aspects. The company is in the process of engaging the servic
es of an international agency for implementation of an IT system capable of providing management with all data required to be managed and published in a Sustainable Development Report. ICL aims to start the process of internal reporting in near term and has set a target for an externally assured public report based on GRI G4 indicators. These sustainability initiatives will also see the company further aligning its performance to IFC’s E&S standards and requirements



Going forward the company will further improve/strengthen its systems and processes especially those linked to: a) supply chain and contractor management practices (including contract labour management covering aspects of welfare, safety, monitoring, and record keeping/documentation); b) waste handling and disposal practices (especially contractor practices with respect to managing waste from DG sets, and spill prevention and control of battery acids); c) energy efficiency; and d) stakeholder engagement practices. The company will further strengthen its contractor oversight and monitoring processes to manage and monitor E&S risks linked to its operations. The company will, in its sustainability programme/agenda include and adopt requirements of IFC Performance Standards and relevant EHS Guidelines to the extent relevant

ICL’s operations are carried out by approximately 16,000 employees, including contracted, casual and temporary workers. The company has a documented human resource manual, which lays down employment policies and procedures, covering amongst other aspects employment conditions and working hours, leave, recruitment, compensation, promotion, rewards and recognition, benefits and employee welfare, performance management, separation, protection and safeguards aspects relating to gratuity, pension, insurance, travel allowance. Other aspects of ICL’s human resource system cover processes including those for talent management, employee engagement, training and development, internal as well as external grievance handling/management, including a whistle blower policy. These policies and procedures are available to all employees either through company’s internal intranet or via the employee handbook for those employees engaged in rural operations. ICL’s systems for human resource management have earned several awards including the best telecom employer award in the Asia Pacific. Apart from this, the company also has an employee code of conduct which outlines standards of personal and professional conduct for all employees.



ICL has recently adopted a human rights policy which outlines the company’s commitment to developing a culture of respect and support for human rights, which include diversity in workplace, provision of secure environment for all personnel, proactive communications, and contribution to socio-economic development of communities where the company operates. The policy further encourages the company’s key suppliers to uphold human rights in their operations and communities and reinforce awareness on these issues.



The management of contractors’ employees relies primarily on the systems and processes of the vendor/supplier/contractor or business partner engaged by the company. The company’s key vendor/ supplier contracts include clauses addressing human rights aspects such as abolition of forced and child labour, worker safety and hygiene, absence of abuse and intimidation etc.



The occupational health and safety aspect linked to company’s operations are managed directly (for employees) by the company or through contractors (for contract or casual employees). The safety, health and environment policy of the company extends to its third party vendors/suppliers. Compliance to the same is monitored by the respective operations team/group within the company. The training programme/calendar of the company includes aspects of health and safety including those for construction safety (like working for height and in confined spaces) and emergency response planning including safety drills, evacuation, firefighting, and life and fire safety. These training programmes cover both permanent and contract employees.



Going forward ICL will further improve/strengthen its systems and processes especially those linked to supply chain and contractor
management and occupational health and safety. The company will strengthen its contractor oversight and monitoring processes to manage and monitor labour and OHS related risks linked to its operations

ICL recognizes the importance of stakeholder engagement and has as a business process mapped out both internal as well as external stakeholders. The company’s engagement programmes are aimed at encouraging participation and harnessing the transformational potential of mobile telephony and information technology. The company’s public and media campaign are targeted towards delivering social messages of inclusive growth, cleaner environment, better society and improved quality of life.

The company will continue to engage with stakeholders (as and when needed) to manage and mitigate impacts if any caused due to its operations. The company will take into account impacts during the siting process of all the types of facilities and infrastructure that it creates or leases for its operations. The company will disclose/make available information on electromagnetic radiation from tower sites as needed, ICL will be proactive in collecting and following up on complaints and seek speedy and satisfactory resolution of any complaints/grievances

Ms. Rachana Shetty
Assistant General Manager – Finance & Accounts
Idea Cellular Limited
''Windsor'', 5th Floor, Off CST Road,
Near Vidya Nagari, Kalina, Santacruz(E),
Mumbai – 400098
Tel: +91 95940 04000
Fax: +91 95940 03181
http://www.ideacellular.com

Broad Community Support is not applicable for this project