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 Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP).

Key areas of E&S focus include: (i) development and implementation of a corporate E&S management system (ESMS) and relevant procedures and plans to screen, assess and manage the limited adverse E&S risks and impacts applicable to the business of the company in line with IFC PSs during projects, operations, terrestrial and subsea fiber network maintenance, expansion and acquisitions, including land access and land acquisition; (ii) HR policies and procedures, labor and working conditions, occupational health and safety (OHS) management during projects and operations and maintenance (O&M) of its network (e.g. marine safety, electrical safety, trenching/ confined space working); (iii) emergency preparedness and response, including risk controls associated with the COVID-19 pandemic; (iv) waste and hazardous material management; (v) community health and safety including motor vehicle safety; (vi) security management; and (vii) stakeholder engagement and grievance mechanism.                                                 

SEACOM has developed E&S policies addressing occupational health and safety and human resources. In 2018, the company drafted an ethics and social report which is aimed at setting out SEACOM’s commitments and approaches to i) stakeholder engagement, ii) community, iii) supply chain management, iv) environmental protection and v) anti-bribery and corruption. Complementing these policy commitments, the company has developed procedures to address workplace safety risks relating specifically toward the telecommunications fiber sector.

As part of the subsea fiber roll out in 2009, the company undertook a series of environmental and social impact assessments (ESIAs) for the jurisdictions through which the fiber optic cable is routed. These studies have been undertaken to meet host nation statutory environmental and social license requirements. To maintain the company’s owned subsea optic fiber infrastructure, SEACOM has in place a long-term maintenance contract with a maritime service supplier whose vessels operate under the directives of the international maritime law, including i) the International Management Code for the Safe Operation of Ships and for Pollution Prevention, and ii) the International Code for Security of Ships and of Port Facilities. All vessels are certified by recognized classification societies. The installation of SEACOM’s terrestrial infrastructure has been undertaken within existing right of ways and/ or road servitudes and consistent with government guidelines and with requisite regulatory approvals.

As part of IFC’s financing the company shall revise, complement and develop its overarching E&S policy/ies defining the company’s E&S objectives and principles, which shall meet IFC’s Performance Standards requirements, be approved by the SEACOM board and implemented across the organization, per ESAP #1a. Regarding fiber optic installations the company will develop and adopt a land acquisition, access and compensation policy for such installations per ESAP #1a.

To operationalize its revised E&S policy commitments, SEACOM will build on its draft ethics and social report to develop and implement an environmental and social management system (ESMS) per ESAP #1b. The ESMS will apply to, and be suitably scaled for, all SEACOM business activities and will be developed and implemented in accordance with the requirements of PS1. The ESMS will address SEACOM’s direct operations and indirect operations undertaken by construction contractors, O&M contractors and by service providers (including telecommunications fiber optic service providers and data center providers) where SEACOM is an anchor tenant in a manner consistent with the PSs.

The ESMS [ESAP #1b] shall include the following management programs to develop projects and operate in a manner consistent with IFC’s PS: i) E&S risk screening and impact assessment requirements for new fiber optic routes, ii) due diligence and assessment procedures to identity, assess and manage relevant E&S risks and impacts of future acquisitions and assets, iii) emergency response, iv) community grievance redress, v) training, vi) marine and terrestrial occupational health and safety, vii) contractor assurance, audit and management, viii) waste management, ix) environmental monitoring, x) community health and safety, xi) security management, xii) a land access and acquisition procedure (discussed further below), xiii) biodiversity management requirements for sites located in terrestrial and marine areas of significant biodiversity value, natural, or critical habitat in compliance with IFC PS6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources.

The land acquisition and compensation procedure will include details on the company’s roles and responsibilities, including collaboration with regulatory authorities, planning, implementation, monitoring, and measures to address potential gaps against host nation process and IFC’s PS1 and PS5 (Land Acquisition and Involuntary Resettlement) requirements, as applicable. The procedure will also articulate the provisions for the engagement of indigenous communities, consistent with IFC PS7 on Indigenous Peoples. The land acquisition and compensation policy and procedure will also apply to all service providers and be included in a ‘Client’s E&S Standards’ document, discussed further below, per ESAP #1d. Grievance management pertaining to any land acquisition or land access activities during construction or operations will be managed through the external grievance management mechanism per ESAP #5b.

SEACOM relies on a network of contractors, suppliers and service providers who provides the business with a range of products, services, and infrastructure support. As part of the SEACOM ESMS development [ESAP #1b], SEACOM will develop a ‘Client’s E&S Standards’ document defining E&S requirements for all contractors and service providers per ESAP #1d. The document will reflect the requirements set out in SEACOM’s ESMS, and will consider risks associated with engineering, procurement and construction (EPC) contractors along with O&M contractors engaged by SEACOM to develop and operate its network. Assurance of these standards will be achieved via monitoring and review of contractor’s, supplier’s and service provider’s compliance to the company’s standards as part of the SEACOM ESMS [ESAP #1b]. In instances of anchor tenancy, the ESMS [ESAP #1b] will define a management process to include i) E&S greenfield screening, ii) a procedure to ensure fiber routing is suitably permitted before SEACOM leases any optic fiber, and iii) E&S provisions for primary service providers. The SEACOM ESMS shall include requirements for the development and maintenance of a permitting register for its owned telecommunications assets, to track the permitting status for all SEACOM owned assets per ESAP #1b.

The ESMS will also define E&S elements required for inclusion within the corporate risk register, covering elements such as health and safety (including road traffic risk) of direct, contracted and supply chain workers (as defined under IFC’s PS2), E&S risks associated with the company’s activities, including physical, chemical, electrical hazards, and gender-differentiated risks. The risk register will also include risks associated to security management and use of security personnel. For each risk identified, the company will define and implement appropriate mitigation measures, which will be auditable elements and shall be communicated to senior management and periodically reported to the SEACOM board per ESAP #3.

SEACOM’s board is responsible for the oversight of E&S matters. SEACOM’s management team periodically report E&S risks to the board on an as needed basis. As part of IFC’s investment, the company shall formalize the board’s E&S reporting requirements defining routine reporting E&S requirements to the SEACOM board. At the management level, the SEACOM CDO has a functional responsibility for the oversight of environmental, health and safety performance across all SEACOM businesses. These responsibilities are shared and/ or delegated across a number of direct and parallel reporting functions in the organization, including facilities management, operations, and procurement. As part of IFC’s financing, SEACOM shall retain an appropriately qualified E&S manager who shall report directly to the CDO, and who shall be supported by the appropriate resources to develop, implement and operate the corporate ESMS and oversee E&S aspects of the SEACOM business, per ESAP #2.                                            

As of end March 2022 SEACOM employs 310 direct employees. SEACOM Africa’s staff within the borrowing operating companies is comprised of 46% female employees.

Oversight of all direct employment relationships is provided by the human resources (HR) function managed centrally from SEACOM’s operational headquarters in Johannesburg. Company HR policies are consistent with South African host nation labor regulations and IFC PS 2 requirements and apply to all SEACOM South Africa employees. HR policies define non-discrimination and equal opportunity conditions to avoid bias towards gender, health, disability, race, or religion. Requirements against sexual harassment and harassment-free workplace are explicitly addressed. These are included in employment contracts for all employees directly under SEACOM South Africa’s purview and address working conditions, terms of employment, leave, wages and benefits.

SEACOM employs staff based on merit, with recruitment based on a role profile for each position and the completion of a pre-employment checklist that includes checking age, qualifications, and experience prior to offering a position. SEACOM encourages freedom of association and labor representation across the workforce, and regularly engages with and cooperates with recognized trade unions in markets where it operates. The company operates a structured worker grievance mechanism. SEACOM shall revise and update the existing grievance mechanism to fully meet IFC PS2 to: i) include an anonymous channel to register grievances without fear of repercussion, ii) include specific provisions for gender based violence grievances, ensuring open timeframes for lodging a grievance, and iii) extend the grievance mechanism to all contracted workers, including workers of EPC and O&M contractors per ESAP #4c.

SEACOM shall revise all existing HR policies and procedures i) to extend to all SEACOM business activities where the current scope is focused toward the South African business and ii) to ensure consistency with PS2 requirements, per ESAP #4a. The company shall develop an employee handbook to be provided to each employee at the point of employment, per ESAP #4b.

SEACOM has developed a health and safety plan applicable to its South African business which covers a comprehensive set of risk controls associated with the business including i) risk assessment, ii) construction management, iii) safe working, iv) life and fire safety, v) hazardous chemicals storage, vi) emergency preparedness, contingency planning and response, and vii) first aid.

As part of SEACOM’s ESMS [ESAP #1b], the company will augment its existing safety plan to develop and implement the following OHS elements either as part of the ESMS, or as a standalone safety management system, to apply to all aspects of the SEACOM business, including: i) OHS training, including emergency preparedness and response, for SEACOM staff and its contractors and service providers to operate in a manner consistent with SEACOM’s ESMS requirements; ii) a monitoring and reporting program consisting of the collection of key OHS statistics including near misses, accidents/incidents and root cause and trend analysis, verification of implementation of corrective actions, and other relevant components covering SEACOM staff and contractors; iii) an audit program for SEACOM construction sites, owned passive infrastructure and contractors responsible for construction and O&M of telecommunications optic fiber installations where SEACOM is an anchor tenant; and iv) formalized COVID-19 safety protocols, tailored to the company’s operations, in compliance with relevant requirements as defined by host nation health authorities per ESAP #1c.                                                

Electricity is sourced from the public grid for the majority of the company’s assets. Grid reliability can be variable and so backup power generation is in place for SEACOM’s offices, key infrastructure sites including sites where SEACOM’s fiber lands onshore. SEACOM’s GHG emissions therefore primarily relate to electricity consumption. SEACOM leases space at numerous data centers to support its network requirements and these site represent key electricity consumers due to the air conditioning requirements of the servers and data storage equipment. The GHG emissions for the SEACOM business is estimated to be approximately 8,222 tons CO2eq per annum.

The ESMS [ESAP #1b] will include an environmental monitoring plan (e.g., water consumption, energy consumption, and noise), a hazardous materials management plan (e.g., hydrocarbon storage requirements and having secondary containments for fuel tanks greater than 1,000 l capacity and generators) and a waste management plan, to be extended to SEACOM’s contractors and service providers contracts, as articulated in the Client’s E&S Standards [ESAP #1d] to ensure compliance with local legal requirements, PS3, and alignment with GIIP as per WBG General EHS Guidelines and EHS Guidelines for Telecommunications. The waste management plan will include procedures to identify, separate, reuse/recycle where possible, and ultimately safely dispose of waste, especially e-waste and will include a waste tracking system.                                           

Community health and safety risks primarily relate to i) road traffic incidents involving SEACOM staff or its contractors, and ii) contracted EPC and O&M services for the expansion and maintenance of SEACOM’s optic fiber and telecommunications networks. As part of SEACOM’s ESMS development [ESAP #1b], contractor E&S management procedures will be developed to ensure contractors meet the company’s policies and ESMS requirements as defined in the ‘Client’s E&S Requirements’ document [ESAP #1b] with regard to community health and safety.

As part of its ESMS [ESAP #1b], SEACOM will develop and implement a motor vehicle safety management standard for direct staff and contractors. The company’s ESMS [ESAP #1b] will require SEACOM undertakes appropriately scaled country level security risk assessments defining requirements for security service providers and security personnel. These will be articulated in country/ site level security management plans to be developed by either SEACOM or its contractors ahead of any EPC or O&M activities consistent with both national legislation and the requirements of PS4.