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 and Social Assessment and Management System: The company has a corporate ESMS that is applied across its countries of operation and is aligned with IFC Performance Standard (PS) 1. The ESMS comprises the following key elements: (i) E&S policy; (ii) identification of E&S risks and impacts; (iii) E&S management programs; (iv) organizational capacity and competence; (v) emergency preparedness and response; (vi) monitoring and review, and (vii) a Stakeholder Engagement Plan. The Group's E&S Policy underscores its commitment to adhering to local regulations, proactively managing E&S risks, and ensuring efficient use of natural resources.
Identification of Risks and Impacts: The E&S risk assessment and management procedure developed as part of the ESMS guides the risk identification and management across the business, consistent with IFC’s PS. The Group's approach to identifying E&S risks and impacts starts during site selection. The Group has developed terms of reference for conducting E&S impact assessment (ESIA) based on local E&S regulations of the relevant host country and IFC PS. The assessments are conducted by national consultants who also assist in obtaining the relevant E&S permits. All DC in operation and under construction have an approved ESIA report, that covers aspects such as identification, analysis and assessment of E&S, stakeholder consultation, institutional and legal frameworks, and an E&S management plan.
The company will conduct Climate Risk Assessments for all sites and prepare mitigation measures posed by flooding risks and extreme temperatures (ESAP#1).
Organizational Capacity and Competency: The Group maintains a dedicated team responsible for overseeing E&S matters across the company and countries of operation. This includes the Health Safety Security and Environment (HSSE) Manager, who coordinates E&S initiatives, reporting, and integration with other departments, including engineering, technical operations, and project management offices. The HSSE Manager is supported by an HSE/E&S international consultancy firm. At the facility level, Raxio has a HSSE officers for the operational sites and a HSSE consultant for the sites under construction who report to the company’s Senior Management.
Monitoring and Review: As part of the corporate ESMS, the Groups has developed a framework for monitoring and auditing E&S performance of the company’s operations, contractors’ performance, and compliance with regulatory requirements and IFC’s PSs. Key performance indicators such as occupational health and safety (OHS) incidents, near misses, energy use, and water use, are defined, monitored, and periodically reported to senior management. The ESMS has provisions for periodic reviews or change management, including evolution of legislative requirements or changes in projects or operations.
Emergency Preparedness and Response. Raxio has a corporate level Emergency Preparedness and Response Plan (EPRP) covering all the countries of operation, detailing procedures for potential emergency scenarios. These plans designate responsibilities, address communication, include emergency drills, and outline procedures for alarms, firefighting, and medical emergencies.
PS2: Labor and Working Conditions
A DC under operation like Uganda will have approximately 30 workers, 15 direct employees and 15 full time contractors. During construction a typical site has approximately 60 workers, with 70% being temporary workers. Raxio will have a total of 150 direct workers when all the ten DC are operational.
Human Resources Policies and Procedures: The Group has a HR Handbook covering all its countries of operation that includes workplace policies like non-discrimination, sexual harassment, and bullying, OHS, employee code of conduct, training and development, human rights, whistleblower diversity, and inclusion. Raxio will update the HR Handbook to further align it with IFC PS2 and include policies on workers engaged by third parties, retrenchment, commitments regarding freedom of associations, and supply chain, and procedures to ensure compliance with labor regulations across its countries of operation. (ESAP #2). The HR Handbook is managed by a competent Group-level HR Manager.
Working Conditions and Terms of Employment: Working conditions and terms of employment are detailed out in the employment contracts. Workers have fixed term formal contracts (annual or bi-annual) explaining working conditions including salary and deductions, working hours, leave entitlement, period of notice and job title.
Workers Grievance Mechanism: Raxio’s HR Handbook has an Open Door/Conflict Resolution Policy to address workers grievances. The policy requires that problems, concerns, or grievances by an employee about the workplace are brought to the attention of the supervisors and, if necessary, to HR team or upper-level management. The grievance policy will be aligned to the requirement of PS2, including providing for grievance documentation at all stages, clearly detailed feedback timelines during grievance processing, and options for anonymous grievances.
Workers Engaged by Third Parties: For construction and maintenance activities, Raxio retains specialized contractors. Contracts and legal documents signed with the referred companies usually contains legally binding requirements covering labor and E&S aspects and responsibilities in line with host country regulations. Additionally, the Group’s existing procedures related to contractors and third-party workers, such as code of ethic and conduct, environmental health and safety (EHS) policy, among others, are aligned with IFC PSs requirements. Raxio has strengthened its practices by developing Contractor Management Procedure (CMP), that include: (i) pre-qualification E&S criteria and process, (ii) minimum E&S requirements for contractors in line with the IFC PSs, (iii) E&S audits, monitoring and reporting (including performance indicators), and (iv) requirements and provisions regarding compliance with labor host country law and IFC PS2.
Occupational Health and Safety (“OHS”): The Group manages OHS matters under the Quality and EHS Vice Presidency, following the Group’s SGI requirements and procedures and consists of the strategic planning of OHS practices mapped out for the implementation of programs and compliance with the legal requirements of the host country and customer requirements. For the construction phase, Raxio has developed a comprehensive OHS guidelines the civil works and DC contractors. The Group has also developed OHS policies and plans in line with IFC PS2, including risks identification and control procedure, health security inspections, safety induction, OHS training programs, and an incident system that includes accident reporting, investigation, and corrective actions. All DC in operation will follow the aforementioned OHS procedures and practices aimed at preventing risks and accidents.
Life and Fire Safety: Raxio data centers are designed and equipped with fire prevention and response measures, including automatic sprinkler systems for the office blocks, and gas fire suppression system for the data hall. The system is fitted with a double interlock pre-action dry sprinkler protection system. Operational sites in Ethiopia and Uganda obtained operation L&FS permits from the local fire department, and the other sites will obtain the required permits before start of operations. Periodic fire and emergency response drills simulate scenarios. Raxio conforms to US National Fire Protection Association (NFPA) requirements for Life & Fire Safety, and local fire code.
Supply Chain: As part of ESAP #2 above, Raxio will strengthen its procurement procedures to align them with IFC PS2 and include a sourcing policy and supplier code of conduct stating prohibition of child and forced labor and significant safety issues.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency: The Project aims to achieve an average power usage effectiveness (PUE) of 1.42, which is in line with a PUE threshold of 1.56 or lower that is required for EDGE Green Data Center certification in hot & humid climate (~20% improvement in energy efficiency against a baseline PUE of 1.95). The data centers will largely be powered by energy sourced from the grid which mostly rely on renewable energy.
Water is supplied from the public network and in some countries supplemented by on site boreholes. The water used in the chillers is recirculated. The cooling system uses indirect adiabatic cooling which utilize a mixture of air and water cooling which considerably reduces water consumption.
All facilities monitor the electricity (PUE) and water use effectiveness (WUE), and the data is collated at the corporate level.
Greenhouse Gases (GHG) Emissions
As part of Raxio’s Environment and climate strategy, the Group has started collection of data from direct emissions from the organization's activities, indirect emissions that are generated in the consumption of electricity, and indirect emissions from diesel fuel consumption, to quantifies its footprint regarding to GHG emissions. The DC in Uganda has estimated emissions of 2,118 tons of equivalent carbon dioxide (tCO2e) per year for Scope 1 (direct) and 13 tCO2e for Scope 2, indicating the corporate level GHG emissions is not expected to exceed the 25,000 tCO2e per year.
Pollution Control
The wastewater produced in all operational data center facilities is domestic and therefore is discharged into the public sewage system. Regarding monitoring of emissions (wastewater, air, and noise), the company has developed an environmental quality monitoring program to ensure compliance against the General EHS WBG guidelines and local regulatory limits.
The backup generators’ fuel tanks are in built and equipped with adequate safety measures to prevent the likelihood of spills and leaks (double wall, containment, enough volume capacity to absorb full discharge). They also count with a nuisance control technology, which cancels 98% of the noise generated from its operation.
The Group has corporate waste management procedures for general, e-waste, and hazardous waste. The procedure specifies the collection, storage and final disposal of all wastes and implemented by all operational DCs. Solid waste is properly managed and controlled.
Raxio has disaster recovery plan and impact mitigation for hazardous material spill as part of its business risk management and service continuity planning.
PS4: Community Health, Safety and Security
Security Personnel: Raxio’s DCs are guarded by unarmed security guards from a specialized third-party contractor in each country. Raxio Group has prepared Corporate Security Management Guidelines in line with IFC PS4, which addresses the selection of security firms and their personnel to be installed at their worksite locations, as well as the training scheme including human rights and appropriate conduct towards data center users and potential interactions with nearby communities.
