There are no risks and impacts expected to be significant, associated with PS 5: Land Acquisition and Involuntary Resettlement: the majority of the length of the proposed new cable project will be laid in the sea, while the on-shore cables to landing points will run on existing utility routes, as designated by the Government of Seychelles. Temporary impacts on fishermen in some shallow water locations resulting in minor economic displacement associated with shortened fishing access for a period of days is anticipated to be limited and will be assessed and, as needed, mitigated as part of the Environmental and Social Impact Assessment (ESIA) under Environmental and Social Action Plan (ESAP) #2. All beach manholes and the landing station for the submarine cable in Seychelles are in urban/peri-urban areas and considered Modified Habitats. The Seychelles landing site is adjacent to areas of coral reef, and thus likely Natural Habitats, but exact alignment of the submarine cable is unfixed with respect to marine and nearshore coastal biodiversity risks (e.g. sea grass beds, coastal dunes, coral reefs). The planned ESIA (ESAP #2) will assess biodiversity risks and, if PS 6 - Biodiversity Conservation Sustainable Management of Living Natural Resources is triggered, will develop appropriate biodiversity mitigation measures, focusing on avoidance wherever possible.  PS 7: Indigenous Peoples: there are no indigenous peoples in Seychelles. PS 8: Cultural Heritage: the exact route and landing points is yet to be defined and hence potential risks and impacts to sites or artefacts with significant cultural value are to be assessed and are covered under the management program component of PS1.

 This is a Category B project, according to IFC’s Environmental and Social Sustainability Policy (2012). Based on information reviewed during the appraisal, it is expected to have limited adverse environmental and social risks and impacts that are few in number, short-term and site-specific, and can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections.

Key E&S issues associated with the project include: adequacy of Intelvision’s environmental and social management system; the company’s capacity to assess and manage E&S risks and issues associated with the expected surge in construction, cable-laying and operations; provision of fair labor and working conditions for employees and contractors alike including on occupational health and safety, grievance management, gender-based violence and equal opportunity; hazardous material, waste and wastewater management, both on and off-shore; security management, and the company’s stakeholder engagement activities.

The deep-water international cable laying results in minimal impact as there will be no interference with fishing activities and minimal disturbance to wildlife. Avoiding direct impacts on seagrass, coral reefs and fishermen will be the basis of final ROW selection during the Marine Survey of shallow water. An ESIA will be conducted to identify, assess and mitigate significant impacts to shallow water or terrestrial habitats or resources. Given the alignment of the submarine cable is still to be defined, implementation of the mitigation hierarchy will ensure that impacts are minimized and anticipated to be manageable to ensure compliance with PS requirements. The final ESIA report will be disclosed by IFC after completion of studies under ESAP #2.

 Intelvision has active operations in Seychelles and complies with statutory environmental and social licenses. The company has policies such as a tower maintenance policy, human resources management, contractor management and systems for fire and water leaks in data centers but lacks a standard documented procedure for assessing and managing environmental and social risks, consistent with IFC’s Performance Standards. To appropriately address the scale and range of risks posed by Intelvision’s project development and operation, the company will develop an Environmental and Social Management System (ESMS) aligned with IFC Performance Standard 1, and national requirements. Specifically, the ESMS is to include an overarching E&S policy statement objectives & targets; and to define an E&S organization capacity including roles and responsibilities.  Environmental and Social Management procedures which will be developed and implemented as part of the ESMS include: (i) Labor and Human Resources ; (ii) Environmental Health and Safety (EHS) procedure; (iii) Occupational Safety and Health procedure; (iv) Waste Management plan; (v) Emergency Preparedness and Response Plan; (vi) Stakeholder Engagement plan (that includes External Communication and Grievance Mechanism); (vii) Community Health and Safety procedure; (viii) Security Management Procedure; (ix) Project E&S Risks and Impacts Assessment Procedure; (x) Contractor E&S Management Procedure; and (xi) Land Acquisition Procedure. The company will involve external experts to assist in the development of the ESMS and in the risks and impacts identification (ESAP #1).

Identification of Risks and Impacts:

As indicated above, for the ISCS, ASN will design, install and commission the project infrastructure. ASN, as part of their responsibilities, will be identifying, investigating and securing the permits and consents, licenses, and supporting environmental documentation required for the installation and operation of the cable system. ASN will appoint a permitting subcontractor for these activities, including the ESIA in the Seychelles. Intelvision will ensure that ESIA is carried out in compliance with the national requirements of, and consistent with the IFC PS requirements. The ESIA will include an assessment of risks and impacts, and relevant avoidance, mitigation and compensation measures, on economic activities, including potentially limited and temporary impacts on fishing community livelihood, associated with shortened fishing access; on marine biodiversity (i.e. impacts on marine species health, habitats, wetlands and estuaries, coral reefs and any areas of known ecological significance), indigenous peoples (if affected) and cultural heritage. To achieve these benchmarks, Intelvision will submit the terms of reference (ToR) for the ESIA for IFC review. Prior to submission of the ESIA Report to the national authorities for permitting, Intelvision will also submit the report to IFC for review to ensure that the report meets relevant PS requirements. The company will ensure that IFC comments on the ToR and ESIA report are addressed appropriately (ESAP #2). The final ESIA report will be disclosed by IFC after completion of the studies.

The company uses contractors for its operations and maintenance guided by a maintenance contract. While the contract provided guidelines on the installation, cabling and determination of signal strength, in addition to appointed contractors requirement to comply with local legal requirements, there are no specific set of E&S risk management procedures documented by the company to guide E&S compliance by such contractors. As such, the corporate ESMS, under ESAP #1, will include E&S risk and impact assessment and management procedures to guide risk identification and management across the business, consistent with IFC’s Performance Standards.

Management Programs:

As indicated, Intelvision currently implements some E&S policy and human resources management for routine business operations. The set of E&S risk and impact assessment and management procedures to be developed in the ESMS (ESAP #1) will represent the company guidelines to assess and manage risks for projects and for routine company operations, while a Environmental and Social Management Plan (ESMP) will be developed as part of the ESIA (ESAP #2) for the project. The ESMP and the relevant management plans which will be developed will define the project commitment to risk management and the mitigations required during construction and operation phase of the project.

As part of ESAP #1, the company will develop a corporate procedure which will require that contractor management plans are developed prior to project implementation. For the ISCS, Intelvision will therefore develop and include such contractor E&S requirements (aligned to local legal requirements and IFC PS requirements) in the contractor procurement procedures and contract agreements to ensure that all contracted parties meet the company’s policies and comply with the project E&S requirements as part of ESAP #1 and ESAP #2.

Organizational Capacity and Competency:

The Technical Manager and the Field Operation Manager are responsible for E&S under company’s Operations & Maintenance (O&M) activities, while the HR Manager is responsible for training of personnel, including EHS training. The company does not have a trained environmental, health and safety professional to effectively discharge this function and coordinate with other responsible offices in implementing the ESMS. Given the planned operational expansion, Intelvision understands the need for a more formal E&S management organization and will engage an external E&S expert to effectively oversee E&S risk and impact assessment process in compliance with IFC Performance Standards, and will appoint a competent E&S officer, to coordinate and manage the implementation of the ESMS, and oversee the E&S mitigation implementation and E&S management during project development and implementation and during routine operations (ESAP #3).

Emergency Preparedness and Response:

Currently, Intelvision does not have an emergency preparedness and response procedure. As part of ESAP #1 a corporate Emergency Preparedness and Response Plan will be developed that cover emergency triggers, emergency types, roles and responsibilities, equipment types and locations, emergency contacts, drills and training. Similarly, a project-level Emergency Response and Management Plans will be developed as part of ESMPs for the connectivity project, under ESAP #2.

Monitoring and Review:

For the routine operations, the Environmental Health and Safety (EHS) Management Procedure to be developed and implemented as part of the ESMS (ESAP #1) will include monitoring and audit protocol to streamline the type, quality and frequency of monitoring and audits throughout the company’s operations and projects.  The monitoring and reporting requirements for the ISCS project will be defined as part of the project ESMPs, under ESAP #2. During ISCS operations, the company will implement the monitoring, reporting and management review procedures developed as part of the corporate ESMS.

  Human Resources Policies and Procedures:

The company has a HR policy to guide the recruitment and retention of workforce and foster a healthy, safe and productive work environment.  The policy is managed by the Human Resources and Administration Manager. As part of the ESMS under ESAP #1, the company will review and update all its procedures and align the same with the requirements of this Performance Standard.  Labor and Human Resources management will be an integral part of the ESMS. 

Working Conditions and Terms of Employment:

The company’s workforce totals about 100 employees in the various departments. Intelvision has developed standalone policies to inform the working conditions and terms of employment.  These include use of company devices, sick leave, overtime, progressive disciplinary action, annual leave, compassionate leave, maternity leave, dress code, uniform and grooming, induction policy, medical insurance coverage policy, staff loan policy, company vehicle policy, and employee benefit policy. All employees have written contracts specifying terms of employment, hours of work, salary amounts and timelines, training, rights and responsibilities and clear job description. Management has indicated that there are no restrictions for workers to join trade unions/organizations at will, however there is no policy statement. As part of this proposed investment, the company will develop an Employee Handbook which abides to local legal employment requirements and provides information on procedures, practices, rights and responsibilities for all employees in relation to working conditions and wages, and is issued to each employee upon recruitment, consistent with the requirement of Performance Standard 2. The Handbook will: (i) include provisions committing the company to respect workers’ rights to organize, (ii) document company stance on child and force labor, (iii) document the grievance procedure, including modes of raising anonymous complaints (or a Whistleblower’s Policy), and (iv) include retrenchment management procedures (ESAP #4). As part of the contractor E&S management procedure (ESAP 1), the company will implement relevant procedure with respect to the rights of the contracted workers; specifically, the company will contractually require its contractors to align their human resources policies with company’s policies and IFC’s Performance Standard 2.

Non-discrimination and Equal Opportunity:

The company has a non-discrimination and equal opportunity policy statement that fosters fair treatment at the workplace. It commits Intelvision to establishing values that do not discriminate against employees or applicants with regard to differences in race, tribe, color, HIV/AIDS status, religion, pregnancy, sex, age, national origin, marital status, or physical disability or any other protected characteristic. Key aspects such as recruitment, training, promotion, salary increase are reported to have been undertaken according to the company policy and are guided by developed instruments and protocols, including legal requirements, as opposed to subjective preferences. As part of the Employee Handbook (ESAP #4) adequate guidelines on harassment and intimidation will be included and provision of relevant disciplinary procedures.

Retrenchment:

No retrenchment is foreseen as part of the project, since the company is in an expansion phase. The company will develop a retrenchment procedure as part of its company ESMS and under ESAP #4. The procedure will be consistent with IFC’s Performance Standard 2.

Grievance Mechanism:

Intelvision has a documented grievance procedure in the Progressive Disciplinary Action Policy. As part of activities under ESAP #4, the grievance procedure will be improved to require grievance documentation at all stages, clearly detail feedback timelines during grievance processing and provide options for anonymous grievances and whistle-blowing.

Protecting the Workforce:

No child or forced labor is engaged in the operations. The employee recruitment process aligns to national legal provisions, which are designed to protect unsafe child labor or forced labor. The Employee Handbook will include the company documented commitment on prohibition of child or forced labor, as part of ESAP #4.

Occupational Health and Safety:

While the company’s HR Policy acknowledges management commitment to foster a healthy, safe and productive work environment, Intelvision does not an have a specific Occupational Health and Safety (OHS) policy and relevant procedures.  Given the expansion, the company will develop an OHS procedure as part of the ESMS under ESAP #1 and provide required resources to implement the procedure. The procedure will have provisions that require risk management measures to ensure safe and secure workplaces and establishment of risk registers at each unit/office, asset or project including procedures for managing contractors’ OHS risks.

Third Party Workers:

The company engages third-party contractors in some of their projects. In such cases, the HR manager conducts due diligence on the contractors, including HR systems; grievance mechanism and documented evidence that workers enjoy all employment benefits required by the Seychelles labor laws. The official working time ends after eight hours, any additional hours worked is considered as overtime including, working on weekends and public holidays. The Contractor E&S Management Procedure (ESAP #1) will be applied in overseeing the management of third-party workers.

 Resource Efficiency:

Energy: Grid electricity is the main energy source for Intelvision operations. The company uses solar for some of its operations. The main energy sources in the project will be generators during construction, and grid electricity (with back-up generators) at the Landing site facilities during operations.

Water: Intelvision records water used in all of its operations. Quantities are limited and primarily used for routine administrative, sanitary and cleaning purposes. No significant additional water use is expected due to the project. The additional requirements will mainly be for similar purposes as above.

Greenhouse Gas (GHG) Emissions: Potential emission sources from routine administrative operations are mainly related to electrical consumption, back-up generator and vehicle use and are relatively insignificant. The project development is not expected to directly contribute significantly to GHG emissions.

Pollution Prevention and Abatement:

At present, the main wastes generated from Intelvision operations are office general wastes, wastewater from cleaning activities and non-hazardous wastes from occasional from equipment repairs. Wastewater from the operational facilities, mainly sanitary wastewater, are discharged into municipal sewers. A Waste Management Procedure for the operations will be developed as part of the ESMS (ESAP #1).

Waste generated as part of project construction and operation will be managed as per local requirements and in alignment with this Performance Standard. ASN’s sea vessels will adhere to MARPOL and IMO requirements with regard to waste disposal. A Project Waste Management Plan will be developed as part of the ESMPs. Waste from excavation (dirt and rocks etc.) from terrestrial cable laying and manhole construction will either be buried in the duct/trench or disposed, along with other general waste (plastic, paper etc.), at designated municipal sites. Terrestrial operations entail laying a cable in the ground to a depth of approximately 0.5-1.0 meter in a concrete duct following an existing ROW or road. Contractors will be required to control runoff and dust during duct construction through implementation of erosion and runoff control measures, and watering dirt roads and construction sites.

Hazardous Materials Management:

Intelvision does not use and store significant quantities of hazardous materials. However, during project implementation, the nature of work, equipment and processes may involve use of various forms of hazardous materials (including fuel). The Environmental Health and Safety (EHS) Management Procedure developed in the ESMS (under ESAP #1) will include protocols for management of fuel and hazardous materials in the company. All fuel storage tanks (e.g., at the data centers) will be designed and constructed to meet international standards, including adequate secondary containment.

 Community Health and Safety:

Corporate community health, safety and security procedures will be developed as part of the ESMS (ESAP #1).

Cable laying activities may have temporary safety risks on other water users, including fisherfolks and other operators and their vessels. There is potential entanglement of anchors, vessels and fishing nets with the cable, and interference with marine recreational activities. The project ESIA will include consultations with these stakeholders and design of mitigation measures to be implemented during cable laying works. Safety of marine operations will be addressed through a set of measures which will defined as part of the project ESMPs. The company will ensure that the project contractor retains a fisher liaison officer in their team to address fisher safety and liaison (ESAP #5).

On-shore, Intelvision operations do not significantly interfere with communities, hence no or negligible health risk. However, the activities on laying of connectivity cables between landing stations and the data centers may pose safety and health risks to local communities. The relevant mitigations will be described in the project ESMP (ESAP #2). There may be minor and temporary traffic interference during trench excavation and cable laying activities. The company will ensure adequate traffic control, sanitary and construction waste management, housekeeping, and dust management through proper work procedures and posting of physical measures, barriers, signals or other measures, such as the use of signal men where needed.

Security Personnel:

Intelvision has contracted private security companies to provide security for the data centers and at their offices. These are non-armed security officers. During the laying of connectivity cables, there may be need for enhanced security provision at landing point and around critical equipment storage/uphold areas. The company will develop Security Management Procedures as part of the ESMS (ESAP #1), aligned to the IFC PS requirements, to address potential security matters, including for cases where armed security will be required, if any.  Even though these guards will be unarmed, they will be trained in accordance with the requirements of PS 4, to be able to take action appropriate to the scale of the potential threat posed.

  By the nature of its operations, Intelvision regularly engages with the regulatory agencies in Seychelles. The company also has social media platforms to interact with any interested parties to their operations. At project level, the company has usually relied on contractors to engage directly with local communities and affected persons. Going forward, the company will develop a corporate Stakeholder Engagement Plan to standardize and supervise all stakeholder engagement activities as indicated in ESAP #6. For the ISCS project stakeholder engagement will be conducted during the ESIA studies and implementation of the project, with communities neighboring the facilities, local government authorities and relevant non-government entities, and project specific community grievance management protocols be implemented. As part of ESAP #7, the company will appoint a community liaison officer in charge of the stakeholder engagement activities, who will also monitor implementation of the company’ stakeholder engagement procedures by the contractors.

 Contact Person: Rahul Walavalkar

Company Name: Intelvision Ltd

Email: rahul@intelvision.sc

Phone: +248 2719841