The fiber cables are being laid along roads, railway, power and waterline wayleaves and the PoP sites are located within government institutions. Therefore, no additional land acquisition will occur in this project. None of the remaining fiber cables will be laid in areas of significant biodiversity value, indigenous peoples or cultural heritage; hence there are no anticipated impacts associated with PS 6 (Biodiversity conservation and sustainable management of living natural resources); PS 7 (Indigenous Peoples) and IFC PS 8 (Cultural Heritage).

 This proposed investment is expected to have limited E&S impacts, which are expected to be short-term and site-specific, and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability.

The key E&S issues associated with this investment include: i) adequacy of Liquid’s E&S management system (ESMS); ii) fair, safe and healthy working conditions for project contractors’ workers, including, harassment and gender-based violence; (iii) community health and safety, especially related to cable route excavations and road traffic; and iv) engagement with key stakeholders including local communities within the project area.

 As a result of IFC’s previous investments, Liquid implements an ESMS aligned with IFC PS, which has been adopted and applied at LTSA. Liquid ECG Infraco (Pty) Ltd (the SPV) has been registered as a legal entity within South Africa, and will own the network infrastructure which will be leased to LTSA to enable LTSA to meet its contractual obligations. LTSA and the SPV will sign an operation and maintenance (O&M) agreement in place whereby services including E&S will be provided to SPV by LTSA, in line with LTSA ESMS. LTSA has retained a dedicated HSE Officer and a Community Liaison Officer (CLO) to oversee E&S matters in the project and support the project team. All regulatory permits required by the local authorities were obtained prior to project commencement. The project works are undertaken through contractors and each contractor has a Liquid-approved construction HSE plan appropriate for their scope of work and own HSE Officers to oversee their implementation. The Liquid HSE Officer conducts regular monitoring of compliance and periodic audits of contractor activities against this plan and Liquid’s project HSE audit template.

As agreed in ESAP #1, Liquid ECG Infraco (Pty) Ltd will: (i) fully adopt the Liquid ESMS for the project; and (ii) design and implement a clear E&S reporting structure from the project into the Regional HSE Manager and Group Executive Head ESG.

 Through the O&M agreement, Liquid ECG Infraco (Pty) Ltd will be managed by both seconded existing LTSA staff and own assigned staff. The project is primarily undertaken by contracted companies. Currently, Liquid has retained nine locally registered contractor companies for the project, employing 627 male and 95 female workers. The contractors are required to hire workers from their localities of activities (various villages along the fiber cable routes). The workers are therefore retained on casual work basis, with daily wages. Grievance reporting and management process is clear to the contractor workers. All workers hold safety toolbox talks each morning before work, tailored to the risks faced in the day’s task. Accidents or incidents are recorded in a standard template, and none have been reported in the project at the time of appraisal.

As agreed in ESAP #2, Liquid will conduct labor audits on the assigned contractors per PS 2 to confirm that the casual workers’ wage brackets and other working conditions meet local labor laws and IFC PS and address any identified non-compliances.

 The main source of energy at the PoP sites is grid electricity. Some stand-alone PoP sites will have back-up diesel generators for use during grid power outages. The greenhouse gas (GHG) emissions from the project activities are expected to be significantly less than 25,000tCO2eq/annum. The main sources of wastes in the project comprise general paper and plastic wastes and cable parts at the working sites, hazardous wastes from possible oils and grease leaks from heavy equipment and vehicles. Wastes are collected before leaving every site and disposed at the closest municipal bins.

 Main community health and safety risks are related to traffic and cable route trenching. Vehicles are driven at prescribed speeds (in the respective contractor HSE plans and the group’s Driver Policy) within urban areas and cable excavations are cordoned and backfilled within the same day, as the teams progress. Pavements or road shoulders are restored to original status soon as work is completed.

 Community engagement for the project is managed by project-dedicated Community Liaison Officers (CLO).

As agreed in ESAP #3, the project will adopt and implement the Liquid stakeholder engagement procedure, including mapping and identification of relevant stakeholders, documenting and reporting on stakeholder and community engagements and on community grievances.

 Contact Person: Faizel Khan

Company Name: Liquid SA

Address: 401 Old Pretoria Road Midrand

Email: Faizel.khan@liquid.tech

Phone: +27115851258