The MA subsidiaries secure land required for their operations based on willing buyer-willing seller basis or space leases on existing properties. Based on the scope of operations at the subsidiaries, no adverse impacts related to IFC PS7 on Indigenous Peoples; or IFC PS8 on Cultural Heritage were identified. In any case, as described in IFC PS1, the ESMS of each subsidiary, will include risk screening, assessment, and management procedures for cultural heritage.

 This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012), since it is expected to have limited adverse E&S impacts that are few, site-specific, reversible, and readily addressed through existing mitigation measures and Good International Industry Practices (“GIIP”). 

Key E&S aspects associated with the Project include (a) the subsidiaries’ ESMSs; (b) management of labor and working conditions and occupational health and safety (“OHS”) policies and practices, including for contractor workers; (c) impacts on community health and safety including impacts from electro-magnetic fields (“EMF”), road transport, and security; (d) assessment and management of biodiversity impacts; and (e) stakeholder engagement.

 Some subsidiaries implement Quality Management Systems are aligned to ISO 9001:2015 (for quality) and have quality, health, safety, and environment (“QHSE”) policies, which are mainly focused on OHS. As agreed in the ESAP, each of the eight MA subsidiaries will develop and implement an ESMS specific to and suitably scaled for the size of its business activities, in accordance with the local legal requirements and the requirements of IFC’s PS1. The ESMS will comprise an overarching E&S Policy defining the company’s E&S objectives and principles and relevant procedures to identify, assess and manage relevant E&S risks and impacts for: OHS risk management; contractor environmental, social, health and safety (“ESHS”) management; environmental management (water, energy, waste management, biodiversity, and pollution prevention); road transport risk management; electro-magnetic frequency monitoring; land acquisition and resettlement; security risk management; emergency preparedness and response; and stakeholder engagement (ESAP #1).

As part of the ESMS, each subsidiary will also develop and implement an E&S Assessment and Management Procedure, to ensure that site selection, E&S impact assessments, installation and operation of all new towers meet local as well as IFC PS compliance requirements (ESAP#2). Each subsidiary will also assign a suitably qualified staff member to oversee E&S risk management in the business (ESAP #3).

For all existing owned towers, each subsidiary will ensure that all environmental permits required by respective government regulators are obtained; while for the rented towers, each subsidiary will establish the status of environmental permits and make best effort to influence regularization by the owners where required permits lack (ESAP #4).

 The eight subsidiaries have approximately 2,500 direct workers in total, and varying numbers of contractor workers depending on the scope and duration of projects (tower construction, call centers, operation and maintenance (“O&M”), fiber cable works) by each subsidiary. The subsidiaries have documented different HR procedures designed to meet the requirements of respective host country laws, and apply mainly to direct workers. Direct workers have written contracts that describe the working conditions and terms of employment as required by local laws. Some subsidiaries have workers’ organizations while there are none in others.

As agreed in the ESAP, each subsidiary will update their existing HR policies and procedures to align them with local labor laws and IFC PS2 requirements, including procedures related to retrenchment, non-discrimination or equal opportunity, freedom of association; and managing all forms of harassment (including gender-based violence), and workers’ grievance mechanism. Each subsidiary will communicate the HR policies and procedures to all workers (ESAP #5).

Some subsidiaries have OHS committees in place while others do not. Workers across the subsidiaries are provided with task-specific personal protective equipment (“PPE”). As agreed in the ESAP, each subsidiary will conduct an OHS Risk Assessment in line with IFC PSs and develop and implement a corresponding comprehensive OHS Management System (“OHSMS”). The OHSMS will also cover contractors. (ESAP #6).

The subsidiaries retain labor firms to hire and manage some temporary and other outsourced workers; and engage contractors for technical/installation works, network deployment, security, and commercial activities – as needed. As agreed in the ESAP, the subsidiaries will develop and implement a contractor ESHS Management Procedure in line with IFC PS and the IFC Good Practice Note: Managing Contractors' Environmental and Social Performance (ESAP #7).

Energy required for the operations at the subsidiaries is mainly via the national grid, and the technical centers and tower sites are equipped with diesel generators and back-up batteries. The annual greenhouse gas (“GHG”) Scope 1 emissions includes those from grid electricity consumption, vehicle fuel consumption and back-up generators, and emissions across the eight subsidiaries are estimated to be less than 25,000 t/CO2e, mainly because generators are only used occasionally, and the light fleet of vehicles do not cause significant emissions. The main sources of air and dust emissions include diesel generators and vehicles (primarily service cars) driving on dirt roads. Vehicles and diesel generators are also considered the main sources of noise, along with construction works when applicable.

The solid waste generated by the subsidiaries includes used batteries, electrical and electronic waste, scrap metal, oil and diesel filters, and general waste from maintenance and operations. Lubricant oil is the main hazardous material found on sites.

Each subsidiary will, where relevant, implement additional environmental management procedures as required in ESAP #1 to address risks related to water, energy, pollution, and wastes in consistency with the requirements of IFC PS3 .

Key risks to communities’ health and safety linked to operations at the subsidiaries include exposure to EMF, and road accidents. In terms of road safety, some subsidiaries’ vehicles conduct periodic vehicle maintenance and have vehicles equipped with GPS for location monitoring. To standardize the approach to building driver competence and enhanced driver oversight and supervision across all eight subsidiaries (as part of ESAP #1), each subsidiary will develop a road transport management procedure and ensure this procedure is communicated and implemented adequately by both direct workers and all contractors. Similarly, as part of ESAP #1, each subsidiary will develop and implement an EMF monitoring program consistent with the requirements of WBG EHS Guidelines.

Security provision across the subsidiaries is outsourced to local companies that employ unarmed security guards. As part of ESAP #1, each subsidiary will develop a security risk management procedure applicable to all security personnel in line with IFC PS 4 requirements.

MA operates 10,069 existing towers across eight countries, namely Benin, Burkina Faso, Chad, Côte d'Ivoire, Gabon, Mali, Niger and Togo. 544 towers overlap various protected areas and key biodiversity areas (“KBAs”). 36 of these towers are located in natural habitats and the rest are located in modified habitats associated with human settlements, agriculture, or immediately adjacent to existing roads. No material changes relative to baseline conditions are expected for any of these sites, both in natural and modified habitats. 11 operating towers are located within Alliance for Zero Extinction (“AZE”) and United Nations Economic and Social and Cultural Organization (UNESCO) World Heritage Sites (“WHS”), five in Adiopodoume AZE site in Côte d'Ivoire and six in the following World Heritage Sites - Kaobagou in Benin; Lakes of Ounianga and 1 Ennedi Natural and Cultural Reserve in Chad; Comoe National Park in Côte d'Ivoire; and Air et du Tenere Natural Reserve in Niger. These 11 towers in AZE and WHS sites are all located in modified habitats and changes relative to baseline conditions are unexpected.

To ensure appropriate assessment and management of biodiversity risks for existing sites and any future acquisition or construction on new sites across the business, each MA subsidiary will (i) include PS6-compliant biodiversity commitments in its ESMS and (ii) develop a Biodiversity Risk Management Procedure for sites located in protected areas and KBAs aligned with PS6 requirements which may include additional biodiversity protection measures and additional enhancement programs for the AZE and WHS sites as needed (as part of ESAP #8). Biodiversity-related stakeholder components will be integrated with the Stakeholder Engagement Plan (“SEP”) (see ESAP #9), and relevant stakeholders associated with UNESCO, the AZE Secretariat and the KBA Secretariat will form part of the key stakeholders to be scoped into the SEP.

All eight subsidiaries engage with institutional and regulatory stakeholders on a regulated basis, and with communities on an ad hoc basis. Each subsidiary will develop and implement a corporate Stakeholder Engagement Procedure in line with PS 1 requirements, per ESAP #9

Contact Person: Vitte Francois

Company Name: ITISSALAT AL MAGHRIB

Address: Rabat, Morocco

Phone: +212 537 71 21 21