35725 - IHS Nigeria 2

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Environmental & Social Review Summary

Project Number

35725

Company Name

IHS NIGERIA LIMITED

Date ESRS Disclosed

Aug 21, 2014

Country

Nigeria

Region

Africa

Last Updated Date

Jun 12, 2021

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Sep 25, 2014
Signed : Oct 9, 2014
Invested : Nov 6, 2014

Sector

Other (Including Satellite Telecommunications, Radio and Television Broadcasting, etc.)

Industry

Telecommunications and Technology

Department

TMT, Venture Capital & Funds

Project Description

This project involves a proposed repeat investment by IFC in IHS Nigeria, a 100% subsidiary of IHS Holdings, also an existing IFC client. IHS Holdings owns and operates mobile telecom tower companies in Rwanda, Nigeria, Cameroon, Zambia and Cote d’Ivoire.

The project consists of the acquisition and upgrade of Etisalat’s portfolio of 2705 towers and the construction of new tower sites under a program of building towers to suit the needs of clients of IHS Nigeria. The total project cost is approximately US$1,355 million. IFC will contribute up to $50 million for its own account and raise an additional $150 million from participant banks.

Overview of IFC's Scope of Review

The review of this project consisted of IFC’s appraisal of environmental and social (E&S) documentation provided by IHS Nigeria Plc (“IHS Nigeria” or “the company”), including a set of human resources policies and procedures, a technical site survey form, an agreement between IHS Nigeria and a security services provider, and an Annual Monitoring Report covering the company’s operations in 2013.

IFC’s previous investment in IHS Nigeria (IFC project 29741) was disclosed on July 12, 2010. Based on review of the Annual Monitoring Report for 2013, the current environmental and social (E&S) performance of the company is considered to be Satisfactory.

IFC’s appraisal for the proposed new investment considered IHS Nigeria’s E&S management policies and procedures and gaps between them and IFC requirements. Where necessary, corrective measures intended to close those gaps, within a reasonable period of time, are summarized in the paragraphs that follow. Through implementation of those measures, the project is expected to be operated in accordance with Performance Standard objectives.

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

The key environmental and social (“E&S”) issues associated with the project are in the construction of towers; labor and working conditions (including employee and contractor occupational health and safety); and pollution prevention and abatement.

As 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 might result, the proposed investment has been classified as a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects.

PS5, PS6, PS7 and PS8 are not considered applicable given that most sites will be leased, and any purchased ones are expected to involve a willing seller; no operations are expected to require biodiversity conservation or any substantial management of living natural resources; no Indigenous Peoples are expected to be affected; and no important cultural heritage is expected to be involved.

Environmental and Social Mitigation Measures

Stakeholder Engagement

IHS Nigeria is committed to complying with IFC Performance Standards on disclosure and community engagement. Accordingly, IHS Nigeria will post at least one sign at each new site at least three days prior to the start of work.

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

IHS Nigeria will continuously make available information to local community members on electromagnetic radiation from tower sites if requested, consistent with IFC’s Telecommunications Guidelines.

Broad Community Support

Environmental & Social Action Plan

Title	Anticipated completion Date
PS2: IHS Nigeria will add to its human resources policies and procedures a reasonable limit on hours worked per week.	09/30/2014
PS3: IHS Nigeria will develop and implement policies and procedures to provide for all sites to be acquired as follows: (a) auditing all such sites to assess such factors as noise from generators, waste management, leakages, and secondary containment around fuel tanks; and (b) repairing at all such sites any leakages or replace the relevant equipment; improving waste management wherever needed; and adding soundproofing and secondary containment wherever it is missing.	09/30/2014
PS4: IHS Nigeria will develop and implement the following new documentation regarding security service providers: (a) new terms to be included in all agreements with security providers to ensure that they screen individual guards and train them on the use of force; (b) procedures for IHS Nigeria to monitor compliance with the new terms to be included in agreements with security providers, and to seek improvement in the event that non-compliance is identified; and (c) procedures for managing any concerns from local community members about its security services.	09/30/2014

**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.

Projects

Environmental & Social Review Summary

Project Description

Overview of IFC's Scope of Review

E & S Project Categorization and Applicable Standard

Identified Applicable Performance Standards

Environmental and Social Categorization and Rationale

Environmental and Social Mitigation Measures

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

Stakeholder Engagement

Stakeholder Engagement

Local Access of Project Documentation

Broad Community Support

IFC's Determination of BCS

Environmental & Social Action Plan

Environmental & Social Action Plan

Press-Release

Related SII

Similar Projects

Information on E&S Complaints and Grievance Mechanisms

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