For PS5 on Land Acquisition and Involuntary Resettlement, it is noted that the company secures lands for its operations based on voluntary land transactions with the landowners (e.g., rental agreements with the provision of rate revision every 2-3 years). Optical fiber network installation is done in the existing Right of Way (RoW) of the Road Development Authority (RDA), Provincial RDA, or local authorities in rural areas.

 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, 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 E&S aspects associated with this project include: (a) company's capacity to formulate and implement an integrated ESHS management system that meets IFC PS 1 requirements and GIIPs; (b) 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 and operation; (c) assurance of fair, safe and healthy working conditions including occupational health and safety (OHS) in compliance with IFC requirements; (d) community health, safety and security; and (e) stakeholder engagement and community grievance redress mechanism.  

 The company has an environmental policy (dated 31st July 2020) and an ESMS that were recently revised as part of the ISO 14001 certification on environmental management. Dialog has also adopted policies on H&S, HR, whistleblowing, data privacy, and Supplier Code of Conduct.  DNS, which is subsidiary providing key services to Dialog, follows the company’s corporate policies and ESMS provisions and guidelines.

Dialog ESMS’s is managed by the Quality Systems and Process Management Unit (QSPM) and responsibility for implementation is spread across multiple departments. The Sustainability Team handles aspects such as social innovation, digital inclusion, and product and service innovation; the Supply Chain Management (SCM) team is responsible for vendor and supplier (e.g., tower parts, network equipment, service contract for technical services, and manpower services etc.) ESHS screening and annual monitoring of their performance against the ESHS and labor conditions on the contracts; and there is also a Corporate H&S Team under Human Resources. The company has an Internal Audit Team helping ensure ESHS implementation across Dialog’s operations.

The company has a comprehensive reporting system as part of ISO 14001 and ISO 9001, the annual sustainability reporting process, and legal requirements. Additionally, the company conducts internal monitoring as part of ISO 14001 through a third party, and ESHS external monitoring is undertaken by a certification agency ensuring that all the assets (e.g., telecom towers) are monitored at least once annually. The H&S team at different office facilities undertake internal monitoring monthly as per the agreed checklist with the corporate H&S unit.

The company’s Board of Directors (BOD) has the responsibility of decision-making and oversight on sustainability issues (including economic, environmental and social impacts). The Board is briefed on sustainability performance-related matters by the Head of Group Sustainability. The Group Chief Executive and Group Chief Corporate and People Officer, along with other Chief Officers and Senior Management are directly engaged in seeking assurance and take part in management discussions as part of the Annual Sustainability Report Assurance process.

Quarterly presentations are conducted for the board to provide updates on the most recent achievements and challenges faced, from a sustainability viewpoint. The quarterly Board Audit Committee meets quarterly to review updates on possible risks/opportunities related to Sustainability Governance procedures and other sustainability performance related topics. Compliance forms the basis for all decisions and ensures the company’s actions remain sustainable.

The construction or extension of assets go through a process of identification and management of E&S risks and impacts, which is aligned with the regulatory requirements pertaining to telecommunication tower siting. This process includes obtaining clearance from the Telecommunications Regulatory Commission of Sri Lanka (TRCSL) and environmental protection license (EPL) from the Central Environmental Authority (CEA), alongside approvals from other relevant authorities including Urban Development Authority, Civil Aviation Authority, and Ministry of Defense. If the location of the tower falls within any environmentally protected areas or if any archaeological, aesthetic, cultural, social concerns, or national security issues are identified, the company must also obtain clearance from the relevant authorities.

DNS is responsible for site planning and selection, construction, and operations, and obtaining the required permits for which Dialog’s legal team provides support on a need basis. As per the agreed ESAP #1, the company will update the existing ESMS to include (a) a procedure to ensure that ESHS risks, including those associated with community health and safety, land acquisition, Indigenous People (IPs) and cultural heritage are identified and managed in line with IFC PS; (b) a screening method for new towers to avoid construction in areas of high biodiversity value(c) a contractor ESHS management procedure for construction and operations stage activities; (d) a land acquisition procedure in compliance with IFC PS 5 requirements; (e) a stakeholder engagement plan including a grievance redress procedure; and (f) a traffic safety procedure to manage risks during construction, operations, and maintenance (O&M).

Typical land requirement for the tower is limited to 50 m2 to 1500 m2 (recent towers require mostly around 50-100 m2) and the land transaction is voluntary (on rent through lease agreement or memorandum of understanding). The local authority approval (post TRCSL approval) for any asset development considers the land ownership status and consent from the landowner. For the upcoming 300-400 towers, in case Dialog choses to erect its own towers, it will use the E&S screening criteria (to be developed as part of proposed ESAP # 1) to avoid land impacting Indigenous Peoples lands; in case such lands cannot be avoided, the company will meet the requirements of PS7 on Indigenous Peoples.

The company has in place an emergency preparedness and response (EPR) framework developed as part of the H&S manual. The Corporate H&S team has detailed EPR procedures for each of the operations teams as per identified emergency risk and their implementation are monitored quarterly. Additionally, each of the offices (corporate, regional center, depots, service center, data center, landing station etc.) are supposed to have detailed EPR plans implemented at sites. The responsibility of implementing EPR procedures at tower sites currently lies with DNS’ O&S teams. The EPR for the towers does not currently include community-related aspects. The company workers have undertaken regular training on fire safety preparedness and response. As part of ESAP # 2, the company will update the EPR (a) to consolidate and review the procedures shared with multiple departments; and (b) to include community preparedness and response to any emergency situation including fire safety and structure safety. 

 As of March 2022, the company directly employs 3,089 people (777 female and 2,312 male). The company also has third party workers engaged through manpower agencies and service contracts of technical, security, and housekeeping services for their sites. There are a total of 1024 third party employees (821 male and 203 female), not including security guards, housekeeping, or canteen workers.

The company has HR policies and procedures principally aligned with Sri Lanka labor regulations, which follow the eight principles of the ILO core conventions that define workers' rights, obligations, and working conditions and are applied consistently across its subsidiaries. These policies and procedures cover key PS2 principles such as child labor, forced labor, non-discrimination, and equal opportunity. Concerning freedom of association, there is no trade union or collective bargaining agreement within the company; however, the company does not oppose workers' rights to establish/join trade unions and collective bargaining. Further, the company has set and implemented various channels to support robust workplace communication between management and employees including quarterly Townhall meetings, skip-level meetings, and whistle-blower mechanism. The company is a registered member of the Employer's Federation of Ceylon, advising harmonious industrial relations and better working conditions. The primary documents regulating labor-related issues include the Employee Code of Conduct and individual employment contracts or letters of appointment. The Code of Conduct outlines the company's commitment to ensure all employees carry out their duties and responsibilities to the highest personal and corporate integrity standards and within the framework of applicable laws and regulations. The Code prohibits, amongst others, any form of abuse and harassment, including sexual harassment and bullying. HR policies and procedures are communicated to all company employees during onboarding and posted in the company HR portal. The company has developed the Speak-Up Platform, which allows staff and third-party workers to report potential or alleged violations against the company's Code of Conduct and raise employment-related complaints.  The Speak-up Platform, developed, maintained, and operated by an external third party, provides various communication channels, including anonymous reporting. The company also has an internal grievance handling policy that outlines processes for its direct employees to voice concerns and lodge workplace-related grievances to seek redressal. As per ESAP # 3, the company will revise the existing internal grievance handling policy per IFC's PS2 to (a) clearly define the principles of anti-retaliation and identity protection; (b) include multiple grievance intake points to raise and address allegations anonymously if complainants prefer; and (c) address sexual harassment and gender-based violence grievances.

From 2018 to 2021, the company rolled out a staff optimization strategy that resulted in approximately 300 employees being made redundant, which represented around 2.5% of the workforce during that period. The company implemented the process in line with national regulations, in consultation with the employees and offered retrenched staff severance packages above the regulatory requirements. There is no evidence of open claims or court cases related to historical retrenchment. 

In relation to third party workers, the company ensures that the third parties who engage these workers are reputable and legitimate enterprises and have appropriate systems in place to manage working conditions in line with local regulations and the relevant aspects on PS2 including child and forced labor, non-discrimination, freedom of association, grievance mechanism, and OHS-

In relation to supply chains, the company has a Supplier Code of Conduct that covers labor and working conditions, including child and forced labor, freedom of association, and non-discrimination. Dialog uses a sourcing platform operated by the SCM team to screen vendors through physical site visits, meetings with their H&S representative, and review of their performance improvement If any gaps are identified vis a vis Dialog’s ESHS requirements, corrective actions are agreed with the vendors for addressing the issues before they can be considered for engagement. An annual audit of the vendors is undertaken, including of their labor-related performance. In addition, a review of the contract terms and implementation is done every quarter.

As per ESAP # 3, the company will review and update, as required, the existing HR policies and procedures to align them with IFC's PS2 requirements, including policies and procedures concerning freedom of association and collective bargaining, workers’ grievance mechanism, child labor, forced labor, non-discrimination, retrenchment policy, and workers’ accommodation (particularly during the construction stage).

Occupational Health & Safety (OHS) Management: The company has developed an OHS manual (updated in 2020). The manual includes Hazard Identification and Risk Assessment (HIRAs) procedures, H&S governance and implementation team, workplace accidents review, and reporting. In addition, the company has established H&S standard operating procedures (SOPs) to support a safe working environment. The operations, oversight, and review of performance improvement of OHS policies and procedures are the responsibility of the corporate H&S unit with the support of the sites H&S Committee, which consists of OHS-trained cross-functional representation from across the entire workforce. The corporate H&S Head performs quarterly internal OHS monitoring at all locations, excluding the operating towers as the management of towers is under the DNS’ emergency response team's responsibility. Fire, emergency, and basic first aid training is conducted every six months or annually, depending on the regional regulatory requirements. The company has had zero fatalities or high-consequence injuries over the last three years. As part of ESAP # 4, the company will update the H&S manual to include detailed HIRAs for all the construction and operations activities (at minimum for all of the company and DNS activities,  including mitigation measures, legal register, Standard Operating Procedures (SOPs) and associated formats for key hazards and risks (such as laser light exposure during optical fiber installation, electro-magnetic field (EMF) exposure during operation for workers and nearby communities, construction safety, etc.) and documentation formats. The H&S manual update will further include supporting documents related to training need assessment, Personal Protective Equipment (PPE) matrix for various activities, incident recording, and root cause analysis.

COVID-19 Management: The company has adopted procedures to minimize the risk of Covid-19 at the workplace, including training, testing, treatment centers, PPE supply for office and field employees, contact tracing, sanitation, and decontamination, quarantine supports, and home isolation package, etc. The Covid-19 procedures are continuously reviewed and updated per the latest Government guidelines and orders. Due to the pandemic, the Company has not and does not plan to lay off any staff. The Company shifted to a ‘Work From Home (WFH)’ operating model during the periods of lockdown imposed by the Government and health authorities (approximately five months, across two separate instances) to curb the spread of COVID-19. 

 As per Dialog’s GHG estimations (Sustainability report 2020), based on an internationally recognized methodology, its Scope1 emissions totaled to 5,074.03 tCO2e per annum, while Scope 2 emissions reached 103,876.96 tCO2e per annum. Dialog is currently in the process of synchronizing itself with the Axiata Group’s move to commit to a significant carbon footprint reduction as per the United Nations Science Based Targets initiative. The company has developed an action plan for energy efficiency management including the following initiatives: (a) infrastructure-sharing schemes, with 40 percent of its operations running on shared-sites owned by other operators; (b) operational optimization through conversion and retrofitting of equipment; (c) working with and imposing upon vendors' design efficiency and energy efficiency criteria for procurement of eco-friendly alternatives; (d) gradually shifting towards tower sites powered primarily by solar power and other forms of renewable energy; (e) procurement and integration of highly efficient transmission systems and hardware, and devices that consume less energy per unit bandwidth; and (f) specific initiatives at network sites including the solarization of generator huts, the implementation of Charge-discharge cyclic (CDC)  setups at full-time generator off-grid sites toward optimizing the efficiency of Lithium-ion batteries, and the high capacity net metering introduced at sites with large rooftops. Dialog has started to use Internet of Things (IoT) based technology (including physical Energy management dashboards) and plans to expand such technologies its office locations and tower sites to ensure live monitoring of its energy performance for quicker turnaround and increase in efficiencies.

The water supply for the offices is mostly through the municipal supply and its operations do not depend upon ground water extraction. The tower operations do not require water, while the contractors/ vendors are responsible for sourcing water for civil construction during tower foundation. The company monitors water consumption per employee.

In terms of pollution prevention, Dialog’s facilities/ offices are connected to the main sewerage system operated and managed by the local authorities/ municipal bodies. Dialog conducts periodic water audits at key office locations.  The company's operations do not generate significant air emissions. Diesel Generator (DG) set stack monitoring is mandated as per the EPL issued for tower operations.

The company generates domestic municipal solid waste, recyclables and metal scraps, damaged solar panels, e-wastes (such as used telecom equipment, cables, old computers) and hazardous wastes (such as used batteries and used oil) which are managed and disposed in compliance with local regulations. The company has a waste management policy and management framework which includes segregation, and disposal guidelines, and has an electronic waste program named “eKunu” (“e trash” in the colloquial).

`Hazardous materials use both during construction and operational phases is very limited. The company handles and stores diesel for the backup power generation. The company as part of ISO 14001 implementation has a chemicals management policy and started ensuring secondary containment (up to 110% of tank capacity) at all the sites with DG set operations. DG set maintenance is undertaken by a third-party vendor, who are responsible for ensuring fuel spill control kits at all diesel storage locations. The company will document update the H&S manual to clearly document the existing practices related to DG set operations, diesel storage, spill management procedures etc.

Pest control operations in office areas, network infrastructure buildings, data centers (during operation phase) are undertaken by licensed pest control specialist operating in the country who comply to local regulations.            

 Dialog has a dedicated team and robust processes to ensure structural design safety, in additional to complying with Telecommunications Regulatory Commission of Sri Lanka (TRCSL) requirements. Dialog designs and constructs the tower and other related infrastructure in conformity with GIIP. Towers exceeding 30m height are designed to include disaster resilient features. All the structural aspects are certified by a chartered civil engineer (specialized in structural design) before submitting to TRCSL for approval. The civil team and the SCM team undertake detailed screening of the tower manufacturers including site visit and audit of the tower structures. Before commissioning of a tower, a detailed review is undertaken before User Acceptance Certificate (UAC) is awarded by Dialog. The company undertakes third-party insurance coverage of the risk of physical damage and injury prior to the commencement of construction of towers and is included as part of application for TRCSL approval.

Regarding EMF exposure, Dialog complies with TRCSL guidelines which are consistent with International Commission on Non-Ionizing Radiation Protection (ICNIRP) and WBG EHS guidelines. TRCSL mandates verification of compliance with stipulated standards either directly or through a recognized institution immediately after commissioning of the site (or after any modification to the tower site) or once in five years to ensure public safety. The company is also required to maintain a minimum distance of 150m from Schools and Hospitals. Additionally, the base Station equipment comply with the Electromagnetic Compatibility (EMC) standards -International Electrotechnical Commission (IEC) 61000).

Dialog as per TRCSL guidelines provides a comprehensive lightning and surge protection measures to minimize the lightning related damage and injury. The guidelines also require the company to have an insurance cover to cover any lightning damage caused to neighborhood equipment attributed to antenna structure. The company carries out the soil resistivity test and designs the earthing system (certified by a Chartered Electrical Engineer) to achieve the specified earth resistance value (below or equal 10 O) and submits annual compliance report to TRCLS certified by a qualified Electrical Engineer.

Licensed third-party private security service contractors provide non-armed security personnel to be deployed cross offices and tower sites to guard the access gates (entry and exit points). Security service contractors are required to provide basic training to their personnel commensurate to the nature of the job. There have been no violent incidents involving company staff or security guards with community members. As part of ESAP # 5, Dialog will develop a corporate security management protocol in line with PS4 documenting 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 Dialog employees and potential interactions with the local community surrounding tower sites.           

 An analysis of the existing towers owned or used by Dialog for their antennas identified that 13 towers owned by Dialog are located within 10 Alliance for Zero Extinction (AZE) sites. Of these 13 towers, two are located within a World Heritage Site (WHS). The majority of these towers are located within degraded habitats consisting of cleared lands, agricultural fields, and urban settlements.  As per ESAP # 6, Dialog will consult with the AZE Secretariat and World Heritage Committee to confirm the status of the location of these towers with respect to the biodiversity values and will develop and implement Biodiversity Action Plans (BAPs) for those sites based on their recommendations in compliance with and to meet the objectives of PS6.

The siting of new towers under the proposed investment will follow the procedures referenced in ESAP #1, which require that Dialog seeks to avoid construction in areas of high biodiversity value, such as protected areas, Key Biodiversity Areas (KBA), and particularly WHS and AZE sites.  The company, as part of its ESMS, will develop a Biodiversity Screening & Management Procedure (BSMP) (ESAP #7).  The BSMP will (i) define an approach to screen for areas of environmental sensitivity, and (ii) identify the steps required when new towers are proposed in such areas, which will include consultation with the relevant stakeholders (e.g., protected area management, conservation organizations) to ensure compatibility with the values of these areas. The BSMP will also include measures relevant to the rehabilitation of disturbed areas with native species, management of invasive species, soil erosion, forest clearance, managing human access, and ongoing maintenance, as part of the management of biodiversity-related aspects for planned sites in line with PS6.   As per the BSMP, when avoidance of KBAs and protected areas for planned sites is not possible, Dialog will contract a qualified consultant to develop a BAP to define actions to contribute to the conservation objectives of these areas, in consultation with relevant stakeholders.

Dialog’s existing Bay of Bengal Submarine Cable Network and the Sri Lanka Maldives Submarine Cable Network have been constructed within benthic habitats with landing points on sandy beaches.  The cables do not pass through any Marine Protected Areas or Key Biodiversity Areas; however, the Hulhumale of Maldives to Mount Lavinia of Sri Lanka cables pass within close proximity to an Important Marine Mammal Area.

For any future submarine cable project, as part of the ESMS update, Dialog will develop a Marine Biodiversity Procedure (ESAP #8), to identify, assess, monitor, and manage relevant risks and impacts during the installation of new cables and maintenance and repair of operating cables and for the landing points in line with PS6, including analysis of alternatives and potential impacts in fishery-based livelihoods.