PS 5: Land Acquisition and Involuntary Resettlement issues are not foreseen as the majority of urban infrastructure will be rooftop, whereas small greenfield sites, mainly for tower infrastructure, will predominantly be leased on a long-term basis. Should land be required, this will only be acquired on a willing buyer - willing seller basis and hence will not involve involuntary displacement (physical or economic). The Operating Company’s management system, as described in PS1, will include a site screening procedure to identify and avoid potential for any form of displacement through practical design and siting measures.

This is a Category B project according to IFC’s Environmental and Social Sustainability Policy (2012). 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.

Environmental and Social Assessment and Management System:

STE will be responsible for the development and implementation of the necessary environmental and social (“E&S”) policies, procedures, and management approaches to ensure the Operating Company operates in alignment with both the local legislation, as well as the requirements of IFC’s Performance Standards (“PS”). To effectively manage the scale and range of risks posed by STE’s operations, the Operating Company has commenced with the development and implementation of an overarching ESMS for Ethiopia to identify and manage E&S risks related to their operations, in line with IFC PS and GIIP. STE has developed a roadmap to work towards obtaining ISO 14001 on environmental management by the end of 2023. The decision to go for the certification will be decided once STE have delivered on the ESMS requirements.

As per ESAP 1, STE will complete and adopt an overarching ESMS to identify and manage E&S risks related to their operations, in line with IFC Performance Standards and GIIP. The ESMS may derive from existing Vodacom/Vodafone/Safaricom group policies and operational plans and will incorporate the following elements: (i) policies defining the environmental and social objectives and principles that will guide the Operating Company 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) building organizational capacity and competency; (v) emergency preparedness and response (including community health and safety); (vi) stakeholder engagement (that includes an external communication and a grievance mechanism); and (vii) a monitoring and review procedure.

Identification of Risks and Impacts:

As defined by the Ethiopian Environmental Protection Authority (“EPA”), telecommunications infrastructure, such as towers, do not require the completion of an Environmental Impact Assessment (“EIA”), however, the construction and operation of electrical transmission lines are listed under Schedule 2, and hence require a Preliminary Environmental Impact Study. STE has developed a Request for Proposal (“RfP”) in anticipation of the procurement of an external service provider to conduct the necessary E&S assessments in accordance with both local legislation and IFC PS should they be required.

As a component of their ESMS, STE has developed a procedure for the identification, assessment, and management of E&S risks associated with the Operating Company’s operations. The process covers all risk areas, including occupational health and safety (“OHS”), stakeholder engagement, supply chain management, legal and regulatory compliance, land allocation, etc. All identified risks are captured and assessed within a risk register. This includes the nature and impact of the risk, risk rating, mitigation, and control measures. Key risks are presented to the board on an ongoing basis.

STE will finalize, adopt and implement a Site Screening Procedure, aligned with the requirements of IFC PS, based on a mitigation hierarchy of anticipate, minimize, and compensate. The screening process is the first stage in project planning and looks to identify and avoid potentially sensitive locations from an E&S perspective, as well as inform assessment and permitting requirements. The procedure covers areas of stakeholder identification, labor risks and opportunities, resource efficiency, community health and safety, land acquisition and involuntary resettlement, biodiversity conservation, indigenous peoples, and cultural heritage (ESAP 2).  

STE has selected, in consultation with members of GPE, and in the process of finalizing the contract and appointment of BSR, an international consultancy, to conduct a human rights assessment to support in developing, embedding, and implementing human rights considerations throughout the Operating Company’s operations. Key risk areas to be assessed include recruitment, supply chain management, stakeholder engagement, data privacy, labor and working conditions, grievance management, and land acquisition.

Management Programs:

As a component of their ESMS, STE has, or is in the process of developing, several E&S management policies, and procedures to mitigate risks and impacts of their projects and operations. These include an Environmental Policy, Social Performance Policy, various HR and OHS related policies, Community Health and Safety Policy, Health and Safety Policy, Crisis Management and Emergency Evacuation procedures, Biodiversity Policy, Land Acquisition Policy, Energy Management Procedure, Integrated Waste Management Policy, Security Policy and Management Plan, and a Stakeholder Engagement Plan.

Organizational Capacity and Competency:

Management of E&S functions within the Operating Company are currently overseen by the Executive Head of Department for Compliance. STE has recently appointed an E&S Manager for Ethiopia with adequate experience to coordinate E&S risk management functions covered by different departments including but not limited to HR, health and safety, environment, contractor/supplier management, stakeholder engagement, land acquisitions etc. (ESAP 3). STE has also procured an international Environment, Social and Governance (“ESG”) consultancy to support with the development and initial implementation of their ESMS, including the establishment of policies and procedures, building internal capacity, and overall E&S training across the STE management team. 

Health and safety, including OHS is managed under the Health, Safety, Environment and Wellbeing (“HSEW”) function. This includes the Chief Human Resource Officer, Lead: Health, Safety, and Wellbeing, and wellness, health and safety managers dedicated to different departments. 

The Operating Company will also establish an ESG Management Committee that will initially comprise members of STE and BII. The ESG Committee will be responsible for monitoring the implementation of the ESMS and overall ESG management and will report to the Audit and Risk sub-committee which reports to the Board. 

Emergency Preparedness and Response:

As a component of its ESMS, STE is in the process of developing and implementing a number of emergency preparedness and response policies and procedures. This includes a Health and Safety Policy Statement, that covers areas of life and fire safety (“L&FS”), training, emergency evacuation, audits, and maintenance requirements. This policy statement is supported by a detailed Emergency Evacuation Procedure detailing the procedures for the evacuation of a STE facility due to threats such as fire, bombs, explosions, seismic disturbances etc. The procedure clearly identifies roles and responsibilities, including an Emergency Coordinator, Emergency Response Officer, and Emergency Response Team. STE has also established a Crisis Management Center at their head office to manage emergencies on a 24-hour basis.

STE has also developed and implemented a COVID-19 policy statement aligned with both national legislative and World Health Organization (“WHO”) requirements and guidelines.

Monitoring and Review:

As a component of their ESMS, STE is in the process of developing four core monitoring, reporting, and compliance assurance processes. This includes an E&S Monitoring and Review Procedure, OHS Monitoring and Review Procedure, E&S Internal Audit Checklist, and an E&S Key Performance Indicator (“KPI”) dashboard.

Reporting on E&S is provided to the ESG Management Committee on both a quarterly and annual basis.

STE employ 601 direct workers (as at end Q2 2022), of which 321 are locally employed and 175 are expatriates. Through the Operating Company’s staffing planning process, it is anticipated that the number of expatriate workers will decrease as the Operating Company matures and upskills local resources. STE also have 175 indirect workers employed through third parties. These workers are predominantly within their technology department and call center. The male to female ratio of all workers is currently 65% to 35% respectively.

Human Resources Policies and Procedures:

STE will develop a documented HR Policy and Code of Conduct in line with IFC PS 2 that outlines workers’ rights under national labor and employment law, including rights related to hours of work, wages, overtime, freedom of association and benefits upon beginning the working relationship and when any material changes occur (ESAP 4). In addition, STE is in the process of finalizing and adopting a number of HR related policies and procedures, including a Staff Manual, Grievance Handling Policy and Procedure, Whistle Blowing Policy, Disciplinary Policy, Leave Policy, Sexual Harassment Policy, and Bullying and Harassment Policy among others. All workers are provided with a starter pack upon appointment and undergo a two-day induction process. All policies and procedures are available to workers on the Operating Company SharePoint site.

As per the requirements of local labor legislation, all workers are provided with a written contract governing their terms of employment. Currently STE provide workers with both open ended and term contracts (12-month and 24-month).

Labor and Working Conditions

Labor and working conditions within the Operating Company reflect the provisions of the Ethiopian Labor Proclamation No. 1156/2019. The STE Staff Manual covers all aspects including recruitment, performance management, learning and development, workplace health and safety, salaries and benefits, overtime and leave.

Ethiopia does not currently have a legislated national minimum wage; hence STE has benchmarked their salary bands against industry norms. All bands are currently above sectoral averages. In addition, STE has developed an incentive matrix determining performance-based bonuses for local workers.

As per the requirements of the local labor law, standard working hours are eight hours per day, and a maximum of 48 hours per week. Any hours in excess of this are considered as overtime, and overtime payments are applicable.

STE provides both a pension scheme and medical health insurance for all direct workers.

Workers Organizations:

Currently no STE workers have joined or formed a labor union and/or workers organization, nor elected worker representatives. As per the requirements of IFC PS2, through the development of their HR Policy (ESAP 4), STE will uphold 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, STE 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, STE 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 defined in the Staff Manual, STE apply principles of equal opportunity during recruitment, appointment, promotion, payment, training, and other employment practices. The Operating Company has also developed a Diversity and Inclusion Policy committing them to a diverse and inclusive workplace. The policy is supported by the Operating Company’s overarching Diversity and Inclusion strategy, as well as other policies including the Talent Acquisition Policy, Flexible Workplace Policy, and Fleet and Travel Policy.

STE has also developed and implemented a Bullying and Harassment Policy as well as Sexual Harassment Policy to safeguard workers, in particular female workers, from any form of intimidation or harassment in the workplace.

Grievance Management:

STE has developed and implemented a workers’ Grievance Handling Policy and Procedure. The procedure includes a three-stage process whereby both direct workers and those employed through third parties can raise grievances with their line manager, senior manager, or Chief Officer or Chief Executive Officer in the third stage. As per ESAP 5, STE will enhance its Grievance Handling Policy and Procedure, by developing an Internal Grievance Policy and Mechanism accessible to direct and contract employees in Ethiopia that should clearly define feedback timelines and include options for anonymous reporting and in different languages. STE will also develop and maintain a grievance register.

Protecting the Workforce:

As per the requirements of the Ethiopian Labor Proclamation and the International Labor Organization (“ILO”) Minimum Age Convention, as ratified by Ethiopia, STE will not employ anyone under the age of 14, nor anyone under the age of 18 for any work that may be hazardous to their health. STE’s HR Policy and Staff Manual, under ESAP 4, will reflect these requirements.

Occupational Health and Safety:

The management of OHS currently sits within STE’s HR function, under the Executive Head of Health, Safety and Wellbeing. STE has adopted an ‘Zero Harm’ culture across the Operating Company, which is enforced through a number of management approaches and procedures.

STE has developed a dynamic ‘Heat Map’ identifying the top five risk areas relating to OHS. Currently this includes occupational road risks, activities of third-party contractors, working at heights, working with electricity, and general construction works. These risk indicators are shared with all contractors involved the applicable areas of work. All third-party contractors are contractually required to comply with STE’s ‘Absolute Rules’, as well to provide an OHS schedule of work prior to the commencement of any activities.  Contractors are also required to complete a daily risk assessment to identify dynamic risks, such as changing weather patterns, and be in possession of a permit to work prior to the commencement of any activities. STE monitor the OHS performance and compliance of their contractors on a monthly basis.

As a component of their ESMS, STE has developed a Fleet and Transport Management Policy 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 policy covers areas of vehicle and driver safety requirements, fleet procedures and requirements, a driver code of conduct, and incident reporting processes. The policy applies to both the STE fleet and drivers as well as contractor operated vehicles. STE is also in the process of procuring an In Vehicle Management System (“IVMS”) for their fleet.

Workers Engaged by Third Parties:

STE utilizes third-party contractors for various project activities, including tower construction, security, catering etc. Prior to the procurement of any third-party contractors, the STE procurement department conduct a due diligence and competency assessment. Minimum requirements of contractors include the development of a Risk Treatment Plan, possession of an International General Certificate in OHS (“IGC”), and a signed labor proclamation ensuring alignment with local labor laws.

Third-party contractors are required to adopt and comply with STE policies and procedures. This includes the requirement to conduct daily toolbox talks covering dynamic risks, which are posted on an internal portal and assessed by STE management. STE conduct random monitoring of contractors to ensure compliance, issuance of required personal protective equipment (“PPE”) etc.

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

Resource Efficiency:

Energy: STE utilizes national grid electricity as the main energy source for their infrastructure, including towers, main office, call centers, data centers etc. Additionally, to limit power interruptions, all key sites (except those in areas with consistent grid coverage) will also be equipped with back-up diesel generators. STE is in the in the process of assessing the feasibility of solar power, specifically for tower sites, as an opportunity to manage operating expenditure and reduce their carbon footprint. As a component of its ESMS, STE is in the process of developing an Energy Management Procedure defining their approach to resource efficiency, as well as detailing ongoing monitoring and reporting requirements.

Water: STE currently utilize municipal water for majority of their operations. Quantities are limited and primarily used for routine administrative, sanitary, and cleaning purposes. No significant water use is expected due to the nature of the project.

Pollution Prevention and Waste Management:

As a component of its ESMS, STE has developed an Integrated Waste Management Policy defining the Operating Company’s management approach to waste management, including an approach of reuse, reduce and recycle. To support the implementation of the policy, the Operating Company has also developed an Integrated Waste Management Standard defining roles and responsibilities, procurement of approved service providers, waste streams and categorization, monitoring, and training. The only hazardous waste currently generated from the project includes lubricant oils from diesel generators, light bulbs, and paint. E-waste generation is currently limited to computers, printers and other electronic equipment used in the offices.

 Community Health and Safety:

The primary community health and safety risks associated with the project could include exposure to construction vehicles and transport, and exposure to dust, noise and vibrations caused by construction works. Construction works are typically limited in terms of magnitude, duration, and impact. Operational phase hazards may include tower failures and collapse, unauthorized site access, road safety and EMF exposure.

As a component of their Social Performance Policy, STE is committed to minimizing the risks and impacts to community health, safety, and security that may emanate from their project activities. This approach is supported through the implementation of their Site Screening Procedure, as discussed under PS1, that looks to proactively identify potential community health and safety risks, as required under PS4, and apply a mitigation hierarchy of avoidance and mitigation. 

STE has developed an EMF Policy defining the objectives, scope, roles and responsibilities, and monitoring requirements. The policy has adopted the independent scientific committee (“ICNIRP”) guidelines for exposure limits. In addition, STE has also developed and adopted an EMF Guidebook for employees and contractors defining the process for safe construction and operation of EMF emitting equipment.

Security:

STE has an internal security team responsible for the management and oversight of security, including private third-party security providers. Due to the dynamic operating environment, the team meet daily to conduct security briefings. Given the immaturity of the private security sector in Ethiopia, STE is currently assessing and training a number of third-party service providers to ensure compliance and suitability.

STE does not employ security guards at every site, but rather only at sites where the local risk and security profile necessitate this. Where possible, STE intends to employ technology, such as CCTV, to enhance on site security. In some instances, particularly to protect key infrastructure such as data centers, STE receive support from the Ethiopian Federal Police.

STE has developed a Security Policy covering areas of perimeter security, access, and egress control, roles and responsibilities, and training. Given the contextual risks associated with the project, STE will develop a Security Management Plan in line with IFC PS4 and IFC’s “Good Practice Handbook: Use of Security Forces: Assessing and Managing Risks and Impacts” with a focus on tower sites, particularly around appropriate use of force and risks to security guards from potential theft. Site security arrangements will be informed by regular security risk assessments, where needed (ESAP 6).

STE has planned for the construction and operation of over 1,500 new tower sites within their first two years of operation. This infrastructure will occur across the country and will predominantly be located along existing transport routes and near urban centers. Three tower sites are proposed within the Bale Mountains National Park, Key Biodiversity Areas (“KBA”) and Alliance for Zero Extinction (“AZE”) site. The three towers are within the footprint of existing urban areas at the western edge of the site. No changes relative to baseline conditions are expected for any of these sites. Consultation with AZE Secretariat and associated stakeholders regarding these towers will be required.

As a component of the enhanced ESMS, under ESAP 1, STE will include PS6-compliant biodiversity commitments. As part of this update, STE will commit to avoiding construction of any future towers within AZE sites or World Heritage Sites. Additionally, as a component of their site screening and assessment procedure, under ESAP 2, the Operating Company will develop and implement appropriate assessment and management of biodiversity risks for any future sites across the business. Biodiversity-related stakeholder components will be integrated with the Stakeholder Engagement Plan (SEP).

 As a component of their Social Performance Policy, STE has committed to establishing contextual engagement structures and systems, engaging with communities, and developing partnerships with national and regional government. To achieve this, STE will develop a corporate-level Stakeholder Engagement Framework or Procedure to map all relevant stakeholders in Ethiopia, including federal/local government, community leaders, NGOs, and organizations in the public and private sector, and methods of engagement, with an emphasis on expansion activities. This Plan should include a centralized system for recording stakeholder engagement activities. The SEP will include processes for stakeholder mapping, information disclosure, community grievance management, and key management functions. The SEP will also adapt and enhance the existing Safaricom External Complaints and Whistle-blowing Policy as needed to the Ethiopia context, and to align with the requirements of IFC PS1. The process will include country-specific requirements including language and accessibility. STE will also maintain a register for capturing complaints and grievances (ESAP 7). Additionally, as per the Site Screening Procedure (ESAP 2), STE will ensure potentially affected communities are identified, informed, and consulted during the E&S risk identification process.

Contact Person: Matthew Harrison-Harvey

Title: Chief Regulatory and External Affairs Officer

Company Name: Safaricom Telecommunications Ethiopia plc

Email: mhh@safaricom.et