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 (ESMS). As established under previous IFC investments, AA continues to implement a group wide ESMS appropriate to the scale, geographic footprint, and E&S risk profile of a multi country telecommunications platform operating under an asset light model. The ESMS is operationalized through group-level policies and standards, OpCo-level reviews and action plans, standardized E&S and Occupational Health and Safety (OHS) KPI frameworks, and contractual cascading of requirements to third parties. Implementation is evidenced across Kenya and DRC through ESMS reviews, KPI reporting, and site inspections, supported by recent IFC supervision activities confirming consistent identification of non-conformances, corrective actions, and monitoring at OpCo and contractor levels. While group-level aggregation and trend analysis are still maturing, this reflects evolving management processes, and IFC will follow up through routine supervision.
Policy. AA maintains an overarching environmental, social, health and safety (SHE) policy framework that defines objectives, responsibilities, and accountability across the group and is contractually extended to third parties, in line with PS1 requirements. Policy commitments are reinforced through detailed vendor, TowerCo, and fibre contractor requirements (including SHE standards), which mandate compliance with applicable laws, permit to work systems, life saving rules, incident reporting timelines, and audit rights. This approach is consistent with that disclosed under previous AA disclosures and continues to underpin contractor E&S performance across the platform.
Identification of Risks and Impacts. E&S risk identification is undertaken through a layered process combining regulatory approvals where applicable, contractor risk assessments and method statements, routine and ad hoc site inspections, OpCo ESMS reviews, and IFC supervision missions. The reviewed documentation confirms consistent identification of non conformances and corrective actions and management of the principal E&S risks typical of telecom operations, including occupational health and safety (working at height, electrical safety, lifting operations), road safety, fuel handling and spills, waste management, public safety, and Radio Frequency and Electromagnetic Fields (RF/EMF) exposure.
The E&S risks associated with the proposed Upsizing II are materially consistent with those identified under previous investments. Risks are predominantly site specific, predictable, and manageable through established controls and contractor requirements, and supervision evidence confirms that these risks are actively monitored. Biodiversity risks associated with AA’s operations are limited, site-specific, and primarily arise at the point of new site selection, particularly for greenfield infrastructure. These risks are managed through ESMS-integrated screening procedures that include biodiversity considerations to avoid sensitive habitats and ensure alignment with GIIP. As such, biodiversity risk remains low, non-systemic, and proportionate to the asset-light, small-footprint nature of telecom operations, and will continue to be monitored through routine IFC supervision.
E&S Management Programs. AA’s E&S management programs comprise OpCo level ESMS review action plans, contractor contractual requirements, and site level corrective actions, collectively aligned with PS1 requirements. OpCo ESMS reviews define findings, corrective measures, responsible parties, and timelines, demonstrating a structured approach to mitigation and continuous improvement. Inspection and supervision records show that hazards are generally addressed through avoidance and minimization measures, with responsibilities and closure timelines defined and tracked.
Organizational Capacity and Competency. Clear E&S roles, responsibilities, and authorities are assigned at both group and OpCo levels. Group level sustainability, supply chain, network and human resource functions provide oversight and guidance, while OpCo management remains accountable for implementation. Capacity is supported through structured training programs, operational health and safety committees, and competence requirements embedded in contractor manuals and fibre SOPs, including supervision requirements and stop work authority. Quantitative tracking of OHS indicators at OpCo level further supports accountability and effective implementation.
Emergency Preparedness and Response. Emergency preparedness and response arrangements are established at site and contractor levels, including documented emergency procedures, drills, first aid and fire fighting provisions, and coordination with local emergency responders for higher risk facilities where relevant. These arrangements are evidenced in inspection records and contractor operating procedures and are consistent with PS1 principles and the WBG EHS Guidelines for Telecommunications.
Monitoring and Reporting. AA has established monitoring and review mechanisms through standardized KPI reporting for employees and contractors, OpCo ESMS reviews with action plans, and routine inspections and audits. These systems provide a sound basis for identifying trends and verifying corrective action implementation across operations and contractors.
PS2 – Labor and Working Conditions
AA operates as a multi-country telecommunications platform with a relatively lean direct workforce and significant reliance on contractor and subcontractor labor for network rollout, maintenance, and site operations. Consistent with previous IFC transactions, labor and working conditions are managed through centrally governed group-level human resources (HR) policies, cascaded to subsidiaries and supplemented by OpCo-level procedures and contractual requirements imposed on TowerCos, FibreCos, OEMs, and other vendors.
Working conditions. HR functions are centrally managed, with group policies adapted at OpCo level to reflect host-country legal requirements, mandating compliance with applicable national labor laws with regard to minimum standards on recruitment, working hours, training, medical fitness, incident reporting, and workplace conduct among others, in line with PS2 principles. For direct employees, employment contracts incorporate these policies and set out terms and conditions of employment, including wages, benefits, leave, and workplace conduct, which are communicated through induction and ongoing training. For contractor and subcontractor workers, working conditions are primarily governed through contractual E&S and OHS requirements, induction processes, and supervision mechanisms, consistent with the contractor-management approach applied under previous AA transactions. In both Kenya and the DRC, supervision findings confirm that these requirements are operationalized through contractor inductions, site supervision, and routine inspections, including verification of fitness-to-work, use of personal protective equipment, and adherence to safe working procedures. Documentation and KPI submissions provide comparable evidence of ongoing implementation across both markets.
Workers’ Organizations. AA operates within national legal frameworks that recognize freedom of association and collective bargaining. Based on reviewed documentation and supervision findings, there is no evidence of restrictions on workers’ rights to form or join workers’ organizations or of anti-union practices. Labor relations are primarily governed through national regulatory frameworks and the group’s HR policies, which are considered adequate for the nature and scale of the Project.
Non Discrimination and Equal Opportunity. Group-level HR policies and codes of conduct include provisions on non-discrimination, equal opportunity, and a harassment-free workplace, and are supported by contractor requirements addressing workplace behavior and fitness-for-work criteria. Supervision records and inspection findings reviewed do not indicate discrimination-related grievances or systemic issues. These arrangements are considered broadly aligned with PS2 principles and commensurate with the project’s risk profile.
AA’s Anti Harassment policy and Code of Conduct address gender-based violence, harassment and sexual exploitation and abuse (GBVH/SEA), and are supported by training and grievance mechanisms for direct workers. Supervision confirms that these systems are operational, with no reported incidents in recent periods. Implementation of GBVH and SEA measures is being progressively strengthened, particularly across contractor interfaces and reporting processes. These efforts build on established policies and remain consistent with the evolving maturity of the ESMS.
Retrenchment. No retrenchment, restructuring, or large scale workforce downsizing is planned or anticipated under the Project. In the event of any future workforce adjustments, AA is expected to apply its established HR policies and national legal requirements consistent with PS2.
Grievance Mechanisms. AA maintains grievance and reporting mechanisms applicable to both direct employees and contractor workers, including internal grievance channels, anonymous reporting options, and an independent third-party whistleblowing mechanism covering labor, OHS, and code-of-conduct concerns. Contractor agreements establish clear requirements for grievance and incident reporting, with defined escalation pathways to both OpCo and group management. Supervision findings confirm that these mechanisms are functioning effectively; however, the comprehensive consolidation and trend analysis of grievances—especially concerning contractor workforces—continues to evolve as part of the ongoing implementation of the ESMS. Grievance handling and related monitoring processes are being strengthened across the project markets, with ongoing efforts to improve oversight and follow through, commensurate with the scale and contractor dependent nature of operations.
Occupational Health and Safety (OHS). OHS is a central element of AA’s ESMS and remains a key focus of IFC supervision. The group has established a comprehensive OHS framework, including OHS manuals, tower and fibre installation standard operating procedures (SOPs), life-saving rules, site inspection protocols, KPI-based monitoring tools, and incident reporting procedures, covering hazard identification, risk assessment, training and certification, inspections, emergency preparedness, and corrective action management. These arrangements are aligned with PS2 requirements for providing a safe and healthy working environment. Supervision findings confirm that OHS requirements are actively implemented and monitored at both OpCo and contractor levels, supported by measurable performance indicators and routine inspections. In both Kenya and the DRC, site-level supervision and contractor oversight demonstrate consistent application of safety requirements, including safe-work procedures, road safety controls, and incident management practices. OHS performance data consolidation and closure verification are advancing as part of a broader strengthening of management processes. These enhancements build on established controls and reflect a proportionate approach to continuous improvement in a contractor intensive operating context.
PS3 – Resource Efficiency and Pollution Prevention
AA’s approach to PS3 has remained largely proportionate to its asset-light telecommunications platform, where the principal resource demands relate to energy consumption for network operations and backup power, and to a lesser extent water and consumables at offices, data centers, and technical sites. Resource efficiency measures are embedded within the ESMS and contractor control framework and focus on technically and financially feasible, cost-effective improvements, consistent with PS3 principles.
Resource Efficiency and Energy Use. Resource efficiency is primarily managed through operational controls and contractor requirements aimed at optimizing energy use, including minimizing generator run-time and improving energy management at sites with unreliable grid supply. These measures are implemented through site-level procedures, contractor practices, and routine inspections. In Kenya and the DRC, supervision findings confirm that energy management practices are operationalized through monitoring of generator use, application of efficiency controls, and contractor compliance with fuel handling and maintenance procedures, consistent with established ESMS requirements. Environmental monitoring and reporting practices are being refined, particularly for contractor led activities and key resource streams, building on existing controls and aligned with the Project’s operational footprint.
Greenhouse Gas (GHG) Emissions. GHG management is addressed through measurement and disclosure of Scope 1 and 2 emissions, primarily driven by electricity consumption and diesel use for backup power, alongside a transition pathway focused on reducing diesel reliance and improving energy efficiency. For its Financial Year 2024/25, AA reported emissions on a regional basis, with East Africa accounting for 34,869 tCO2 eq and francophone Africa for 67,436 tCO2 eq, within which Kenya and the DRC are included. Residual risks relate to continued reliance on diesel in areas with unreliable grid supply, which are moderate, localized, and operational in nature. Continued efforts to strengthen emissions tracking and energy management practices support improved visibility over key drivers and align with the group’s broader decarbonization trajectory.
Pollution Prevention. Pollution prevention measures are embedded within the ESMS and contractor control framework, and operationalized through ESMS procedures, contractor requirements, and site-level controls focusing on air emissions from generators and vehicles, noise management, spill prevention, and general housekeeping. Primary pollution sources are limited to backup power systems, fleet operations, and associated fuel handling activities. Controls include emission management for generators, noise attenuation measures, spill prevention and containment systems, and minimization of reliance on backup power. Supervision and inspection records indicate that these controls are implemented consistently across sites and contractors and are aligned with PS3 principles and the WBG EHS Guidelines for Telecommunications.
Electromagnetic Fields (EMF) management is addressed as a defined environmental and health topic, with compliance aligned to the International Commission on Non-Ionizing Radiation Protection (ICNIRP) exposure limits and applicable national requirements. Operational controls include equipment standards, siting practices, and worker training, supported by periodic verification where required. Across OpCos, AA is strengthening the systematic recording of EMF compliance evidence, including the development of registers and consolidated tracking mechanisms. These improvements build on existing controls and reflect ongoing enhancement of monitoring systems.
Waste and hazardous materials management is implemented through ESMS procedures and contractor controls that prioritize the waste hierarchy (avoidance, reduction, reuse, recycling, and safe disposal). Key waste streams include electronic waste (e.g., batteries and circuit boards), used oils, and general site waste, which are managed through licensed service providers with appropriate tracking and disposal arrangements.
Hazardous materials management focuses on diesel storage and handling, lubricants, and battery systems, with controls such as secondary containment, spill prevention, and safe handling procedures embedded in contractor requirements and site practices. These measures are consistent with PS3 and GIIP for telecommunications operations.
PS4 – Community Health, Safety, and Security
Community health and safety risks associated with AA’s operations remain limited, site-specific, and primarily linked to contractor-led activities, including road traffic incidents, construction and maintenance works (e.g., towers and fibre), and life and fire safety (LFS) risks at directly operated facilities. These risks are managed through the ESMS framework and enhanced EHS requirements applicable to both staff and contractors, including safe driving procedures, LFS controls, and emergency response measures, aligned with host-country regulations and GIIP.
In both Kenya and the DRC, supervision findings confirm that these controls are operationalized through contractor oversight, routine site inspections, and enforcement of safe-work procedures, including road safety measures, public safety controls at work sites, and emergency preparedness arrangements. These practices are consistent with the approach established under previous AA transactions and are considered proportionate to the Project’s risk profile.
EMF related community exposure risks are managed through the corporate EMF framework described under PS3, including compliance with ICNIRP guidelines, controlled access to antenna locations, and contractor requirements implemented through site level supervision. These controls are considered adequate to manage potential risks to the public.
Security Personnel. Security risks are managed through risk-based assessments that determine appropriate security arrangements for different operating contexts. AA engages qualified security providers where required and conducts due diligence to ensure alignment with good international practice, the group’s code of conduct, and human rights policies. These arrangements are considered adequate to manage security-related risks, including those associated with the use of private security personnel.
Residual PS4 risks are limited in scale and duration and are considered manageable through existing controls. IFC will continue to monitor implementation through routine supervision, focusing on contractor oversight, road safety performance, EMF compliance tracking, and consistency of site-level controls across markets, without the need for additional ESAP measures.
PS5: Land Acquisition and Involuntary Resettlement
Land acquisition is expected to be limited and associated with incremental network expansion, including fiber deployment, installation of equipment on existing infrastructure and, in some cases, new sites developed by third party tower providers. While the asset light model reduces direct exposure, potential economic displacement and limited physical displacement risks may arise in connection with greenfield sites. As part of previous IFC investments, the company has established procedures within its ESMS to screen and manage land related risks in line with IFC PS5, including identification of affected persons, application of cut off dates, compensation at replacement cost, and livelihood restoration where applicable. Given the dispersed and often remote nature of sites and reliance on third party providers, such impacts may not always be systematically identified or reported in practice; however, the applicable procedures are in place within the ESMS to address these risks where they arise.
The ESMS requires third party providers to comply with applicable PSs, including stakeholder engagement, information disclosure, grievance mechanisms, and provision of compensation and assistance prior to displacement, with monitoring of outcomes where relevant. Based on IFC’s due diligence, PS5 risks are expected to be limited and manageable, and the project is expected to be implemented in a manner consistent with IFC PS5.
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