Considering the nature of business operations and project activities and based on IFC’s review during project appraisal, no significant risks and impacts associated with the requirements of PS 5 (Land Acquisition and Involuntary Resettlement), PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources); PS 7 (Indigenous Peoples) and IFC PS 8 (Cultural Heritage) were identified for this proposed project. In any case, the company will develop policies and procedures to screen for E&S risks and impacts and, when such risks and impacts are identified, mitigate them consistent with all the PSs as summarized under the PS1 section below.

If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards.                                                 

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability as the potential adverse E&S risks and/or impacts, which are generally site-specific, are largely reversible and can readily be addressed thorough mitigation measures. Based on the available project information, key project related E&S issues and risks include the company’s capacity and systems to review and manage E&S performance of three company’s managed co-investments, the operations of their assets, new projects and acquisitions, , including: environmental and social management systems (ESMS) of the investee assets, ensuring that appropriate organizational capacity is in place to implement the ESMS, management of labor relations and working conditions, occupational health and safety, consistency and replicability in the site acquisition process to ensure that leases are entered into freely and there are no impacts to untitled land-users, monitoring and management of environmental emissions, stakeholder engagement and community grievance mechanism, and contractor management across all asset operations.                                                  

Environmental and Social Assessment and Management System

Scala, Highline, EdgePoint and AIMS undertake to conduct assessments to identify potential E&S risks and impacts, and to develop and implement required actions as per local regulations where they operate prior to engaging in either acquisitions and/or construction. DB works alongside its portfolio companies to set ESG-specific goals, determine how to best monitor, and measure progress and to develop performance measurement tools. Specifically, DB also relies on an external ESG consultant who provides ESG due diligence analysis for each investment that the company considers.

In addition, DB expects from each portfolio company to understand and manage key ESG issues as well as reporting of ESG metrics. Each portfolio company is expected to conduct a materiality assessment to identify and prioritize the ESG issues that have the greatest impact on its business and stakeholders and provide the results of this mapping exercise to the company’s Board of Directors. This information is then used to identify company specific ESG issues not covered by DB’s core ESG KPIs.

Telecommunications towers within Brazil, Malaysia and Indonesia are required to obtain local regulatory permits prior to commencement of construction, except in cases where a site is exempt from permitting requirements. Towers built by Highline and Edgepoint on a greenfield basis are appropriately permitted or in the process of being appropriately permitted.   In instances where the portfolio company has agreed to acquire tower portfolios where select sites are not fully permitted, both parties will agree to a remedy process before assuming full operational control of these individual assets. DCs within Malaysia are required to secure various regulatory approvals including change of use permits for existing building, approvals for constructing new buildings, and life and fire safety (LFS) certification. AIMS has in place processes to ensure that these approvals are secured.

Policy

DB has a responsible investment policy, which defines focus ESG objectives for its investments including governance, H&S, Diversity, Equity and Inclusion (DEI), physical risk, and climate change. As a guiding force for all its operations, the policy also clearly defines the need for compliance with local laws and regulations.

Scala has a well-defined E&S policy stating responsibilities and E&S commitments aligned with IFC PS 1. Highline has active policies in place which includes environmental and social objectives and principles that guide the company to achieve sound environmental and social performance. Particularly, it highlights its commitment to the E&S regulations of Brazil, its aim to implement sustainability best practices, and its commitment to forbidding child and forced labor. As a new operation, EdgePoint is using DB’s ESG framework until they develop their own procedures/policies. AIMS through its previous holding company (TIMEdotCom) has EHS and OHS policies in place that will be revised and updated to reflect requirements of both DB and the IFC PS.

Management Programs

DB’s environmental and social management system (ESMS) includes a due diligence procedure and a reporting system. As signatory of the PRI Principles for Responsible Investment since 2020, DB has committed to incorporating environmental criteria into its analysis and decision-making process, ensuring adequate disclosure, and establishing reporting measures, among others. As part of aligning the ESMS with IFC Performance Standard 1, DB will undertake to include aspects related to (i) community engagement and (ii) enhance its contractor screening assessment checklists to include contractors’ workers labor conditions (ESAP Action No. 1).

Scala’s ESMS is aligned with and is in the process of obtaining ISO 14001. It has specific procedures for new site identification and detailed due diligence assessment, including biodiversity impacts (i.e., endangered species/ migratory birds). Although, the current facilities are located in industrial sites with limited risks of negative impacts to communities, to address risks and potential impacts from future developments, Scala will undertake to upgrade its ESMS by developing a stakeholder engagement procedure including a community grievance redress mechanism (GRM), for use during construction and operation, aligned with IFC PS1 (ESAP Action No 2).

In November 2020, Highline acquired a former IFC client (Phoenix Tower do Brasil, project # 36722, approved in 2016) and retained their established E&S procedures and systems aligned with IFC E&S requirements. Currently, Highline is extending those procedures to the remaining towers in its portfolio. As Highline is undergoing fast growth (i.e., so far building over 400 towers throughout Brazil year-to-date as of July) there is a need to maintain robust E&S systems and procedures to meet E&S requirements and ensure sound oversight of construction and operations & maintenance (O&M) activities which are conducted by contractors throughout the country.

Highline has due diligence procedures for acquiring existing and building new towers. Through checklists, it assesses potential E&S impacts as per Brazilian requirements (i.e., restrictions due to proximity to areas of protection or conservation, parks, roads, indigenous people land, etc.) and, as needed, identifies suitable alternatives. Highline aims to acquire assets with proper permitting; whenever there are pending permitting issues, Highline ensures that detailed remediation and mitigation plans are implemented once it assumes full operational control. Even though Highline does not have a social management system, whenever there is a community concern, it engages with the relevant communities and according to information provided, there have been very few cases related to community concerns. Notwithstanding, Highline will undertake to develop procedures for stakeholder engagement, including GRM, before/during tower construction and operations (ESAP Action No. 3).

As part of its ESMS, for both Indonesia and Malaysia, EdgePoint is currently implementing its new Code of Conduct and Compliance Regulatory ESG protocol, as well as a Crisis Management procedure. A H&S Manual is in place which is operationalized in Malaysia and will soon be in Indonesia. EdgePoint will undertake to complete and upgrade the existing ESMS to include environmental, social/ community, HR and labor aspects, covering both Indonesia and Malaysia national requirements and aligning with IFC’s Performance Standard 1. The ESMS will incorporate the following elements: (i) policy, (ii) identification of risks and impacts, (iii) management programs, (iv) organizational capacity and competency, (v) emergency preparedness and response, and (vi) stakeholder engagement, including GRM. As mentioned earlier, EdgePoint will also develop a corresponding H&S Manual for Indonesia (ESAP Action No. 4).

The management programs presently implemented by AIMS are driven by regulatory compliance and include workplace monitoring and performance reporting, third-party supplier management, a waste management protocol and programs supporting the implementation of the OHS policy. AIMS will revise and update this approach as part of an ESMS (ESAP Action No. 5).

Assessing and Complying with Performance Standard Requirements for Future Developments

As IFC’s investment will be used in large part to develop greenfield facilities and the locations/land for these developments have not yet been identified, Scala, Highline and EdgePoint will undertake to comply or bring into compliance with the requirements of the IFC PSs and local environmental, labor and social requirements. Currently, Highline and Scala acquire or lease land for the siting of towers and data centers and assess legal and potential biodiversity consideration to ensure compliance with relevant Brazilian requirements. EdgePoint, particularly in Malaysia, follows regulations which establish among other aspects, setback distances to houses and roads and detailed requirements when land is to be used for farming or designated as protected and forested areas. In Malaysia, EdgePoint aims to repurpose lamp posts or other suitable structures as part of tower construction. 

To align and meet the requirements of IFC’s PSs, Scala, Highline and EdgePoint, as part of their management systems, will undertake to enhance their site screening and selection procedures by defining criteria and conducting early screening and detailed assessments related to: (i) land acquisition as per IFC PS5, (ii) biodiversity risks and impacts including assessments of key biodiversity areas, endemic bird areas, and other habitat features that may trigger a natural or critical habitat classification, and thus offsetting requirements, as per IFC PS6; (iii) risks and  impacts to indigenous peoples as per IFC PS7, and to cultural heritage as per IFC PS8. Where risks are identified, the procedures will require the development of mitigations according to the mitigation hierarchy to comply with IFC’s PSs. The procedures will include chance find protocols to manage impacts to items of potential cultural heritage significance during the construction of the towers. Once established, these procedures will be implemented by each portfolio company and will become a contractual requirement for any contractor engaged in new project developments and construction on behalf of Scala, Highline and EdgePoint. Furthermore, the portfolio company will be required to develop corresponding E&S management plans (ESMPs) to oversee the implementation of the mitigations and E&S performance of these activities (ESAP Action No. 6).

The AIMS co-investment will be used in part to facilitate expansion of AIMS physical footprint throughout South-east Asia and AIMS will undertake to ensure that this is conducted in full accordance with both the prevailing regulatory framework in each country and the IFC PS. As part of the ESAP AIMS will undertake to develop site screening and selection procedures by defining criteria and conducting early screening and detailed assessments relating to regulatory compliance factors, land acquisition, biodiversity, risks and impacts to Indigenous Peoples, cultural heritage, and community health and safety factors (ESAP XX). AIMS is already in the process of conversion of the KWPS facility in Kuala Lumpur (5MW), construction of Cyberjaya Block 2 (8MW), with planning for Cyberjaya Block 3 (10.8MW) having recently commenced and form the entirety of the planned expansion through to the end of FY2025. All future expansion will need to be conducted in accordance with the new procedure and become a contractual requirement for any contractor involved in new project development and construction on behalf of AIMS. The primary ESMS developed by AIMS will ensure that construction and operation of each new facility will be conducted in accordance with prevailing regulations and IFC PS, with a specific E&S management plan (ESMP) to oversee the implementation of any proposed management, mitigation, and monitoring measures.

Organizational Capacity and Competency

In 2020, DB established a cross-functional ESG Committee (operating and investment professionals) to oversee the company’s ESG program, develop initiatives designed to improve related performance, metrics, and disclosure, and to present ESG data and updates on a quarterly basis to the Board of Directors. The ESG committee is advised by an external consultant, who conducts the environmental and social due diligence processes of proposed investments. The ESG Committee and its external consultant will oversee the implementation of the ESMS and adequately monitor and report on the E&S performance of its investments with respect to compliance with IFC’s PSs.

Scala’s EHS responsibilities were previously distributed along various areas within the organization, but Scala recently created an EHS team that centralizes the EHS’ responsibilities and develops the EHS criteria in the company and implements the ESG Program, mainly focused on energy and water optimization.

In April 2021, Highline established an ESG committee to oversee key E&S aspects including environment, occupational health, human resources, land acquisition/leasing, biodiversity, and security management.

EdgePoint has yet to develop its E&S organizational chart. Recently, EHS functions have become aligned between both countries and are now overseen by the Operations team. In Malaysia, a dedicated team is in place to manage permits and land acquisition, while in Indonesia, a Head of Compliance will be hired to oversee both Indonesia and Malaysia requirements. EdgePoint will identify dedicated personnel to screen, assess, and oversee E&S risk and impact management and mitigation, ESG reporting and matrices and identify dedicated personnel for overseeing community/ stakeholder management and GRM (ESAP Action No. 7).

AIMS presently has a single position in the organization responsible for oversight of EHS management and oversight of construction and O&M and is in the process of employing an additional EHS officer. There is also a EHS Committee that meets quarterly and has been established primarily to meet regulatory expectations within Malaysia and its functions will be adapted to meet IFC PS and DB expectations. As part of expansion planning, AIMS will ensure that there is a dedicated management-level position within the organization responsible for compliance with local and IFC PS requirements during any expansion (ESAP XX).

Emergency Preparedness and Response

Each of Scala’s data centers has functional emergency response plans, aligned with IFC PS requirements, including appropriate emergency preparedness and response measures to be implemented in the event of potential emergency scenarios; addressing emergency communication, post emergency activities, emergency drills, abandonment plans and detailed procedures for use of alarms, search and rescue, firefighting, and medical emergency, among others. Scala’s data centers are fitted with appropriate fire prevention and response measures, including automatic sprinkler systems, water supply, water mains and fire hydrants, alarm systems, portable first aid and firefighting equipment and comply with the NFPA requirements for life, fire, and safety. Fire and emergency response drills are carried out periodically simulating scenarios based on a risk assessment. 

Highline and EdgePoint are responsible for the emergency prevention and response of their towers. Highline and EdgePoint apply emergency response practices at their headquarters buildings, participate in fire and emergency response and prevention, and are part of the building emergency brigade but have not yet developed corresponding emergency response plans for tower construction and O&M. As part of its regulatory compliance obligation in Malaysia, AIMS has in place emergency preparedness and response plans for each of its current facilities as part of securing LFS certification, however these need to be expanded to capture construction phase and full consistency with good international industry practice expectations and regulatory requirements across the geographies in which AIMS operates. Therefore Highline, EdgePoint and AIMS will develop their specific emergency response plans for tower construction and O&M, including (i) emergency response procedures and  scenarios, (ii) accidents/incidents that may arise during construction and during O&M, including road traffic accidents and security related incidents, (iii) communication policy, (iv) roles and responsibilities, (v) mitigation and follow-up, (vi) identification of affected communities and relevant communication protocols, and (vii) provision of equipment and resources (ESAP Action No. 8).

Training

Scala provides onboarding training mainly oriented on health and safety procedures and will implement additional training on environmental and social aspects. Highline provides training on its Ethics and Conduct policy to staff on an annual basis. Additionally, Highline will design and implement E&S training, mainly focusing on E&S permits and requirements, H&S impacts, E&S management of contractors, and stakeholder engagement. EdgePoint is set to roll out ESG training for its employees. AIMS has a basic training protocol established through its OHS policy and human resources team which includes training of its own staff, suppliers, and contractors. Scala, Highline, EdgePoint and AIMS will design and implement an E&S training program for their staff, considering E&S programs and procedures. Training will include aspects on E&S permitting requirements, H&S impacts, E&S management of contractors, and stakeholder engagement. All E&S teams will receive training on the application of the E&S screening, assessment and management procedures to meet compliance with IFC’s PSs for site screening and selection, project design and developments, construction and O&M management (ESAP Action No.9).

Monitoring and Review

Measuring E&S performance is a key core activity for DB. The company has developed high level KPIs (i.e., DEI, energy consumption, GHG emissions, workplace H&S, whistleblower program), it requires its companies to provide input on their metrics and submits them for discussion to the Board of Directors. To meet IFC PS requirements, DB will develop standardized KPIs to track E&S performance of its operations as per applicable PS requirements including aspects such as contractor oversight and status of implementation of E&S procedures and systems (ESAP Action No. 10).

Furthermore, DB requires its operations to have in place a procedure to ensure that all material ESG issues are reported to the portfolio company Board of Directors within 48 hours (i.e., sexual harassment, an accident that causes the death or serious injury of employees/contractors, furloughs, regulatory investigations, lawsuits, etc.).

To date, neither Highline nor EdgePoint have a formal procedure to undertake monitoring and review of E&S performance of both its own personnel, and those of their contractors and sub-contractors engaged in construction and maintaining the towers in Brazil, Malaysia, and Indonesia. There are periodic random inspections both during construction and O&M activities as part of the process to monitor and evaluate contractor performance. The management and monitoring of contractors and sub-contractors is a key aspect of E&S performance across these companies’ portfolio, particularly given that tower construction and O&M is largely outsourced. Similarly, AIMS does not yet have a centralized and consolidated management and review procedure to facilitate monitoring and review of E&S and OHS performance of its own personnel and those of their contractors engaged in construction and O&M activities. As part of contractor management procedures (see PS2 below), Scala, Highline, EdgePoint and AIMS will undertake to develop a monitoring scheme to oversee contractor E&S performance during construction and O&M operations as well as implementing an appropriate monitoring and reporting program, including periodicity of monitoring, and identification of roles and responsibilities.

Human Resources Policies and Procedures

DB has a corporate Human Resource (HR) policy, procedures, and a Code of Conduct that sets out the company’s terms and conditions to meet national labor law requirements as well as corporate principles of safety, integrity, sustainability, and respect. The HR policy makes explicit reference to equal opportunity employment, recruitment, employee conduct, employment regulations, salaries, disciplinary code, training and performance management. The Code of Conduct provides guidance to all employees on dealings with stakeholders and communication; conflicts of interest; safety, health, environment, and quality; human rights; community and public relations; among other aspects. All employees undergo training on the Code of Conduct and are expected to comply with the standards laid out in the code.  Furthermore, DB has Anti-Sexual Harassment and Whistleblower procedures in place. The Whistleblower procedure addresses offences, violation/non-compliance of company’s policies/procedures; health and safety risks; and unprofessional and inappropriate actions. DB has made a core aspect to implement Diversity, Equity, and Inclusion (DEI) at all its operations and each operation has its specific human resources department lead by qualified experts. DB also requires its companies conduct human resources compliance reviews and/or audits with outside resources to ensure compliance with all relevant local labor regulations. As DB’s HR practices are yet to be applied consistently to their contractors, Scala, Highline, EdgePoint and AIMS will include relevant provisions in their Contractor Management Plans that bind their contractors to comply with relevant local labor regulations and applicable IFC PSs (ESAP Action No. 11).

DB’s HR policy is aligned with IFC PS2 requirements to not use child or forced labor; to meet local minimum employment age requirements and to establish worker conditions (compensation, benefits, etc.) and rights to freedom of association, collective bargaining, and grievance mechanisms. The company hires local workers and has no migrant workers or worker accommodation. 

Working Conditions and Terms of Employment

As of Q2 2021, DB currently has a worldwide operation with 110 direct employees (65% men and 35% women). Scala has262 employees, including statutory directors and interns (78% men and 22% women). Highline has 84 employees, out of which 80 are direct hires and 4 are contractors who focus on acquisitions and licensing, construction and corrective and preventive maintenance. EdgePoint has 430 employees and in both countries of current operation has an approximate employment ratio of 35 female/65 male. DB prioritizes the use of local and regional labor forces for its own and contracting activities. In accordance with specific countries labor legislation, Scala, Highline and EdgePoint comply with requirements related to minimum wage, benefits, working hours, shift times and overtime payment.

Under the Diversity, Equity and Inclusion (DEI) initiatives, DB ensures that it hires people from all backgrounds and requires all portfolio companies to have a diversity and inclusion program with policies and procedures to ensure a diverse and inclusive workplace. In 2020, DB established a cross-functional, 15-member DEI Steering Committee, reporting directly to the CEO.

Scala and Highline have codes of conduct that define workers responsibilities with their colleagues and clients, address diversity and inclusion, sexual / work harassment, and state disciplinary measures to be applied to all employees. In 2020, Scala was awarded as a “Great Place to Work Brazil”, placing the company among those companies that offer their employees a fair and satisfactory working environment.

Although the appraisal found no evidence of non-compliance with PS2 with either its own or contractors’ employees, Highline and Scala will expand their contractor management procedures to include relevant IFC PS 2 labor provisions (i.e., freedom of association, no child/forced labor, grievance mechanism, etc.) of their contractor’s workers. Even though, EdgePoint currently confirms no use of child labor by its contractors and requires them to sign the company’s code of conduct, it will include these aspects as part of their Contractor Management Procedure (ESAP Action No.11). 

AIMS HR policies and procedures are presently embedded within that of its previous holding company and defined by the relevant local labor regulations within the geographies is presently operates. AIMS will therefore update its HR policies to ensure full alignment with PS2 (ESAP Action No. 12). Performance of contractors during new facility development is managed primarily contractually through assigned project and development managers with the aim of ensuring compliance with national laws. As with Highline, Scala and Edgepoint, AIMS will develop and implement and Contractor Management Procedure (ESAP Action No. 13).

Gender

DB is committed to increase the number of women across its operations. Through enhanced hiring practices, DB have more than tripled the percentage of women in its investment team over the past three years. Highline has a balanced 50-50 distribution between men and women, Scala has a proportion of 78-22, EdgePoint has a proportion of 65-35 and AIMS a proportion of 70-30.

Workers Engaged by Third Parties

DB operations rely on contractors for construction and O&M activities.  Each of Scala, Highline, and EdgePoint has a contractor selection criteria checklist to screen suitable contractors to comply with E&S requirements prior to being selected. AIMS drives this process through its existing supplier OHS management procedure. Scala, Highline, EdgePoint and AIMS will endeavor to upgrade their contractor screening checklists to also include compliance with the IFC PS2 requirements. Once selected, contractors will be required to sign the company’s Code of Conduct and E&S policies and procedures. Furthermore, contractors who do not meet basic EHS/HR standards will be removed from the list of service providers.

Even though each operation has general E&S practices; they do not have a systematic approach to oversee contractor E&S performance. Therefore, Scala, Highline,  EdgePoint and AIMS will develop or improve, as applicable, a comprehensive E&S contractor management procedure to define and establish the contractual requirements to comply with the company E&S policies and procedures, including compliance with local labor laws related to non-discrimination, compensation, training, timely payment of salaries, child and forced labor, occupational health and safety, as well as, contractual legal E&S requirements during construction and O&M activities, oversight procedures for contractor E&S performance, and actions to be taken when contractors are found out of compliance. Scala, Highline, and EdgePoint will undertake to select their contractors following rigorous vetting of past E&S performance and current qualifications and will contractually require that provisions of their ESMSs be included in the agreed contracts. 

Scala, Highline, EdgePoint and AIMS will undertake to develop their Contractor Management Plans incorporating a standardized Terms of Reference to include details on: (i) minimum E&S requirements in line with the IFC Performance Standards (i.e., mandatory competency building trainings etc.), (ii) provisions of their ESMS be included in the agreed contracts, (iii) E&S pre-qualification criteria and process, (iv) systems for communicating E&S expectations to contractors, (v) E&S audit process and frequency, (vi) requirements and process for E&S risk assessment prior to work commencement, (vii) E&S monitoring and reporting (including performance indicators) and frequency, (viii) provision for no use of child or forced labor; (ix) requirements and provisions regarding working conditions and compliance with labor host country law; and (x) emission and waste management and pesticide use (ESAP Action No. 11).

Aside from security providers, AIMS directly engages all employees and does not utilize the services of any outsourcing providers, however, this approach may change as part of the overall expansion programs and entry into new markets in the region. The HR policies and procedures (ESAP Action No. 12) will need to capture the protections that will be afforded to all workers engaged by third parties.

Grievance Redress Mechanism (GRM)

DB has in place a Whistleblower procedure that is required to be deployed to all its operations. A hotline is in place for all stakeholders to report concerns and all call logs are provided to the Board of Directors. Currently, Scala and Highline both have developed a whistleblower hotline. In Indonesia, EdgePoint has a whistleblower hotline in place that came from Centratama and it is currently working towards expanding it to the entire company. AIMS has adopted a formal employee grievance mechanism and an established whistleblower policy, both of which have been developed to meet Malaysian regulatory requirements.

As currently set, the GRM does not include procedures for easy access by workers and contractors and definition of the resolution process and final outcomes. Scala, Highline, and EdgePoint will enhance their grievance mechanism to develop a procedure for (i) filing claims/ grievances, (ii) receipt and recording of claims/ grievances, (iii) evaluation of claims/ grievances, (iv) guidelines for rejection, (v) receipt and recording of suggestions, (vi) evaluation and implementation of suggestions, if applicable, (vii) distribution of grievance mechanism, and (viii) procedure for escalation of grievances lodged with third parties, feedback/ outcome of the grievance to the complainant and timeframe for investigation and response (ESAP Action No. 14).

Occupational Health and Safety (OHS)

Scala has adequate procedures to assess and monitor OHS aspects associated with its operations, including an emergency response plan, life, fire and safety measures, safety training, incidents management, among others. Highline includes legal contract provisions for its contractors related to OHS responsibilities such as the use of adequate personal protective equipment (PPE), and worker training certificates required for working at heights. However, it is not evident how Highline oversees their contractors to prevent or to correct life-threatening workplace situations. As EdgePoint is currently developing their EHS procedures, the specific H&S requirements for contractors will be reflected in their contractors’ management procedure.  AIMS has an OHS policy which is supplemented by procedures developed to reflect fundamental best practice and Malaysian regulatory compliance requirements. Scala, Highline, EdgePoint and AIMS will develop or upgrade to develop OHS procedures for their operations and to ensure oversight of their contractors during construction and O&M (ESAP Action No. 15).

COVID-19 Response

As a result of the COVID-19 pandemic neither DB nor Scala, Highline or EdgePoint have laid-off workers but have made temporary adjustments to its workforce by adapting to both national and local labor laws. DB as well as Scala, Highline and EdgePoint have paid full salaries to employees during the lockdown period. Furthermore, DB and its portfolio companies are implementing a COVID-19 infection prevention, control and response plan, which is consistent with the provisions under PS2, PS4, and the Interim Advice for IFC Clients on Preventing and Managing Health Risks of COVID-19 in the Workplace.

Resource Efficiency

Aligned with DB policy on resource efficiency, Scala has implemented procedures to optimize use of energy and water. Specifically, it relies 100% on renewable energy to satisfy all its energy needs and has effective systems to reduce and track water consumption with specific KPIs at all its data centers. Pursuing this objective, Scala obtained a Carbon Neutral certification issued by Natural Capital Partners.

Highline, aligned with DB’s commitment to zero greenhouse gas emissions by 2030, is installing photovoltaic solar panels to provide the minimum needed energy by the towers’ users. Furthermore, in June 2021, the company was awarded the eco-label Selo Verde (Green Seal). Highline was chosen among companies that exhibit sustainable practices resulting from surveys and consults with local and national environmental authorities.  AIMS has a waste management protocol, however needs to define procedures to optimize the use of energy and water that meet the KPI’s and resource efficiency policy requirements of DB. These will be captured within the ESMS.

GHG Emissions

It is anticipated that Scala, Highline, and EdgePoint operations will be below the 25,000 tons per year which is the established IFC threshold for period reporting on GHG emissions. DB will report on GHG emissions of the project.  In relation to AIMS, given the overall planned capacity of 38MW it is estimate that Scope 2 emissions may reach up to xxt/CO2-e annually. The ESMS will therefore capture a requirement for Scope 1 and Scope 2 emissions to be monitored and energy management programs to be designed and implemented at corporate and facility levels.

Pollution Prevention

Neither the Scala data centers nor Highline and EdgePoint towers operations generate air emissions. Both Scala and AIMS have diesel backup generators. The fuel storage tanks for Scala have the needed safety measures to prevent the likelihood of spills (double containment, enough volume capacity to absorb full discharge), while AIMS is in the process of ongoing and upgrades to ensure that the appropriate safety measures are in place. Scala and AIMS only generates domestic wastewater and discharges to the sewage municipal systems. Neither Highline nor EdgePoint generate wastewater during its operations. Scala has procedures for the collection/storage/final disposal of hazardous and non-hazardous wastes. AIMS has procedures to also cover domestic waste and is in the process of developing longer-term e-waste management procedures, with other sources of emission being those associated with construction and expansion activities such as noise, surface water, and management of hazardous and non-hazardous waste streams. AIMS will establish requirements for management of all potential pollution sources during construction and O&M phases. Highline and EdgePoint currently require their contractors to meet relevant E&S local laws. As part of their ESMSs (ESAP Action No. 3 and 4) and their contractor management procedures (ESAP Action No. 11), Highline and EdgePoint will establish criteria and measures for the required setback distances from residences (including electromagnetic field (EMF) monitoring and management), and the required handling of emissions (including noise), fuel (including storage for standby generators) and wastes generated by their contractors in the respective contractor management plans aligned with IFC Performance Standard 3 and EHS Guidelines requirements.

Scala nor AIMS not use or manage pesticide for its operations. Highline and EdgePoint do not use and manage pesticide, but it will include E&S legal provisions in contracts with the O&M contractors that do the maintenance of green areas around towers (ESAP Action No. 11).

Community Safety

To protect communities from entering the tower area, Highline and EdgePoint identify whether the acquired towers are fenced and have locks. As there have been recent acquisitions, both companies are currently completing the implementation of this safety measure. Highline anticipates having all its towers fenced and locked by the end of 2023, and EdgePoint anticipates that this will be done for its Indonesia and Malaysia towers by the end of 2022. Site screening and selection criteria and setback distance criteria (for EMF exposure management and monitoring and for infrastructure and equipment safety) will be defined as part of the upgrade of the ESMSs, under ESAP actions No. 3, 4 and 6.

Prior to conducting any construction, AIMS conducts and evaluation of measures required to limit public access to active construction zones and conveys any requirements to its selected contractor. During operations, AIMS works with security providers to ensure that unauthorized access to these sites by members of the community is eliminated. These procedures will be incorporated into the risk and impact identification and management provisions in the required ESMS (ESAP Action No. 5).

Security Personnel  

Scala hires non-armed security services with specialized companies for its sites. Scala will undertake to develop a security management protocol addressing the vetting process for the selection of security firms and their personnel to be installed at their worksite locations as well as the training scheme including human rights and appropriate conduct towards data center users and potential interactions with nearby communities (ESAP Action No. 16). Highline does not hire security personnel for either its administrative offices or for any of their tower sites, however they will undertake to ensure security and safety features such as CCVs and alarm equipment. In Indonesia, EdgePoint appoints security personnel for office security. The security arrangements for AIMS include both members of auxiliary police and registered private security. A Security Management Protocol will be developed in line with IFC PS4, addressing the vetting process for the selection of security firms and their personnel to be installed at worksite locations, how it collaborates with auxiliary police, and the training scheme capturing human rights and appropriate conduct towards data centre users and nearby communities (ESAP Action No. 16).

 DB will undertake to develop a Stakeholder Engagement Procedure, requiring Scala, Highline, EdgePoint and AIMS to develop their Stakeholder Engagement Plan (SEP), applicable to new project developments and to O&M of their assets, including a process for i) stakeholder identification, analysis and planning; ii) disclosure and dissemination of information; (iii) development of a community grievance redress mechanism (GRM)’ and iv) ongoing reporting to affected communities, aligned with IFC’s PS1 requirements (ESAP Action No. 17).                                      

 DCP Fund Adviser, LLC

Kevin Smithen

Chief Commercial and Strategy Officer

750 Park Of Commerce Drive, Suite 210
Boca Raton, FL 33487, USA

Tel: 561-570-4644

Email: Kevin.Smithen@digitalbridge.com

Website: https://www.digitalbridge.com

Scala

Christiana Weisshuhn

Strategy & Marketing Executive Director

Alameda Tocantins, 350 16 andar

Barueri, SP, 06455-020, Brazil

Tel: 5511 98257 5687

Email: christiana.weisshuhn@scaladatacenters.com

Highline

Elys Koga

Operacions – PMO

Av. Nove de Julho 5229 – 4 andar

CEP: 01407-200 SP, Brazil

Tel: 5511 3192 5272

Cel: 5511 98209 3662

Email: elys.koga@highline.com.br

Web Address: highline.com.br

EdgePoint Infrastructure Sdn. Bhd.

Chee Wi Lyn

VP, Corporate Services & Program Management

60-1 Jalan Delima 19/KS9, Bandar Parklands, 41200 Klang, Selangor, Malaysia

lyn@edgepointinfra.com

https://edgepointinfra.com/                                    

AIMS Data Centre

Stanley Leong

AIMS Data Centre (Holding) Sdn. Bhd

Menara AIMS, Bukit Ceylon, 50200, Kuala Lumpur, Malaysia

Tel: +60 12 421 9329

Email: stanley.leong@aims.com.my

Web Address: http://aims.com.my