PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; or PS 8: Cultural Heritage. The procedures by which the company will address any situation that requires application of these PSs is described in the narrative of PS 1 below. PS 7: Indigenous Peoples is not applicable as Indigenous Peoples meeting the criteria established by the World Bank Group have not been identified in Uganda to date.

   This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). The company’s operations have limited environmental and social impacts, and these are site-specific, temporary and not significant. Impacts associated with the existing operations and proposed network upgrades and enhancements and implementation of smart meters can be avoided or mitigated by adhering to recognized performance standards, operating procedures, guidelines and design criteria as described in the sections below.

Key issues related to this project include: the prevention of fatalities and injuries to operations staff, contractors and the public resulting from exposure to energized transmission lines; management of the disposal of PCB contaminated transformer oil; disposal of chemically treated wooden utility poles and improvement of waste management practices through consistent implementation of an environmental management system.

   Environmental and Social Assessment and Management Systems:

Umeme’s Board of Directors formally adopted an Environmental and Social Responsibility Policy, in October 2012, committing its management to minimizing the adverse impacts of its operations on the environment and the health and safety of its customers, stakeholders and employees. To achieve these commitments, the company has revised its Environmental, Health and Safety (EHS) management system to meet the requirements of IFC’s Performance Standards and Ugandan legislation.

Organization and Staffing:

There are no changes on staffing of Umeme’s Safety Department since 2016. Umeme has an Environmental Safety and Governance (ESG) Committee at the corporate level. EHS matters are managed by Umeme’s Safety Department. The department consists of the Head of Safety, Safety Leader who oversees the activities of the four Regional Safety advisers who support Umeme operations staff at the district level; a Contractor Safety Adviser dedicated to appraising, pre-qualifying and monitoring contractor safety compliance; three Safety Auditors who monitor and assess the overall company compliance with the Safety standards; an Environmental Adviser dedicated to improving awareness of environmental issues among Umeme staff and promoting sound waste management practices in Umeme’s operations.

The Safety Department regularly engages other utility companies within the region to share lessons learned in the management of EHS. Umeme remains a member of the Power Institute of East and Southern Africa and participates regularly in meetings in which quality, safety and environment management are discussed. The last such meeting was held in November 2018 in Maseru, Lesotho.

Identification of Risks and Impacts:

The company has a system to identify environmental and social risks associated with major network expansion. Umeme, as part of the management system, has a procedure for preparation of ESIAs consistent with IFC requirements and national laws.  An Environmental Impact Assessment (EIA) is required by law for every new sub-station as well as for substantial refurbishments of existing sub-stations and development of new distribution lines. EIAs must be approved by the National Environmental Management Agency (NEMA) before development can be undertaken. Umeme engages NEMA-approved independent environmental consultancies for its EIA requirements and the Environmental Advisor coordinates and supervises the work of the consultants. Typical issues associated with network expansion include containment of oils via appropriately sized bund walls and sumps to prevent surface and groundwater contamination, and the installation of fire barriers between transformers. The company commissions environmental audits when sub-stations are being refurbished, to identify and address historical issues such as oil-contaminated soils. NEMA issues a compliance agreement once audits are submitted, together with a work plan outlining action items. Environmental mitigation measures defined in approved EIAs are supervised by the EIA consultants during construction.  However, no distribution lines that require ESIAs have been constructed since 2016.

To date, the company has not encountered issues related to adverse impacts on biodiversity largely because it has been rehabilitating an existing distribution network. Umeme sources utility poles predominantly from Forest Stewardship Council-certified suppliers. Any direct impacts resulting from future greenfield expansion requiring new transmission line rights-of-ways and substations will require EIA studies and appropriate management plans undertaken by independent consultants as described above. The company’s Environmental Advisor will screen proposed future greenfield expansions and ensure that PS 6 requirements and objectives are met in the development of the new infrastructure.

Management Programs:

As part of the ESMS, Umeme is implementing several management programs and include; human resources management; environmental health and safety, waste management, and some Standard Operating Procedures (SOPs).  Umeme has acquired the 450001 & 14001 Standards and is reviewing some of the SOPs in preparation for benchmarking and commencement of adoption and incorporation.

Monitoring and Reporting:

The Safety Department establishes EHS Key Performance Indicators (KPIs) each fiscal year and reports on the achievement of these indicators to the ESG Board Committee on a quarterly basis, and to IFC via an Annual Environmental & Social Monitoring Report. In addition, the Safety Department conducts regular internal EHS audits covering a wide range of topics including: buildings; environment management; staff welfare; personnel protective equipment; public safety; internal communication and training; documentation and reporting; fire prevention and protection; supervision and monitoring; staff appointments; and plant and equipment maintenance and isolation procedures. Regular external audits are conducted by NEMA during new sub-station or distribution line installation.

   Human Resources Policies, Procedures and Terms of Employment:

Umeme has a comprehensive Human Resources (HR) Manual, which is provided to all employees on joining the organization. Terms of reference, remuneration, working hours, overtime rates, sick pay and termination notices are highlighted in each employee’s appointment letter. These terms are further explained during induction training. The HR manual contains conditions of service including the disciplinary code and severance pay arrangements if retrenchment is necessary. Umeme’s HR department carries out annual market surveys to ensure the wage and benefits packages offered to employees are competitive.

As of February 2019, Umeme had 1,516 direct employees of which 1,175 are males and 341 are females and only 7 are expatriate staff. Another 495 workers are employed by contractors/subcontractors for Operation and Maintenance (O&M) or new construction activities.

Workers Organizations and Grievance Mechanism:

The Company has a collective bargaining agreement with the Uganda Electricity & Allied Workers Union, in accordance with the Labor Unions Act of 2006. The current collective agreement was recently signed on 7th February 2014 and has an open-ended validity.  As of the beginning of 2019, approximately 500 or one-third of Umeme employees are union members.

The company has a clearly defined formal and robust grievance mechanism for all workers. The mechanism, which is contained in the HR Manual, provides for a procedure whereby any employee can e-mail the directors to make their complaints known, after failing to get redress from within the company systems and procedures.  In addition, Umeme has an anonymous grievance procedure managed externally by a third-party contractor.

Non-discrimination and Equal Opportunity:

Umeme is an equal opportunity employer and abides by all statutory requirements of the Ugandan labor law. The company does not discriminate based on HIV-AIDS status, color, tribe, sex, disability, religion or political opinion.

Protecting the Work Force:

Umeme does not make use of child labor and/or forced labor in its operations. All employees must be at least 18 years of age to quality for a job with Umeme as stipulated in Uganda labor laws. The company uses identity documents to verify age at the time of engagement.  As part of its due diligence process, Umeme confirms that contractors do not use child labor and/or forced labor in their operations.

Occupational Health and Safety (OHS):

Umeme places great emphasis on OHS of its staff and contractors by providing adequate training and Personal Protective Equipment (PPE) in addition to safety management system.  Nine members of the Safety Department completed the International Certificate of Occupational Safety and Health administered by the UK National Examinations Board in Occupational Health and Safety (NEBOSH).  The company also organizes driver training, safety briefings and tool box talks on a wide range of subjects. The Safety Department ensures that appropriate PPE is provided to all employees and enforcement on the use at all times. Umeme is also considering the adoption of OHSAS 18001 and ISO 45001, and progress of this process will be communicated to the IFC as part of the required Annual Environmental & Social Monitoring Reports.

Electrical competence is the cornerstone of Umeme’s safety program.  The company continues to maintain the annual KPIs for Health and Safety for engineering operations and nonoperational offices. These KPIs are reported monthly and are embedded into the annual bonus scheme and form part of the appraisal process. In addition, safety awards have been introduced to enhance performance in all sections of the company. Awards are given to the best performing sections.

The Safety Department maintains a comprehensive database of Lost Time Accidents among employees and contractors that allows analysis of OHS trends and performance. This information forms part of monthly reports covering all aspects of the company’s safety management system. Recordable incidents include fatalities, lost time incidents, restricted work incidents and medical treatment incidents. The current Lost Day Accident Rate/Million Man Hours is about 1.2 compared to about 1.5 in the previous reporting cycle – January to December 2017. There were zero staff and contractor fatalities in 2018.  When there is a workplace injury, formalized systems of review (root cause analysis) are used, with the objectives to identify the type of risk, nature of the accident, injured area of the body, causes of the accident, and areas of follow-up which are allocated to individuals and tracked until completed. Based on records reviewed, measures necessary to prevent recurrence, which include training of workers, are systematically identified and implemented as appropriate.

Umeme has established an OHS compliance system for screening of contractors and major suppliers, and is built into the procurement process, as a pre-qualification criterion.  The system also provides for an ongoing assessment of contractors OHS readiness and performance.

  Pollution Prevention:

Umeme has waste management programs and specific pollution prevention and control measures that are supported by robust procedures and consistent with good practice.

Polychlorinated Biphenyl (PCB) Management:  Umeme Ltd has been testing power and distribution transformers. As of early 2019, a total of 12,541 transfers were tested, of which 58 distribution transformers and four power transformers confirmed to have PCBs > 50ppm. The PCB contaminated transformers are still in use and have been clearly identified awaiting decommissioning and disposal. Umeme is geared towards total PCB elimination in line with Stockholm Convention (2025).

Since 2012, Umeme has been implementing a management plan to collect and destroy suspected PCB-containing transformer oil through its program of rehabilitation or replacement of transformers in use. Designated Umeme employees are trained in PCB handling and provided with adequate PPE. Incineration of oil is contracted to Luwero Industries Ltd, a Uganda Peoples Defense Force facility, a third-party contractor registered by NEMA Uganda. The incineration process involves mixing the oil with sawdust and combust at 14000C secondary chamber & >8000C for the primary chamber (combustion) and air pollution control equipment designed to minimize dioxin formation. The generated ashes from the incinerator are collected and disposed of in an engineered landfill. Umeme in collaboration with NEMA audit these facilities periodically to ensure compliance with disposal procedure.  The last audit was conducted in 2015, since Umeme has not disposed any PCB oil since 2016.

To prevent or minimize contamination from transformer oil (or insulating oil) spillage, Umeme’s engineering department ensures that all new and refurbished substations are fitted with bunded oil sumps located below the transformers which can handle a minimum of 110 % of the total oil capacity of the transformers. In addition, the refilling and maintenance procedures are robust and prevent spillages and plugs on most of distribution transformers have been welded shut to avoid oil theft and a progressive program of fencing off ground mounted transformers country-wide is being implemented to prevent loss of oil due to theft and vandalism. As a monitoring procedure, Umeme carries out soil contamination surveys in all its substations to determine transformer leakages into the environment after which appropriate mitigation measures are developed and implemented. In addition, a joint inspection of the new transformer repair yards is periodically carried out with NEMA to determine compliance with key environmental requirements as stipulated in contracts. Umeme received a satisfactory rating from NEMA on the last inspection in 2017.

Hazardous Materials:

Besides transformer oil, Umeme uses few hazardous materials. Small quantities of paint and thinners are kept in the engineering center, in a ventilated, locked area. No fuel is stored by Umeme; refueling and maintenance of the fleet of Umeme trucks and Umeme motorcycles is outsourced to third party providers such as Shell and Total. No pesticides are used in way-leaves and no burning of vegetation in these wayleaves is undertaken.

Solid Waste Management:

Umeme generates two dominant solid waste streams, namely old transformers and treated utility poles. Typically, the transformers are stored at Umeme’s main depot before being sold to registered scrap metal dealers. If transformers are found to contain PCBs, both the oil and the transformer carcass are transported for disposal at the NEMA approved government facility in Nakasongola. Such transformers are not sold to scrap dealers as Umeme’s transformer repair yards do not have the capacity to rid transformers of PCBs. Umeme makes use of its used oil transport and disposal trucking manifest. The manifest is signed by the originator, transporter and by the disposal facility.

Used Treated Wood Utility Poles Management:

Good industry practice for management of used treated wood utility poles involves one of three main options, namely: a) land filling in a sealed site; b) high temperature incineration; or c) controlled recycling for uses that exclude burning on open fires and close skin contact. The first two options are currently not feasible in Uganda.  As such Umeme developed a pole disposal management system with the objective of disposing used poles in an environmentally sound manner.  The system involves cutting the poles into 2 meters length logs, which are issued to members of public for free. The recipient is required to apply by filling and signing a Used Pole Disposal Form that stipulates safe usage, no of pieces required, detailed contacts and a disclaimer on non-alternative use. The accountability for poles disposed of using the pole disposal form is now part of the terms and conditions for approval of payments to contractor firms. Umeme conducts random audits to ensure adherence to the disclaimer. Customer Service Engineers, Project Managers and the Contractor Safety Advisor oversee the implementation of the process.  Umeme has disposed 19,370 poles since 2016; (5,614 poles in 2016; 5,726 poles in 2017 and 8,030 poles in 2018). It should be noted that this challenge is faced throughout the region and in developed country markets where it has been managed in different ways by different agencies.

Greenhouse Gas (GHG) Emissions:

Umeme’s GHG emissions are relatively insignificant and associated almost entirely with fuel consumption by the Company’s fleet of motor vehicles. Total annual consumption for this fleet in 2018 was approximately 1,492,322 liters of diesel. This amounts to emissions of about 3,402 tonne CO2 equivalent per annum.  Although Umeme use Sulfur hexafluoride (SF6) insulation gas for its circuit breakers and switchgear, the company has developed a robust SF6 Management guidelines, which has managed to prevent and minimize leakage.  Umeme uses approximately 60 kg of SF6 per annum to replace losses of SF6.

   Community Health and Safety:

Umeme has significantly reduced the number of public fatalities associated with failure of its network (referred to as “attributed fatalities” by Umeme). Since 2009, Umeme has succeeded in reducing these fatalities from an average of 12.75 per year (2005-2008) to an average of three per year. This has been largely achieved through the company’s progressive refurbishment of its network.  No attributed fatality was recorded in 2018.  However, there were a total of 31 fatalities in 2018 (compared to 16 in 2017) due to power theft and poor domestic wiring (these types of fatalities are referred to by Umeme as “non-attributed”).  As an ESAP Item # 1, Umeme will conduct a root cause analysis on the causes of the spike in fatalities to develop and implement a “non-attributed fatalities” action plan.  In addition, Umeme will review its current stakeholder engagement plan to include new methods (from the action plan) of creating public awareness as a mechanism of reducing fatalities.  The new strategy will be in addition to the current initiatives on school talks, community presentations and use of print and electronic media and in addition to bulk metering points to control connections and use aerial bundled conductors to prevent illegal connections via contact with un-insulated conductors.

Security Personnel

The security arrangements of 2009/2012 have remained the same with the same security companies being deployed but with changes in their scope and areas of operations. The new contracts for the security companies have the relevant IFC Performance Standards embedded in their contracts.  The security companies are subjected to a degree of screening by the Uganda Police Force. Following advice from the Uganda Police Force, guards are armed at senior staff residences and at locations where cash is handled. To date, there have been no armed robberies or incidents involving the use of guns by these guards. In addition, there has been no complaints or reports regarding abusive behavior or improper use of the arms or force by the security service. The main security issue for Umeme is theft of equipment, disposables and power. Cable and power line theft has increased significantly since 2009, notwithstanding the replacement of copper conductors (power lines) with lower value aluminum conductors.

Umeme no longer uses the Uganda Police Force for security arrangements at its facilities. However, in situations where illegal connections are being dismantled or power cut off after illegal use, the Uganda Police Force may be asked to accompany Umeme employees to ensure their safety and security. As well, a Deputy Superintendent Police Officer has recently been seconded from Uganda Police Force to strengthen the Company’s physical asset security across the country.  Given the use of armed guards and police, as part of ESAP Item #2, Umeme will assess risks posed by its security arrangements to those within and outside the project site and create a complete Security Management Plan (SMP), including a training module for management and security personnel. This SMP shall be aligned with the Voluntary Principles on Security and Human Rights and with the requirements of Performance Standard 4 (paragraphs 12, 13 & 14)

  Stakeholder engagement related to new infrastructure development is conducted by independent EIA consultants, as part of the mandatory EIA process in Uganda. Every EIA involves discussions with local government leaders, adjacent land owners, and the district engineer and district planner. Feedback from these parties is incorporated into the planning process as appropriate.

Umeme maintains a 24-hour call center to receive customer complaints, reports of electricity theft and any other issues affecting its network. The Company pledges to make any emergency situation safe within 20 minutes. The 2018 data indicates majority of the complaints are related to network operation, maintenance, safety and customer accounts.  Complaints on wayleave are few and are managed at the district level.

At the corporate level, Umeme’s public communication program utilizes a wide range of media such as targeted radio programs, safety stalls at trade shows, news posters, adverts in newspapers and the use of an SMS platform which was introduced in 2013. A key element of Umeme’s communication program is the education of members of the public, and especially children (through school-based safety programs), of the dangers associated with electricity and the tampering with transmission and distribution infrastructure and equipment.

 Contact Person: Grace Semakula

Company Name: Umeme Limited

Address: 2nd Floor Rwenzori House, Plot 1 Lumumba Avenue

Email: grace.semakula@umeme.co.ug

Phone: +256 312 360667