The key E&S issues associated with the project are generally limited impacts associated with the installation and operation of the small number of new towers planned; human resources management; and contractor and supplier management. 

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.

As an early stage company, Sigfox has yet to develop and implement new policies and procedures for E&S management.  Under IFC’s investment Sigfox will appoint a competent officer to be responsible for E&S management (as per the attached E&S Action Plan item #1), and will develop and implement policies and procedures for E&S management in compliance with IFC’s Performance Standards.

For Sigfox’s engagement with suppliers to commission the manufacture of Sigfox equipment, the company will develop a supply chain screening and monitoring procedure and screen for manufacturer-related risks involving potential use of harmful child labor, forced labor and significant occupational health and safety concerns (E&S Action Plan item #2).  Sigfox will include E&S terms in agreements between Sigfox and the manufacturers of its equipment, and will provide for monitoring by Sigfox of those terms.  Sigfox will keep records of any related E&S incidents and will report them to IFC. 

Sigfox’s procedures will ensure that the company will identify potential limitations or barriers to ensuring compliance with relevant IFC Performance Standard requirements, and measures to overcome any such limitations or barriers.  Provision will be made for at least one review per year of the manufacturers’ E&S performance, at which time potential gaps or opportunities for improvement will be explored, and any needed remedial measures will be developed and implemented.  If further evaluation indicates that the manufacturer is unlikely to achieve compliance with company’s E&S policies and therefore causing the company not to be in compliance with IFC’s requirements, then Sigfox will shift the manufacturing of its equipment to another manufacturer selected per company’s procedures. 

For the installation of Sigfox base station equipment on existing towers or other buildings, E&S risk is minimal.  As there is only a slight chance that Sigfox itself will ever develop a new telecommunication tower site in a Part II country, the company will develop E&S policies and procedures for such activity only if and when it becomes likely to happen.  Through the implementation of its policies and procedures, Sigfox would avoid the acquisition or development of any base station site involving adverse impacts on sensitive ecology, requiring involuntary resettlement of local community members, adversely impacting indigenous peoples, or damaging to cultural heritage. 

Sigfox’s E&S policies and procedures for tower sites would cover contractor management; E&S assessment and selection of sites for towers; land acquisition; worker health and safety; waste management; emergency preparedness and response; security management; and disclosure and community engagement, as described further below under the Client’s Stakeholder Engagement section below.  Policies and procedures would also cover site operations, including fuel management, with secondary containment and spill prevention technology to be installed around any fuel tank (if a fuel tank is required), consistent with IFC’s telecommunications guidelines. 

In the event that armed security guards are ever hired by any Sigfox contractor, Sigfox will include terms in agreements with contractors to provide for measures to comply with PS4.  

Sigfox’s E&S policies and procedures will be made available to (and implemented by) both the company’s own workers and the contractors, and will ensure that the project and the company’s operations comply not only with applicable local social and environmental laws and regulations, but also with IFC’s Performance Standards. 

Sigfox will ensure that there is a feedback loop for continuous improvement in E&S management.  The company will report to IFC on compliance with the Performance Standards.

At appraisal, Sigfox directly employed 213 workers in France, 26 workers in the United States, and about 30 workers spread across 7 other countries.  The company also indirectly employs about 40 other workers as consultants, interns, subcontractors, and other third party workers. Sigfox has operations in only two Part II countries (Brazil and South Africa) where the company employs a total of 3 workers, expected to increase to 15by 2017.

Under IFC’s investment, Sigfox will manage human resources consistent with PS2.  Sigfox will develop a version of its human resources policies and procedures tailored to each Part II country operation where the company has 10 or more direct or indirect workers, in which cases the company will make those policies and procedures available in the country’s major language (as per the attached E&S Action Plan item #3). 

Consistent with PS2, Sigfox’s human resources policies and procedures will provide for fair treatment and equal opportunity both for Sigfox’s own workers and for indirect workers; non-discrimination in recruitment and 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.

Sigfox’s procedures and systems will aim to prevent, manage, track and report occupational injuries, illnesses, and other E&S incidents.  Sigfox will ensure that its contractors comply with national laws, meet company’s human resources policies and requirements, and 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. 

Sigfox’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, Sigfox has no record of any conflicts with workers or of any violation of labor laws.

Sigfox recognizes the importance of community engagement, and is committed to complying with IFC Performance Standards on disclosure and community engagement.  As there is only a slight chance that Sigfox itself will ever develop a new telecommunication tower site in a Part II country, the company will develop policies and procedures for disclosure and community engagement only if and when it becomes likely to happen.  If that happens, then Sigfox will ensure that all relevant information is disclosed to local communities prior to the start of work on the site, and that consultation is conducted as needed.  If an E&S impact assessment is required in order to comply with applicable standards, then Sigfox will ensure that the assessment documentation is disclosed to any affected local communities prior to the start of work on any site.

As part of its policies for public disclosure and community engagement, Sigfox will make available information to local community members on electromagnetic radiation from base stations as needed, consistent with World Bank Group’s EHS Guidelines for Telecommunications.  Sigfox is committed to the resolution of any complaints from community members until they are resolved. It will ensure that each key contractor has in place a grievance mechanism to handle any complaints from community members, and will provide a backup mechanism in case of failure by any key contractor.

Xavier Drilhon, Deputy CEO

3 Rue de Londres

Paris, 75009

France