While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security

PS 5: Land Acquisition and Involuntary Resettlement issues are not foreseen as land to develop the build-to-suit sites will predominantly be leased on a long term basis (10-15 years), although some sites may be acquired through  a willing buyer - willing seller basis and hence will not involve expropriation or compulsory land acquisition that may lead to the involuntary displacement (physical or economic). Furthermore, sites will be small, approximately 225 m2, limiting the extent of land required. The company’s management system, as described in PS1, will include a land acquisition procedure consistent with PS 5. 

Given the stage of the project, where the identification of the new sites is still to be carried out, no adverse impacts can be identified on biodiversity conservation, Indigenous Peoples (IPs) and cultural heritage that need to be managed consistent with PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS 7: Indigenous Peoples; and PS 8 on Cultural Heritage, but the company’s management system, as described in PS1, will include a risk screening, assessment and management procedure for biodiversity, IPs, and cultural heritage consistent with PS 6, PS 7 and PS 8.

This is a Category B project according to IFC’s Environmental and Social Sustainability Policy. Based on IFC’s review, coupled with existing knowledge of the sector, the project 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, good international industry practice (GIIP) procedures, guidelines and design criteria as described in the following sections.

Key project E&S issues include: (i) development of the company’s E&S management system and procedures allied to the company’s internal capacity to implement and effectively identify, assess and manage E&S risks and impacts associated with the construction and operation of telecom tower sites; (ii) the development and implementation of suitable human resource policies and procedures to provide for fair and safe working conditions for workers (including contractors) specifically security guards and road traffic accident risk; (iii) the development of policies and procedures for the management of solid waste inclusive of e-waste and hazardous waste/materials; (iv) E&S screening procedures for the siting of telecom towers; (v) procedures for the management of community safety and security management at the company sites, especially towers at remote locations; and (vi) stakeholder engagement strategies and procedures, including effective grievance management and redress.

Environmental and Social Assessment and Management System:

To effectively manage the scale and range of risks posed by Eastcastle’s operations, the company will develop an Environmental and Social Management System (ESMS) aligned with IFC Performance Standard 1 and commensurate to the level of risks associated with the company’s proposed activities. Specifically, the ESMS will incorporate the following elements: (i) policies defining the environmental and social objectives and principles that will guide the operations to achieve environmental and social performance in compliance with the PS; (ii) processes and procedures for the identification of risks and impacts; (iii) relevant E&S management programs; (iv) organizational capacity and competency; (v) emergency preparedness and response; (vi) stakeholder engagement (that includes an external communication and a grievance mechanism); and (vii) a monitoring and review procedure (ESAP 1). With respect to its management system, Eastcastle is planning to obtain ISO 9001, ISO 14001 and ISO 45001 by the end of 2022.

The ESMS will be performance (outcomes) based and include a suite of performance indicators that will be assessed and reported on a monthly basis for senior management review. As Eastcastle propose a direct employee to contractor ratio of approximately 1:5, the company will include clauses in their contracts that require contractor compliance with their E&S policies and procedures and will ensure implementation through ongoing monitoring and audits of the contractors against a predefined set of E&S performance indicators.

Identification of Risks and Impacts:

The identification of E&S risks and impacts will firstly be guided by the local legislative and permitting requirements in each respective operating company (OpCo). To the extent required in each country (Nigeria, Cote D’Ivoire and Democratic Republic of Congo), Eastcastle will commission independent Environmental and Social Impact Assessments (ESIA), meeting local legislation and consistent with IFC Performance Standards, to identify and assess E&S risks and impacts for the construction and operation of new telecom towers and other infrastructure as appropriate.

In addition, Eastcastle will develop and adopt an E&S risk and impact screening, assessment and management procedure for the development of new towers and associated facilities such as access roads to comply with IFC’s Performance Standards. Specifically, the company will (i) develop and implement screening criteria for the selection of sites and projects to screen and avoid high risk areas, including the criteria of "no-go areas", with respect to community health and safety, security, land acquisition and access,  biodiversity conservation, IPs and cultural heritage, in accordance with IFC’s Performance Standards 1, 4, 5, 6, 7 and 8; and (ii) develop a site E&S assessment procedure for new sites to standardize assessment requirements across the business (ESAP 2).

Management Programs:

Eastcastle has developed a draft Environmental and Social Management Plan (ESMP) that describes the proposed environmental and social management procedures to mitigate risks and impacts of their projects and operations. The ESMP addresses three main areas including: general operations, site acquisition and construction and site operation. Relating to site acquisition, the ESMP provides high-level detail relating to site selection criteria and site environmental assessment considerations. Relating to design and construction, the ESMP details potential E&S issues including vegetation clearance, soil erosion, impacts to wildlife, impacts on grazing and agriculture, pollution due to dust, noise, waste management, worker and community safety, and contractor management processes and considerations.

The ESMP does not provide detailed actions or management programs required to achieve its overarching objectives, roles and responsibilities, monitoring and verification and key performance indicators. In addition to meeting national requirements, Eastcastle will update the ESMP to include these requirements and to promote effective environmental and social management throughout the lifecycle of their projects, in accordance with IFC Performance Standards (ESAP 3). Specifically, the ESMP will detail management measures relating to site selection and assessment, developed under ESAP 2; land acquisition policy; E&S engineering design considerations; approval and permitting requirements; site clearance and landscaping; chance find procedures; water use management; materials use handling and storage; fire control and emergency procedures; waste management; dust management; stormwater management; transportation management; noise management; security and access management; recruitment and labor management, training and contractor management. The ESMP will also include a legal register indicating applicable legislative requirements, as detailed in the legal due diligence report, and standardized Environmental Codes of Practice which will be made available to contractors and form part of any contract.

ESMP performance, against the key performance indicators, will be monitored and audited by Eastcastle on an annual basis.

Organizational Capacity and Competency:

As the company is still in the early stages of development, the internal organizational capacity is deliberately limited at this stage. The company has employed a Group Safety, Health, Environment, Risk and Quality (SHERQ) Manager, who will report to the Head of Group Operations, and will assume all E&S related responsibility including training and preparation for ESAP compliance. The number of further E&S resources required at both a group and OpCo level will be defined by the growth of the company’s operations.

E&S compliance will be the responsibility of the Managing Director of each Eastcastle OpCo, who will report to the Group COO for the group as a whole. Senior management will continually assess the need for the appointment of an HSEC officer for each OpCo. HSEC officers will be required to have knowledge, skills, and experience necessary to perform their work, including current knowledge of the host country’s regulatory requirements. HSEC officers will also need to possess the knowledge, skills, and experience to implement the specific measures and actions required under the ESMS (ESAP 4).  The HSEC officers, once appointed, will report to the Group Head of Operations and will be responsible for the overall implementation and monitoring of the ESMP, the maintenance of E&S records, and the preparation of E&S performance reports, to be presented at monthly business review meetings, and annual E&S audit reports. 

Emergency Preparedness and Response:

As a component of the ESMP (ESAP 3), Eastcastle will develop an overarching Emergency Preparedness and Response Plan (EPRP) that will be adopted by each OpCo. The EPRP will identify and detail potential areas where accidents and emergency situations may occur, communities and employees who may be impacted, appropriate response procedures, provision of necessary equipment and resources, designation of roles and responsibilities and liaison with local authorities as appropriate. The EPRP will be communicated to all employees as well as potentially affected communities. Periodic training will also be conducted with employees and contractors to ensure effective response and understanding.

Monitoring and Review:

As a component of the ESMP (ESAP 3), Eastcastle will develop key E&S performance indicators that will be reported on a monthly basis at business review meetings and audited on an annual basis. This review will include compliance with any related legal and/or contractual obligations and regulatory requirements. The extent of monitoring will be commensurate with the project’s environmental and social risks and impacts and with compliance requirements.

The HSEC Officers will be responsible for providing monthly EHS performance reports, against the predefined key performance indicators, to the Managing Director of each Eastcastle OpCo and to the Group Head of Operations.

Eastcastle anticipate employing between 6 and 20 direct employees in each OpCo, depending on the scale of their initial operations. This will include both office-based staff (operations director, program director, project manager, HSEC officer) as well as field-based employees. In addition, it is anticipated that between 50 – 100 contract workers will be required in each OpCo to support activities such as site selection and acquisition, construction as well as ongoing maintenance, security and operations.

Human Resources Policies and Procedures:

Eastcastle will develop and adopt a Human Resources (HR) policy that will detail the company’s approach to managing their workforce in a manner consistent with the requirements of PS2 and local labor laws and requirements. (ESAP 5). All employees, including contract workers, will be provided with documented information pertaining to their rights, terms and working conditions. This will include, where applicable, working hours, wages, overtime, compensation and benefits, leave, performance reviews, right of association, health insurance, pension, termination procedures and grievance management. Additionally, the HR policy will include detail pertaining to employment equity and non-discrimination, a code of conduct (including management of sexual harassment and gender-based violence), and protection of the workforce (forced and child labor).

As a part of the hiring process, every employee, including individual contractors, will be provided with a written contract detailing their terms of employment, commencement date, labor and working conditions (as per the HR policy).

Workers Organizations:

As per local legislative requirements and detailed in the HR policy (ESAP 5), Eastcastle will comply with workers’ rights to join and form workers’ organizations and/or unions of their choosing. Should local legislation not require, or restrict the workers from joining workers’ organizations, Eastcastle will not restrict workers from developing / joining alternative mechanisms to express their grievances and protect their rights regarding working conditions and terms of employment. Where such organizations exist, Eastcastle will provide a designated resource to engage and consult with these organizations, as well as provide ongoing feedback to management.

Non-Discrimination and Equal Opportunity 

As per the HR Policy (ESAP 5), and in accordance with Performance Standard 2, Eastcastle will not make employment decisions on the basis of personal characteristics unrelated to inherent job requirements. Eastcastle will base the employment relationship on the principle of equal opportunity and fair treatment and will not discriminate in any manner, as detailed in Performance Standard 2, with respect to any aspects of the employment relationship,  recruitment and hiring, compensation (including wages and benefits), working conditions and terms of employment, access to training, job assignment, promotion, termination of employment or retirement, and disciplinary practices. Eastcastle will take measures to prevent and address harassment, intimidation, and/or exploitation, especially in regard to women.

Eastcastle, as a component of their draft ESMP, has developed an HIV/AIDS policy that requires that employees and job applicants are not discriminated or stigmatized based on their real or perceived HIV status.

Retrenchment:

No major retrenchment is expected in the foreseeable future as the company is expanding. However, as per the draft ESMP, in the event that any retrenchment becomes necessary, the relevant OpCo must prepare a retrenchment plan and submit it to the Eastcastle HR officer for review in consultation with the Chief Legal Officer. Once the plan is approved, it will then be presented to the CEO / COO for final approval prior to initiation of the program.

Grievance Management:

Eastcastle will develop and communicate an employee grievance mechanism to raise workplace concerns (ESAP 6). The company will inform employees of the grievance mechanism at the time of recruitment and make it easily accessible. The mechanism will involve an appropriate level of management and address concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned, without any retribution. The mechanism will allow for anonymous complaints to be raised and addressed. As detailed in the Code of Conduct, contractors / third party suppliers will be required to implement an internal grievance management process, however, contract employees will also have access to the Eastcastle Whistleblowing Mechanism.

Protecting the Workforce:

As per their draft ESMP, Eastcastle have committed not to employ persons below the legal age limit of 16 years. The company will update the ESMP, and include in the HR Policy under ESAP 5, that it will identify the presence of all persons under the age of 18. Where national laws have provisions for the employment of minors, the client will follow those laws where applicable. The HR Policy will state that children under the age of 18 will not be employed in hazardous work and that all work of persons under the age of 18 will be subject to an appropriate risk assessment and regular monitoring of health, working conditions, and hours of work. Site supervisors will be required to document names and ages by checking national identification cards prior to allowing contracted workers, including unskilled workers, to access the site. Eastcastle has also adopted a zero-tolerance approach to slavery, trafficking or forced labor in any part of the business or supply chain. The company is committed to doing business responsibly and ensuring that workers’ fundamental rights and freedoms are respected. 

Occupational Health and Safety:

Eastcastle will develop an Occupational Health and Safety (OHS) Procedure. In a manner consistent with good international industry practice as per applicable and relevant sections of the World Bank Group Environmental, Health and Safety Guidelines, the OHS Procedure will address areas that include (i) the identification of potential hazards to workers, particularly those that may be life-threatening; (ii) provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents; and (v) emergency prevention, preparedness, and response arrangements. The OHS procedure will also include specific threats to female employees (ESAP 7). As described under PS1, Eastcastle are looking to obtain ISO 45001 (OHS Management System) certification by the end of 2022.

All workers, including contractors, will be provided with appropriate personal protective equipment (PPE) and health and safety training for the type of work in which they are engaged (as detailed in the OHS procedure). For all of its offices and operational sites, Eastcastle will employ appropriate measures for life and fire safety, under the OHS procedure (ESAP 7).

As a component of the OHS Procedure under ESAP 7, Eastcastle will develop a Road Traffic and Driver Safety (RTS) procedure, consistent with GIIP as per the relevant sections of the World Bank Group EHS Guidelines, to manage potential impacts and risks emanating from road traffic accidents. The RTS procedure will apply to both the Eastcastle fleet as well as contractor operated vehicles. The objective of the RTS procedure will be to ensure drivers are equipped not to cause accidents and also to avoid being involved in accidents created by others. At a minimum, the RTS procedure will include driver, vehicle, and journey management procedures, as well as appropriate leading and lagging indicators.  The company will also develop suitable driver recognition and sanction to engender the required driver behavior. Recognizing the risk associated with motorcycle transport, the company will only allow the use of motorcycles in exceptional circumstances and under specific conditions, as defined and assessed through specific procedures under the RTS procedure.

All contractors will be required to comply with the OHS procedure and will be required to submit monthly reports of all safety statistics including lagging indicators, such as fatality, major injury (or lost time injury), minor injury (medical and first aid treatment) and near-misses, and leading indicators such as training and OHS inspections. Contractors OHS performance will be monitored on an ongoing basis as per the requirements of the OHS procedure. Eastcastle will implement an audit and inspection program to assess the veracity of the reporting.

Experience on similar projects indicates the vulnerability of security guards to attack for criminal purposes.  Eastcastle, as a component of the Security Management Plan (ESAP 9), will accordingly implement a security risk assessment for each of their tower sites, assessing contextual risk and developing an approach that would prevent security guards from being injured during criminal attacks.  All new sites developed will be screened for contextual security risks and security arrangements informed by the assessment. 

Workers Engaged by Third Parties:

Eastcastle will outsource activities such as site acquisition, construction activities, operation and maintenance (O&M), refueling and site security to specialized contractors. Prior to appointment, a due diligence will be conducted on all contractors including relevant qualifications, experience, labor practices and working conditions. All contractors will be required to submit written confirmation that they have received, read and understood all relevant Eastcastle E&S policies and procedures, and will adhere to these requirements.

The relevant Eastcastle construction supervisor will inspect contractors as necessary depending on-site activities. Where necessary, the construction supervisor will have the right to stop construction activities if conditions are considered potentially dangerous to workers or the environment. Such cessation of work may be until such time as the necessary measures can be taken to correct the situation. On an ongoing basis, contractors will be periodically audited against the E&S performance requirements to ensure compliance. 

For suppliers of equipment, the Eastcastle head of procurement will conduct regular visits to the manufacturing facilities to satisfy the company that there are no ethical issues regarding their production facilities.

Eastcastle will formalize and document the above in a third-party / contractor selection and management process (ESAP 8) that will include the vetting and ongoing monitoring of contractors’ safety, compliance with labor law, and compliance with Eastcastle health, environmental, working conditions and labor standards and policies. In addition, the contractor management process will ensure that all contractors have access to the Eastcastle employee grievance mechanism (ESAP 7) should they not have a suitable internal procedure available within their organization.

COVID-19:

In light of the ongoing COVID-19 pandemic, Eastcastle will develop and implement a COVID-19 infection prevention, control and response plan, consistent with the provisions under PS2 and PS4 and Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace. Moreover, the company will ensure ongoing compliance with IFC Performance Standards – especially provisions under PS2: Labor and Working Conditions and PS4: Community Health Safety and Security.

Resource Efficiency:

Energy: Eastcastle plan to prioritize grid electricity as the main energy source for their towers. Additionally, to limit power interruptions, all sites (except those in areas with consistent grid coverage) will also be equipped with a system consisting of diesel generators if required and solar / lithium ion battery/hybrid installations. The use of solar power has been identified as a both an opportunity to reduce emissions, but also to manage operating expenditure. As a component of the ongoing monitoring and reporting, as detailed under PS1, Eastcastle will monitor monthly energy consumption for efficiency planning across the business.

Water: It is anticipated that Eastcastle will utilize municipal water for majority of its operations. Quantities will be limited and primarily used for routine administrative, sanitary and cleaning purposes. No significant water use is expected due to the project.

Pollution Prevention and Waste Management:

The management of onsite generators and fuel delivery and storage will be the responsibility of the O&M contractor. All diesel generators will be fitted with draw out type fuel tanks that will also contain built in fuel spillage containment arrangements. The only hazardous waste anticipated from the project is used lubricant oils from diesel generators, lithium and lead acid batteries and contaminated soils where spillages may occur. E-waste generation will be limited to computers, printers and other electronic equipment used in the offices. Where possible, Eastcastle will prioritize the recycling of waste, and where not feasible, will utilize registered waste collectors to collect and manage the disposal at authorized disposal sites.  

As a component of the ESMP (ESAP 3), Eastcastle will formalize all waste management procedures (at both construction and operating sites) including the requirements of O&M contractors to manage pollution prevention and abatement as well as waste. This will also include a waste tracking procedure

Community Health and Safety:

The primary community health and safety risks associated with the project includes exposure to construction vehicles and transport, and exposure to dust, noise and vibrations caused by constructions works. Operational phase hazards may include tower failures and collapse, unauthorized site access and road safety. Despite not being the source of EMF (the monitoring and management of this potential impact being a responsibility of the active telecom tenants), Eastcastle will ensure that all required regulatory set backs, reviewed to ensure they consider the siting guidelines under the World Bank Group EHS Guidelines for Telecommunications, other than in evaluation of EMF, are applied in the site selection process.

The E&S risk and impacts screening and assessment procedure (ESAP 2) will take into consideration these potential community impacts during site selection, construction and operation. Additionally, the third-party / contractor selection and management process (ESAP 8) will ensure that impacts such as dust, noise and traffic risk, and risk of public access to towers, are managed effectively. 

Security:

Eastcastle have proposed that full time security guards will only be deployed at towers sites should the local risk and security profile necessitate this. The provision of security guards will be the responsibility of the O&M contractor or a direct security contractor, who will be required to only employ security guards from third parties that hold valid licenses/permits.  Operations in Nigeria may necessitate rapid response teams to assist with security operations, with such teams also being fully trained and suitably certified.

Given the contextual risks associated with the countries of operations identified at the time of IFC’s review, Eastcastle will develop a Security Management Plan (SMP) that will include prescriptions for guard selection, rules of engagement (including minimum force), training, equipment, facilities, working conditions, grievance mechanism and others (ESAP 9). Security personnel will not be armed.  In certain localities, specialist armed escorts or guards will be provided or required by the Government under very specific conditions. These procedures will be included in the SMP. Site security arrangements will be informed by annual security risk assessments undertaken by each OpCo, under ESAP 9.

Eastcastle will develop and implement a Stakeholder Engagement Procedure for each OpCo that will comply with the IFC Performance Standard requirements on disclosure and community engagement (ESAP 10). The Stakeholder Engagement Procedure will include requirements for prior disclosure of any Eastcastle project (including new tower sites or build-to-suit sites) to local communities as necessary. Eastcastle will review and update the Stakeholder Engagement Procedure on an annual basis.

Grievance mechanism:

As a component of the Stakeholder Engagement Procedure (ESAP 10), Eastcastle will establish a grievance mechanism to receive and facilitate resolution of communities’ concerns and grievances relating to the company’s environmental and social performance. The grievance mechanism will be contextually appropriate. The mechanism will employ an understandable and transparent process that is culturally appropriate, practical and readily accessible. Eastcastle will inform communities about the mechanism at the onset of the stakeholder engagement process. Each OpCo will appoint a designated resource to manage the grievance mechanism, and where necessary, elevate grievances to senior management. 

Contact Person: Srivats Grandhe

Company Name: Eastcastle Infrastructure Limited

Email: srivats.g@ecinfras.com