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
As agreed with IFC under the previous transactions, Airtel Africa has developed an ESMS, to address E&S risks associated with its operations in line with the principles of IFC PSs and Good International Industry Practice (GIIP). The ESMS applies to both direct operations (active operations) and those of service providers (TowerCos and fiber optic service providers) or passive operations. The ESMS has been adequately cascaded to the Kenya and Rwanda Opcos.
The ESMS includes a comprehensive set of E&S policies, procedures and tools to ensure compliance with relevant regulations and standards, and to promote continuous improvement. The ESMS is underpinned by the ‘Sustainability Strategy’ released in October 2021, which outlines AA’s commitment under business, people, community, and environment pillars, and a targeted approach to six United Nations Sustainable Development Goals. The strategy is also aligned with the UN Global Compact principles on human rights, labor, environment, and anti-corruption. Under the first project AA #43749’s ESAP, the company developed E&S policies consistent with the objectives of IFC PSs including: (a) an environmental policy; (b) a safety, health, and security policy; (c) a land acquisition, access, and compensation policy; (d) a stakeholder engagement policy; (e) a prevention of sexual harassment policy; (f) a human rights policy; and (g) a modern slavery policy.
Additionally, under project Airtel II ESAP, AA was required to develop an ‘E&S Review Procedure’ focused on the ESMS implementation for each subsidiary, which will be continuously updated as part of the ESMS Review. AA has developed the required procedures in line with IFC’s PSs requirements.
AA’s ESMS includes a risk register that identifies and addresses E&S risks, including health and safety hazards, environmental impacts, and gender-differentiated risks. The identified key E&S risks associated with the new project in Kenya and Rwanda are generally similar to those of the existing projects.
The company works with reputed third-party contractors for tower construction, operation, and maintenance and for fiber network laying, which follow their own E&S standards and procedures broadly aligned with GIIP. For fiber optic cabling, installation is systematically undertaken within existing right of ways and road servitudes and consistent with host-government guidelines and with requisite regulatory approvals. This applies to all subsidiaries and to TowerCos in Kenya and Rwanda.
AA has developed E&S procedures and management controls to support the implementation of its E&S policies. These include (a) a greenfield screening procedure with a focus on biodiversity and social screening that applies to any site acquisition by Airtel Africa and includes developing or acquiring data centers and expanding base transceiver stations (network coverage) at greenfield sites; (b) “client EHS standards” document that applies to Airtel Africa suppliers and contractors including tower companies and maintenance contractors, outlining requirements for high-risk tasks such as electrical work, work at heights, safe driving and vehicle safety, and fire safety, among others; (c) life and fire safety (LFS) and occupational health and safety (OHS) requirements for its own and Airtel Africa operated assets; (d) electromagnetic field assessment and monitoring procedure; and (e) stakeholder engagement policy, stakeholder engagement plan, and community grievance mechanism.
Furthermore, as agreed under Airtel II project, the company has developed a ‘Contractor E&S Management Procedure (CMP)’ consistent with its EHS Standards and IFC PSs and aligned with the principles outlined in the “IFC’s Good Practice Note on Managing Contractors’ E&S Performance”. These new terms will be incorporated into contracts (new and renewals) upon the expiration of the ongoing agreements.
Airtel Africa has assigned E&S roles and responsibilities both at group and subsidiary levels to facilitate ESMS implementation. At the group level, there is an executive committee reporting to the Board of Directors, responsible for setting the sustainability strategy and vision and deploying it across Airtel Africa’s Opcos. The corporate team includes an E&S lead who advises and supports the group and country-level E&S organizations to implement the sustainability commitments and E&S requirements. At the Opco level, the local managing directors are accountable for the effective implementation of the ESMS, while the implementation of specific E&S procedures is allocated to functional directors. The implementation of the Life and Fire Safety (LFS) and Occupational Health and Safety (OHS) requirements at AA's own and operated assets, including in Kenya and Rwanda, is a shared responsibility between facilities managers, EHS managers and the health and safety committees established for each country.
With respect to TowerCos and infrastructure service providers, AA was required to assign E&S organizational responsibilities to improve management and oversight of EHS performance in accordance with its ESMS requirements, and to enhance its E&S framework to strengthen capacities and competency of the OHS committees. The company has developed a new Opco level organizational EHS policy that has been approved by the Sustainability Committee and the E&S manager has taken on additional responsibility for OHS oversight. Refresher training sessions are planned for the Health and Safety Committee on roles and responsibilities, risk assessments, incident investigation and reporting. Per ESAP #1, AA will provide evidence of adequate implementation of the updated policy for its Opcos and contractors, as well as the training of the E&S personnel and OHS committees.
AA has implemented life and fire safety requirements that apply to all its owned and operated assets; these requirements generally align with the WBG EHS Guidelines. Buildings are provided with fire and smoke detectors, fire extinguishers, first aid kits, and fire suppression systems as relevant (e.g., data centers). General emergency awareness training is carried out periodically for the workforce, and specialized fire marshals and first aid trainings are provided to designated employees who are tasked with emergency response. Periodic fire and evacuation drills take place. Airtel Africa Opcos coordinate with local government agencies for regulatory compliance and licenses on LFS requirements such as inspections and drills.
The company has developed a monitoring and review framework to track the implementation and effectiveness of its management programs. Key performance indicators (KPIs) are established to measure progress and identify areas for improvement. Regular internal audits and third-party assessments are conducted to ensure compliance with the ESMS and relevant standards. The company publishes an annual sustainability report consistent with the Global Reporting Initiative (GRI) (see https://airtel.africa/assets/pdf/Sustainability_Report_2024.pdf). As part of the disclosure process, it monitors the implementation of the sustainability strategy, and tracks selected E&S KPIs. AA also performs regular environmental, OHS and security audits that cover operations in all its subsidiaries. In response to previous IFC’s recommendations, AA committed to developing an E&S Review Procedure focused on the ESMS implementation for each subsidiary and to take improvement actions as relevant. Going forward, AA will incorporate additional monitoring and reporting requirements developed for its Opcos, including Rwanda and Kenya, with applicable measurable E&S KPIs and OHS statistics for the workforce and specific type of contractors in line with IFC PS and the ‘WBG EHS Guidelines (General and sectoral for telecommunications)’ (ESAP #2)
PS2: Labor and Working Conditions
Airtel Africa’s workforce in Kenya and Rwanda comprises direct employees (referred to as on-roll employees) and third-party entity employees (referred to as off-roll employees).
Human Resource (HR) is centrally managed by Airtel Africa’s headquarters. Corporate HR policies are cascaded to subsidiaries and customized to comply with respective host nation labor regulations and IFC PS2 requirements. The policies apply to all employees including direct and third-party employees. They cover non-discrimination and equal opportunity; requirements for sexual harassment and harassment-free workplace are addressed in the corporate code of conduct and policies. All direct employees contracts reference these HR policies, and include provisions relating to working conditions, terms of employment, leave, wages, and benefits among others. This information is provided to employees during their induction process.
Both subsidiaries have adopted Airtel Africa’s Human Rights Policy, which encourages freedom of association and labor representation across the workforce. They regularly engage with and cooperate with recognized trade unions at country-level and have no plans to undertake retrenchment in the foreseeable future.
Airtel Africa has implemented a worker grievance mechanism, cascaded at subsidiary level, which includes an anonymous channel to register grievances and is extended to the whole workforce. There is a whistleblower mechanism managed by an independent third party, available and accessible publicly to all stakeholders, to address issues related to the code of conduct, anti-bribery, corruption, tax evasion, conflict of interest, related party related transactions.
The OHS committees at country level are responsible for the implementation of OHS/LFS requirements. As agreed under previous project, Airtel Africa enhanced its OHS/LFS framework with additional training and capacity building initiatives for the committee to support effective and consistent implementation of OHS/LFS requirements across its subsidiaries’ operations.
Airtel Africa is committed to working with suppliers and contractors to manage relevant E&S risks. Suppliers must comply with Airtel Africa’s Code of Conduct, Code of Business Ethics for Partners & Suppliers and Human Rights Policy, which includes provisions on forced labor and child labor and are required to complete an ESG self-certification and declaration process. As agreed under previous project, Airtel Africa is in the final stage of rolling out its ‘Contractor E&S Management Procedure’ based on the overarching “EHS standards”, including labor conditions and OHS with respect to its tower and fiber installations.
PS3: Resource Efficiency and Pollution Prevention
Both subsidiaries rely on electricity sourced from the public grid as the primary power source for offices, network operating centers, and passive infrastructure. Diesel is used as a backup option at locations where the electricity grid is not reliable or available and where no solar system has been installed.
Airtel Africa discloses its consolidated data on annual GHG emissions associated with electricity use and diesel consumption, as well as its optimization commitments, in its annual sustainability report, available at https://airtel.africa/assets/pdf/Sustainability_Report_2024.pdf. Therefore, GHG emissions primarily relate to electricity and fuel consumption. The 2024 sustainability report estimates total scope 1 and scope 2 GHG emissions for the East Africa market at 24,345 tons CO2eq.
In an effort to optimize energy consumption (electricity and fuel) and improve business processes, Airtel Africa has developed a decarbonation strategy with the ambition of achieving Net Zero carbon emissions by 2050. As part of the strategy, Airtel Africa identified the following focus areas: (i) improve energy efficiencies across all operations including operational improvements and modifications (ii) reduce diesel consumption at mobile network sites and investigate the use of low carbon alternative fuels for back-up energy generation (iii) increase the use of renewable energy and (iv) use more environmentally friendly gas-based cooling and fire suppression systems at the data centers to reduce GHG emissions. In collaboration with its TowerCo partner in Kenya, Airtel Africa has prioritized 'Green Sites' which exclusively utilize solar systems equipped with storage batteries or minimal grid power when necessary.
As part of Airtel Africa’s EHS standards, passive infrastructure service providers at each subsidiary are required to adhere to pollution prevention measures with regard to noise, air emissions from generators, waste and hazardous materials management requirements. Measures include mandatory secondary containment, overfill prevention for fuel tanks, and procedures for delivery and spill prevention. Airtel Africa has established waste management protocols to ensure compliance with host-country legal requirements, PS3, and alignment with WBG EHS Guidelines for Telecommunications. E-waste is managed through qualified licensed service providers, who ensure safe recycling and disposal.
PS4: Community Health, Safety and Security
Community health and safety risks primarily relate to (a) road traffic incidents involving the subsidiaries’ staff or their contractors (b) contracted services for network and fiber capacities expansion activities, such as towers contractors or fiber installation contractors; and (c) LFS at subsidiary directly operated stores. Following IFC's recommendations, Airtel Africa enhanced its EHS requirements for both staff and contractors at the subsidiary level, to ensure safe driving and implement LFS controls emergency response measures in alignment with host country regulations and GIIP.
In line with the corporate EMF assessment and monitoring procedure, both subsidiaries are committed to meeting host country radio field/electromagnetic field (RF/EMF) requirements, and those of the International Commission on Non-Ionizing Radiation Protection (ICNIRP). The procedure is consistent with the WBG EHS Guidelines for Telecommunications, which sets out requirements to eliminate potential health and safety hazards associated with EMF from their own network equipment and from sites operated by tower companies. The procedure specifies criteria for equipment approval related to EMF exposure guidelines. It also includes requirements for EMF measurement, auditing, safe working, employee training and training for tower company contractors, among others.
Airtel Africa performs security risk assessments to determine the level of risk in different locations across its markets. The results of these assessments determine the level of security arrangements required to secure equipment and assets. Airtel Africa uses different forms of security arrangements, including employing the services of qualified security services. Where contracted firms are retained to provide security, due diligence is completed to assess the integrity of contracted security firms, and Airtel Africa requires the security firms to comply with the good security practices, Airtel Africa code of conduct, and human rights policies. These measures are adequate to address the risks identified with regard to the management of security forces in both subsidiaries.
