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
E&S Policy and Management System
IENTC has developed a corporate Sustainability Policy that is aligned with IFC PS principles and IENTC’s corporate ESG Strategy, Social Policy, Code of Conduct (CoC), Human Rights Policy and Corporate Risk Management Policy, which are applicable to all the company’s operations. These policies include commitments relating to E&S management and sustainability, OHS, compliance with applicable E&S laws in Mexico, as well as communication and engagement with stakeholders.
IENTC implements its policy commitments through an Integrated ESG Management System (IMS), generally aligned with IFC PS1, comprised of corporate policies, risk assessment and identification processes, social principles and supporting mechanisms and procedures (at different levels of development), emergency response plans (ERP), and monitoring systems that apply across all operations. aimed at overall E&S and OHS management and ensuring compliance with relevant local regulations.
E&S Assessment and Management
IENTC has in place assessment and management procedures for E&S and OHS aspects covering key areas such as solid waste management, emergency preparedness and response, and legal E&S compliance. However, in accordance with Mexican legislation, the company is not required to undertake a full Environmental and Social Impact Assessment (ESIA) for the type of assets and activities covered by this project, which are considered of limited E&S risk.
As set forth in ESAP #1, the company will develop an E&S Assessment and Management Procedure (ESAMP) commensurate with the E&S risks of its operations and align it with IFC PS.
Organizational Capacity and Competency
IENTC Risk Management Committee (RMC) and Corporate Sustainability Working Group (CSWG), is composed of professionals from relevant units, overseeing and monitoring the implementation of the IMS. The RMC main purpose is identifying, assessing, monitoring, prioritizing, and escalating the company’s main risks, including finance, legal, operations, IT and HR areas. On the other hand, CSWG’s main objective is to coordinate sustainability execution across the company, ensuring that ESG commitments are embedded in operations
Additionally, a dedicated health, safety, and quality management team has been appointed to manage, control and monitor E&S risks for each subproject site. As set forth in ESAP # 2, the company will nominate a qualified corporate-level E&S coordinator, to oversee and coordinate the implementation of the E&S aspects of the corporate IMS, the ESAMP, and the ESAP implementation.
Emergency Preparedness and Response Planning (EPRP)
IENTC has a corporate ERP applicable to all the company operations, including the definition of responsibilities and duties of each emergency response team including office, operative facilities (antennas, etc.) and service centers. The ERP consists of a standard operating procedure in case of fire, medical emergency, and emergency reporting procedure based on the requirements of Mexico’s Civil Protection agency. The emergency response team provides relevant emergency training in cooperation with the HR department and relevant committees. The plan includes accidents occurring for the transportation of personnel services provided by the company and crews’ transportation. (refer to PS4 Section for additional information)
Monitoring and Review
IENTC has established corporate sustainability objectives, key performance indicators (KPIs) and targets to continuously monitor the company’s E&S performance, including accident record, training records, energy consumption and efficiency, E&S management, legal compliance, etc. In addition, the company has developed a regulatory compliance checklist to ensure its business operations comply with relevant laws and regulations. The RMC and the CSWG and representatives from corporate departments are responsible for collecting and reviewing assessment information.
At present, the company does not hire contractors for the construction or maintenance of its infrastructure. However, should the need arise in the future, the company will oversee contractors' environmental and safety performance through the corporate IMS (EHS Annex). This oversight will include specific requirements for EHS risks, high-risk activities, accident reporting, and the use of personal protective equipment, among other measures.
PS2- Labor and working conditions
Working Conditions and Terms of Employment
As of February 2026, IENTC employs approximately 704 workers directly, including operational and administrative personnel, with women representing approximately 14% of the workforce. IENTC has had rapid growth over the last 3 years, with an expected workforce of 1000 employees by the end of 2026. The company relies primarily on its own direct workforce and does not use third-party workers for core operational activities or any other services.
The company has established a Human Resources Policy, procedures, and an Employee Handbook that addresses key aspects of labor management. These include worker obligations; working days and hours; overtime provisions and payments; holidays and leave entitlements; disciplinary measures; medical examinations; insurance benefits; and conditions for termination of employment, all in line with national labor regulations. Formal employment contracts reflecting these terms and conditions are provided to each worker prior to the start of employment.
IENTC HR policies prohibit the use of child and forced labor in its operations, in accordance with national labor legislation and international labor standards. The company’s Social Policy requires compliance with the legal minimum working age, ensures that all employment is voluntary, and explicitly forbids child and forced labor across its workforce and supply chain through its ESG and supplier management framework.
Workers’ Organization
IENTC recognizes workers’ freedom of association and does not restrict employees from exercising this right in accordance with national labor legislation. Currently, no labor union represents employees working at the company, and there are no collective bargaining agreements in place.
Non-discrimination and Equal Opportunity
ENTC has Human Resources, non Discrimination, and Equal Employment Opportunity policies aligned with national labor law, including prohibitions on child and forced labor and measures to prevent discrimination, harassment, and gender based violence (GBV). These commitments are embedded in the company’s IMS and Social Policy, which promotes gender equality, fair labor conditions, and an inclusive workplace. IENTC has also adopted a workplace violence and harassment protocol, including sexual harassment, with clear complaint and response procedures. The company provides equal employment conditions for men and women in line with national legislation and internal policies.
Retrenchment
IENTC’s Internal Labor Regulations allow termination in line with the Ley Federal del Trabajo (LFT). In order to align with IFC PS2, under ESAP #3, IENTC will develop and implement a PS2-aligned Retrenchment Policy and Procedure.
Gender Based Violence
IENTC has policies supporting equal opportunity and non-discrimination, promoting gender equality, and preventing workplace violence and harassment. These policies foster an inclusive work environment and prohibit gender-based discrimination. IENTC has a protocol to prevent and address workplace violence, harassment, and sexual harassment, with clear complaint procedures.
Workers’ Grievance Mechanism
IENTC has multiple internal grievance channels, and mechanisms, including the Petitions, Complaints, Reports, and Suggestions (PQRS) system, under its IMS, allowing employees to report workplace issues, incidents, and cases of violence or harassment (including sexual harassment). Complaints are handled through a defined, confidential procedure overseen by an internal committee. As part of ESAP #4, IENTC will further strengthen the mechanism by adding an anonymous reporting channel to enhance protection against retaliation.
Occupational Health and Safety
IENTC manages OHS through its IMS and corporate risk management framework, supported by OHS policies applicable to employees and suppliers, all of which are aligned with IFC PS2 requirements. The company promotes safe working conditions through risk prevention measures, regular training, incident investigation, and oversight by a dedicated health and safety committee that reports quarterly to management.
Supply Chain
The company applies their corporate Code of Conduct and Human Rights Policy that embed human rights, OHS, and environmental considerations across procurement and supplier engagement, supported by regular supplier mapping and risk screening, mandatory policy acknowledgment, and annual ESG performance evaluations of key suppliers. These practices are being further strengthened through the development of a formal Sustainable Procurement Policy and the use of supplier sustainability questionnaires to promote continuous improvement across the supply chain.
PS3-Resource Efficiency and Pollution Prevention
Resource Efficiency and Greenhouse Gas (GHG) Emissions
IENTC’s operations are primarily office based and have low water use and relatively limited environmental footprint. Resource efficiency measures include LED lighting, solar panels for office operations, energy management systems, and reduced paper consumption. Electricity use is limited and sourced from the national grid, and direct annual GHG emissions, which are negligible, mainly related to fuel consumption from the vehicle fleet.
Waste Management
The company has a waste management and recycling framework that promotes waste segregation, proper storage, and reduced disposal. Waste is managed through authorized third party service providers specialized by waste type, including a licensed e waste recycler approved by environmental authorities, ensuring compliant recycling and disposal practices across operations.
PS4-Community Health, Safety and Security
Infrastructure Safety
IENTC’s offices comply with national fire and safety regulations and hold valid certifications issued by local authorities and Civil Protection, supported by regular inspections and emergency drills. Facilities are equipped with compliant fire detection and suppression systems and are not open to the public. For field operations, the company applies strict safety procedures for fiber optic installation, including the use of ADSS (All Dielectric Self Supporting) fiber, a non metallic cable that supports its own weight and reduces fire and electrical risks, combined with advanced subsurface detection, trained personnel, and close coordination with utilities and authorities, with incidents monitored through the Security Operations Center.
Transportation
IENTC provides worker transportation from specific locations of the area of Queretaro to its offices, and operates a fleet of vehicles for field activities, managed directly by IENTC, under defined safety protocols. Community risks from transport activities are addressed through driver training, vehicle inspections, emergency preparedness, and real-time GPS monitoring. Under ESAP #5, the company will further strengthen these measures by adopting a Corporate Transportation Manual focused on community safety, emergency response, and code of conduct and Sexual Exploitation, Abuse and Harassment (SEAH) prevention during interactions with communities.
Security Personnel:
Some company facilities, including the corporate and branch offices and other premises, are protected using unarmed security staff. The company regularly undertakes internal briefings and provides training for the security personnel, including emergency response.
