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
As agreed with IFC under the previous transactions, ATK has established and operationalized an Environmental and Social Management System (ESMS) to address E&S risks associated with its operations in line with the principles of IFC PSs and Good International Industry Practice (GIIP) which is largely appropriate for a multi-site telecommunications platform with rolling and partially undefined assets. The ESMS has been expanded to support portfolio growth and includes an overarching E&S policy, risk identification and screening procedures, contractor management requirements (including Owner’s E&S Standards), emergency preparedness arrangements, monitoring and reporting mechanisms, and grievance handling processes. Senior management provides oversight for the ESMS via a formal E&S Committee, which evaluates performance, monitors action items, and ensures compliance with IFC PSs.
The ESMS includes a risk register that identifies and addresses E&S risks, including health and safety hazards, environmental impacts, and gender-differentiated risks. Key E&S risks associated with the new project are largely similar to those of the existing project.
In accordance with the Site Screening Procedure, each proposed tower location is subject to E&S screening prior to construction, and development does not proceed until all required regulatory permits and internal approvals are secured. Site level risks are identified through the screening process, regulatory permitting, preparation of ESIAs or Project Reports where applicable, and routine inspections. The screening emphasizes key risks related to land tenure and access, statutory compliance, occupational health and safety, community interactions, and biodiversity sensitivity. As part of this screening, the company excludes sites where land tenure or access is contested, including locations with known or suspected squatter presence, adverse possession claims, unresolved disputes, or circumstances that would require the use of eminent domain or result in physical or economic displacement. Greenfield sites are acquired through a defined site acquisition process, which is based on long terms lease or willing buyer/willing seller agreements, and then are subject to an Environmental & Social Impact Assessment (ESIA) where required. Only sites assessed as having clear, uncontested access and no displacement risk proceed to permitting and construction. Where screening identifies potential ‘PS5’ risks that cannot be avoided—such as restrictions on land use or impacts on informal users—these sites are not advanced unless risks can be demonstrably avoided through site redesign or alternative siting. Where the company acquires brownfield tower sites, they are subject to an E&S due diligence (ESDD) covering areas relating to land rights and tenure, environmental impacts, biodiversity sensitivity, design specifications, security, resource efficiency, waste management, and accessibility among others. The subsequent section on PS6 examines the methodology for assessing and managing potential risks related to biodiversity.
As agreed under the previous IFC investment, compliance with permit conditions, incident reporting, contractor approvals, and corrective actions are tracked through the Smartsheet platform, enabling centralized portfolio level oversight. Where screening identifies . ATK has developed E&S procedures and management controls to support the implementation of its E&S policies, including corporate EHS and occupational health and safety (OHS) management programs; contractor inductions, audits, supervision, and systematic tracking of corrective actions, life and fire safety (LFS) requirements, waste management, biodiversity screening and management measures; stakeholder engagement and grievance handling processes embedded within the ESMS. Furthermore, there is a formal Contractor Management Plan that governs contractor selection, training, supervision, and EHS performance monitoring as defined in its ‘Owners E&S standards’ document, largely in line with IFC PSs requirements for contractor and primary supplier management.
ATK manages emergency preparedness and response through its ESMS, with site level measures primarily focused on construction and operational OHS risks. Existing arrangements include job safety analyses that consider prevailing weather conditions, provision of drinking water and shaded rest periods during high temperature conditions, and procedures to modify work schedules in response to heat stress risks. It also includes adequate measures to address climate specific emergencies related to extreme rainfall, flooding, and other severe weather potential events across the portfolio.
The E&S organizational structure and management arrangements are largely appropriate for the scale, geographic footprint, and risk profile of its tower-based operations. E&S oversight is embedded within the senior country management structure, with defined responsibility assigned to the EHS Manager, who reports to the Country Manager and is supported by technical, legal, and operations staff. The EHS Manager is responsible for the day-to-day implementation of the ESMS, which defines internal roles, reporting lines, and management review processes, and is supplemented by external consultants for specialized assessments such as ESIAs and biodiversity screening. Given ATK’s contractor driven operating model, E&S risk management is primarily implemented through formal contractor management arrangements, with permit compliance, incidents, and corrective actions tracked centrally, enabling effective portfolio level oversight.
E&S monitoring and reporting defined in the ESMS are generally appropriate for managing a geographically dispersed tower portfolio. Site level monitoring is undertaken through regulatory permitting, preparation of ESIAs or Project Reports where required, contractor supervision, and routine inspections, with key E&S data—including permit status, incidents and near misses, corrective actions, and contractor compliance—consolidated centrally using a digital platform (Smartsheet) to enable portfolio-level visibility. In line with existing agreements, ATK reports E&S performance to IFC through Annual Monitoring Reports (AMRs), which track ESMS implementation, incident statistics, and progress against the covenanted ESAP and are complemented by periodic IFC supervision and site visits. Incident reporting is also ATK’s obligation as part of agreement with IFC. While these systems support effective data collection, portfolio level analysis of trends and outcomes remains limited; accordingly, ATK will strengthen its monitoring framework by introducing standardized indicators and periodic trend analysis (e.g., E&S incidents, grievances, repeat noncompliance, biodiversity monitoring) to better demonstrate the effectiveness of E&S controls. Worker and community grievance tracking will be strengthened and monitored through the respective grievance redress mechanisms (ESAP #1).
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PS2 – Labor and Working Conditions
ATK maintains a lean direct workforce and relies extensively on contractors and managed service providers (MSPs) for construction, operations and maintenance, security, and specialized technical works. Labor and working conditions are therefore primarily managed through the ESMS.
Labor risks under the new transaction remain typical of the telecommunications sector but increase in complexity due to the scaleup of activities and continued reliance on contractors across multiple regions. Key risks relate to OHS, contractor management as further detailed below.
As required under the previous IFC agreement, ATK developed a comprehensive set of Human Resources policies aligned with PS2 and has adopted and operationalized Gender Based Violence and sexual exploitation, abuse and harassment (GBV/SEAH) and Child Safeguarding Policies. These are applicable to employees, contractors, MSPs, and security personnel. Training records for 2025 confirm that GBV/SEAH, child safeguarding, and worker protection training were delivered to all MSP teams, and that security personnel received training on human rights, use of force, and GBV/SEAH prevention. Additional safeguards applied at sensitive locations include advance notification to school management prior to maintenance activities and implementation of physical controls such as barricading and signage during work. These measures align with PS2 requirements on worker conduct, protection of vulnerable groups, and prevention of abuse and exploitation.
Labor standards are cascaded through contractual obligations, joint E&S awareness sessions, and pre-job inductions with contractors and partners, reinforcing expectations on codes of conduct, OHS, GBV/SEAH, child safeguarding, and emergency preparedness. Also, ATK maintains internal and external grievance mechanisms accessible to employees, contractors, MSPs, and security personnel, including anonymous reporting channels. Although grievance mechanisms are formally established and communicated during inductions, historical data reflect a low number of reported labor grievances, which may suggest under-reporting rather than an absence of concerns. ATK will strengthen grievance reporting and tracking as part of its ongoing ESMS improvements, with periodic reviews conducted during IFC supervision activities.
ATK’s OHS performance has been satisfactory, with declining incident rates and no fatalities reported in recent years. In 2025, one minor first aid injury was recorded, and preventive measures were documented and implemented. ATK has demonstrated enforcement of contractor accountability, including the issuance of ‘Stop Work’ orders where noncompliance is identified. A limited number of material gaps have been identified, including uneven documentation of contractor OHS audits and corrective actions across the portfolio, low reported grievance volumes, and the need for more systematic consolidation of labor and OHS performance data to support portfolio-level oversight. These gaps do not indicate noncompliance but reflect the need to strengthen consistency and traceability as operations expand. Going forward, ATK will strengthen oversight of contractor labor management and occupational health and safety (OHS) performance by: (i) enhancing the frequency, documentation, and follow-up of contractor audits, including tracking of corrective and preventive actions; (ii) reinforcing worker awareness of grievance mechanisms, including confidential reporting channels and nonretaliation assurances; and (iii) improving ESMS based monitoring and management review of labor and OHS incidents and near misses at portfolio level. (ESAP#2).
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PS3 – Resource Efficiency and Pollution Prevention
As assessed under previous IFC investments, the risks relevant to PS3 for ATK remain limited, site specific, and manageable, reflecting the distributed nature of the tower portfolio and the scale of construction activities. Key PS3 risks relate primarily to energy consumption and associated emissions from diesel generators, construction phase resource use (including water), and the management of hazardous and nonhazardous waste streams. These risks are mitigated through standard sector controls, compliance with Kenyan regulatory requirements, and the use of licensed waste management service providers, with no material pollution incidents identified to date.
ATK has implemented a Green Power Program that prioritizes the deployment of solar photovoltaic systems, battery storage, and hybrid energy configurations. As a result, the majority of sites are solarized, and emissions intensity has declined relative to the national grid benchmark, notwithstanding continued portfolio growth.
Water consumption occurs mainly during construction activities and is modest at site level. Waste streams include construction debris, scrap metal, packaging, used oils, and spent batteries. These are managed through site level segregation, spill prevention measures, and disposal by licensed waste handlers, in compliance with Kenyan regulations. Where applicable, hazardous materials are handled under controlled procedures, with appropriate contractor oversight. These measures are largely aligned with PS3 requirements.
Climate-related physical risks are relevant to PS3 and PS4 and were assessed as medium prior to mitigation and low after mitigation. These risks include heat stress affecting workers, flooding during extreme rainfall events, and localized water stress. While tower operations use minimal water, construction activities may increase localized demand during drought conditions. Existing measures will include provision of drinking water at worksites, heat stress adjustments to PPE and work schedules, and reliance on hybrid energy systems that reduce fuel and water dependency. Under its EPRP procedures, ATK has covered measures to address extreme weather, such as suspending or adjusting activities during floods or severe weather and providing targeted worker training on climate risks.
Overall, PS3 risks under the project are considered limited, predictable, and manageable, given the small physical footprint of tower infrastructure, declining emissions intensity, and established pollution prevention controls. Continued attention to systematic monitoring of construction water use, centralized tracking of waste streams, and integration of climate related measures into emergency preparedness planning supports alignment with IFC PS3 and EHS Guidelines.
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PS4 – Community Health, Safety, and Security
Under the previous investments, ATK managed community health, safety, and security risks that were localized, predictable, and typical of a distributed telecommunications infrastructure portfolio. These included construction-related risks (including traffic safety, emergency preparedness, and electromagnetic field ‘EMF’ exposure). In addition, the presence and conduct of contractors and security personnel— poses a moderate risk of sexual exploitation and abuse under the project.
Under the new transaction, PS4 risks remain site-specific but increase in complexity as operations expand into new geographic areas with varying community and security contexts. ATK manages community health, safety, and security risks through a risk-based approach that combines controlled site access, physical security measures, and centralized remote monitoring. Tower sites are secured through perimeter fencing, access-controlled locks, and enhanced deterrents at higher-risk locations, with security arrangements scaled based on site-specific risk assessments. Remote oversight is supported through centralized monitoring systems, and where applicable, security personnel receive training on human rights and use-of-force principles. SEA risk management under PS4 is implemented through codes of conduct, training, and a confidential grievance mechanism as outlined in the PS2 section of this ESRS.
Supervision to date did not identify significant community health or security impacts under the previous investment. ATK will continue to strengthen the consistency and documentation of security risk assessments and incident monitoring in line with its ESMS. The company will also continue to apply a risk-based approach to community health, safety, and security, including screening and supervision, and monitoring of community grievances and incidents to inform corrective actions through the ESMS.
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PS6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
Under the previous IFC investment, biodiversity risks for Atlas Tower Kenya were limited and site-specific, primarily related to a small number of legacy sites located near biodiversity sensitive areas. These risks were addressed through enhanced screening, regulatory approvals, and the implementation of a Biodiversity Action Plan (BAP) for a site in proximity to the Taita Hills Alliance for Zero Extinction (AZE) site, where no significant residual impacts on the AZE species were identified.
Under the current transaction, ATK proposes to construct approximately 450 towers across Kenya, of which, the location of 115 are known – none of these sites are situated in protected areas or internationally-recognized areas. ATK operates a geographically dispersed tower portfolio across Kenya, with the majority of existing sites located in modified and human dominated landscapes. Biodiversity risks are therefore generally limited in scale and are most relevant for future, as yet undefined sites, given Kenya’s ecological diversity. To manage these risks, ATK applies a risk based and precautionary approach to biodiversity management through the use of its site screening procedure, developed as a requirement of the previous transaction and incorporated within its ESMS. All proposed sites are screened during site selection for proximity to protected areas, Key Biodiversity Areas (KBAs), Ramsar sites, AZE sites, and UNESCO World Heritage Sites using recognized tools e.g. Integrated Biodiversity Assessment Tool (IBAT) and Global Forest Watch, amongst other publicly available datasets. Critical Habitat is explicitly avoided, and ATK does not develop tower sites within AZE or World Heritage Sites. Where sites are located in or near biodiversity sensitive areas, the mitigation hierarchy is applied, supported by site-specific ESIAs or Project Reports and regulatory approvals. ATK will continue to use this screening procedure to support implementation of PS6 requirements in the context of the as-yet unknown tower locations under current pre-development and/ or planning, and in such cases where sensitive sites cannot be avoided, ATK will develop a Biodiversity Action Plan (BAP) to define actions to contribute to the conservation objectives of these areas, in consultation with relevant stakeholders, and provide regular monitoring updates, as outlined under ESAP#1.
