PS3 (Resource Efficiency and Pollution Prevention), PS4 (Community Health, Safety and Security), PS5 (Land Acquisition and Involuntary Resettlement, PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) are not considered applicable given that resource efficiency and pollution prevention are not significant issues in the development and maintenance of underground fiber networks (and to the extent that are relevant to CSquared, they can be managed under PS1); easements for new sites will be obtained only from willing landowners, as needed; no risks and impacts on biodiversity values are expected, as the projects occur in urban areas; no Indigenous Peoples are expected to be affected; and no important cultural heritage is expected to be impacted (but if it is, then CSquared’s policies and procedures provide for its proper management).

 The key E&S issues associated with the project are generally limited to construction impacts associated with laying fiber, and labor and working conditions, including employee and contractor occupational health and safety. 

 As E&S risks and impacts are expected to be limited, site-specific, and relatively few in number, and any adverse impacts that might result can be avoided or readily addressed through mitigation, the proposed investment has been classified as a Category B project according to IFC’s Policy on Environmental and Social Sustainability.

Environmental and Social Assessment and Management System

 The Company’s development and operations of underground fiber-optic networks will be mainly outsourced, with management and supervision provided by the Company. To do so, the Company will implement management system requirements for its own workers and for contractors that address various environmental and social issues.  These requirements will be based on those developed for Google’s fiber-optic network projects in Kampala and Entebbe in Uganda, and in Accra, Ghana.  At least one senior officer will be responsible for corporate management of environmental and social issues, and at least one senior officer will be specifically responsible for management of human resources.

The Company will adopt a similar code of conduct and environmental, health, and safety policies and procedures substantially similar to the relevant sections of those followed by CSquared Ghana and CSquared Uganda, and will require all of its contractors to do so too.  CSquared Ghana and CSquared Uganda’s existing code of conduct and policies and procedures are publicly available as of the date of this announcement at https://abc.xyz/investor/other/google-code-of-conduct.html and at https://www.google.com/about/company/responsible-manufacturing.html.

Consistent with PS1 and with the policies and procedures implemented by CSquared Ghana and CSquared Uganda, CSquared’s policies and procedures will ensure that every new country operation will implement an environmental management system in accordance with ISO 14001 or equivalent, which will include requirements for environmental and social assessment prior to any significant construction or maintenance activity; stakeholder engagement; granting of easements and permitting prior to construction or maintenance; and avoidance of interference with existing underground cables and other underground infrastructure. 

Also consistent with PS1 and with the policies and procedures implemented by CSquared Ghana and CSquared Uganda, CSquared’s policies and procedures will provide for management of waste and hazardous substances; emergency plans and response procedures; and management of cable trenching, installation, and repair.

In the projects in Uganda and Ghana, E&S impact assessment included a review of local laws, rules and regulations; a detailed description of the environmental setting of the project area, the project design, and the project’s characteristics; an evaluation of potential environmental and social impacts; and an E&S plan describing impacts, indicators, and mitigation measures.  CSquared will carry out similar appropriate assessment for each new project undertaken, in compliance with IFC Performance Standards. 

The Company will report to IFC on compliance with the Performance Standards.

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Human Resources Policies and Procedures

 At appraisal, CSquared employed 11 full time employees and about 17 contracted workers in Uganda, and 8 full-time employees and about 14 contracted workers in Ghana.  The number of workers and contractors to be employed by CSquared, including in countries to which it will expand, remains to be determined.

 In the projects implemented by CSquared Ghana and CSquared Uganda, no state inspection on labor or health and safety issues or court cases for labor law violations or other labor unrest or disputes have occurred.

The Company will implement human resources policies and procedures consistent with those of CSquared Ghana and CSquared Uganda under Google’s ownership.  Consistent with PS2, those policies and procedures will provide for fair treatment of workers and equal opportunity; non-discrimination in recruitment and/or throughout employment; avoidance of harmful child labor and forced labor; a reasonable limit on working hours; measures to resolve any worker grievances; and measures to ensure that employees and contractors’ workers are provided with appropriate protective clothing and equipment, and are trained on environmental, health and safety issues.

As noted under PS1, the Company will use a substantially similar code of conduct and environmental, health, and safety policies as those followed by CSquared Ghana and CSquared Uganda under Google’s leadership, and will require all of its contractors to do so to.

Consistent with PS2, CSquared and its contractors will enforce in each new country operation the following requirements:  no child labor; a limit on working hours; no discrimination at recruitment and throughout employment; freedom of association; a health and safety management system in accordance with OHSAS 18001 or equivalent; and procedures and systems to prevent, manage, track and report occupational injury and illness.

Information Disclosure

 In the projects in Uganda and Ghana, CSquared Ghana and CSquared Uganda worked to avoid any social tensions.  Consultative meetings were organized with various stakeholders at an early stage, so the views of local community members and appropriate mitigation measures could be incorporated in final plans for cable installation.  Community liaison officers were appointed to engage stakeholders and to manage public relationships with local communities, and to keep records of complaints and responses.  Under IFC’s investment, CSquared will undertake the same types of measures for public disclosure and community engagement for all new operations starting at an early stage, consistent with IFC’s requirements.  

Bhavesh Mistry

Google Kenya Ltd.

7th Floor, Purshottam Place

Westlands Road, P.O. Box 66217 - 00800

Westlands

Nairobi, Kenya

Email: bhaveshm@google.com

Mobile: +254 733738131 / Office: +1 415-736-6002