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
E&S Policies. Orange Mali has adopted the Orange Group Integrated Management System (IMS) policy aligned to with ISO 9001 (Quality), ISO 14001 (Environment), ISO 45001 (Occupational Health and Safety) by which the company commits to operate in compliance with national regulatory requirements, promote E&S practices, and an accident-free workplace. The policy does not include commitments on E&S assessment and management of risks and impacts, oversight of contractors, and stakeholder engagement. As per ESAP#1, Orange Mali will enhance the IMS policy to include these requirements as well as management procedures and requirements relating to, biodiversity, and land management in compliance with IFC Performance Standard (PS) requirements (ESAP#1).
Environmental & Social Management Systems. As per the requirements of the Orange Group IMS, Orange Mali has developed a Quality, Safety and Environment (QSE) policy, QSE manual and procedures on the management of waste, emergency response, risk evaluation, OHS and HR. Currently these E&S risk management procedures are not considered commensurate with the scope and nature of project related E&S risks and impacts. As per ESAP #2, Orange Mali will enhance its IMS to ensure adequate E&S management of ongoing and future operations in accordance with the principles of IFC PSs and World Bank Group (WBG) Environmental, Health and Safety (EHS) Guidelines (General and Telecommunications). This will include development of E&S management procedures on contractor E&S (including health and safety) management; E&S training; environmental management (noise, air, energy resource use); road transport management; electro-magnetic frequency monitoring; security risk management; community emergency response, monitoring and review, and stakeholder engagement (ESAP#2).
E&S Risk Assessment. Orange Mali identifies and manages E&S risks and impacts associated with new projects by conducting Environmental and Social Impact Assessments (ESIAs) per national standards, and E&S regulatory requirements. As per these requirements, Orange Mali has developed an E&S Impact Notice for each subproject. Site specific E&S Impact Notices related to the construction of relay antenna in the municipality of Bamako (municipalities I, II, IV, VI) and the rural areas of Bafoulabé, Dioka, Kangaba, Kati, Kayes, Kenieba, Kita and Koulikora have been completed, and these sub-projects have been constructed and completed. In addition, the company conducts environmental risk analysis based on feedback from key stakeholders e.g. contractors and suppliers. Potentially significant environmental aspects flagged are greenhouse gas (GHG) emissions, the use of natural resources, noise pollution, hazardous waste, and energy consumption. As per Ref. ESAP #2, Orange Mali will develop and implement procedures that address the applicable Ps requirements across all their installations, including prior to the commencement of works.
E&S training. Orange Mali will enhance their current training program to include EHS aspects and as part of their ESMS (Ref. ESAP#2), which will include training modules on its updated E&S policies, E&S management system, biodiversity risk management, and stakeholder engagement.
Organizational Capacity and Competency. The management of E&S aspects of the company is the shared responsibility of the HR Director, whose team includes Occupational Health Doctors and Safety Officers; and the Director of Audit, Risk and Quality (ARQ) Department who supervises the IMS Manager and the Environmental Compliance Officer. The HR Director also oversees the teams in charge of labor, security and contractor management respectively. Due to the current limited understanding of IFC PS among the Director ARQ, IMS Manager and the Environment Compliance Officer, Orange Mali will engage the services of an E&S expert to upskill the team on the IFC PS and WBG EHS Guidelines to ensure E&S risk are managed adequately in compliance with IFC PS (ESAP #3).
Emergency Preparedness and Response. As part of its IMS, Orange Mali has developed an emergency response procedure and a Disaster Recovery Plan which include site-specific measures to respond to potential environmental or OHS accidental occurrences, including accidents, fuel leakage, and fire. The procedures adequately define roles, responsibilities, and response measures; and set out requirements for staff and security guards training, work in remote locations, periodic drills and provisions for site operator’s emergency kits. Under their ESMS, Orange Mali will upgrade its plan to capture community emergency response and climate change risk (flooding, extreme weather including heat stress, etc.) In addition, the client will establish emergency response protocols, provide respiratory protection, and maintain clear evacuation routes to safeguard workers from wildfire hazards.
PS2: Labor and Working Conditions
Direct Workforce. As of December 2024, Orange Mali had a total of 675 employees, including 576 direct staff (permanent and temporary) and 99 third-party workers managed directly by Orange; with 29% of the workforce being women. Contract workers are hired for different activities, based on scope and duration (tower construction, call centers, O&M, fiber cable works, etc.).
Human Resource Policy and Procedures. Orange Mali has an Internal Regulation manual, aligned with local labor laws and national requirements, that addresses labor and working conditions and terms of employment, including wages, working hours, leave, hygiene and safety at work and freedom of association. The manual also covers policies related to discrimination, GBV and harassment, hiring (internal and external), performance evaluation, training, and induction. The company provides benefits and allowances for direct employees including health insurance, transport, leave and social security. Child and forced labor are strictly prohibited and this is documented in the manual. Orange Mali has a grievance mechanism applicable to their employees. Going forward, Orange Mali will enhance the current grievance mechanism and extend it to all workers including contractors and all other third-party service providers, consistently with the requirements of IFC PS 2. The mechanism will provide for receipt and resolution of grievances on multiple platforms, including anonymous grievances (ESAP #4).
Third Party workforce. Orange Mali relies on the services of third-party service providers. 99 workers are hired and paid directly by third party suppliers, however; are supervised directly by Orange Mali. The wages meet national requirements, and the terms of employment are aligned with national law. To align with IFC PS 2, The company will develop a procedure to manage those externalized workers and as part of ESAP #2, and the company will ensure its policies will apply to these workers.
Contracted workers. Orange ’s Mali workforce includes a significant number of outsourced and contracted workers for construction, operation and maintenance with task specific contracts. Those are directly hired by the company following their procurement procedures. Terms and working conditions of those contractors are aligned with national regulations.
Orange Mali has developed and implemented a supplier code since 2020. As per the ESMS (Ref. ESAP#2), the company will upgrade its procurement Management Procedure, outlining the E&S requirements that primary suppliers must adhere to integrate environmental and labour requirements into the project contracts, commensurate with the risks arising from respective operations. The clauses will include E&S audit, remediation action and contract termination if significant non-compliances are persistent.
Workers Organizations. Orange Mali is signatory to the Malian interprofessional collective bargaining agreement which guarantees employees freedom of association and encourages all employees to exercise their rights through election of representatives and participation in union activities. Currently, workers in Orange Mali belong to two unions, Ostom (Organisation Syndicale des Travailleurs d’Orange Mali and Systom (Syndicat National des Travailleurs d’Orange Mali). The company acknowledged the unions’ existence and had a respectful relationship with them. No pending concerns/ grievances.
Occupational Health and Safety. Orange Mali has developed an QSE Policy and manual that is certified for ISO 45001 and audited periodically. A risk dashboard is established based on its probability, significance and based on the feedback received from contractor workers and technicians. This dashboard is updated annually. Major risks flagged are terrorism, fall from height, physical attack, reptile attack, private data leakage, and propagation of an epidemic. The company implements a permit to work system and job safety analysis are required by each contractor before commencement of work, including site OHS meetings. Since 2016, the companies recorded OHS incidents and accidents are mostly related to road traffic, fires and other minor injuries to workers. In 2023 and 2024, a total of eight hours has been recorded as lost time injuries, and.no fatalities have been recorded since 2016. Orange Mali will upgrade its OHS manual to include specific measures for protecting workers from high temperatures and flooding events. These measures should cover heat stress prevention (e.g., hydration, shaded rest areas, adjusted work schedules) and flood risk management (e.g., evacuation procedures, safe work protocols during heavy rainfall). Orange Mali will cascade down the requirements of the OHS management system to its contractors and will require that each contractor retains a suitably qualified OHS personnel within their project teams (ESAP#5).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency. Orange Mali’s sites are mainly powered via the grid, except technical centers and tower sites, which are equipped with diesel generators and back-up batteries. Orange Mali is also deploying limited solar panels at some locations to reduce its dependency on the grid.
Greenhouse Gas Emissions. The company track and record their emissions. Based on the electricity and fuel consumption data, the GHG emissions is 43,700 tCO2e in 2023 and 69,700 tCO2e in 2024. Approx. 98% of the emissions are from the fuel consumed by the backup diesel generators. Under their ESMS (ESAP#2), the company will enhance their GHG management procedures to clearly stipulate measures to reduce GHG emissions.
Water. Water is supplied from municipal sources, but total consumption is not monitored as Orange Mali considers that quantities are limited and primarily used for routine administrative, sanitary, and cleaning purposes. As part of its ESMS (Ref. ESAP #2), Orange Mali will integrate water management and usage in the monitoring scope.
Wastewater. Sanitary wastewater production is limited to their administrative office. The company relies on the municipal sewerage system to dispose of their wastewater. No quantity monitoring in taking place.
Pollution prevention. Potential pollution risks from the company’s 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.
Management of Solid/electronic Waste. Solid waste generated includes used batteries, electrical and electronic waste, scrap metal, oil and diesel filters, and general waste from maintenance and operations. The ISO 14001 management system provides commitment to minimize adverse impacts on the environment and promote efficient resource utilization. The company has developed a waste management procedure. To support their waste management program, the company has also contracted a service provider for the recycling of electrical and electronical waste.
Hazardous Materials. Lubricant oil and lead-acid batteries are the main hazardous material found on sites. The waste management procedure developed by the company has a provision for the collection of hazardous waste by a contractor. Orange Mali as per the E&S management system (Ref. ESAP#2) will upgrade the existing waste management plan to integrate hazardous waste management and set key performance indicators (KPI).
PS4: Community Health, Safety and Security
The primary community health and safety aspects associated with this project include potential risks from electricity and EMF; unauthorized access to fixed telecommunication assets; security arrangements; and traffic and road safety. As part of the E&S procedures under ESAP #2, Orange Mali will include community risk considerations in its Emergency Preparedness and Response Plan (EPRP) and will develop a Community Health and Safety Procedure aligned with national requirements, IFC PSs, and WBG EHS Guidelines (General and Telecommunications) to address risks to communities and members of the public at large.
Traffic safety. Company vehicles and transportation conducted by Orange Mali or by its contractors will be regulated through a Transport and Traffic Management Plan, which will be developed as a part of the company’s E&S procedures under ESAP#2, and aligned with national requirements, IFC PS4 and WBG EHS Guidelines. As such, the plan will specifically address driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance and safety standards.
Security personnel. The Orange Mali security framework consists of hiring third-party contractors to provide unarmed security at their offices and sensitive installations. No screening of security guards is conducted and induction given to the security guards is related to site access and the monitoring of the fuel for the generators. Orange Mali will develop and implement a Security Screening Evaluation procedure to conduct background checks and identify past abuses associated with guards, as well as; develop and implement a Security risk Management Plan commensurate with the project’s risks including, training requirements, a code of conduct, and provision of human rights training (ESAP#6).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Orange Mali operates approximately 2,780 towers which are situated throughout the country. Most existing towers are situated in modified habitats associated with human settlements, agriculture, or immediately adjacent to existing roads, with no changes relative to baseline conditions expected for any of these sites. Some existing towers overlap the following eco-regions: South Sahara Desert, West Sudanian savanna, and Inner Niger Delta flooded savanna. Numerous existing towers overlap with nationally protected or internationally recognized areas (IRAs), including the following Key Biodiversity Areas (KBAs): Sirakoroni – Tyènfala, Bafing, Lac Débo - Lac Oualado Débo, Tombouctou and Falaise de Bandiagara KBA. Twenty-one towers are situated in the Cliff of Bandiagara, Land of the Dogons World Heritage Site (WHS) which is listed based on cultural criteria.
To ensure appropriate assessment and management of biodiversity risks for existing sites and any future acquisition or construction on new sites across the business, Orange Mali will (i) include PS6-compliant biodiversity commitments in its E&S Policy/ESMS (Ref. per ESAP#1) including avoiding the construction of new assets in areas of high biodiversity value, such as legally protected areas, IRAs, KBAs, and particularly Natural and Mixed WHS and Alliance for Zero Extinction (AZE) sites.
As part of ESAP#7, Orange Mali will develop a Biodiversity Screening and Management Procedure aligned with IFC PS6 requirements which will (i) define an approach to screen for areas of biodiversity sensitivity, and (ii) identify the steps required for assets located in such areas, which will include consultation with the relevant stakeholders (e.g., legally protected area management agencies, conservation organisations) to ensure compatibility with the values of these areas. The procedure will also include measures relevant to the rehabilitation of disturbed areas, including the use of native species for rehabilitation purposes, management of invasive species, soil erosion, forest clearance, managing human access, and ongoing maintenance, as part of the management of biodiversity-related aspects for planned sites in line with IFC PS6.
As per the procedure, when avoidance of areas of high biodiversity value is not feasible, the company will develop a Biodiversity Action Plan (BAP) to define additional biodiversity protection measures and enhancement programs to contribute to the conservation objectives of these areas (Ref. ESAP #7), in consultation with relevant stakeholders – these engagements will be integrated in the Stakeholder Engagement Plan (Ref. per ESAP#8). For the existing portfolio, Orange Mali will ensure that biodiversity mitigation measures (e.g. sediment and erosion control measures) are included in management plans; and in regions with high biodiversity risk, Orange Mali will identify additional conservation actions to contribute to the conservation objectives of these areas, in consultation with relevant stakeholders.
