This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. Based on information reviewed by IFC, the proposed project is expected to have limited adverse E&S risks and impacts that are few in number and site-specific, and readily addressed through existing mitigation measures and good international industry practices (GIIP) as described in the following sections.   

No additional E&S risks and impacts are expected from this transaction given IFC’s exposure to all activities as an equity partner. Further, there will be no fundamental changes to the company’s activities other than those needed to manage Covid 19 risks. However, the appraisal reviewed operations in Zambia focusing on implementation of the corporate environmental and social management system (ESMS) at the subsidiary level and especially performance on OHS management during operations and maintenance (O&M) and network maintenance (e.g., electrical safety, working at heights, vehicle movement, movement of heavy equipment and others); labor and working conditions; gender based violence and harassment (GBVH); emergency preparedness and response; solid and hazardous wastes, hazardous material management, electro-magnetic fields (EMF); community health and safety including road safety; security management and risk of injury to security personnel; and stakeholder engagement and grievance mechanism.

 Environmental and Social Assessment and Management System

IHS is implementing a corporate ESMS. As part of ESAP #1, the company will a) based on the entire scope of E&S risks to the business, upgrade the ESMS Manual and respective procedures as appropriate; and b) review and update E&S risk and impacts screening and assessment procedures for acquisitions and development of new towers and facilities. Specifically, the company will: (i) fully establish and implement screening criteria for the selection of sites and projects to avoid high risk areas, including the criteria of no-go areas, and those with high risk issues related to community health and safety, land acquisition, biodiversity conservation, Indigenous Peoples and cultural heritage, in accordance with IFC’s Performance Standards; (ii) review, revise and update the E&S assessment procedure for new sites to standardize assessment requirements across the business; and (iii) develop an environment and social management plan (ESMP) template that will be included in the contract agreements with third-party contractors responsible for construction of new sites. 

Organizational Capacity and Competence

The company has dedicated E&S management personnel at corporate and country levels; however, the organizational structure and personnel can be strengthened and as part of ESAP #2, the company will ensure alignment of the E&S organizational structure, define OHS responsibilities and accountabilities and recruit E&S resources with specific competence and experience in OHS to oversee and support effective implementation and monitoring of corporate E&S policies and procedures at each country of operation.

Emergency Preparedness and Response

The company has an overall emergency management procedure designed to provide a systematic approach to emergency management in line with the IHS HSE policy. The procedure provides for emergency training and awareness, appointment of fire marshals, liaison with external agencies; fire prevention measures; routine checks on fire/safety equipment; medical evacuation procedure; and records management. Roles and responsibilities of various relevant offices, including reporting requirements, are detailed in the procedure as well. The emergency procedure will be upgraded to clearly cover incidents related to fuel and oil spills, work at height at the tower sites, EMF/electrocution, fire risk at the tower sites, vehicle/motorcycle use and security; and adequately provide related preventive as well as post-incident emergency response measures. The procedure will also include requirements for contractor compliance. Contractors will be required to adopt this procedure or develop own procedures covering relevant risk areas and be approved by IHS.

Monitoring and Review

IHS has developed metrics to track E&S performance at the corporate level. The actions in the agreed ESAP have different completion timelines, and will need clear tracking given that multinational scope of the business risks. As part of ESAP #3, the company will i) draw a detailed ESAP Implementation Plan (EIP) articulating short-term, medium-term and long-term targets; implementation mechanism; responsible parties; and target dates for meeting each action item; and ii) implement a standard OHS data and metrics reporting template and ensure inclusion of relevant leading and lagging performance data relevant to its business operations and taking into account OHS impact e.g., high potential near misses, occupational injuries (first aid cases, medical treatment cases and lost time injuries), security and fatalities for all countries of operation. The company will also ensure the OHS performance data are periodically presented and reviewed at the highest levels of the company (i.e., senior leadership team and Board). 

 IHS employs 2,113 direct workers out of which about 21 percent are women; and oversees over 43,000 contractor workers across all countries of operation.

Human Resources Policies and Procedures

IHS have a global recruitment and performance management policies. The company runs an online onboarding process supplemented by local operating company practices and regular online and in-person training. The IHS Group Employee Code of Conduct, which is publicly disclosed, sets out the Group’s commitment to best standards of doing business and workforce management. The Code outlines commitments related to employee responsibilities, whistleblowing, no-retaliation, diversity and respect, no-harassment, anti-bribery, and workers welfare. To achieve consistency in worker and contractor management, the company will develop a human resources policy and manual that provide overall framework for employee management, including management of compensation, working hours, employees’ rights to join or form labor unions, workers and contractors grievances, child and force labor and retrenchment.

Working Conditions and Terms of Employment.

At IHS, staff working conditions and terms of employment are largely dictated by country specific legislative requirements. All employees are provided with written contracts of employment as required in their respective countries of assignment.

Workers’ Organizations.

Membership or union activity is largely dictated by the relevant country legislation. No workers’ organizations exist in the business.

Non-discrimination and Equal Opportunity

The Code of Conduct also promotes a professional, friendly, team oriented and open-minded working environment, free of any form any form of physical, mental, verbal or other abuse. Any form of harassment or intimidation is strictly prohibited.

Retrenchment

No retrenchment is currently anticipated in the business. As retrenchment process is generally guided by the relevant country legislative requirements, IHS will develop a Group Retrenchment Policy to be adhered to, in case of any future retrenchments.

Grievance Mechanism

The company has the Whistleblower Policy and Ethics Hotline that allows employees, and external stakeholders where necessary, to report unlawful / unethical incidents in a confidential manner. The Policy and hotline are disclosed in the company’s website and applicable to employees, contractors and communities. IHS will develop a clear internal grievance redress mechanism that applies across all operations, including a gender-specific reporting line, consistent with IFC PS 2 requirements.

Occupational Health and Safety

IHS have an ESMS which provide for a hazard identification and risk evaluation framework for both routine and non-routine activities as per the applicable ISO standards. However, cascade of these system needs improvement for the development at the national level to assure safe execution and completion of tasks by both IHS staff and their contractors. The company has experienced and reported fatalities as a result of road traffic accidents (RTA), attacks on security personnel, falls from towers, impact from falling object, diesel explosion, fall from height and crossfire involving security forces.

As part of ESAP Item #4(ii) above the company will ensure consistent implementation of a structured hazard identification and risk assessment process, in line with relevant ISO standards and guarantee availability of project/company specific risk registers across all countries of operation in compliance with the requirements of corporate ESMS procedures and IFC Performance Standards.

On incident investigation process, IFC’s review of investigation reports identified a number of areas of improvement, including the conduct of root cause analyses and corrective action outcomes material to addressing the failures and circumstances leading to reported incidents. Therefore, IHS will strengthen incident investigation capabilities of its workforce by ensuring that members of the investigation teams are appropriately trained on root cause analysis and develop appropriate incident investigation guidelines consistent with GIIP requirements to be used by the appointed team of investigators. In particular, IHS will revise its incident reporting procedure to improve quality and timeliness of reporting serious incidents and fatalities, including notification to IFC, with special attention to the immediacy of preliminary report containing detailed information on the incident and subsequently final investigation reports that contain adequate root cause analysis and recommendations (ESAP #4).

Third-party Contractors

The company relies on third-party contractors to undertake operational and maintenance activities across its tower sites. In consideration of the performance reported by the company, the current practices need to be upgraded to better manage the assurance and monitoring of third-party contractors in achieving compliance with company’s requirements, in alignment with IFC’s PSs. Majority of these contractors need to establish appropriate ESMS that can improve their performance and allow them to operate safely and reliably in the prevention of serious incidents and fatalities involving workers and third-party persons. To that end, the company has agreed to strengthen its procedures for contractor management that cover third-party capability assessment, initial risk assessment, pre-mobilization screening, mobilization and execution requirements including periodic monitoring of OHS performance of the contractors (ESAP #5).

 IHS has invested some $600 million across its operations in green energy and hybrid solutions including hybrid solar solutions, hydromix solutions, increased connections to the grid where possible, new direct current generators and innovative energy storage mechanisms and batteries. The Network Operating Centers (NOCs) monitor tower sites for power, access and diesel supply, in real time, to ensure diesel deliveries are as efficient as possible (viz. minimizing diesel refueling trips).

By the end of 2020, approximately 42% of tower sites in Africa had solar power available to them, with the remainder relying on a combination of generators, hybrid and recycled batteries, and the grid. Although diesel generators are still in use in many sites, the company has also deployed LPG generators to help further reduce CO2 emissions. The company is also monitoring battery technology with a view to decreasing generator running times. IHS report that these initiatives resulted in savings of more than 345,000 tons of CO2 emissions in 2020 up from 320,000 tons saved in 2019. The company’s current greenhouse gas emissions are estimated at 733 thousand tons of CO2eq from all its operations regionally. 

IHS implement a waste management procedure to guide waste reduction, management, and disposal in the operations.

 Community Health and Safety

IHS builds and operates tower sites in remote locations which involve significant road transportation by its personnel and contractors. Between 2016 and 2021, the company and its contractors have recorded fatalities of both workers and third-party road users. In order to achieve step-change in reducing road traffic related fatalities, the company will accordingly develop and implement a Road Safety Management Plan, expanding current efforts to improve road safety for direct employees, contractors/sub-contractors and which can prevent injuries and fatalities to third-part road users. Specifically, the improvements required shall include, among others, improving the effectiveness of company’s and contractors’ journey management, road hazard analysis, driver management, fleet management and to provide adequate resources to manage and monitor the implementation of the road safety measures (ESAP #6). IHS have an electromagnetic radiation / RF procedure and will require tower operators to ensure that EMF from tower sites are monitored and do not pose any risk to communities, by adopting adequate setback criteria (ESAP #7).

Security Personnel

IHS employs unarmed security guards to protect its tower sites during night and day times. Over the last years, security personnel have been subjected to attack and suffered fatalities in some cases. The company, following the investigations of the most recent security related fatalities carried out throughout the years, will review existing security management arrangements and develop additional mitigation measures to be implemented as a formal Security Risk Management Plan to ensure the safety of guarding employees and safeguarding of assets across its tower sites (ESAP #8).