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
PS5 (Land Acquisition and Involuntary Resettlement) is not applicable as land acquisition is voluntary, based on negotiated leasing agreements. 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 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.

This is a Category B corporate investment as per IFC’s Sustainability Policy. Existing and future telecommunications towers are considered to have limited environmental and social impacts. IGT’s medium-term growth strategy is focused toward the development of additional telecommunications towers throughout Myanmar.

Key risks 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; 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 the disposal of solid and hazardous waste during construction and operations; v) ensure the 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.

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.

Since acquiring its operational license in April 2014, IGT have developed a number of Environmental and Social policies, along with an anti-bribery and corruption policy. The company currently operates an integrated Quality, Health, Safety, Environment (QHSE) management system, organized to comply with ISO 9001, ISO 14001, and OHSAS 18001. The QHSE Management System defines the objectives, organizational responsibilities and legal requirements, including host national requirements and referencing good international industry practice for additional guidance (Health and Safety at Work Act, United Kingdom).



As part of the development of the QHSE management system, the company has drafted a number of complementing procedures covering the activities associated with tower construction and operations within Myanmar, including i) control of contractors, ii) incident reporting and investigation, iii) first aid, iv) noise in the workplace, v) hazardous waste management, vi) manual handling, vii) personal protective equipment procedures, viii) lone working, ix) climbing and working at heights, and x) underage workers.



Similarly, IGT has developed a supplier code of conduct outlining the minimum set of standards for supplier and contractors including labor standards; human rights; forced labor; child labor; non-discrimination; employment conditions; health, safety and the environment, management of hazardous wastes; electrical safety; overhead working operations; welding and cutting operations and the usage of compressed gasses; excavation; permit to work systems; housekeeping and anti-corruption.



IGT maps potential sites to be acquired or developed according to requests from its clients as well as based on IGT’s own analysis of potential future need for cellular service coverage. The company subsequently identifies and assesses risks and impacts relating to each potential site. Site selection identifies a number of environmental and social aspects, including access availability and associated impacts; owner documentation and confirmation of land tenure, including the presence of informal settlers; archaeology and cultural heritage; assessment of construction and operational impacts; safety, which includes consideration of spark source isolation and shelter temperature; housekeeping; waste generation; structural safety; electrical safety; signage and display; assessment of working at heights; fire and emergency preparedness and training. Where applicable, these may also include visual and noise impacts arising from diesel generators in residential and commercial areas. Avoidance measures are in place to ensure that battery back-up is prioritized over generator back-up during the hours of darkness. Among IGT’s business objectives is to offer tower space to multiple cellular service operators in order to avoid the need and costs of building multiple towers in proximity to one another. The practice minimizes potential cumulative visual and
noise effects.



With regard to materials suppliers, much of IGT’s materials supply for the construction of telecommunications towers has been from outside Myanmar. The company has undertaken audits of potential suppliers focusing on quality and safety in the supplier’s workplace.



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 the corporate-wide QHSE 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. The revised QHSE management system will also require the development of an Environmental and Social Management Plan (ESMP) for each new project setting out: i) measures to mitigate adverse 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 IGT will augment existing policies procedures at both the corporate and contracting levels, which will be finalized within a timeframe agreed with IFC, to ensure that 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 Safety Guidelines (ESAP#1).



IGT operates in a diverse number of locations throughout Myanmar, and retains a range of contractors and sub-contractors, who rely on short term labor to deliver IGT’s construction portfolio. To manage E&S risk, IGT has retained an experienced QHSE manager who has, among other responsibilities, developed the corporate QHSE management systems and policies. Similarly, an additional QHSE resource has been retained to support the QHSE manager’s role and two QHSE auditors have been retained and trained to assist in the supervision of IGT’s QHSE monitoring of construction sites. To provide additional operational capacity to manage IGT’s asset and capacity growth strategy, IGT will retain additional qualified QHSE superintendents to support the implementation of the augmented QHSE management system at the contracted and sub contracted levels. Once implemented the QHSE function will i) ensure contractors deployed by each project will meet relevant provisions of IGT’s QHSE management system and ensure implementation of the ESMP as applicable to their respective activities; ii) HSE&S training of IGT 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 QHSE management system effectiveness and implementation of measures for system upgrade; and vi) support the QHSE manager in the quarterly reporting of HSE&S performance to IGT’s Board of Directors and investors.



IGT currently plans and implements training programs according to good international industry practice. These include aspects such as the identification of workplace hazards, the use of personal protective equipment and collective protection equipment, working at heights, and the roles and responsibilities of employers and employees. IGT 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.



IGT will ensure that existing training policies and procedures are fully integrated into the corporate QHSE management system, 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, IGT 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.



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 at least one attendant staff across three shifts per day. Complaints are ticketed and logged with follow-up procedures in place to close out concerns in a time-specific manner.

IGT currently employs approximately 300 direct employees. Oversight of all direct employment relationships is provided by the human resources function which is managed centrally from IGT’s headquarters in Yangon. 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. The company’s approximate 35 contractors, most of which are retained to undertake telecommunications tower construction activities, each employ approximately 30-40 workers on average. All workers, whether full-time or on daily contracts, are covered by social insurance according to local labor requirements.



To date, IGT have developed a number of human resources policies and procedures, covering compensation, disciplinary and grievance procedures, an accommodation and travel policy, company vehicle policy and a driver policy. The company will review and where necessary augment existing HR policies, procedures, and employee manuals. The company will ensure these documents are communicated with workers so that the content is clearly conveyed and feedback is collected and considered. The company maintains ongoing communications with staff and receives grievances through monthly staff meetings and staff-supervisor meetings.



IFC found no indications of the Sponsor restricting freedom of association at the workplace. The Myanmar Labor Organization Law (The PyidaungsuHluttaw Law No. 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 IGT, although the company is committed to supporting initiatives by workers to set up a labor union should they wish per the Labor Organization Law. There have been no instances of major retrenchment in the past and there are no plans by IGT to do so in future.



As described above in PS1, IGT will build on its OHS monitoring efforts to develop and implement the following: i) a detailed OHS training and incentive program 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, into contractor agreements.



IFC’s review found no instances of forced/ indentured or child labor practices at construction sites. At construction sites, identification documents of workers are inspected to verify age information. IGT currently has drafted a
procedure to ensure the prevention of the use of underage labor by construction contractors and sub-contractors which, as part of IFC’s investment will be completed in a manner consistent with all child and forced labor provisions of PS2.

The preferred energy supply for IGT’s tower sites is the national electricity grid although additional, autonomous, power solutions are required due to the absence or poor reliability of grid-supplied electricity. The most common power solution is through diesel powered auxiliary generators (typical capacity of 20 kva) equipped with self-contained fuel storage. No sites are presently scheduled contain diesel back-up power generation with volumes greater than 1000 liters per site. In the event that a project location is required to house greater than 1000 liters at a site, the revised QHSE management system 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 QHSE management system, the company will implement maintenance inspection protocols for sites where back-up generation and hydrocarbon storage is present.



As outlined previously, IGT has established policies and procedures for hazardous and non-hazardous waste management at tower sites, and includes terms in its agreements with contractors that cover pollution prevention and abatement.



In an effort to become more energy efficient, the company is presently researching renewable and hybrid technologies (solar/diesel) for incorporation into the autonomous power options. However, the final selection of auxiliary and autonomous power sources will depend on reliability and financial feasibility factor.



Additionally, during the design of the tower site layout, the company explores opportunities and options to reduce the potential for nuisance noise to nearby residences due to the use of auxiliary generators.

IGT’s seeks to educate communities about the hazards associated with the construction of telecoms towers. As part of IFC’s investment, IGT will implement an ongoing monitoring program of IGT’s construction sites and contractors to ensure that sufficient demarcation and segregation of work and public areas are in place. When operational, telecommunications towers represent a lower risk to the public, reduced further by all sites being enclosed by adequate ingress protection measures, including fencing and locked gates. The company monitors each operational site. Additionally, the company has a security management program to address potential safety concerns in conflict and post-conflict regions of Myanmar, including the avoidance of areas where the safety of construction contractors could be compromised. Consistent with host national law, in the event private security is required, such services will be unarmed.



As described in the ESAP and as part of the development of each project ESMP (as defined by the corporate management system), IGT will review current public safety management practice and develop and implement a comprehensive public safety program consistent with good international industry practice.

IGT’s stakeholder engagement currently occurs as a result of the site selection and land access for new tower sites. In addition to the formal permitting process, in the early stages of site selection the company secures acceptance of the tower by local township officer (village chief), property owner, and property neighbor. IGT negotiates lease fees and temporary site access on a willing buyer, willing seller basis. The most common types of environmental and social concerns raised by affected stakeholders during the engagement with IGT are the risk of electromagnetic radiation, noise, and the risk of lighting. The company explains how these risks are managed and shares information as needed including, for example, copies of a public information handout on electromagnetic radiation prepared by the Myanmar Ministry of Information and Telecommunications. IGT is also in the process of finalizing a Stakeholder Engagement Plan (SEP) consistent with the IFC Performance Standards. The SEP outlines mapping, engagement and disclosure activities, grievance management and monitoring and evaluation for each of the three milestone-level phases: site acquisition; construction; and operations and maintenance. It further includes a contractor management component to ensure compliance with plan standards by IGT’s contractors and otherwise attempts to align with other related components, including QHSE policies and procedures, community health, safety and security, and pollution prevention and resource efficiency. The SEP includes requirements for posting of signs at all tower construction site with the phone number and email of IGT’s call center, where community members can contact IGT 24 hours a day to lodge complaints or concerns. The SEP also includes a procedure to register, process, and respond to complaints from community members in a time-specific manner.

AYAD CHAMMAS
CHIEF EXECUTIVE OFFICER
IRRAWADDY GREENT TOWERS LIMITED
308 AHLONE ROAD
DAGON TOWNSHIP, YANGON
MYANMAR
mailto:ayad.chammas@irrawaddytowers.com
+95 9798601600

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Environmental and Social Management System (ESMS). IGT will review and, as required, revise and implement per IFC’s Performance Standards and guidelines: i) corporate level E&S Policies, with specific reference to - IFC’s Performance Standards, - labor and - occupational health and safety ii) a corporate level ESMS and supporting procedures, including but not necessarily limited to: - standardized site Environmental and Social Management Plans - Excavation Safety Standard Operating Procedure - Working at heights - Site Risk Identification Procedure, with specific focus toward a) stakeholder engagement; b) land negotiation; c) visual impacts; d) cultural heritage; and e) noise impacts.	08/01/2016
Identification of Risks and Impacts: As part of the corporate QHSE management system, IGT will develop and/ or formalize and implement: i) Supply chain management audit procedures ii) Cultural Heritage Management and Chance Finds procedures; iii) Emergency Preparedness and Response plan (EPRP);	08/01/2016
Organizational Capacity and Competency i) The Company will ensure suitably qualified QHSE field superintendents are retained – as a minimum - at a ratio of no more than 50 construction projects to 1 QHSE field superintendent.	08/01/2016
Stakeholder Engagement. As part of the corporate QHSE management system, finalize draft Stakeholder Engagement Plan, outlining mapping, engagement and disclosure activities, grievance management and monitoring and evaluation for each of the three milestone-level phases: site acquisition; construction; and operations and maintenance.	08/01/2016
Labor and Working Conditions As part of the corporate QHSE management system, IGT will develop and implement: i) an overarching HR policy consistent with IFC’s PS 2 for IGT’s workforce, with supporting procedures. IGT 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 IGT employee and contractor work practices including documentation of worker ID and age information, to ensure compliance with all child and forced labor provisions of PS2; iii) a detailed OHS training and incentive program for staff, contractors and their workers with training content consistent with local requirements and good international industry practice; iv) 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; v) regular audits of construction sites and contractors responsible for construction and maintenance of telecommunications towers to be undertaken by qualified QHSE field superintendents; vi) incorporation of OHS related clauses, including performance-dependent payment clauses, into all future contractor agreements; vii) worker Grievance Mechanism for all IGT staff and contracted labor.	08/01/2016
Resource Efficiency and Pollution Prevention As part of the corporate QHSE management system, IGT will develop and implement: i) Maintenance inspection protocols for sites where back-up generation and hydrocarbon storage is present ii) Policies and procedures for the management of hazardous and non-hazardous waste at telecommunications tower sites, and include terms in contractor agreements that cover pollution prevention and abatement.	08/01/2016
Community Health, Safety and Security As part of the corporate QHSE management system, IGT will review, and where necessary augment current public safety management practice with specific requirements for access control to construction sites.	08/01/2016