While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and Working Conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 - Community Health, Safety and Security
PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources

The project will not result in impacts that must be managed in accordance with PS 5, PS 7 and PS 8 as the focus is on existing tower portfolio. Engro Deodar’s ESMS will include procedures to screen for risks associated with these PSs during future expansions, aiming for compliance if triggered. Deodar will lease land for tower installation through voluntary lease basis, this approach will be incorporated into Deodar’s ESMS procedures for screening and managing land related risks during future expansion ensuring compliance with PS 5.

Relevant contextual risks associated with Pakistan include labor rights violations and security concerns, climate risks, and gender-based violence and harassment. Key E&S issues associated with this investment include: 1) identification and management of E&S risks and impacts including E&S screening and assessment of new assets and sites; 2) policies and procedures on human resources management, occupational health and safety, stakeholder engagement, gender based violence, fair and safe working conditions for employees, contractors and security guards; 3) solid waste management, including e-waste and hazardous materials; 4) communities’ health, safety and security: construction impacts, traffic management, electric and magnetic fields, use of security forces; 5) biodiversity risks for new assets; and 6) stakeholder engagement strategies including effective grievance redress mechanism.

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

Jazz is Pakistan’s first and largest Mobile Network Operator (MNO) providing voice, SMS, and data services to over 71.3million mobile subscribers. In 2016, Jazz carved out its telecommunications towers business under a wholly owned subsidiary Deodar Private Ltd. (“Deodar”). Deodar owns and operates 10,617 towers and has a 55% market share in the national Towerco space. Post carve-out from Jazz, Deodar continued to receive operational support from Jazz in the form of employees, systems, processes and procedures, and technology.

In December 2024, Jazz and Engro Corporation Limited (Engro) entered into an amalgamation agreement, under which Deodar would be vested as a wholly owned subsidiary of E-Connect. The first payment for this transaction was made on June 3rd, 2025, after which the legal ownership of Deodar transferred to E-Connect.

Jazz and Engro have executed a Transition Service Agreement (TSA), for a period of 1 year to end in Q2 2026 (extendable on a monthly/annual basis), under which Jazz will continue to provide operational support, including its Environmental, Social, and Governance (ESG) and Health, Safety, and Environment (HSE) frameworks. These frameworks, managed by Jazz’s ESG and HSE teams, include risk assessments, emergency preparedness, and environmental monitoring, ensuring continuity for Deodar’s operations. Despite the Transaction, both Jazz and Deodar have a symbiotic relationship – Jazz is the anchor tenant on Deodar’s existing towers, and as such it is in Jazz’ interest to ensure that the services envisaged under the TSA are fully extended so that its MNO operations remain unaffected.

Post-TSA, Jazz’s involvement will end, and Deodar’s E&S systems will fully transition to Engro’s framework. Engro maintains a comprehensive Health, Safety, and Environment (HSE) policy framework, including hazard identification, risk assessment, and control (HIRAC) procedures and ISO 14001-aligned practices, cascaded to all subsidiaries. E-Connect, focused on telecom infrastructure initiatives like build-to-suit towers, operates entirely under Engro’s management system with no distinct E&S policies.

Policy: Jazz maintains a corporate level Health, Safety and Environment (HSE) policy, supported by a dedicated Environmental, Social and Governance (ESG) department. The environmental components are aligned with the Global Reporting Initiative (GRI) standards and the European Union’s Corporate Sustainability Reporting Directive (CSRD), focusing on climate change, adaptation, resilience and circular economy. The social component, which is guided by Veon’s (the ultimate parent company of Jazz) global sustainability goals, emphasizes the improvement of lives and livelihoods of women and youth in Pakistan through technology.

At the corporate level Engro provides leadership, HSE policies and procedures that are cascaded to its subsidiary companies. Engro’s HSE policy aims to achieve zero occupational injuries and illnesses and prevent safety and environmental impacts.

Deodar has been operating under the umbrella of Jazz and therefore subject to Jazz’ policies and management systems. As part of the TSA, Deodar will develop its capacity, capabilities and competencies with the support of Jazz and Engro E&S functions and systems. During such period, Engro will lead the harmonization of Deodar’s E&S systems, integrating Jazz’s ESG and HSE frameworks with Engro’s policies (e.g., risk assessments, contractor training HIRAC, sustainability reporting) to ensure compliance and leverage existing strengths. As per ESAP #1a, Deodar will align its Environmental and Social Management System (ESMS), with IFC Performance Standards (PS) and World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines, building on this harmonized framework.

E&S Management Programs: Prior to the Transaction, Jazz maintained an Environmental and Social Management System (ESMS) that included procedures for OHS, risk assessment (permit to work), waste management, emergency planning, accident reporting, and firefighting, aligned with national regulations and OHSAS 45001. These systems were in place to manage E&S risks associated with Jazz's operations, and Deodar, as part of Jazz, followed these procedures. The ESG department oversaw environmental and social risk management, with a focus on sustainability reporting and compliance.

Engro’s HSE team implements ESMS across its subsidiaries, incorporating risk assessments, emergency response plans, and compliance monitoring, guided by ISO 14001 principles and national regulations to ensure environmental and social performance that meets compliance requirements. This demonstrates Engro's commitment to robust E&S management across its operations. E-Connect's management system is fully integrated in Engro’s corporate systems and processes.

During the TSA, Deodar will use its systems in place like the procedure for Environmental Assessment for new sites and rely on the systems in place by Jazz. These procedures are guided by national laws and regulations and are informed by the OHSAS 45001 methodology. This agreement ensures continuity of operations and E&S management while Deodar integrates with Engro.

Upon termination of the TSA, Deodar will harmonize its Environmental Management System with ISO 14001 and other standards to strengthen its E&S performance and align with good international practices. This alignment includes procedures for assessing and managing health and safety risks, conducting environmental assessments of new sites, ensuring effective emergency planning and response, and HSE management during operations.

To achieve this, Deodar will conduct a gap analysis of its EMS against IFC Performance Standards 1-4 and 6, and relevant WBG EHS Guidelines (2007), including those for telecommunications. As per ESAP #1a, Deodar will develop and implement an Environmental and Social Management System (ESMS) for ongoing and future operations that will encompass an Environment, Health, Safety and Social (EHSS) Policy.

Deodar will develop an ESMS Manual (ESAP#1b), with monitoring and reporting indicators and responsibilities, an updated accident reporting and investigation procedure, a land leasing policy and procedure, a biodiversity policy, a Greenhouse Gas (GHG) Monitoring and Reporting System, an EHSS training plan for staff and contractors and sub-contractors to address topics such as contractor management and stakeholders engagement including affected communities.

Deodar as part of ESAP#1c develop and implement E&S Management Plans (ESMPs) as part of its ESMS to manage E&S risks associated with its operations. These plans will include, but not be limited to:
• Resource Efficiency Plan
• Atmospheric Emissions and GHGs Plan
• Hazardous Materials Management Plan
• Waste and Hazardous Waste Management Plan
• Noise Management Plan
• Dust Management Plan
• Occupational Health and Safety Management Plan
• Electric and Magnetic Fields (EMF) Management Plan
• Biodiversity Management Procedure
• Emergency Preparedness and Response Plan (EPRP)
• Transport and Traffic Management Plan
• Security Management Plan
• Community Health and Safety Plan
• Stakeholder Engagement Plan (SEP)
• Community Grievance Redress Mechanism (GRM)
• Contractor Management Plan (CMP)

Identification of Risk and Impacts: Deodar has established procedures for assessing and managing health and safety risks applicable to both its direct operation and those of its contractors. These procedures, which are aligned with OHSAS 45001 standard, include hazard identification methods, risk assessment techniques, and implementation of control measures. They define the scope, responsibilities and minimum standards for risk assessment and management, so that hazards are identified, and risks are properly assessed, so applicable actions can be taken to eliminate, reduce and control them.

Deodar also maintains a HSE policy with the objective of achieving zero incidents, and utilizes hazard identification, risk assessment, and control (HIRAC) sheets as part of its established procedures to identify potential work-related hazards, evaluate the associated risks, and lists relevant control measures to minimize these risks. During the transition services agreement, Deodar will consolidate its own risk identification procedures with Jazz and Engro.

Currently, Deodar has 10,617 telecommunication towers, and under the Transaction, may add an additional 4,200 towers during the next twelve years. While national regulations in Pakistan do not mandate Environmental Impact Assessments (EIA) or Initial Environmental Examinations (IEE) for mobile communication tower development, regulatory requirements include submitting an Environmental Screening Checklist for construction of Built to Suit (BTS) towers and obtaining environmental approval (NOC) from the Environment Protection Agency (EPA) at the planning stage, as per IEE/EIA guidelines. The EPA approval process restricts tower locations in environmentally sensitive areas such as forests, biodiversity hotspots, or protected areas.

Deodar has developed a procedure for the Environmental Assessment of new greenfield sites, incorporating site selection criteria that consider sensitive socio-economic, historical, cultural, and environmental receptors, as well as employees’ health & safety. The existing procedure will be strengthened to align with IFC PS (ESAP#2). The revised E&S Assessment and Management Procedure (ESAMP) will cover aspects including (a) E&S screening of future asset locations incorporating a Biodiversity Screening Procedure, (b) geospatial analysis to map sensitive E&S receptors within proximity of potential sites, including but not limited to high-risk areas for biodiversity and cultural heritage sites; (c) land leasing procedures; (d) assessment and mitigation procedure for noise, waste management, hazardous material and waste management, electric and magnetic fields (EMF); and (e) stakeholder engagement guidance.

The revised ESAMP will ensure that locations of higher environmental, biodiversity, cultural heritage, or other social value for local communities (including land leasing) are identified and avoided, or where avoidance is not possible, risks and impacts are assessed and mitigated as per IFC’s PSs. The screening process will consider risks to Legally Protected and Internationally Recognized Areas, and other significant areas of high biodiversity value as per IFC PS6. In the event that a technically suitable location for new assets is identified within Legally Protected or Internationally Recognized Areas, and no suitable alternative is viable, Deodar will contract specialist biodiversity consultants to develop site-specific Biodiversity Management Plans (BMPs), based on engagement with relevant stakeholders (including protected area managers and sponsors, regional/national authorities, conservation organizations, etc.), to ensure that construction, operation, and maintenance of the asset(s) do not adversely affect the biodiversity values of the sites. If the development of a new tower requires lease of land or existing built structures, Deodar will screen the potential locations in accordance with the requirements of the ESAMP, which will include land leasing considerations. Upon selection of a site, lease procedures will be governed by the Land Acquisition Policy, which will be included in the Company’s ESMS (ESAP #1).

Organizational Capacity and Competency: Deodar's organizational structure for E&S management includes the Managing Director (MD) who is accountable for Deodar's compliance with health and safety policies, including the allocation of resources across the business, and the Safety, Health, Environment, Risk, and Quality (SHERQ) Manager, who has overall responsibility and authority to ensure that Deodar's Health and Safety Management System is defined, documented, and communicated across all workplaces. The SHERQ Manager also oversees fire management procedures, focusing on identifying and mitigating fire risks. To strengthen its E&S organizational structure and capacity and ensure effective ESMS implementation, Deodar will undertake the following actions (ESAP #3): a) provide training in IFC PS requirements to the newly hired E&S Manager enabling them to effectively supervise the development, implementation, and monitoring of the Company's ESMS and oversee the implementation of the ESAP items; b) hire dedicated Occupational Health and Safety (OHS) Officers for each region (North, Central, South, West and East) where there are operations to manage and monitor health and safety risks during tower construction and maintenance activities; and c) hire a social and labor specialist to enhance oversight and monitoring of stakeholder engagement, community grievances, and labor and working conditions of third-party contracted workers.

Jazz's E&S function is integrated within the Corporate Communications and Environment, Social and Governance (ESG) team, which serves as a corporate regulatory authority. Social risk management is managed collaboratively by three departments: ESG, HSE, and the Diversity, Equity, and Inclusion (DEI) team. Management of environmental risks falls under the purview of the Head of ESG (Environment and Climate Change), while social risks are managed by the Stream Head of ESG (Governance and Sustainability). The environmental function operates in accordance with Global Reporting Initiative (GRI) and Corporate Sustainability Reporting Directive (CSRD) material topics. Jazz's HSE department consists of a team of HSE officers, led by an HSE Manager, with dedicated regional HSE managers reporting to the headquarters corporate HSE function. These regional HSE managers oversee national compliance and contractor safety training. Oversight responsibilities include random audits and training of technology teams on HSE standards and global practices. Under the TSA, Deodar will continue to have access to Jazz’s policies, procedures and required resources ensuring continuity of E&S management.

At the Engro level, E&S risk management is led by the Health, Safety, and Environment (HSE) team. This team develops policies and procedures that are cascaded to subsidiaries, including Deodar, and provides technical guidance, support, and oversight. Following the TSA with Jazz, Deodar will increasingly integrate Engro’s E&S policies and procedures into its own management system, leveraging Engro corporate’s expertise and resources.

Emergency Preparedness and Response Plan (EPRP): Deodar has established an Emergency Preparedness and Response procedure, and an Emergency Evacuation Procedure covering all its operations, including planning, implementation, and maintenance. Emergency plans have been developed for each site. The Managing Director, SHERQ Manager, QA Supervisor, line management, and staff (employees and contractors) are responsible for implementing these procedures. The Emergency Planning Committee (EPC) is responsible for the planning, implementation, documentation, review, and assessment of the company wide Emergency Response Plan. The procedures outline the roles of the safety warden and quality assurance supervision and reference OHSAS 45001 and the Factory Act (1934). They guide the company in identifying and assessing potential emergencies arising from events and/or activities and implementing suitable response plans. The Emergency plans include specific emergency plans for each site, emergency control personnel contact details and responsibilities, local emergency authority contact details (police, fire brigade, ambulance), identification of emergency situations, and record keeping protocols.

Jazz has developed an Emergency Responses Procedures Manual applicable to all its operations. During the TSA, this manual also applies to Deodar’s operations, supplementing Deodar’s existing procedures with additional detail and resources. The Jazz manual provides a more comprehensive framework while Deodar’s existing procedures ensure site specific considerations are addressed. These manual addresses potential risks to Deodar’s infrastructure, operations and staff. Jazz also has an emergency procedure to ensure the safe evacuation of employees, contractors and visitors during company operations. Quarterly mock drills and training sessions are documented through reports and photographs. All contractors are trained by the Jazz team. Engro provides the guiding policies and procedures for emergency preparedness and response to its subsidiaries.

To ensure alignment with international best practices, as part of the Company ESMS update (ESAP #1), Deodar will update its existing Emergency Preparedness and Response Plan (EPRP) to make it fully consistent with the requirements of IFC PS 1 and 4.

Training: Deodar provides training on health and safety to its employees and some contractors. Deodar’s Emergency Planning Response procedures provide guidance on workplace induction training, new employee starter packs, training for stakeholders, coordination of emergency preparedness drills, and emergency training for all employees. These procedures outline the roles of the Emergency Planning Committee in guiding suitable training on emergency preparedness.

Jazz's HSE training needs are identified through periodic assessments, audits, and sessions. The Jazz HSE training program for direct and contracted workers covers working at heights, fire safety, health and hygiene, first aid CPR, electrical safety, and defensive driving for fleet drivers. Jazz's HSE policies are communicated to employees through onboarding sessions, periodic trainings, internal communication, and visual displays at worksites.

Engro HSE teams provides training to all its subsidiaries’ HSE teams on the group HSE policies, procedure and its sustainability framework.

As part of the ESMS (ESAP #1), Deodar will develop a training plan drawing from Jazz’s and Engro established training system and tailored to Deodar’s specific operations to provide training for employees on: (a) IFC Performance Standards, ensuring that employees understand their roles and responsibilities in meeting these standards; (b) World Bank Group (WBG) General EHS Guidelines (2007) and WBG EHS Guidelines for Telecommunications (2007), ensuring awareness of industry best practices for environmental, health, and safety management; (c) the structure, content, and implementation of Deodar’s ESMS; (d) emergency response procedures, including fire safety, earthquake and flood response, and evacuation protocols; (e) effective stakeholder engagement techniques, communication protocols, and grievance resolution mechanisms, emphasizing cultural sensitivity and respect for community concerns; (f) Gender-Based Violence (GBV), promoting respectful workplace behavior, as well as reporting and addressing GBV incidents.

Monitoring and Review: The construction and maintenance of Deodar’s towers is outsourced to third-party contractors. The Deodar team supervises the construction and maintenance work carried out by sub-contractors, both virtually and by conducting frequent visits. Pakistan Telecommunication Authority (PTA) carries site inspections to ensure radiation levels remain within permissible limits. Deodar will enhance its E&S monitoring and reporting of third-party contracted workers as part of the Company ESMS update (ESAP#1) and Contractor Management Plan (CMP) (See PS2 section).

Jazz develops an annual sustainability report which covers Jazz’s economic, social, and environmental impact in the country. Engro’s annual sustainability report discloses its environment, social and HSE performance. On completion of the TSA, Engro’s sustainability reporting will include Deodar as a subsidiary of Engro.

Supply Chain Risk and Management: Jazz has standard operating procedures in place for the management of suppliers and expects its business partners to uphold similar HSE standards and provide a safe and healthy working environment by agreeing to Jazz’s Business Partner Code of Conduct. This document outlines the values and behaviors expected of third parties, suppliers, and business partners, focusing on anti-corruption, conflict of interest, child and forced labor, as well as health, safety, and environment. The Jazz ESG team has planned to carry out capacity-building workshops for the top 50 suppliers to train them on ESG functions, policies, and procedures. Jazz has introduced a third-party logistics (3PL) clause in the suppliers’ contracts to support the selection of suppliers with a lower carbon footprint in their business operations. Jazz has developed a tool for screening suppliers based on ESG best practices, which will be used in the future induction process to reduce the company’s Scope 3 emissions.

Engro’s supply chain management involves rigorous protocols to ensure compliance and reliability across all vendors, whether managed by the centralized procurement function or trading subsidiary. Vendors are required to undergo stringent Know Your Customer (KYC) procedures. Additionally, they must satisfy a comprehensive vendor onboarding checklist that encompasses key areas such as environmental regulations, social responsibility standards, occupational safety, and process safety requirements. This approach ensures that all suppliers adhere to Engro’s operational and ethical standards.

Deodar will develop a comprehensive framework that integrates relevant elements of the supply chain management systems of both Engro and Jazz, while also adhering to the core supply chain management principles outlined in the IFC PSs. Deodar’s framework will build upon Jazz’s Business Partner Code of Conduct and ESG screening tools and incorporate Engro’s KYC and vendor onboarding procedures. The framework will include: a Supply Chain Management System (ESAP#4) including i) a procurement policy and supplier code of conduct; ii) specific environmental and social provisions related to IFC PS1, PS2, and PS6 into purchase contracts, covering commitment to ethical labor practices, environmental responsibility, biodiversity protection, monitoring and reporting, right to audit; iii) a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the code of conduct; iv) a communication strategy to inform suppliers about the code of conduct; v) a formal process for supplier engagement, remedy or disengagement in case non-compliances are not addressed; and vi) supplier training and capacity building.

PS 2 – Labor and Working Conditions
Human Resources (HR) policies and procedures: Jazz’s HR policy meet Pakistan Labor Policy which covers universal/voluntary health coverage, issuance of national identity cards, minimum wages, women empowerment and gender equality to reduce gender inequality, rights of contractual employee, child labor, health and safety, social security and Employees’ Old-Age Benefits Scheme (EOBI), decent work, skill development and employment, and persons with disabilities. Jazz Code of Conduct outlines expectations for ethical behavior, transparency, and respect in both internal and external engagement with third parties.

Engro’s Human Resources (HR) policies and procedures are comprehensive and structured to support subsidiary businesses and meet national laws and regulations. These include the code of conduct, managed by the Engro’s ethics department, which applies to employees, contractors, and suppliers, addressing ethics, employee behavior, workplace standards, governance, and disciplinary measures.

Deodar's labor management practices are guided by Pakistan labor law and regulations that apply across all provinces. During the TSA, Deodar is aligning its HR practices with Jazz's and Engro HR policies and procedures. However, Deodar retains its own payroll and benefits administration.

Working relations, working conditions and terms of employment: Deodar currently employs 180 workers, comprising 173 males and 7 females, with plans to hire an additional 272 individuals by the end of the year. The company establishes its employment terms and conditions in accordance with Pakistan's labor laws, ensuring fair treatment, safe working environments, and equitable pay. Standard working hours are set at eight per day and forty per week. Workers are entitled to various types of leave, including annual, sick, maternity (12 weeks), and family leave. Transport vans are provided for employees who commute to work. The company's hiring requirement of a National Identity Card ensures that no individual under 18 years old is employed. Deodar pays above minimum wages, issues contracts, and provides leave in compliance with regulatory requirements. Health insurance is also provided to direct workers. There is no retrenchment envisaged for Deodar workers as a result of this project.

Workers organization: The HR policies and procedures of Jazz do not explicitly provide for this right. Deodar does not have any employee who is a member of any trade union. The right for workers to associate and join trade unions is protected by the Pakistan constitution and the Industrial Relations Act (2012).

Non-discrimination and Equal Opportunity: Jazz has a Non-Discrimination Policy, and a Diversity, Equity & Inclusion (DEI) policy which includes a gender program which include women leadership development programs, targeted hiring of women in technical and management roles, partnership with universities and technical institutes to create women focused recruitment pipelines and establishment of mentorship programs. The DEI policy prohibits discrimination based on various legally protected characteristics, including age, race, gender, sexual orientation, and more, in hiring and employment practices. Engro has a diversity inclusion policy, and a gender program aimed at hiring, retaining, and promoting women to management positions, while also addressing other forms of diversity. Engro’s code of conduct emphasizes equal opportunity, fair competition, and nondiscrimination for all employees, regardless of religion, caste, or gender.

Protecting the workforce: Jazz enforces a zero-tolerance policy against workplace harassment, supported by a Standard Operating Procedure (SOP) that complies with local regulations. This includes the establishment of a harassment inquiry committee and a harassment disciplinary committee to handle complaints and enforce disciplinary actions.

Engro aims for a harassment-free workplace through an anti-harassment policy endorsed by senior management, which adheres to the Protection Against Harassment of Women at Workplace Act, 2010. This policy clearly defines harassment, including sexual harassment, outlines responsibilities, establishes complaint procedures, and ensures protection against retaliation and confidentiality. Both companies demonstrate a proactive stance in creating a safe workplace by establishing clear policies, procedures, and committees to address and prevent harassment.

As per ESAP #5a, Deodar will develop a human resources management framework that integrates relevant elements from the HR management systems of both Engro and Jazz, while also adhering to the requirements of IFC PS 2. including those related to non-discrimination, anti-sexual harassment and gender-based violence, prohibition of child and forced labor, and collective bargaining. The company will engage dedicated local HR resources to support the implementation of these HR policies, and all project workers will receive related relevant regular training

Workers Grievance Mechanism: Jazz’s grievance mechanism called ‘Speak Up’ is available to all employees. The system receives all grievances and employees’ concerns, including those related to gender-based violence.

Engro has a grievance mechanism also called 'Speak Up', aligned with national labor laws and publicized across the organization. It offers multiple channels for reporting grievances, managed by a worker's grievance committee which includes both male and female worker representatives, and representatives from the HR team. This mechanism also offers grievance escalation options for workers to the ethics team. As per ESAP#5b, Deodar will build upon the existing grievance mechanism of Jazz and Engro to develop its own worker grievance mechanism that is accessible, transparent, and responsive, with guaranteed anonymity and protection against retaliation, and will include specific channels for reporting and addressing gender-based violence incidents. The grievance mechanism will be made accessible to direct workers and indirect workers.

Workers Engaged by Third Parties: Jazz has established procurement procedures that require all contractors to undergo a rigorous selection process, including mandatory compliance with HSE clauses. These clauses cover safe work practices, use of PPE, and incident reporting. Jazz has also developed a Business Partner Code of Conduct, which sets the minimum standards and requirements that must be followed by business partners with respect to local laws, regulations, rules, policies, and procedures. Jazz HSE trained technology teams conduct random spot checks to monitor contractor compliance to the company’s EHS requirements.

Engro’s engagement with third-party workers occurs at the procurement level, with purchase orders structured around legal standards. Contractors are responsible for adhering to terms, including payment of workers’ wages and benefits in full compliance with Pakistan’s labor laws and regulations.

Deodar engages a total of 156 contractors employing workers involved in Deodar's operations, including construction and maintenance of tower sites, transport services, security arrangements, waste disposal, and other activities. Deodar does not carry out audits on the labor practices of its contractors and sub-contractors. As per ESAP #6, Deodar will conduct a third-party labor audit of its primary direct contractors that provide regular services to Deodar in each region to assess compliance with local labor regulations as well as identify gaps with IFC PS2. In addition, as per ESAP #7, Deodar will develop and implement a Contractor Management Plan (CMP) aligned with IFC PSs. The CMP will consider current and future operations drawing on both Jazz contractor selection process, HSE clauses, and Business Partner Code of Conduct, as well as Engro’s focus on legal compliance in its purchase order structure. The CMP will stipulate the requirement and frequency of third-party labor audits of its contractors in each region, to assess compliance with local labor regulations (contract, minimum wage, overtime, leave, etc.), as well as identify gaps with IFC PS2. The CMP will follow the guidance provided in IFC’s ‘Good Practice Note - Managing Contractors’ E&S Performance’ and will include a procedure to include legally binding obligations in the contractor (and subcontractor) contracts to ensure compliance with the requirements of all relevant management plans contained within the ESMS, as well as national and IFC PS requirements. The CMP will establish clear SOPs for contractor workers, including labor practices, OHS, working conditions, and provide for regular monitoring and enforcement. Deodar will conduct regular internal audits to monitor the E&S performance of contracted workers.

Occupational Health and Safety: Jazz’s HSE policy outlines the company’s commitment to preventing accidents at the workplace and providing its employees with a healthy and safe working environment. Additional measures put in place by Jazz include the availability of drinking water at sites, shaded rest areas and adjusted work schedules during extreme heat, PPEs such as hats and lightweight, breathable vests are provided where necessary. Jazz has maintained incident data for the last three years (2022-2025), there are four fatalities reported and Lost Time Injuries (LTIs) of 91 cases within this period. Guidelines for preventing and managing fires are summarized in the Fire Fighting procedure, while a First Aid procedure summarizes the requirements of providing first aid in case of an accident.

Engro is committed to OHS through its comprehensive Health, Safety and Environment (HSE) Policy, which emphasizes occupational health, industrial hygiene, behavioral safety, and process safety.

Deodar’s accident reporting and investigations procedures, use of personal protective equipment procedures working on towers and at heights procedures, aim to provide safe working conditions, and outline steps to report and investigate work-related incidents and illness. Deodar has developed an Accident Reporting and Investigation Procedure that sets out minimum standards for reporting, recording and investigating accidents, incidents and ill health at work. There is a procedure for working on towers and at heights, to ensure that all regulations, applicable codes of practice and safety measures are adhered to when performing any installation or maintenance on towers. There is also a procedure for use of Personal Protective Equipment (PPE), which includes the identification of PPEs required for each job function, necessary training on its usage, PPE maintenance and safekeeping, and instructions on mandatory use during Deodar operations by all staff, contractors and sub-contractors. A Health and Safety Incident Record sheet is maintained to record accidents, incidents and near-misses. The Deodar team manages and monitors the HSE performance of contractors during construction and maintenance work. Ten (10) hazards specific HSE procedures have also been established for Deodar, including those for working at heights and towers. The OHS statistics reported cover direct employees only and do not include contractor performance data. This gap highlights the need for OHS monitoring across all workers engaged in Deordar’s operations.

As part of its company ESMP (ESAP 1b), Deodar will prepare a detailed Occupational Health and Safety Plan tailored to the risks of its operations. Deodar will record and report all OHS statistics including both employees and contractors. It will include necessary OHS management measures, monitoring and reporting of comprehensive safety statistics, OHS training and competence requirements, OHS inspection and auditing in line with the requirements of IFC PS2. The Contractor Management Plan (ESAP#7) will include requirements for contractors to report all incidents accidents and safety performance to Deodar, ensuring visibility and accountability across all operational activities.

PS 3 – Resources Efficiency and Pollution Prevention
Raw Material and Resource Efficiency: Deodar utilizes national grid electricity and UPS batteries as the main energy source for most of their infrastructure, including towers, main office, call centers, data centers, etc. Additionally, to limit power interruptions, and where grid electricity is not available or reliable, diesel generators are used as back-ups. The power consumption is 4.6kWh on average per site. Approximately 250 Deodar towers, which do not have a reliable source of electricity, run on diesel generators. The Company is also implementing solar power where feasible. Out of 10,617 towers, 183 are solarized, with a kilowatt capacity ranging from 3kW-25.92kW, the average capacity of the solar systems is approximately 12.5kW, with a total installed capacity of approximately 2,3 MW. There are plans to increase the number of solarized towers to 1,169 by end of 2025. As part of its company ESMS (ESAP#1), Deodar will develop a Resource Efficiency Plan to manage and minimize the use of electricity both from grid and off-grid sources.

GHG Emissions: The average absolute Scope 1 and 2 GHG emissions associated with the project during the IFC investment period are estimated to be 382,962 tCO2e per year. This represents a reduction of 5,072 tCO2e per year compared to the baseline emissions for the same period.

Vulnerability to climate change: Pakistan faces significant vulnerability to climate change, with anticipated environmental and social impacts including an increased likelihood of extreme precipitation leading to riverine, flash, and coastal flooding. Additionally, higher temperatures and heat waves are expected, which could compromise worker safety through increased accidents, heat-related illnesses, lightning strikes, and potential loss of communication. Climate-related events may also damage company infrastructure, such as cell towers and network facilities, resulting in service disruptions. Jazz's climate change adaptation strategy is guided by the Pakistan Climate Change Act of 2017, focusing on infrastructure resilience to maintain network quality, resilience, and expansion. Jazz climate emergency response plan ensures uninterrupted services. As per ESAP#8, Deodar will put in place the following climate adaptation measures: a) update Emergency Response Plan to include extreme weather events; b) update Worker´s Health and Safety Policy to include risks associated to climate change/extreme weather events; and c) train relevant staff in disaster recovery procedures.

Noise: The generators at Deodar’s telecommunication towers are enclosed within noise-proof canopies, and the HSE team monitors noise levels regularly during health and safety audits.

Hazardous and nonhazardous waste management: Deodar, as part of its environmental management strategy aligned with Jazz’s broader ESG initiatives, manages hazardous and non-hazardous waste streams in compliance with the Factories Act (1934), National Environmental Quality Standards (NEQs), and ESMS ISO 14001 guidelines. Its waste management procedure governs the identification, handling, sorting, reduction, disposal, reuse, and recycling of waste. Non-hazardous waste from offices and cafeterias is managed by a third-party vendor, who segregates organic waste for composting into green manure and recycles materials like paper, plastic, cardboard, and glass, with non-recyclable waste sent to permitted landfills. Hazardous waste, including network equipment, lead-acid batteries, and used lubricants/oil filters, is stored on-site for up to 90 days before disposal at permitted landfills by EPA-approved third-party contractors. Network equipment is crushed before the contracting process of the third-party contractors, and batteries are stored until sufficient quantities allow for reuse or recycling. Detailed records, including waste type, volume, disposal date, and contractor details, are maintained.

As outlined earlier, the company will prepare E&S Management Plans (ESMPs) (ESAP #1b) as part of its ESMS, to minimize pollution and enhance resource efficiency and address impacts from operations including waste, atmospheric emissions, noise, dust, GHG emissions.

PS 4 – Community Health, Safety, and Security

Community Health and Safety: Deodar has developed a procedure on Assessment & Management of Health & Safety Risks, which includes those affected by its work activities beyond its employees. Deodar's procedure for Environmental Assessment of new sites considers impacts to local communities. All towers are located at a minimum distance from communities to minimize human exposure to Electromagnetic Frequency (EMF). Deodar has an accident reporting and investigation procedure for its operations and contractors, covering accidents resulting in illness or injury to employees, contractors, or third parties. The total number of incidents reported between 2022-2025 is five (5).

Jazz adheres to international guidelines on EMF exposure, including those set by the International Commission on Non-Ionizing Radiation Protection (ICNIRP) and local regulatory requirements established by PTA. PTA carries out site inspections to ensure radiation levels remain within permissible limits. As part of its company ESMS (ESAP #1), Deodar will develop an Emergency Preparedness and Response Plan (EPRP) as well as a Community Health and Safety Plan aligned with national requirements, IFC PSs, and WBG EHS Guidelines to address risks to communities and members of the public.

To better address community impacts, Deodar will update its risk assessment procedures (ESAP#2) to include evaluation of risks and impacts to the health and safety of affected communities during the project lifecycle and establish preventive and control measures, which include EMF exposure controls, managing construction related issues such as community exposure to construction vehicles and transport, exposure to dust, noise and vibrations during construction works, and operational phase hazards for local communities, which may include tower failures and collapse, unauthorized site access, and road safety.

Road Traffic Safety: Deodar outsources the provision of a fleet of 150 vehicles for staff transportation, for moving office equipment and supplies. Transport for construction and maintenance of towers is also outsourced to third-party contractors. These transport activities occur both within and between cities across the country. Deodar will develop a Transport and Traffic Management Plan (as part of its company ESMS, ESAP #1). This plan will be aligned with national requirements and IFC PS4 and will apply to all Deodar operations, whether managed directly by employees or by contractors.

Security Personnel: Jazz maintains a procedure for Executive Protection and Security Duties, as a commitment to employee security at office premises and other locations. Security services are provided by third-party contractors, including armed security personnel at sensitive installations. To ensure responsible security practices, Deodar will develop a Security Management Plan (ESAP#1) in line with IFC PS 4 and the Voluntary Principles on Security and Human Rights. This plan will incorporate risk-based and human rights due diligence, use-of-force procedures, a grievance mechanism, community engagement strategies, and gender-sensitive human rights training.

PS 6- Biodiversity Conservation and Sustainable Management of Living Natural Resources

The portfolio of towers under the Transaction includes over 10,000 ground-based towers across Pakistan, where the main biome is semi-desert and xeric shrublands, including ecoregions of Registan-North Pakistan sandy desert, South Iran Nubo-Sindian desert, Baluchistan xeric woodlands, Aravalli west thorn scrub forests, Indus Valley desert, and Thar desert. There are also Himalayan subtropical pine forests, Western Himalayan subalpine conifer forests, and Western Himalayan broadleaf forests ecoregions within the tropical and subtropical coniferous forests biome, and Karakoram-West Tibetan Plateau alpine steppe ecoregion in the montane grasslands and shrublands biome to the north of the country. 238 towers are located in Legally Protected Areas (LPAs) and 53 towers are in Internationally Recognized Areas (IRAs), of which 34 are located in both where LPA and KBA boundaries are overlapping.

The company will develop and implement a Biodiversity Policy and Biodiversity Management Procedure as part of its updated corporate ESMS applicable to both existing and new assets (ESAP#1). For the existing assets, the Procedure will include measures to manage impacts on biodiversity, specifically on LPAs, IRAs and associated priority biodiversity values, during the operations, maintenance and update of towers. For the new towers, the Procedure will identify key risks and impacts, and define mitigation measures commensurate with these to inform biodiversity surveys and assessments leading to development and implementation of site-specific Biodiversity Management Plans (BMPs).

The company will also develop and implement an Environmental and Social Assessment and Management Procedure (ESAMP), which will incorporate a Biodiversity Screening Procedure for future asset locations (ESAP#2). The Screening Procedure will be implemented to identify and map any overlap of project activities with high-risk areas for biodiversity, including LPAs, IRAs, or areas which qualify as Critical Habitat, Natural Habitat and other priority biodiversity values per PS6. In line with IFC PS mitigation hierarchy, the company will assess the feasibility of avoiding construction of ground-based 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 and mitigate any impacts in consultation with relevant stakeholders, including the micro-siting of ground-based towers in a manner to avoid impacts on the biodiversity values associated with these areas. The site-specific BMPs will include all avoidance and minimization measures, implementation of which will be documented by the company.

Jazz provides various channels for addressing operational complaints, including a helpline, customer care centers, and complaint portals on the company website. To enhance stakeholder engagement and address potential concerns related to its operations, Deodar will develop and implement a Stakeholder Engagement Plan (SEP) and grievance mechanism (ESAP #9) in alignment with IFC PS1. This will include: (a) ensuring the grievance mechanism includes specific channels, referral pathways for reporting, and addressing Gender-Based Violence (GBV) related complaints; (b) conducting consultations with local communities and regulatory agencies to communicate Deodar's commitment to managing negative environmental and social impacts; and (c) undertaking periodic audits to assess the effectiveness of the SEP and grievance mechanism and identify areas for improvement. The SEP will be a dynamic document, regularly updated to reflect evolving stakeholder needs and project circumstances.

Broad Community Support is not applicable for this project.

S.no	Description	Anticipated Completion Date
1	Enhance Deodar’s E&S organizational capacity and:a) provide training in IFC PS requirements to the newly hired E&S Manager, enabling them to effectively supervise the development, implementation, and monitoring of the Company's ESMS and oversee the implementation of the ESAP items; b) hire dedicated Occupational Health and Safety (OHS) Officers for each region (North, Central, South, West and East) to manage and monitor health and safety risks during tower construction and maintenance activities; and c) hire a social and labor specialist to enhance oversight and monitoring of stakeholder engagement, community grievances, and labor and working conditions of third-party contracted workers.	10/31/2026
2	Deodar will:a) Develop a Supply Chain Management System including i) a procurement policy and Supplier Code of Conduct; ii) inclusion of specific environmental and social provisions related to IFC PS1, PS2, and PS6 into purchase contracts and the code of conduct for suppliers, covering commitment to ethical labor practices, environmental responsibility, biodiversity protection, monitoring and reporting, right to audit; iii) a verification process to ensure new suppliers have the policies and procedures in place to meet requirements of the code of conduct; iv) a communication strategy to inform suppliers about the code of conduct; and v) a formal process for supplier engagement, remedy or disengagement in case non-compliances that are not addressed; vi) supplier training and capacity building.	04/30/2026
3	Deodar will:a) Develop a human resources management framework that integrates relevant elements from the HR management systems of both Engro and Jazz, while also adhering to the requirements of IFC PS 2, including those related to non-discrimination, anti-sexual harassment and gender-based violence, prohibition of child and forced labor, and collective bargaining.b) Develop a worker grievance mechanism that is accessible, transparent, and responsive, with guaranteed anonymity and protection against retaliation, and includes specific channels for reporting and addressing gender-based violence incidents. The grievance mechanism will be made accessible to not just workers, but also third-party and contracted workers	01/15/2027
4	A. Deodar will conduct a third-party labor audit of its direct contractors (those contractors that provide regular services to Deodar e.g., construction and maintenance, security) in each region to assess compliance with local labor regulations as well as identify gaps with regard to IFC PS2.Phase 1 – Initial Assessment and desk review/studyObjectives of phase 1:• Establish a baseline for total direct contractors, capacity, and current compliance status.• Set minimum legal safeguards for contractor management.• Prepare Terms of Reference for the full audit.	02/28/2027
5	Deodar will conduct a third-party labor audit of its direct contractors (those contractors that provide regular services to Deodar e.g., construction and maintenance, security) in each region to assess compliance with local labor regulations as well as identify gaps with regard to IFC PS2. Phase 2 – Full audit & Corrective Action PlanContractor Management Plan (CMP) as an ESAP item and integrate Phase 1 and Phase 2 findings. Include a clause obligating the client to implement audit findings (CAP) in a phased manner agreed mutually with IFC, providing a binding enforcement mechanism through the loan agreement.	06/30/2027
6	Develop and implement a Contractor Management Plan aligned with IFC PSs considering current and future operations. The Contractor Management Plan will follow the guidance provided in IFC’s ‘Good Practice Note - Managing Contractors’ E&S Performance’ and will include a procedure to include legally binding obligations in the contractor (and subcontractor) contracts to ensure compliance with the requirements of all relevant management plans contained within the ESMS, as well as national and IFC PS requirements.	01/15/2027
7	Engro Deodar will put in place the following climate adaptation measures a) updated Emergency Response Plan to include extreme weather events; b) update Worker´s HSE Policy to include risks associated to climate change/extreme weather events; and c) train relevant staff in disaster recovery procedures.	11/30/2026
8	Develop and implement a Stakeholder Engagement Plan (SEP) and community grievance mechanism (GM) to align with IFC PS1. This will include: (a) ensuring that the grievance mechanism includes specific channels for reporting and addressing Gender-Based Violence (GBV) related complaints, with appropriate referral pathways; (b) ensuring consultations with local communities and regulatory agencies communicating the Deodar’s commitment to managing negative environmental and social impacts (c) undertaking periodic audits to assess its effectiveness and identify areas for improvement.	01/15/2027
9	Deodar will:a) Align its Environmental and Social Management System (ESMS), with IFC Performance Standards (PS) 1–4 and 6 and World Bank Group Environmental, Health, and Safety (WBG EHS) Guidelines General and Telecommunications). b) Develop an ESMS Manual, with monitoring and reporting indicators and responsibilities, an updated accident reporting and investigation procedures, a land leasing policy and procedure, a biodiversity policy, a Greenhouse Gas (GHG) Monitoring and Reporting System, and EHSS training plan for staff and contractors to address topics such as contractor management and stakeholders’ engagement including affected communities. c) Develop and implement E&S Management Plans (ESMPs) as part of its ESMS to manage E&S risks associated with its operations. These plans will include, but not be limited to: • Resource Efficiency Plan; • Atmospheric Emissions and GHGs Plan; • Hazardous Materials Management Plan; • Waste and Hazardous Waste Management Plan; • Noise Management Plan; • Dust Management Plan; • Occupational Health and Safety Management Plan; • Electric and Magnetic Fields (EMF) Management Plan; • Biodiversity Management Procedure;• Emergency Preparedness and Response Plan (EPRP); • Transport and Traffic Management Plan; • Security Management Plan; • Community Health and Safety Plan; • Stakeholder Engagement Plan (SEP); • Community Grievance Redress Mechanism (GRM)• Contractor Management Plan (CMP)	02/28/2027
10	Develop and implement an E&S Assessment and Management Procedure (ESAMP) aligned with IFC PS. The ESAMP will cover aspects including: a) E&S screening of future asset locations, incorporating a Biodiversity Screening Procedure, b) geospatial analysis to map sensitive E&S receptors within proximity of potential sites, including but not limited to high-risk areas for biodiversity and cultural heritage sites; c) land leasing procedure; d) assessment and mitigation procedure for noise, waste management, hazardous material and waste management, electric and magnetic fields (EMF); and e) stakeholder engagement guidance.	01/15/2027