PS3, PS4, PS5, PS6, PS7 and PS8 are not considered applicable given that Cabo’s business no usage of resources or pollution risks;  Cabo will use no armed security service;  no land is expected to be acquired, as telephone poles are installed through easements rather than land acquisition; no operations are expected to affect biodiversity conservation or any substantial management of living natural resources; no Indigenous Peoples are expected to be affected; and no cultural heritage is expected to be impacted (as very little earthworks are needed for the telephone poles to be installed in this project). 

The key E&S issues associated with the project aimed at expanding Cabo’s network are relevant to E&S management of the business activities, including safety and community engagement, and labor and working conditions.

 As E&S risks and impacts are expected to be limited, site-specific, and relatively few in number, 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 Social and Environmental Sustainability. 

Assessment and Management of Environmental and Social Risks and Impacts

Cabo’s chief operating officer takes responsibility for the company’s E&S management.  Cabo has developed and implemented a comprehensive set of policies and procedures for environmental risk management, occupational health, work at heights, and human resources management, consistent with IFC’s Performance Standards and relevant World Bank Group Environmental, Health and Safety (EHS) Guidelines.  Cabo’s policies and procedures cover all of the company’s different types of facilities and they cover physical, chemical, biological, mechanical, and ergonomic aspects. 

Construction and maintenance of Cabo’s network are performed by a third party contractor.  Therefore, contractor management is an element of paramount importance in the company’s E&S management system in order to comply with IFC Performance Standards. 

Cabo’s contract arrangements require contractors to make its best efforts to prevent environmental impact; to report periodically to Cabo on their performance; and to follow all local laws and regulations, particularly those concerning worker safety.  Cabo’s contract arrangements also provide for Cabo to train its contractors’ employees, and for Cabo to undertake periodic audits of contractors’ worker safety and of their legal and administrative compliance.  Cabo reserves the right to change the policies to be followed by its contractors at any time, and immediately to terminate the contract in case of noncompliance.

The company will not undertake any activity anywhere if the activity cannot be expected to comply with IFC Performance Standards. Some of Cabo’s expansion may be undertaken by acquiring one or more smaller companies. Accordingly, as part of its E&S management procedures, Cabo will review E&S risks in any company prior to acquisition and ensure that its E&S policies are applied to the relevant business activities after acquisition. 

More broadly, Cabo will review E&S risks before defining and working with any new easement, erecting any new pole, or undertaking any other activity in its operations.  Such E&S review will be commensurate with the level of social and environmental risks and impacts in the relevant operations. Cabo’s E&S review will ensure that the project and the company’s operations comply not only with applicable social and environmental laws and regulations of Brazil, but also with IFC’s Performance Standards.  The company will report to IFC on compliance with the Performance Standards.

Labor and Working Conditions

Cabo employs about 870 workers in Brazil directly, with about 200 outsourced workers.  Cabo has a collective bargaining agreement with its workers, which provides for a limit of eight regular working hours per day and overtime pay.  Cabo has a human resources coordinator who monitors compliance with those provisions, and who otherwise oversees implementation of the company’s policies and procedures for human resources management.  For example, Cabo trains its own employees on issues including worker health and safety, as well as environmental issues.   

Cabo also provides its workers with protective clothing and equipment.  Cabo’s collective bargaining agreement includes a provision for non-discrimination regarding workers with same-sex preferences.  Under IFC’s investment, Cabo will develop and implement a more comprehensive policy on non-discrimination at recruitment and throughout employment, as well as a grievance mechanism, consistent with PS2 (as per ESAP item #2). 

In the past 5 years, in relation to working conditions, Cabo has recorded a couple of dozen lawsuits by individual workers, mainly involving working hours, and a few dozen administrative violations, mainly involving substandard office furniture.  To address these issues, Cabo has hired more workers and has upgraded its office furniture.  Cabo is committed to ensure compliance with PS 2 in the implementation of its employment contracts and also to review and monitor implementation of adequate labor and working conditions by its contractors, and will take all necessary measures to remedy any noncompliance. 

Cabo recognizes the importance of stakeholder engagement, and is committed to comply with the requirements of IFC Performance Standard 1 on disclosure and stakeholder engagement. 

 Cabo publishes notices for local community members in local newspapers at least 7 days before undertaking any installation or maintenance work, and publishes contact information so local community members can notify the company of any concern.  Under IFC’s investment, Cabo will develop and implement documented policies and procedures to address any grievances from local community members regarding installation or maintenance work (as per ESAP item #1).

Marcus Varotti

Triple Play Brasil Participacoes S.A

Rua Bandeira Paulista 726 Cj. 191 Sao Paulo, S.P.

55-11-96698-8896

mvarotti@3pp.com.br

Website https://cabotelecom.com.br/