PS5 on Land Acquisition and Involuntary Resettlement and PS7 on Indigenous Peoples are not considered to be applicable because all new tower sites will be acquired on a willing seller-willing buyer basis with no involuntary resettlement, and the World Directory of Minorities and Indigenous Peoples does not include population groups that would be viewed as Indigenous Peoples in the Comoros.  Given the stage of the project, where the identification of the new sites is still to be carried out, the likelihood of adverse impacts on biodiversity and cultural heritage is unknown and PS6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources and PS8 on Cultural Heritage are not considered applicable; however the company will develop relevant risk screening and assessment procedures to be implemented during site selection to avoid sensitive sites, as described in PS1 below.  

The key E&S risks associated with the project are in the construction of towers; labor and working conditions (including employee and contractor occupational health and safety); possible pollution and diesel and oil spillage from refuelling and servicing generators; risks to communities as a result of vehicle movement and tower safety, including risk of tower collapse, illegal access to the tower and the base stations, with risks of falling and electric shock.  In addition, risk may be posed by security guards if not trained in use of minimum force and appropriate conduct toward workers and Affected Communities.  The islands have important biodiversity areas and cultural heritage but these risks can generally be avoided and mitigated effectively through siting of towers and base stations. 

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 Policy on Environmental and Social Sustainability.  

At present, Telma has only informal arrangements to assess and manage E&S risks and impacts, and although compliant with applicable laws of Comoros, will need to make a number of improvements to ensure compliance with IFC Performance Standards, and to adopt good international industry practice as discussed in the relevant parts of the applicable World Bank Group EHS Guidelines.  Each site is permitted to operate but there are no requirements by local authorities for environmental and social assessment in order to obtain permits. 

Under IFC’s investment, Telma will appoint a qualified person at its headquarters to be an Environment Health, Safety and Social (EHSS) coordinator, who will be responsible for developing and implementing an integrated E&S management system (as per the attached E&S Action Plan item #1).  Telma’s new E&S management system will include policies and procedures to provide for the assessment and management of all relevant site development and operations E&S issues commensurate with their risks and impacts, and to provide the necessary E&S requirements, including performance monitoring for selected key indicators to monitor and ensure compliance with applicable national laws and standards and with IFC Performance Standards.  As a key element of the E&S management system, Telma will develop and implement an E&S Policy. 

Telma will develop a procedure for screening proposed base station sites to determine the sensitivity of such sites and, within the constraints of the technical requirements, avoid such sites, wherever possible.  Telma will define E&S screening and assessment criteria to be met, as a result of the risks and impacts identification, consistent with IFC Performance Standards, in order to proceed with the development of any site; the company will not develop sites that cannot be expected to comply with applicable E&S standards, including IFC Performance Standards, and before all relevant local permits are obtained. Where sensitive sites cannot be avoided, Telma will perform or commission E&S impact assessment (ESIA) which will be carried out by competent professionals (as per the attached E&S Action Plan item #2).  The ESIA will include a framework for E&S management plans to be developed and implemented during installation and operation of the base station. Telma’s site screening procedure will include biodiversity criteria apposite to the significant biodiversity values that exist for the country, and, consistent with IFC Performance Standard 6, will adopt the mitigation hierarchy of avoid, minimize, rehabilitate or offset in respect of the siting of new towers and base stations as detailed in ESAP Action Item #2.  Telma’s site screening procedure will also include cultural heritage criteria, consistent with the requirements of IFC Performance Standard 8, and the company will develop and ensure implementation by contractors of a chance finds procedure.

Telma’s key contractors (Camusat and Huawei) are international companies that have well developed E&S systems. Telma will nonetheless screen contractors and primary suppliers to ensure that they are well-established companies with solid track records in EHS management and labor compliance.  Telma will include E&S terms in its agreements with contractors and primary suppliers (as per the attached E&S Action Plan item #3). Those terms will be consistent with IFC Performance Standards, in addition to complying with local E&S laws and regulations, and will cover topics including labor and working conditions, occupational health and safety, and pollution and waste management.  In the case of existing agreements, Telma will ensure that the new E&S terms, consistent with IFC Performance Standards, are included as amendments.  Telma will monitor compliance with E&S terms in its agreements with contractors and primary suppliers, and will include in the agreements provisions that allow the company to require corrective actions in the event that non-compliance is identified.

Telma has a detailed HR manual that includes the company’s HR policy and specifies labor and working conditions.  Each employee is expected to sign acceptance of these conditions when starting work. Each employee is provided with a copy of the conditions, which are also presented in poster form on the main noticeboard in the HQ building. The working conditions are consistent with Comoros labor law, which is based in turn on conventions of the International Labour Organisation (ILO) (all eight fundamental ILO conventions were ratified between 1978 and 2004) and are thus consistent with the requirements of PS2.  The conditions include a 40-hour workweek, agreed salary scales as a function of technical competence and level of work, the provision of a safe and productive work environment, and limits on overtime work.  The nature of the work generally precludes unskilled workers, and so the risk of child or forced labor is negligible. Telma is currently dependent on outsourcing much of the active maintenance work on its network, but intends to grow the capabilities of the company over time to reduce that dependence.    

The company currently employs 98 people, of which 31 are women and Telma promotes gender equity in its workforce. Collective bargaining is allowed but the Telma workforce is not yet unionized.   Workers’ representatives are nominated to represent the workers and there are frequent meetings (at least monthly) between management and these representatives to raise and resolve grievances.  There has been no industrial action to date, which Telma attributes to the effectiveness of the workers’ representatives in addressing worker grievances. In the early stages of establishing the company Telma made use of contractors to assist with the commercial processes needed by the company in the Comoros, with upfront short-term contracts, so there was no retrenchment  per se  at the end of this phase of the company’s development. 

Telma is required to report regularly to the telecommunications regulator on  inter alia  occupational health and safety (OHS) performance.  Telma ensures that personnel who must climb towers are effectively trained in working at heights and prohibits tower access to untrained personnel. Telma will develop a risk register that includes all OHS risks associated with the company’s operations and tower sites, including physical, chemical, and electromagnetic radiation (EMF) hazards, and specific threats to women (as per the attached E&S Action Plan item #3).  For each risk identified, the company will develop and implement suitable mitigation, the training required for such mitigation to be effective together with formal records of such training. Telma will maintain up-to-date OHS indicators of performance.  The company will also compel and monitor contractors and primary suppliers to comply with PS2 requirements including OHS requirements, especially tower infrastructure supply and maintenance contractors. Those requirements will be specified in the contractor’s contracts (as per the attached E&S Action Plan item #4).                                                      

All Telma’s towers have hybrid power generation (diesel engines that charge batteries) and many of the sites have solar power (some 40% of towers).  High levels of electricity independence were required due to the poor performance of the national electricity supply grid, but this has improved over time to about 97.5% grid power currently available.  Due to the high cost of grid supplied electricity, Telma will progressively include solar power at some 90% of their sites.  The tower sites have been designed and installed according to good international industry practice, including practice described in the WBG EHS Guideline on Telecommunications, having been installed by a reputable international contractor. 

In 2016, Telma used approximately 30 MWh of electricity and approximately 13 000 litres of fuel for its back-up generators.  This translates to approximately 400 CO2eq ton/year for 2016.  Telma will continue to track these measurements.  

All diesel storage tanks are integrated within the generators and are dual skinned to prevent rupture and leakage. The generators are also cladded with baffling that reduces ambient noise. 

Waste quantities are small and limited to oil/fuel-contaminated materials, waste oils and e-waste.  There is no hazardous waste facility on the island and as a result Telma has plans to facilitate, in conjunction with other hazardous waste producers, the establishment of a hazardous waste disposal service for the Comoros.  Waste oils are currently stockpiled on the island pending the establishment of safe disposal options.  The company will develop and implement a waste management plan, consistent with the requirements of this Performance Standard (as per the attached E&S Action Plan item #5). The waste management plan will include provisions for hazardous waste management and the development of a dedicated e-waste program that serves to ensure the safe disposal of e-waste. 

The company uses neither herbicides nor rodenticides at the masts clearing vegetation by hand and using traps to control rodents.  The company is investigating the use of high frequency noise to deter rodents from the base stations, and Telma protects cables with gravel, which is typical practice to avoid having to use rodenticides.                                                  

Potential threats to local communities stem from project related traffic , risk of masts collapsing, access to tower sites, electrical and electromagnetic radiation risks, and security personnel.  Telma has a series of rules governing safe (defensive) driving practices with vehicles being monitored by GPS for speeding and harsh breaking.  Masts are enclosed by security fences and have permanent security guards to prevent illegal access to the masts.  The masts are regularly serviced to ensure mast stability and prevent risk of collapse. Security is unarmed, but anyway, Telma will adopt the voluntary principles on human rights to ensure that security personnel do not commit human rights abuses (as per the attached E&S Action Plan item #6). This will include policies and procedures for assessing security risks, managing security services, training on the use of force, and screening of potential security service firms, all consistent with the requirements of PS4. Telma will include such terms in any new or renewed agreements with security providers and include amendments to existing contracts to cover this provision.  Telma will develop and implement an EMF measurement program to confirm the safety of communities in close proximity to the towers (as detailed in ESAP Action Plan item #7). 

Telma has started the process of developing emergency preparedness and response programs.  Under IFC’s investment, the company will complete the development of these programs, by identifying where such emergencies may pose a risk to communities, and implementing regular drills to test the efficacy of the program (as per the attached E&S Action Plan item #8).                                                  

At present, Telma has an informal process of engaging with communities affected by their business activities.  Under IFC’s investment, Telecom will develop and implement procedures for prior disclosure of construction activities (as per the attached E&S Action Plan item #2) and for any maintenance activities that could result in community disturbance such as vehicular traffic and noise.  

Telma will disclose information regarding such activity by posting signs at sites at least three days prior to the start of such activity.  Telma will also schedule information sessions with local community members, and will otherwise address any grievances expressed by local community members.  These procedures will be consistently implemented for each project site.                                                  

 Rija Ranaivoson

Director Finance

+269 411 00 03                               

Rija.ranaivoson@telma.km

Alliance franco-comorienne, Rivka 2eme

stage, Moroni, Comores

www.telma.km