The key E&S issues associated with the project are in the potential impacts from any new development of telecommunications towers and underground or above-ground cable, and in labor and working conditions (including employees’ and contractor workers’ occupational health and safety). 

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. 

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Altán contracted with Applus Mexico to assist the company with E&S management during the bidding process.  Now that Altán has won the bidding process, it is expected that a well-respected international firm will be contracted to undertake E&S screening of existing telecommunications sites, underground fiber, and above-ground fiber to be used by Altán.  The screening will ensure that all existing sites, assets, and operations will be reviewed against compliance with PSs and a gap analysis including corrective actions will be developed consistent with ESAP item #2.

For Altán’s operations, the company expects to use in-house strategy and management, while outsourcing most construction, operation and maintenance activities.  For those activities, Altán will develop and implement an E&S management system, which will include E&S policies and procedures, covering all of the elements required under applicable Performance Standards and implemented for all operations and new projects (as per the attached E&S Action Plan item #2).  The policies and procedures will made available to and implemented by the company’s management and workers.  The company will ensure that relevant policies and procedures are known and implemented by contractors.  The company will also ensure that policies are communicated to other stakeholders, including local communities potentially affected by company’s business activities. 

Altán will appoint a competent officer to be responsible for E&S management (as per the attached E&S Action Plan item #1).  The company will not undertake any activity anywhere if the activity cannot be expected to comply with IFC Performance Standards. Altán’s E&S management policies and procedures will cover topics including solid waste management plan, emergency preparedness and response, energy efficiency, worker health and safety, contractor management and supply chain management, environmental assessment for obtaining permits, security management, land acquisition, biodiversity conservation, and cultural heritage, among others.  The management policies and procedures will be fully aligned with applicable IFC PSs.   

As part of its E&S management procedures, Altán will reviews risks before undertaking activity on any part of its network.  Such E&S review will be commensurate with the level of social and environmental risks and impacts in the relevant operations. Altán’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 Mexico, but also with IFC’s Performance Standards.  Under IFC’s investment, Altán will also develop and implement procedures for public disclosure, as described further below under the Client’s Stakeholder Engagement section below (and as per the attached E&S Action Plan item #3).

Altán is committed to use best practices in the management of its supply chain, and the company will include E&S terms in its agreements with suppliers, in addition to its contractors.  Altán will supervise, monitor, and report on E&S risks and impacts of all operations for the duration of the company’s involvement.  The company will report to IFC on compliance with the Performance Standards.

PS2: Labor and Working Conditions

Altán expects to employ directly about 10 workers (all managers) in Mexico by the end of 2016, and expects to employ most of its other workers through contractors to perform core functions for the company.  Contractor management will therefore be an element of paramount importance in the company’s E&S management system in order to comply with IFC Performance Standards.

Altán will develop and implement a set of human resources policies and procedures, which will include provisions for contractors’ workers in line with the requirement of paragraphs 24-26 of PS2.  As per ESAP item #5, Altán’s policies and procedures will ensure that a safe and healthy work environment is provided to all employees and contractor’s workers, and will promote the fair treatment, non-discrimination, freedom of association (right to unionize) and equal opportunity.  Altán will protect its workforce and ensure the same for its contractors’ workforce, with respect to avoiding child labor and forced labor. 

Altán will ensure that its contractors implement training for their workers, covering worker health and safety, as well as environmental issues, and that contractors’ workers will be provided with protective clothing and equipment.  Altán’s procedures will require the deployment of appropriate measures for life and fire safety at the company’s offices, operational sites, and switching centers.  As a new company, Altán has no record of any conflicts with workers or of any violation of labor laws.

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

Under IFC’s investment, Altán will develop and implement procedures for prior disclosure of any significant construction or maintenance activity (as per the attached E&S Action Plan item #4).  For construction activities with limited E&S risks and impact, Altán will disclose information by posting signs at sites at least 3 days prior to the start of such activity.  For activities involving potentially more significant risks and impacts, Altán will schedule information sessions with local community members according to criteria consistent with good international practice, and which will be defined in the company’s stakeholder engagement procedures, to address any grievances expressed by local community members.

Joaquin Coronado

joaquin.coronado@digital-five.com

Tel: +34-915238040