This is a Category B project according to IFC’s Policy on Environmental and Social (E&S) Sustainability considering that it is expected to have limited adverse E&S risks and impacts that are a few, site-specific, largely reversible, and readily addressed through mitigation measures as described in the following sections.

Key E&S aspects associated with the project are: i) PTCL’s capacity to manage E&S system and organizational structure in line with IFC’s Performance Standards (PSs); ii) HR policies/procedures regarding working conditions, use of child/forced labor, gender based violence (GBV) prevention, contractors management, freedom of association, retrenchment, internal and external grievance mechanism; iii) management of OHS per good international industry practices (GIIP) focused on work at height, traffic/road safety, electrocution, extreme weather conditions, vibration, noise and use of personal protective equipment (PPEs); iv) effectiveness of emergency preparedness and response systems; v) effectiveness of life and fire safety system; vi) liquid and solid waste management generated from offices and hazardous waste generated from routine maintenance operations at tower sites; vii) contractor management; viii) community health and safety; ix) security management; and x) biodiversity risks management.                   

 PTCL has a Health Safety and Environment Policy which outlines the company’s commitment to conduct business in a manner that conforms with the national regulatory requirements. There is also an OHS manual and supporting documents, to manage health and safety risks of the Company’s operations in line with the local regulatory requirements. As per ESAP #1, PTCL will develop and implement a detailed E&S Management Systems (ESMS) for ongoing and future operations, in accordance with local regulations, IFC PSs, and WBG EHS Guidelines (General and Telecommunications). The ESMS will include the following elements: General E&S Policy; OHS Manual; Land Acquisition Policy; Greenhouse Gas (GHG) Accounting and Reporting System; and Management Review Procedure. 

As per ESAP #2, the company will develop the following E&S Management Plans (ESMPs) as part of its ESMS, to manage adverse E&S impacts of its operations: Resource Efficiency Plan, Atmospheric Emissions and GHGs Plan; Waste Management Plan; Water and Wastewater Management Plan; Hazardous Materials Management Plan; Noise Management Plan; Dust Management Plan; Electric and Magnetic Fields (EMF) Management Plan; Biodiversity Management Procedure; Emergency Preparedness and Response Plan (EPRP); Transport and Traffic Management Plan; Security Management Plan; Community Health and Safety Plan; and Stakeholder Engagement Plan and Community Grievance Redress Mechanism (GRM).

National regulations in Pakistan do not require Environmental Impact Assessments (EIA) or Initial Environmental Examination (IEE) for the development of mobile communication towers. However, there is a regulatory requirement to submit an Environmental Screening Checklist for construction of Base Transceiver Station (BTS) Towers. PTCL has developed a Risk Assessment (RA) and RAEAIA Procedure as part of its OHS Management System. The purpose of this procedure is to identify, evaluate and mitigate the EHS risks as a result of company operations. At this time, PTCL does not intend to construct new towers as the focus will be on acquiring Telenor’s existing assets. To guide ongoing and future operations, as per ESAP#3, PTCL will develop and implement an E&S Assessment and Management Procedure (ESAMP) aligned with IFC PS. The ESAMP will cover aspects including (a) E&S screening of future asset locations, (b) geospatial analysis to map sensitive E&S receptors within proximity of potential sites, including but not limited to biodiversity hotspots and cultural heritage sites; (c) land acquisition; (d) assessment and mitigation procedure for noise, waste management, hazardous material and waste management, electric and magnetic fields (EMF); and (e) stakeholder engagement guidance.

In the eventuality that a technically suitable location for new assets is within an area having key biodiversity values, and no suitable alternative is viable, site-specific Biodiversity Management Procedures, based inter alia on engagement with the relevant protected areas agencies, will be developed by specialist biodiversity consultants contracted by the Company to ensure that construction, operation, and maintenance of the asset(s) do not adversely affect the biodiversity values of the sites. If the development of a new tower will require the acquisition or lease of land, or of existing built structures, PTCL will screen the potential locations in accordance with the requirements of the ESAMP, which will include land acquisition considerations. Upon selection of a site, land acquisition or lease procedures will be governed by the Land Acquisition Policy, which will be included in the Company’s ESMS (ESAP #1).

The company has a competent Health, Safety and Environment (HSE) team headed by the HSE Director who is supported by the Group’s HSE and Sustainability Vice President and Director in Pakistan. Senior HSE Managers (South, Central, North) ensure on-the-ground implementation of the company’s EHS management procedures and policies.                                                   

 PTCL currently employs 15,047 workers (14,580 male and 467 female). In addition, there are 8,345 outsourced workers (employed by contractors). PTCL’s HR policies include a Statement of Ethics Policy and Diversity and Inclusion Policy, which is applicable to all employees of PTCL and its subsidiaries (PTCL Group). The company established requirement of a National Identity Card for hiring ensures that no individuals less than 18 years old are hired. As per ESAP #4, the company will enhance its HR policies to align with PS2 requirements, including those related to anti-sexual harassment and gender-based violence, prohibition of child and forced labor, and collective bargaining. The company will engage dedicated local HR resources to support the implementation of these HR policies, and all project workers will receive related relevant regular training.

The company provides all workers with a written contract that describes the working conditions and terms of employment. There is also an online portal called the People Care Experience Hub which functions as an employee handbook, and provides a summary of the remuneration, leaves, compensation, and benefits.

The company does not prohibit freedom of association, and workers have the right to form and join unions. An agreement with the Collective Bargaining Agent for PTCL workers was signed in October 2023 and is valid for three years.

Retrenchment of some staff is expected as a result of the merger of PTCL and Telenor. As per ESAP #5, PTCL will develop and implement a Retrenchment Plan in line with IFC PS2 to reduce adverse impacts of retrenchment on workers. The Retrenchment Plan will be based on principles of non-discrimination and comply with all legal and contractual requirements.

PTCL has a workers’ grievance mechanism (WGM), which addresses grievances and complaints including on sexual harassment and gender discrimination. As outlined in ESAP#6, PTCL will enhance the WGM in line with PS2 for workers to enable submission of anonymous complaints, and make it accessible to contractual and third-party workers. 

The company has a comprehensive ‘Contractor OHS Handbook’ which provides guidelines for safe operation. However, the document does not cover E&S aspects and is not legally binding on contractors. As per ESAP#7, PTCL will develop and implement a Contractor Management Plan aligned with IFC PSs considering current and future operations. The Contractor Management Plan will follow the guidance provided in IFC’s ‘Good Practice Note - Managing Contractors’ E&S Performance’ and will include a procedure to include legally binding obligations in the contractor (and subcontractor) contracts to ensure compliance with the requirements of all relevant ESMPs contained within the ESMS as well as national and IFC PS requirements.

Occupational health and Safety (OHS) is managed in PTCL through the ‘OHS Manual’, ‘Incident Reporting and Investigation Procedure,’ ‘Incident Portal,’ as well as ‘Training, Awareness and Competence OHS Management System.’ There is also a procedure for ‘Quarterly HSE Inspections.’ PTCL will develop an OHS Management Plan as part of its corporate ESMS (ESAP#2) which will be integrated with existing OHS policies and procedures. It will include required OHS management measures, monitoring and reporting of comprehensive safety statistics, OHS training and competence requirements, OHS inspection and auditing in line with the requirements of IFC PS2.

PTCL has established a Business Code of Conduct, that outlines the values and behaviors expected of third parties, suppliers, and business partners, including, but not restricted to anti-corruption, conflict of interest, child labor, as well as health, safety and environment. As per ESAP#8, PTCL will a) update this Business Code of Conduct to include forced labor issues; and b) develop a Supply Chain Management System to identify, manage supplier’s risk in alignment with PS2, this should include as a minimum i) a procurement policy and supplier code of conduct that addresses child labor, forced labor and significant safety issues as per PS2; ii) inclusion of contractual clauses requiring suppliers’ compliance with the code of conduct; iii) a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the code of conduct; iv) a communication strategy to inform suppliers about the code of conduct; and v) a formal process for supplier engagement, remedy or disengagement in case non-compliances that are not addressed.

 PTCL has wide range of facilities spread in all urban and rural areas of Pakistan including offices, customer care centers, exchanges and network towers. The Company utilizes national grid electricity as the main energy source. To limit power interruptions, almost all key sites are also equipped with back-up diesel generators. Keeping in view the energy situation of Pakistan, PTCL has a strong focus on adopting solar solutions to meet network energy requirements. Over 1,600 PTCL group sites currently have solar solutions which produce in excess of 13,000 MWh per annum. In 2024, there is a plan to deploy solar solutions on more than 200 tower sites, 20 exchange sites and data centers. Related supply chain risks will be addressed through the SCMP (ESAP #8). As part of its corporate ESMS, PTCL will develop a Resource Efficiency Management Plan to manage and minimize the use of electricity both from grid and off-grid sources.

The total expected greenhouse gas emissions from the PTCL project is 143,055 tonnes GHG (Scope 1 = 58,590 tonnes GHG and Scope 2 = 64,465 tonnes GHG) after the acquisition of Telenor Pakistan and decommissioning of redundant towers. As part of corporate ESMS (ESAP#1) a greenhouse gas (GHG) accounting and reporting system will be developed.

Pakistan has a high vulnerability to climate change. Expected climate impacts on the E&S side include a higher probability of extreme precipitation with subsequent riverine, flash, and coastal flooding. Higher temperatures and heat waves are expected. Under these conditions, worker´s safety can be compromised by increasing accidents, heat-related illnesses, lightning strikes, and the risk of losing access to communications. Climate-related events can damage the company's infrastructure, such as cell towers and network facilities, leading to service interruptions. As per ESAP#9, PTCL will put in place the following climate adaptation measures a) update Emergency Response Plan to include extreme weather events; b) update Worker´s HSE Policy to include risks associated with climate change/extreme weather events; and c) train relevant staff in disaster recovery procedures.

The company utilizes municipal water for majority of their operations. Quantities are limited and primarily used for routine administrative, sanitary, and cleaning purposes. No significant water use is expected due to the nature of the project.

Potential pollution risks from PTCL operations are associated with the use of backup generators for uninterrupted power supply in areas with unreliable connection to the electrical grid. 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 solid waste generated includes used batteries, electrical and electronic waste, scrap metal, oil and diesel filters, and general waste from maintenance and operations. Lubricant oil and lead-acid batteries is the main hazardous material found on sites. The E&S Policy of PTCL provides commitment to minimize adverse impacts on the environment and promote efficient resource utilization. The company has developed a draft ‘E-Waste Policy’, a draft ‘Waste Management Procedure’ as well as a ‘Risk Assessment and Environmental Aspects & Impacts Assessment (RAEAIA) System’ to ensure EHS-related risks of all routine and non-routine activities are identified, analyzed and mitigated as required. As per ESAP#2, the company will develop a Waste and Hazardous Waste Management Plan as part of ESMPs.

 The key community health and safety aspects for this project include potential risks from electricity and electromagnetic field (EMF); unauthorized access to fixed telecommunication assets; security arrangements; and traffic & road safety. PTCL has developed a EAIA system. The document includes ‘Guidelines to Identify Social & Community Risk’. As part of the ESMPs (ESAP #2), PTCL will develop an Emergency Preparedness and Response Plan (EPRP) as well as a Community Health and Safety Plan aligned with national requirements, IFC PSs, and WBG EHS Guidelines to address risks to communities and members of the public at large.

Staff and equipment transportation conducted by PTCL staff or by its contractors will be regulated through a Transport and Traffic Management Plan, which will be part of the Company’s ESMPs (ESAP #2), aligned with national requirements and IFC PS4.

PTCL security framework consists of hiring third-party contractors, such as security companies, to provide armed security at their offices and sensitive installations. As part of the Company’s ESMPs (ESAP #2), PTCL will develop and implement a Security Management Plan in line with the requirements of IFC PS4.        

 Helpline, customer care centers, and complaint portals on company website are available to address operational related complaints. PTCL will develop and implement a corporate Stakeholder Engagement Plan (SEP) as part of its ESMS (ESAP #1) and will also include guidance on pre-acquisition stakeholder engagement in its ESAMP (ESAP #3). The SEP will include a GRM to address community and other stakeholders’ concerns pertaining to PTCL operations.           

Contact Person: Mr. Muhammad Shoaib Baig

Company Name: PTCL

Address: PTCL Group Head Office, Plot#55C, PTCL Group Tower, Main Jinnah Avenue, Sector F -7/1, Blue Area, Islamabad, Pakistan

Email: shoaib.baig@ptclgroup.com