This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012) considering that 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 E&S issues and risks associated with the project include:

-          continued implementation and adaptation of the existing ESMS to adequately assess and manage risks and impacts associated with the DRC-based operations;

-          adequate E&S resourcing at both a Group and OpCo level;

-          risks and impacts associated with the acquisition of brownfield tower sites;

-          consistent management of labor and working conditions in line with national legislation and implementation of existing occupational health and safety (OHS) policies and practices;

-          impacts on nearby community health and safety; and

Eastcastle DRC has adopted and implemented an ESMS which is aligned with IFC Performance Standard 1 and commensurate to the level of E&S risks associated with the Company’s proposed activities. The ESMS includes relevant E&S policies and procedures, risk identification processes, management and monitoring measures, emergency response procedures, and stakeholder engagement plans. Eastcastle plan to undergo ISO 9001 (Quality), 14001 (Environment), and 45001 (OHS) certifications once they have achieved suitable scale within their operations. Implementation of the ESMS is the role of the Eastcastle DRC SHERQ manager, who reports to the managing director and the group head of SHERQ.  

Eastcastle DRC has adopted a comprehensive E&S Management Plan (ESMP) that covers areas of general operations, site acquisition procedures, design and site construction procedures, and site operation methodology. As a component of the ESMP, Eastcastle have adopted an approach of avoidance and/or minimization of E&S impacts where feasible, however, where impacts are unavoidable the process for identifying E&S risks and impacts associated with Eastcastle DRC’s operations is twofold.

Greenfield sites are acquired through a defined site acquisition process, which is based on long terms lease or willing buyer/willing seller agreements, and then are subject to an Environmental Impact Assessment (EIA) where required. Where Eastcastle DRC acquires brownfield tower sites, they are subject to an E&S due diligence (ESDD) covering areas relating to land rights and tenure, environmental impacts, design specifications, security, resource efficiency, waste management, and accessibility. Identified gaps are addressed through a time-bound corrective action plan. Eastcastle DRC plan to have completed the ESDD process on all existing brownfield sites by December 2022 (ESAP 1).

Eastcastle DRC has adopted the existing E&S monitoring process, including the development of monthly management and monitoring reports (MMR) which are provided to senior management, as well as annual internal E&S audits presented to the board of directors. Eastcastle also has an E&S board sub-committee overseeing all E&S aspects of the business.

 Eastcastle DRC currently employs 37 direct workers and 13 contract workers. The Company has adopted the existing human resource (HR) policies and procedures developed by Eastcastle, including an employee handbook, grievance management mechanism, and policies on child and forced labor, and retrenchment. The existing HR policy framework also includes an anti-discrimination, harassment, and violence policy that includes gender specific requirements, including gender-based violence. HR is managed by an OpCo level HR manager.  

Labor and working conditions are defined within the employee handbook and are aligned with local labor laws. This includes key areas of work hours, overtime, benefits, leave, performance management, and freedom of association. Eastcastle DRC has also adopted and implemented the existing employee grievance mechanism which is aligned with the requirements of IFC PS2. 

Eastcastle DRC has adopted the existing OHS management framework that includes a risk identification and evaluation process, incident management and reporting procedure, emergency preparedness and response, and ongoing SHERQ training requirements. Eastcastle DRC has also implemented a Driving at Work policy as well as an in-vehicle monitoring system (IVMS) in all their vehicles.

All Eastcastle DRC contractors are subject to a pre-qualification process covering areas of labor practices, health and safety, and sustainability. Third party contractors are required to adopt and abide by Eastcastle’s ESMP and are monitored via a weekly construction supervision form.

 The Company’s operations primarily involve the construction and operation of telecommunication towers. The nature of these operations does not result in significant quantities of waste and emissions.

Currently Eastcastle DRC utilizes diesel generators for all their tower sites predominantly due to the lack and / or unreliability of existing grid connectivity. Where feasible, the Company is exploring the installation of solar / lithium-ion batteries to reduce emissions, and to manage operating expenditure. Should Eastcastle DRC adopt this approach, the Company will be required to conduct an adequate supply chain screening process related to risks of child and/or forced labor. As a component of the ongoing monitoring and reporting, Eastcastle DRC monitor monthly energy consumption.

As a component of the ESMP, Eastcastle DRC has formalized all solid and liquid waste management procedures (at both construction and operating sites), including the requirements of contractors to manage waste. Eastcastle DRC has also developed and implemented a standard operating procedure (SOP) for waste management.

The primary community health and safety risks associated with Eastcastle DRC’s operations occur during construction activities and include exposure to construction vehicles, and exposure to dust, noise and vibrations caused by constructions works. Operational phase health and safety risks are limited and may include tower failures and collapse and unauthorized site access. Through the implementation of the site selection process and ESMP, including contractor management, these impacts are largely mitigated and monitored.

The monitoring and management of electromagnetic frequency (EMF) is the responsibility of the active telecom tenants; however, Eastcastle DRC ensures that all required regulatory setbacks are considered during the site selection process.

Eastcastle DRC conducts a security risk assessment for each site which informs the security requirements. Currently, all sites are guarded by a third-party security provider. Eastcastle DRC has adopted the Security Management Plan that includes prescriptions for guard selection, rules of engagement (including minimum force), training, equipment, facilities, working conditions, and grievance management.

Eastcastle DRC plans to construct and operate over 500 tower sites. This infrastructure will occur across the country and will predominantly be located within existing urban centers. Eleven existing tower sites are located within the boundaries of the Lendu Plateau, a Key Biodiversity Area (KBA) and Alliance for Zero Extinction (AZE) site, while two are located within Irangi Forest, also a KBA. The towers are all within the footprint of existing urban areas. No changes relative to baseline conditions are expected for any of these sites.

As a component of the existing ESMS, under ESAP 2, Eastcastle will define their PS6 compliant biodiversity commitments in a Biodiversity Policy. As part of this update, Eastcastle will commit to avoiding, to the extent possible, construction of any future towers within AZE or World Heritage Sites. Should construction be deemed unavoidable, consultation with the AZE Secretariat and associated stakeholders will be required. Additionally, under ESAP 3, Eastcastle will update the existing ESMP, in particular the site identification and assessment process, to ensure the implementation of appropriate assessment and management of biodiversity risks for any future sites across the business.

The extent of Eastcastle DRC’s stakeholder engagement activities is commensurate to the nature of their operations and impacts. As a component of the ESMS, the Company has adopted a formal stakeholder engagement procedure defining their engagement approach and roles and responsibilities. Engagement is predominantly focused on site acquisition procedures, regulatory requirements, and grievance management.

As a component of the stakeholder engagement procedure, Eastcastle DRC have implemented a community grievance reporting process to receive and facilitate resolution of communities’ concerns and grievances relating to the Company’s environmental and social performance. In addition. Eastcastle DRC have also adopted a Whistleblowing Policy to allow for the reporting of breaches in policies and procedures.

Contact Person: Hisham Sabry

Company Name: Eastcastle Infrastructure Limited

Email: hisham.s@ecinfras.com