DRC Infraco SPRL (HTD)
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed prior to the date on which MIGA’s Board of Directors considers the proposed issuance of a Contract of Guarantee. Its purpose is to enhance the transparency of MIGA’s activities. This document should not be construed as presuming the outcome of the decision by MIGA’s Board of Directors. Board dates are estimates only.Any documentation that is attached to this ESRS has been prepared by the project sponsor, and authorization has been given for public release. MIGA has reviewed the attached documentation as provided by the applicant, and considers it of adequate quality to be released to the public, but does not endorse the content.
The project consists of the operation and upgrade, reactivation and expansion of Helios Towers DRC (“HTD”), an independent telecom tower company operating in the Democratic Republic of Congo (“DRC”). MIGA has been approached to provide guarantees to Standard Bank South Africa (“SBSA”) and other commercial lenders to be identified to support refinancing of existing debt and, the German Investment and Development Corporation (“DEG”) and the Belgian Investment Company for Developing Countries (“BIO”) for financing upgrade, reactivation and expansion of HTD’s tower portfolio in DRC.
HTD currently has a portfolio of towers predominantly located in the urban centers of Kinshasa, Bas-Congo and Katanga, with 37 in-service towers situated in the eastern Kivu provinces.. HTD provides passive infrastructure (space on towers, ground space, power, site maintenance and security) to multiple telecom operators and internet service providers under long-term lease agreements.
HTD is a subsidiary of Helios Towers Africa (“HTA”), a holding company with a current portfolio in excess of 2,600 towers, owned and managed across DRC, Ghana and Tanzania.
Environmental and Social Categorization
This project involves the development and operation of telecommunications tower sites. The key issues associated with the project are environmental, health, safety, and social management; construction of towers; labor and working conditions (including employee and contractor occupational health and safety); and pollution prevention and abatement. The environmental and social risks and impacts are limited, generally site-specific, and readily addressed through mitigation measures, therefore the project is Category B under MIGA’s Policy on Social and Environmental Sustainability.
While all Performance Standards (“PSs”) are applicable to this guarantee project, based on current information the project will have impacts which must be managed in a manner consistent with the following PSs:
- PS1: Social and Environmental Assessment and Management Systems
- PS2: Labor and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health, Safety & Security
Tower sites where significant issue would exist relating to biodiversity conservation and natural habitats will be avoided, therefore PS6 is not applicable. HTD will acquire any property for tower expansions based on negotiated lease arrangements, therefore PS5 is not applicable. No indigenous people have been identified that would be expected to be impacted by the project, therefore PS7 is not applicable. HTD would avoid developing any site where a significant issue relating to cultural heritage would need to be managed according to PS8.
The E&S review of this project consisted of review of the following project documentation:
- Helios Towers DRC Health, Safety and Environmental Management System
- Helios Towers DRC Site Acquisition Manual
- Helios Towers DRC Employee Handbook
- Helios Towers Africa Health, Safety and Environmental Management System
- Helios Towers Africa Supplier Code of Conduct
- Helios Towers Africa Diesel Fuel Leaks & Spillages, Clean-Up Procedure
- Helios Towers Africa Corporate Social Responsibility Proposals
- Helios Towers Africa Annual Environmental and Social Monitoring Report (2012)
- Helios Towers Africa Annual Environmental and Social Monitoring Report (2011)
PS1: Social and Environmental Assessment and Management Systems
HTD has prepared and implemented a Site Acquisition Manual (“SAQ Manual”) which includes procedures for assessing risks and impacts relating to tower expansion and construction, meeting regulatory and permitting requirements and avoiding ecologically sensitive areas and physical or economic displacement of local community members. For each proposed tower site, HTD commissions independent consultants to perform environmental and social impact assessments for all sensitive sites. Permits are obtained for each site and are available for viewing at HTD’s offices. HTD provides precise specifications to contractors for durable construction of towers and outsources construction of new tower sites to reputable companies with high quality management standards based on HTA’s Supplier Code of Conduct. HTD includes terms in its agreements with contractors requiring sound environmental and social management by the contractors, and monitors compliance with those terms. Contract terms provide for termination of contracts in the event of non-compliance with environmental and social requirements. HTD manages environmental and social risks and impacts in its operations through its Health, Safety and Environmental Management System (“HSEMS”) which has been prepared consistent with PS requirements. HTD is expected to achieve OHSAS 18001 certification for occupational health and safety management systems by the end of 2013 and ISO 14001 certification for environmental management systems by mid-2014.
PS2: Labor and Working Conditions
HTD’s human resources policies and procedures are provided in the Helios Towers DRC Employee Handbook and designed to ensure compliance with all applicable local labor laws and regulations and requirements of PS2. These policies and procedures promote the fair treatment, non-discrimination and equal opportunity of employees, and include written procedures for handling employee grievances. HTD has implemented procedures to ensure that no employee is below the legal employment age and makes commercially reasonable efforts to ensure that no contractors who performs work related to core functions of HTD for a substantial duration is below the legal employment age.
Occupational health and safety policies and procedures are provided in the HSEMS. HTD ensures that its employees are provided with appropriate personal protective equipment and health and safety training for the type of work in which they are engaged. For all of its offices, operational sites, switching centers, and retail outlets, HTD employs appropriate measures for life and fire safety. HTD makes commercially reasonable efforts to ensure that contractors who perform work related to core functions of HTD for a substantial duration shall be provided a safe and healthy work environment, including appropriate training, protective clothing and equipment. Where occupational health and safety deficiencies are identified, HTD has procedures in place to implement corrective actions, including additional training, to ensure that practices are consistent with good international industry practice.
PS3: Pollution Prevention and Abatement
HTD has established policies and procedures for waste management at construction sites, including terms in its agreements with contractors that cover pollution prevention and abatement. Fuel tanks at tower sites are to be constructed of steel and meet quality assurance standards, and HTD will make commercially reasonable efforts to ensure all tanks have secondary containment. Monitoring of the tanks is conducted regularly. HTA has prepared a Diesel Fuel Leaks & Spillages, Clean-Up Procedure to respond to accidental leaks and spills of hydrocarbons and fuels at tower locations, which will be implemented by HTD through maintenance and security contractors.
PS4: Community Health, Safety & Security
Security Arrangements: All tower locations are fenced or have controls to prevent access by the public. Security is a contractual obligation of HTD’s maintenance and security contractors who sub-contract to specialized security companies. Security generally takes one of four forms: (i) no security, (ii) roaming security covering a few sites, (iii) night-time security only, or (iv) 24 hour security. The level of security is determined by the maintenance and security contractors themselves based on risk, with the maintenance and security contractors financially liable for any loss, theft or penalties imposed. No armed security guards are used in any of HTD’s operations.
HTD recognizes the importance of community engagement. For acquisition of tower sites, HTD consults with relevant municipalities and local village councils, obtains all required permits and authorizations, and complies with local codes and IFC Performance Standards. HTD will ensure prior disclosure of the development of new tower sites to local communities, as site conditions warrant, as well as informing communities for the procedures for submitting, handling and resolving complaints or grievances from community members at all tower sites. HTD’s community grievance procedure is included as part of the HSEMS.
There are no attachments to this ESRS document.