IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Kacific’s current E&S procedures are aimed at meeting the E&S legal requirements of each host country of operation.
An Initial Environmental Examination Report including E&S compliance audit conducted by an independent third party in 2019, before the launch of the satellite, refenced IFC’s PSs standard and did not identify any high-risk E&S non-compliances, but it did identify corrective actions that were implemented by Kacific in late 2019, such as the implementation of site-specific E&S management plans (ESMPs) tailored to each teleport location. Kacific conducts annual internal monitoring to evaluate the ESMPs’ implementation performances, including accident and incidents occurrences and rates.
The company’s emergency preparedness and response (EPR) approach are to follow the office building operators’ EPR plan and participating in the emergency drills. The responsibility of implementing EPR procedures at teleport sites lies with Kacific’s partners who are operating the sites.
Moving forward, Kacific will develop a corporate E&S Policy and Management System (ESMS) in line with IFC’s PSs requirements (ESAP#1).
PS2: Labor and Working Conditions
Kacific has a total of 75 employees among which 54 (60%) are based in Singapore, 9 in Philippine, 4 in Australia, and 7 in Indonesia. Additionally, there are about 600 individual direct sales agents contracted at commission-based term.
Kacific’s HR policies and procedures are tailored to follow each host country legal labor requirements in terms of working hours, wage, overtime payment and paid leave and social benefits. Kacific has developed a code of conduct which applies to all its employees and consultants and sales agents. This code of conduct requires the employee to behave in a socially responsible manner and maintain the highest standards of ethics and integrity when representing Kacific and dealing with Kacific’s customers, suppliers, other members of staff and competitors, covered the areas such as nondiscrimination, no harassment, anti-money laundry, anti-bribery, protection of intellectual property, protection of privacy, etc. The HR policies, procedures and the Code of Conduct are easily accessible to employees.
Kacific has developed employment contract template which adheres to host country local labor laws and defines the key employment terms and conditions including the job description, duration of employment, working hours, overtime, salary and allowances, leave entitlements, welfare, probation and notice periods, social responsibility and business ethics. Though company’s employees are not unionized, the company respects freedom of association. Employees can raise their grievances through the company’s intranet, face-to-face meeting, or by talking to HR department and/or management directly.
Kacific developed formal policy statement in the code of conduct to prohibit discriminate on any grounds, including race, religion, gender, nationality, age or disability, and no engage in any form of harassment. Contractors are required to strictly follow the national labor law and hire only employees older than 18 years of age. The ESMP for each teleport site includes measure for age and forced labor screening.
Moving forward, Kacific will update its HR Policy in line with IFC PS2 to include policies and procedures on freedom of association, workers’ grievance mechanism (WGM), workplace anti-Gender Base Violence and Harassment (GBVH); and prohibition of child and/or forced labor in its partners and supply chain (ESAP #2). The WGM will include steps to be taken by workers to manifest any concerns, engage in a mediation process, contact responsible persons, and provide timely feedback. The company will also reinforce the policy of confidentiality and non-retribution, along with ability to raise anonymous grievance.
Site-specific EMPs cover OHS aspects including hazard identification and risk assessment in the project. training, and the use of personal protective equipment (PPE). All employees undergo health checks required by national legislations and industrial practices. Regular OHS trainings including security, safety and emergency situations will be conducted to all workers. The franchisers appoint an experienced engineer to oversee the OHS practices of a site they operate. The engineer is also responsible for providing training to site-based workers, maintaining OHS statistics, investigating accidents, and ensuring corrective actions are implemented. Periodic reports will be compiled at project site, and incident investigation and reporting procedures are followed. Kacific management reported that no lose time injuries occurred in the past 3 years since the teleports operate in 2019.
PS3: Resource Efficiency and Pollution Prevention
Electricity is sourced from the national public grid and diesel fueled generator as a backup. Electricity consumption for the teleport operations is limited. The company committed to energy efficiency by: (a) infrastructure-sharing schemes, with all 5 teleports established on shared-sites owned by other operators; (b) operational optimization through conversion and retrofitting of equipment; (c) sharing the use two-sized back-up diesel generators (a 1400kw generator and a 400kw generator) to meet the changing needs and minimize the site fuel consumption; and d) increase the use solar power and other forms of renewable energy wherever feasible. GHG emissions are expected to be less than 25,000 tons of CO2- equivalent annually. The water supply for the offices is from the piped municipal supply. The drinking water for employees and guests is bottled water purchased locally.
The most significant volume of hazardous material stored on-site was diesel for the back-up generators. Underground storage tank and steel tank above ground with secondary containment. Teleport sites produces limited volume of waste. Waste Management plans are developed as a part of the ESMPs, which contain detailed specific measures to manage pollution and wastes. The primary sources of air emissions are from back-back generator which have been tested regular with results met the local emission limits, which is also in line with WB HS parameters.
All sites have installed a fire alarm system that incorporates smoke alarms, heat detectors and fire alarm bells and manual alarm points, inspected and tested on an annual basis by a third party. Fire extinguishers are installed around the facility and are reportedly routinely inspected.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Kacific operates teleports in Philippines, Indonesia and Australia which are located within existing facilities and have small footprints. However, the Kacific Subic Bayone site in the Philippines is located within the Subic Bay Forest Reserve. which is adjacent to the Bataan Natural Park and are within a Key Biodiversity Area (KBA) but it has minimal ongoing impact KBA. In any case, as required by IFC PS6, the KBA secretariat and the management of the Subic Bay Forest Reserve will be required to consult to understand if there are any ongoing risks and conservation needs of the KBA, which should be implemented through a Biodiversity Action Plan (ESAP #3).
