This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key areas of E&S focus include: (i) development and implementation of a corporate E&S management system (ESMS) and relevant procedures and plans to screen, assess and manage the limited adverse E&S risks and impacts applicable to the business of the company in line with IFC PSs during operations, network upgrades and potential expansion and acquisitions, including land access and land acquisition; (ii) HR policies and procedure, labor and working conditions, OHS management during its operations and maintenance (O&M) and network maintenance (e.g. electrical safety, working at heights etc.); (iii) emergency preparedness and response, including for COVID-19 pandemic; (iv) waste and hazardous material management, and electro-magnetic fields (EMF); (v) community health and safety including motor vehicle safety and life and fire safety in retail stores; (vi) security management; and (vii) stakeholder engagement and grievance mechanism.

 Airtel Africa released its Sustainability Strategy in October 2021 which describes Airtel Africa’s commitments in terms of four sustainability pillars: business, people, community, and environment, and a targeted approach to six United Nations Sustainable Development Goals. The sustainability strategy has also been developed to align with the 10 principles of the UN Global Compact on human rights, labor, environment, and anti-corruption. As described in the Airtel Africa Sustainability Strategy, Airtel Africa is committed to addressing and minimizing the impact of its operations on the environment and providing the highest standards of health and safety for its employees and contractors. Airtel Africa is committed to achieving this through the development and implementation of (i) a social, health and safety management system, (ii) an environmental management system, with an ambition, in the longer term, for it to be certified to ISO 14001, and (iii) supply chain ESG oversight and control measures. For the purposes of this disclosure, Airtel Africa’s social, health and safety management system and environmental management system will be collectively referred to as an environmental and social management system (“ESMS”).

Airtel has drafted a suite of corporate E&S policies which Airtel Africa has committed to finalize, per ESAP #1a. The ESMS will be specific to and suitably scaled for Airtel Africa business activities and address its direct operations and indirect operations by passive infrastructure service providers (telecommunications tower and fiber optic service providers) in accordance with IFC Performance Standard (PS) 1 through PS4, screen and manage new telecommunication tower sites against IFC PS 5 through to PS8 for risks associated with land acquisition, and sites with significant biodiversity values, per ESAP #1b. Per the Airtel Africa Sustainability Statement, the ESMS will include the finalized and Airtel Africa board approved overarching E&S policies defining the company’s E&S objectives and principles. At present, Airtel Africa operates a permitting register for its own telecommunications towers, which tracks permitting status for all Airtel Africa owned towers. This continues and will continue to operate as part of the company’s divestment of its telecommunications towers portfolio.

Airtel Africa relies on a network of contractors and suppliers who provides the business with a wide range of products, services, and infrastructure support. As part of its Sustainability Strategy, Airtel Africa has committed to upholding its suppliers to high standards in human and labor rights, environmental performance, and business ethics. Airtel Africa has committed to ensuring that employee rights, legislative requirements, regulation or governance, and environmental performance is upheld in the Airtel Africa supply chain.  Airtel Africa has committed to achieving this by developing a process to monitor its suppliers, measure risks, build visibility and ensure supply chain resilience. As part of the Airtel Africa ESMS development [ESAP #1b], these commitments will be achieved via monitoring and review of suppliers’ compliance to the company’s standards and will be based on a combination of supplier self-certification and periodic audits in due course of time. The ESMS will include E&S requirements for telecom tower service providers where Airtel Africa is an anchor tenant [ESAP #1b]. In such instances, the supply chain management process will include i) E&S greenfield screening, ii) a procedure to ensure the towers are suitably permitted before Airtel Africa installs any electronic equipment on the tower, and iii) E&S provisions for primary service providers. The E&S provisions for primary service providers, namely tower companies and maintenance contractors, will be expressed via a ‘Client’s E&S Standards’ document, defining Airtel Africa’s E&S requirements as defined in its ESMS for all primary service providers, including auditable criteria.

The ESMS will also define E&S elements required for inclusion within the corporate risk register, covering elements such as health and safety (including road traffic risk) of direct, contracted and supply chain workers, E&S risks associated with the company’s activities, including physical, chemical, electrical hazards, and gender-differentiated risks. The risk register will also include risks and injuries related to security. For each risk identified, the company will define and implement appropriate mitigation measures, which will be auditable elements and shall be communicated to senior management and periodically to the Airtel Africa board per ESAP #3. The installation of Airtel Africa’s infrastructure such as fiber optic cabling is undertaken within existing right of ways and road servitudes and consistent with government guidelines and with requisite regulatory approvals. As part the ESMS [ESAP #1b], the company will develop and adopt a Land Acquisition, Access and Compensation Policy for its passive tower assets [ESAP #1a]. The ESMS [ESAP #1b] will define the activities required as part of Airtel Africa’s infrastructure development consistent with PS1 requirements grievance management pertaining to any land acquisition or land access activities and will be managed through the external grievance management mechanism per ESAP #4.

Airtel Africa has established a board sustainability sub-committee which includes permanent members of the Airtel Africa board, along with members of the executive committee. The board sustainability sub-committee provides oversight to ensure sustainability goals are established, determining actions and measurements necessary to reach the sustainability goals as defined by the Airtel Africa board. The Airtel Africa board sustainability sub-committee currently meets monthly and works closely with the executive committee, providing regular updates to the Airtel Africa board. At the Airtel Africa management level, the company has defined an organizational structure, including a sustainability leadership position (Chief Strategy, Partnership and Sustainability Officer appointed on 1 December 2021)) which shall report to the Airtel Africa CEO and interface with the executive committee. Supporting its sustainability commitments, Airtel Africa has commenced the process of nominating environmental officer in some Airtel Africa offices. A sustainability working group and a health and safety committee have also been established, the latter of which reports to the sustainability lead, and executive committee. Airtel Africa has established an adequate organizational E&S (including health and safety) structure at the corporate level. This will be supported by the appropriate resources in the countries of operations, including training, to develop, implement and manage the corporate ESMS per ESAP #2.                                                  

 As of end November 2021 Airtel Africa employs 3,659 direct employees. Airtel Africa Africa’s staff within the borrowing operating companies is comprised of 939 female and 2,720 male employees, and by 2025 plans to increase the percentage of female employees from 28% to 30% and senior executives from 25% to 30% and ensure there will be a minimum of 33% female representation at the board level.

Oversight of all direct employment relationships is provided by the human resources (HR) function managed centrally from Airtel Africa’s operational headquarters. Company HR policies are consistent with host nation labor regulations and IFC PS 2 requirements and apply to all employees. The HR Policy contains non-discrimination and equal opportunity conditions to avoid bias towards gender, health, disability, race, or religion. Requirements against sexual harassment and harassment-free workplace are explicitly addressed in the corporate code of conduct. These are included in employment contracts for all employees directly under Airtel Africa’s purview and address working conditions, terms of employment, leave, wages and benefits. This information is provided to the employee at the time of induction.

Airtel Africa employs staff based on merit, with recruitment based on a role profile for each position and the completion of a pre-employment checklist that includes checking age, qualifications, and experience prior to offering a position. Airtel Africa encourages freedom of association and labor representation across the workforce, and regularly engages with and cooperates with recognized trade unions in markets where it operates. Airtel Africa is in the process of updating its performance management system to further incentivize employees through variable pay component.

Airtel Africa operates a whistleblower mechanism managed by an independent third party, available and accessible publicly to all stakeholders, to address aspects related to the code of conduct topics such as anti-bribery, corruption, tax evasion, conflict of interest, party related transaction. The company operates a worker grievance mechanism which includes an anonymous channel to register grievances and is extended to contracted workers, without fear of repercussion.

Airtel Africa is committed to providing the highest standards of health and safety for both employees and contractors are thus aligned with the provisions of PS2. As noted in PS1, Airtel Africa seeks to realize these commitments via the development of a best practice social and health and safety management system, in full compliance with all legislative requirements, and in a manner consistent with the provisions of PS2, per ESAP #1b. The ESMS will include i) OHS training, including emergency preparedness and response, for Airtel Africa staff to ensure contractors and primary supply chain service providers, including their workers operate in a manner consistent with Airtel Africa’s ESMS requirements; ii) a monitoring and reporting program consisting of the collection of key OHS statistics including near misses, root cause and trend analysis, verification of implementation of corrective actions, and other relevant components covering Airtel Africa staff and contractors; iii) the development and implementation of a worker EMF safety program per the guidance provided in World Bank Group (WBG) Environmental, Health, and Safety (EHS) Guidelines for Telecommunications, iv) an audit program for Airtel Africa construction sites, owned passive infrastructure and contractors responsible for construction and maintenance of telecommunications towers where Airtel Africa is an anchor tenant; and vi) formalized COVID-19 safety protocols, tailored to their operations, in compliance with relevant requirements by host nation health authorities.

 Electricity is sourced from the public grid for the majority of the company’s assets. Grid reliability can be variable and so backup power generation is in place for Airtel Africa’s offices, network operating centers and passive infrastructure sites (telecommunications towers) where telecom tower service providers where Airtel is an anchor tenant. Airtel Africa’s GHG emissions therefore primarily relate to electricity consumption. Airtel Africa operates numerous data centers to support its network requirements and they represent key electricity consumers due to the air conditioning requirements of the servers and data storage equipment. Consistent with the requirements of PS3 for projects with GHG emissions > 25,000t /y, Airtel Africa is committed to fully identifying, measuring and reducing the organization’s GHG emissions, by establishing a decarbonization pathway with support from a globally recognized consultancy with expertise in defining complex carbon-reduction strategies. Airtel Africa has committed to defining a carbon reduction strategy and decarbonization pathway with the support of a globally recognized consultancy. As part of this work, Airtel Africa will require passive infrastructure service providers maintain a record of energy used at tower sites and the sources of that energy and to periodically report such information. The company will integrate GHG reporting requirements as part of its ESMS [ESAP #1b] development.

The ESMS [ESAP #1b], will include environmental monitoring requirements to be articulated to telecom tower service providers where Airtel is an anchor tenant (including water consumption, energy consumption, and noise), a hazardous materials management requirement (including hydrocarbon storage requirements and having secondary containments for generator fuel tanks with a capacity >1,000 l) and a waste management requirements to ensure compliance with local legal requirements, PS3, and alignment with GIIP as per WBG EHS Guidelines for Telecommunications. These environmental monitoring requirements will also apply to Airtel Africa’s operated assets.  The waste management requirements will require third parties managing waste maintain an auditable process to manage waste including procedures to identify, separate, reuse/recycle where possible, and ultimately safely disposal of waste, including e-waste.

 Community health and safety risks primarily relate to i) road traffic incidents involving Airtel Africa staff or its contractors, ii) contracted services for the expansion of Airtel Africa’s telecommunications networks, such as towers contractors or fiber installation contractors, and iii) life and fire safety in locations where Airtel Africa’s directly operated stores are located. As part of Airtel Africa’s ESMS development [ESAP #1b], contractor E&S management procedures will be developed to ensure contractors meet the company’s policies and ESMS requirements on community health and safety, including i) identification and enclosure of working areas; ii) access and traffic control; and iii) site housekeeping. Life and fire safety controls primarily relate to emergency response in the event of fire for both members of the public and Airtel Africa’s own workers at Airtel Africa’s directly operated stores.

Airtel Africa currently meets international standards with respect to electromagnetic field radiation (“EMF”), by exclusively sourcing and using EMF equipment from international vendors who meet or exceed the guidelines as articulated by the International Commission on Non-Ionizing Radiation Protection (“ICNIRP”). The corporate ESMS will define procedures relevant to EMF assessment and management, including aspects of antenna characteristics, installation, and operations in consideration of the tower characteristics and location. The procedure will be aligned with GIIP and international standards, including ICNIRP and other applicable and relevant recognized international guidelines.  The Airtel Africa EMF assessment and management procedures will require and assure future equipment vendor contracts provide performance guarantees or require equipment vendors to provide confirmations, demonstrating consistency with ICNIRP thresholds, per ESAP 1b.

As part of its ESMS [ESAP #1b], Airtel Africa will develop and implement a motor vehicle safety management standard for direct staff, contractors and tower companies where Airtel is an anchor tenant. Airtel Africa’s ESMS [ESAP #1b] will include a security management procedure, including the requirement for security risk assessments to be carried out for the countries of operations and requirements for security service providers and security personnel, consistent with national legislation and PS4 requirements.