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 Impact
Policy. Woda has adopted an Integrated Management System (IMS) Policy detailing the company’s approach to managing their operational risks, such as labor and human rights, environmental impacts, and occupational health, and safety (OHS) among others in accordance with both host country legislation and good international industry practice (GIIP).
Identification of Risks and Impacts. The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and requirements. As per the requirements of the Ethiopian EIA Proclamation (No. 299/2002) and other relevant statutory requirements, Woda completed Environmental and Social Impact Assessments (ESIAs) for both their tower fabrication and cable and wire manufacturing facilities in 2022. The ESIAs identify key impacts associated with the operation, including waste management, noise, air pollution, water, and health and safety.
Woda has also developed an Aspect and Impact analysis whereby key operational risks are identified for warehousing, tower and cable workshops, galvanization, maintenance, administration, and IT facilities and operations. The process includes a description of the risk, control measures, roles, and responsibilities. In addition, the company has developed Job Risk Assessments (JRA) for all on-site activities, whereby key risks and mitigation measures associated with each activity are identified.
Management Programs. Woda is currently ISO 9001 (Quality Management Systems), 14001 (Environmental Management Systems), and 45001 (Occupational Health and Safety Management Systems) certified. These certifications are valid until November 2026. Woda has developed and implemented an Environmental and Social Management Plan (ESMP) detailing their operational management and mitigation requirements. The ESMP covers key areas such as environmental pollution, waste management, air quality, occupational noise levels etc. The ESMP includes roles, responsibilities, and CAPEX requirements for five years of implementation. Compliance with the ESMP is audited by the Ethiopian Environmental Protection Agency (EPA) on an ongoing basis.
In addition, Woda has developed several management procedures and guidelines covering a variety of operational areas. This includes procedures related to hazard and risk identification, contractor management, design and development, hazardous materials, internal audit, procurement, and waste management among others.
Organizational Capacity and Competency. Woda has a Quality, Health, Safety and Environment (QHSE) department comprised of a QHSE supervisor and two support staff. The department’s primary function is to oversee the ongoing implementation and monitoring of the company’s ESMS. Woda has also implemented a Training Awareness and Competence procedure to support awareness and capacity building in relation to the overall IMS. This includes, among other requirements, general QHSE training, orientation, awareness, and the definition of core competencies within each department.
Emergency Preparedness and Response. Woda has implemented specific evacuation plans for each of its operational facilities, including the cable and tower workshops, office building, galvanization plant, and canteen. The company also has trained and certified firefighters and first aiders available on each shift. As per ESAP #1, the company will consolidate its emergency procedures into an Emergency Preparedness and Response Plan (EPRP), aligned with the requirements of IFC PS1, detailing potential emergency scenarios and how the company will appropriately respond to these. This will include, where relevant, collaboration with local authorities. The EPRP will also detail the life and fire safety (L&FS) requirements to minimize risk and help prevent loss, injury, and death from fire. This will include the relevant fire permits obtained from the local authorities.
Monitoring and Review. Monitoring requirements within the company are managed under the Health, Safety, and Environment (HSE) performance monitoring procedure, and the Internal Audit procedure. The latter is used for assessing the effectiveness of Woda’s IMS and its conformity to the company’s internal requirements. The company's monitoring requirements are managed under the Health, Safety, and Environment (HSE) performance monitoring procedure and the Internal Audit procedure. The latter is used to assess the effectiveness of Woda’s IMS and its conformity to the company’s internal requirements and to the requirements of GIIP.
As a component of the ESMPs developed for the project, compliance monitoring plans have been developed and implemented. These plans detail the minimum statutory monitoring requirements to ensure compliance with recommended environmental protection standards, including waste, air quality, traffic, noise, and OHS. In addition to ongoing compliance monitoring, Woda is subjected to quarterly inspections and audits by the national EPA. The audits consider assessment methodologies, liquid and solid waste management, and health and safety. As per the latest EPA directive submitted to the company, they have hired an external auditor to support their ongoing monitoring requirements.
Woda are also subjected to surveillance and external compliance audits in order to maintain their ISO 9001, 14001, and 45001 certifications. The last surveillance audit was conducted in December 2023.
PS2: Labor and Working Conditions
Human Resources Policies. Woda currently has approximately 340 directly employed workers and 20 contract workers. The workforce has a male to female ration of approximately 75:25. Woda has developed a number of policies and procedures in relation to their human resource (HR) management, including an IMS and Grievance Management policies, and procedures relating to contractor management, procurement, training and awareness. The company has also developed a Worker’s Manual detailing the company’s general employment principles, culture, and code of conduct. These policies and procedures are largely aligned with the requirements of national legislation and IFC PS2.
Working Conditions and Terms of Employment. Labor and working conditions within the company reflect the provisions of the Ethiopian Labor Proclamation No. 1156/2019. As per the requirements of local labor legislation, all workers are provided with a written contract governing their terms of employment.
The Worker’s Manual covers key aspects of labor and working conditions, including recruitment, onboarding, working hours, leave, training, resignation etc. The company operates six-days a week, with workers required to work 8-hours per day, with a one-hour lunch break. Where work hours go beyond the stipulated 8-hours, overtime is paid at the appropriate rate. Worker remuneration is comprised of a basic salary and various other allowances. While Ethiopia does not currently have a legislated national minimum wage, wages are benchmarked against industry norms. In addition, Woda has implemented various incentives including performance-based bonuses. Woda also provides workers with social insurance, meal subsidies, communication allowances, and transport services.
Woda provides on-site accommodation for approximately 50 workers. As per ESAP #2, the company will conduct an assessment and gap analysis of the existing worker accommodation relative to the requirements of the IFC/EBRD guidance note on Workers’ Accommodation. Based on the findings the company will incorporate these into the time-based action plan to address identified gaps.
Workers’ Organizations. As per the requirements of the Ethiopian Constitution, Woda respects the rights of workers to join or form unions and/or worker’s associations of their choosing. Currently, there is no active labor union at Woda, however, in December 2023, workers established a ‘Workers' Mutual Aid Association’ with the objective of advocating for worker’s welfare. The association currently has approximately 250 members and engage with Woda management on an ongoing basis.
Equal Opportunity. As per the Worker’s Manual employees are given equal opportunities for employment and promotion, regardless of their ethnicity, age, gender, or religious background.
Grievance Mechanism. Woda has developed and adopted a Grievance Policy detailing the procedure for workers to raise grievances. The policy allows for the submission of physical, telephonic, and electronic grievances. Woda has established a grievance committee to assess grievances and assign them to the relevant party. Woda maintains a grievance register, however, it has not received any formal grievances to date. As per ESAP #3, Woda will update the Grievance Policy to allow for the submission of anonymous grievances as per the requirements of IFC PS2.
Protecting the Workforce. As per the company’s IMS Policy, Woda does not support or condone any form of child or forced labor. As per the Worker’s’ Manual, the company does not employ anyone under 18 years of age.
Occupational Health and Safety. Woda has developed an OHS management system aligned with national law, ISO 45001, and requirements of IFC PS2. This includes several safety guidelines aligned with the National Examination Board in Occupational Safety and Health (NEBOSH) requirements, relating to hazard identification, driving, electrical, fire, forklift, hazardous substances safety etc. Woda has also adopted a Personal Protective Equipment (PPE) policy defining the company’s minimum PPE requirements. The company has also partnered with international consultancies and development organizations to further enhance and refine their health and safety practices where necessary.
The company is in the process of finalizing the adoption and recognition of its safety committee which comprises six management and six employee representatives. Woda maintains an incident register and formal incident investigation procedure. In 2023 Woda recorded two lost time injuries, resulting in a Lost Time Injury Frequency Rate (LTIFR) of 2.9.
Workers Engaged by Third Parties. Woda utilizes a limited number of third-party service providers. As per Woda’s IMS Policy, all service providers and other external parties are required to adhere to Woda’s policies and procedures. The company has also implemented a Contractor Management procedure detailing the selection, evaluation, management, and monitoring of third-party service providers. The procedure includes involvement of the QHSE supervisor, including evaluation and monitoring of contractor’s health, safety and environmental (HSE) practices and performance as per Woda’s polices and valid work permits.
Supply Chain. Woda sources various materials, including angle steel, welding pipes, steel plates etc. through various suppliers, including Zhaowei. The company has implemented a basic procedure for selecting and evaluating service providers and suppliers. Zhaowei has also implemented a Supplier Code of Conduct that largely aligns with PS2 requirements and the responsible business alliance principles. As per ESAP #4, Woda will develop a company specific supply chain management system aligned with PS2 requirements and acceptable to IFC that includes: i) a procurement policy and supplier code of conduct that addresses child labor, forced labor, and significant safety issues as per PS2; ii) inclusion of contractual clauses requiring suppliers’ compliance with the code of conduct; iii) a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the code of conduct; iv) a formal process for supplier engagement, remedy or disengagement in case of unresolved non-compliances.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. Woda currently utilizes electricity from the national power grid for all their operational activities, sourced from an onsite 50MW substation operated by the Ethiopian Electrical Utility (EEU). The company makes limited use of small capacity diesel generators where portable power is needed for welding and grinding requirements. It is estimated that Woda’s greenhouse gas (GHG) emissions resulting from the use of these energy sources is 35.13 tons of CO2 equivalent per annum.
Water Consumption. Woda sources its water from an onsite borehole. The company’s current water consumption is relatively limited and predominantly associated with its galvanization process, and daily domestic use. The company also provides water to the local community as required. As per ESAP #5, Woda will develop a water monitoring, testing, and reporting procedure as a component of their ESMS. This will include monthly groundwater consumption, quality testing (and treating as required for human consumption) and the identification, where feasible, of viable water conservation measures within the company’s operations.
Waste Management. As a component for their ESMP, Woda has implemented a Waste Management procedure detailing the sorting, handling, storage, transport, and disposal of all waste streams generated by their operation. The procedure's implementation and monitoring is the QHSE Manager's responsibility. Woda currently segregates waste by type and stores the waste in dedicated areas. Where feasible, Woda prioritizes the reuse and/or recycling of solid wastes such as plastic, paper and glass, while any waste metal is sold to scrap metal merchants.
Hazardous Materials Management. Woda has developed a hazardous material procedure to identify its primary hazardous materials, and the risks and impacts associated with their storage, handling, and use. This includes the maintenance of a Hazardous Substance register and Materials Safety Data Sheets (MSDS). The procedure further defines the handling, storage, and disposal requirements. Hazardous substances Woda uses are primarily associated with their galvanizing process, including alkaline caustic solutions, hydrochloric acid, zinc chloride and ammonium chloride.
As per the Hazardous Material and Waste Management procedures, hazardous waste generated by Woda is labeled and stored in controlled areas and collected and disposed of by accredited service providers. Waste manifests for such disposal are maintained.
PS4: Community Health, Safety and Security
Community Health and Safety. Woda’s operation is located on a 100ha industrial park approximately 7km’s outside of Sebeta. Given the location of the operation, no significant additional impacts to the health, safety, and security of the local community are expected. The company does not operate 24 hours a day therefore impacts of noise are minimal. Woda does not operate an extensive truck fleet, with only two trucks maintained by the company. The company has adopted a Driver Safety guideline describing driver behavior and best practices. Completed towers are transported in smaller components and assembled on site. Woda is not responsible for the transport of tower components, this is undertaken by the customer.
Security Personnel. Woda does not utilize a third-party service provider for security purposes, rather security guards and supervisors are directly employed by the company. The company has a total of 38 unarmed guards over three shifts, and four supervisors who report directly to the HR department. As per ESAP #6, Woda will develop and adopt a Security Management Plan (SMP) guided by the principles of proportionality and good international practice. The SMP will define the company’s approach to risk assessments, hiring, rules of conduct, training, appropriate conduct toward workers and community members, equipping, and monitoring of security guards and their activities.
