This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S risk and 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:

• Netis’ E&S management systems and resourcing, at a corporate and country level, to manage its operations in line with IFC PSs.
• Adequate site risk assessment protocols and procedures to identify, assess, and manage risks and impacts.
• Implementation of fair, safe, and healthy working conditions for employees, contractors, and sub-contractors in line with PS2 and relevant legal requirements.
• Occupational health and safety management for construction and maintenance activities.
• Road safety and site security management.

Environmental and Social Assessment and Management System:

Netis has developed and implemented a comprehensive corporate E&S Management System (ESMS) largely aligned with the requirements of IFC PS1 and commensurate with the level of E&S risks and impacts associated with project activities. The Company, both at a corporate and operational level, except for Ivory Coast, Niger, Democratic Republic of Congo, and Ethiopia, is ISO 140001, 45001, and 9001 certified.

The Netis corporate and in-country business units operate under an integrated safety, health, environment, risk, and quality (SHERQ) management system policy. Netis has a corporate level SHERQ function responsible for overall oversight and reporting on E&S performance. At a country level, E&S is managed by respective SHERQ managers and coordinators / assistants to further reinforce coordination and communication on the ground. 

Identification of Risks and Impacts:

Netis are not responsible for the initial risk identification and assessment process associated with site acquisition, including the completion of necessary environmental impact assessments (EIA), which is conducted by their clients, in line with local regulations. As a component of their ESMS, Netis will develop and adopt an E&S Assessment and Management Procedure (ESAMP) (ESAP 1). A checklist based on the ESAMP is to be completed for each site at the point of handover from a client and is to identify key site characteristics and risks associated with different stages of the Project, including construction, maintenance, and operation. The ESAMP will cover requirements related to permitting, community health and safety, occupational health and safety (including exposure to electromagnetic frequencies), security, land acquisition, biodiversity, climate vulnerability, and cultural heritage.

Should risks / sensitivities be associated with the site, Netis will implement associated management programs / standard operating procedures as defined in the ESAMP. This will include, but not be limited to, community health and safety plan, security management plan, biodiversity management plan, herbicide/pesticide management plan, land acquisition policy, chance find procedure, cultural heritage management plan, and stakeholder engagement.

Emergency Preparedness and Response:

Netis and associated in country business units have developed and implemented Emergency Preparedness and Response Procedures (EPRPs). The EPRPs are supplemented by a specific emergency response plan established at in-country business unit level Netis will review and update the existing in-country EPRPs to ensure they adequately reflect the requirements of the corporate ESRP, as well as cover key risks such as road accidents, community accidents, climate change risks, etc. (ESAP 2). The implementation of the EPRPs will be informed by the ESAMP as per ESAP 1. 

Monitoring and Review:

Netis has established procedures to monitor and measure the effectiveness of its ESMS. This includes a robust E&S reporting dashboard known as the UTAD reporting system, which includes several relevant environmental, health, safety key performance indicators (KPIs) that are reported by each in-country business unit monthly. Netis has also adopted an internal cross-check audit system, whereby alternative SHERQ managers audit different in-country business units on an alternating basis.

Netis currently has a workforce of over 2,600 workers, including both permanent and contract workers with approximately 18% female representation. In-country business units in Togo, Gabon, Uganda, and Ghana have workforces of 412, 193, 136, and 331, respectively. At the corporate level, Human Resources (HR) are managed by the Group’s Chief HR Officer. At an in-country level, HR management is overseen by an HR Manager, who is supported by an HR department of between two and four personnel, dependent on the local workforce scale.

Human Resources Policies and Procedures:

As defined in the Code of Conduct and HR Manual, labor and working conditions across Netis’ respective in-country operations are managed as per national labor requirements and existing collective bargaining agreements. The existing Code of Conduct defines relevant requirements regarding adherence to national legislative requirements, as well as human rights (child labor, harassment, gender equality, non-discrimination, and equal opportunity). In addition, Netis have developed an HR Manual that details labor and working conditions, including remuneration, working hours, leave, overtime, training, and performance management. In-country business units are required to adopt these requirements, as well as define their own procedures as per national legislative requirements (règlement intérieur).

Netis have also developed defined procedures and tools about on-boarding, leave management, performance management, training, and travel policy. HR KPIs are monitored through the HR UTAD. Netis will enhance its existing HR management system through the development of a standalone HR Policy defining the Company’s approach, principles, and objectives toward safe, fair, and legal labor and working conditions across all business units in line with local regulations and IFC PS2 (ESAP 3). Furthermore, Netis will define a rollout plan to ensure that the existing HR management system, and broader ESMS, is adequately cascaded to all in-country business units, in particular new entities (ESAP 4). This will include training and awareness sessions relating the requirements of IFC PS2.

Working Conditions and Terms of Employment:

All workers are provided with written contracts (term, open-ended, contract, internship) managed by the relevant in-country business units. Netis will develop a standardized contract for casual workers, which will be aligned to national legal requirements and IFC PS2. All causal workers will be provided with a written contract upon employment (ESAP 5).

Given the diverse nature of Netis’ workforce and nature of work, the Company will develop and implement, as a component of the UTAD system, a working hour management system to actively monitor workers’ on-duty hours and overtime. The procedure will also define specific thresholds for time off in lieu and will clearly state the local regulatory' requirements (ESAP 6).

Workers’ Organizations:

Currently all countries where Netis operates recognize workers’ right to form and join workers’ organizations of their choosing, and to bargain collectively.

Currently workers in Gabon and Ghana are unionized and relevant collective bargaining agreements are applied. In countries where workers are not unionized, such as Togo, worker representatives are elected as per national legal requirements and engage with management and HR monthly.

Non-Discrimination and Equal Opportunity:

Netis has developed and implemented an unfair discrimination and harassment policy. As per ESAP 4, Netis, through a defined roll-out plan, will ensure enhanced awareness and understanding of existing HR policies and procedures, including the discrimination and harassment policy.

Workers’ Grievance Mechanism:

As a component of the existing Code of Conduct, Netis have developed guidance for the reporting of concerns via the Netis website or email. While a partial workers’ grievance mechanism exists, Netis will develop and implement a formal process, including the definition of roles and responsibilities, assessment of grievance severity, mechanism for submission of anonymous complaints, and associated timelines (ESAP 7). This mechanism will be communicated to in-country business units as a component of ESAP 4, and grievances will be monitored monthly through the HR UTAD system.

Occupational Health and Safety:

As a component of their ESMS, Netis has developed and implemented several occupational health and safety (OHS) procedures. This includes a ‘permit to work’ system for high-risk activities, monthly monitoring and reporting through the UTAD system, investigation reporting and root cause analysis. These requirements extend to both Netis workers as well as contractors. In 2022, as per the UTAD reporting, the Company did not experience any fatalities across their in-country business units.

Netis will conduct an internal OHS audit identifying key gaps within the implementation of the OHS management system and define key corrective actions to ensure alignment with local requirements and IFC PS2 (ESAP 8). Additionally, as a component of ESAP 1, Netis will identify the potential risks posed by exposure of workers to Electromagnetic Frequency (EMF) on a site-by-site basis, and where necessary implement the necessary management measures as required under ESAP 2.

Workers Engaged by Third Parties:

Currently 25% of Netis’ total workforce is outsourced, particularly in Ethiopia, Rwanda, Togo, and Nigeria. The Company also has approximately 670 contractors, predominantly providing civil engineering support and security, across their various business units.

The Company has developed a Code of Conduct for Business Partners (suppliers, vendors, subcontractors, and recruitment agents) outlining contractual requirements in relation to human rights, child and forced labor, freedom of association, equal opportunity, fair working conditions, and environmental protection. This, along with compliance with local laws, is included in all contracts. 

Netis will develop and implement a third-party monitoring procedure to adequately assess the performance of contractors against key parameters, including labor and working conditions, OHS, and road safety (ESAP 9). If suitable, the process will be integrated into the existing UTAD system.

Supply Chain:

Netis’ supply chain function is centralized at the corporate level, under the responsibility of the Supply Chain Officer. Netis completes a vendor SHERQ prequalification questionnaire with all potential suppliers. Each contractual agreement includes the Code of Conduct for Business Partners as described.

Resource Efficiency:

All in-country business units monitor and report their electricity, fuel, and water consumption through the UTAD system monthly. Based on these KPIs, Netis will define a resource reduction strategy that will include technically and financially feasible and cost-effective measures for improving efficiency in its consumption of energy, water, and fuel (ESAP 10).

Netis currently conduct internal greenhouse gas (GHG) emission monitoring (Scope 1 and 2) for their various business units. While the Project is expected to produce less than 25,000 tonnes of CO2-equivalent annually, as per ESAP 10, Netis will identify alternatives and implement technically and financially feasible and cost-effective options to reduce project-related GHG emissions during both construction and operation activities.

Pollution Prevention:

Netis’ waste streams, including waste oil, filters, fan belts, cardboard, packaging etc., are generally generated by passive or ongoing maintenance activities. Waste is segregated and disposed of by certified waste disposal companies within the respective countries of operation. As a component of the UTAD system, Netis will include a process for the monitoring of different waste streams across the business units (ESAP 11).

Pesticide Use and Management:

Netis currently utilize a range of pesticides during ongoing maintenance activities. Given the extensive use of pesticides and herbicides, as a component of ESAP 1, Netis will develop and implement a Pesticide/Herbicide Management Plan that will define i) preferred herbicides and pesticides to be used in line with level of hazards and toxicology as defined by the World Health Organization, ii) handling and storage requirements, and iii) disposal. This management plan will be applied based on specific site requirements.

 Community Health and Safety:

The potential community health and safety risks associated with Netis’ operations primarily 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. As required by ESAP 1, upon handover of a site, Netis will conduct a site risk and impact assessment to identify site specific considerations, including potential community health and safety impacts. Should risk and/or impacts be identified, Netis will implement specific management measures as required under ESAP 1.

Road Safety

Netis currently operate a fleet of 815 vehicles which is managed by a dedicated fleet department, under the overall responsibility of the SHERQ Chief officer. Existing road safety practices include defensive driver training, In-Vehicle Monitoring Systems (IVMS) including location, speed and driver behavior, random alcohol testing, journey management for travel over 100km, and reporting of road accidents and incidents through the UTAD system. As per ESAP 2, Netis will ensure the existing road safety procedures are adequately communicated, understood, and implemented within all in-country business units.

Security:

Depending on contractual requirements with clients, Netis may engage third-party service providers for the provision of on-site security. Netis’ contractual requirements with security providers includes age and criminal background checks, rules of engagement, training records, proportional use of force, and gender considerations. As per ESAP 10, Netis will develop and implement enhanced monitoring of their third-party service providers, including security providers, to ensure contractual requirements are adequately fulfilled. Additionally, as a component of ESAP 1, Netis will develop a corporate level Security Management Plan that will further define the Company’s approach to security management, risk assessment, and monitoring.

While Netis doesn’t own the telecom infrastructure, the services it provides require site access, land clearing, soil stabilization etc. during both construction and ongoing maintenance activities. Should such activities be required within potentially sensitive areas (protected areas, key biodiversity areas, Alliance for Zero Extinction (AZE) sites and World Heritage Sites), it will be necessary for Netis to apply relevant management measures to identify, avoid, and mitigate site specific risks and impacts.

As a component of the ESAMP (ESAP 1), Netis will define their E&S site risk assessment process, including identification of potentially sensitive sites as described above. Should sensitive sites be identified, Netis will apply the relevant management measures as described in the ESAMP. This will include, but not be limited to, notification of key stakeholders such as AZE, definition of standard operating procedures (such as minimization of team sizes, restricting work hours, banning possession/collection of any wildlife products, consultation with relevant managers when entering priority sites, and avoiding placement of work camps/storage etc. within priority sites where feasible).

Currently, Netis identifies their stakeholders on an annual basis at group and in-country business unit levels, by using a dedicated stakeholder identification matrix. As a component of ESAP 1, Netis will develop a Stakeholder Engagement Framework that will define their engagement approach and strategy commensurate to the nature of the risks and impacts associated with each site (as determined in the ESAMP in ESAP 1). The framework will detail Netis’ engagement principles and strategy and define an engagement approach compatible with Performance Standard 1.

As a component of the existing Code of Conduct, the Company has defined guidance for the reporting of external concerns and grievances. All grievances are reported to the Group Chief and Legal Compliance Officer, either via the Netis website or email. The number of complaints and grievances are monitored monthly using the UTAD platform. While a partial external grievance mechanism exists, the procedure has not been formalized, including the definition of roles and responsibilities, assessing grievance severity, and defining the grievance resolution process and timelines (ESAP 12). The dissemination of the updated grievance mechanism will be defined in the Stakeholder Engagement Framework as detailed above.

Contact Person: Luc Rigouzzo

Company Name: Amethis

Email: luc.rigouzzo@amethis.com

Phone: +33 1 56 68 85 66