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 and Policies. WIOCC has developed Group level E&S and OHS policies for its operations. These policies include commitments to build and operate its assets in a manner that protects the environment, prevents pollution and promotes continuous improvement. They also emphasize the provision of necessary resources, the establishment of clear objectives, and fostering a positive safety culture and behavior within the organization. Additionally, WIOCC Group has developed and is implementing an ESMS aligned with IFC PS1. The ESMS details WIOCC Group’s entire approach to managing E&S risks and impacts within its operations and is outlined in a Manual updated in 2025. This ESMS Manual includes the Group’s ESG Roadmap and governance structure and clearly spells out roles, responsibilities, and procedures for managing E&S risks across the organization. Under the 2025 IFC financing, WIOCC strengthened its ESMS by introducing implementation arrangements to support risk-based management, capacity building, monitoring, and continual improvement across its operations and subsidiaries. As this requirement remains relevant to the Group's ongoing expansion, WIOCC will continue to extend and operationalize its ESMS across newly acquired and developed facilities through the implementation of its Management of Change procedure, ensuring consistent identification, assessment, and management of E&S risks and impacts in accordance with IFC PS1.
Identification of E&S risks and impacts: WIOCC Group applies a risk-based process for identifying and assessing E&S risks and impacts that is aligned with good international industry practice. Depending on the nature, scale and location of activities, the Group undertakes E&S due diligence, E&S risk assessments, climate risk assessments and regulatory compliance reviews. Also, WIOCC's E&S Screening and Risk Categorization Tool requires ESIAs and E&S risk assessments to consider the project's Area of Influence proportionate to the nature, scale and risk profile of the activity. For new or undefined assets and business lines, WIOCC screens every new activity at the concept and planning stage using its E&S Screening and Risk Categorization Tool, assigning a low, moderate or high-risk rating based on location, nature, scale and potential impacts. The Management of Change procedure ensures that new projects, acquisitions or changes in scope are re-screened before they proceed, with findings built into planning, mitigation and monitoring.
Under the 2025 IFC financing, WIOCC committed to undertake a Strategic Environmental and Social Assessment (SESA) for its FTTx program and to conduct proportionate E&S due diligence of material third-party metro infrastructure partners. As these actions remain outstanding and are necessary to assess and manage the program's E&S risks and impacts, WIOCC will complete the SESA and partner ESDD, and implement associated mitigation measures, including centralized risk register and SOPs for significant operational activities, as per the approved Terms of Reference and IFC Performance Standard (ESAP #1).
Also as an outstanding action, WIOCC Group will update the Climate Risk and Vulnerability Assessment and based on the recommendations of the baseline study to include; (i) climate modelling (including scenario analysis) for current and future risk projections; (ii) develop a climate resilience roadmap with phased implementation; (iii) risk assessments in line with climate data trends; and (iv) where applicable, demonstrate how climate risk assessment has influenced design (ESAP #2).
E&S Management Programs. WIOCC Group’s ESMS is backed by core plans, sub-plans and procedures including; (i) Contractor HSE Specifications; (ii) Water Resources Management Plan; (iii) Group Waste, Wastewater, and Hazardous Materials Management Guidelines; (iv) Group EMS Water Strategy (v) Climate Risk Management Plan; (vi) Emergency Preparedness and Response Plan (EPRP); (vii) Stakeholder Engagement Plan (SEP); (viii) Health and Safety (H&S) Plan; (ix) Group Corporate Security Management Protocol (SMP); (x) Transportation Management Plan (TMP); (xi) Grievance Mechanism; (xii) Chance Finds Procedure (CFP); (xiii) Gender Risk Management Plan; (xiv) Supply Chain Management Procedure (xv) Group Biodiversity Guidelines. Furthermore, findings from ESIAs and risk assessments feed into these programs whose implementation is monitored through internal audits. Furthermore, WIOCC Group operationalize a Know Your Supplier (KYS) process which assesses ESG criteria such as compliance with local and international environmental regulations, availability of Health, Safety and Environment (HSE) policies, employee safety awareness and training, relevant environmental or occupational health and safety certifications, disaster recovery and emergency response planning, workplace accident prevention measures, and greenhouse gas emissions reporting where applicable.
Under the 2025 IFC financing, WIOCC committed to strengthen its ESMS through the development of a Contractor ESMP (CESMP) template for contractors engaged in data center and connectivity-related construction activities. As this action remains relevant, WIOCC Group will prepare or mandate its FTTx Contractors to prepare a CESMP that incorporate SOPs to address risks identified in the centralized risk register (ref. ESAP #1) associated with their operations including: (i) Open-Cut Trenching and Reinstatement; (ii) Micro-Trenching and Horizontal Directional Drilling (HDD) operations; (iii) Aerial Cable Installation; (iv) Utility Strike and Damage Prevention; (v) Community Access and Livelihood Protection; (vi) Open Access Metro Service delivery including non-discriminatory wholesale access procedures, service level agreement (SLA) enforcement, network maintenance scheduling, planned outage notification to downstream operators (ESAP #3).
Organizational Capacity/Competency. WIOCC has established organizational capacity and competency to implement its ESMS, including a dedicated ESG function responsible for environmental and social risk management, sustainability strategy, and oversight of ESMS implementation across the Group. The function is supported by a Group E&S Manager, Group HSE Manager, site-level HSE personnel, and external specialists where required. A Group HSE Committee provides oversight of HSE performance, incident reporting, and continuous improvement across operating companies.
Under the 2025 IFC financing, WIOCC strengthened its environmental and social management capacity through the recruitment of a Senior E&S Advisor to support consistent ESMS implementation across operating companies and the rollout of mandatory E&S training, including Human Rights and GBV/SEAH awareness. As part of this financing, WIOCC will periodically assess the adequacy of E&S and HSE resources and strengthen capacity, as required, to support the expansion of the FTTx business. Also, WIOCC will continue to require principal contractors to maintain appropriately qualified HSE personnel commensurate with the environmental and social risks and impacts of their activities, consistent with the requirements of IFC PS1.
Emergency Preparedness and Response. WIOCC maintains a Group-wide Emergency Preparedness and Response Plan covering fire, medical, environmental, electrical, and flooding incidents. The plan defines response responsibilities, communication and evacuation procedures, training requirements, and measures to protect workers, communities, assets, and the environment. Emergency drills are conducted regularly across facilities, and incidents are reported, investigated, and managed through the HSE management system. Data centers are equipped with appropriate fire detection, suppression, and life-safety systems, including automated thermal runaway protection and gas-based fire suppression technologies.
As part this financing, WIOCC will strengthen emergency preparedness and response arrangements by establishing mutual-aid protocols and on best-effort basis, conducting coordinated emergency response exercises with landlords, co-tenants, and public emergency services at co-located data center facilities in South Africa, consistent with the requirements of IFC PS1.
Monitoring and Reporting. WIOCC Group’s E&S monitoring and review approach is set out in the ESMS Manual and Monitoring and Measurement Procedure. Operationally, E&S performance is monitored through site inspections, audits, incident and grievance tracking, management reviews, and annual lender reporting, supported by external consultant audits. ESHS performance monitoring is conducted through a SHEQ digital platform for OHS metrics, supplemented by manual tracking of sustainability data (energy, water, GHG) at the site level. Finally, the E&S team aggregates the leading and lagging indicators tracked through the digital platform and generate dashboards for reporting up to senior management. As part of the ESMS continuous improvement, WIOCC Group will incorporate controlled KPI protocol covering Power Usage Effectiveness (PUE), Water Usage Effectiveness (WUE) and Carbon Usage Effectiveness (CUE) across the portfolio on its digital platform.
Performance Standard 2: Labor and Working Conditions.
WIOCC Group currently has a total workforce of 520 of which 145 were recruited in the last two years. The workforce is comprised of 72 % male and 28 % female. The Group rely on Contractors for the data centers expansion and the FTTx rollout. WIOCC Group’s operations are engineering-centric and highly specialized, and large shifts in gender representation remain constrained by the available talent pool in the different markets.
Human Resources Policies and Procedures, Working Conditions, and Terms of Employment. WIOCC has developed and is implementing an HR procedure that comply with national labor laws and are aligned with IFC PS2 requirements. WIOCC Group manages direct employment terms through standardized employment contracts that outline job descriptions, remuneration, probationary periods, working hours, leave entitlements, travel allowances, confidentiality, data protection, and dispute resolution procedures. Also, direct employees receive statutory benefits aligned with local labor legislation, including paid annual leave per national law, shift premiums, and enrolment in social security schemes. Furthermore, direct staff and key technical contractors experience structured working arrangements, competitive pay, and opportunities for career development.
Workers’ Organization. WIOCC Group’s corporate framework respects the rights of workers to form and join workers' organizations of their own choosing, as well as to bargain collectively without interference or fear of retaliation, meeting the core objectives of IFC PS2. Across the portfolio, there are currently no active trade unions or collective bargaining agreements in place, but staff and contractor interviews consistently confirmed that management displays no anti-union animus or restrictive measures.
Non-discrimination and equal opportunity: WIOCC Group promotes non-discrimination and equal opportunity across its human resources policies, aligning with IFC PS2. The company enforces explicit prohibitions against workplace discrimination and harassment through its Code of Conduct, Disciplinary Policy, and Whistleblowing system. WIOCC Group rolled out mandatory online training on Human Rights, Gender-Based Violence and Sexual Harassment (GBVSH), and De-escalation via its learning management system for both security and non-security personnel. Furthermore, WIOCC Group implements an active culture of upward mobility and non-discrimination, where junior level workers have successfully transitioned into senior technical and senior leadership positions on merit bases.
Retrenchment: WIOCC Group HR procedures lay out its approach to retrenchment. However, WIOCC Group’s operational history reflects workforce expansion as the company has never undertaken workforce retrenchment or collective dismissals and has no plans for retrenchment in connection with the proposed financing facility. WIOCC Group prioritized workforce retention, employment stability, and seamless transition without staff layoffs during the recent acquisition of existing data centers in South Africa.
Grievance Mechanism. WIOCC Group has an established Employee Grievance Procedure generally aligned with IFC PS2 requirements. Employees are made aware of the grievance mechanism during induction training. Direct employees have access to formal internal grievance channels designed to raise workplace concerns without fear of reprisal, meeting the core principles of IFC PS2. As part of the 2025 investment, WIOCC Group updated its corporate grievance mechanism in August 2026 to explicitly accommodate anonymous reporting and third-party contractor’s submissions. Under this investment, WIOCC will install multi-lingual physical notices detailing internal, third-party, and anonymous grievance reporting channels in all employee and contractor common areas across all facilities and operationalize a centralized, confidential grievance log within its digital platform to record, investigate, and resolve all direct and contractor grievances, ensuring transparent documentation for internal governance and reporting.
Occupational Health and Safety. WIOCC Group has established an Occupational Health and Safety (OHS) Management System and has assigned health and safety experts. WIOCC Group manages OHS primarily through its digital platform, which tracks safety KPIs, incidents, contractor onboarding, and site compliance, aligning with IFC PS2. As part of the ongoing ESMS maturation, WIOCC will formalize a standalone Group PPE Policy and execute its ISO 45001 implementation roadmap expanding it to newly acquired data centers.
Workers Engaged by Third Parties. WIOCC Group relies on a network of active Contractors and service providers to complete operation and maintenance activities. WIOCC manages third party workforce risks and labor risks within its supply chain through its KYS screening process and mandatory Supplier Code of Conduct, addressing the objectives of IFC PS2. Under the 2025 IFC financing, WIOCC completed a targeted labor conditions audit of key suppliers and contractors. To support implementation of the audit findings, WIOCC Group will contractually require Contractors and suppliers to implement corrective actions resulting from the 2025 third party workers labor conditions audit including: (i) contractually requiring contractors to standardize core wage and benefit structures for workers performing equivalent tasks as well as directly engage contractor management to align leave policies with the statutory minimum; (ii) establishing a SOP for managing casual workers associated to the FTTx construction activities; (iii) finalize, approve, and deploy the Supplier Risk Tool across all operating entities to enforce systematic contractor pre-qualification and monitoring and (iv) establishing site-specific GBVSH risk management protocols and field codes of conduct for civil works contractors associated with the FTTx activities (ESAP#4).
PS3: Resource Efficiency and Pollution Prevention.
Resource Efficiency. WIOCC Group demonstrates a structural commitment to resource efficiency by optimizing energy consumption and managing water intensity across their data center portfolio. Power Usage Effectiveness (PUE) is tracked as the primary metric for energy efficiency, with the overall portfolio average improving from approximately 2.0 to 1.6 close to the 1.5 industry benchmark. The Company improved PUE through infrastructure modernizations, installation of high-efficiency LED lighting with occupancy sensors and the integration of near-unity power factor UPS units. WIOCC Group is reviewing alignment with ISO 50001 (Energy Management) to formalize its group-wide energy efficiency practices.
Greenhouse Gas (GHG) Emissions. WIOCC’s greenhouse gas (GHG) emissions profile is driven primarily by Scope 2 indirect emissions from electricity consumption from national grids and Scope 1 direct emissions from diesel backup generators during power outages. WIOCC Group has successfully established a formalized greenhouse gas (GHG) accounting methodology. The methodology is governed by the Carbon Accounting Basis of Preparation (dated 22 April 2026), covering Scope 1, Scope 2, and selected Scope 3 emissions under an operational-control boundary. WIOCC reported a total corporate greenhouse gas footprint of 87,891 tCO2e, comprising 2,357 tCO2e of Scope 1 emissions from direct fuel consumption and refrigerants, 4,927 tCO2e of Scope 2 emissions from purchased electricity, and 80,607 tCO2e of Scope 3 emissions associated with value-chain activities.
Water and Wastewater. Water consumption across WIOCC Groups data centres portfolio is maintained at low intensity, averaging approximately 200,000 liters per month across the South African footprint with one data centre employing a closed-loop adiabatic cooling technology while the rest employ air / gas cooling. WIOCC’s activities do not generate processed wastewater as non-contact cooling water is recirculated. Sewage from offices, canteen and hygienic facilities is discharged to septic tanks and or directly to the municipal sewer system.
Pollution Prevention. WIOCC manages air emissions and noise pollution primarily associated with backup diesel generators deployed to maintain power availability during grid failures. Generators are housed within acoustic attenuation enclosures, fitted with exhaust silencers, and maintained according to manufacturer specifications to comply with ambient noise standards and WBG General EHS Guidelines. Real-time noise near-miss tracking is integrated into the Company’s SHEQ digital platform and fuel systems feature continuous diesel filtration and mechanical fire-triggered fuel shut-offs.
Waste Management. WIOCC manages non-hazardous and hazardous waste streams through contracted service providers in accordance with local regulations and waste management plans. Electronic waste (e-waste) comprising decommissioned server hardware, hard drives, printed circuit boards, and copper cabling is disposed of through specialized third-party contractors who provide certificates of destruction, Backup power lead-acid batteries are replaced on a 3-to-4-year cycle and returned to accredited battery recyclers.
Hazardous Materials Management. Hazardous materials present across WIOCC data centers consist primarily of diesel fuel for backup power, refrigerants contained in cooling equipment, and clean-agent gaseous fire suppression systems. Fuel spill and fire hazards during transport, delivery, and storage are mitigated using secondary containment (bunding), dedicated fuel transfer bays, mechanical fire-triggered shut-off valves, and absorbent spill kits.
Performance Standard 4: Community Health and Safety.
Community Safety. WIOCC Group assess community health and safety risks as an integral part of their group-wide E&S risk identification process. Core operations consist of indoor, high-security data centers located within established commercial and industrial zones in South Africa, DRC and Nigeria, where structural perimeter controls minimize routine community exposure. Facilities incorporate universal accessibility design features, including level thresholds, smooth ramps, wide elevators, and automatic doors to accommodate persons with disabilities. Public interface risks associated to WIOCC Group operations primarily arise from linear civil works associated with the FTTx network expansion as related civil works involve street trenching, duct laying, and traffic interface, representing the highest potential risk area in the group portfolio for public safety and Gender-Based Violence and Sexual Harassment (GBV/SH). Equipment transport and road safety risks are managed through contractor requirements, with no major traffic accidents involving the public reported across operations. As part of this IFC investment, WIOCC Group will embed mandatory community safety control standards into civil works contracts in accordance with the SESA (ref. ESAP 1) and require civil works contractors to implement SOPs (ref. ESAP #3) and physical hazard barriers, localized traffic management plans, and pedestrian safety controls, backed by periodic E&S spot-audits during urban network installation.
Infrastructure and Equipment Design and Safety. WIOCC Group’s data center facilities are engineered, constructed, and operated in accordance with international technical standards, local building codes, and life and fire safety regulations. Physical infrastructure incorporates Tier III availability design principles, redundant utility feeds, and automated safety systems. Building safety certifications are maintained directly by WIOCC Group for owned properties and by facility landlords for leased premises. WIOCC Group will commission independent Life and Fire Safety audits across all newly acquired data centers, securing formal L&FS compliance certificates as part of its ESMS (and management of change implementation.
Security Personnel. Physical security at data centers is provided by contracted security firms assuring 24/7 access control, perimeter guarding, and surveillance. In Nigeria, WIOCC Group is commencing the use of government security forces, specifically the public mobile police, for specific project sites based on formal Security Risk Assessments (SRAs) finalized as part of the 2025 investment. Security personnel undergo mandatory training on human rights, Voluntary Principles on Security and Human Rights (VPSHR), Gender-Based Violence and Sexual Harassment (GBVSH), and de-escalation techniques, which was rolled out in July 2026 with attendance records and knowledge assessments logged. Security contracts restrict the use of force to defensive and preventive purposes only. Under this investment, WIOCC will include incident reporting protocol for public security forces and ensure full adherence to the Voluntary Principles on Security and Human Rights (VPSHR) and IFC PS4 requirements.
