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 Impact
E&S Policies. As required under the previous IFC investment, AT developed a corporate-level ESMS, which includes an overarching Health-Safety Environment & Social (HSES) policy (available online at https://www.axian-telecom.com/cirdowee/2024/06/IMS-POL-AT-101-HSES-Policy-AxianTelecom_ENG.pdf). The policy underpins the group’s E&S strategy designed in accordance with the UN Global Compact principles. It underscores AT’s commitment to achieving sound E&S performance in line with IFC PSs requirements and World Bank Group’s EHS Guidelines, and mandates compliance with applicable host country regulations across all subsidiaries. The policy applies to all AT direct and indirect ‘employees, contractors, suppliers and visitors, and was updated to include AT’s biodiversity-related commitment to avoid construction of new towers in areas that could negatively impact Alliance for Zero Extinction (AZE) sites or World Heritage Sites.
Environmental & Social Management Systems. AT has implemented its ESMS in accordance with its corporate HSES strategy and has continuously improved it as part of IFC’s involvement, to ensure alignment with PSs principles. There is an ‘ESMS Manual’ which specifies the essential ESMS elements required at both corporate and Opco levels, including the HSES policy, roles and responsibilities, HSES risk and impact identification and management framework, emergency preparedness and response, stakeholder engagement and grievance management, and E&S monitoring and reporting. Opcos were required to adhere to the AT’s standards and ensure that all documentation be integrated and updated accordingly. There is a central tracking table to monitor ESMS updates at each subsidiary level. The implementation of the ESMS by the various Opcos has been satisfactory in Madagascar, Comoros, and Togo, but requires further development across all countries of operation.
AT conducted the E&S due diligence (ESDD) of Wananchi corporate’s ESMS as part of the ongoing acquisition and determined that the existing system largely aligns with AT’s requirements and IFC PSs.
E&S Risk Assessment. AT’s E&S risk assessment and management framework is outlined in the ‘HSES Risk Management Procedure’ and the ‘E&S Risk and Impact Evaluation and Audit Procedure’. The procedures set out generic criteria for initial risk screening and an internal process for impact assessment and reporting. As required under the previous agreement, AT also developed the ‘Site Acquisition Procedure’ outlining the key requirements for identifying, screening, and securing land for tower construction activities consistently with IFC PS5 requirements. A group-level Biodiversity Management Procedure was also developed for risk screening of proposed sites in areas of high biodiversity value, which is applied prior to acquisition of existing assets or construction of new sites. The procedures have been adopted by Opcos and are under implementation. The procedures specify that every project, including construction sites, fiber laying, warehouses, offices, and all activities conducted by or on behalf of the company, must be screened and categorized in line with applicable regulatory criteria and international standards, including IFC PSs. The scope of risk review covers all stakeholders, including employees, subcontractors, service providers, and communities.
All qualifying projects, particularly tower erections, are also required to undergo a complete Environmental and Social Impact Assessment (ESIA) in accordance with host country legislation and IFC PSs and to acquire the necessary operating licenses. Assets acquisitions such as the ongoing acquisition of Wananchi Group, are subject to the 'E&S Risk and Impact Evaluation and Audit Procedure'. Terms of Reference for the ESDD have been designed to assess compliance with IFC PSs and the World Bank Group EHS Guidelines (General and for Telecommunications). The ESDD report determined that the project is “Category C-Low E&S risk Project” due to the minimal physical assets footprint. The identified gaps have been integrated into the corrective action register which will be tracked as part of the ‘Subsidiary audit plan’.
Finally, there is a corporate Risk Register, replicated at each Opco level, identifies, assesses, and prioritizes HSES risks based on likelihood and impact. Some of the key risks identified relate to contractor OHS management and road traffic accident, especially with regard to vehicles used by local contractors. These are further explored in the sections below.
Management Programs. Further to the risk management procedures explained above, AT has documented a set of management plans and standard operating procedures that have been cascaded to Opcos and are being implemented progressively. Key plans include the ‘Contractor E&S Management Procedure (CMP)’ designed in line with the IFC PSs framework and aligned with the principles outlined in the “IFC’s Good Practice Note on Managing Contractors’ E&S Performance”. Other core management plans and programs include the site OHS management plan, the ‘Group's Internal Auditing Standard’, the waste management plan, the Community Health and Safety Management Plan, the stakeholder engagement plan, the Heritage Chance Find Procedure, traffic Management Procedure, to name a few. For key contractors that had existing ESMPs at the time of appointment, supplementary E&S management measures have been defined based on E&S gap analysis and are being embedded progressively into contracts (new and renewals) upon the expiration of ongoing agreements.
Organizational Capacity and Competency. The Group Head of HSES reporting to the Chief Risk and Compliance Officer oversees the implementation of the ESMS and is supported by the corporate E&S Coordinators, HSES compliance Officer, the OHS Manager, the OHS Coordinator and the Biodiversity Manager. Together they ensure integration of E&S requirements across the organization and adherence thereof by subsidiaries and contractors. In response to previous IFC’s recommendations, subsidiaries also reinforced E&S capacities by recruiting additional competent resources as necessary. For instance, the Togo Opco nominated a new experienced E&S Manager with one OHS supervisor, one E&S Coordinator and one community liaison officer; Tigo Tanzania also hired a qualified HSES Manager, supported by 3 E&S staff, including a community liaison officer (CLO). ToA Uganda strengthened its team with the recruitment of a E&S and Quality Coordinator. Opcos E&S teams report directly to the respective country Managers or to the most senior leadership member, with a dotted line to the group Head of HSES.
Key O&M contractors are required to appoint dedicated E&S personnel, to enforce compliance in line with the Group’s E&S commitments. To enhance their E&S skills, AT has rolled out a comprehensive E&S training program for local contractor personnel, stressing on OHS cultural shift and safe driving.
Emergency Preparedness and Response. As part of the ESMS, AT has developed an Emergency Preparedness and Response Plan (EPRP) that defines site-specific measures to address potential environmental or accidental OHS occurrences and flooding risk. The plan also defines roles, responsibilities, emergency triggers, types and drills; evacuation protocol, emergency structures, life and fire safety (LFS) measures, coordination with external parties; emergency training; and standard emergency operating procedures for various emergency types. The plan has been adopted at Opco level and customized as needed.
Monitoring and Review. AT monitors E&S performance through several mechanisms, including monthly data collection and analysis. Subsidiaries report E&S performance to the corporate team, according to group-defined key performance indicators (KPIs). Consolidated data are centralized at group level, from which reports are generated and inform the AT Annual Reporting (https://www.axian-telecom.com/cirdowee/2024/05/SUSTAINABILITY-REPORT-2023_VF_280524.pdf). The corporate audit officer evaluates the effectiveness of E&S performance requirements and reports on necessary improvements according to the ‘Group's Internal Auditing Standard’. At country level, Opcos are subject to periodic compliance audits by relevant host country authorities. Additionally, AT engages an independent E&S auditor to conduct annual E&S audits in accordance with its obligations to international partners.
PS2: Labor and Working Conditions
Human Resources (HR) Policies. AT employs approximately 3400 direct workers, with the majority operating at the OpCo level. The company also employs approximately 3,000 contract workers through third-party service providers at the OpCo level. The male to female ratio of both direct and contract workers is approximately 70:30.
HR policies are documented in the ‘Corporate HR Charter’ and are supplemented by various procedures including the ‘Code of Conduct’. They apply to all Opcos direct and contracted workers engaged by third parties and were designed consistently with PS2 requirements. The policies explicitly cover key topics such as recruitment, remuneration, working conditions, workers' freedom of association, non-discrimination and equal opportunity, gender-based violence and workplace harassment (GBVH), prohibition of child labor and forced labor, retrenchment, OHS management, worker grievance management, among others. Opcos have adopted the corporate HR policies and developed project-level ones that meet host country labor requirements, in addition to specifying minimum compensation principles and employee benefits for direct and contracted workers.
Working Conditions and Terms of Employment. AT issues employees with written employment contracts, which may be fixed term or permanent. Contracts outline the terms of employment and are communicated during onboarding. Terms covered include remuneration, working hours, leave, benefits, training, working hours, wages, overtime, rest days and annual leave among others, and are defined at Opco level in line with local labor laws. Contractors are required to establish contracts with their workers on the same basis, as outlined in the ‘Contractor HSSE Management Procedure’.
Workers’ Organizations. AT’s HR Charter and Opcos HR policies have been updated to incorporate a commitment to respecting employees’ rights to collective bargaining and acknowledging freedom of association in accordance with the International Labor Organization (ILO) conventions.
Non-Discrimination and Equal Opportunity. As detailed in the HR Charter, Opcos have adopted the corporate Equal Opportunity Policy which outlines AT’s management commitment towards equal opportunity in employment, non-discrimination etc. The company has also defined an Anti-Harassment and Bullying Policy emphasizing its approach to providing a workplace free from harassment, including sexual harassment, and bullying. In 2022, the Togo subsidiary received reports of employee discrimination and concerns about retaliation. In accordance with the previous transaction requirements, AT commissioned a labour audit that reviewed HR policies and procedures for compliance with national labour laws and IFC PS 2 on labour and working conditions. This led to the implementation of a new collective bargaining agreement in March 2023.
Grievance Mechanism. AT's internal grievance management procedure was updated to align with PS2. It includes a separate employee (and contracted workers) grievance management mechanism covering employees and contracted workers, along with clear steps for grievance processing: i.e reception, investigation, response, arbitrage, and monitoring. The mechanism provides clear channels for raising grievances by direct and contracted workers (including anonymous channels); defined grievance registration and documentation process; clear timelines and responsibilities for grievance processing; feedback channels to the claimants; and options for grievance escalation. Opcos have adopted and customized the procedure to fit their operating environment. In 2024, Opcos recorded internal grievances, closing over 90%, with the rest still being processed.
Protecting the Work Force. In accordance with the HR Charter, Opcos HR procedures have been revised to include clauses on Child Labor and Forced Labor prohibition. This requirement is also extended to contractors and third parties through the Contractor EHS Requirements.
Occupational Health and Safety.
AT's HSES policy, including commitments to a safe work environment and accident prevention, is enforced throughout its operations and OHS is a key part of its ESMS. As detailed above, each Opco has developed its own ESMS, based on the principles established at the corporate level, and appointed qualified E&S staff to oversee implementation as required under the ongoing agreements. Contractors are also required to appoint competent E&S staff as specified in their terms of contracts.
AT systematically monitors and tracks its OHS performance across all Opcos. Each Opco is ranked based on its performance, considering both incident rates and achievements in leading and lagging indicators. The corporate risk register captures OHS risk related to different activities, including those undertaken by third-party contracted workers. There is ongoing dissemination and exchange of OHS information (policy and procedures) with employees, management, and relevant stakeholders. AT has also established mandatory training requirements for contracted workers, including on OHS culture shift, HSES induction, defensive driving, working at heights, electrical risk/authorization, first aid, among others. Contractors are required to submit training certifications prior to the start of any work.
Following the acquisition of various existing operations and their OHS legacy, the company has implemented several management and operational measures, including requirements for notification, investigation, reporting, and corrective actions to effectively address root causes of project-related occupational injuries and fatalities. The company has made improvements to bring under control safety incidents directly affecting employees and contractors and will continue to implement risk reduction measures. At the same time, safety incidents impacting contracted workers and members of the public, which are primarily attributed to road safety, have also decreased over the past 3 years. Specific actions to address public safety are captured under PS 4. A comparative analysis of Lost Time Injury Frequency Rate (LTIFR) from 2023 to 2024 indicated a reduction in workplace incidents, showcasing a measurable improvement in safety performance (from 0.08 in 2023 to 0.06 in 2024).
Wananchi group’s OHS practices were audited against AT’s E&S commitments and in line with IFC OHS requirements. Identified gaps were incorporated in a timebound corrective action plan that will be monitored as part of AT’s ongoing Opcos audit program.
Workers Engaged by Third Parties.
AT relies on contractors for various activities, including civil works, operations and maintenance, transport, and security. Contractors and local subcontractors are mandated to comply with AT and Opcos’ HSES standards, manage risks, and ensure that all activities are performed safely and in compliance with applicable local regulations. The group’s contractor management framework includes procedures for pre-qualification, selection and monitoring of contractor EHS performance, and audit. As per the procedure, AT evaluates potential contractors HSE practices and performance to ensure alignment with its commitments. This includes contractor’ ESMS, labor and OHS practices, subcontractors’ management, training and supervision of high-risk activities and environmental compliance. In 2023, AT focused on the initial rollout phase of the ESMS, while in 2024, the emphasis was on reinforcing the ESMS's effectiveness.
Each Opco has been required to maintain an updated list of its active contractors, prioritized according to the "Activity Categorization Procedure", and identifying E&S focal personnel in charge of ESMS implementation. In 2024, AT conducted 38 audits of key contractors involved in high-risk activities (security services, civil works, equipment operations and maintenance). Corrective actions were defined and will be monitored as part of follow-up audits.
AT improved its contractor risk management framework by developing a ‘ Fatality Prevention System’ (FPS), focusing on five critical risk areas that have historically contributed to workplace and community incidents.
Going forward, AT will (i) enhance its training program by incorporating recurrent training sessions on major E&S risks for contractors (i.e. annual sessions for top 5 risks at their operations), and training for AT’s operational staff involved with contractors on how to conduct ‘contractors audits’; (ii) develop a timebound action plan specifying KPIs, expected deliverables, and groups of contractors targeted under the various elements of the ‘Fatality Prevention System’ FPS, (i.e Road safety management, Health management, Security management, Work at height safety, Electrical safety); (iii) revise its contractor audit strategy and program to prioritize high and medium risk contractors. The audit plan will include bi-annual audits for such contractors to ensure compliance with safe operations and labor requirements as per contractual EHS clauses and in line with PS 2 requirements (ESAP#1).
PS3: Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gases. Grid electricity and diesel are the primary sources of energy for the group’s operations, which include tower sites, data centers, and other assets. Solar power is utilized as a supplementary energy source at remote base transceiver station (BTS) sites. Opcos track energy consumption and report to management and the corporate E&S team as part of HSES monthly and quarterly reports. AT consumes mainly municipal water for the majority of its operations. Quantities are limited and primarily used for routine administrative, sanitary and cleaning purposes.
AT has defined resource usage KPIs and integrated its Opcos into the group’s ‘Impact scorecard framework’ for resources tracking and reporting, following the ‘GHG protocol’. Emissions are predominantly associated with diesel generators and motor vehicles. In 2024 total scope 1 and 2 emissions amounted to 88,290 tCO2.
The Company’s assets and operations may be exposed to climate hazards such as high temperatures (which may affect equipment performance), an increase in precipitation, and sea level rise which may lead to flooding. AT agreed to conduct detailed physical risk assessments and implement adaptation measures for the Telma Comoros and Tigo Tanzania Opcos under the previous transaction (#49849). This requirement will be extended to all its Opcos. (ESAP #2)
Pollution Prevention. Diesel generators at BTS are self-contained to prevent spillage, and diesel supplies are stored securely. The diesel supplies are contained in secure tanks or gallons, usually stored on hard surfaces. AT ensures that posters detailing spill containment procedures are prominently displayed at tower sites, and attendants receive basic training on spill management. To mitigate noise nuisance complaints, AT has been transitioning from generators to grid power or solar power at locations where noise-related grievances have been reported. Where this is not possible, generator's hours are reduced by alternating with two power options.
Besides limited quantities of hazardous waste from construction activities and equipment maintenance, the main waste streams include general office waste, cleaning wastewater, and sanitary effluent. AT developed a waste management procedure aligned with the IFC EHS Guidelines, which has been rolled out to Opcos. Specific additional procedures have been established for the management of hazardous waste, including electronic waste, used oil, and batteries. Opcos work with licensed waste service providers. As a general practice, obsolete equipment is reconditioned or sold, used batteries are sent to specialized dealers and non-hazardous waste is collected for disposal at municipal landfills or recycled where it is feasible. Each subsidiary is required to report quarterly KPIs related to waste management, including waste generated, disposed of, and recycled as part of the ‘Impact scorecard’. AT has also developed procedures for the monitoring of Electromagnetic Radiation, noise levels and water consumption in line with the IFC EHS Guidelines.
PS4: Community Health, Safety and Security
Community Health and Safety. As per the requirements of the company’s site acquisition procedure, community health and safety risks and impacts, including impacts to livelihoods, access, social cohesion etc., are assessed during the pre-acquisition site phase. In addition, AT has established a Community Health and Safety Management Procedure which includes risk considerations in the design and erection of new towers, repairs and maintenance, fiber works, management of impacts of electromagnetic fields (and relevant siting criteria), waste management, security provision and training, managing transportation risks to communities and community engagement and external grievance redress process.
Traffic Management. Due to the remote location of assets, AT’s operations require extensive road travel, which has resulted in safety and road accidents across the different Opcos. In order to manage this risk, Axian has started the implementation of a comprehensive road transportation safety management program. This program includes journey management, mandatory driver training, standardized driver selection criteria, In-Vehicle Monitoring System (IVMS), vehicle condition monitoring, zero tolerance for alcohol and substance abuse, and frequent awareness on road safety for both employees and contractors. In the past 2 years, Axian has rolled out an IVMS adoption strategy and currently, 95% of the vehicles used for Axian operations are equipped with IVMS. The IVMS is primarily used for critical driving behaviors such speed violations and harsh braking. Road accidents are investigated using root cause analysis through existing accident investigation procedures. These measures have led to a reduction in road accidents.
Security Personnel. AT Opcos utilize private security companies to provide security and access control at offices and specific assets, including tower sites and datacenters. Security at the corporate level is managed by the Group Security Director, while technical teams and main contractors oversee security service providers’ day-to-day operations at each Opco. As agreed under the ongoing investments, AT has developed a ‘Corporate Security Management Procedure’ that has been adopted by Opcos. The procedure includes provisions on screening of security service providers against basic on crowd control; requirements to carry out security risk assessments; regular refresher training; provision of adequate PPE and communication resources; reporting arrangements; use of arms; working conditions of security guards and compliance with AT’s E&S policies and with this Performance Standard.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
To align and meet the requirements of IFC PS6, Axian have committed in their HSES policy to avoid, to the extent operationally and financially feasible, the construction of new assets in areas of high biodiversity sensitivity, such as Legally Protected Areas, Internationally Recognized Areas (IRAs), and particularly Natural and Mixed World Heritage Sites (WHS) and Alliance for Zero Extinction (AZE) sites.
The group developed the ‘Biodiversity Screening & Management Procedure’ which defines the approach to screen for areas of high biodiversity sensitivity, and identifies the steps required when new towers are proposed in such areas. These steps include consultation with the relevant stakeholders (e.g., legally protected area management, conservation organizations that have designated IRAs) to ensure compatibility with the values of these areas, and, as required, implementation of additional programs, to promote and enhance the conservation aims and effective management of such areas. Under the Biodiversity Management Procedure, AT must inform lenders as soon as existing or proposed project activities/infrastructure are identified in an AZE site or WHS, and if the requirements for sites in these areas cannot be met, alternative sites must be identified. The procedure also includes measures relevant to the rehabilitation of disturbed areas once construction activities are completed.
AT have previously prepared biodiversity screening reports for Comoros Islands and Tanzania, and subsequently developed a biodiversity action plan (BAP) for Comoros as set out in the Biodiversity Management Procedure – these have been appraised under previous transactions https://disclosures.ifc.org/project-detail/ESRS/46459/axian-telecom-bond and https://disclosures.ifc.org/project-detail/ESRS/37209/telco-sa. AT have also prepared country-level biodiversity screening reports for Madagascar (ToA and YAS), Uganda, and Togo. In Madagascar (ToA), eight proposed tower locations were situated within AZE, five of which also overlapped protected areas. To date, draft critical habitat assessment reports have been prepared for the five sites situated within protected areas, and biodiversity mitigation measures and action plans (BAP) developed, further to engagement with KBA secretariat and species experts. Finalization and implementation of the BAP actions is pending. In Togo, no infrastructure overlaps with protected areas, internationally recognized areas, AZE, or WHS, as per the country-level screening report.
Implementation strategies for conservation actions identified for sites within AZE sites, but outside of protected areas, are required. The BAP for the Tanzania portfolio is a pending action where advancement has been observed, but still needs to be completed, in order for the previous ESAP items to be closed. Axian’s progress on implementation of completed BAPs and additional conservation actions will be reported to IFC, together with the outcomes of any additional conservation actions implemented in AZE as well as KBA sites, on a biannual basis.
