While risks and potential impacts relevant to the application of 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 expected from the company’s business activities, the corporate E&S management system (ESMS) will include relevant screening procedures as discussed under PS1. The proposed new cables will be deployed aerially on the existing infrastructure of utility providers which poses a limited risk for community safety and does not require land acquisition; however, if required, the land acquisition process for the laying cables will only involve a willing buyer willing seller transaction. All communication nodes have a small footprint and are either mounted on leased facilities or owned by the company. No infrastructure installation is expected to negatively affect habitats of high biodiversity value; no Indigenous Peoples are expected to be affected by the project; and no important cultural heritage is expected to be impacted.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.         

 This is a Category B project, according to IFC’s Environmental and Social Sustainability Policy. There are only potential limited adverse environmental or social risks and impacts expected to result from the proposed project, and it is possible to avoid or mitigate any limited adverse impact by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections.

The key E&S issues associated with the project are: (i) development and implementation of a corporate E&S management system (ESMS) and relevant procedures and plans to assess and manage the limited adverse E&S risks and impacts in line with IFC Performance Standards (PSs); (ii) labor and working conditions; (iii) OHS management. including during installation of cables and for maintenance activities; (iv) waste management; (v) security management; and (vi) stakeholder engagement activities.          

 Environmental and Social Assessment and Management System and Policy

Currently, ElCat does not have a documented environmental and social management system in place but has a safety guideline and checklist to assess and manage relevant risks and impacts, meeting Kyrgyzstan regulations. The company’s guidelines govern occupational safety aspects during installation and maintenance of cables (such as use of personal protective equipment (PPE), health and safety training, fire safety, electricity safety and general safety requirements).

Under the proposed investment, ElCat will review and integrate the company’s guidelines, developing an Environmental, Social and Health and Safety Management System (ESMS) commensurate with the level of risks and impacts associated with the company’s business activities. The ESMS will include E&S policies and procedures, including a screening procedure to identity, assess and manage relevant E&S risks and impacts due to site/infrastructure development or installation and due to operations and maintenance. The management system will define a procedure for performance monitoring of key indicators to monitor and report on compliance with applicable national laws and standards and with IFC Performance Standards. Once established, the ESMS will comprise the following procedures: (i) corporate oversight for E&S and OHS related regulatory compliance; (ii) E&S risk and impact identification, assessment and management, including a screening procedure for land and biodiversity risks, (iii) waste management, (iv) occupational safety and health management, (v) emergency preparedness and response, (vii) security management, (viii) stakeholder engagement procedure including community grievance mechanism, (iv) community health and safety management (ESAP #1)

Identification of Risks and Impacts and Management Programs

In compliance with Kyrgyz regulations, prior to cable deploying the company develops “Project Design Documentation” that includes an initial E&S risk screening as part of the route’s selection. Issues considered in this process include overlap with protected/sensitive areas and land ownership. The project document is submitted to the State Environmental Protection Agency. Following the approval from this agency, the company applies for a construction permit from the State Agency for Construction and Architecture. The company will not develop any site before all relevant local permits are obtained.

As indicated above, under the ESMS, ElCat will formalize a screening procedure for each proposed cable infrastructure deployment to assess the sensitivity of the sites crossed by the alignment of the cable. The procedure will aim at avoiding sites of higher environmental, biodiversity, cultural heritage or other social value for the local communities, within the constraints of the technical requirements, and will inform the identification of design measures to minimize impacts on those sites, consistent with IFC Performance Standards (as part of ESAP item#1).

Where sensitive sites cannot be avoided, ElCat will prepare an E&S impact assessment (ESIA), which will be carried out by competent professionals in line with its corporate ESMS. Such ESIA will include a framework E&S management plan to be developed and implemented during installation, operation and maintenance of the infrastructure. The framework will include procedures to ensure adequate traffic control, waste management, housekeeping, dust management, and community safety measures such as barriers, signals or other measures, such as the use of flag men where needed, during execution of installation or maintenance works. As part of the corporate ESMS, the company will develop a chance finds procedure applicable for projects requiring earthworks.

Procedures and instructions will be communicated to relevant personnel and appropriate training will be provided to all employees.

Organizational Capacity and Competency

Currently, E&S matters are managed by a senior officer at the corporate level and supported by a technical department. The senior officer is responsible for ensuring legal compliance with country regulations comprising obtaining permits from relevant agency, undertaking initial E&S risk screening, and ensuring OHS trainings are provided during onboarding of new employees. The company also works with an E&S consultant/consultancy firm to manage E&S related operations on a request basis. Under IFC’s investment, ElCat will contract an external suitably qualified consultant to support the client in developing the E&S management systems (ESMS) in line with the requirements of IFC’s Performance Standards (PS), and relevant World Bank Group (WBG) Environmental Health & Safety (EHS) Guidelines (ESAP#2). The company will set up an E&S team with adequate technical knowledge of good international industry practice and defined roles and responsibilities that will be responsible for implementing and maintaining the ESMS consistent with IFC PS requirements (as per E&S Action Plan item #3).           

 Human Resources Policies and Procedures

ElCat currently employs a total of 164 direct employees (85% male, 15% female) as of March 2020. At the time of IFC’s appraisal, ElCat had no formal policies and procedures for managing human resources activities. As a part of this project, ElCat will develop and implement corporate HR policy, programs, and procedures to meet with Kyrgyz Republic Labor Code and in compliance with IFC’s PS2. Once established, the corporate HR policy and procedures will include elements such as that related to equal employment opportunity, non-discrimination, freedom of association, sexual harassment, trainings, a grievance mechanism and anti-corruption in compliance with international good practice and PS 2. Each employee will be provided with a copy of an employee handbook and at the time of joining, new staff will receive a copy with their appointment letter and contract. The corporate HR policy and procedures will be incorporated in new employee induction and refreshment trainings including gender-based violence training for all staff and contracted workers, including private security personnel as defined in ESAP #4.

The nature of ElCat’s work generally precludes the use of unskilled workers, so the risk of child or forced labor is negligible.

Collective bargaining is allowed but ElCat’s workforce is not unionized. However, the company indicated that there is no restriction for workers to organize. The right to form and to join workers’ organizations will be specified in the corporate HR policy. In the three years prior to IFC’s appraisal, the company represented that no state inspection on labor nor occupational health and safety issue was recorded; no court case was brought by employees based on alleged labor law violations; and no labor unrest or dispute was recorded.

Occupational Health and Safety

As indicated, the company has a corporate guideline that covers occupational safety aspects during installation and maintenance of cables. The workers assigned to installation and maintenance works are provided and required to attend training against OHS risks for the company’s business activities by the construction director. Workers are required to wear appropriate PPE while working with cable-laying equipment and working at heights as required. ElCat ensures that personnel who must climb electrical poles are effectively trained in working at heights and prohibits access to untrained personnel. IFC’s review identified limited evidences of documented risk assessments and incident/accident records. ElCat will develop a risk register that will include all OHS risks associated with the company’s operations, including physical, chemical, and electric hazards, and gender-differentiated risks (as per E&S Action Plan item #5). For each risk identified, the company will define and procedurize the required mitigation measures and will ensure the training required for such mitigation to be effective, together with maintaining formal records of such training. ElCat will also maintain up-to-date OHS indicators of performance, including leading and lagging indicators. In case the company ever use a contractor for any work related to core business processes, the company will contractually require the contractor to comply with the company’s OHS policy and procedures, consistent with Performance Standard 2. The company will monitor the contractor’s performance and compliance with such requirements.                       

Electricity is supplied by the national grid, complemented by diesel and gasoline fired back-up generators.. Furthermore, the possibility of installation of solar panels, water cooling at their facilities are being studied. Sources of limited emissions of air pollutants and greenhouse gases are the back-up generator and company’s vehicles.

ElCat uses municipal water at its offices. Wastes generated from ElCat business activities include office general wastes, wastewater and inert and non-hazardous wastes from installation and maintenance and other construction works. Hazardous waste includes batteries designed for the stable operation of communication centers and stored in the company’s storage area in Kara-Balta. Waste is disposed of through third party licensed enterprises. As part of ESMS, the company will monitor and record the wastes generated from offices, infrastructure and construction activities, and will obtain the relevant chain of custody documentation to the final destination.

ElCat uses some chemical cleaning agents and solvents used in equipment repair. Based on the nature of the operations, equipment, including stand-by generators, and processes involve the use of limited quantities of hazardous materials and fuel and the generation of s of hazardous waste (i.e. batteries). A waste and hazardous materials management procedure will be developed as part of the ESMS (under ESAP #1).                 

  Community safety risks and potential impacts are limited during installation or maintenance of the cables and relevant infrastructure and can be mitigated through implementation of measures which are typical of construction sites, such the ones described in the relevant section of the World Bank Group General EHS Guidelines.

Security Personnel

The company contracted a private security company for the security of their office building in Bishkek. Furthermore, in Osh and Batken, the company contracted a state-owned enterprise which provides private security services to private sector. Security personnel are unarmed and mainly responsible for conducting security checks in the company’s offices and responding when alarm systems are activated in communication nodes. During laying of cables, there may be the need for some security arrangements. Hence, the company will develop security management procedure as part of its ESMS (ESAP #1) in line with IFC Performance Standard 4. The procedure will include provisions for the company to inform the lessors of leased facilities, providing their own security, about company’s policy with respect to security personnel.                         

  At present, ElCat has an informal process of engaging with communities affected by their business activities. As part of this investment and under ESAP item #1, the company will develop and implement procedures for prior disclosure of any laying of new cable, any construction of infrastructure and any maintenance activities that could result in community disturbance, such as accidental cuts in adjacent underground infrastructure. ElCat will disclose information regarding such activity by posting signs at sites at least three days prior to the start of such activity. ElCat will also schedule information sessions with local community members if needed and will otherwise address any grievances expressed by local community members. These procedures will be consistently implemented for each project site.                                              

Contact Person: Ulan Tolubaev

Company Name: ElCat LLC

Address: Kievskaya Street 71, Bishkek, Kyrgyzstan

Email: t.ulan@elcat.kg

Phone: +996 222 664400