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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
Significant community health, safety and security issues are not expected to arise in this project hence PS 4 does not apply. The requirement of new land for the Project will be fairly limited. Any land required for network infrastructure (towers, base stations) will comprise of small plots of land. Company will lease / purchase those directly from the legal owners through a purely market-based transaction. Project does not involve any involuntary land acquisition or resettlement. As such, PS5 - land acquisition and involuntary resettlement does not apply. IFC’s review also indicated that no significant impacts related to Biodiversity (PS6), Indigenous Peoples (PS7) or Cultural Heritage (PS8) are expected due to the company’s operations hence these do not apply

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.

This project proceeds will be used for upgrade and expansion of a cellular network and for increasing its coverage and capacity in rural area of Bangladesh. The key issues associated with the project are implementation of a policy and procedures for environmental, occupational health, safety, and social management; and labor and working conditions, including employee and contractor/supplier occupational health and safety. These can be avoided or mitigated by adhering to generally recognized performance standards, guidelines and/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

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.

Robi has adopted a Health, Safety and Environment (HSE) Policy for management of environment, health and safety and social issues/aspects linked to its establishment and operations. The policy covers both the employees and contractors associated with the company’s operations. This policy states the company’s commitment to a) promoting positive, safe and healthy working environments and culture; b) preventing accidents and work related ailments/illness; c) continuously improve HSE management performance; d) protecting the environment through environmental friendly operation and e) improving use of natural resources through energy efficiency initiatives.

To ensure sound interpretation and implementation of this policy, the company has designed an environment, health & safety (EHS) procedure manual and an employee health & safety handbook covering standard operating procedures, guidelines, organizational structure with defined roles and responsibilities for EHS manager, employees, contractors, line managers and senior management. The manual also lays down requirements for training, periodic audit, documentation, management review and reporting to both internal as well as external stakeholders.

Issue/aspect specific policies and procedures based on risk assessment and analysis have been designed for management of risks and impacts associated with the operations of the company. Standard operating procedures for workplace health and safety include aspects like personal protective equipment, electrical safety, working at height, confined space, first aid medication, earthquake and structure collapse, road safety, contractor management and responsibilities linked to safety etc. Similarly work environment management procedures cover aspects like cleanliness/housekeeping, waste disposal, ventilation, dust and fume management, lighting, management of inflammable liquids/gases, office ergonomics, scrap handling and disposal etc. These policies and procedures outline the company’s approach to dealing with EHS issues linked to its operations.

The management of passive infrastructure like land, shelter, tower structure, diesel generator (DG) set operation etc is done through a wholly owned subsidiary of the group company “edotco” along with other contractors/suppliers. Edotco adheres to the EHS policies and procedures of the company. Apart from this it has established and implemented its own EHS manual. This EHS manual includes standard operating procedures for management of employee health and covers aspects like hearing protection and fitness for work etc. The occupational safety aspect of the EHS manual includes aspects like job safety analysis, energy isolation, electromagnetic field safety, optical fiber safety, emergency planning and response, chemical and waste management and internal as well as external audit and reporting parameters. Edotco has a clearly defined organizational structure with assigned roles and responsibilities to manage the EHS
risks of its operations.

Robi’s contractual agreement with edotco and other contractors/suppliers includes E&S clauses including a) compliance to statutory requirements, and b) mitigation/management of identified impacts (identified during site screening/survey and during construction and operations phase). All the contractors/suppliers/business partners in their contractual agreement with the company commit to adhering to, ‘supplier conduct principles” which include clauses linked to labour, respect for basic human rights, health & safety, environment including waste management. Critical performance benchmarks are defined and identified for each of these aspects. The company’s role is mainly limited to monitoring and ensuring compliance to these performance parameters. Annual audits are carried out to ensure that the critical performance parameters are strictly adhered.

For each potential tower, cable laying, shed etc, the company or the contractor completes a site survey report which covers relevant environmental and social risks and impacts and their mitigation/management strategies. These typically cover aspects including those linked to visual impacts, structural safety, noise (from generators in residential and commercial areas) and emissions to air. The site acquisition process flow chart and the standard operating procedure for technical site assessment prior to acquisition lists down these requirements.

The company purchases or leases land for passive infrastructure (like towers, shelters, DG set operation yards etc) based on the negotiated settlement with the land/structure owner. Apart from this it also shares/co-locates infrastructure with other service providers/companies who in in turn charge monthly/annual fees for use of these infrastructure and facilities. As a procedure for site selection, the company 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 community meetings, feedback programmes and field 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. The company’s CSR strategy focusses on education, healthcare, sustainable livelihood and environment protection/preservation. The company’s CSR strategy focusses on education, healthcare, sustainable livelihood, infrastructure development and social change. The company engagement programs (like “mAgri and mEductaion” aim to create awareness among
st communities (on aspects like agriculture, weather forecast and advisory) and promote rural education, employment and social awareness building.



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 designated staff/personnel and set up systems to collect collect/generate data on identified sustainability indicators with an aim to benchmark and set/achieve performance improvements targets. The company aims to start internal reporting by the end of 2016 and has set a target for an externally assured public report based on GRI indicators by the end of financial year 2017. 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 EHS and social management systems and processes especially those linked to supply chain and contractor management system/practices (including contract labour management covering aspects of a) welfare, safety, monitoring, record keeping/documentation etc), and c) stakeholder engagement practices (linked to grievance handling). The company will further strengthen its contractor oversight and monitoring processes to manage and monitor E&S risks linked to its operations by streamlining requirements in contractual agreements, regular visit/ follow up and increasing coverage and frequency of EHS and supply chain audits. The strengthening process would also include steps/actions like a) screening potential key suppliers, vendors, and core contractors on their past EHS labour related performances and current capacities, b) including E&S terms in its agreements consistent with IFC and local E&S standards; and c) incorporating termination clauses in the event of continued non-compliances on EHS and labour related aspects. The company will, in its sustainability programme/agenda include and adopt requirements of IFC Performance Standards and relevant EHS Guidelines. The company will ensure that its operations comply not only with all applicable national E&S laws and regulations, but also with IFC’s Performance Standards 1 through 8 (as applicable).

Robi’s operations are carried out by approximately 6000 personnel (including contractual/casual/temporary workers) who are employed in different functions. The company has a documented Human Resource (HR) manual, which lays down policies and procedures for its employee (covering amongst other aspects employment condition 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 Robi’s HR system covers processes including those for talent management, employee engagement, training and development, internal as well as external grievance handling/management (like whistle blower policy) etc. These policies and procedures are available to all employees either through the company’s intranet or as employee handbook or both. The company’s HR systems have been in the past earned it several awards for good HR management. Apart from this, the company also has a “code of conduct and business ethics” which outlines standards of personal and professional conduct for all employees and covers aspects like equal opportunity and diversity, zero tolerance for harassment, confidentiality etc. The company has an ethics officer who ensures and monitors compliance to this code of conduct and business ethics and reports to the board/senior management on a periodic basis.

The contractor employee management of the company relies primarily on the systems and processes of the vendor/supplier/contractor or business partner engaged by the company. The company requires all its contractors to have third party registration where statutory compliances are checked and verified by authorized representatives. All contractors sign/commit to addressing the supplier code of conduct which covers aspects such as avoiding forced and child labour, ensuring worker safety and hygiene, absence of abuse and intimidation etc in their business activity and these clauses are included in their contracts. The company monitors the performance of its key contractors.



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). All the contractors are expected to follow the Health, Safety and Environment (HSE) Policy of the company and ensure safe and healthy working condition for their workers. 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 at height and working in confined spaces) and emergency response planning including safety drills, evacuation, firefighting, life and fire safety etc. These training programmes cover both permanent and contract employees.



The company will going
forward further improve/strengthen its implementation systems and processes especially those linked to supply chain and contractor management and occupational health and safety. The company will strengthen implementation of its contractor oversight and monitoring processes to manage and monitor labour and OHS related risks linked to its operations as discussed in PS 1. The company will ensure that the contractor systems and processes meet the statutory requirements as well as those related to PS 2

The company’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. However, some of these initiatives (like hydrogen fuel cell hybrid technology) have met with limited success. The company promotes better carbon management, re-use of hardware and providing e-bill facility for its consumers. The above initiatives are aimed at reducing carbon emissions, reducing energy consumption, reducing environmental footprint. The company handles and disposes waste (including hazardous waste) through registered vendors. At present the company does not have a programme to monitor EMF radiation (not a statutory requirement) but plans to take this up in the near future.



Impacts linked to visual issues, structural safety, noise (from generators in residential and commercial areas) and emissions to air are mitigated/managed through camouflaging of towers and fixtures, undertaking structural stability tests on a periodic basis, providing sound barriers (where noise levels exceed prescribed limits due to DG operation) and monitoring air emissions (where specific concerns are reported from DG operations) and ensuring proper disposal of scrap and wastes (primarily used oil from DG sets). Going forward the company will further improve/strengthen its systems on issues like waste handling and disposal (especially contractor practices with respect to managing used oil (hazardous waste generated) from operation of DG sets and replacement of used batteries (preventing spillage/contamination etc) and enhancing energy efficiency. The company will ensure that all new or renewed agreements with any core, long-term contractors/suppliers include clauses for implementing pollution prevention, abatement, and mitigation measures for relevant impacts in compliance with IFC Performance Standards. The company will monitor compliance with those terms, and will seek improvement in the event that non-compliance is identified

Robi recognizes the importance of stakeholder engagement and has as a business process mapped out covering both internal and external stakeholders. 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 engages with local communities as and when needed to manage and mitigate impacts, if any, caused due to its operations. The company will take into account public perceptions about impacts during the siting process of all the types of facilities and infrastructure that it creates or leases for its operations. The company will be proactive in collecting and following up on complaints from community members and seek speedy and satisfactory resolution of any complaints/grievances.

The company engages and partners with NGOs and other civil society groups to implement its community development programmes. The social obligation fund of the company has in the past, seen the company partner with local as well as international NGOs to promote health, education and improved environment management practices

Yap Wai Yap
Chief Financial Officer
Robi Axiata Limited
Robi Corporate Office
53 Gulshan South Avenue
Gulsan-1, Dhaka-1212
Bangladesh
Telephone: +88-02-9887146-52
Fax: +88-02-98885463

Broad Community Support is not applicable for this project

Robi Axiata II(36136) Appraisal Disclosure Snapshot – Version 3
Description	Anticipated Completion Date
Update and Strengthen the existing Environment, Health & Safety and Social Management System (EHSMS) and ensure its implementation across supply chain and contractors (especially practices around labour, safety, waste handling and management, monitoring, resource efficiency etc)	31-Oct-2015
Strengthen internal capacities (Hiring of EHS manager) to manage the EHS related issues in accordance with IFC Performance Standard requirement.	31-Oct-2015
Company will review and strengthen its service agreement conditions on E&S aspects that it enters with telecom tower operators. E&S related performance conditions must include among others: E&S related regulatory compliance; compliance to local labor laws; compliance to PS 2 requirements on child/forced/bonded labor and institution of an occupational health and safety (OHS) management systems; institution of emergency response infrastructure and management systems including life and fire safety management; waste management; and screening on biodiversity and IPs risks. The company will integrate monitoring and auditing mechanism to verify regulatory compliance specifically labor law compliance and compliance to E&S conditions by its contractors.	30-Jun-2021
Company will review and update their HR policies, procedures and training to include a sexual harassment and gender-based violence policy, including Code of Conduct toward local communities, as well as grievance mechanisms to ensure anonymous, confidential and survivor centered approach to GBV, in the workplace or community, by employees or their contractors and by community members. The project teams and auditing teams of the company will periodically review, monitor and report on compliance with the sexual harassment and gender-based violence related policies and the code of conduct.	30-Jun-2021
Company will review and strengthen its COVID-19 infection prevention, control and response plan, consistent with the provisions under IFC Performance Standard # 2 and #4 and Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace. Moreover, the company will ensure ongoing compliance with IFC Performance Standards – especially provisions under PS2: Labor and Working Conditions and PS4: Community Health Safety and Security.	30-Jun-2021