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.
PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
Telecom Armenia has a corporate Environmental Policy in place, including a code of conduct and policies related to occupational health and safety and human resources, which are applied across the operations.
The company is implementing an ESMS in accordance with PS 1 and applicable national regulation. The ESMS includes plans and procedures to identify, assess and manage E&S risks associated with company’s operations, including an E&S screening, due diligence, and assessment procedure, waste management, visual impact, pollution prevention / spill management, community health and safety, contractor management, security management, land acquisition and access, biodiversity conservation, and chance finds (cultural heritage). The ESMS is robust and allows the company to identify, assess and manage relevant E&S risks and impacts of new projects and assets, including the project capex plan, as well as acquisitions.
As required under the E&S Action Plan (ESAP) and agreed under the existing loan with IFC, Telecom Armenia has a suitably qualified E&S expert, whose responsibility includes to oversee the implementation of the ESMS.
Among others, as a result of the ESMS upgrade carried out under the ESAP, the company has developed an Environmental & Social Management Plan, including a Biodiversity & Land Management & Monitoring Plan (BLMP), which, along with its Screening Procedure applies to both existing and new tower locations. The Screening Procedure is implemented to identify and map any overlap of project activities (e.g. construction, maintenance, updates) with high-risk areas for biodiversity, including Legally Protected Areas, Internationally Recognized Areas (notably Alliance for Zero Extinction (AZE) sites), or areas which qualify as Critical Habitat, Natural Habitat and other priority biodiversity values per IFC Performance Standard 6. In line with PS6 mitigation hierarchy, the company avoids construction of towers within these areas. Where avoidance is not possible and project activities are to be performed within areas of known biodiversity value, the company will apply PS6 requirements, including the micro-siting of ground-based towers in a manner to avoid of impacts on the biodiversity values associated with these areas and will document the implementation of such measures.
PS 2 – Labor and Working Conditions
As of October 2024, Telecom Armenia employed approximately 1,900 direct employees and around 200 contractor staff. Specialized works are done in-house, but general construction works are outsourced to contractors.
Armenia has ratified the ILO core labor standards, and they are incorporated in the national labor laws. Hereby the core labor standards, as defined in PS2, are part of the national requirements which the company is required and committed to follow for its employees. The labor code of Armenia forbids forced labor. The company and its contractors do not employ anyone under the age of 18 years and the employee’s age is verified and recorded during the recruitment process.
Telecom Armenia has formal Human Resources (HR) policies and procedures which define rights and obligations (including non-discrimination and equal opportunities) and working conditions. The Code of Ethics, which applies to all company employees and extends to contractors, outlines a commitment to encouraging equality and diversity among the workforce and eliminating unlawful discrimination. The code also prohibits any form of harassment, including sexual harassment.
Human resources requirements, including the Code of Ethics, are communicated to all company employees during onboarding with refresher training being conducted periodically. The company has a Workers’ Organizations Policy which outlines the respect of employees’ rights to join a lawful workers’ organization of their choosing and commitment to comply with the laws on freedom of association and collective bargaining.
The company has developed and implemented policies on the prevention of forced labor, child labor, discrimination, sexual harassment, and gender-based violence which cover for the work force protection against all forms of those risks. As per the HR procedures, the requirements outlined within the policies and procedures are extended to all contractors and sub-contractors irrespective of the duration of their contract.
The company implements a worker's grievance mechanism (‘Speak Up Policy’) in accordance with IFC PS2, which allows staff and contractors to report potential or known violations against the Code of Ethics and to raise employment-related complaints. This process includes various channels of communication, including anonymous reporting. The grievance mechanism also includes specific considerations related to harassment/gender-based violence grievances. This includes multiple entry points to raise and address allegations.
An Occupational Health and Safety Management System (OHS MS) is implemented in accordance with IFC PS2. The OHS MS includes an OHS risk assessment and OHS Management Plan which includes clear procedures for hazard identification and assessment, hazard and risk controls, incident reporting and investigations and OHS training and competency requirements. The company conducts annual safety inspections of all working locations. All workers complete basic OHS training and supervisory staff and employees undertaking high risk activities complete specific OHS training. The management system includes a risk register OHS risks associated with the company’s operations, including physical, chemical, and electric hazards, and gender-differentiated risks, including appropriate mitigation measures.
The company implements a supplier due diligence procedure consistent with IFC PS2 to identify, manage, and monitor supply chain risks, and track performance of project key contractors and suppliers. The company also implements a Business Partner Code of Conduct which defines requirements and responsibilities of suppliers and contractors in relation to sustainability and human rights including child labor, freedom of association, and health & safety risks.
PS 3: Resources Efficiency and Pollution Prevention
Telecom Armenia’s operations do not result in significant quantities of waste and emissions. Electricity is sourced from the public grid for the majority of the company’s assets, with diesel generators only being relied upon in more rural areas in which grid power is unreliable. Backup power in case of outages at base stations and towers is predominately provided by batteries and in some cases by solar panels. IFC estimates that the GHG emissions associated with the project are 35,000 tCO2 equivalents per year.
Potential pollution risks from company operations are associated with the use of backup generators. 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. The only hazardous waste anticipated from the project is used lubricant oils from diesel generators, lithium and lead acid batteries and contaminated soils where spillages may occur. E-waste generation will be limited to computers, printers and other electronic equipment used in the offices.
As part of the ESMS, Telecom Armenia implements an environmental monitoring plan (e.g., noise and EMF, as discussed under PS4) and a hazardous material and waste management plan, aligned with local legal requirements, IFC PS3 and the relevant and applicable parts of World Bank Group EHS general guidelines and EHS guidelines for Telecommunications.
The company utilizes municipal water for its operations. Quantities are limited and primarily used for routine administrative, sanitary and cleaning purposes. Significant use of water resources is not expected.
PS 4: Community Health, Safety and Security
Community health and safety risks associated with the project include exposure to construction vehicles and transport, and exposure to dust, noise and vibrations caused by constructions works. Operational hazards may include unauthorized site access, road safety, life and fire safety (L&FS) of publicly accessible buildings i.e., retail stores, and potential risks from electric and magnetic fields (EMF).
Telecom Armenia implements a Community Health and Safety Plan as part of its ESMS and in accordance with IFC PS4 requirements, covering equipment and infrastructure design and safety, EMF, prevention of unauthorized access, hazardous materials safety, and community exposure to disease. Separate management plans for traffic safety, emergency preparedness and response, and security management are also in place.
The company has conducted an inspection program of existing assets, including a review of structural integrity, physical security, and EMF (as per ICNIRP guidelines).
The company’s retail stores are aligned with the national fire code, which includes requirements for fire prevention, fire protection and emergency planning. The company is implementing a fire safety policy commensurate to the risk level of the retail stores and includes information on basic fire emergency planning and training.
The company has Emergency Preparedness and Response Plan (EPRP) at a corporate level which is aligned with IFC PS and GIIP, and facility level (i.e., retail stores, warehouse) plans. The EPRP includes features specific to retail stores, management of the general public (i.e., children, people with disabilities and elderly, etc.), information related to the particular store (i.e. location and address, selection of two safe external gathering points, external hazards) and drawings of the specific fire protection features. The EPRP also cover emergency scenarios for towers and other infrastructure, such as fires, electrical hazards, tower collapse, and severe weather conditions.
The company implements a Traffic and Road Safety Management Plan aligned with national requirements, IFC PS4 and GIIP. Traffic safety measures include a risk matrix, safety training for drivers, and regular journey planning and car inspections.
Physical security at retail stores, office buildings and warehousing are predominately completed by in-house security personnel, with security service providers engaged in selected locations, in which 24-hour surveillance is required. The company implements a Security Management Plan in accordance with IFC PS4, and including screening and training requirements for security personnel, rules of force, and incident reporting.
