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.   

Key E&S issues reviewed included: (i) development and implementation of a corporate E&S management system (ESMS) and relevant procedures and plans to screen, assess and manage the limited adverse E&S risks and impacts in line with IFC Performance Standards (PSs) during operations, network upgrades and potential expansion and acquisitions, including land access and land acquisition; (ii) HR policies and procedure, labor and working conditions, OHS management during operations and maintenance (O&M) and network maintenance (e.g. electrical safety, working at heights, vehicle movement etc.); (iii) management of past retrenchment and retrenchment policy; (iv) emergency preparedness and response, including for COVID-19 pandemic; (v) waste and hazardous material management, and electro-magnetic fields (EMF); (vi) community health and safety including motor vehicle safety and L&FS in the retail stores; (vii) security management; and (viii) stakeholder engagement and grievance mechanism.                                                  

  Environmental and Social Assessment and Management System and Policy

Togocom has dedicated E&S and OHS managers who are supported by Axian’s managers in the same roles. Togocel has an ISO14001 certified ESMS, although the scope of the system does not cover the entire organization and business activities of Togocom.  The company has initiated the development of an E&S policy and an ESMS for the entire organization, but some time is still needed for full development.  Under the proposed investment, Togocom will further develop and implement the ESMS, specific to and suitably scaled for its business activities, in accordance with the general requirements of IFC’s PS1. The ESMS will include an overarching E&S policy defining the company’s E&S objectives and principles, and include relevant plans / procedures, including E&S screening, due diligence and assessment procedures to identity, assess and manage relevant E&S risks and impacts of acquisitions and new assets, occupational health and safety, waste management, land access and acquisition policy and procedures, community health and safety, contractor E&S management, greenhouse gas accounting and reporting, environmental monitoring, emergency response, and security management, consistent with IFC’s PS.  As part of the ESMS, a risk register will cover the safety and E&S risks associated with the company’s activities, including physical, chemical, electrical hazards, and gender-differentiated risks. The risk register will include risks associated with security guard and motor vehicle accident (MVA) injury. For each risk identified, the company will define and implement appropriate mitigation measures, which will be incorporated in the ESMS.

The installation of Togocom’s infrastructure such as fibre optic cabling is to be done within existing right of ways and road servitudes. As part the ESMS, the company will develop and adopt a Land Acquisition, Access and Compensation Policy and procedure to guide such processes, including implementation of the mitigation hierarchy and management of encroachment, consistent with IFC PS. The procedure will include details on the company’s roles and responsibilities, including collaboration with the authority, planning, implementation, monitoring, and measures to address potential gaps in the local authority process and complement the actions. Grievance management pertaining to any land acquisition or land access activities will be managed through the external grievance management mechanism, as detailed in ESAP 7, including addressing retrospective compensation obligations (ESAP 1).

As indicated above, the company will sell its towers to a passive infrastructure provider (tower company), as part of the conditions precedent agreed with IFC for the proposed investment. As part of the documentation prepared for the sale, the company will provide a detailed review of the permitting status of the towers. While the towers will not be owned and operated by Togocom in the future, the towers will remain essential for project operations. Togocom will disclose its commitments to abide by IFC PSs to the tower company and will request that the tower company adheres to the same including effective E&S risk screening and assessment of tower locations, including risks for community health and safety, biodiversity conservation, and cultural heritage. Togocom will also request the tower company to ensure stakeholder engagement and obtain required E&S permits and authorizations. The company will accordingly develop and implement a procedure for ensuring that where new tower sites need to be established for network densification or expansion, that the tower company contracted to establish the tower and associated passive infrastructure, will confirm that the towers are suitably permitted before Togocom installs any electronic equipment on the tower (ESAP 2).                                                 

 Since acquiring TGC and TGT, the company has been optimizing staff with 309 redundancies occurring through a voluntary departure plan over a period of three months in 2019 that appears to have been consistent with Togolese labor law. In December 2020 and February 2021, employees of TGT and TGC went on strike due to long outstanding unpaid performance bonus (by the previous owner). Togocom and the unions agreed on the modalities for the resolution of the labor action and, at the time of IFC’s review, the company was addressing these commitments. Togocom will undergo a third party labor audit to assess its human resource practices and working conditions, including assessment of past retrenchment process and closing of outstanding labor commitments as agreed with the unions, in accordance with applicable national legislation and other relevant local labor requirements / regulations and IFC PS2 on Labor and Working Conditions. Togocom will also conduct regular labor audits amongst its contractors (ESAP 3).  The labor audit will further inform Togocom on strengthening human resources management practices in accordance with IFC PS2.

At the time of appraisal, the company employed a total of 1112 direct employees (61% male and 39% female) and 1040 contractor employees. Each worker receives a written contract that describes the working conditions and terms of employment.  Direct employees are hired on both permanent and fixed term contracts. Employees are required to work 40 hours per week.  Overtime is remunerated with compensatory time off (CTO) at a premium rate in line with Togolese labor law. Currently Togocom does not have any HR policies and procedures at corporate level, while its subsidiaries TGC and TGT have documented HR policies and procedures detailing recruitment, rights and obligations of workers and working conditions. Togocom will develop and implement a corporate HR manual and revise those of its subsidiaries in accordance with the requirements of Togolese labor laws and IFC’s PS2, including policies on forced or child labor, equal opportunities and non-discrimination/retaliation, sexual harassment and retrenchment. The HR manual will include a workers’ grievance mechanism safeguarding confidentiality and allowing for anonymous grievances.  This HR manual is to include provisions for contracted and casual workers, including the grievance mechanism as per ESAP 4.

As part of its ESMS (under ESAP 1), the company will revise and upgrade its OHS MS to ensure that it meets PS2 requirements and is developed in accordance with GIIP. The OHS MS will include an OHS Management Plan which will include clear procedures for hazard identification and assessment, hazard and risk controls, incident reporting and investigations (including reporting of safety statistics), life and fire safety (especially in retail outlets) and OHS training and competency requirements. As part of the OHS management procedures, the company will formalize COVID-19 safety protocols, tailored to their operations, in compliance with relevant requirements by the health authorities. This action plan will define preventive actions to mitigate any risk related to the business continuity and employee’s and community safety, consistent with the provisions under PS2 and PS4.                                                    

   Electricity is sourced from the public grid for the majority of the company’s assets. Grid reliability is relatively good but there is backup power generation for the offices and the NOC. The GHG emissions from the project are primarily due to the electricity consumption. The company’s current GHG emissions are estimated at about 3 685 tons of CO2eq from all its operations regionally. Togocom will require passive infrastructure service providers to keep a record of energy used at tower sites and the sources of that energy and to periodically report such information. Under the ESMS (ESAP 1), the company will report on greenhouse gas emissions.    

The ESMS will include an environmental monitoring plan (e.g., water consumption, energy consumption, noise and EMF) and a hazardous material and waste management plan, to be extended to their contractors’ compliance with local legal requirements and IFC PS3. The waste management plan will include procedures to identify, separate, reuse/recycle where possible, and ultimately safely disposal of waste, especially e-waste and will include a waste tracking system. Togocom will develop a protocol for monitoring EMF and will ensure the implementation of that protocol by electronic equipment suppliers and maintenance contractors.                                                

   Community health and safety risks mainly lie with project traffic and MVA involving Togocom staff or its contractors and third parties. Other risks lie with any construction work or improvement / maintenance of the network infrastructure, including the fiber network. As indicated above, as part of the ESMS under ESAP 1, Togocom will develop contractor E&S management procedures to ensure that contractors meet company’s policies on community health and safety, including but not limited to: identification of the working area; installation of signal light and use of flagman for traffic control, in case of open cut and in road crossing areas; maintaining sufficient distance from the road traffic; and cleaning up of work areas, and collection and disposal of waste.  Togocom will develop and implement a motor vehicle safety management plan for both direct staff and contractors including the installation of defensive driving training, vehicle telematics and others that may be needed in response to road safety risks in Togo (ESAP 5). Togocom will develop a security management procedure including requirements for security service providers and security personnel, compliant with both national legislation and PS4 (ESAP 6).