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
PS1: Assessment and Management of Environmental and Social Risks and Impacts
As required under previous IFC transactions with Telco (#37209) and Axian Bond (#46459), the two operations companies (Opcos) developed ESMSs to address E&S risks. Both Opcos have IFC-aligned E&S policies underpinning their ESMS, aligned with Axian Telecom Group’s E&S strategy and policies, endorsed by senior management are aligned with UN Global Compact principles. ESMS Manuals were developed at the group level and shared with the Opcos for adoption and customization of relevant procedures, checklists, and templates required by IFC under previous investments’ E&S Action Plans (ESAP). The policies are also aligned with legal laws and regulations and are communicated to staff and key contractors. The group will however review its corporate commitments on biodiversity protection as specified in the PS6 section below.
Both Opcos conduct Environmental and Social Impact Assessments (ESIAs), where required, and secure environmental permits for the installation, operation, and maintenance (O&M) of existing assets, including new base transceiver stations (BTS), and design and construction of new ones. The laying and installation of optic fiber cables is done along public utilities rights-of-way and does not require an ESIA. However, ESIAs for both Opcos and environmental permits for proposed new assets were still in process, awaiting confirmation of engineering designs. Prior to installation and commissioning of any new site, Tigo Tanzania and Telco will provide IFC with copies of the required environmental permits and completed ESIAs prepared in line with IFC Performance Standards (ESAP#1).
The Opcos have adopted corporate E&S plans and procedures to develop country-level documents, including procedures for EHS risk management, emergency response, contractor EHS management, grievance management, traffic management, land acquisition, waste management, chance find, EHS training, security management, stakeholder mapping, community safety and internal audit, all broadly in line with IFC PS requirements and WBG EHS Guidelines. However, contractors’ oversight in Tanzania appeared to require enhancements to reduce incidents and accidents. Going forward, Tigo Tanzania will (i) strengthen its contractors’ oversight and extend the applicability of E&S requirements to cover local sub-contractors, with additional E&S training and clearly articulated EHS compliance objectives in line with the company’s E&S commitments and the relevant WBG EHS Guidelines (General and for the Telecommunications sector); (ii) develop an audit plan and requirements to monitor adherence by sub-contractors to the enhanced objectives. (ESAP#2)
In response to previous IFC’s recommendations, both Opcos strengthened their E&S organizational structure. Telco nominated an experienced E&S and Regulatory Director assisted by one HSES Manager and two EHS Officers. Tigo Tanzania also appointed a qualified EHS Manager, supported by 3 EHS staff, including a CLO (community liaison officer). Opcos E&S teams report to Axian Telecom’s Sustainability and Impact Manager who is seconded by the group’s HSES Compliance officer (in charge of internal audit) among others. Key O&M contractors have appointed dedicated personnel, to enforce and monitor compliance in line with the Group’s E&S commitments, including compliance with IFC PSs and EHS Guidelines. Local contractor personnel at Tigo Tanzania however, appeared to require additional E&S training, including on safe driving; this will be covered under ESAP#2 above.
Both Opcos have developed Emergency and Response Plans which include site-specific measures to address potential environmental or OHS accidental occurrences, including flooding risk. The procedures adequately define roles, responsibilities, emergency triggers, types and drills; evacuation protocol, emergency structures, life and fire safety (LFS) measures, coordination with external parties; emergency training; and standard emergency operating procedures for various emergency types. The current plans will be updated to cover climate change risks as specified under ESAP#5 below.
Telco and Tigo Tanzania track and report monthly E&S performance to the corporate team, covering all E&S KPIs as defined at group level. Opcos’ inputs inform Axian Telecom’s Annual Reporting (https://www.axian-telecom.com/cirdowee/2024/05/SUSTAINABILITY-REPORT-2023_VF_280524.pdf). The corporate audit Officer is responsible for appraising the effectiveness of the set E&S performance requirements, and reporting on required improvements, in line with the Group’s Internal Auditing Standard. Both Opcos also report on their E&S performance to IFC as part of the previous engagements.
PS2: Labor and Working Conditions
As of July 2024, Tigo Tanzania had 610 employees, including 574 permanent staff, with 32% women. Telco had 164 employees, with 50% women. Both Opcos use contractors for various activities. Axian Telecom developed a Group-level HR Manual, adopted by Telco and Tigo Tanzania, covering key issues like recruitment, remuneration, workers' rights, working conditions, retrenchment, career development, OHS, and non-discrimination. Employees receive written contracts outlining terms of employment, communicated during onboarding.
Both Opcos developed PS2-aligned policies on non-discrimination and non-harassment, ensuring a conducive workplace. Telco held Delegates elections in April 2023. The HR Manual includes a retrenchment procedure requiring analysis of alternatives before collective dismissals. Axian Telecom developed a PS2-compliant grievance management mechanism, with Telco implementing a country-level mechanism. Tigo Tanzania will develop a similar mechanism, including channels for reporting GBV&SH complaints (ESAP#3).
The Group’s HR Manual mandates compliance with national labor regulations, prohibiting child and forced labor, extended to contractors. Tigo Tanzania will verify this during contractor EHS reviews per ESAP#2).
Both Opcos have developed OHS systems underpinned by the group’s HSES Policy, ensuring a safe working environment. An OHS risk reporting system is in place, with periodic evaluations and audits. Company vehicles have GPS systems, and drivers undergo defensive driving training every two years. Per group’s policy and previous commitments, Axian developed Accident/Incident Investigation and Reporting Procedures, enforced by Opcos via their OHS systems with compliance inspections, including on contractor activities. However, Tigo Tanzania did not adequately oversee its contractors/subcontractors OHS performance. It also recorded 2 road traffic incidents which resulted in fatalities in 2023. Telco in contrast, had a more satisfactory performance with 1 LTI (Lost Time Incident) in 2023. Under ESAP#2, Tigo Tanzania will carry out an audit of its contractors, prioritizing those in charge of transport, security, civil works and operation and maintenance works; against the Contractor EHS Management Procedure and Contractor E&S Requirements Guide and develop an Action Plan to close out any identified gaps with respect to compliance with PS 2.
The ‘Contractor HSES Management Procedure’ was designed at corporate level in line with the previous engagement and was cascaded down to the Opcos to govern contractor’s operations, including working conditions and workers terms of employment. Telco successfully conducted an HSES gap analysis of its contractors’ ESMS and OHS practices in 2022 and used the findings to inform a corrective action plan that has been satisfactorily implemented. Tigo Tanzania will carry out its audit as recommended under ESAP#2 above.
Both Opcos’ workforces use a significant number of outsourced and contractor workers. The contractor selection and vetting procedure has been recently upgraded to include general performance requirements prior to awarding a contract.
PS3: Resource Efficiency and Pollution Prevention
Tigo Tanzania and Telco rely on grid electricity and diesel generators, with complementary solar power at remote BTS sites. They track energy consumption and report to management and the corporate E&S team. Water is supplied from municipal sources for administrative, sanitary, and cleaning purposes. Axian has assigned resource usage KPIs and integrated both Opcos into the group’s ‘Impact score framework’ for resource tracking and reporting. The group has established a methodology for annual greenhouse gas (GHG) emissions quantification and reporting. 2023 emissions for Telco and Tigo Tanzania were respectively 2594.5 tCO2 and 15002 tCO2, including Scope 1 and Scope 2 emissions.
The main climate change vulnerabilities in Comoros and Tanzania include extreme temperatures and flooding. Both Opcos will conduct detailed physical risk assessments, implement adaptation measures, arrange hydration stations, and incorporate evacuation procedures, safety drills, and training into their emergency preparedness and response plans (ESAP#4).
Diesel generators at BTS are self-contained to prevent spillage, and diesel supplies are stored securely. Tigo Tanzania is replacing generators at sites with noise grievances with grid or solar power. Telco will complete noise monitoring and share findings with IFC, including corrective measures (ESAP#5).
The main waste streams at both Opcos include office general wastes and hazardous wastes from equipment maintenance. Telco developed a waste management procedure validated by IFC in 2021. Used batteries are processed abroad, waste oil is stored awaiting disposal, and non-hazardous waste is collected for municipal landfill disposal. Tigo Tanzania follows a corporate procedure for waste collection and disposal via licensed dealers. Obsolete equipment is reconditioned or sold. Specific procedures for hazardous waste management, including e-waste, used oil, and batteries, have been developed. Waste management targets are set for each Opco as part of the ‘Impact scorecard’.
PS4: Community Health, Safety and Security
Community health and safety risks at both Opcos are mainly related to road traffic incidents involving company and contractors’ staff (or their subcontractors), potential risks from electricity and electromagnetic field (EMF); unauthorized access to fixed telecommunication assets; security arrangements; or LFS risks at worksites and shops.
The group developed a Community Health and Safety Management Procedure which mandates to include E&S considerations in the design of assets, erection of new towers, repairs and maintenance works, and impacts of EMF (and relevant siting criteria) and provide training for staff and contractors on the management of waste, security, transportation risks to communities. These will be strengthened as part of the current investment (per ESAP#3). EMF assessment and monitoring procedures and LFS requirements for Opcos have also been defined in line 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 the related Opco’s own workers at directly operated stores. Under ESAP#5, Telco will agree with IFC on a timebound plan to conduct EMF monitoring plan and share its findings.
The Opcos security framework consists of hiring third-party security companies to provide unarmed security at their offices and sensitive installations. As required by the group’s security management policy, Opcos carry out security risk assessments to determine the level of risk at various operational sites and perform a due diligence to assess the integrity of the contracted security firms. The results of these assessments determine the level of security arrangements required to secure equipment and assets, and to interact with members of the public. The selected security firms are required to comply with the good security practices, Axian Telecom Group’s code of conduct, and human rights policies.
PS6: Biodiversity Conservation and Sustainable Management of Natural Living Things
To ensure adequate management of biodiversity risks, under the previous transactions, Axian Telecom was required to update its overarching E&S Policy to include PS6-compliant biodiversity commitments and avoid potential risks to Alliance for Zero Extinction (AZE) or World Heritage Sites (WHS). The group has also appointed an experienced biodiversity manager based in Madagascar to implement the policies and support all subsidiaries in biodiversity risk management. Axian Telecom will review its corporate E&S Policy to fully avoid adverse impacts on UNESCO WHS and AZE sites, ensuring protection of the Outstanding Universal Value (OUV) and the species and ecological processes they support. (ESAP#6)
Similarly, all subsidiaries, including Telco and Tigo Tanzania, were required to carry out country-specific Biodiversity Assessments and develop site screening procedures and Biodiversity Action Plans (BAPs) in line with IFC PS6. While Telco has implemented its BAP satisfactorily, Tigo Tanzania is still developing its own.
In Comoros, Telco proposes expanding its tower footprint by 24 sites in the Comoros Forests ecoregion, with two sites in Key Biodiversity Areas (KBA), one of which is an AZE site. Telco must develop a PS6-compliant BAP and dismantle towers in AZE sites as part of the E&S requirements from the last transaction. Axian Telecom Group's HSES policy will be revised to meet PS6 requirements for AZE and WHS as specified above. Telco will update its BAP to include the relevant new sites (ESAP#7).
Tigo Tanzania operates 370 existing towers and plans to deploy 262 additional sites in various ecoregions, including East African montane forests and moorlands, Southern Acacia-Commiphora bushlands and thickets, and Central Zambezian miombo woodlands. A biodiversity screening report for the first 127 additional sites indicates that thirteen are in nationally protected or internationally recognized areas, including KBAs and UNESCO WHS. Tigo Tanzania will urgently complete the pending Biodiversity Assessment and adjust the scope of the BAP to include the additional planned sites and existing towers (ESAP#8).
The remaining 135 sites will be screened using the same protocol once the Tanzanian government discloses the proposed locations. The findings will be substantiated by ground-truthing, and the sites will undergo critical habitat assessment, BAP development, and usual ESIA processes. The screening report for the remaining sites will be submitted to IFC for review, and the stakeholder component of the BAP will be integrated with the updated Stakeholder Engagement Plan (SEP) (ESAP#9).
