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 management systems and Policies. HT has established a corporate ESMS, supported by group-level policies covering environment, health and safety, human resources, supply chain, security, site acquisition, and ethics. The ESMS is integrated with ISO 9001, ISO 14001, and ISO 45001 certifications across OpCos. Also, all nine OpCos are certified to the integrated management system under ISO 9001, ISO 14001 and ISO 45001. Furthermore, HT provides active guidance to help its contractors achieve the safety standard and this resulted in 16 of its 17 contractors or maintenance partners being ISO 45001 certified in 2024. Finally, HT’s corporate ESMS is broadly aligned with IFC PSs and includes a suite of performance indicators reported monthly for senior management review.
However, the level of implementation of HT’s corporate ESMS varies across the different OpCos. As part of continuous improvement, HT will update its ESMS manual and cascade it consistently across the different OpCos by: (i) including the E&S organization chart and E&S Committee with defined roles; (ii) implementing a comprehensive E&S assessments that addresses risks consistent with all IFC PSs; (iii) establishing E&S management programs and standard operating procedures (SOPs) for E&S risk mitigation during project development and O&M, applicable to Contractors, subcontractors and suppliers; (iv) enhancing the monitoring and evaluation program with comprehensive KPIs (e.g., spills, theft/vandalism, GBVH, grievances, Indigenous Peoples proximity, chance finds), (v) updating the emergency response plan to include scenarios like equipment failure, outages, and security threats; (vi) formalizing a stakeholder engagement plan including an external grievance mechanisms that including gender considerations; (vii) supply chain management procedure with a supplier code of conduct; and, (viii) a schedule for ESMS rollout to all OpCos (ESAP#1).
Identification of E&S risks and impacts. HT’s policy commitments include conducting E&S impact assessments (ESIAs) to ensure risks and impacts are identified and mitigated, and the required permits/authorizations are obtained. Risk identification is undertaken through a combination of corporate risk registers, site screening tools, security matrices, and contractor risk assessments.
Site acquisition: In 2025 up to Q3, 2025, HT developed 306 new sites. HT applies a structured site acquisition and screening process, including Search Area Reports and permitting checks. The process seeks to avoid involuntary resettlement and sensitive receptors. Land acquisition and involuntary resettlement issues are not foreseen as land to develop the build-to-suit sites (new towers) are acquired on a willing buyer - willing seller basis and does not involve expropriation or compulsory land acquisition that may lead to the involuntary displacement (physical or economic) of people. Under the previous investment, HT developed a corporate land acquisition policy aligned with IFC PS5 requirements. As per ESAP #1, HT will update the E&S assessment procedure to (i) cover all assets including workers’ accommodation, (ii) clearly define roles and responsibilities; (iii) comprehensively cover all nationally applicable working condition and environmental regulations (iv) include a standard site layout plan incorporating E&S criteria such as buffer zones, flood avoidance, safety equipment; and, (v) a structured training program for internal departments and subcontractors.
Management programs. HT has established a comprehensive supplier management procedure that addresses health and safety, traffic safety, contractor oversight, and environmental management. In 2024, HT enhanced its contractor management program by adopting new technologies, specifically introducing virtual supervision using camera helmets, a remote management tool. Additionally, HT allocated resources to procure camera helmets for contractor supervisors as well as engineering and technical teams to serve several key purposes including: (i) virtual site visits with ability to view work sites from the supervisor’s perspective, enabling sampling, recording, and assessment of compliance with HT’s SHEQ standards; (ii) virtual permit authority which enables verification of essential SHEQ controls during high-risk activities, such as working at heights or handling electrical connections; and (iii) investigation review which offers the means to examine circumstances surrounding incidents, supporting thorough investigations. Furthermore, HT has developed a Contractor E&S Management Plan (CESMP) Template, designed for inclusion in legally binding clauses with contractors and subcontractors. Each contractor is required to use this template to prepare a CESMP that addresses the E&S risks and impacts associated with their specific scope of work. Implementation of management programs is strongest for OHS, while environmental management programs for biodiversity, waste, and hazardous materials vary by OpCo and contractor. As part of ESAP #1, HT will implement a documented process at each OpCo level to monitor CESMP implementation as well as periodic training for contractors and subcontractors to ensure alignment with HT’s requirements and the IFC PSs.
Organizational capacity and competence. HT’s organizational structure includes a Group Head of Sustainability, a Group Head of HSEQ, and at least one but typically two HSEQ Advisors within each OpCo. Managing Directors (MDs) of the different OpCos are accountable for reporting their respective E&S performance during monthly business review meetings. Each OpCo is also supported by an HR Head responsible for labor management and community outreach initiatives. Tier I Contractors are mandated to maintain an HSEQ management team with the requisite experience. As part of the ESMS manual update (ref. ESAP #1), HT will identify and establish sustainability champions for each OpCo.
HT has developed a comprehensive training program, featuring mandatory onboarding courses for all new staff members. Additionally, HT personnel receive additional training and awareness on environmental, social, and health and safety matters through: (i) HSE inductions; (ii) formal internal and external training; and (iii) Toolbox Talks, with each OpCo operating its own dedicated training programs. As part of ESAP#1, HT will formalize an E&S training plan that includes training on IFC PSs for relevant management and sustainability staff, expand the e-learning platform to address key E&S topics, and make it accessible to Contractors and subcontractors.
Emergency Preparedness and Response Plan (EPRP). HT has established an Emergency Preparedness and Response (EPR) system that mandates all OpCos to develop local procedures for identifying potential incidents and emergencies. Also, HT’s OpCo offices adhere to EPR protocols by incorporating measures such as displaying building floor plans with clearly marked evacuation routes, installing illuminated exit signs at emergency exits, and strategically placing fire alarms and fire extinguishers throughout key locations. Emergency contact numbers are posted, and fire marshals are assigned to each floor to coordinate response efforts. Regular emergency drills are conducted to maintain preparedness. Furthermore, firefighting equipment are positioned adjacent to generators at various tower sites, and reports confirm the execution of site-level emergency drills. Under ESAP #1, HT will standardize drill planning and registration in collaboration with each Contractor or subcontractor and ensure that emergency-related considerations, including climate-related risks such as heatwaves, floods, and high winds, are integrated activity planning and site layouts.
E&S Monitoring. HT uses digital platforms for incident reporting, audits, and performance tracking. HT audits every contractor at least twice a year using 26 EHS criteria divided into 13 on management systems and 13 on operational controls, all specified in contracts. The audit scoring recognizes innovation, compliance, and various types of non-compliance, including serious or legal breaches. As part of ESAP #1, HT will expand its monitoring to include KPIs for spills, theft, vandalism, GBVH cases, grievances, sites near Indigenous Peoples, and Chance Finds.
PS2: Labor and Working Conditions
Human Resources Policies and Procedures. Helios Towers currently has a total workforce of 735 up from 611 in 2024 and relies on third party workforce for its construction and O&M activities. HT’s direct workforce is made up of 95% local employees and divided into 29% female and 71% male. Corporate staff constitutes around 17% of HT’s overall workforce while 83% is spread out across the different OpCos. In 2025, HT appointed (promoted) a new Group HR Director.
HT Group has developed a corporate HR management system (HRMS) which includes procedures related to recruitment and onboarding, work organization (working hours, management of interns, disciplinary sanctions), salary payment, training and promotion. HT policies and procedures require compliance with all applicable local labor laws and regulations across countries of operation especially that of fair treatment, non-discrimination and equal opportunity of its employees, prohibition of forced / child labor, freedom of association, safe working environment and written procedures for handling employee grievances. HT employee handbook and Code of Conduct outlines HR processes aligned with IFC PS2 requirements. As part of this financing, HT will update its HR procedures to formalize (i) retrenchment procedure in line with IFC Good Practice on managing retrenchment, and ILO Conventions outlining job protection alternatives, stakeholder engagement and consultation, retrenchment criteria and assistance programs; (ii) compliance monitoring of all Contractor employment contracts with national labor law, ILO and IFC PS2 requirements as it pertains to (minimum wage, monitor working hours and overtime for on-call staff, and (iii) HRMS requirements awareness programs extended to Contractors and subcontractors across all OpCos (ESAP #2).
Workers Organization. HT Code of Conduct addresses collaboration with labor unions and associations and clearly states the employees’ rights to freedom of association and collective bargaining. Unions operate in the DRC, and employee representatives are present in Senegal, Congo Brazzaville, and Madagascar. National-level collective bargaining agreements exist in Senegal and Congo Brazzaville. DRC, Congo Brazzaville, and Madagascar have negotiated approved rules and regulations with employee representatives.
Grievance Redress Mechanism: HT has developed and is implementing an internal grievance mechanism which allows workers to raise concerns, and a confidential integrity line is available for employees and third parties to report issues anonymously. Also, a complaint investigation team exists at the level of the OpCos chaired by HR and should a complaint concern a member of the committee, then the member is replaced. Furthermore, HT has engaged gender base violence and sexual harassment specialized services providers in South Africa and Tanzania to provide 24 hours confidential personnel support service. As part of the HRMS update (ref. ESAP #2), HT will socialize its internal grievance management procedure outlining how grievances reported through the Confidential Reporting Line are handled / escalated at the OpCos level and Contractors.
Occupational health and safety management performance. HT OHS is a core focus area, with strong policies, training, incident reporting, and monitoring systems. HT implements 10 lifesaving rules across its activities, and its safe system of works require risk assessment and permitting for working at heights, electrical safety and road safety. Also HT implements, technology integration, such as camera helmets and fixed cameras at worksites, as well as dashcams in vehicles to support continuous monitoring and promote safe behaviors. Furthermore, safety leadership and engagement are reinforced through active participation from management and key influencers, ensuring accountability and a strong safety culture throughout the organization. Finally, HT utilizes digital tools like ServiceNow for accurate and efficient reporting, facilitating real-time analysis and continuous improvement.
Under the previous bond investment in alignment with IFC PS 2 requirements, HT has achieved a reduction in workplace accidents and injuries through targeted interventions and ongoing training programs materialized by reductions across all key indicators in the last 5 years including (i) Lost Time Injury Frequency Rate (LTIFR) falling from 0.91 to 0.15 per million man-hours (an 84% reduction), while Lost Time Injury Severity Rate dropped from 23.97 to 1.86 days per million man-hours (a 93% reduction); (ii) Fatal Accident Frequency Rate decreased by 71% over the same period, and road safety outcomes also strengthened, with Road Traffic Accident Frequency Rate reducing by 30% and Severity Rate by 29% since 2021. As part of ESAP #1, HT will implement regular site-specific OHS risk assessments and training, schedule OHS Committees meetings, standardize PPE provision, and enhance monitoring for all OpCo workers, contractors and subcontractors.
Workers Engaged by Third Parties. HT relies extensively on contractors for construction, maintenance, security, and logistics to serve its over 14,000 sites in the none OpCos. Also, E&S provisions are included in the contracts established between the build partners, maintenance partners and other suppliers. As part of ESAP #2, HT will: (i) update the partners register to include warehouse management subcontractors, driver subcontractors, and labor brokers, as well as add HR provisions monitoring; (ii) establish and implement a corporate-level audit program to assess contractors and subcontractors compliance with relevant national legislation, and (iii) where gaps are identified, develop and implement an action plan aligned with IFC PS2.
PS3: Resource Efficiency and Pollution Prevention
Resource Use Efficiency: HT’s main energy sources for its activities are grid electricity and diesel. In 2024, HT’s implemented hybrid installations, integrating solar systems and long-life lithium batteries leading to a 46% reduction in diesel consumption, equating to over 400 tons of carbon emissions avoided. Also, HT has adopted a semi-automated panel washing system, coupled with water recycling for repeated washes, efficiently minimizing water consumption. Finally, HT is implementing measures for managing hydrocarbon products and site waste, including spill prevention and litter control.
GHG Emissions: HT used 819,125,195 kWh of total fuel (diesel and petrol) and consumed 423,951,922 kWh total electricity in 2024 across it operations. The energy consumption equates to 210,603 tCO2e Scope 1 and 140,414 tCO2e Scope 2 emissions reported in 2024. Group-level GHG emissions are quantified annually, exceeding the IFC reporting threshold. Finally, HT has set medium and long-term decarbonization targets, supported by solar roll-out and fuel reduction initiatives.
Waste Management: The most significant waste stream associated with HT’s activities include metal (iron, steel) with a high recycling rate. Other waste streams include generators, batteries and rectifiers. HT’s waste management philosophy integrates (i) returning any equipment or materials that cannot be repaired or reused on site to warehouses, (ii) repair or refurbish generators, batteries and rectifiers to extract full value and expand the lifespan of equipment, and (iii) when repair is no longer possible, use a certified and approved recycling partner. Also, under the previous investment, HT has included waste management in the CESMP Template developed for all its Contractors and subcontractors. As per ESAP #1, HT will formalize a waste management procedure at the OpCo level to address local constraints and stakeholders and enhance waste management practices by contractors and subcontractors.
Hazardous Materials: The main hazardous materials include fossil fuel, batteries and chemical waste. HT implements pollution prevention and control measures including installation procurement of generators with inbuilt containments and double lined fuel reservoirs. Also, a generator inspection program is enforced to detect and address spills. As part of ESAP #1, HT will, (i) establish procedures and training for fuel collection and delivery that address spills, (ii) formalize a corporate spills management SOP with reporting, and (iii) update the incidents register to include spill cases from operator errors during O&M.
PS4: Community Health, Safety and Security
Transport Safety: Road safety is a significant residual risk, particularly for contractor vehicles. Between 2024 and 2025, HT conducted a full review of driving risks across its partner network and developed a Safe Vehicle Use procedure, to specify expectations for safe vehicle usage. Also, vehicle IVMS, dashcams and Motorcycle GPS are mandated in partner contracts. Furthermore, partner driver and rider behaviors are monitored using vehicle IVMS and motorcycle GPS which are both performance-managed monthly as part of the SHEQ oversight and performance management framework along with the motorcycle phase out program. Going forward, HT will update and implement a transport risk management program applicable to its own fleet and that of its contractors and suppliers across all OpCos that includes; i) route risk assessment that maps high risks zones within each market and implement controls or maintain collaboration with public road safety officials; ii) a journey management plan template that sets maximum driving hours and required break periods, verify presence of fire extinguishers and first aid kits in all vehicles, addresses refueling and transport of hazardous goods, and enforces driver identity controls; iii) reinforcements of IVMS/Dashcams in markets where authorized as pre-requisites for vehicle mobilization; (v); and, (v) driver fitness, competence and training, speed limits, emergency response for road accidents, vehicle maintenance, safety standards and GBVSH (ESAP #3).
Security: Security risks vary by country, with higher risks in conflict-affected areas. In 2025, HT updated its Group Security Policy to further guarantee a safe workplace by identifying and minimizing risks from political, economic, labor, or social factors, promoting accountability, and complying with all security laws and best practices. Also, the policy calls for collaboration with authorities, thorough investigation and follow-up on incidents or grievances, and the use of tailored security solutions. Furthermore, HT defines security solutions according to the risk profile of each site, integrating technology such as motion sensors, CCTV cameras, alarms, electronic access locks and guards. Finally, security is a contracted private service and does not make use of armed guards with guards trained not to engage with criminals but rather to keep themselves safe in the event of criminal attack and are simply raise the alarm. As per ESAP #1, HT will (i) standardize and regularly update mapping of high-risk areas using GIS layers to assess security risks and guide mitigation strategies such as revising travel routes or suspending O&M activities and (ii) where feasible, formalize relationships with public forces through Memoranda of Understanding, either directly or via partners.
PS6: Biodiversity Conservation and Sustainable Management of Natural Living Things
HT currently operates 14,097 towers across nine countries, with 1,175 located within or near protected areas including 52 towers in Alliance for Zero Extinction (AZE) sites, and UNESCO World Heritage Sites (WHS). These towers are in modified habitats adjacent to human activity, with no anticipated impact on baseline conditions. Also, HT has integrated biodiversity protection into its E&S Policy, including commitments to avoid future siting of towers in AZE and WHS zones in alignment with IFC PS6 requirements. Additionally, under the previous investment, HT recruited an independent consultant to screen and assess biodiversity risks and inform the development of a biodiversity action plan (BAP). Going forward, HT will map biodiversity-sensitive locations as required by IFC PS6, develop and implement a Biodiversity Management Plan which operationalizes the mitigation hierarchy and where residual impacts persist, develop a proportionate or fit for purpose BAP (ESAP #4).
