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
Once established, TowerCos will develop an ESMS aligned with Actis’s Sustainability Policy. The ESMS will build on the policies and sustainability objectives of Actis, as well as the experience from operating the assets under TSG's management, and include requirements enforced upon suppliers and contractors.
As per the E&S Action Plan (ESAP#1) agreed between Actis and IFC, TowerCos will appoint a suitably qualified corporate E&S manager/coordinator to oversee the development and implementation of its ESMS and assign sufficient resources to provide adequate E&S oversight, in each country of operation.
In addition, as per ESAP#2, TowerCos will develop and implement a detailed ESMS for ongoing and future operations per local regulations, IFC PSs, and WBG EHS Guidelines (General and Telecommunications). The ESMS will include an overarching E&S policy defining TowerCos's E&S objectives and principles and include relevant plans/procedures, including but not limited to biodiversity management, pollution prevention (including EMF), GHG accounting & reporting, emergency preparedness and response, transport and traffic management, land acquisition and resettlement, security management, and supply chain.
National regulations in the three countries of operation do not uniformly require Environmental Impact Assessments (EIA) for the development of mobile communication towers. However, as per ESAP#3, TowerCos will develop and implement an E&S Assessment and Management Procedure (ESAMP) in line with IFC PS and WBG EHS Guidelines. The ESAMP will include a mechanism to screen the E&S sensitivity of future asset locations. The procedure will ensure that locations of higher environmental, biodiversity, cultural heritage, or other social value for local communities (including land acquisition) are identified and avoided, or where avoidance is not possible, risks and impacts are assessed and mitigated as per IFC’s PSs. The screening process will consider risks to both legally protected, internationally recognized areas and other priority biodiversity features as per IFC PS6. The procedure will include corporate procedures applicable to all countries of operation and reflect and address the specific requirements of each country.
To ensure continuity of operation, TSG will support TowerCos through the ownership transition period via a Transition Services Agreement (TSA - anticipated to be in place for up to 15 months). During this time and until TowerCos’s E&S team and ESMS have been established, TSG E&S procedures will be implemented. TSG has an integrated management system, certified according to ISO 14001 (Environmental Management) and 45001 (OHS). TowerCos will include legally binding obligations in the TSA to ensure compliance with national OHS and labor requirements and ensure a mechanism for workers to raise grievances is available (ESAP#4). In view of the use of contractors for operation and maintenance activities in each country of operation, TowerCos will develop a Contractor Management Procedure (ESAP#5) that will be used to guide all contractors related to compliance with its ESMS and IFC PS. The Contractor Management Procedure shall follow the guidance provided in IFC’s Good Practice Note Managing Contractors’ E&S Performance.
If the development of a new tower will require the acquisition or lease of land, or of existing built structures, TowerCos will screen the potential locations in accordance with the requirements of the ESAMP (ESAP#3), which include land acquisition considerations. Upon site selection, land acquisition or lease procedures will be governed by the Land Acquisition Procedure, which will be included in the TowerCos’s ESMS (ESAP #2). The procedure will guide TowerCos to apply IFC PS-compliant processes to acquire/lease the land/asset and compensate the owner(s) or users (formal and informal) of the land or buildings.
PS 2 – Labor and Working Conditions
TowerCos expect to employ approximately 40 staff distributed in the three countries of operations. This will include both office-based and field-based staff. In addition, it is anticipated that contract workers will be required to support some operational functions.
As per ESAP#6, TowerCos will develop and implement human resources (HR) policies and procedures according to IFC PS2, and local labor codes in each country of operation, and applicable to all project workers (including contractors/sub-contractors). All employees will be provided with documented information pertaining to their rights, terms and working conditions. This will include, where applicable, working hours, wages, overtime, compensation, and benefits, leave, performance reviews, right of association, health insurance, pension, termination procedures and grievance management. Additionally, the HR policy will include details pertaining to employment equity and non-discrimination, a code of conduct (including management of sexual harassment and gender-based violence), and protection of the workforce (forced and child labor). As per local legislative requirements and detailed in the HR policy, TowerCos will comply with workers’ rights to join and form workers’ organizations and/or unions of their choosing.
TowerCos will develop and implement a worker's grievance mechanism (WGM), in accordance with IFC's PS2 standards. The WGM will be available to all workers, irrespective of their employer. The WGM is to include specific considerations related to sexual harassment/gender-based violence grievances. This should include multiple entry points to raise and address allegations, including options to report anonymously if preferred (ESAP#7).
TowerCos will develop an OHS Procedure (ESAP#8) that will include (i) the identification of potential hazards to workers; (ii) provision of preventive and protective measures; (iii) training of workers; (iv) documentation and reporting of occupational accidents, diseases, and incidents. The OHS procedure will also include specific threats to female employees. The OHS procedure will be consistent with national requirements, and Good International Industry Practice (GIIP) as per the relevant sections of the WBG EHS Guidelines.
PS 3 – Resource Efficiency and Pollution Prevention
TowerCos’s operations will not result in significant quantities of waste and emissions. Electricity will be predominately sourced from the public grid for the majority of the TowerCos assets, with diesel generators only being relied upon in more rural areas in which grid power is unreliable. Backup power in case of outages will predominately be provided by batteries. IFC estimates that the GHG emissions associated with the project are 17,000 tonnes GHG per year, based on a portfolio of 1,828 towers across Serbia, Bosnia & Herzegovina and Montenegro. These estimated emissions assume towers receive all energy from the grid and incorporate 70% electricity from renewables for towers in Serbia. As per ESAP 2, TowerCos will implement a GHG accounting and reporting system based on internationally recognized methods to consolidate GHG accounting and reporting associated with the operations of the newly established company after a full year of operation.
Potential pollution risks from TowerCos operations will be associated with the use of backup generators. Such risks will include potentially elevated noise levels and ambient air pollution. In addition, fuel handling and storage for the generators may be a source of soil and/or groundwater contamination in case of spill or loss of containment. The only hazardous waste anticipated from the project is used lubricant oils from diesel generators, lithium and lead acid batteries and contaminated soils where spillages may occur. E-waste generation will be limited to computers, printers and other electronic equipment used in the offices. Where possible, TowerCos will prioritize the recycling of waste, and where not feasible, will utilize registered waste collectors to collect and manage the disposal at authorized disposal sites.
The environmental plans/procedures (ESAP#2) developed as part of TowerCos’s ESMS will address key PS3 aspects such as waste and hazardous material management, noise emissions, and potential impacts from EMF. The ESMS will also include procedures to calculate and report GHG emissions associated with the operations, and a program to improve energy efficiency and reduce GHG emissions.
TowerCos will utilize municipal water for its operations. Quantities will be limited and primarily used for routine administrative, sanitary and cleaning purposes. Significant use of water resources is not expected.
PS 4 – Community Health, Safety and Security
The primary community health and safety risks associated with the project includes exposure to construction vehicles and transport, and exposure to dust, noise and vibrations caused by constructions works (during the implementation of TowerCos Capex plan). Operational hazards may include tower failures and collapse, unauthorized site access and road safety. Despite not being the source of EMF (TowerCos are not acquiring any active equipment), TowerCos will ensure that all required regulatory setbacks are reviewed and ensure that the siting guidelines under the World Bank Group EHS Guidelines for Telecommunications are applied in the site selection process.
The E&S Assessment and Management Procedure (ESAP#3) will take into consideration these potential community impacts during site selection, construction and operation. Additionally, the third-party/ contractor selection and management process (ESAP#4) will ensure that impacts such as dust, noise and traffic risk, and risk of public access to towers, are managed effectively.
As per ESAP#9, TowerCos will, as part of its future asset inspection program, inspect all physical assets to ensure their structural integrity and to ensure that appropriate measures have been implemented to prevent unauthorized access. If non-compliances are identified, an action plan will be developed and implemented in a timely manner.
As part of its ESMS (ESAP#2), TowerCos will develop an Emergency Preparedness and Response Plan (EPRP) aligned with national requirements, IFC PS, and GIIP to address risks to communities and members of the public. TowerCos will develop and implement a Traffic and Road Safety Management Plan aligned with national requirements, IFC PS4, and GIIP and will extend it to all contractors and sub-contractors (ESAP#2).
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
The portfolio of towers to be acquired includes two existing ground-based towers located in Durmitor National Park Natural World Heritage Site (WHS) in Montenegro, both of which were built in 2008. Per ESAP#10, TowerCos will engage with UNESCO and request their input on additional conservation programs to support the WHS site. Additionally, TowerCos will develop and implement a Biodiversity Action Plan to identify additional programs commensurate with the risk and include any additional good industry practice with respect to ongoing maintenance activities.
For future tower locations, as per ESAP#3, TowerCos will develop and implement an ESAMP, which will screen the E&S sensitivity of future asset locations. In line with IFC PS mitigation hierarchy, TowerCos will assess the feasibility of avoiding the construction of ground-based towers within Protected Areas, including both Legally Protected and Internationally Recognized Areas. Where avoidance is not possible, and towers are in Protected Areas, project sites will be developed in alignment with PS6 requirements, notably with respect to stakeholder consultation.
