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 Impact
E&S Policies. To effectively manage the scale and range of E&S risks posed by the company’s operations, IPT has developed, and implemented, a well-defined ESMS aligned with local laws and regulations, IFC PS 1 and commensurate to the level of risks and impacts associated with the company’s activities. The ESMS is underpinned by several policies, procedures, and guidelines, including an overarching ISO 9001, 14001 and 45001 certified Group Integrated Management System (IMS). The IMS Manual details various E&S policies and processes, risk identification, operations planning, emergency preparedness, contractor management etc. As per ESAP #1, IPT’s proposed Liberian, Sierra Leonean, and Ethiopian entities will refine and adopt the requirements of the IMS Manual, and other relevant policies and procedures where required, prior to the commencement of operations.
Identification of Risks and Impacts. As per the T-ESCO business model, IPT is not responsible for the identification, acquisition, or permitting of sites as this responsibility falls to the relevant MNO or tower company. Further, IPT only conduct construction and maintenance activities within the boundaries of these telecom sites, and only pertaining to the standard installation and maintenance of the energy infrastructure. The company maintains a dynamic risk register and has implemented a group level procedure for the identification and evaluation of site-specific risks and hazards in relation to all activities, products, and services. The procedure follows a Hazard Identification Risk Assessment and Determining Control (HIRA-DC) process. As per the procedure, the head of each department and the respective local entity is required to undertake a job risk and environmental risk assessment, as per defined templates, prior to the commencement of any constriction activity. As per ESAP #2, prior to the commencement of construction activities on sites in Liberia, Sierra Leone, and Ethiopia, IPT will conduct the required risk assessments, including a job hazard analysis, and provide evidence to IFC, as per the defined process.
Management Programs. IPT has developed several group level management procedures and plans, including a Health and Safety Management Manual, and standard operating procedures relating to electrical safety, working at heights, waste management, refueling, contractor management, training requirements, emergency preparedness etc. Local entities, as a component of their overall ESMS, are required to adopt and refine these procedures as necessary.
Organizational Capacity and Competency. IPT’s current organizational capacity is commensurate with the nature and scale of the company’s E&S risks and impact. This includes a group level Health, Safety, and Environment (HSE) manager as well as a Science Based Targets Initiative (SBTi) certified resource within the technical team. At the operational level, all local entities have dedicated Quality, Health, Safety and Environment (QHSE) managers. These managers are further supported by several QHSE officers, and in some cases QHSE committees. As per current practice, IPT will procure, prior to the commencement of operations, the necessary QHSE resources at the Liberian, Sierra Leonean, and Ethiopian operations.
Emergency Preparedness and Response. IPT has developed a group level Emergency Preparedness and Response procedure that is applicable across all operations and activities. The procedure, which outlines emergency response processes to minimize the impacts on employees, contractors, the public, and the environment. The procedure stipulates the frequency of drills, identifies the roles and responsibilities, and trainings required, and states the actions to be taken in an emergency. Due to the nature of IPT’s operations, fire presents a key risk and can present associated emergency elements. In this regard, all workers are provided with firefighting training and all sites are equipped with adequate fire detection and suppression systems.
Monitoring and Review. The company has developed a Monitoring HSE Performance procedure covering all activities defined in the IMS Manual. The procedure provides guidance on qualitative and quantitative data collection to measure the efficacy of the IMS implementation. Local entities conduct site safety audits on a monthly basis as per a defined checklist. HSE performance statistics are kept for personnel injury, man-hours, road traffic statistics, environmental and site integrity, waste management, security issues, and leading indicators. The company also has an internal audit function which assess and audit compliance with the IMS on an ongoing basis.
PS2: Labor and Working Conditions
Human Resources Policies. IPT employ approximately 1,500 workers across their various T-ESCO operations, with a male to female ratio of 92:8. The company has a group HR Manager, with each subsidiary employing their own HR management team. IPT has defined a group Code of Conduct which local entities are required to adopt. The Code of Conduct defines the company’s approach to health and safety, discrimination, harassment, child, and forced labor etc. Each IPT subsidiary has also developed a relevant Employee Handbook covering areas such as probation, working hours, disciplinary action, termination of employment, compensation, benefits, and career development. As per current practice, the company will define a respective Code of Conduct and Employee Handbook as per local legal requirements and IFC PS2 for the Liberian, Sierra Leonean, and Ethiopian operations.
Working Conditions and Terms of Employment. Labor and working conditions are defined by the relevant statutory requirements of the country of operation. Terms and conditions of employment, including remuneration, working hours, leave, benefits, training etc., are detailed in written employment contracts provided to all workers. Country specific Employee Handbooks, made available to all staff upon employment, further define labor and working conditions and detail specific policies relating to equal opportunity, harassment, confidentiality, health and safety etc. Existing policies and procedures were found to be largely aligned with the requirements of IFC PS 2. Where enhancement is required, these actions have been specified in the ESAP.
Workers’ Organizations. As per the IPT Employee Handbook, workers are permitted to i) establish trade unions, without any discrimination, for the promotion and protection of their economic and social interests, ii) join any such unions of their choice subject to the rules of that union, or iii) refrain from joining any such unions. Currently only workers within the company’s Guinean operations are unionized under the national sectoral union, the African Telecommunications Union (ATU-UAT).
Non-Discrimination and Equal Opportunity. As detailed in the Employee Handbook, and reiterated in the Code of Conduct, IPT has adopted an Equal Opportunity Employment Policy whereby the company details their management approach towards equal opportunity in employment, non-discrimination etc. Additionally, the company has defined a Harassment Policy defining the approach to managing issues of harassment in the workplace.
Grievance Mechanism. IPT has developed a Grievance Mechanism applicable across their various entities, including contractors as necessary. Implementation of the mechanism is the responsibility of the relevant HR managers and community liaison teams and follows a stepwise process for the receipt and resolution of worker and external stakeholder grievances. The procedure makes allowance for anonymous complaints, and defines requirements and timeframes for the logging, reporting and resolution of grievances. As per ESAP #3, IPT will provide evidence of dissemination of the mechanism, and presence and maintenance of a grievance log at their Sierra Leonean, Liberian and Ethiopian operations.
Protecting the Workforce: As defined in the Employee, handbook, IPT does not employ children in manner that is economically exploitative, likely to be hazardous, or interfere with education. In this regard, the company does not employ anyone under the age of 18 years. Further, IPT will not utilize any form of forced labor within their workforce.
Occupational Health and Safety. Key OHS risks associated with IPT’s T-ESCO operations primarily emanate from construction and maintenance activities, as well as road safety risks (covered under PS 4). In this regard, the company has implemented a group procedure for the identification of risks and hazards and has conducted a comprehensive assessment and impact analysis of their activities and associated hazards. Where high risk activities are present, the company applies, as relevant, standard operating procedures (SOPs) for high-risk activities such electrical safety, hot work, manual handling, working at height, confined spaces etc. In addition, the company provides periodic OHS training to all workers and has implemented a personal protective equipment (PPE) procedure defining the requirements for specific PPE depending on the nature of the job and associated risk.
The company has developed an Incident Investigation Procedure, supported by standard reporting templates, an incident log, and root cause analysis. As per the 2023 incident reports for existing T-ESCO operations, the company reported a total of 48 incidents, including 1 fatality.
Workers Engaged by Third Parties. IPT does not make extensive use of third-party contractors, with the majority of their T-ESCO operations managed by their direct workers. Contractors are utilized for areas such as security, and in limited cases, additional workers are contracted through HR firms where required. The company has developed a Contractor Management Procedure covering all contractors and third-party service providers. The procedure highlights the process for selection, approval, and monitoring of contractor performance.
From an E&S perspective, as per the Contractor Management Procedure, the relevant HSE manager is responsible for providing technical inputs into the procurement process, ensure bids are aligned with the IMS, assess submissions, conduct inductions, ensure contractor awareness of OHS and E&S risks and obligations, and conduct periodic audits. All contractors are required to comply with the IPT IMS as well as relevant policies and procedures.
Supply Chain. IPT currently utilizes several primary suppliers for various project components, including, but not limited to, solar photovoltaic (PV) panels, lithium-ion and lead acid batteries, diesel generators (DG), and industrial enclosures. The company currently has a limited supply chain management system. In this regard, as per ESAP #4, the company will (i) develop and adopt a Supplier Code of Conduct that explicitly prohibits any form of child and/or forced labor and includes specific requirement in relation to OHS, (ii) implement contractual clauses in written agreements with suppliers requiring compliance with the Supplier Code of Conduct, (iii) implement a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the Supplier Code of Conduct, (iv) have a communication strategy to inform suppliers about the Supplier Code of Conduct, (v) implement a formal process for supplier engagement, remedy or disengagement in case non-compliances that are not addressed.
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. As noted, IPT’s T-ESCO business model involves the design, sourcing, operation, and maintenance of energy solutions for telecoms operators. These energy solutions typically include a combination of energy sources, depending on technical and contextual requirements and limitations, such as national grid, DGs, and solar. As IPT largely operate in countries where the availability and reliability of grid power is limited, a combination of DGs and solar are the predominant approach.
The company has initiated a greenhouse gas (GHG) reduction / decarbonization project supported by an international consultancy. This includes the establishment of an emission baseline and implementation of a medium-term GHG strategy. Based on current estimates and the proposed expansion into Liberia, Sierra Leone, and Ethiopia, the company’s total estimated GHG emissions are approximately 22,000 tonnes of carbon dioxide equivalent (tCO2e) per annum.
Due to the nature of IPT’s T-ESCO operations, no significant water usage or air emissions are expected.
Waste and Hazardous Waste Management. Due to the nature of IPT’s T-ESCO operations, quantities of waste are generally limited. Main waste streams include plastic, paper, cabling etc., while hazardous waste includes used engine oil, lithium ion and lead acid batteries.
As a component of the IMS, the company has defined a Waste Management procedure, covering both hazardous and non-hazardous waste, detailing the approach to waste handling, storage, transportation, collection and disposal. The company has adopted a reduce-reuse-recover and dispose approach. Key elements of the management approach include designated on-site areas for waste storage, recording of waste types and quantities, maintenance of waybills, and monthly reporting.
The management of hazardous waste, specifically batteries, used oil and e-waste, is covered under specific SOPs. Currently used batteries are stored in an appropriate manner as per their chemical composition. Batteries are either disposed of through approved local service providers, or where not available, they are exported and recycled. The company maintains waste manifests regarding the disposal of all hazardous waste. The company will identify suitable service providers in Liberia, Sierra Leone, and Ethiopia.
PS4: Community Health, Safety and Security
Community Health and Safety. The nature of IPT’s T-ESCO business model does not result in significant risks to community health and safety. Potential risks include those resulting from construction activities, although these are temporary and limited to the site, fire, traffic and road safety, and noise and vibration. In terms of noise, while the company does not have control over site selection and location, specifications of energy equipment, in particular DGs, and noise limits, are specified in contracts with the MNO or towerco. As noted, fire also presents a risk, particularly on rooftop installations. To mitigate this risk, all battery cabinets and DGs are equipped with temperature, smoke, pressure and airflow sensors and cooling units. All sites are secured with perimeter fencing to prevent public access.
As per ESAP #2, prior to the commencement of construction activities on their sites in Liberia, Sierra Leone, and Ethiopia, IPT will conduct the required risk assessments, including consideration of potential community health and safety risks.
Traffic Management. Where IPT currently has T-ESCO operations, they operate a rented fleet of vehicles to allow technicians to access sites during construction and infrastructure installation, for refueling of generators, and to conduct periodic maintenance. The company has developed a Transportation of Equipment procedure, that applies to direct and contract workers, detailing the procedure for the safe transportation of large equipment. All vehicles are also fitted with GPS and any road traffic incidents are reported, and investigated, through the existing incident reporting procedure.
As per ESAP #5, the company will update the existing transportation plan or develop and implement a standalone Transport Management Plan detailing requirements for driver vetting, training, vehicle inspection and maintenance, route management etc.
Security Personnel. As per IPT’s T-ESCO model, the company is usually responsible for the provision and management of onsite security personnel. Each OpCo has a Head of Security responsible for overall security management, and the company has implemented OpCo specific Security Management policies and management plans. Security incidents predominantly relate to the theft of fuel and batteries. In this regard, the company utilizes third-party service providers for the provision of unarmed security guards at all sites. Security providers are subject to the same procurement process as defined under the IMS, with performance assessed bi-annually.
As per ESAP #2, IPT will conduct the required risk assessments for their respective sites in Liberia, Sierra Leone and Ethiopia which will inform the nature of site security arrangements, including the deployment of guards. In addition, as per ESAP #6, the company will define OpCo specific Security Management plans in Liberia, Sierra Leone and Ethiopia, aligned with the requirements of IFC PS4 and IFC’s “Good Practice Handbook: Use of Security Forces: Assessing and Managing Risks and Impacts”.
