PS 5: Land Acquisition and Involuntary Resettlement issues are not foreseen as land to develop the build-to-suit sites and for further organic growth (new towers) will be acquired on a willing buyer - willing seller basis and will not involve expropriation or compulsory land acquisition that may lead to the involuntary displacement (physical or economic) of people.

Based on the existing facilities, no adverse impacts related to IFC PS7 on Indigenous Peoples; or IFC PS8 on Cultural Heritage have been identified. Nonetheless, the Company’s E&S Management System (ESMS), as described in the IFC PS1 section below, includes risk screening, assessment, and management procedures for indigenous peoples and cultural heritage consistent with IFC PSs 7 and 8.

This is a Category B project according to IFC’s Environmental and Social Sustainability Policy given that the business activities related to the construction and operation of passive telecom services in the countries being supported by the investment, have limited potential adverse E&S risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures. 

Key project E&S aspects are: (i) implementation of HT’s corporate ESMS in countries of operation, including procedures for site risk screening and site selection, construction and equipment installation and transport and logistics risks; (ii) human resource (HR) policies providing for fair and safe working conditions for Company and Contractors, including grievance mechanism, occupational health and safety (OHS) management and prevention of harassment and gender-based violence; (iv) energy efficiency and management of wastes; (v) electromagnetic field exposure for employees and external 3rd parties, (vi) security management and safety of security personnel in remote locations; (vi) traffic safety; (vii) biodiversity risk management; and (viii) stakeholder engagement.  

Environmental and Social Assessment and Management System

The company has an integrated environmental and social management system (ESMS) for the entire business operation which is certified ISO 9001:2015 (Quality), ISO 14001:2015 (Environment) and ISO 45001 (OHS).  The ESMS is strongly performance / outcomes - based and a suite of performance indicators are provided monthly for senior management review. The key E&S challenge for HT is ensuring that the company’s contractors and sub-contractors implement the E&S management requirements, given that the ratio of direct employees to contractors is approximately 649 to 11780.  Therefore, HT implements an audit program where every contractor is audited at least every six months for compliance with the HT requirements by HT themselves. The audit procedure has 26 environmental, health and safety (EHS) criteria of which 13 focus on the management system used by the contractor and 13 focus on operational controls.  The 26 criteria are articulated in the contract between HT and the contractor. The audit scoring system is structured to provide recognition for innovations that go beyond the HT requirements (and could potentially be replicated by other contractors), compliance with the HT requirements, non-compliance; and non-compliance which could results in fatality or serious injury or breach of legal requirement risk. The audit criteria include the contractors’ ability to manage the E&S performance of their own subcontractors. HT has set an internal target of full HSE audit scoring compliance by 2026 for all its contractors.

‘Stop work’ instructions are issued to contractors when they are audited and found performing unsatisfactorily and such contractors are compelled to go on a recovery plan until compliance is achieved to the satisfaction of HT. Where contractors score partly unsatisfactory, they are placed in ‘EHS Intensive Care’ and are audited monthly until they comply with the minimum standard.  HT also has a process of audit review where the quality and consistency of auditing is assessed for continual improvement. 

Company’s management and audit procedures are also designed to identify systemic E&S management weaknesses of contractors.  HT requires Tier I contractors to have certified ISO 9001, ISO 14001 and ISO 45001 management systems and to date 96% of maintenance partners have achieved this.  The criteria do not fully reflect the PSs, however, and are more focused on health and safety issues rather than environmental and social issues. The audit scoring system nevertheless lends itself to implementation in new countries of operation.  In addition to the existing scored audit program, HT has developed a contractor audit procedure (Supplier Performance Management and Auditing Procedure) as part of its ESMS to ensure alignment with IFC’s Performance Standards (PS) objectives, including among others labor management, community safety, stakeholder engagement and grievance mechanism, and deployed that mechanism across its operations, amongst contractors. HT will (i) update this procedure to include minimum requirements on contractor workers’ terms of employment and working conditions, in line with PS 2; and (ii) review and update their corporate E&S risk register to include risks related to labor and working conditions from contractor activities including a clear approach to monitoring this risk in new OpCos including Senegal and Madagascar (ESAP #1). 

As per ESAP #1, HT includes clauses in the contracts that require compliance with HT policies by contractors and conducts periodic audits of the contractors with a specific focus on subcontractor management. As part of the measures to support E&S management of the expansion plan, HT updated its E&S risk and impacts screening and assessment procedures for acquisitions and the development of new towers and facilities. Specifically, the company (i) developed and is implementing a 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, 4, 5, 6, 7 and 8. As per ESAP #2, the company will ; (i) develop a site E&S assessment procedure for new sites to standardize assessment requirements across the business; and (ii) develop an E&S management plan (ESMP) template that will be included in the contract agreements with third-party contractors.

As indicated, land acquisition is carried out by the company through voluntary land transactions.  HT has a policy that prohibits physical displacement of people in establishing new towers. As part of initial expansion, HT has developed and is implementing a policy on land acquisition that serve to ensure that all land acquisitions are voluntary market land transactions and that, in the event that HT can resort to government authority to gain access to the land or to impose limits on land use, be compliant with PS5. As part of ESAP #3, the company will update the Land Acquisition Policy and E&S Screening template to increase the scope of application, indicate local laws and IFC PSs as the applicable standards, and provide a requirement for implementation of a biodiversity action plan where screening findings indicate impact on biodiversity.

As per ESAP #4, HT has a policy on avoiding siting towers in national parks or other formalized conservation areas but, where such cannot be avoided, the policy commits the company to conduct Environmental and Social Impact Assessments (ESIAs) to ensure risks and impacts are identified and mitigated, and the required authority permits/authorizations are obtained.  For newbuild tower sites there is the risk of impacting on natural or critical habitat even where the same is not necessarily formally protected. Going forward, HT will develop and implement a Corporate Policy on Biodiversity as well as a Biodiversity Action Plan that implements (and verifies the implementation of) a mitigation hierarchy compliant with PS6. The policy will prioritize avoiding natural and critical habitat, as per PS6 definition, in establishing new tower sites and where such avoidance is not possible develop a mitigation plan consistent with PS6 requirements (ESAP #4).

With newbuild towers in the countries in which HT plans to further expand there is a likelihood of establishing tower sites in areas inhabited by Indigenous Peoples (IP). For this reason, as per ESAP #5, HT will develop and will implement an IP policy aligned with IFC PS7, with a view to avoiding the same wherever possible, and where not possible to obtain Free Prior Informed Consent (FPIC) from the communities so affected.

As per ESAP #6, HT screens for impacts on cultural heritage and has developed and is implementing a policy on cultural heritage to ensure: (i) the implementation of a chance finds protocol; (ii) that any chance cultural heritage finds are managed in accordance with the PS8; and (iii) that a tower site in its own right does not negatively affect the aesthetics or sense of place of cultural heritage sites. As part of ESAP #6, HT Site Acquisition Policy requires that areas with cultural heritage or IPs are avoided, but if not feasible for operational reasons, assessments by competent professionals are conducted in line with the requirements of the IFC’s PS 7 and 8.

Organizational capacity and competence 

HT employs a group head of sustainability, a group head of HSEQ and each country specific OpCo has at least one but typically two HSEQ advisors. The managing directors (MDs) of the individual OpCos are required to report on their OpCo’s E&S performance in monthly business review meetings. HT terminated the services of a contractor in 2019 due to poor E&S performance and E&S management capability forms part of the contractor’s pre-qualification review. E&S performance is also part of senior managers’ bonus assessment criteria. The E&S organization will be expanded to include the new OpCos established as part of the project expansion. As per ESAP #7, new HSEQ Advisors have been appointed for each new OpCo including Senegal and Madagascar. Implementation of E&S requirements within HT and its contractors is supported through inductions, formal internal and external trainings and toolbox talks. The leadership of every OpCo receives the six sigma (orange/green and black belt) training mandated by the corporate leadership. There exists a corporate training program which is implemented across the different OpCos. Training of relevant HT personnel will include a specific program on implementation of the applicable requirements of the IFC Performance Standards.

As part of the expansion project, HT has completed the assessment required to evaluate the understanding of the company E&S policies, OHS principles, and competence in oversight and management of contractors. The main outcome of the assessment is a low level of E&S competence within the contractors’ organizations. Going forward a training needs analyses will be conducted and included in all new contracts and stipulate a SHEQ bill of quantities as appropriate, including on applicable requirements of the IFC Performance Standards (ESAP #7)

Emergency Preparedness and Response

Within their SHEQ manual, HT has an Emergency Preparedness and Response (EPR) section that details that all OpCos establish local EPR procedures for identifying potential incidents, emergency situations and ensuring rapid and effective response to accidents, emergencies and hazardous situations. These procedures include inter alia: a) identifying potential emergency conditions, b) drills and exercises, c) how to react to different kinds of emergencies, and d) coordination with authorities. The company is guiding the new OpCos on developing respective EPRs.    

 Human Resources Policies and Procedures:

HT employs about 649 direct workers divided into 72% male and 28% female but with a forward-looking gender target of 70% male to 30% female and has an overarching human resources (HR) policy that is materially compliant with the requirements of PS2 and which is available to all staff. HT’s policies and procedures are designed to require compliance with all applicable local labor laws and regulations across countries of operation. These policies and procedures promote the fair treatment, non-discrimination and equal opportunity of its employees, and include written procedures for handling employee grievances, which includes contractors. In addition, the company implements procedures to continue to ensure that no employee is below the legal employment age. As per ESAP #8, HT will cascade the HR procedures through a relevant regulatory register for each OpCo including Senegal and Madagascar and will provide audit reports showing effectiveness of its HR processes roll-out.

Staff have medical insurance. Across the Group, there are unions present in DRC, with employee representatives present in Senegal, Congo Brazzaville and Madagascar. Senegal and Congo Brazzaville have collective bargaining agreements at national level. In addition, DRC, Congo Brazzaville and Madagascar have established an approved ‘Règlement Intérieur’ (rules and regulations document) negotiated with employee representatives. As per ESAP #8, HT has developed and adopted an anti-harassment policy and implemented a gender-based violence and harassment (GBVH) prevention program amongst staff and contractors across all countries of operation through the recently launched Diversity, Equity and Inclusion (DEI) program aimed at promoting gender diversity and non-discrimination, including principles against gender-based violence; and the employee Code of Conduct that includes principles against discrimination, and GBVH.

No major retrenchment is expected in the foreseeable future as the company is expanding. In 2020 the company stated that there were no instances of workforce reduction or no-pay-leave arrangements due to COVID-19 pandemic. However as per ESAP #8, the company now has a retrenchment policy that is compliant with the requirement of PS2. The company has policies and procedures for managing and monitoring the performance of third-party employees in relation to the requirements of this Performance Standard. HT will update the procedure (per ESAP #1 above) and will continue to use commercially reasonable efforts to incorporate these requirements in contractual agreements with contractors.

Grievance Redress Mechanism: There is a process for complaints to be filed through the management or HR. There is a separate grievance redress mechanism uptake channel through the ethics point which includes reporting to an independent body at corporate level. A complaint investigation team exist at the level of the OpCos chaired by the HR. If a complaint concerns a member of the committee, then the member of the committee is replaced. There exist gender base violence and sexual harassment specialized service providers in South Africa and Tanzania that provide 24hours confidential personnel support service. Each OpCo has a compliance champion who are volunteers and represent an entry point for employee grievance. Contractors’ complaints are also received through this system.

Occupational health and safety management performance 

As described under PS 1, HT has fully transitioned to ISO 45001 OHS management system. Workers are provided with appropriate personal protective equipment and health and safety training for the type of work in which they are engaged. For all of its offices, operational sites, HT employs appropriate measures for life and fire safety. HT will continue strengthening its system and ensuring that contractors’ employees who perform work related to core functions of HT for a substantial duration are provided a safe and healthy work environment, including appropriate training, protective clothing and equipment. The efficacy of the management system amongst the company’s contractors is strongly driven by the audit scoring system described above and underpinned by the Life Saving Rules.  Nonetheless, fatal incidents remain a critical concern for HT.  In recent years the company has experienced and reported fatalities, mainly involving contracted workers and Road Traffic Accidents (RTA).  HT has accordingly prioritized RTA risk reduction and contractor management especially remote work as its most important OHS management requirement.

RTA Risk Reduction: HT and their contractors collectively drive approximately 20 million kilometers a year on generally poor roads, where the driving, roadworthiness of 3rd party vehicles and pedestrian behavior create high exogenous risk. HT’s objective is to ensure drivers are equipped not to cause accidents and also to avoid being involved in accidents created by others. To reduce RTA risk, HT compels all vehicles used by both HT personnel and all contractors and subcontractors to be fitted with In Vehicle Monitoring Systems (IVMS). The IVMS monitors real time harsh braking, acceleration and cornering (oversteer) and speeding. This monitoring has allowed HT to profile individual driver behavior and thereby target high RTA risk drivers. Driver performance is presented monthly as part of the E&S review and OpCo MDs are held to account for driver performance. When the IVMS was first introduced there were drivers in the company with 60 or 70 infringements per 1000 km but these have since been reduced to generally less than 10. Target performance is < 5 infringements per 1000 km. Monthly performance data is available and the system can be accessed at any time to focus on an individual’s driving behavior. HT is currently investigating an incentive scheme to reward good driving so that there is both reward for safe driving and sanction for driving violations respectively. HT has also rolled out the use of forward and inward-looking dashcams as a long-term additional layer to support safe driving interventions. The benefit of dashcams is that they provide information in the event of an accident and also play a role in driver behavioral change given that drivers are alert to the fact that there are under watch. An important remaining risk factor identified by the company is the use of motorcycles by contractors. Through the strict implementation of the audit program, HT is eradicating non-essential motorcycle use (for example using a motorcycle to avoid traffic congestion) but RTA risks remain. Per ESAP #9, HT developed and continues to implement a program for the minimization of motorcycle use by contractors, the compliance of which will be monitored by HT. HT also implemented further risk reduction requirements with respect to motorcycle use including for example GPS tracking devices, high visibility clothing, PPE, additional driver training and sanctions use of motorcycles only in exceptional circumstances.

HT will implement IVMS on all vehicles in OpCos including Senegal and Madagascar and effect the same monitoring and performance review as done in the existing countries of operation (ESAP #10).  

Non-RTA OHS Risks For the non-RTA OHS risks, HT has implemented a similar approach of performance review and management using both leading and lagging indicators.  In order to achieve that performance management, HT has implemented the safety triangle and Bird ratio principles.  HT now requires monthly reporting of all safety statistics by all contractors in the categories of fatality, major injury (or LTI), minor injury (medical and first aid treatment) and near-miss. The company registered a more than 67% reduction in fatalities in the last 5 years. The monthly LTIFR has reduced from 0.35 to 0.25 during 2023. The implementation of this granularity in performance monitoring is not without its challenges and HT still believes that there is potential underreporting certainly of near misses and minor injuries but thinks such underreporting is unlikely for major injuries/fatalities due to the close working relationship between HT and its contractors. In addition, the countries in which HT operates have workmen’s compensation which would ultimately flag a potentially unreported injury to the company. The same approach will be immediately implemented for the new OpCos, starting with Senegal and Madagascar.   

Security guard safety: There is evidence to show that security agents are vulnerable to attacks from criminals. The rate of attacks on security personnel has dropped from 0.5 to 0.36 and the severity rate reduced to 15.85 days away to 2.24 days away per million manhours worked during 2023, but the risk remains. HT has considered various possible interventions including removing the security guards, the company does not yet have a finalized strategy on preventing security guard injuries. As per ESAP #11, HT will accordingly conduct a security risk assessment to be implemented for the tower sites, assessing contextual risk and developing a prioritized program to review security arrangements at the sites and prevent security guards from being injured during criminal attacks.  All new sites developed for the new countries of operation are screened for contextual security risks and security arrangements informed by the assessment.

Overall, HT continues to strengthen its contractor EHS management system. To improve measures to address incidents resulting from road traffic accidents, physical attacks on security workers, and other non-road traffic accidents. HT has undertaken a detailed audit that captures  the contractor’s vehicle journey and driver management programs; contractor (and their sub-contractor) EHS compliance monitoring and audit program at the OpCos; the status of the contractor motorcycle use phase-out process and the existing compliance measures for risk-based use of motorcycles where operationally permitted; (ii) conducted a competence assessment of OpCo EHS leaders/managers and implement improvements actions as identified including roll-out of dashcams and GPS-tracking equipment in contractor vehicles.

Also as part of the above audit, a pattern of experience supervisors placing unaware casual workers in the line of fire has been identified in the review of the most recent incidents thus prompting HT to develop an action plan which includes: (i) a target for the maximum amount of subcontracting that can be undertaken by each contractor; (ii) a bill of quantities and associated service level agreements (SLA) targets for the provisioning of HT HSEQ requirements; (iii) the deployment of 4k camera helmets to all project supervisors and quality engineers; (iv) pre-qualification and ongoing assessment of all sub-contractors (tier II) and (v) the performance management of partner safety critical training. Finally, HT will monitor and report on the implementation of this action plan and matrix to demonstrate progress on implementation as per ESAP #9 above.

 Resource Use Efficiency:

The main energy sources for the business are grid electricity and diesel and petrol. HT has an energy reduction program that sees a combination of hybrid systems at tower sites, reducing the number of vehicle trips to tower sites, solar panels and conversion to DC rather than AC systems. The net effect has been a progressive reduction in overall fuel use over time. The estimated annual Scope 1 greenhouse gas emission for 2023 is 195,151 tons of carbon dioxide equivalence. As part of the expansion program, HT implements an energy use reduction strategy that aims to reduce direct and indirect greenhouse gas (GHG) emissions including energy efficiency performance targets and reporting against the targets and reporting against the targets through various measures to reduce energy consumption and a corporate greenhouse gas (GHG) emission reduction program aimed at achieving 46% reduction in emissions by 2030 and net zero ambition by 2040. Water use in the HT operations is minimal.

Solid Waste:

HT has established policies and procedures for waste management at construction sites and includes terms in its agreements with contractors that cover pollution prevention and abatement. HT’s Lean Six Sigma processes aim to eliminate waste, but where it is produced, reuse and recycling are prioritized. Key waste streams include tower materials, generators and batteries. Safe disposal is assured through internal review of authorized local companies and disposal manifests to confirm that the materials have been disposed of in an authorized disposal site are received.

Monitoring of the fuel tanks at the tower sites is performed. HT will continue deployment of secondary containment for fuel tanks as required under IFC’s first investment. In any proposed investment where HT finds secondary containment structures around fuel tanks are not in place, HT will maintain its prior commitment to develop and within a reasonable timeframe implement a corrective action plan for putting secondary containment structures in place, consistent with IFC’s telecommunications guidelines. 

 Community Health and Safety:

The key risks to communities are brought about by RTAs through the involvement of third parties and heightened security risk by attracting criminals to tower sites that may be close to communities. Both issues are addressed earlier in this document. It should be noted though that HT as passive telecom providers are not the key source of EMF risk; it is rather the transmission devices used by the telecom operators who are clients of HT. Nevertheless, HT adheres to the guidelines of the International Commission on Non-Ionizing Radiation Protection, an independent advisory body working in collaboration with the World Health Organization (WHO). HT has been part of a March 2024 community engagement program as a response to a RTA that included; driving safety and traffic awareness to school children as well as implementation of road traffic signage, zebra crossing and speak break in coordination with Tanzanian roads authority at a accident hotspot close to a school in Ibara-Izebu, Tanzania.

Security:

HT has a security policy that includes prescriptions for guard selection, rules of engagement (including minimum force), training, equipment, facilities, working conditions and others. Security is a contracted private service and does not make use of armed guards.  Security guards are trained not to engage with criminals but rather to keep themselves safe in the event of criminal attack and are simply there to raise the alarm. Continued safety of HT security personnel will be addressed per ESAP #5 above.

HT operates 14,097 existing towers across the nine countries of operation. Out of these, 1,175 towers overlap various protected areas and key biodiversity areas (KBAs), including Alliance for Zero Extinction (AZE) and UNESCO World Heritage Sites (WHS).

In Congo Brazzaville, eight towers overlap with Lower Congo River right bank AZE sites. In DRC, 19 towers are in AZE zones (Lendu Plateau, Marungu highlands, Virunga National Park). In Madasgacar, 23 towers are located in AZE sites (Mahavavy - Kinkony wetlands NPA, Montagne d'Ambre National Park and Special Reserve, Menabe Central Corridor NPA, Daraina - Loky - Manambato NPA, PK32-Ranobe NPA, Ankeniheny Zahamena Corridor NPA (CAZ), Mahajilo River, Ampasindava - Rigny Bay (East) NPA, Mananara-North National Park, Lake Alaotra NPA, Manombo Special Reserve, Ankarafantsika National Park and Ampijoroa, Ranomafana National Park and extension). In Malawi, one tower is in an AZE site (Chizumulu Island and Taiwanee Reef). In South Africa, five towers are located in AZE sites (the Waterberg System, Wolkberg Forest Belt, Cedarberg - Koue Bokkeveld complex). In Tanzania, seven towers are in AZE sites (West Usambara Mountains, Jozani Forest, Udzungwa Mountain Range, Livingstone Mountains forests). Overlap with World Heritage Sites (WHS) occur in DRC where nine towers are found in Virunga National Park and Okapis Wildlife Reserve; in Madagascar where one tower is sited in the Rainforests of the Atsinanana; in Malawi where one tower is in the Lake Malawi National Park; and in Senegal where one tower is located in National Park of Niokolo-Koba.

All the above towers are in modified habitats (within the AZE and WHS zones) associated with human settlements, agriculture, or immediately adjacent to existing roads. Therefore, no changes relative to baseline conditions of these AZE and WHS zones are expected because of these existing sites.

As indicated in ESAP #4 above, to ensure appropriate assessment and management of biodiversity risks for existing sites and any future acquisition or construction on new sites across the business, HT will; (i) include PS6-compliant biodiversity commitments to avoid future siting of towers in AZE sites and WHS sites in its E&S Policy; and (ii) develop  a corporate Biodiversity Action Plan to be applied for sites located in protected areas and KBAs (including the AZE sites and WHS)  aligned with PS6 requirements, which may include additional biodiversity protection measures and additional enhancement programs for the AZE and WHS sites as needed. Biodiversity-related stakeholder components will be integrated within the Stakeholder Engagement Plan (“SEP”) (see ESAP#7), and relevant stakeholders associated with UNESCO, the AZE Secretariat and the KBA Secretariat will form part of the key stakeholders to be scoped into the SEP.                             

HT will continue to recognize the importance of community engagement, and to comply with IFC Performance Standards on disclosure and community engagement. The company will continue to implement procedures developed under IFC’s first investment for prior disclosure of any HT project (including new tower sites or build-to-suit sites) to local communities, consistent with IFC standards. The company will review and update its current practice and will develop and implement a Stakeholder Engagement Procedure that is compliant with the requirements of PS 1 and that includes ongoing consultation with communities and key stakeholders (ESAP 13).

Grievance mechanism

Although HT reports that grievances related to issues such as excessive noise, fumes from diesel generators and others are resolved by the OpCos there is no formalized grievance mechanism.  Per ESAP #13, HT was to formalize the system for lodging, recording and resolving community grievances in compliance with IFC’s requirements, including the relevant communication channels. Going forward, HT will formalize a grievance management mechanism within the SEP that includes a system for lodging, recording, and resolving community grievances in compliance with IFC’s requirements, including the relevant communication channels. Relevant stakeholders associated with UNESCO, the AZE Secretariat and the KBA Secretariat will form part of the key stakeholders to be scoped into the SEP. The SEP will be rolled out as a plan for each OpCo (ESAP #13).

 Helios Towers PLC

Point of Contact: Tom Greenwood, Chief Operating Officer

Telephone number: +44 (0) 207 871 3670

10th Floor 5 Merchant Square, West London, W2 1AS United Kingdom

https://www.heliostowers.com/