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
Environmental & Social Policies
IHS adopted a Sustainability Strategy in 2019 which is structured across four pillars, (i) Environment and climate change; (ii) Our people and communities; (iii) Ethics and Governance, and (iv) Education and economic growth. IHS has established and implemented Group Health Safety Security and Environmental (HSSE) management system consisting of a suite of documents including the Group Health Safety and Security Policy (2021) and Group Environmental Policy (updated in 2024), and a set of corporate HSSE directives, supported by a range of HSSE procedures. The subsidiaries have adopted the Group HSSE Policies which are made available to employees and contractors. As part of streamlining the Corporate ESMS, IHS will develop corporate HSSE standards and systems that clearly define (i) guidelines for auditing and monitoring program for corporate and subsidiaries that establish a clear framework for the ongoing evaluation of the organization’s HSSE compliance with the corporate HSSE Standards, IFC’s Performance Standards and good international industry practices, (ii) guidelines for management of audit actions including a system for tracking resolution of corrective actions and (iii) guidelines for establishment, cascade and management review of corporate HSSE key performance indicators (KPI’s).
Identification of E&S Risks and Impacts
As required by relevant environmental laws and regulations in the countries of operation, IHS has commissioned ESIA studies for greenfield tower sites before the construction of tower sites and obtained relevant regulatory licenses and permits. IHS will develop an ESIA Standard for greenfield site developments which will outline the minimum requirements and guidance including a screening criteria for no-go areas consistent with good international industry practice and IFC PSs. To align and meet the requirements of IFC PSs, for future developments in non-urban zones, IHS 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.
IHS will develop a Biodiversity Screening & Management Procedure which 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 procedure 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 procedure, 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. For the existing portfolio, IHS will ensure that biodiversity mitigation measures (e.g. sediment and erosion control measures) are included in existing management plans; and in regions with high biodiversity risk, IHS will identify additional conservation actions to contribute to the conservation objectives of these areas, in consultation with relevant stakeholders.
In addition to the ESIA, IHS completed a hazard and operability (HAZOP) study and Bowtie risk analysis for the bulk fuel storage depots in Nigeria. The HAZOP studies raised specific recommendations regarding potential risk of overfill of the aboveground storage tanks, modification of oil-water separator skimmer and development of a spill response plan for the bulk fuel unloading and transfer operations at the jetty. IHS will develop a corrective action plan including timebound implementation schedule and budgeted CAPEX/OPEX to capture all outstanding HAZOP recommendations for the two depot facilities and to ensure the actions are efficiently and effectively implemented.
IHS has an overarching HSSE Risk Management procedure which identifies the approach to risk assessment from IHS and how the Group is structured to support active risk assessment across its operations. This document sets out the responsibilities of the key stakeholders in the process from the senior manager through to site workers as well as documenting the hierarchy of controls for the reduction of HSSE risks. The requirement for regional risk registers is included and the document sets out a recognized risk matrix to define the criteria for risk categorization.
E&S Management Programs
As part of the HSSE management system, IHS has developed a set of procedures that support the High-Level Directives issued by the Corporate team to improve its E&S performance and meet the IFC Performance Standards. These management programs include fleet safety consequence management guide, HSSE Addendum for contracts, emergency management procedure, safe methods for refueling, safe methods for tank cleaning, fleet management policy, spill prevention and response procedures, and a carbon reduction roadmap, among others.
E&S Organizational Capacity and Competency
IHS has established Group HSSE Department led by the Group VP HSSE comprised of two full time staff and additional HSSE managers have been approved by management for recruitment. Clear lines of authority and responsibilities have been established for each of the roles at the corporate and country levels. There is no formal HSSE competence programme in place across the organization. IHS will develop and implement a suitable HSSE competency programme focused on all employees with E&S responsibilities.
E&S Training
At the subsidiaries' level, IHS has identified and established HSSE training programs that are managed by the local Human Resource (HR) teams. The corporate IHS Academy has been set up to organize and deliver the training modules including specific HSSE modules to support and develop the team. These include Permit to Work (PTW) and risk assessment training, Safety culture transformation for management staff, Institution of Occupational Safety and Health (IOSH) Directing Safely, defensive driver training, emergency response procedures, environmental management, incident investigation procedures, HSSE induction and general HSSE awareness sessions. In both subsidiaries, the training programs apply to direct employees, who are trained via the IHS Academy, contractors and suppliers. IHS will establish and implement a plan for upskilling and strengthening HSSE capabilities of contractors to address deficiencies in core HSSE awareness covering permit to work system, incident classification and investigation protocols, safe system of work and risk assessment.
Emergency Preparedness and Response (EPR)
IHS has a high-level directive entitled Emergency Management Procedure. This corporate document sets out the approach to emergency response for the corporate office and subsidiaries and defines the specific responsibilities for key individuals in the process particularly the incident commander and the HSSE team. IHS will review and update the Emergency Management Procedure into a corporate Emergency and Crisis Response Standard that sets out the standards and expectations for emergency and crisis response by subsidiaries and for each subsidiary to identify credible emergency scenarios and define a program for executing all credible emergencies based on nature and type of previous incidents, operational risk assessments and other significant operational events and to ensure the emergency teams are tested for the entire range of anticipated incident scenarios. The corporate Emergency and Crisis Response Standard should include, as a minimum, requirements for an emergency and crises response team, trained response teams, the frequency of exercises and drills and crisis management protocols. IHS Nigeria has developed emergency response plans for the bulk fuel storage depots. IHS will update the spill contingency plan to address spill emergency scenarios for the bulk fuel storage depots and ensure appropriate response resources are made available.
E&S Monitoring & Reporting
IHS maintains monthly HSSE performance dashboard for its operations, including key performance indicators (KPIs), for Corporate and subsidiaries including HSSE leading and lagging indicators for contractors and sub-contractors, road safety incidents, driver infractions, HSSE training and tower site electromagnetic fields (EMF) monitoring. Specific HSSE-related KPIs are reported in the Group’s annual sustainability report. The HSSE country teams undertake inspections of tower sites and bulk fuel storage depots for the case of Nigeria. IHS will streamline monitoring and auditing of the HSSE management system as well as compliance with relevant legal and/or contractual obligations and regulatory requirements. This will include implementation of a risk-based approach to annual auditing and assurance at three distinct levels, focusing on site-based assurance at the country level, leadership/management reviews and, at the corporate audit level.
PS2: Labor and Working Conditions
As of December 31, 2023, IHS employed 2,988 people. The proportion of women in the IHS workforce was 27% in 2023, while 28% of managers were female. Nineteen percent of employees are female in senior management and technical roles. Contractors are engaged in tower site installation and maintenance as well as support functions such as transportation and distribution of supplies and security.
Human Resources Policies and Procedures
IHS has cascaded the corporate HR policies through country level HR Policies and Procedures manuals and Employee Handbooks. Staff are sensitized to these policies and procedures at induction and have access to digital versions through the employee self-service system. The policies and procedures are aligned with local laws and PS requirements.
Non-Discrimination and Equal Opportunity
Corporate and company level HR policies provide commitments on non-discrimination and equal opportunity that are aligned to local laws and PS2.
Workers Grievance Mechanism
The company has established a workers’ grievance mechanisms (GM) with mechanisms for submission of anonymous complaints and maintenance of confidentiality as appropriate. The group whistleblowing platform is also structured to receive anonymous complaints. Staff involved in investigations and GM committees receive in-house training from focal points based in the HR team. Staff and contractors are issued with codes of conduct and are made aware of the group’s Non-Reprisal Policy, while first responders to complaints and managers receive induction training on receipt and management of grievances. The company will establish a respectful workplace program to enhance prevention of general harassment, gender-based violence /sexual harassment (GBV/SH) in the workplace. To enhance the company’s capacity to implement survivor-centric responses to complaints related to GBV/SH, IHS will implement a training program on gender-based violence and sexual harassment (GBV/SH) for designated staff and those responsible for handling complaints related to GBV/SH. The training will cover, among other measures, survivor-centered approaches to workplace GBV/SH.
Protection of the Workforce (Child and Forced Labor)
The company prohibits any form of child and forced labor among its direct and third-party workers. IHS has procedures in place for verifying the age of its workforce and reviews its contractors’ and suppliers’ policies and procedures to verify compliance for third-party workers.
Workers’ organizations
The company has documented its commitments on collective bargaining. Staff are sensitized about these rights at induction with refresher communication undertaken by country HR teams where necessary, as part of the agenda, in staff town halls and road shows to sites.
Third Party and Supply Chain Workers
Procurement of suppliers, goods and services is categorized at Group and country level, at Group level being responsible for defining IHS wide procurement vision, objectives, sourcing, strategies, policies and relevant sourcing delivery. The Group has cascaded its procedures to country level, and undertakes E&S due diligence, inspection visits where applicable and performance reviews of contractors and suppliers as part of its Group and Country level procurement systems and processes. The HSSE requirements are documented in service level agreements and include the right for IHS to conduct HSSE monitoring and audits of contractors and suppliers at corporate and country level where applicable. The company also has a Supplier Code of Conduct that broadly complies with PS2 requirements, and the company monitors and audits the sensitization and acknowledge the code of conduct for new suppliers. The scope of the contractor and supplier E&S screening and audits includes OHS, human rights, labor rights and prevention of forced labor. Corrective actions for each contractor or supplier are documented as part of the E&S monitoring and audit system. As indicated under PS1, HSSE training by the company incorporates contractors’ workers.
Occupational Health & Safety
Key OHS risks for workers and contractors include working at height, energized conductors, confined spaces, exposure to volatile organic compounds (VOCs) and hazardous materials, electromagnetic fields (EMF), and driving related hazards. A hazard identification and risk analysis (HIRA) has been completed by each of the subsidiaries and forms part of the employee training program. Although occupational health (OH) remains an area of focus for IHS, at the corporate level, there is no clear standard for OH expectations across the Group and no clarity around the need for OH monitoring for direct employees and contractors. There is a similar gap around the OH requirements for contractor staff. IHS will implement a corporate occupational health standard which sets the requirements for subsidiaries to establish and implement country specific occupational health programs which should include, as minimum, requirements for OH risk assessments, medical surveillance and health screenings and OH awareness trainings for direct workers and contractor workers.
As part of strengthening health and safety practices, IHS now requires employees and contractors to conduct per-task risk analysis to identify and mitigate risk related to each key activity as per the established risk management procedures. Permit to work system is progressively being developed and implemented at the operational level to formalize and document the pre-task risk assessment process.
PS3: Resource Efficiency and Pollution Prevention
Greenhouse Gases
As of December 31, 2023, in IHS African markets (excluding South Africa), 48% of sites were powered with hybrid power systems (a combination of diesel generators with solar and/or battery systems), and in some of the sites as a supplementary power supply from the national electricity grid. To reduce IHS dependency on diesel and lower GHG emissions, IHS launched Carbon Reduction Roadmap. Under Carbon Reduction Roadmap, IHS has set target to reduce kilowatt-hour emissions intensity by approximately 50% by 2030. This target covers Scope 1 and Scope 2 emissions from tower portfolio. In 2023, IHS reduced Scope 1 and Scope 2 emissions intensity by approximately 6% compared with 2022. IHS currently discloses its greenhouse gas emissions in its annual Sustainability Report for Scope 1 and Scope 2 emissions.
Waste Management
IHS has implemented a waste management procedure to guide waste reduction, handling and disposal of hazardous waste streams generated from its operations such as used oil, spent batteries, used filters, etc. Hazardous waste streams are collected and disposed of by government approved/licensed waste contractors.
Hazardous Materials Management
Hazardous materials storage at IHS sites includes fuel utilized at its tower sites for operational generators and maintained in the bulk fuel storage depots. Storage of diesel, including installation of secondary containment, needs to be upgraded at the bulk fuel storage depots. IHS will rebuild the secondary containment bund wall for the bulk fuel storage tanks to ensure 110% of the tank volume to achieve compliance with regulatory standards and World Bank Group EHS Guidelines. IHS will also ensure installation of a fire alarm system in the facility.
Given the potential risk of overfill during bulk transfer of fuel into aboveground storage tanks at the depots, IHS will install appropriate high-integrity, automatic operating level detection and shut-off system that is physically and electrically separate and independent from the tank gauging system for the aboveground storage tanks.
IHS will develop a leak detection and repair (LDAR) program to address fuel leaks at the bulk fuel storage depots, following good international industry practice. The LDAR program will be implemented at the bulk fuel storage depots.
Photos and site inspection records of the storage tanks at the bulk fuel storage depots indicate that the tanks are overdue for calibration and have corroded roofs potentially compromising structural integrity of the roofs. To assure the integrity of the bulk storage tanks, IHS will implement a fit for purpose calibration program that will cover calibration requirement, corrosion monitoring, risk assessment and mitigation for all aboveground storage tanks at the bulk fuel storage depots.
Performance Standard 4: Community Health, Safety and Security
Infrastructure and Equipment Design and Safety
IHS has developed asset acquisition due diligence guidelines for acquisition of towers sites. For new site build, IHS outsources design, engineering and fabrication of tower infrastructure and components and engages engineering construction for site construction under the supervision of the company’s technical teams. Tower site infrastructure and safety are routinely inspected by field services engineers and the HSE teams and periodically by competent external engineering firms.
Road Traffic Safety
IHS has a corporate procedure entitled, HSSE Motor Vehicle/Driving Safely, which outlines a set of procedures and guidelines designed to ensure that direct employees, contracted employees, and sub-contractors use vehicles safely. As part of improvements implemented to address historical project-related road traffic incidents, all IHS vehicles, and in some cases, vehicles owned by contractors, have installed telematics devices, comprised of vehicle trackers, dashcam cameras and in-vehicle voice communication devices in all operational vehicles. By implementing these actions, IHS has recorded a 7% improvement in road traffic accident rate in 2023. IHS will extend the road and driving safety practices to all Operations and Maintenance (O&M) contractors and ensure suitable monitoring and consequence management protocols are implemented by subsidiaries that are yet to adopt the fleet safety management practices.
Security Forces
Country level operations have their own security contractors which may include the use of government forces in high-risk areas. For countries where armed government forces are needed, IHS has engaged staff with either training or work experience operating under the UN principles on use of force and firearms. The company has also documented a procedure for arrest of staff in the event of unlawful conduct and incorporates clear information on contact persons for reporting of breaches of these requirements, including on the corporate whistle blower platform. The procedure also indicates the conduct of government forces including on appropriate use of force. The company undertakes training for contracted security staff and sensitization of its government partners on these commitments.
Electric and Magnetic Fields
IHS has established a comprehensive Group High-Level Directive for non-ionizing electric and magnetic fields (EMF) monitoring which is implemented at country level operations. The Directive is aligned with international best practices and regulatory guidelines and is designed to ensure the protection of general public, including employees and contractors.
