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.
The OpCos secure land required for their operations based on willing buyer-willing seller basis (land leasing) or space leasing on existing properties (e.g., retail shops or kiosks in shopping malls, or retail containers/booths at busy market locations). No impacts to IFC PS8 on Cultural Heritage were expected. In any case, the environmental and social management system (ESMS) of each OpCo will include risk screening, assessment, and management procedures for E&S aspects, including IP and cultural heritage. If IFC’s investment proceeds, IFC will periodically review the Project’s ongoing compliance with the Performance Standards.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
No overarching environmental and social policies have been developed for Vodafone Samoa, Vanuatu and Kiribati although the OpCos state to follow the Vodafone Global Sustainable Business Policies (https://www.vodafone.com/sustainable-business). The OpCos have not practiced E&S impact and risk identification and assessment. Although the OpCos have some procedures related to HR and OHS management for legal compliance, there is no structured E&S management system (ESMS) in place for implementation of the policy. Only Vodafone PNG has an overarching E&S policy. It has also undertaken an initial environmental examination (IEE) for all network, including around 1200 towers, and put in place a structured ESMS since 2021, which is generally aligned with IFC PSs. However, the E&S overarching policy and IEE have some gaps against IFC PS, including no specific policies on biodiversity protection/conservation, limited risk/impact assessment for community safety, including GBVH risk, from the acts of security forces.
While Vodafone PNG has EHS personnel with defined roles and responsibilities, the Vodafone Samoa, Vanuatu and Kiribati have no dedicated team responsible for EHS and social risks and impacts management. In all four OpCos, employees/staff receive no specific training on E&S risk and impact management. New employees/staff only receive onboarding training, sometimes including general OHS, conducted by HR team.
Vodafone PNG has developed and implemented an Emergency Preparedness and Response Procedure, but it has not assessed potential emergency scenarios related to its operations. Vodafone Samoa, Vanuatu and Kiribati have not fully developed and implement an IFC PS compliant EPRP.
Vodafone Samoa, Vanuatu and Kiribati currently has no EHS and social monitoring program, and no key performance indicators (KPIs). Only Vodafone PNG has developed monitoring and measurement procedure, as well as clear KPIs in its E&S management plans. In addition, the OpCos require only a few construction contractors and suppliers for its electronic equipment and tower parts. Contractor management and supply chain management systems regarding E&S aspects are currently absent in all OpCos.
Accordingly, as mentioned in ESAP#1, Vodaphone PNG will upgrade its E&S policies, with regard to biodiversity protection/conservation, and GBVH policies. Vodafone Samoa, Vanuatu and Kiribati will develop and implement E&S overarching policies in line with IFC PS, taking into account existing E&S policies from Vodafone PNG, local national regulations, and Vodafone Global Sustainable Business policies, if applicable.
As mentioned at ESAP#2, Vodafone PNG will update IEE, construction and operation E&S management plans/procedures based on impact/risk assessment identified as required for the development and update of emergency preparedness and response plan (EPRP), environmental and social monitoring program, supply chain management procedure, energy efficiency assessment and management plan, security management plan, biodiversity screening and management plan (BMP), and stakeholder engagement plan. Vodafone Samoa, Vanuatu and Kiribati will draw upon the updated IEE and ESMS from Vodafone PNG, adapt, adopt and implement in their respective operations, including among other aspects having in place (i) an E&S risk and impact identification and assessment procedure; (ii) a full review of OpCo-level E&S risks associated with existing facility operations and new activities to be financed by IFC loan, and determine corrective actions; and (iii) E&S management plans and procedures with clear responsibility allocation and resourcing; training and capacity building program; internal and third-party audits; monitoring, reporting and management review plan; emergency preparedness and response plan; supply chain management procedure and contractor management system, including contractual clauses/policy that explicitly prohibit GBVH, sexual exploitation, abuse, harassment (SEAH), with clear expectations for behavior, conduct, and ethics; community health and safety management plan; security management plan; biodiversity screening and management plan (BMP); Indigenous People Plan, and stakeholder engagement plan and community grievance mechanism.
As mentioned at ESAP#3, E&S capacity must be strengthened to include one E&S Manager, with in-depth knowledge and experience in sector specific standards and GBVH expertise to coordinate E&S policies and ESMS upgrade in the four OpCos. Each OpCos will put in place an appropriate E&S organization for implementation and oversight of the ESMS with at least one dedicated and qualified EHS and one social staff.
PS2: Labor and Working Conditions
HR Policies and procedures. The four OpCos have human resources (HR) policies and procedures covering some aspects of labor working conditions, but the aspects covered vary between the OpCos. Further, while employees are able to access the HR policies and procedures, these are inconsistently applied particularly in relation to non-office staff and third party workers. There have been no retrenchment, and it is not envisaged. While there are no workers union, the OpCos do not prevent workers from joining lawful unions. The OpCos do not have a structured system for oversight of contractor’s compliance with labor laws and OHS requirements. Two OpCos have some supply chain code of conduct but lack formal procedures for supplier due diligence and oversight related to child labor, forced labor and OHS. The HR policies and procedures of the OpCos do not include comprehensive and standardized terms of employment; policies on workers’ organization, and retrenchment; contractor management; and GBVH policy. Two of the OpCos have policies on equal opportunity and nondiscrimination but lack procedures to support effective implementation. Working conditions in OpCos lack comprehensive and enforceable standards, particularly in housing, compensation, and workplace facilities. The OpCos have grievance mechanism but lack provisions for anonymous reporting, confidentiality protection and non-retribution and do not cover third party workers. While some OpCos have a mechanism in place to ensure that contractors comply with labor standards, including prevention of GBVH, and extend some general expectations to contractors under their internal Codes of Conduct, OpCos lack grievance mechanisms for third party workers and do not have mechanisms to regularly monitor contractors. Sector-specific GBVH risks are considered high, particularly at remote worksites. Verbal, physical and sexual harassment risks were found in customer-facing retail settings. Verbal and psychological abuse, including sexually explicit harassment were also experienced by call center staff particularly those working evening and night shifts. As part of this investment, all OpCos will (i) review and update the existing HR policy and procedures in line with IFC PS2 requirements, including but not limited to prohibition of child labor, forced labor, working terms and conditions, including overtime policy, workers accommodation standards, worker organization, non-discrimination or equal opportunity; retrenchment policy, supply chain policy and code of conduct, and a formal GBVH policy (with relevant mitigation measures to prevent GBVH among workers) and an internal, safe, confidential and survivor-centered grievance redress mechanism and referral pathways; (ii) communicate and provide training on the updated HR policies and procedures to all employees; and (iii) extend the scope of application to third-party and supply chain workers, as appropriate. As such, the OpCos will develop and implement policies, procedures and contractual agreements for managing and monitoring third-party workers, including OHS requirements and grievance mechanism, to ensure their performance aligned with PS2 requirements (also refer to ESAP#2). For the supply chain, the OpCos will identify and assess risks related to child labor, forced labor and life-threatening OHS conditions (refer to ESAP#5), and implement appropriate mitigation/remediation measures (ESAP# 4).
Occupational Health & Safety. Project-related OHS risks include, among other, works at heights, electrical hazards, exposure to radio-frequency radiation, slips trips and falls, and confined space entry (e.g. cable works). Vodafone Samoa has OHS manual and associated policies that cover incident response, root cause analysis, internal audits, and provisions for worker health screenings. Vodafone PNG has a standalone OHS policy and related documents, including an OHS Risk Management Plan. Nevertheless, OpCos generally lack documented SOPs, internal audits, or indicators for tracking safety performance, and notably, no oversight mechanisms for contractors engaged in high-risk environments. As part of this investment, all four OpCos will develop or upgrade (i) OHS Management System to comply with IFC PS and relevant WBG EHS Guidelines including OHS policy, procedures of hazard identification and risk assessment, requirements for competency assurance and training matrix, procedures for monitoring and management audit; and (ii) operation-level EHS SOPs, including health and safety procedures and work to instructions, to align with IFC PSs, WBG EHS Guidelines for Telecommunication. The OpCos will ensure, including through contractual agreement, that contractors have an appropriate OHS Management System aligned with PS2 requirements. The OpCos will assess and monitor OHS management system and performance of primary suppliers, and implement OHS procedures/mitigation measures to prevent or to correct life-threatening OHS situations (ESAP#5).
PS3: Resource Efficiency and Pollution Prevention
Energy required for the operations at the OpCos is mainly via the national grid, and diesel generators and back-up batteries for technical centers and tower sites. Only Vodafone PNG has an energy efficiency management and monitoring plan, focusing on high-level measures toward energy efficiency. It is also planning for a systematic energy use assessment to find opportunities to save energy-related cost. The other three OpCos are also reviewing energy needs and availability to systematically move toward using more renewable energy in its operations. All four OpCos have not practiced calculation of annual greenhouse gas (“GHG”) emissions and reduction strategy.
The main sources of noise, air and dust emissions include diesel generators and vehicles. Only Vodafone PNG has developed and implemented an air and noise emissions management plan. No industrial effluent is produced as part of the operation. Domestic effluent generated from offices is treated through sewage systems with septic tanks and maintained by approved service providers. Leaking septic system and pit latrines are used in Vanuatu or Kiribati, which may cause soil and groundwater contamination.
The solid waste generated by the OpCos includes used batteries, electrical and electronic waste (e-wastes), scrap metal, and general waste. Lubricant waste oil and diesel filters are the main hazardous wastes generated from sites. Only Vodafone PNG has a waste and hazardous materials management plan. Wastes are generally segregated, stored and handed over to licensed contractors for disposal or shipment offshore (e.g., batteries). Common gaps regarding hazardous materials management include (i) oil spills with no secondary containment for fuel tanks; (ii) waste oil dumping in nearby environment.
The four OpCos will immediately (i) practice waste segregation; (ii) keep hazardous wastes (e.g., waste oil, light bulbs and discarded paint containers) in storage meeting national requirements and WBG EHS Guidelines; and (iii) handover only to licensed contractors (ESAP#6). The OpCos will (i) review energy efficiency and implement an energy use efficiency plan; (ii) assess environmental impacts from noise and air emissions, septic system and pit latrines, and solid and hazardous wastes, including consideration of local regulations, and provide mitigation measures, including waste and hazardous materials management plan, as required (refer to ESAP#2).
PS4: Community Health, Safety and Security
Key risks to communities’ health and safety linked to the operations at the OpCos include (i) exposure to electromagnetic field (EMF); (ii) use of heavy machinery during construction and road traffic accidents; (iii) structural integrity of towers and potential unauthorized access to tower sites; and (iv) potential abuse or GBVH from the acts of security personnel. Vodafone PNG has conducted assessment of the above potential community health and safety impacts and has management plans in line with the WBG EHS Guidelines for Telecommunication (2007) since 2021. Such community health and safety impact assessment and management plans have not been systematically established in other OpCos. As part of this investment, Vodafone Vanuatu, Samoa and Kiribati will conduct the risk assessment from its existing operation and future expansion to the community health and safety and determine mitigation/corrective actions, including but not limited to a road transport management procedure and EMF management program, as required (refer to ESAP#2).
Security Personnel. Each OpCo signs contracts with private security firms to provide security for main buildings, offices and data centers. Vodafone Vanuatu, Samoa and Kiribati employ third-party unarmed security guards. Vodafone PNG contracts a combination of internal and 35 external security firms. Security personnel in Port Moresby, PNG are trained and licensed by authorities to use firearms. Security companies are vetted for general background checks, including authorization by government. Security guards are screened for offenses including GBVH-related, but there is no evidence that these checks are standardized. Security staff do not receive specific training on GBVH or community engagement. All OpCos hire local care takers/guardians to oversee and protect telecommunications towers and equipment. While these caretakers are unarmed, they do not receive any formal onboarding or training, including GBVH prevention, appropriate conduct, or community engagement. The OpCos have no formal documentation or incident reporting system in place for misconduct or conflict involving security personnel or caretakers. As part of this investment, Vodafone Samoa, Vanuatu and Kiribati will develop a Security Management Plan to be aligned with IFC PS4. Vodafone PNG may update the existing IEE and Community Health and Safety Management Plan with appropriate mitigation measures regarding community health and safety from the acts of security forces (ESAP#7).
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources. The currently established mobile phone network is located within the island nations of Samoa, Kiribati, Vanuatu, and Papua New Guinea. All towers are terrestrial and occur mainly within Melanesia and Polynesia. The EcoRegions of the islands are diverse, and contain tropical forests, grasslands, coral reefs and forested coastal zones and wetlands. The region has a high endemicity and diversity of species.
A screening of all existing telecommunication towers across the network was conducted to determine if any of the towers have been constructed within Alliance for Zero Extinction (AZE) sites and World Heritage Sites (WZE). Further screening was conducted to identify overlaps with protected areas (PA) and Key Biodiversity Areas (KBA). The screening identified that there is one tower in Samoa that overlaps with an AZE site and eight towers in PNG that overlap with two AZE sites. For the site in Samoa, it overlaps with the Central Savaii Rainforest AZE site which has been identified for endemic birds. This tower is approximately 10 years old and is located on a hilltop on the southern edge of the AZE site. The site is within natural habitat and has a single access track which is maintained. It is unlikely to pose ongoing risks to the AZE site as it is not proposed to be expanded and will be subject to regular maintenance only. For the towers in PNG, seven towers are located within the Kemp Welch River AZE site, which has been identified for the Big Eared Bat Pharotis imogene IUCN CR, and one tower is located within the Central Manus AZE Site, which has been identified for Manus melomys IUCN EN, an endemic rat. All towers in PNG are within villages and pose low risks to these species.
Across the network, there are overlaps with KBAs and PAs in Vanuatu, Samoa and Papua New Guinea. These sites are located in a mix of natural habitats and modified habitats. A site visit was undertaken of a tower site within a KBA in Samoa to review site conditions, and it was confirmed that the site is long established with low biodiversity risks posed from access tracks and maintenance activities. The current management framework for mobile phone towers in Vanuatu and Samoa requires strengthening to reduce risks to biodiversity both during site selection and maintenance. Vodafone PNG has developed and implemented site selection procedure and BMP for maintenance, but has not considered WHS and hence requires updating.
To manage any ongoing risks from the telecommunication towers and their maintenance, Vodafone Samoa, Vanuatu and Kiribati will respectively prepare a Biodiversity Management Plan (BMP), which is to be included in the ESMS (refer to ESAP#2). The BMP is to include standard measures to manage risks to biodiversity values from access tracks, vegetation control, introduction of invasive species and access for community members that may promote illegal logging or poaching. The OpCos’s tower inspection and maintenance regime is to screen and identify towers of higher biodiversity risk which will then be subject to auditing and BMP implementation. For new tower projects, a biodiversity screening procedure is to be prepared that identifies the location of towers in relation to AZE and WHS sites as well as KBAs and PAs. Proposed sites within AZE and WHS sites are to be avoided unless there is no other alternative location, and the site is subject to a specific biodiversity assessment as required under PS1. Sites planned in KBAs, and PAs are to avoid sensitive biodiversity values as required under PS1 and mitigate any ongoing impacts as outlined within the BMP. Vodafone PNG will update the existing site selection procedure and BMP to ensure the prohibition of site in WHS (ESAP# 8).
PS7: Indigenous Peoples The great majority of population in the four countries are Indigenous Peoples. Key impacts to the IPs relate to land leasing for tower premises, but the impacts is considered limited due to micro-siting for tower operation, partially to avoid impacts. The OpCos seek the consent for development from the IP through a good faith negotiation process, with no influence from government. Only Vodafone PNG has developed and implemented an IP plan (IPP). Vodafone Samoa, Vanuatu and Kiribati has not systematically identified and assessed the impact to IP from its operations, and thus these OpCos will develop and implement an Indigenous Peoples Plan (IPP) in line with the requirements of IFC PS7 and commensurate to level of impacts to IP (refer to ESAP#2).
