Considering the nature of business operations and the project, there are no identified risks and anticipated impacts associated with the requirements of PS 5 (Land Acquisition and Involuntary Resettlement), PS 7 (Indigenous Peoples), and PS 8 (Cultural Heritage) for this proposed project at the time of the appraisal. However, Axian will develop relevant management procedures and program to comply with PS 1 requirements and will comply with the specific requirements of PS 5 through 8, if and when they apply at its operating company’s business activities under the proposed investment.

  This is a Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability. The proposed investment is expected to have limited environmental and social impacts, which are expected to be short-term and site-specific. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections.

The key E&S issues associated with this investment include i) adequacy of Axian’s environmental and social management system to cover the entire scope of E&S risks in the operations, including operating company’s (OPCO) operations; ii) adequacy of risk screening and assessment procedures to identify E&S risks related to new tower sites as well as existing assets during acquisitions; iii) assurance of fair, safe and healthy working conditions for employees and contractors, including, grievance management, security, health and safety, harassment and gender-based violence; iv) contractor and third party environment, health and safety (EHS) management, monitoring compliance assurance; v) community health and safety; vi) implementation of PS 5-aligned land acquisition and compensation process in tower acquisition and operation; vii) adequate risk identification and management at tower sites within areas of biodiversity value; and viii) enhanced and coordinated engagement with key stakeholders including local communities.

Axian have recently developed an environment and social management system (ESMS) comprising: a health, safety and security (HSS) Policy; an E&S Policy; an ESMS Manual; and a set of procedures, key among them: Health and Safety (H&S) Risk Management Procedure, E&S Risk and Impact Evaluation and Audit Procedure, Emergency Preparedness and Response Procedure, Contractor HSSE Management Procedure, Grievance Management Procedure, Traffic Management Plan, Land Acquisition Procedure, Archeological Chance Find Procedure and Waste Management Procedure. Most of these procedures and related implementation checklists and templates are already fully developed at Group level and shared with the OPCOs for adoption. Other procedures, including Stakeholder Mapping and Engagement Procedure, Security Management Procedure, E&S Training Procedure, Community Health and Safety Procedure and Internal Audit Procedure are scheduled for development and will also be integrated into the ESMS. Axian will complete and roll out its pending Procedures as well as their respective implementation documentation by 31 December 2022. To effectively address biodiversity risks related to tower locations, Axian will update the E&S Policy to include PS6-compliant biodiversity commitments including commitment to avoiding construction of any future towers within Alliance for Zero Extinction (AZE) sites or World Heritage Sites; and develop a Group Biodiversity Procedure for appropriate assessment of biodiversity risks for any purchase of existing sites or construction of new sites across the business (see detail under PS 6 below). Axian will ensure Tanzania and Togo OPCOs adopt this Procedure in their operations (ESAP #1).

Axian has confirmed that all tower sites to be acquired in Tanzania have undergone environment and social impact assessments (ESIAs) per local regulatory requirements and EIA permits obtained for each site. In Togo, as per disclosed ESAP (item #3) under Project #44666, Togocom is committed to: i) develop an action program to obtain the required E&S permits and authorizations in accordance with the local law for all towers lacking such permits and authorizations, and will carry out the necessary E&S assessments, including risks for community health and safety, biodiversity conservation, and cultural heritage in accordance with IFC PS requirements; ii) ensure adequate stakeholder engagement is conducted during these studies; iii) ensure that any new/future tower owned by the company are suitably permitted before erection and installation of any electronic equipment; iv) if towers are sold to an independent tower operator, disclose its commitments to abide by IFC PSs to the tower company and will request that the tower company adheres to the same including, including to ensure stakeholder engagement and obtaining of required E&S permits and authorizations; and v) develop measures for ensuring that, where new tower sites need to be established for network densification or expansion, the tower company, contracted to establish the tower and associated passive infrastructure, will confirm that the towers are suitably permitted before Togocom installs any electronic equipment on the tower (ESAP #2).

The E&S Risk Evaluation and Audit Procedure will be revised to i) integrate biodiversity, Indigenous Peoples and cultural heritage screening criteria, and ii) refer to the applicability and implementation of the Land Acquisition Procedure, Stakeholder Engagement Procedure and Biodiversity Management and Monitoring Plan in the assessment, mitigation and management of new sites and tower acquisition, consistent with IFC’s PS (ESAP #3).

Identification of Risks and Impacts

The Axian H&S Risk Management Procedure guides management of routine operational H&S risks. This Procedure is currently in various phases of adoption the OPCOs, with a target of full compliance by June 2022. The Procedure entails risk identification, assessment and reporting processes, including determination and implementation of corrective/remedial actions. In addition to the E&S Risk Evaluation and Audit Procedure aimed at new projects, the Group also has a risk register for tracking all E&S risks in the business. Each OPCO completes own risk register per the Group template and shares this with Group EHS Coordinator and E&S Manager for collation and review. To complete and update the risk registers, operational risk assessments are conducted monthly, while activity or project level risk assessments are done at the beginning of each project. OPCO risk assessment meetings are held every month, and whenever incidents occur, to review key risks, identify corrective actions, and align management actions to these. The new Tanzania OPCO will adopt the same procedure and will be included in the corporate management review process.

For new projects, mainly new tower construction or for acquisitions, the E&S Risk and Impact Evaluation and Audit Procedure will be applied. The Procedure sets out parameters for initial risk screening and an internal process for impact assessment and reporting. The procedure will be applied once sites are identified and will be considered in strategic management decisions on such sites.

Management Programs.

The H&S Risk Management Procedure and the E&S Risk Evaluation and Audit Procedure guide management of EHS performance for business and new projects, respectively. These are complemented by other topical risk management procedures as mentioned above. Risk registers are the primary risk tracking tools for the OPCOs. From the periodic OPCO risk assessments, E&S Action Plans are developed, covering several key performance indicators (KPI) including health and safety, waste, environment and energy efficiency, contractor EHS performance, competency and training, and EHS reporting in the operations. Monthly meetings are held at the OPCO level to track implementation of the Action Plans, and quarterly at the Group level, with the Group E&S Manager and EHS Coordinator co-leading these meetings. The Group E&S Manager and EHS Coordinator collect and consolidate all KPIs from OPCOs ahead of these quarterly review meetings. Data are centralized in a dedicated software (PREVISOFT), from which reports are generated as needed. Action Plans are set at the level of each OPCO aimed at the implementation of each Group E&S Procedure which are rolled out. Monthly OPCO meetings are held to ensure follow-up of these Action Plans. Staff training is provided to E&S and EHS teams for each OPCO, and they in-turn conduct general staff trainings within their respective OPCOs.

The establishment of tower sites is the main reason for land acquisition by Axian. Typically, the company selects sites and acquires land on a willing buyer-willing seller basis. In some cases, the company may encounter communally-owned land or parcels with encumbrances and where expropriation or other legal proceedings based on eminent domain are an option, if a negotiated settlement fails. Based on IFC’s review, engagement, negotiation and compensation activities relating to land acquisition have been managed through the OPCO E&S teams on a case-by-case basis with no formal guidance in line with PS 5. At the time of the IFC’s review, Axian had developed a Land Acquisition Procedure to guide such acquisition processes going forward. The company will review and update the Procedure to fully meet PS 5 requirements when such requirements apply and roll out the Procedure across its OPCOs, including the OPCOs under IFC existing and proposed investments (ESAP #1).

The Contractor HSSE Management Procedure, alongside the Supplier Code of Conduct and Contractor E&S Requirements Guide, provide the task-related E&S requirements, and general requirements on project risk management and contractor compliance with company policy and national laws. The OPCO EHS management is responsible for contractor supervision to ensure adherence to the requirements, consulting with Group EHS Coordinator and E&S Manager as needed. Their monitoring roles include onboarding, review of contractor’s EHS Management Plans and method statements, supervision of site EHS practices, incident investigations and contractor audits.

Organizational Capacity and Competency.

Axian Board of Directors sets corporate objectives and targets and takes strategic decisions on safety, health and environmental management. The Group CEO is accountable for the overall E&S performance, and is responsible for allocating sufficient human, financial and other resources to secure effective EHS management, taking competent advice on matters of EHS where relevant. Axian have a Group E&S Manager and a Group EHS Coordinator, both leading E&S risk management across the business. Each OPCO (including Togo) has an E&S Manager (some titled EHS Managers), similarly leading E&S risk management at each OPCO. These managers are supported by junior EHS specialists to ensure effective delivery of their targets. Axian has scheduled to hire an EHS auditor and EHS trainer to streamline the internal audit and training objectives of the Group; and OPCO Community Liaison Officers (CLOs) to spearhead external engagements with host communities by June 2022. There is an existing EHS team for the Tanzania MNO. The full E&S organizational capacity will be reviewed once the acquisition is completed and mapped similarly to the other Axian OPCOs. A CLO will be hired for Tanzania operations within this timeframe as well (ESAP #4).

Emergency Preparedness and Response.

The company has a Group Emergency Preparedness and Response Plan that sets out the requirements and actions during emergencies at all premises and active work sites in order to minimize and/or where possible prevent losses, injuries, damage and disruption. Key emergencies listed as part of the guideline include natural hazards (such as cyclones and inundations, among others); fires; explosions; civil unrests; and accidental spills. Axian has also developed an emergency mapping and register template. The document provides the minimum requirements to be included and addressed in Emergency Preparedness and Response Plans to be compiled by each OPCO. Each OPCO’s EHS team is expected to ensure that the plans are developed in alignment with the Group Plan. Axian has developed health and safety rules and a checklist relating to the prevention of COVID-19, which includes hygiene measures, temperature monitoring, social distancing, implications and measures if positive case recorded.

Axian will provide completed Emergency Preparedness and Response Plans for Tanzania and Togo OPCOs, addressing emergency triggers and types; drills and procedures; evacuation protocol, emergency structures, roles and responsibilities; coordination with external parties; emergency training; and standard emergency operating procedures for various emergency types, by June 2022 (ESAP #5).

Monitoring and Review.

To meet the company’s commitment to E&S performance, management teams at OPCO and Group levels have set E&S KPIs. These KPIs are tracked and reported on during monthly OPCO EHS meetings, and quarterly at the Group EHS meetings. To appraise its effectiveness of the set EHS performance requirements, Axian is currently developing an Internal Auditing Standard, which will include E&S performance (including ESMS) auditing scope and periodicity. As part of ESAP #1, this Standard will be implemented by the Group EHS Auditor to appraise E&S performance and report on required improvements or updates to monitoring tools.

 Axian, through its various OPCOs, cumulatively employs over 3,221 direct employees out of which about 2,101 are male and 1,120 are female. About 5,000 workers are employed through contracted third parties.

Human Resources Policies and Procedures.

At the group level, Axian has developed a Human Resources (HR) Charter, representing the group’s policy on labor management. The Charter provides broad commitments on recruitment and induction, capacity building and career development, remuneration, working conditions, and social dialogue. Each OPCO currently implements own labor management procedures in compliance with the group Charter and local laws. No cases of discrimination or harassment were reported at the time of appraisal. To ensure efficient and consistent management of Human Resources across the business, Axian will develop a detailed group HR Manual with policies that cover, in consistency with PS 2: employee hiring procedures, policies on freedom of association and workers’ rights to organize, occupational health and safety, gender-based violence and workplace harassment, grievance management, non-discrimination and equal opportunity, child and force labor, and retrenchment. The scope of the Manual will cover direct workers and contracted workers engaged by third parties. Tanzania and Togo OPCOs will adopt the Manual to their respective local labor requirements, ensure it’s communicated to all staff and contracted workers, and incorporated into new employee induction and refresher trainings (ESAP #6).

Working Conditions and Terms of Employment.

Working conditions and terms of employment at Axian are largely dictated by country specific legislative requirements and are detailed and implemented through individual OPCO HR Procedures which are provided to all employees upon appointment. All employees are provided with written contracts of employment (fixed-term and permanent contracts), designed to fit requirements of their specific roles and in line with local employment laws. The HR Manual, to be a developed and adopted by the OPCOs under ESAP #6, will document the Group procedures to address minimum compensation principles, employee welfare benefits, gender-based violence and workplace harassment, grievance management, non-discrimination and equal opportunity among direct and contracted workers.

Axian has set the Contractor HSSE Management Procedure to guide in the management of contractor’s operations, including working conditions and terms of employment for their workers.

Workers’ Organizations.

Workers union and collective bargaining agreements exist in some OPCOs, including Togo. Though Axian does not restrict the formation of workers’ unions, this is not currently documented at the policy level and will be included in the HR Manual.

Retrenchment.

Togocom implemented a voluntary separation process as part of the restructuring process implemented in 2019 and 2020 (as mentioned in the ESRS under Project #44666). All pending items relating to severance payments have reportedly been cleared (no documentation provided for review at the time of writing of this report). Currently, any new individual and collective claims regarding the former employer are reported to the Head of HR at Togocom. There has reportedly not been any further formal complaint filed against Togocom relating to the retrenchment which occurred as part of the privatisation since the conclusion of the implementation of the retrenchment process. A third party labor audit on Togocom is yet to be conducted, as recommended under Project #44666 and has been included in the ESAP for this proposed investment (ESAP #7).

As included in ESAP #6, the Axian HR Manual will include principles to guide in the development of retrenchment procedures by each OPCO, in line with their local laws and PS 2. The Procedures will ensure that prior to implementing any collective dismissals, adequate analysis of alternatives is done, and where inevitable, guidelines relating to retrenchment plan developed to reduce adverse impacts of retrenchment on workers (including vulnerability assessment; retrenchment criteria; consultation with workers, their organisations and applicable government or relevant local authorities; notice dismissal and severance payments, and grievance mechanism, all in compliance with PS 2).

Grievance Mechanism.

Axian has developed a procedure for grievance management which includes key requirements for OPCOs relating to grievance management, including the process and different phases (receipt, addressing the grievance, investigation, response, arbitrage, monitoring). OPCOs are expected to adopt and modify the Procedure to fit their operating environment whilst retaining the key principles. The Group Procedure is designed to cover grievances both from employees (direct and contracted workers) and external parties and indicates that the grievances to be addressed will be related to certain activities of the company. To provide a clear separation of internal and external grievance redress processes, Axian will develop and embed an employee (and contracted workers)-specific grievance management mechanism within the HR Manual to cover all employees and contracted workers, separate from the current guideline which focuses more on external parties. The employee grievance mechanism will provide clear channels for raising grievances by direct and contracted workers (including anonymous channels); defined grievance registration and documentation process; clear timelines and responsibilities for grievance processing; feedback channels to the claimants; and options for grievance escalation beyond the company, if need be. Togo and Tanzania OPCOs will adopt this grievance procedure in their operations (ESAP #8). A separate external grievance mechanism will be developed as provided under Stakeholder Engagement section.

Some 11 grievances were recorded in 2021 (four in Togocom), mainly external grievances related to tower locations, generator noise and land. Others related to contractor workers’ wages and lighting at the workplace. These grievances are in various stages of processing by the OPCOs.

Protecting the Work Force.

In line with the Group HR Charter, terms of employment are set by each OPCO in compliance with relevant national labor regulations of the country of operation. The company confirmed that their OPCO-level procedures are designed to prohibit employment of any person under the local minimum employment age or mandatory school leaving age (whichever is higher). This requirement is also extended to all contractors / third parties through the Contractor EHS Requirements which requires all contractors to commit to avoiding employment of child and forced labor. Axian will verify the same for Togo and Tanzania during contractor EHS review as required in ESAP #10 below.

Occupational Health and Safety.

Axian commits to safeguard the health and safety of their employees and contractors through providing and maintaining a working environment that is safe and without risk to the health of employees and contractors. In the company’s Health, Safety and Security Policy and Environment and Social Policy, Axian commits to ensure compliance with national and international standards of occupational safety and health in their operations. The H&S Risk Management Procedure provides steps of risk management during operations and maintenance. H&S risk reporting within the business is done through a software platform, including but not limited to: risk register updates, permit to work processing, personal protective equipment (PPE) management and periodic overall H&S performance reports. Each OPCO conducts own H&S risk evaluation and updates the risk register periodically. Additionally, both employees and contractors are required to conduct per-task risk analysis to identify and mitigate risk related to each key activity. Work permit system is progressively being developed and implemented at the OPCO level to formalize and document the pre-task risk assessment process. For traffic management, all company vehicles are equipped with a GPS system monitoring speed, distance, and rest time. All journeys of two hours or more must have a journey management plan that include requirements regarding rest breaks and sleeping hours for drivers. All drivers must have defensive driving training in every 2 years. There is a maintenance program for the company cars. Each OPCO is expected to conduct at least four EHS inspections a year within their operations, including on contractor activities.

The key H&S incidents including near misses, lost-time injuries, road accidents and related injuries, and fatalities are clearly documented, reviewed and investigated within the company. Corrective actions are developed and tracked to completion by management. Axian will develop a Standard Accident/Incident Investigation and Reporting Procedure to standardize quality of incident or accident investigation and reporting across the business. Tanzania and Togo OPCOs will adopt this Procedure for their operations (ESAP #9).

Workers Engaged by Third Parties and Supply Chain

Majority of on-ground activities are undertaken by contractors. Axian’s Contractor HSSE Management Procedure guides contracting EHS requirements, contractor EHS audits and contractor EHS reporting requirements. The EHS considerations in contractor selection are also included in the Procedure. Each contractor is required to submit a risk management plan for each task to be carried out, as well as submit monthly reports. For Tanzania and Togo, Axian will audit the contracts of the contractors, with priority being those providing transport, security, civil works and operation and maintenance works, against the Contractor HSSE Management Procedure and Contractor E&S Requirements Guide and develop an Action Plan to close out any identified gaps with respect to compliance with PS 2 (ESAP #10). Axian has included an explicit policy statement against child labor, commitment to environment and human rights and supplier audit as part of the Supplier Code of Conduct, to be signed by every primary supplier and contractor. 

 Resource Efficiency.

Grid electricity and diesel are the main source of energy for company’s operations and tower sites, among other assets, although some OPCOs has started complementing grid electricity and diesel in some tower sites with solar power generation. In 2021, diesel was most consumed by the towers site generators, followed by project vehicles. Energy consumption is tracked by OPCOs and reported to management alongside EHS monthly and quarterly reports. The company consumes mainly municipal water for the majority of its operations. Quantities are limited and primarily used for routine administrative, sanitary and cleaning purposes.

The company has established a methodology and templates for annual greenhouse gas (GHG) emissions quantification and reporting. Per the 2020 Impact Report, GHG emissions totaled 54,788t CO2eq.

Axian will include Togo and Tanzania OPCOs in their energy consumption reporting regime and ensure water consumption at these OPCOs is integrated into the resource tracking and reporting program. Future annual reporting will cover emissions from Tanzania and Togo OPCOs (ESAP #11).

Pollution Prevention.

The diesel generators at tower sites are self-contained (with 110% secondary containment) to prevent external spillage of diesel. The diesel supplies are contained in secure tanks or gallons, usually stored on hard surfaces. The company ensures posters of spill containment procedures are at visible places at the tower sites, and the attendants are given basic training on spill management. For noise pollution, the company is in the process of replacing sites with priority given to sites where noise related grievances are reported with grid power or solar power, as feasible. In other cases, the generator running hours are reduced by alternating with the two power options.

The main wastes generated from routine operations include office general wastes, wastewater from cleaning and tower construction activities, effluent from sanitary facilities and some hazardous wastes from equipment maintenance and repairs at tower sites and other workplaces. A Waste Management Procedure has been developed at the Group level, and, at the time of IFC’s review, it was being adopted by the OPCOs. For hazardous waste, specific additional procedures have been developed for e-waste, used oil and batteries. Process of identification of licensed waste service providers to help manage waste disposal process at the OPCOs was ongoing at the time of the appraisal and will be completed by June 2022, including Tanzania and Togo OPCOs. Also, waste management targets were being set by individual OPCOs at the time of appraisal.

The H&S Risk Management Procedure provides for quarterly and annual HSSES performance monitoring and reporting where all key environmental parameters are reported, including environmental incidents, grievances, energy consumption etc. The company will add noise, water and waste monitoring into this reporting regime, under ESAP #1.

 Community Health and Safety.

Axian is developing a Community Health and Safety Management Procedure (ESAP #1). This Procedure will include provisions on risk considerations in design and erection of new towers, repairs and maintenance, management of impacts of electromagnetic fields (and relevant siting criteria), waste management, security provision and training, managing transportation risks to communities and community engagement and external grievance redress process.

A Transport Management Procedure has been developed at Group level, and, at the time of IFC’s review, it was being adopted by the OPCOs. This Procedure has provisions for driver training and competence checking, journey management to reduce risks of accidents, vehicle maintenance requirements and traffic incident reporting. The Procedure will be updated to indicate who are responsible for preparing and approving vehicle journey plans, especially on contractor vehicles; level of oversight by Axian on contractors vehicles and drivers; responsibilities for accident/incident investigations and review by Axian; consequences for non-compliance by contractors; and periodic performance audits by Axian to make it effective for addressing occupational and community health and safety risks related to road transport. Tanzania and Togo OPCOs will adopt this Procedure (ESAP #12).

Security Personnel.

Axian utilizes private security companies to provide security and access control at their offices and tower sites. Security at the strategic level is managed by the Group EHS Coordinator. OPCO EHS Managers manage security service providers’ day to day operations at each OPCO. A corporate Security Management Procedure was not developed at the time of appraisal. The Procedure will include provisions on screening of security service providers against basic on crowd control; requirement to carry out security risk assessments; regular refresher training; provision of adequate PPE and communication resources; reporting arrangements; use of arms; working conditions of security guards and compliance with Axian company policies and with this Performance Standard. Tanzania and Togo OPCOs will adopt this Procedure (ESAP #13).

 Tanzania OPCO will operate 370 existing towers. These towers occur across the country and overlap the following eco-regions: East African montane forests and moorlands; Southern Acacia-Commiphora bushlands and thickets; Central Zambezian miombo woodlands. Fourteen of these existing towers overlap with nationally protected or internationally recognized areas, such as Key Biodiversity Areas (KBAs): Dar es Salaam Coast KBA, Zanzibar Island-East Coast KBA, Zanzibar Island-South Coast KBA, Kilombero Valley KBA, Kilombero Valley Floodplain Ramsar site, and Ngorongoro Conservation Area UNESCO World Heritage Site (WHS) and KBA. At least 13 of these towers occur in modified habitats associated with human settlements, agriculture, or immediately adjacent to existing roads. One tower appears to occur in natural habitat within the Kilombero Valley KBA but this requires ground truthing. No changes relative to baseline conditions are expected for any of these sites.

All fourteen of these towers are treated as Critical Habitat based on the criteria for which the KBAs were defined (e.g. threatened species, migratory concentrations). One of these towers occurs within the Ngorongoro Conservation Area natural/mixed WHS, which exhibits multiple land uses, including wildlife conservation coexisting with community uses by Maasai. The tower in the WHS is located on the far eastern boundary of the WHS, and immediately adjacent to community farmland within the WHS. Consultation with UNESCO regarding this existing tower will be required.

Axian will update the E&S Policy to include PS6-compliant biodiversity commitments and develop a Group Biodiversity Procedure (as part of ESAP#1) for appropriate assessment and management of biodiversity risks for any purchase of existing sites or construction of new sites across the business. As part of this policy update, Axian will commit to avoiding construction of any future towers within Alliance for Zero Extinction (AZE) sites or World Heritage Sites. Axian will develop a Biodiversity Action Plan (BAP), including Biodiversity Monitoring and Evaluation Plan (BMEP), for the Tanzanian portfolio which will include: i) appropriate mitigation measures for existing towers, ii) describes additional conservation actions to achieve net gains for Critical Habitat; iii) identification and consultation with relevant stakeholders associated with management of areas treated as Critical Habitats (ESAP#14). The stakeholder component of the BAP will be integrated with the Stakeholder Engagement Plan (SEP).