Considering the nature of proposed business operations and project activities, and based on IFC’s review during project appraisal, there are no risks or anticipated impacts associated with the requirements of PS 5 (Land Acquisition and Involuntary Resettlement) and PS 8 (Cultural Heritage) for this project.  In relation to PS5, it is noted that the company secures lands for its operations based on voluntary land transactions. In any case, as part of the ESAP the company will be required to develop policies and procedures to screen for E&S risks and impacts, and where such risks and impacts are identified, mitigate them consistent with all the PSs as summarized under the PS1 section below.      

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, as it is expected to have adverse E&S risks and/ or impacts that are limited in scale, few in number, generally site-specific and readily addressed through mitigation measures, by adhering to good international industry practice (GIIP) procedures, guidelines and design criteria, as described in the following sections. Key risks and impacts include the company’s capacity and systems to screen and assess the sites for E&S risks and impacts, and to review and manage E&S performance; management and mitigation of impacts during construction (including emissions to air, greenhouse gases, and noise); labor and working conditions; occupational and community health and safety, during construction and O&M, including risks associated with road traffic and monitoring of electric and magnetic fields (EMF) during operations; and waste and hazardous material management.                      

Environmental and Social Assessment and Management System: The EPC and O&M services for the towers being developed by CREI Phils will be undertaken by iEngineering, which has developed an integrated management system (IMS) to provide the EPC and O&M services in line with GIIP on Quality, Environment, Health and Safety. iEngineering’s management system(s) are certified for: ISO 14001:2015 (Environment Management Systems), ISO 9001:2015 (Quality Management Systems), ISO 45001:2018 (occupational health and safety (OH&S) management system), ISO 22301:2019 (Business Continuity Management system). The scope of certification currently does not include Philippine operations, with the intention this will occur in 2022. CREI will leverage iEngineering’s E&S frameworks, policies, and procedures until they develop their own ESMS specific for the project.

iEngineering’s IMS establishes an overarching policy defining the EHS objectives and principles that guide projects to achieve robust performance. The policy is endorsed by senior management and is actively communicated to employees at all levels and functions. Particularly, it highlights its commitment to the national environment and OH&S regulations and to implement GIIP. The company’s ESMS that will be developed by CREI will use the procedures and policies adopted by iEngineering as the base and contextualize them to the operations and aligning with PS1 and national requirements (ESAP Action No 1)

Identification of Risks and Impacts: IFC use of proceeds will be used to develop greenfield facilities, with the locations of many of these towers yet to be defined. Lands where the sites are built are leased by CREI Phils from individual owners on willing lessee / willing lessor basis. Currently, the site selection process is based around securing sites within the approved Nominal Points required by the MNO. E&S considerations consistent with IFC PS are currently not specifically integrated in the site selection process, with the company noting that key considerations in addition to the MNO requirements being: (i) proximity to power lines and power sources, (ii) can be accessed through a legal right of way, (iii) site sufficient to accommodate the tower and associated infrastructure, (iv) social acceptability, and (v) authenticity of all legal documents pertaining to the identified property. To align and meet the requirements of IFC’s PSs, CREI, as part of its ESMS, will develop an E&S Screening Procedures to screen the tower sites and identify E&S risks during the site selection process (ESAP Action No 02). The criteria for the E&S screening will be based on the mitigation hierarchy and will include criteria related to PS5 (demonstrating that all land acquisition has been undertaken on a willing-buyer willing seller negotiated settlement basis and thus avoiding any involuntary resettlement), PS6 (avoidance of overlap or impacts to natural and critical habitats; legally protected areas and internationally recognized sites, including not constructing towers in World Heritage Sites or Alliance for Zero Extinction Sites); and PS7 (potential impacts on indigenous peoples lands) and PS8 (avoidance / minimization of impacts on cultural heritage).

Risk/hazard assessment procedures and the implementation of necessary control measures are adequately defined in the management systems of iEngineering. CREI will expand upon the risk/hazard assessments of iEngineering and prepare project specific E&S assessment register. For each risk identified, the company will define and implement appropriate mitigation measures in accordance with the mitigation hierarchy (ESAP Action No. 01).

Management Programs: The management plans to mitigate the identified E&S risks will be developed by CREI Phils, in coordination with iEngineering, and implemented by the local Quality, Health, Safety and Environment (QHSE) representatives of iEngineering, with the supervision of CREI Phils which will be responsible for compliance with IFC’s PSs. In addition, the QHSE representative will undertakes periodic audits to identify any non-conformities (NCs) on the EHS performance which are relayed to the iEngineering head office IMS representative. The corrective actions for the NCs are prepared by the iEngineering head office IMS representative and conveyed to the local QHSE representative for implementation. CREI’s ESMS will include provisions on the monitoring and review of the periodic audits and the implementation of corrective action. Annual independent audits of the EHS performance to provide independent assurances that the control measures, risk management, governance and procedures & policies are operating effectively is provisioned in the management systems and will be required under the CREI’s ESMS.

Organizational Capacity and Competency: iEngineering group’s IMS & Sustainability Department handles the IMS and sustainability audits across all entities and the department has four employees. The key roles and responsibilities of iEngineering’s IMS & sustainability department capture elements such as audits of procedures and policies, efficiency improvements, monitoring of E&S indicators, developing procedures as part of management systems, controlling management system performance in local operations, and ensuring the management systems are periodically reviewed, maintained, and updated as required. CREI will appoint a qualified E&S manager to lead its E&S organization including designated QHSE Representatives in charge of conducting Management System Audits to ensure implementation of the ESMS requirements and compliance with IFC’s PSs (ESAP Action No. 03). The roles and responsibilities of QHSE representatives at CREI will include conducting internal audits, maintaining compliance with management system and client requirements, monitoring, and reporting E&S performance, and overseeing external auditing. The level of resourcing and organizational structure for Environmental, Health, and Safety (EHS) matters will be continually monitored throughout the project and reviewed as necessary. Currently, QHSE representative of iEngineering is also tasked with handling and responding to any grievances and questions from the community surrounding each tower location. To cater for the increased growth in the project operations, CREI will appoint a dedicated resource, reporting to the E&S manager, to oversee implementation of the Stakeholder Engagement Plan (SEP), grievance mechanism and social risk and impact identification and management processes, including liaising with the human resources team and procurement team to manage labor and working conditions in accordance with PS2 requirements (ESAP Action No. 04).

Emergency Preparedness and Response: The  iEngineering IMS includes functional emergency response plans aligned with IFC PS requirements, including identifying various emergency scenarios, 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. As part of ESAP Action No. 01, CREI will develop and implement its emergency preparedness and response procedure and plans to cover for company’s operations and maintenance activities. 

Monitoring and Review: Periodic management review meeting is undertaken to review and evaluate the effectiveness of the IMS by iEngineering. The periodic review also ensures that all levels of management are made aware of any changes, updates, revisions, etc. A similar approach will be implemented by the company and periodic review will be extended to CREI’s ESMS. Periodic training of the employees is undertaken under a training plan which includes (a) EHS training as part of the orientation of the new employees, on safe work practices, EHS policy and procedures, usage of safety equipment and Personal Protective Equipment (PPEs), etc.; (b) code of ethics; and (c) any other trainings on the basis of learning needs identified by the direct supervisor of the employee. There are external trainings also scheduled as needed. As part of ESAP Action No. 01, CREI will develop and implement a similar training plan for its direct workers and for contracted workers.

iEngineering evaluates their sub-contractors on ESG criteria in addition to technical and financial criteria. In addition, as part of the iEngineering’s ISO 14001:2015 certification, third-party auditors also review supplier documentation to assess supply chain EHS requirements. iEngineering also has QHSE requirements included in the agreements with its subcontractors. As part of ESAP Action No. 01, CREI will develop and implement similar requirements, aligned with IFC’s PSs, to be included in its contractor contractual agreements.       

iEngineering has expressed their commitment to comply with the national labor regulations and other legal requirements, as stated in the IMS policy. This includes the 38 International Labor Organisation Conventions that have been ratified by the Philippines and therefore embedded within the national labor codes. The policies developed by CREI as part of ESAP Action No. 1 will underline the company’s commitment to comply with national labor regulations and IFC’s PS, including PS2 on Labor and Working Conditions.

Human Resources Policies and Procedures: iEngineering has a set of formal human resources (HR) policies and procedures that define recruitment (including the principle of equal opportunities), onboarding, paid and unpaid leave, employee welfare, training and employee education, and termination. 

Policies and procedures on child labor, anti-discrimination, no forced labor, freedom of association and collective bargaining, retrenchment, internal grievance system, and prevention and mitigation of COVID-19 at the workplace will be developed for CREI Phils operations (ESAP Action No. 05). This will also include the development and adoption of an employee code of conduct outlining employees' rights and obligations and working conditions, including management of sexual harassment and gender-based violence. 

 Grievance Mechanism: iEngineering has developed and implemented an employee's satisfaction survey system to determine employees' basic needs and concerns. CREI will develop policy and procedures to implement an effective workers grievance mechanism for its employees, contractors, sub-contractors, as required under IFC’s PS2 (ESAP Action No. 05).

Occupational Health and Safety: CREI’s QHSE department manage Occupational Health and Safety (OHS) risks and verifies the performance of contractors. As indicated, construction, operation and maintenance of the assets will be contracted to iEngineering-Philippines. This company will set up an additional QHSE organization consisting of staff members. Both CREI and iEngineering are currently setting up an OHS management system to manage and mitigate project-specific risks. This system is based on iEngineering’s OHS management system that has been implemented and certified against the ISO 45001 standard in all their operations around the world. The group’s OHS management system consists of: i) an OHS policy on group level; ii) a suit of procedures to manage high risk activities including lifting, working at height, working with electricity, lock out / tag out, journey management, hot work, chemical management and use of PPE; iii) procedures to select and evaluate subcontractors; and, iv) forms and instructions to collect, record and or analyze critical OHS data including information on incident investigations, emergency response training, toolbox talks, work permits, and vehicle inspections. Due to the recent startup of CREI’s activities, these OHS management systems have not been fully implemented by the company; however, CREI has indicated its intention to prepare company specific OHS Management system (ESAP Action No. 01).

Workers Engaged by Third Parties: CREI contracts tower construction and their operation and maintenance work to iEngineering who in turn further employs various sub-contractors. In compliance with the Contractor Management procedures IMS, iEngineering will only engage with contractors registered on the list of approved suppliers that can demonstrate their competence, knowledge, and qualifications for QHSE requirements.

iEngineering’s designated team leader and QHSE representatives will review, assess conformance, monitor, and train contractors on QHSE requirements and compliance with labor requirements as per PS2 and national legislations before work commences and during the duration of the contract. Sub-contractors shall ensure their commitment to conform with the QHSE requirements, including reporting all accidents and incidents immediately to iEngineering and participating in site inspection.

The company recognizes the need to manage labor and OHS risks associated with the use of day labor by sub-contractors to perform non-skilled tasks during tower construction. These risks include utilization of underage labor, withholding of all or part of salaries, requiring payment for PPE and non-conformance with EHS requirements, among others. To counter this, CREI will ensure and monitor the implementation of iEngineering’s contractor management plan which will include inspections, audits and trainings of subcontractors with respect to the engagement of contracted workers and day laborers and compliance with PS2 requirements (ESAP Action No. 06).                    

Resource Efficiency: The project carbon footprint covers emissions from grid electricity consumption and fuel consumption from vehicular movements associated with the O&M activities and from other sources, including any onsite generators at the tower sites. To address the carbon footprint of the value chain from the beginning of operations, the company engages with suppliers in sustainability initiatives. Internal audits, external certifications under ISO and external disclosures to EcoVadis annually are undertaken. Going forward the company will publish greenhouse gas (GHG) emissions as part of annual sustainability reports. Based on the forecast of annual electricity consumption for all the towers subsumed under the proposed investment, the GHG emissions are expected to be 28,536 tCO2e/annum.

Pollution Prevention: The impacts to physical environment are limited during the construction phase and can be avoided through adopting Standard Operating Procedures (SOP’s) that will be developed by company as part of action plans to manage the E&S impacts under the ESMS developed as indicated in ESAP Action No. 01. The IMS of iEngineering has procedure to control the generation, treatment, storage, transportation, and disposal of industrial waste. CREI’s ESMS will include procedure of waste management for Philippines operations by referencing to “Republic Act 6969: Toxic Substances and Hazardous and Nuclear Waste Control Act of 1990” and in compliance with IFC’s PS3, aligned with the relevant and applicable sections of the WBG EHS Guidelines (ESAP No. 01). As part of the iEngineering IMS, a fuel leakage procedure is included to manage fuel storage and handling and mitigate any leakage from onsite generators, fuel tanks, fuel pipes, during refueling activities and provided secondary containment for storage tanks and onsite generators. CREI will extend this procedure for its business operations and will also include a requirement for secondary containment to contain fuel spills and leakage at the tower sites, and a process for assessment of any contamination in case of fuel leakage or spills and procedures for cleanup.                      

Community Health and Safety: CREI will incorporate appropriate fencing, locking and other design measures in all towers to ensure that communities are protected and prevented from entering tower areas where risks to community health and safety will be highest. The long-term maintenance of the integrity of fences and locking mechanisms will be included as part of the QHSE checks on operational assets. Site screening, selection criteria and setback distance criteria (for aspects such as control and monitoring 0f electric and magnetic fields (EMF) exposure, constructability and infrastructure and equipment safety) will be integrated as part of the ESMS to ensure prevention and mitigation of community health and safety risks, during site selection, construction, and operations of each tower.  To mitigate the risk from EMF exposure, CREI will develop procedures as part of ESMS for (a) evaluating potential exposure to the public against the reference levels developed by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) while finalizing the site selection; (b) limiting public access to tower locations; (c) following good engineering practice in the siting and installation of directional links (e.g. microwave links), to avoid building structures; and (d) taking into account public perception about EMF issues by consulting with the local community during the siting process of the telecom towers (ESAP No. 01).

Infrastructure and Equipment Design and Safety: All CREI’s towers will be new installations and will be designed according to relevant engineering design standards, with the required safety criteria to prevent risks associated with structural failures and meet good international industry practice. The engineering department is tasked with carrying out technical feasibility analysis which includes assessments of structural stability and engineering requirements. Company’s ESMS will require review of the technical feasibility analysis undertaken by iEngineering to ensure that the design accounts for structural stability and engineering designs in line with GIIP and specifically addresses natural hazards identified as potentially affecting the site as part of ESAP Action No. 1.

A limited number of seven rooftop towers will be developed as part of the project. Such towers require specific design and safety measures to be implemented to ensure their structural integrity, and the one of the associated dwelling/structure and to prevent access to potentially hazardous areas by eventual occupants of the dwelling. The company’s ESMS will require that relevant procedures for undertaking analysis of structural integrity and stability of rooftop towers, are implemented [ESAP Action No 1].

Emergency Preparedness and Response: The company is currently referring to iEngineering’s Emergency Preparedness Plan (ERP). This document covers only the direct company workforce and does not describe any measures for detailing how the local community is (i) able to contact the company in the event of an emergency such as fire or tower collapse occurring at a particular tower, (ii) how the company is to notify or involve the local community appropriately in aspects of emergency response, and (iii) the appropriate local authorities that will be involved in responding to specific emergencies such that emergency response effectiveness is maximized. The company will develop and implement a project ERP addressing the gaps identified during IFC’s review as part of ESAP Action No. 1.

Security Personnel: CREI has indicated that it does not intend to hire any armed or non-armed security services to guard operational tower sites, including within higher risk areas such as Mindanao which remains under martial law. However, in some settings, particularly within Mindanao, the company will engage security firms as part of the construction phase for towers. CREI will develop a corporate security management protocol addressing the screening process for the selection of security firms and their personnel, as well as training schemes and procedures focused on human rights, appropriate conduct towards CREI employees and potential interactions with the local community surrounding tower sites (ESAP Action No.07).             

Of the currently operating sites, six of the 30 sites are located within the Manila Bay Important Bird Area (IBA).  The IBA has been gazetted due to migratory shorebirds that winter in the coastal mudflats within Manila Bay and surrounds.  The IBA covers both coastal areas and the urban areas of Malolos and the northern suburban fringe of Manila.  The risks associated with the installation of the telecom towers within the IBA are considered minimal given the highly modified nature of the habitats. All operational sites are located in modified habitats consisting of urban areas or peri urban areas.  To comply with IFC PS6, the project will consult with BirdLife International Philippines representative to define any ongoing risks and define additional conservation management requirements, in the form of a Biodiversity Management Plan (BMP), for operating towers located within the Manila Bay IBA (ESAP Action No.08).

A screening of the 97 sites under construction indicated that 10 sites are located within IBAs; 9 sites within the Manila Bay IBA and one site is located within Mt. Apo Natural Park IBA (which is also a Protected Area).  As previously discussed, risks within the Manila Bay IBA are considered low due to the urban nature of the area.  The site located within the Mt Apo Natural Park IBA is located on the lower slopes of Mt Apo close to Davao City within modified habitats.  The IBA has high conservation values associated with endemic birds and flora, including the Philippine Eagle Pithecophaga jefferyi IUCN CR. Given that the tower is not located within natural habitats and is within the lower slopes of Mt Apo, it is considered low risk.  All sites screened are located along roads, adjacent to or within urban areas which are considered to be modified habitats.  Relevant measures to manage risks for potential new towers are to be standardized and included in the project ESMS [as per ESAP Action No 01]. For all sites being constructed within IBAs, consultation with BirdLife International and preparation of a BMP will be required (As per ESAP No. 08).

Screening of the remaining 491 sites still to be constructed identified approximately 52 sites located within KBAs, 26 within Protected Areas and   potentially 20 sites occurring in natural habitats.  The company will implement the relevant study to screen and assess the sites in order to apply the mitigation hierarchy to avoid potentially sensitive sites, including potential critical and natural habitats, in compliance with this PS [ESAP Action No.08] during site selection. As part of ESAP Action No. 2, the company will integrate such screening procedure in its ESMS.

Within the Philippines, approval of development in land owned or managed by Indigenous Peoples (IPs) and mechanisms to secure their free, prior, and informed consent (FPIC) are largely governed by the National Commission on Indigenous Peoples (NCIP) who issue and certify ancestral domains maps. NCIP is also responsible for issuing Certification of No Overlap (CNO) for any land uses that may be within proximity to these mapped ancestral domains. A CNO constitutes evidence that a site is not located within a mapped ancestral domain. CREI reported that local level authorities have not required CNOs to be secured for any of the over 120 sites for which approvals have already been granted.  As indicated, issuing a CNO is a responsibility of NCIP which sits at national government level and is not a matter for consideration in issuing environmental approvals. Investigation of the sites already operational or under construction has identified a total of 25 sites where there could be proximity to ancestral domains and further investigations are required to reconfirm that there are no direct impacts on IPs lands. CREI will evaluate these sites in consultation with NCIP to definitively exclude any impacts on IPs that would require applying PS7 provisions. In the event that an overlap is identified for any of the sites already constructed or under construction, this ESRS will be updated as needed and CREI will be required to ensure that such sites meet PS7 requirements Additionally, the screening procedure under ESAP Action No. 02 will require all future sites be checked against NCIP ancestral domains mapping to determine if a CNO or any additional actions in relation to PS7 compliance are necessary.       

Stakeholder engagement is actively undertaken during the site selection and procurement process whereby CREI undertakes consultation with the surrounding community to determine social acceptability of the proposed tower prior to committing to the site. Aside from this phase, there is no active stakeholder engagement, with the QHSE team tasked with engaging with stakeholders in the vicinity of towers and receiving and resolving grievances. CREI will develop a stakeholder engagement plan (SEP), to apply to the entire project, capturing site selection and acquisition, construction, and operations phases. This will include a process for (i) stakeholder identification, analysis, and planning, (ii) disclosure and dissemination of information, (iii) development of an effective community grievance mechanism, and (iv) ongoing reporting to affected communities and stakeholders, in a manner aligned with IFC PS1 requirements (ESAP Action 9).              

Contact Person: Khwaja Abdullah

Company Name: ieng Philippines

Address: Manila, Philippines

Email: kabdullah@ieng-group.com

Phone: +1 416 473 3528