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.
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
Following previous IFC investments, WIOCC implements an ESMS aligned with IFC PSs that comprises an ESMS Manual, E&S policies and procedures covering aspects such as E&S screening and assessment, land acquisition, stakeholder engagement, waste management and contractor E&S management. The OADC data centres are designed to meet recognized international standards, including Uptime Tier III Certification. To manage the E&S risk related to the OADC business unit, WIOCC will: (i) conduct a E&S risk assessment of the OADC operations against IFC PS; (ii) review and expand the scope of the ESMS to include identified OADC business E&S risks; and (iii) integrate WIOCC ESMS requirements and performance indicators into the existing department-based standard operating procedures (SOPs) (ESAP #1).
Phase 1 of the DRC data center construction is ongoing (expected completion by December 2023), and an EHS Management Plan developed by the contractor is being implemented. WIOCC will obtain the environmental permit for the DRC data center before commencement of operations (ESAP #2). Further, WIOCC will conduct E&S impact assessments for; (i) all new data centers and obtain respective environmental permits in line with IFC PS before commencement of construction; and (ii) any energy efficiency projects with material E&S impacts (ESAP #3). In South Africa, the Durban and Johannesburg data centers are on repurposed existing buildings and as required by the South African laws, site-specific EHS Management Plans have been implemented in the refurbishment and fitting works.
In addition to the oversight roles of the Board of Directors and the Chief Executive Officer (CEO), the company has recently recruited a Head of Environmental, Social and Governance (ESG) whose role will cover both data center and connectivity operations. The ESG Head will be responsible for sustainability strategy, policy, systems and processes, ESG risk management, and driving implementation of sustainability and ESG initiatives. The ESG Head will also be responsible for implementing systems and processes for the management and mitigation of E&S risks as contemplated in the IFC PS. The existing WIOCC and OADC team members who are conducting E&S functions will continue to support the ESG Head where required. These include the WIOCC Legal Director and the OADC EHS Manager. The ESG Head will also use external consultants or contractors to supplement any gaps in resource requirements in the short term.
WIOCC implemented a corporate Emergency Preparedness and Response Procedure (EPRP), which will be updated to include a provision to require positing of external (security, medical, fire safety) contacts in public at each operational site, including the data centers and where long-term projects are situated (ESAP #4). Once construction of each data center is completed, WIOCC will obtain regulatory fire safety certifications to demonstrate that they comply with national fire safety requirements (ESAP #5)
PS 2: Labor and Working Conditions
WIOCC’s workforce totals about 203 direct employees in the various countries of operation; comprising 65 female employees and 138 male employees. All employees have written contracts specifying terms of employment, hours of work, salary amounts and timelines, rights and responsibilities. No workers’ organization exists, and no collective bargaining agreements have been entered. The company’s Employee Handbook has been updated and comprises policies on non-discrimination and equal opportunity, freedom of association, grievance management, child or forced labour, recruitment, training, promotion which are consistent with the requirement of IFC PS2. WIOCC’s worker’s grievance procedure will be updated to provide for alternative channels for dissatisfied claimant after final grievance committee decision; and the updated procedure will be applied at OADC (ESAP #6).
WIOCC routine operations do not pose serious OHS risks to the workers. However, during projects (cable laying, data center construction and maintenance), OHS risks do occur, and the SOPSs are applied to ensure organized approach to tasks. These SOPs will be updated by integrating E&S requirements therein, per ESAP #1. The company has also developed a training procedure that will guide employee and contractor EHS training and capacity enhancement. To manage contractors, who conduct the bulk of project construction, cable laying and maintenance works, the Company implements a contractor E&S management procedure that requires compliance with country laws, WIOCC E&S policies and IFC PS (as relevant) in the project works. The contractors are expected to prepare and implement construction EHS Management Plans and adequately oversee their workers’ labor and OHS conditions. All project sites implement EHS Management Plans commensurate to respective scales of EHS risks.
WIOCC procures different components for its operations, and in order to manage risks related to the various supply chains, the company will implement a Supply Chain Management Procedure aligned with IFC PS2; and the procedure will be applied at OADC (ESAP #7).
PS 3: Resources Efficiency and Pollution Prevention
Energy is the most significant resource consumed at a data center, mainly used for cooling and powering-up equipment at the WIOCC and OADC facilities. The sustainability linked loan will include targets to improve energy efficiency over the period of the loan. In addition, WIOCC will also include targets relating to IFC Excellence in Design for Greater Efficiencies (EDGE) certification for new greenfield data centers. To this end, WIOCC have engaged an advisor to advise on EDGE certification requirements for the data centers. To achieve energy efficiency, WIOCC will also procure and install solar PVs through different suppliers to complement grid electricity in the data centers and related supply chain risks will be managed under the Supply Chain Management Procedure to be implemented as part of ESAP #7 above.
The estimated current greenhouse gas (GHG) emissions in WIOCC operations is 2,800tCO2eq/annum. WIOCC has designed an action plan for future annual GHG quantification and reporting at the data centers, including for the OADC business. WIOCC will proceed to develop all tools required to implement the action plan objectives, in line with good international industry standards, and will report to IFC on an annual basis including for OADC (ESAP #8).
Minimal volume of water will be required in the data centers due to the designed use of air-cooling systems instead of water-based systems. Data center operations are not expected to cause significant air emissions. Minimal air emissions may occur from the back-up generators as they will be used to complement electricity, in case of power outages. Back-up generators are also the main sources of noise in data centers. However, given they will be used only during power outages, the noise impact is expected to be minimal.
Data center operations will generate electronic wastes, in addition to limited quantities of solid waste from offices. Electronic wastes will be stored on site and will be collected by equipment providers and clients as part of their service contracts. All waste streams generated as part of data center operation will be managed as per the company’s waste management procedure, which will be updated to cover wastes streams from the data centers. Wastes generated during project construction (including energy efficiency projects) activities will be managed by the contractors in accordance with the construction EHS Management Plans and local regulatory requirements.
PS 4: Community Health, Safety and Security
During data centre operations, all fire and electrical systems will be tested in line with national fire regulations and electrical standards. This will safeguard the workforce and any visitors from fire risks from the facilities. The site-level Fire Safety and EPRPs for the new data centers will be developed as per procedure established under the ESMS. For the DRC data center construction phase, the construction EHS Management Plan covers community health and safety risks, such as construction traffic management and management of the construction site, to external parties and local community. Community safety and security aspects will be included in E&S impact assessments for all other WIOCC projects, including energy efficiency projects, as applicable. WIOCC will employ both armed and unarmed security personnel provided by licensed service providers. The company has developed a Security Management Plan aligned to the IFC PS 4 requirements that is applied at OADC facilities as well.
