IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Sonatel has adopted an Integrated Management System (IMS) policy which commits it to operate in compliance with national regulatory requirements, promote sound E&S practices, and an accident-free workplace. Sonatel’s IMS has been certified in accordance with ISO 9001 (Quality), ISO 14001 (Environment), ISO 26000 (Social Responsibility), ISO 45001 (OHS), and ISO 50001 (Energy Management). As per ESAP #1, Sonatel will enhance its IMS to ensure adequate E&S management of ongoing and future operations in accordance with the principles of IFC Performance Standards (PSs) and WBG EHS Guidelines (General and Telecommunications) and will ensure that it becomes applicable to the company to be acquired under the cross-border investment under IFC’s project.
Sonatel identifies and manages E&S risks and impacts associated with its operations through screening against the relevant ISO certification principles, applicable national standards, and E&S regulatory permits. This includes for example, environmental permitting for optic fiber cable laying and installation of new base transceiver stations (BTS). Going forward, as part of its IMS, Sonatel will implement an E&S Assessment and Management Procedure (ESAMP) for the operations and maintenance (O&M) of existing assets and design and constructionof new assets, in line with IFC PS and relevant WBG EHS Guidelines, including specific procedure to avoid and manage potential impacts related to biodiversity and land acquisition (permanent or temporary). The ESAMP will include a E&S due diligence procedure for the potential cross-border acquisition under this project, including the identification of time-bound E&S corrective action to ensure compliance with IFC PS. (ESAP #2)
As part of the enhanced IMS under ESAP #1 , Sonatel will develop specific E&S procedures for: E&S training; contractor EHS management; environmental management (water, waste management and pollution prevention); road transport risk management; electro-magnetic frequency monitoring; land acquisition and resettlement; security risk management; supply chain risk management; biodiversity risk management; and stakeholder engagement – all in line with IFC PS requirements and WBG EHS Guidelines (General and Telecommunications). (ESAP #3)
E&S responsibility is shared between the HR Director, whose team includes Occupational Health Doctors and Safety Officers; and the Director of Audit, Risk and Quality (ARQ) Department who supervises the IMS Manager and the Environmental Compliance Officer. The HR Director also oversees the teams in charge of Labor, Security and Contractors management respectively. Per national requirements, the company has appointed a Health, Safety and Hygiene Committee to support OHS programs implementation. However, it is not clearly specified how contractors E&S compliance is enforced and monitored. Going forward Sonatel will assign a qualified responsible for the development and implementation of the IMS. Additionally, it will incorporate a requirement in contractors’ agreements to appoint competent E&S personnel within their structure to ensure EHS oversight and drive compliance in line with Sonatel’s enhanced IMS. (ESAP #4)
As part of its IMS, Sonatel has developed an emergency response procedure and a Disaster Recovery Plan which include site-specific measures to respond to potential environmental or OHS accidental occurrences, including flooding risk. The procedures adequately define roles, responsibilities, and response measures; and set out requirements for staff and security guards training, for work in remote locations, periodic drills and include provisions for site operators emergency kits.
Sonatel reports its ESG performance in its Annual Report and in the Corporate Social Responsibility (CSR) Report (available at https://sonatel.sn/rapports-annuels/). The CSR Report contains Sonatel’s performance against its IMS (ISO 14001, ISO 45001 and ISO 26000) goals, on environmental, OHS, HR and social responsibility performance and against the 17 UN Sustainable Development Goals. Internal performance is driven by process pilots appointed by the management and the ARQ Department is tasked to monitor compliance with the different targets as part of its internal audit program. ARQ also prepares quarterly performance reports for top management and proposes new targets for the upcoming year to achieve continuous improvement. As part of ESAP #1 Sonatel will develop key performance indicators (KPIs) and auditing requirements to monitor compliance with the enhanced IMS objectives, for all its E&S aspects as defined by IFC PSs, applicable legal requirements and any applicable parameters of the relevant WBG EHS Guidelines.
PS2: Labor and Working Conditions
As of December 2022, Sonatel had a total of 2876 employees, including 1796 direct staff (permanent and temporary) and 1080 third-party workers; with 38% of the workforce being women. Contractors workers are hired for different activities, based on scope and duration (tower construction, call centers, O&M, fiber cable works, etc.
Sonatel has documented HR policies that have a commitment to compliance with local laws and to achieving the objectives of UN’s Sustainable Development Goal 8 on full and productive employment and decent work for all. The HR policies, employment terms and conditions are based on local labour laws and are broadly aligned with IFC’s PS2 requirement.
The HR Manual outlines the key commitments required of the Company and its employees, regarding business ethics, corruption, gender equality, harassment, gender-based violence, freedom of association and collective bargaining, safe working conditions and training, prohibition of child and forced labor for its direct and third-party workers. It also sets out the principles for fair recruitment, non-discrimination, employee salary, compensation and leave, and has established a whistleblowing policy through a toll-free number. The 'Internal Regulations’ define the company’s policy in terms of staff code of conduct, disciplinary actions, performance management, learning and development, terminations (dismissal, retirement, resignation and death). HR performance targets are defined in the IMS and monitored as part of the internal audit system. In 2022 Sonatel achieved the Gender Equality & Diversity Certification by European and International Standard (GEEIS).
Workers contracts outline their engagement terms as well as stipulated working hours, overtime arrangements, compensation and benefits, salary and wage payment, leave (annual, sick, maternity, paternity), confidentiality policies, statutory deductions, and notification addresses.
Based on the local labour legislation, Sonatel is signatory to Senegal’s interprofessional collective bargaining agreement, which guarantees employees freedom of association and encourages all employees to exercise their rights through election of their representatives and participation to union activities.
Sonatel has implemented a whistle-blowing policy focused on customers complaints but allowing also for reporting of general workplace harassment. Going forward Sonatel will document a workers grievance redress mechanism (WGM) consistent with the requirements of IFC PS 2 and will provide for receipt and resolution of grievances on multiple platforms including anonymous grievances and will allow for specific measures for identification and management of complaints related to gender-based violence and sexual harassment (GBV&SH). (ESAP #5)
Sonatel has developed an OHS Policy and Management System that is certified for ISO 45001 and audited periodically. The System includes procedures for risk assessment, training, awareness and competence, accident investigation, operational controls, including ‘permit to work’ controls for high-risk activities, monitoring and auditing, among other elements. Incident investigations are led by the Safety Officer with the support of his team and the OHS Doctors. As specified under ESAP #1 and ESAP #4 respectively, Sonatel will cascade down the requirements of the OHS management system to its contractors and will incorporate EHS manpower requirements for each contractor’s structure.
Sonatel’s workforce includes a significant number of outsourced and contractor workers. There is a contractor selection and vetting procedure which includes general performance requirements prior to awarding a contract. Going forward, as part of the Contractor Management Procedure under ESAP#3 Sonatel will (i) develop a Code of Conduct, outlining the values and behaviors expected of third parties, suppliers, and business partners, (ii) integrate environmental and labour requirements into the project contracts, commensurate with the risks arising from respective operations, including specifications for OHS, child labour and forced labour. The clauses will include representations for audit, remedial action and where no improvement on significant non-compliances is observed, exit by Sonatel.
PS3: Resource Efficiency and Pollution Prevention
Sonatel has implemented an energy management system certified against the requirements of ISO 5000. In 2022, the company reported a total energy consumption of 113,7 Gwh including 8% of green energy, through the introduction of solar power at BTS sites in rural areas or replacing lead-acid batteries with lithium-acid batteries. Further energy savings have been achieved during the current year by demoting obsolete equipment.
Sonatel monitors its GHG emissions as part of its IMS and reports emissions in its public Annual Report. The company reported a total of 72,462 tCO2e in 2022, including Scope 1 (emissions from fuel consumption, power generation and vehicles), Scope 2 (emissions from purchased electricity) and scope 3 (emissions from its supply chain, products usage and customers). Water is supplied from municipal sources, but total consumption is not monitored as Sonatel considers that quantities are limited and primarily used for routine administrative, sanitary, and cleaning purposes. As part of its ESMPs (per ESAP #3), Sonatel will develop a water management procedure consistent with WBG EHS Guidelines.
The main vulnerabilities of Senegal to climate change include extreme temperatures, flooding events, and severe droughts. Sonatel has adequately assessed the potential risks and impacts resulting from climate change and developed climate change mitigants, including hazard mapping, climate resilient infrastructure, emergency response plans and Disaster Recovery Plans.
Potential pollution risks from Sonatel’s operations are associated with the use of backup generators for uninterrupted power supply in areas with unreliable connection to the electrical grid. Such risks will include potentially elevated noise levels and ambient air pollution. In addition, fuel handling and storage for the generators may be a source of soil and/or groundwater contamination in case of spill or loss of containment. Solid waste generated includes used batteries, electrical and electronic waste, scrap metal, oil and diesel filters, and general waste from maintenance and operations. Lubricant oil and lead-acid batteries is the main hazardous material found on sites. The ISO 14001 system policy provides commitment to minimize adverse impacts on the environment and promote efficient resource utilization. The company has developed a waste management procedure’ and has identified waste management as risk under its risk register to ensure EHS-related risks of all routine and non-routine activities are identified, analyzed and mitigated as required. As per ESAP#3, the company will update its Waste Management Plan as part of the enhanced IMS procedures to align with the requirements of the WBG EHS Guidelines.
Sonatel manages waste in accordance with its ISO 14001 system targets and applicable legal requirements. Waste management performance is reported in the public Annual Report. A total of 56,71 tons of waste was disposed in 2022, including organic, paper, plastic and electronic waste. The company implemented waste sorting and recycling in partnership with licensed local small enterprises. Hazardous waste and lead acid batteries are temporarily stored before being collected and disposed of by authorized third parties. Obsolete electrical equipment is either reconditioned for redeployment or sold. Wastewater is routed to the municipal sewage system where available or disposed to sewage system.
PS4: Community Health, Safety and Security
The key community health and safety aspects associated with this project include potential risks from electricity and EMF; unauthorized access to fixed telecommunication assets; security arrangements; and traffic & road safety. As part of the E&S procedures under ESAP #3, Sonatel will include community risk considerations in its Emergency Preparedness and Response Plan (EPRP) and will develop a Community Health and Safety Procedure aligned with national requirements, IFC PSs, and WBG EHS Guidelines to address risks to communities and members of the public at large.
Company vehicles and transportation means conducted by Sonatel staff or by its contractors will be regulated through a Transport and Traffic Management Plan, which will be part of the Company’s E&S procedures, aligned with national requirements, IFC PS4 and WBG EHS Guidelines.
Sonatel security framework consists of hiring third-party contractors, such as security companies, to provide unarmed security at their offices and sensitive installations. Under ESAP #3, Sonatel will augment the existing Security Management Plan to align with the requirements of IFC PS4.
PS6: Biodiversity Conservation and Sustainable Management of Natural Living Things
Sonatel operates 2830 existing towers across the country and 283 towers overlap various protected areas and key biodiversity areas (“KBAs”). Ten of these towers overlap with the Niokolo-Koba National Park World Heritage Site and one with Djoudji wetlands World Heritage Site. The one located in Djoudji wetlands constitute a natural habitat. None of the towers overlap with Alliance for Zero Extinction sites of the country. The rest of the towers 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. To ensure appropriate assessment and management of biodiversity risks for existing sites and any future acquisition or construction on new sites across the business, the company will (i) include PS6-compliant biodiversity commitments in its enhanced IMS (per ESAP #1) and (ii) develop a Biodiversity Risk Management Procedure (per ESAP #3) for sites located in protected areas and KBAs which may include additional biodiversity protection measures and additional enhancement programs for the AZE and World Heritage Sites (WHS), as needed. (ESAP #6)
Biodiversity-related stakeholder components will be integrated within the Stakeholder Engagement Plan (“SEP”) (per ESAP #9 below); relevant stakeholders associated with UNESCO, the AZE Secretariat and the Key Biodiversity Area (KBA) Secretariat will form part of key stakeholders to be scoped into the SEP.
