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 Policies and Management System: Airtel Africa released its Sustainability Strategy in October 2021, which describes Airtel Africa’s commitments under business, people, community, and environment pillars, and a targeted approach to six United Nations Sustainable Development Goals. The strategy has also been developed to align with the UN Global Compact principles on human rights, labor, environment, and anti-corruption.
As part of Airtel Africa’s sustainability commitment and under the ESAP of IFC’s first investment, Airtel Africa developed E&S policies consistent with the objectives of IFC PSs including: (a) environmental policy; (b) safety, health, and security policy; (c) land acquisition, access, and compensation policy; (d) stakeholder engagement policy; (e) prevention of sexual harassment policy; (f) human rights policy; and (g) modern slavery policy. These policies are scaled to address E&S risks in Airtel Africa business activities and include commitment to apply to Airtel Africa suppliers and passive infrastructure service providers (telecom tower and fiber optic service providers) as relevant.
E&S Management Programs: Airtel Africa has developed E&S procedures and management controls to support the implementation of its E&S policies. These include (a) a greenfield screening procedure with a focus on biodiversity and social screening that applies to any site acquisition by Airtel Africa and includes developing or acquiring data centers and expanding base transceiver stations (network coverage) at greenfield sites; (b) “client EHS standards” document that applies to Airtel Africa suppliers and contractors including tower companies and maintenance contractors including requirements for high-risk tasks such as electrical work, work at heights, safe driving and vehicle safety, and fire safety, among others; (c) life and fire safety (LFS) and occupational health and safety (OHS) requirements for Airtel Africa own and operated assets; (d) electromagnetic field assessment and monitoring procedure; and (e) stakeholder engagement policy, stakeholder engagement plan, and community grievance mechanism.
Airtel Africa works with reputed third-party contractors for tower construction, operation, and maintenance and for fiber network laying, which follow their own E&S standards and procedures. As per ESAP #1, Airtel Africa will develop a Contractor E&S Management Procedure (CMP) based on the aforementioned “EHS standards” defining minimum requirements and monitoring of contractors, depending on Airtel Africa’s level of control and influence over them, as and when the contract renewals are due starting June 2025.
Organizational Capacity: Airtel Africa defined roles and responsibilities at the group and country level to support ESMS implementation. At the group level, Airtel Africa has an executive committee that reports to the Board of Directors and is responsible for setting the sustainability strategy and vision at the group level and deploying it across Airtel Africa markets.
At the country level, the local managing directors are accountable for the effective implementation of the ESMS. The implementation of specific E&S procedures is allocated to functional directors at the country level. The implementation of the LFS and OHS requirements at Airtel Africa's own and operated assets is the responsibility of facilities managers and the health and safety committees established for each country. Further, Airtel Africa has an E&S lead who advises and supports the group and country-level team to implement the sustainability commitments and E&S requirements.
With respect to the EHS performance and oversight of passive infrastructure service providers, Airtel Africa will assign organizational responsibilities to strengthen management and monitoring of their EHS and social performance in accordance with Airtel Africa ESMS requirements (ESAP #2).
Life and Fire Safety: Airtel Africa has LFS requirements applicable to all Airtel Africa’s own and operated assets. Buildings are provided with fire and smoke detectors, fire extinguishers, first aid kits, and fire suppression systems as relevant (e.g., data centers). General emergency awareness training is carried out periodically for all the workforce, and specialized fire marshals and first aid trainings are provided to designated employees who are tasked with emergency response. Periodic fire and evacuation drills take place. Airtel Africa coordinates with local government agencies for regulatory compliance and licenses on LFS requirements such as inspections and drills.
Monitoring and Reporting: Airtel Africa publishes an annual sustainably report consistent with the Global Reporting Initiative (GRI) (see https://airtel.africa/#/pages/responsibility?tab=approach_and_strategy). As part of the disclosure process, Airtel Africa monitors the implementation of the sustainability strategy, tracks selected E&S KPIs on monthly basis, and reports them in the sustainability report. Airtel Africa also carries regular environmental and OHS and security audits that cover operations in all its markets. Airtel Africa will develop an E&S Review[MK1][JEV2] Procedure that is focused on the ESMS implementation performance for each of project-related subsidiaries and take improvement actions (ESAP #3).
PS2: Labor and Working Conditions
Airtel Africa workforce comprises direct employees (referred to as on-roll employees) and third-party entity employees (referred to as off-roll employees). Airtel Africa HR policies and procedures apply to direct and third-party employees. As of 31st December 2023, more than 1000 employees are employed in the three project countries.
HR Policies: HR is centrally managed Airtel Africa’s headquarters. The company has HR policies which are consistent with respective host nation labor regulations and IFC PS2 requirements and apply to all employees. The HR Policy covers non-discrimination and equal opportunity. Requirements against sexual harassment and harassment-free workplace are addressed in the corporate code of conduct and policies. These HR-related policies are referenced in the employment contracts for all on-roll employees and address working conditions, terms of employment, leave, wages, and benefits. This information is provided to the employee at the time of induction.
Freedom of Association: In accordance with Airtel Africa Human Rights Policy, it encourages freedom of association and labor representation across the workforce, and regularly engages with and cooperates with recognized trade unions in markets where it operates. Airtel Africa has no current plans to undertake retrenchment activities in the foreseeable future.
Worker Grievance Mechanism: Airtel Africa has implemented a worker grievance mechanism which includes an anonymous channel to register grievances and is extended to all workforce. Airtel Africa also has a whistleblower mechanism managed by an independent third party, available and accessible publicly to all stakeholders, to address aspects related to the code of conduct topics such as anti-bribery, corruption, tax evasion, conflict of interest, related party related transactions.
OHS: The implementation of OHS/LFS requirements at the country level is overseen by the relevant Committees. To support effective and consistent implementation of OHS/LFS requirements across Airtel Africa’s operations in the DRC, Rwanda, and Keny, it will enhance its current OHS/LFS Framework to strengthen capacities and competency of the committee; OHS/LFS implementation, monitoring, and reporting requirements including measurable KPIs and OHS statistics for the workforce in line with IFC PS2 (ESAP #4).
Third-Party Workers: Airtel Africa is committed to working with suppliers and contractors to manage relevant E&S risks. Suppliers must comply with Airtel Africa’s Code of Conduct and Human Rights Policy, which includes provisions on forced labor and child labor and are required to complete an ESG self-certification and declaration process. As per ESAP #1, Airtel Africa will adopt a CMP based on the company’s “EHS standards,” including labor conditions and OHS with respect to its tower and fibre installations.
PS3: Resource Efficiency and Pollution Prevention
Electricity and diesel are the main resources used to power Airtel Africa offices, network operating centers, and passive infrastructure. Electricity is sourced from the public grid, and diesel is used as a backup power and is mainly relied on at locations where the electricity grid is not reliable or available. Airtel Africa discloses annually electricity and diesel consumption and optimization commitments in its annual sustainability report (https://airtel.africa/#/pages/responsibility?tab=approach_and_strategy). Therefore, Airtel Africa’s GHG emissions primarily relate to electricity and fuel consumption. Airtel’s 2022 sustainability report estimates total scope 1 and scope 2 GHG emissions in the African markets are 65,180 tons CO2eq and 50,539 tons CO2eq, respectively.
Airtel Africa has a decarbonation strategy with the ambition of achieving Net Zero carbon emissions by 2050. As part of the strategy to reduce electricity and fuel consumption, Airtel Africa identified the following focus areas: (i) improve energy efficiencies across all operations including operational improvements and modifications (ii) reduce diesel consumption at mobile network sites and investigate the use of low carbon alternative fuels for back-up energy generation (iii) increase the use of renewable energy and (iv) use of more environmentally friendly gas-based cooling and fire suppression systems at the data centers to reduce GHG emissions.
As part of Airtel Africa EHS standards, passive infrastructure service providers are required to adhere to hazardous materials management requirements such as the use of secondary containment and overfill prevention for fuel storage tanks and implement fuel delivery and spill prevention procedure among others. Requirements on noise and air emissions from generators are also defined in the EHS standards. Airtel Africa has waste management requirements to ensure compliance with local legal requirements, PS3, and alignment with WBG EHS Guidelines for Telecommunications. As per Airtel Africa requirements, generated e-waste is disposed of with qualified, licensed, and safe recycling and disposal service providers.
PS4: Community Health, Safety and Security
Community health and safety risks primarily relate to (a) road traffic incidents involving Airtel Africa staff or its contractors (b) contracted services for the expansion of Airtel Africa’s telecommunications networks and fiber capacities, such as towers contractors or fiber installation contractors; and (c) LFS in locations where Airtel Africa’s directly operated stores are located. Airtel Africa has defined EHS requirements for Airtel Africa staff and contractors which include requirements on safe driving, the implementation of it will be further strengthened as part of this investment ESAP (described under PS1). Airtel Africa implements LFS controls in accordance with host country regulations and consistent with GIIP, which primarily relate to emergency response in the event of a fire for both members of the public and Airtel Africa’s own workers at Airtel Africa’s directly operated stores.
Airtel Africa is committed to meeting host nation radio field/electromagnetic field (RF/EMF) requirements, and those of the International Commission on Non-Ionizing Radiation Protection (ICNIRP) with regard to EMF management. Airtel Africa has an EMF assessment and monitoring procedure, consistent with the WBG EHS Guidelines for Telecommunications, which sets out the requirements to eliminate potential health and safety hazards associated with EMF from Airtel Africa's own network equipment and sites operated by tower companies. The procedure includes equipment approval process; EMF measurement and auditing; EMF exposure guidelines; training of employees and tower company contractors; safe working procedure; among others.
Airtel Africa carries security risk assessments to determine the level of risk in different locations across its markets. The results of these assessments determine the level of security arrangements required to secure our equipment and assets. Airtel Africa uses different forms of security arrangements, including employing the services of qualified security services. Where contracted firms are retained to provide security, due diligence is completed to assess the integrity of contracted security firms, and Airtel Africa requires the security firms to comply with the good security practices, Airtel Africa code of conduct, and human rights policies.
