IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
Environmental and Social Management System and Policies. WIOCC has developed Group level E&S and OHS policies for its operations. These policies include commitments to build and operate its assets in a manner that protects the environment, prevents pollution and promotes continuous improvement. They also emphasize the provision of necessary resources, the establishment of clear objectives, and fostering a positive safety culture and behaviour within the organization.
In addition, WIOCC Group has developed and is implementing an ESMS aligned with IFC PS1. The ESMS details WIOCC Group’s entire approach to managing E&S risks and impacts within its operations and is outlined in a Manual updated in May 2025. This ESMS Manual includes the Group’s ESG Roadmap and governance structure and clearly spells out roles, responsibilities, and procedures for managing E&S risks across the organization. As part of this IFC investment, WIOCC Group will update its ESMS to include (i) implementation arrangements like training, document control process, coordination meetings, process for extending the ESMS to all new businesses; (ii) EPRP related permitting update and drills; (iii) Cultural Heritage Management Procedure; and (iv) E&S audits and extension of monitoring requirements (ESAP #1).
Identification of E&S risks and impacts: WIOCC Group has developed an E&S screening tool that elaborates its approach to project screening, scoping and categorization. In addition, WIOCC Group conducts comprehensive E&S impact assessments (ESIAs) for all new operations in accordance with local regulatory requirements using the services of international and / or local environmental consultants. Furthermore, WIOCC Group conducts a project specific market assessment as well as E&S Risk Assessment including details on associated actual and potential project biophysical and socioeconomic risks and impacts before entering each new market. Finally, WIOCC has a Group-wide Land Acquisition and Resettlement Policy aligned with IFC PS5 and primarily operates through leased facilities, avoiding physical or economic displacement, prioritizing pre-zoned industrial areas, during site selection. As part of the IFC investment, WIOCC Group will (i) enhance its E&S screening process by incorporating IFC PS 6 requirements and the Agence Francaise de Developpement (AFD) Group Exclusion List when selecting new development sites, and (ii) perform E&S risk and impact assessments in alignment with applicable regulatory requirements, WIOCC Group’s ESMS, and IFC PSs, including conducting a Strategic E&S Assessment (SESA) for its FTTx business (ESAP #2).
Following the E&S assessment of its new businesses, WIOCC Group will update the Climate Risk and Vulnerability Assessment and based on the recommendations of the baseline study to include; (i) climate modelling (including scenario analysis) for future risk projections; (ii) develop a climate resilience roadmap with phased implementation; (iii) risk assessments in line with climate data trends; and (iv) where applicable, demonstrate how climate risk assessment has influenced design (ESAP #3).
WIOCC will use partner infrastructure for FTTx in markets where it lacks its own. Before using third-party networks, WIOCC will perform an ESDD to assess E&S risks related to the owner, location, and operations. This review will be proportionate to risk level, follow IFC PSs, and outline actions to ensure compliance with IFC PSs (ESAP#4).
E&S Management Programs. WIOCC Group has developed and is implementing the following plans and procedures in line with its ESMS; (i) Contractor HSE Specifications; (ii) Water Resources Management Plan; (iii) Group Waste, Wastewater, and Hazardous Materials Management Guidelines; (iv) Group EMS Water Strategy (v) Climate Risk Management Plan; (vi) Emergency Preparedness and Response Plan (EPRP); (vii) Stakeholder Engagement Plan (SEP); (viii) Health and Safety (H&S) Plan; (ix) Group Corporate Security Management Protocol (SMP); (x) Transportation Management Plan (TMP); (xi) Grievance Mechanism; (xii) Chance Finds Procedure (CFP); (xiii) Gender Risk Management Plan; (xiv) Supply Chain Management Procedure (xv) Group Biodiversity Guidelines.
Going forward, WIOCC Group will prepare a project-specific ESMP for each country to address construction and operational risks and impacts, referencing the framework ESMPs provided in the ESIAs or the risk register from SESA (ESAP #5). In addition, WIOCC will require that all Contractors engaged in constructing data centers and connectivity-related works develop a Construction E&S Management Plan (CESMP) to address the relevant E&S risks and impacts within their respective scopes of work (ESAP #6).
Organizational Capacity/Competency. WIOCC Group has an ESG head responsible for sustainability strategy, policy, ESG risk management, and driving implementation of systems and processes for the management and mitigation of E&S risks as contemplated in the IFC PS. Operationally, the current organogram has the ESG Director and HSE Manager having separate functional reporting and the different operating countries are supported by HSE officers who report to the HSE Manager. WIOCC Group will strengthen its organization by appointing a Senior E&S Specialist at Corporate level and upskilling dedicated HSE resources to handle social issues for each operating country or asset. Also, WIOCC Group will mandate construction contractors to deploy an organization comprised of at least one dedicated E&S and human resource professional. Finally, WIOCC Group will provide training on ESMS implementation and standard operating procedures (SOPs) as well as on safe systems of work procedures (ESAP #7).
Emergency Preparedness and Response. The Company has an Emergency Preparedness and Response Plan in place that addresses fires, and other emergency situations. The plan clearly defines roles and responsibilities and detailed procedures to deal with emergencies including detailed drawings showing evacuation plans, a communication chart and contact details for members of the emergency response team. The latest revision was carried out in May 2025 to include posting of site-specific Emergency Response Plans (ERP). As part of the ESMS implementation (ref. ESAP #1) WIOCC Group will conduct drills regularly across its assets, renew expired certifications and ensure emergency systems are periodically tested.
Monitoring and Reporting. Environmental monitoring activities are mostly focused on air emissions and carried out by a third-party consultant for quarterly E&S compliance monitoring requirement. OHS monitoring is carried out by the HSE officers following a monitoring program which includes procedures for carrying out safety observations, identifying and reporting non-conformances to the HSE manager. As part of the ESMS implementation (ref. ESAP #1) WIOCC will strengthen its E&S monitoring and reporting capabilities by stipulating the scope, roles, responsibilities, frequency and methods of monitoring activities in a clearer reporting procedure. The scope of the monitoring procedure shall include greenhouse gas (GHG) emissions, water consumption, waste generation, ambient air quality and noise within and outside its assets, and occupational safety issues including leading and lagging KPIs.
Performance Standard 2: Labor and Working Conditions
WIOCC Group currently has a total workforce of 337 of which 75 were recruited in the last one year. The workforce is comprised of 70 % male and 30 % female. The Group rely on Contractors for the implementation of new projects.
Human Resources Policies and Procedures, Working Conditions, and Terms of Employment. WIOCC has developed and is implementing an HR procedure designed to enable effective workforce management, ensure compliance with regulations, and foster an inclusive and balanced work environment with employment contracts, benefits, and grievance channels established per IFC PS2 requirements. The core tenets of WIOCC's HR procedure focus on non-discrimination based on gender, religion, and political affiliation, a transparent policy system to prevent harassment and bullying, and the encouragement of employees to speak up. The HR process complies with local regulations on pensions, benefits, insurance, and other employee-related aspects. WIOCC’s Legal and HR teams work closely to verify and enforce compliance with country-specific regulations and identifies best practices across the different jurisdictions and incorporate them into corporate policies for implementation across the Group. As part of the ESMS implementation (ref. ESAP#1) WIOCC Group will identify and add resources to its HR department to implement or drive a respectful workplace culture initiative harmoniously across its different operating assets.
Workers’ Organization. The Company is currently not a party to a collective bargaining agreement, as there are no workers’ organizations at the asset level. However, WIOCC Group’s HR procedures have commitment to freedom of association and collective bargaining.
Grievance Mechanism. WIOCC Group has an established Employee Grievance Procedure generally aligned with IFC PS2 requirements. The procedure mentions non-retaliation and confidentiality and describes a separate grievance channel specific to sexual harassment-related grievances. Employees are made aware of the grievance mechanism during induction training. There are currently no ongoing litigations and no major grievances submitted by the employees. As part of this IFC investment, WIOCC Group will (i) improve its Grievance Procedure to allow anonymous submissions from third parties; (ii) record such grievances, including verbal grievances, through a grievance log (iii) ensure all service providers working at its facilities have well-established grievance mechanisms for their employees; and (v) extend its worker grievance mechanism to third-party workers (ESAP #8).
Occupational Health and Safety. WIOCC Group has established an OHS Management System and has assigned health and safety experts. The Company conducts job hazard analysis and implements preventive and mitigation measures accordingly. Adequate personal protective equipment, onboarding and on-the-job training are provided to all employees and contractors, commensurate with the job risk and environmental conditions. Workforce First Aid training is being conducted by the relevant departments in cooperation with local authorities.
WIOCC Group did not record any fatality in the last three years while near-miss and incidents are not reported centrally. As part of the ESMS upgrade (ref. ESAP #1) the Company will institutionalize regular OHS audits for continuous improvement and will ensure that OHS leading and lagging KPIs, including injury rates among contractor workers, being monitored are used to share lessons learned and improve safety performance across the Group.
Workers Engaged by Third Parties. WIOCC Group relies on a network of active subcontractors and service providers to complete operation and maintenance activities. The procurement department list over 1000 cumulative service providers though the active number is much smaller. Key service providers include cables and electrical maintenance partners, data center installation partners and equipment sourcing partners. Given this strong reliance on third party workers including those assigned through employment agencies, service providers and service contracts, WIOCC is required by its contractor management procedures and HR process to conducts checks to ensure that the Group’s EHS, labour, OHS standards and GBVSH requirements are followed in same manner as direct employees. As part of this IFC investment WIOCC Group will i) improve its Vendor Selection Procedure by including a policy statement on labour rights and working conditions criteria; particularly pay above minimum wage, overtime management, grievance mechanism, and gender-based violence and harassment; and ii) establish and implement a comprehensive labour audit process that includes detailed documentary reviews, live testing of HR systems to ensure the third-party employees work in line with WIOCC Group’s relevant policies, national labour law and IFC PS2 requirements (ESAP #9).
PS3: Resource Efficiency and Pollution Prevention
Energy efficiency and GHG emissions. WIOCC Group strives to minimize its environmental footprint through energy-efficient technologies, waste reduction strategies, and water conservation efforts at its facilities. The data centres are connected to grid electricity but have advanced power backup diesel generators system with auto-failover, ensuring operating with a Tier 3 and Tier 4 Uptime Institute redundancy standards. In 2024 WIOOC Group used 1,079,661 litres of diesel and 1,644,249 kwh of grid electricity. The Company has made some efforts to reduce its carbon footprint by introducing solar in its energy mix including 0.3MW solar PV cells installation at its Durban, Kinshasa and Lagos data centres. As part of this IFC investment, WIOCC Group will complete a GHG emissions inventory for the project using internationally recognized methods, including estimation of Scope 1 and Scope 2 emissions (ref ESAP #1) for construction and will systematically report its total GHG emissions annually during operations.
Water supply. Process water is used by the data centres for cooling, and the water is recirculated. External firefighting efforts are supported by reservoirs with pre-treated water connected to booster pumps. WIOCC Group has established a Water Use and Resource Management Guideline that underscores its commitment to responsible water usage, risk mitigation, and minimizing the impact on local water supplies. The guideline encompasses sustainable sourcing practices, systematic consumption monitoring, and conservation initiatives within WIOCC facilities. Going forward, WIOCC will track and report its water use as a KPI (ref. ESAP #1) in accordance with its environmental and social monitoring and reporting obligations.
Wastewater. The company does not generate processed wastewater. Non-contact cooling water is recirculated. Sewage from offices, canteen and hygienic facilities is discharged to septic tanks and or directly to the municipal sewer system.
Air Emissions. The Company’s air emissions are a result of vehicle and generator exhausts and dust generation because of raw materials (e.g., cement, sand aggregates) handling during construction, and vehicular movements on unpaved roads. It is expected that the emission limits are significantly lower than the levels published in the WBG EHS General Guidelines for Construction and Decommissioning. As per ESAP #6, WIOCC Group will ensure that the contractor CESMP has measures to prevent dust emission during transport of gravel and sand, including covering of load and speed reduction across communities.
Hazardous materials management. The Company uses negligible quantities of chemicals but for paints used during finishing of some of the spaces within the data centres per the tenant’s requirement. Material Safety Data Sheets are kept in the storage room where chemical products are stored. As observed at the data centres in Kinshasa and Lagos, diesel for operation of backup generators is stored in double walled tanks within secondary containments drained to adequately dimensioned oil water separators. All tanks containing hydrocarbon are subject to an inspection by the external E&S consultant in charge of quarterly regulatory audits. The Company has a SOP covering Chemical Handling and Spills. The procedure covers both packaged and bulk chemicals, including fuels, and addresses transportation, storage and handling. Spill response measures are also addressed in the procedure.
Hazardous and Non-Hazardous Wastes. WIOCC Group has a waste management plan that includes standard procedure for the collection, segregation and disposal of packaging waste, domestic waste, office and any other waste generated as part of its operations. However, the plan does not address the process of handling E-waste and does not align its management with national Extended Producer Responsibility (EPR) requirements. As part of this IFC investment, WIOCC Group will develop a formal e-waste management procedure aligned with national laws and good international practice (GIIP) and will include disposal logs, vendor checks, and training on e-waste in the ESMS roll-out trainings (ESAP#10).
Stormwater Management: The data centres design incorporates adequate drainage systems and storm water is drained to a sump and emptied in a control manner outside the facilities. The sumps are inspected regularly to ensure no pollutants are included in the storm water. Flood defence and dewatering measures are installed at the Lagos facility located not far from the Atlantic coast.
Performance Standard 4: Community Health and Safety
Life and Fire Safety. WIOCC Group’s infrastructure are in office parks and build-up areas with collocation. Data centres are equipped with fire detection systems, including strategically placed smoke detectors and heat sensors which ensure early identification of potential fire hazards. Also, WIOCC Group uses Bridges 1230 as fire suppressant inside the data centres, particularly notable for its efficiency and minimal environmental impact, having an atmospheric lifespan of five days. Additionally, the data center buildings integrate acoustic roofs and sophisticated ventilation systems further enhancing the safety and comfort of the facility. Finally, each data center has pressurized water hydrants and water reservoirs connected to booster pumps and backup energy systems which guarantees uninterrupted operations even during emergencies. However, the integration of other users of the industrial parks near the data centres in the L&FS arrangement is essential. As part of the ESMS implementation (ref. ESAP #1) WIOCC will extend L&FS awareness to all its neighbours and identify where joint interventions and emergency drills can be performed and resources consolidated.
Road Traffic. Road safety is covered in the Risk Assessment Procedure, but there is no audit record available to examine the Company's and its contractors' road and traffic safety performance. As per ESAP#6, WIOCC Group will ensure that contractors conduct a traffic assessment and include a Traffic Management Procedure as part of the CESMP in line with IFC PS4, and monitor and record its transport operations of equipment, material and workers accordingly ensuring that safe driving practices and defensive driving training is an integral part of the training needs for project drivers.
Security. WIOCC Group’s data centres implement robust security measures including a perimeter fence, CCTV cameras connected to a security control room with an alarm system and unarmed guards that work in two shifts. Also, the command center can reach out to state police in the event of emergencies. In Kinshasa, the facility is located within an Office Park with an external perimeter fence and gate manned by armed security under the responsibility of the Office Park while the data center has its own internal perimeter fence and unarmed security. Security is managed through a set of procedures, including emergency procedures, weapon security, and visitor movement. Security measures and ID card controls are in place. There is an annual training plan for all security personnel, which includes legal and ethical rules and communication protocols. As part of this IFC investment, WIOCC Group will conduct a risk assessment on security practices and train personnel on ethical conduct and the Voluntary Principles on Security and Human Rights (VPSHR) as well as on GBVH (ESAP #11).
