Risks and potential impacts relevant to the application of PS5, PS6, PS7 and PS8 for this investment are managed by the implementation of the corporate E&S management system (ESMS) as discussed under PS1 during the development of sites.  The corporate ESMS will screen for E&S risks as part of the procedures required for the development of new sites, enhancements to existing sites, and for mergers and acquisitions of assets.                                                   

 This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on the information reviewed by IFC, the 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.

Key areas of E&S focus include: potential impacts associated with construction and operation of telecommunications infrastructure; labor and working conditions (including employees' and contractor workers' occupational health and safety (OHS)); HR policies and labor practices, including provisions for addressing risks of gender-based violence and harassment (GBV&H); worker’s grievance mechanism; freedom of association and relationship with unions; pollution prevention and abatement; resource efficiency; waste and hazardous materials management; stakeholder engagement and grievances; and E&S assessment and risk management during the development of new sites and ancillary infrastructure, including potential impacts on areas of high biodiversity value or indigenous peoples’ lands.                                                  

 Environmental and Social Assessment and Management System

Telecom has developed and implemented an ESMS that has been certified separately as ISO14001 (for environment), ISO 26000 (for CSR), and ISO 45001 (for OHS) at the corporate level and has been implemented in Telecom and all companies that were acquired in 2018 in Argentina. The companies that were part of the merger in 2018 and 2019 have been completely incorporated into Telecom’s ESMS. 

Organizational Capacity and Competency

The Company has qualified officers at the corporate level (i.e., Environmental, Health and Safety (EHS) and Sustainability Managers) overseeing the implementation of the ESMS and relevant mitigations of E&S risks and impacts of the Company’s operations. The E&S organization includes an EHS manager for operations in Argentina. The safety management group has 31 employees, the OHS department has 63 employees, and the Sustainability team has 12 employees.

Policy

Telecom’s E&S framework provides for E&S policies and procedures, which are made available to staff and includes provisions for training of Company’s workers on E&S management.

In 2021, Telecom developed a new corporate environmental policy, based on ten general and strategic principles that guide the actions of all areas of the Company. These principles include: (i) risk management and minimization; (ii) regulatory framework; (iii) technology; (iv) contribution to climate change; (v) management of indicators and Key Performance Indicators; (vi) resource efficiency; (vii) waste management; (viii) organizational culture and conduct; (ix) value chain; and (x) transparency - systematic and objective communications with internal and external stakeholders. Telecom is in the process of strengthening its ESMS by developing a separate sustainability policy. The new sustainability policy will be aligned with the IFC’s Performance Standards (IFC PS) (ESAP #1).

Identification of Risks and Impacts

Telecom has a Risk Management Policy that follows the guidelines of the Enterprise Risk Management-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) and which is implemented through an Integral Risk Management Process and supervised by an operational committee.

For the development of new facilities (e.g., towers, buried fiber optic networks) any land required is acquired or leased through “willing buyer-willing seller” transaction, and the site selection process is based on securing sites that meet criteria established by the local municipality. The local regulatory requirements for new facilities can include the development of an Environmental Impact Assessment (EIA), in consultation with affected communities, among others. E&S considerations, fully consistent with IFC PS, are currently not specifically integrated into the site selection process, that presently is based mostly on: (i) proximity to power sources, and clients; (ii) sufficient area to accommodate the tower and associated infrastructure; and (iii) social acceptability.

To align and meet the requirements of IFC PSs, for future developments in non-urban zones, Telecom will seek to avoid the construction of new assets in areas of high biodiversity value, such as Legally Protected Areas, Internationally Recognized Areas (IRAs), and particularly Natural and Mixed World Heritage Sites and Alliance for Zero Extinction sites.  The company, as part of its ESMS, will develop an E&S Screening & Management Procedure (ESSMP) (ESAP #2).  The ESSMP will (i) define an approach to screen, for areas of E&S sensitivity, and (ii) identify the steps required when new towers are proposed in such areas, which will include consultation with the relevant stakeholders (e.g., legally protected area management, conservation organizations that have designated IRAs) to ensure compatibility with the values of these areas. The ESSMP will also include measures relevant to the rehabilitation of disturbed areas with, for example, native species, management of invasive species, soil erosion, forest clearance, managing human access, and ongoing maintenance, as part of the management of biodiversity-related aspects for planned sites in line with IFC PS6.   As per the ESSMP, when avoidance of IRAs and legally protected areas for planned sites is not feasible, the company will develop a Biodiversity Action Plan (BAP) to define actions to contribute to the conservation objectives of these areas, in consultation with relevant stakeholders.

Management and Monitoring of E&S

Telecom’s Sustainability Department and Institutional Affairs within the Corporate Directorate of External Communications and Sustainability and the Quality and Environmental, Health and Safety (QHSE) Department, within the Directorate of HR of Telecom, handle all matters related to the ESMS and CSR functions, including the processing of the external grievances received from the community and external stakeholders. The roles and responsibilities of QHSE representatives include conducting internal Environmental and OHS, audits, maintaining compliance with management system and local requirements, monitoring, and reporting E&S performance, and overseeing external auditing.

As per ESAP #3, the Company will assign internal responsibility within the sustainability and HR teams to oversee and monitor the implementation of the ESSMP and sustainability and environmental policies.                                                   

 Labor and Working Conditions

Telecom employs approximately 21,800 direct workers in Argentina. The number of workers employed indirectly through agents and contractors totals about 31,000 and are primarily associated with commercial services (13,500 workers), operations support for connectivity and installations (6,500), and building of new infrastructure (2,500). The Company’s workforce includes 28% of female employees, and 22% for managerial and supervisor positions. Telecom has developed and implemented a set of HR policies and procedures consistent with IFC PS 2, which are made available to the Company’s workers. In line with local legislation, the Company recognizes freedom of association of its workers, and approximately 70% of the direct workforce, and a similar proportion for contractors’ workers, participate in a union labor. Regular engagement with unions is managed by Telecom’s unions representative who negotiates collective agreements and continuously monitors workers’ concerns which have been primarily linked to wages due to inflation, and working conditions.

The Company’s policies promote fair treatment, non-discrimination and equal opportunities for its employees, regardless of race, gender, religion, nationality, language, age, sexual orientation, civil status, handicapped status, or socio-economic status.  As part of the corporate policy and program for workforce diversification, the Company has formed two committees for anti-harassment, gender and occupational wellness, that are currently developing an internal protocol to actively manage cases of discrimination and GBV&H. The protocol is in draft form and will be rolled out in the upcoming months.

Telecom has corporate policies (HR and Code of Conducts and Ethics) with their respective procedures in place to ensure that grievances of workers, including contractors’ workers, are generally resolved within 30 days, with measures to ensure confidentiality and a channel for appeals. Ongoing engagement with workers is also undertaken through employees’ satisfaction surveys (Encuestas de Clima) and different communication channels including mailing, Yammer, online forums where CEO and management address employees’ concerns, and the On-to-One initiative between employees and the CEO for informal engagement around objectives and challenges.

Third-party workers

Compliance with local labor regulations in terms of labor and working conditions of workers engaged through contractors and agents are monitored two times a year by Telecom’s personnel through document review, and it is planned to use robotics so contractors’ payslips can be monitored in a more systematic manner on a quarterly basis.

Telecom engages contractors to perform core functions with safety risks including work at height, work in confined spaces, electrical work, and tower maintenance. Under the contractual agreements with its contractors and suppliers, Telecom requires compliance with the Company’s E&S, and labor policies and procedures. Telecom performs periodic labor audits of its contractors. The results are communicated to the contractor, as needed with a corrective action plan and deadlines for implementation.

To support the monitoring of labor and working conditions of Telecom’s workforce and contractors in line with PS2, under ESAP #5, Telecom will undertake a labor audit of labor and working conditions and occupational health and safety against IFC PS2 and local regulatory requirements and will develop a time-bound action plan to implement the emerging recommendations. 

Occupational Health and Safety (OHS).

The Company has implemented comprehensive OHS policies and procedures in line with corporate level E&S framework and includes OHS training on work at height, accident prevention, fire and electrical safety, and management of any spills of fuel or other chemicals and contractors on OHS matters. Health and safety performance is measured by the Company, and annual statistics (severity and frequency index) are reported to the government and ART (Argentinian labor risk entity). The Company reports OHS performance on a regular basis and is considered below the benchmark for this type of industry. Most of the occupational incidents reported occurred during the employees’ commute to work and are directly related to injuries, transportation, commuting and incidents while walking on uneven sidewalks and surfaces.  Serious OHS-related accidents are investigated by both the Company and the affected subcontractors, to evaluate the root cause of the events, and to prepare an immediate corrective action plan and mid-term plan to manage and improve the OHS performance of contractors and own personnel and audited by several programs under local law and labor insurance systems in the country. The Company has already implemented corrective actions related to previous accidents as per the governmental labor program to manage fatal accidents - PRAM (Programa de Reduccion de Accidentes Mortales).

A Transport Management Procedure has been developed by Telecom with provisions for driver training and competence checking, journey management to reduce risks of accidents, vehicle maintenance requirements and traffic incident reporting. During the last three years, Telecom reported a low incidence rate of traffic accidents, within the incidence shown above, with occurrences involving Company’s vehicles and private employees’ cars during commuting to work, with minor consequences. 

Appropriate OHS training is provided to Telecom’ staff.  As part of the OHS policies, the Company ensures that its contractors implement the required health and safety measures and the relevant training for their workers. This includes monthly review of contractor’s documentation to ensure alignment with Telecom’s policies and procedures. Telecom proactively monitors LTI (Lost Time Injury) and minor incidents assessing frequency and recurrence and where appropriate setting up internal corrective actions to minimize risks. Contractors are required to provide protective clothing and equipment to their workers and the Company supervises and enforces these provisions.  For daily activities and field work, the Company enforces the use of hazard evaluation checklists and work permits for its own staff and contractors’ employees in all operational activities. In 2021, Telecom further improved OHS policies and procedures to incorporate specific procedures for work at hights, additional training and a permitting process requiring workers to be accredited to undertake certain works.

 Resource Efficiency and Greenhouse Gas (GHG) Emissions

The Project’s carbon footprint covers emissions from grid electricity consumption and fuel consumption from vehicular movements associated with the operation and maintenance (O&M) activities and from other sources, including any onsite generators at the tower sites. The Company publishes GHG emissions as part of annual sustainability reports. In 2021, Telecom reported GHG emissions of about 315,000 tons CO2eq per annum from their operations.  The GHG emissions directly linked to the activities to be financed by this operation are expected to be limited.

The Company has implemented a corporate program (named “Climate – Lighting – Control”) aimed at energy efficiency and energy savings.  In the Company’s buildings where the program has been applied, significant energy savings were reported. In 2021, Telecom implemented a new energy supply matrix promoting the use of renewable energies in its operations, consistent with the Renewable Energy Law (Ley de Energia Renovable) in Argentina. 

Pollution Prevention

At Telecom’s sites, operations inevitably generate some waste materials, that need to be properly disposed of. Telecom has policies and procedures for waste management (collection, recycling / reuse, disposal) consistent with of the World Bank Group EHS Guidelines for Telecommunications and it is a corporate requirement to use certified companies for the final disposal of waste.

In 2021, Telecom became the first technology Company to join the local circular economy network of the government of the city of Buenos Aires, which seeks to strengthen the recycling system through the involvement of all actors in the region.

Telecom’s sites generally use power from the electric grid, with backup power provided by batteries wherever possible, thereby limiting the use of fuel tanks, generators, and associated noise and potential fuel leaks. A small percentage of Telecom’s base stations/telecommunications towers use diesel generators for backup power. Almost all fuel tanks connected to those generators have a capacity between 400-500 liters, while core network equipment requires only one site to have a principal fuel tank of 2,500 liters with a secondary tank of 1,000 liters, and another site with a principal fuel tank of 1,400 liters and a secondary tank of 200 liters. Telecom has policies and procedures to provide for secondary containment around all fuel tanks – with a minimum 110% capacity of the tanks’ volume – and policies/procedures for handling any fuel transportation and spill, consistent with of local regulations and World Bank Group EHS Guidelines for Telecommunications.

Telecom includes terms in its agreements with contractors that cover pollution prevention and abatement. The Company monitors compliance with terms in its agreements with contractors and seeks improvement if non-compliance is identified.                                                  

 All Telecom’s towers are designed according to relevant engineering design standards, with the required safety criteria to prevent risks associated with structural failures and meet good international industry practice, and review of the technical feasibility analysis. Telecom incorporates appropriate fencing, locking and other design measures in all towers to ensure that communities are protected and prevented from entering tower areas where risks to community health and safety are the highest. Site dimension, selection, and setback distance criteria (for aspects such as control and monitoring of electric and magnetic fields (EMF) exposure, constructability and infrastructure and equipment safety) are part of the ESMS to ensure prevention and mitigation of community health and safety risks, during site selection, construction, and operations of each tower. Similarly, a process is followed to deploy buried fiber optic cable, with approved civil work and control of the contractors to minimize impact on the communities, accidents and traffic. 

Presently, the Company has a corporate procedure (Normativa Telecom 03/PC-3036 – Medición de Radiaciones No Ionizantes - RNI) with provisions for the assessment of EMF risks. Annually, for example, the Company performs more than 2,000 measurements of EMF levels at its sites. In addition to meeting local requirements, the procedure requires that readings are done for each of the following cases: (i) before commissioning new sites; (ii) increase in power/ capacity of existing equipment; and (iii) decommissioning of antennas and equipment. Management measures include institutional controls and security (fences, electronic access control, and/or guards) at the towers and other sites, and installation of signage to create awareness of EMF hazard (among others) and contact information for any inquire or complaint from the community. 

Emergency Preparedness and Response

Emergency preparedness and response services are subcontracted by Telecom to specialized companies that are certified in accordance with Argentinian applicable laws. These companies provide several related services, including security, surveillance and buildings’ access control, emergency preparedness and response services, and evacuation management for all main buildings within the urban areas and for remote facilities. Telecom has a corporate-level Emergency Preparedness and Response Plan, ensuring consistency among operations and subsidiaries and addressing all risk scenarios which are applicable for the operations of the group.

Security Personnel

Telecom does not engage any armed or non-armed security services to guard operational tower sites or remote locations. The large facilities (e.g., office buildings, data centers) are covered by third party security service with unarmed guards and the support of electronic security and CCTV (closed-circuit television) systems. The signals from electronic security are monitored by a centralized location at the headquarters’ building in Buenos Aires.