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

Company has formulated and instituted a management system which is focused on health & safety aspects of company operations. The existing management system comprises of elements such as: Health and Safety (H&S) Policy statement complemented with HR policies, supplier code of conduct and documented H&S manual. A H&S policy was published in December 2018 aiming to improve work environment and provide a safe workplace for all its staff. As per agreed environmental and social action plan (ESAP) #1, the Company will implement the corrective actions formulated as part of the independent ESMS audit within the agreed timelines to strengthen its environment and social management systems (ESMS). ESMS shall include a screening procedure to ensure that risks associated with community health and safety, biodiversity and cultural heritage are identified and avoided or mitigated through mitigation hierarchy compliant with IFC Performance Standards (IFC PS).

As part of the ESMS, company will strengthen E&S aspects such as: subproject screening and categorization procedure; land procurement and compensation in compliance with IFC PS 5 requirements; integrate emergency response process and incident response procedures; waste management procedures; hazardous materials storage and handling procedures; formal stakeholder engagement; traffic safety risks during construction and O&M; and grievance redress for workers and community; contractor management system.

For capital expenditure projects that do not trigger the Maldives Environment Impact Assessment (EIA) Regulation 2012, company adopts a regulatory compliance approach. The Company has valid and current E&S related legal permits, clearances, and consents as required by local regulations for the current operations. All existing domestic and international submarine cable systems have approved EIA permits and the respective EIA reports are available on the Maldives EPA website. As part of the regulatory compliance process, legal and regulatory permits are obtained and maintained for all company operations and the regulatory compliance documents are audited annually to ensure that these legal and regulatory permits are valid, current, and updated.

For the SMW6 project, the consortium contractor (M/s SubCom of US – www.subcom.com) will undertake a full-scale ESIA study for the core line while the Company, which is solely responsible for Maldives branch line, will undertake a full-scale ESIA study by a Maldives Environment Protection Agency (EPA) approved consultant and based on a TOR approved by Maldives EPA. The core and branch line ESIA studies will be commissioned immediately after the desk top study (DTS) and cable route survey is completed. As part of route selection process, E&S screening assessment for assessing potential biodiversity risks will be integrated as per good international industry practices (GIIP) and alternative route analysis will be presented as part of ESIA studies. As per the project timelines planned, the core & branch line DTS reports are expected by May 2022 and cable route survey for India, Maldives and Sri Lanka segment is scheduled in the first quarter 2023. Consortium contractor requires the marine installation permits to be available by 2023 during which time the ESIA study is planned in parallel for core and branch lines.

As per agreed ESAP #2, the Company will integrate in the ESIA TOR documents the identification, assessment and mitigation of key E&S risks and impacts including but not limited to: a) social and livelihood impacts; b) relevant risk screening of marine biodiversity risks and impacts discussed in PS 6 section below during route selection for core and Hulhumale branch lines project and analysis of alternative route analysis; c) impact on ambient air quality and ambient noise levels due to marine vessels, cable laying ship, construction machinery, vehicles and machineries; d) risks and impacts due to ballast water discharged by cable laying ships and vessels; e) risks and impacts due to hazardous and non-hazardous waste management. The Company will co-ordinate with the consortium contractor to ensure that the final ESIA documents are aligned with IFC's PS. The Company will ensure that environmental and social management plans (ESMPs), including, if applicable based on the final alignment, a livelihood restoration plan (LRP)for Hulhumale branch line, are developed as part of both ESIA documents and such ESMPs are integrated in the design and construction contract documents.

For any domestic submarine cable links expansions developed by the Company and included in the project, as per ESAP#3, the Company will undertake PS-compliant ESIAs to meet IFC PS requirements and applicable host country E&S permit requirements and will integrate the relevant mitigation measures in project ESMPs which will be part of the design and construction contract documents.

Under the project, some land is required for constructing both beach manhole and cable landing site (CLS) as part of SMW6 branch line component. A land parcel of less than 3,000 square meters has been identified and allocated for Dhiraagu for constructing the CLS in Hulhumale which is vacant and free of any encroachment. In addition, for some CAPEX projects proposed such as providing mobile and Internet connectivity to the Islands and for expansion of coverage to newly developed areas, limited land space or right of way (RoW) is required for installing roadside cabinets, data centers, and laying of underground cables. None of the projects require acquisition of private lands and the required land is provided by the respective Island or City Councils. Land spaces are allocated based on the approved land use plans in which specific spaces are already earmarked for telecommunication purposes. All land parcels are allotted to Dhiraagu by the Island Councils on rent or long lease basis for 10-15years duration. As the sites allocated to Dhiraagu are green field sites under approved land use plans, there is no physical or economic displacement. As part of the ESMS developed under ESAP #1, the Company will formalize and develop a standard operating procedure (SOP) around land procurement and compensation in compliance with IFC PS 5, where such standard is applicable.

Company has instituted a Corporate Health and Safety Unit within the Human Resources Department. The health & safety unit is headed by a manager along with an Executive and the Unit directly reports to Corporate Director of HR Department. During major project (such as the domestic or international submarine cable projects or network expansion projects) execution, the Company also retains independent E&S consultants recommended by the regulator to support the Company in preparing ESIA reports and implementing ESMP and monitoring plans.

The Company has documented emergency response process and incident response procedures formulated and implemented as part of its Business Continuity Management Plan; such procedures will be integrated in the ESMS under ESAP #1 and meet IFC PS. The corporate health and safety manual covers 28 health, safety, and environment (HSE) aspects and is used as the corporate HSE standards for all work environments at Dhiraagu. The manual also provides detailed guidelines for fire safety, first aid and medical emergency scenarios. The Company has instituted an appropriate monitoring, reporting and senior management review process of the management system. A Health & Safety committee comprising of senior corporate management members including the Chief Executive Officer and Managing Director is functional and meets once in a quarter to approve annual HSE plans and review the Company's HSE performance.

Company, as on 30 August 2021, has 600 permanent staff. Female staff account for about 30% of the total employee strength. The Company also hires around 127 fixed term contract staffs (mostly two-year contract term) through manpower supply agency including 103 male and 24 female staffs. In addition, there are around 270 contractor staffs or workers who are hired for specific services.

The Company has documented policies on human resource (HR) aspects such as working hours and attendance, employment contract, non-discrimination and equal opportunity, overtime, leave, grievance redressal mechanism (GRM), and prevention of harassment & bullying at the workplace which are found to be largely aligned to IFC PS 2 requirements. Redundancy and retirement are addressed through the Company's retirement and redundancy policy and there has been no retrenchment or collective dismissal in the past 3years. During COVID-19 pandemic period, the Company avoided any retrenchment and there was no reduction in salary/wages or other cost cutting measures imposed on all categories of staff. All HR related policies/documents are available in the online portal accessible to all employees and contract staff.  The Company HR policies and procedures do not prohibit workers' freedom of association.

The Company has a documented GRM accessible to direct employees of the Company. The Company has a whistle-blowers policy in addition to mechanisms established in a prevention of harassment & bullying at workplace policy. Employees other than direct employees may report through the channels detailed in the Whistleblowing Policy. The Company has a separate committee to prevent sexual harassment at the workplace, which was set up in 2014 in accordance with the Anti-Sexual Harassment Act (Law No. 16/2014). The Company submits information relating to sexual harassment cases to the Ministry of Gender as required by the legislation on an annual basis.

Based on the independent ESMS audit, undertaken by the Company recently, the Company will implement actions aimed at strengthening HR policies and procedures including: (a) updating the HR manual in line with local regulations and IFC PS requirements to include policies pertaining to collective bargaining & freedom of association, child labor, and contract labor; (b) updating the GRM in supplier code of conduct to include provision for anonymous grievances and also make it applicable for contract and third party workers; (c) formalizing the oversight process over the contractors through internal monitoring and third party monitoring; and (d) developing labor accommodation guidelines to meet local regulations and IFC PS 2 requirements.

Occupational Health & Safety (OHS): The OHS management system consist of the Company's HSE policy statement and HSE manual discussed under PS 1. The Company has a dedicated H&S team under the HR Department. At the operational level, there are fire marshals and safety representatives identified in each of the project or operational sites. The OHS management system is reviewed annually as per the HSE manual and an annual HSE program is approved by the H&S committee. Fire safety and basic first aid training is provided to all company staff. Additional OHS training is provided depending on the employee's designation and job requirements. The HSE team reviews the incident/accident report for fatal/ non-fatal accidents and recommends required corrective actions. The Company reports zero fatal accidents in the last three years of its operations.

Workers Engaged by Third Parties: There are around 270 contractor staffs or workers deployed by the Company in different Islands as site support technicians, technical assistants, security personnel, and site cleaning staffs. Third party contractors are hired through open tendering process and company enters into a legal contract agreement with each contractor. The Company HR policies and Acceptable Suppliers Conduct code apply to third party agency workers and each contractor is contractually bound to be compliant with local labor laws. Dhiraagu HR team has an oversight role for all staff under agency contracts.

Supply Chain: The primary suppliers to the Company include companies such as Huawei, CISCO and Nokia which provide telecom related equipment and Oracle which provides billing system to Dhiraagu. Dhiraagu's Acceptable Suppliers Conduct policy was revised in April 2019 and is modelled to set out minimum standards in the areas of labor and human rights, health and safety, environment and ethical dealings. Since 2013 Dhiraagu suppliers and vendors sign Dhiraagu's supplier code of conduct as part of contract agreement and are expected to meet the requirements therein.

The Company is committed to low emission carbon-resilient business practices and has embarked on a 5-year plan to increase its solar power generation footprint. The energy saving features (LED lighting, high heat reflecting glasses and centralized cooling equipment) implemented in company offices have resulted in an annual reduction of approximately 390,228 kWh of electricity consumption. The Company monitors consumption of electricity, fuel oil, water and diesel consumption by company-owned vehicles. Based on the electricity and diesel consumption details available, project greenhouse gas (GHG) emissions are not expected to cross the annual threshold value of 25,000 tons of CO2e annually.

Main source of water is piped supply available from the local utility - Maldives Water Sewerage Company (MWSC). Use of ground water is regulated under Dewatering Regulation, 2013. Groundwater is abstracted for construction purposes only if MWSC supply is not available and permissible under local regulations. For drinking purposes, packaged drinking water is purchased from certified local bottled water companies.

Company's operations do not generate air emissions except for exhaust emissions from diesel powered generators; potential leaks of refrigerants; and accidental discharge of halogenated hydrocarbons from fire suppression systems. The Company ensures procuring generators that comply to EPA Tier 2 / European Union (EU) Stage 2 emission levels. Maintenance of cooling equipment and fire suppression systems is carried out by trained staff. The Company is gradually shifting to use electric vehicles. The Company monitors ambient noise levels at the time of installation and commissioning of power generation facilities. Appropriate signages are displayed in workplace areas where sound levels exceed 80dBA.

Facilities are connected to the main sewerage system operated and managed by the local utility. Company generates domestic municipal solid waste, recyclables and metal scraps, damaged solar panels, e-wastes (such as used telecom equipment, cables, old computers) and hazardous wastes (such as used batteries and used oil) which are managed and disposed in compliance with local regulations. Based on the independent ESMS audit and as part of the ESMS developed under ESAP #1, the Company will strengthen its waste management procedures as follows: a) implementing regular monitoring and maintenance of record on waste quantities generated for each waste stream periodically (e.g. monthly, quarterly or annual basis); b) ensuring adequate and appropriate waste records for the waste types handed over to authorized third parties for handling and disposal; and c) meeting all the reporting requirements under the local regulations.

The Company does not use significant amounts of hazardous materials both during construction and operational phases. The Company handles and stores diesel for the backup power generation and storage is limited to 1-2 days of usage. As recommended by the independent ESMS audit and as part of the ESMS under ESAP #1, measures will be taken to implement improvements including provision of spill kits and installation of secondary containments at their facilities. Pest control operations in office areas, network infrastructure buildings, data centers and labor camps (during operation phase) are undertaken by licensed pest control specialized contractors operating in the country who comply to local regulations.

The tower sites or base transceiver station (BTS), regional centers, operational buildings, underground beach manholes, underground or overground cable routes, and road-side cabinets in the community neighborhood are located after consultations and clearances from Island Councils. Sites are allocated based on the community approved land use plans. The site plans are further reviewed and approved by the Ministry of Planning, Housing and Infrastructure. The Company buildings and BTS tower structure designs are developed by an in-house team of engineers which are reviewed and approved by the Tower Manufacturer, local Certified Civil Engineers, and respective regulatory authorities before construction. Tower locations are inaccessible to local community and are secured with boundary walls.

Section 15 of Company’s HSE Manual covers Electric & Magnetic Field (EMF) related hazards, exposure limits, radio frequency (RF) safe practices at a Radio Site, EMF related training and good practices to ensure compliance with International Commission on Non-Ionizing Radiation Protection (ICNIRP) Guidelines. The manual sets out the safety limits for community exposure and staff exposure to RF radiations based on the reference levels set by the ICNIRP. This is aligned to exposure guideline requirements presented in Table 1 and Table 2 of Section 2.0 of WBG EHS Guidelines for Telecommunications, April 2007.

During construction of CAPEX projects (such as cable trenching & cable laying works in local communities and public spaces) or SMW6 project cable landing site (CLS) development, minor traffic impacts, including relevant safety risks, can be expected. The Company manages such short period traffic impacts on local community through regulatory consultation & permits from Housing Development Corporation (HDC), pre-consultations and notification to local communities and businesses impacted by the traffic diversions or stoppages ahead of time; and completing the road works in the shortest time period possible. During operational phase, no impact on traffic is envisaged as company uses its own fleet of road vehicles and certified marine vessels for O&M activities and follows local road and marine traffic safety rules. The roadside maintenance activities are undertaken in compliance to traffic police work permit guidelines and HSE manual.

The Company deploys security personnel through third party security service contractors who are registered with the Ministry of Economic Development as required by local regulations. Security contract agency is required to provide basic training for security personnel deployed at company sites. None of the security personnel deployed at company sites are armed as it is not permitted under local regulations. There have been no incident or violent conflicts involving company staff or security with community members in the past.

Biodiversity Risks near Cable Landing site in Maldives: The habitat in the vicinity of the proposed cable landing site (CLS) at Hulhumale and near shore vicinity is modified. Hulhumale´ is a reclaimed island, the average elevation is higher (~+2 mMSL) than the natural islands of Maldives. The crest of the beach is lined with concrete-filled bags as an erosion protection measure. There are at least nine underwater cables making landfall very near to the project area.

The Maldives Atoll chain runs some 800 km north to south. As an atoll nation that is 99% ocean, the Republic of Maldives is a country rich in marine biodiversity. It contains about 4,500 km2 of coral reefs, which is about 3% of the world’s total coral reef area, with over 250 recorded species of coral, over 1,100 species of fish, five species of marine turtle and at least 20 species of marine mammals.  There are eight Marine Protected Areas (MPAs) in North Male´ Atoll. The nearest MPA to the CLS site is Banana Reef located about 2 km to the north-east (NE). All other MPAs are outside a five km radius of the project site. Nearest Environmentally Sensitive Area to the project site is Masgiri (located about 4.8 km NE of Hulhumale´).

Because an ESIA is yet to be conducted for the SMW6 project, preliminary biodiversity baseline information was reviewed based on the 2020 EIA study report prepared for the recently constructed “Maldives – Sri Lanka Cable (MSC) Project: Maldives Landing Component” for which the cable landing site is in the vicinity of the proposed CLS location for SMW6 project. The ESIA referenced five species of sea turtles (1 CR, 2 EN and 2 VU), and one fish (EN) in local waters. Additionally, the International Union for Conservation of Nature (IUCN) lists at least seven pelagic sharks/rays that are critically endangered (CR) or endangered (EN) and that are predicted to occur. The ESIA reports that the Maldives Marine Research Institute has stated that the proposed area near Hulhumale is not particularly rich in coral life. No EN or CR bird species are likely to be impacted by the project.

Based on this preliminary review, it is assessed that, due to the project development, limited sessile marine life within the footprint of the cable laying route would be lost and construction may damage corals and other marine life if proper care is not given during the deployment of the cable on the reef or if the cable is not securely clamped to the reef. Primary mitigation measures would include avoidance of major coral structures, not allowing work outside the immediate cable route, relocation of major coral colonies from the footprint; and implementing practices minimize pollution. A monitoring program would also be required. During mobilization of the cable laying vessel to the site, there is a risk of invasive alien species introduction to the local ecosystem either from the ship’s hull or discharge of ballast water. The assessment of these marine biodiversity and ecosystem services risks and impacts will be integrated in the scope of ESIA studies discussed under PS 1 and included in ESAP #2.  The ESIA will include relevant mitigations that meet PS6 objectives and applicable requirements.

Preliminary Marine Biodiversity Assessment of SMW6 Route

Segment 1: 9683 km long submarine cable proposed between Singapore to Ras Ghareb in Egypt

From Singapore, the coastal and marine environments of the Andaman and Nicobar Islands (ANI) cover coral reefs and seagrass beds. Reefs include fringing, patchy, and barrier reefs which would be considered to be natural habitat. There are also Marine Protected Areas (MPAs) in the ANI that would need to be surveyed and investigated as to how they may relate to the cable location in the proposed ESIA study for the core line. Likewise, there are Important Marine Mammal Areas (IMMA) along the narrow continental shelf of Southwest Sri Lanka, as well as the coast of Maldives Archipelago, including 23 cetacean species, with the Blue Whale (Balaenoptera musculus) being Endangered (EN).

The cable route from the ANI through the Gulf of Aden traverses the Bay of Bengal and the Arabian Sea. The cable will pass through the Red Sea, which is a biodiversity “hotspot”.  The coast of the Red Sea is rimmed by shallow submarine shelves and extensive fringing reef systems. Red Sea fringing reef platforms are over 5,000 years old, and the entire coastal reef complex extends along some 2,000 km of shoreline with the reef complex growing directly from the shoreline. The Red Sea also contains numerous offshore reefs. Included in this category are atoll-like rings of coral, elongated coral ridges that rise abruptly from considerable depths on both sides, and peculiar complex reef patterns.

The marine biota of Red Sea coral reefs is characterized by high endemism. For example, of the 1,200 or so coral reef fish species recorded, about 10% are endemic. About 300 hard coral species have been recorded from the Red Sea as a whole. The Egyptian coast alone supports about 200 species of reef building corals belonging to almost 50 genera. A Critical Habitat (CH) assessment may be warranted, depending on the final cable alignment. The cable will also pass close to the Northern Red Sea Islands IMMA.

A growing number of MPAs have been established in the Red Sea. The narrow Gulf of Suez, through which the cable will be laid, is the most productive fishing ground along the Egyptian sector of Red Sea, where more than 64% of Egyptian Red Sea fish production was harvested from it. Potential snagging risk of the cable from bottom trawl gear and commerce vessel anchors could be high.

The other two segments are Segment 2 which is a land route with two underground cable lines of length 411km and 484 km between Ras Ghareb and Port Said in Egypt and Segment 3 which is a 3162 km long submarine cable proposed between Port Said in Egypt to Marseille in France.  For Segment 2 it is expected that the core line ESIA study will assess the terrestrial ecological risks and impacts along the proposed alignment for both the cable alignments and accordingly inform the selection of the best alignment options that protects the terrestrial biodiversity values. While for Segment 3, there appears to be no remarkable marine biodiversity features for the cable route through the Mediterranean Sea in terms of benthic features, there are, however, tuna spawning areas.  It is expected that the core line ESIA study will assess potential impacts on spawning areas of tuna and other economically important species within the cable route.

The assessment of marine biodiversity and ecosystem services risks and impacts associated with the SMW6 core line will be integrated in the scope of ESIA studies discussed under PS 1 and included in ESAP #2.  The ESIA will include relevant maps showing the latest MPAs and IMMAs, which will need to be surveyed as to how they may relate to the cable location and will include mitigations that meet PS6 objectives and applicable requirements.

The Company’s interaction with the communities is primarily through the Island Councils which are locally elected bodies representing the local community. The Company constantly engages with Island Councils and communicates with them on new land requirements, right of way (RoW) or any other community issues relating to any of its sites/operations in the respective Islands. Community engagement is carried out prior to new land or site allocation and hence company rarely receives community grievances. Based on the independent ESMS audit and to meet IFC PS1, the Company will develop a formal stakeholder engagement SOP, as part of the ESMS under ESAP #1. Going forward, the Company will ensure that stakeholder consultations are undertaken as per the SOP and records of such engagements are maintained.

The Company maintains a community grievance redress mechanism (GRM) to address grievances or complaints received from any community member. Grievances can be filed by individuals or communities with the Island Council or directly with Dhiraagu. At Dhiraagu, grievances can be filed through Dhiraagu Call Centers, Regional Centers or Administration Department. The community GRM is assessed to be functional, and the company reported that the HR Department is regularly instructing line departments on the importance of community GRM. The company also has whistleblowing policy and portal through which external stakeholders can lodge complaints about the company activities. Such complaints are received and investigated by Dhiraagu internal audit department. The GRM will be integrated in the stakeholder engagement SOP.

As part of the EIA process, stakeholder consultations are held with relevant Government Institutions (Communication Authority of Maldives (CAM), Maldives Marine Research Institute), local Island Councils, Housing Development Corporation (HDC), Malé Water and Sewerage Company (MWSC), community neighborhood stakeholders located in the project vicinity. Maldives EPA discloses the project EIA reports and decision statements (environmental clearance or permit documents) on its website (Refer: https://en.epa.gov.mv/reports). The regulator also has a webpage for local community to register their complaints and grievances against any of the projects (Refer: https://en.epa.gov.mv/complain). SMW6 Maldives branch line ESIA and submarine cable expansion project ESIAs will be disclosed by the regulator on their website and consultation will be carried in compliance to local regulations. ESIA document will also be disclosed by IFC as Client’s documentation associated with this ESRS when available.

The company will locally disclose the social and environmental information for the project at the following locations:

Any queries and/or comments about the project may be directed to: