Escotel Africa

This Environmental and Social Review Summary (ESRS) covers the application of the Escotel Mauritius (“Guarantee Holder”), a holding entity incorporated in Mauritius for its equity and quasi-equity/shareholder loan investments in Escotel Democratic Republic of Congo SARL(US$15M), Escotel Sierra Leone Limited (US$13.6M) and  Escotel Liberia  Inc. (US$13.4m) against the risks of transfer restriction and inconvertibility, war and civil disturbance (including business interruption) and expropriation for a period of up to 10 years. Escotel Mauritius will own 99-100% of the 3 legal entities that were established as Energy Service Companies (“ESCO”), namely: Escotel Democratic Republic of Congo (EDRC) SARL, Escotel Sierra Leone (ESL) limited  and Escotel Liberia(EL) Inc. (herein referred to as the “Project Enterprise” (PE)). The Escotels are incorporated respectively in the DRC, Sierra Leone and Liberia and Escotel ownership is split between Sagemcom Energy and Telecom (15%), Inspired Evolution (54%) and Norfund (31%). The GH will fund individually each local entity, in the form of equity and share-holder loan, in each country of operations with potential co-investors.

Sagemcom, a privately-owned information technology and communications company has more than 30 years of experience in Sub-Saharan Africa and presence in 22 countries in the region. Sagemcom has built more than 2,000 radio sites in Africa and provided management services on more than 1,000 sites. Sagemcom Group specializes in audio-video, broadband and energy telecom solutions and has partnered with France based telecom company Orange (the “Operator”) to set-up an “ESCO”. The Escotel will take-over and operate the energy supply of more than 900 telecommunication (telecom) towers that belong to Orange’s mobile network in the Democratic Republic of Congo (“DRC”), Liberia and Sierra Leone (“SL”). The PEs in DRC, Liberia and SL will provide Orange with technical and operational services necessary to power the telecom towers. The PEs will oversee and implement on and off-grid solar hybrid systems, which will use a remote monitoring system to switch between solar (off-grid), on-grid electricity and diesel power.

The PEs will contract the three local Sagemcom entities (Sagemcom DRC SARL, Sagemcom Liberia Inc and Sagemcom Sierra Leone Limited) to serve as the Engineering, Procurement and Construction and Operations and Management (EPC and O&M) contractor for the Projects. The PEs respective EPC and O&M contractor will oversee the technical design, migration management and deployment processes via the respective EPC and O&M contractor contractual agreements.

The PEs are planning the deployment of a10-year operation of hybridization equipment such as solar photovoltaics (PVs), batteries, generator sets (gensets), and related electrical equipment of a portfolio of telecom sites owned by Orange. The PEs will enter into a 10-year Energy Optimization Agreement (the “EOA” or the “ESCO Contract”) with the local subsidiaries of Orange in each country. Per the ESCO contract, each PE’s scope of work and modernization process will vary. The scope of work shall include the following: i) reduce diesel consumption by upgrading and replacing existing batteries and gensets to energy efficient options; ii) installation of solar panels, to power telecoms towers, in existing sites with poor grid systems or no grid connections; iii) for new off-grid sites, installation of a hybrid solar system including constructing new solar panels; and iv) operations and maintenance, including fuel supply.

EDRC

In DRC, modernizing sites with solar power is challenging due to space limitation in urban areas. However, assessments are being undertaken to determine feasibility of installing PV on base station towers. Sites which are not connected to the grid or not yet modernized with PV operating relying on diesel driven generators. Sagemcom DRC SARL that has been incorporated and operating in DRC since 2016. Sagemcom DRC SARL had a contractual agreement with Orange between 2016 and 2018, per the contract, equipment ownership remained with Orange. Scope of work under this contract included maintenance of facilities (such as energy systems and other base stations). From 2018, the scope of work was expanded to include the deployment of modernized energy systems on an own and operate basis. Currently, 342 telecoms sites are in scope to maintain and modernize, including the provisions of security services to guard and protect the telecom towers.

On-grid: Only 43 out of the 342 telecom sites are connected to the grid due to poor reliability, availability and quality of electricity from the national grid. Of the 342 sites, 88 have been modernized under the previous contractual agreement.

The DRC PE will be established and start operations under EDRC once the pending EOA is signed between the DRC PE and Orange. Once the EOA is signed, the PE will manage 342 existing sites, plus specific sites: 43 Orange shops, 13 datacenters and 5 residences. The Orange shops are for selling Orange subscription and solutions to their customer, the datacenters are used for housing computer systems, Switches and controllers and the 5 residences are residences of Orange management.

ESL

The PE in Sierra Leone has been in operations since February 2019 after taking over the business operations from GreenWish Energy. The PE signed the EOA with Orange on January 2020 to manage 342 existing sites across Sierra Leone and additional 50 sites will be added to the scope of coverage in June 2020. The Orange sites are located throughout Sierra Leone and they have organized the sites into three geographic ‘clusters’ to enhance service coverage. EPC and O&M contractor will be Sagemcom Sierra Leone (SL) Limited.

EL

The Liberia PE has been in formal operations to manage 329 telecom sites, since January 2020, as the EOA was signed in December 2019. The PE took over the power systems operation and maintenance responsibility that was being managed by Orange Liberia. The current power systems configurations will comprise of 75% hybrid solar systems (PV panels and battery storage) and 25% hybrid genset battery (HGB). No sites are connected to the national power grid, so all sites require off-grid solutions. The EPC and O&M’s subcontractor responsible for the Project maintenance and modernization is Sagemcom Liberia, Inc.

The Projects have been categorized as a Category B under MIGA’s Policy on Environmental and Social Sustainability (2013). The Projects are expected to have potentially limited adverse Environmental and Social (E&S) risks, generally site specific and can be addressed through the implementation of applicable Performance Standards (PSs), Environmental Health and Safety (EHS) guidelines, and design criteria. The key E&S risks and impacts for the Projects include: (i) Occupational health and safety (OHS) and operational hazards related to construction and transportation of hazardous materials (at the community and worker level); (ii) risks of installation and maintenance of the solar PV panels; (iii) waste management (including wood, scrape metals, oil, hazardous materials etc. iv) contractor management; (v) community health and safety; (vi) and life, fire and safety and emergency response; (vii) human resources and labor and working conditions v) water usage impacts (on solar panel cleaning); viii) stakeholder engagement ix) community grievances; and x) managing security issues in Project footprint with existing pockets of fragility that can lead to potential conflicts;; and xi) site security and access control.

While all PSs are applicable to this investment, current information indicates that the proposed investment will have impacts which must be managed in a manner consistent with the following PSs:

• PS1: Assessment and Management of Environmental and Social Risks and Impacts
• PS2: Labor and Working Conditions
• PS3: Resource Efficiency and Pollution Prevention
• PS4: Community Health, Safety and Security

PS5: Land Acquisition and Involuntary Resettlement is not applicable to this Project. The PEs will not acquire or lease any land for the Project. The land necessary for construction and operations of the Projects was obtained through voluntary rental agreements between Orange, the respective Escotels and the landowners. Orange developed all sites in the three countries and is responsible for the E&S issues associated with land acquisition, planning and conducting environmental and social impact assessment (ESIA) and obtaining environmental permits per the national laws and regulations. Orange along with the respective PEs will lead the land transaction process by leasing land for new telecom towers. The land acquisition will entail signing commercial agreements with landowners in urban areas. In rural areas, mutual legal agreements will be signed with communities. The agreements will be in accordance with the PEs national laws and regulations and will be in line with MIGA’s PS5 requirements.

There are no impacts related to the following PSs, thus they do not apply to these Projects:  PS5 Land Acquisition and Involuntary Resettlement; PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7 Indigenous Peoples or PS8 Cultural Heritage, however, the standard chance find procedure requirement will apply.

In addition, the following World Bank Group Environmental Health and Safety (WBG EHS) Guidelines will apply to this Project:

• Environmental, Health and Safety (WBG EHS) General Guidelines (2007)
• Environmental, Health, and Safety (WBG EHS) Guidelines for Telecommunications (2007)
• Environmental, Health, and Safety (WBG EHS) Guidelines for Electric Power Transmission and Distribution (2007)

For this Project, MIGA’s environmental and social due diligence (ESDD) consisted of reviewing and discussing the following documents:

• Sagemcom’s Group Human Resources (HR) Policies and HR Handbook (May 2019)
• Sagemcom’s Environmental and Social Management Plans (including existing emergency preparedness and hazardous waste management plans), May 2019
• Environmental and Social Impact Assessment (ESIA) report for DRC Orange Telecom, June 2017
• Sagemcom and Orange Contractual Agreements for Liberia (Dec 2019),
• IBIS Consulting, Project Environmental and Social (E&S) Due Diligence (ESDD) for DRC, Liberia and SL, April 2020.

In addition to reviewing the above documents, in 2019, MIGA conducted sites visits to DRC (March 29-May 3), to Sierra Leone (May 6-7) and to Liberia (May 9- 10). In DRC and Sierra Leone, MIGA conducted site visits to four (4) randomly selected Project sites. The selected sites had telecom towers connected to good grid (4-hour outage per day), poor grid (20-hour average outage per day), and sites that were Off-Grid and powered by a combination of energy sources such as gensets, batteries and solar. In addition, the MIGA team also visited telecom towers installed in residential areas and within private compounds to assess E&S risks. In Liberia, the team did not conduct any site visits, because the sites were not established or operational.

In addition, during ESDD, MIGA held meetings with the PEs staff, Sagemcom personnel, Orange (SL and Liberia) and the Ministry of Land in DRC and SL. For Liberia, as operations were not established and the project did not have a physical office, the team had a call with the PE’s Operations Director based in SL, held meetings with Orange Liberia and Ministry of land. During the meetings with the PEs’ and Sagemcom’ s teams, MIGA’s E&S team discussed the investment status and timeline, reviewed E&S management plans and procedures, identified E&S risks and impacts and discussed MIGA’s PSs and E&S requirements.

Since MIGA’s E&S due diligence in March 29, 2019, the project ownership, structure and contractual arrangements with Orange in the respective ESCOs have changed. However, the project scope and concept remain the same. As a result of the changes and new ownership structure, MIGA’s E&S team was required to conduct an E&S due diligence to assess the PEs institutional capacity to manage E&S risks and impacts. However, due to travel bans and restrictions as result of COVID-19, MIGA’s E&S team could not conduct a site visit and depended on IBIS which conducted E&S Due Diligence (ESDD) on behalf of Inspired Evolution (a key Project investor and partner). IBIS ESDD comprised of reviewing of PEs E&S documentation; site visits to eight (8) telecommunication facilities in Sierra Leone on March 25 -26, 2020; performed a Reputational Risk Review (RRR); Management interviews with in country Sagemcom staff in DRC and Liberia and via teleconference between 30 March - 1 April, 2020.

MIGA’s due diligence review considered the E&S management planning process and documentation for the Projects and identified gaps (if any) between these and MIGA’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable time period, are summarized in the paragraphs that follow and in the Environmental and Social Action Plan (ESAP) attached to this ESRS. Through the implementation of these measures, the Project is expected to be designed and operated in accordance with the Performance Standards (PSs).

Key environmental and social (E&S) issues associated with the Project business activities are summarized in the paragraphs that follow.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System:

Sagemcom Group has a corporate ESMS that is certified and compliant with International Standard for Environmental Management System (ISO 14001:2015), International Standard for Quality Management Systems (ISO 9001), International Standard for Occupational Health and Safety Management Systems (OHSAS 45001:2018), and International Standard Information Security (ISO 27001). These corporate systems will form the basis of the Projects specific ESMS at the PEs.

EDRC

The PE in DRC has an established Project specific Environmental and Social Management System (ESMS) that is aligned with ISO 14001 and OHSAS 18001. The PE intends to seek ISO 14001 and OHSAS 45001certification in 2021. Since, the current ESMS system and related plans and procedures refers to OHSAS 18001, the PE will ensure the EPC and O&M contractor conduct a gap analysis of the existing system against the ISO 45001 requirements. Where gaps are identified the EPC and O&M contractor will develop and implement an action plan to conform to ISO 45001. The PE will require the EPC and O&M contractor to update Project specific ESMS to align with MIGA’s PSs as well as applicable WBG EHS guidelines, conform to DRC laws and regulations and align with ISO 45001 requirements for the construction and operation per the ESAP. The updated ESMS will include the following items: (i) E&S Policy; (ii) Health and Safety (H&S) Policy (including health safety and environmental monitoring and reporting); (iii) definition of organizational capacity, responsibilities and competence; and (iv) E&S management programs and plans (such as emergency preparedness and response mechanisms, management of hazardous and non-hazardous waste, and stakeholder engagement). The ESMS will be applied during the construction and operations phase and will also be implemented by contractors and subcontractors.

ESL and EL

The PEs in SL and Liberia are newly established business entities and currently do not have a formal ESMS. Therefore, the PE in SL and Liberia will each require the EPC and O&M contractor to develop Project specific ESMS that conforms with SL and Liberia laws, is aligned with MIGA PSs, and as well as applicable WBG Environmental Health and Safety (EHS) guidelines for construction and operations per the ESAP. The ESMS will include the following items: (i) E&S Policy; (ii) Health and Safety (H&S) Policy (health safety and environmental monitoring and reporting); (iii) definition of organizational capacity, responsibilities and competence; and (iv) E&S management programs and plans (such as emergency preparedness and response mechanisms, management of hazardous and non-hazardous waste, and stakeholder engagement). The EPC and O&M contractor will develop and design the Project specific ESMS and procedures and align it with Sagemcom’ s corporate ESMS systems and ISO requirements. The ESMS will be implemented by both the respective PEs contractors and subcontractors during the construction and operations phase.

The EPC and O&M contractor contract is a key tool for ensuring compliance with the PEs’ EHS requirements. The PEs will include specific OHS requirements and E&S risk management clauses in the EPC and O&M contractor contracts. These clauses will include guidance on managing Project E&S risks such as on hazardous materials and hazardous waste management, pollution prevention, working conditions and workers safety, and community safety to comply with MIGA’s PSs and where applicable to subcontractors and main suppliers, as well as a provision of resources for E&S management, monitoring and compliance of its subcontractors per the ESAP.

Policy:

EDRC

The PE in DRC has an EHS Policy and it outlines commitments to reducing environmental footprint, compliance with regulations, and strengthening employees OHS. The PE and the EPC and O&M contractor to update the EHS Policy as part of the ESMS update to include management of social risks to guide the project to achieve sound E&S performance in line with MIGA’s PS1 per the ESAP. The EPC and O&M contractor EHS policy shall be consistent with Sagemcom’ s EHS policy.

ESL and EL

The PEs and EPC and O&M contractor in Liberia and SL have not established a formal policy for E&S performance. The PE and EPC and O&M contractor will develop the HSE Policy as part of the ESMS update to include management of social risks to guide the project to achieve sound environmental and social performance in line with MIGA PS 1. per the ESAP. The EPC and O&M contractor EHS policy shall be consistent with Sagemcom’ s EHS policy.

Identification of Risks and Impacts:

EDRC

Orange in DRC developed all sites and is responsible for the E&S issues associated with land acquisition, planning and conducting environmental and social impact assessment (ESIA) and obtaining environmental permits per the national laws and regulations. The PE plans to use the approved ESIA and environmental permits for Orange sites, adopt it and apply it to the Project. The PE will ensure to implement all the environmental permit conditions and requirements to be in line with DRC laws and MIGA PS1 requirements. The ESIA identified key E&S risks and impacts during the installation and construction of new towers in different locations. The risks are mainly OHS risks linked to construction activities such as working at heights, hazards, installation of communication towers and electrocution risks amongst others. Orange DRC conducted a risk assessment study to determine the screening criteria for selecting new sites in rural areas and provinces. The screening criteria will ensure that sites will withstand potential destruction from weather and vandalism, are not located in conflict zones, are within legally acquired land and are not in sensitive biodiversity areas. Orange DRC is responsible for obtaining and complying with required permits requirements per the national law.

Per MIGA’s and IBIS ESDD findings, Orange DRC (the operator of the telecom sites) is responsible for obtaining the required environmental and operational permits, certificates and other authorizations required by national regulatory requirements based on approved ESIA. The PE will be required to obtain the sites environmental permits from Orange and apply it to the Project to ensure that they operate in compliance with applicable national E&S laws and regulations. However, Orange DRC have not provided the PE with the environment permits and they are still pending. Therefore, the PE will be required to obtain environmental and operational permits for all sites from Orange, review their applicability to project operations, and establish measures to implement and comply with the permit requirements in line with national laws and MIGA’s requirements per the ESAP. Moreover, in DRC the EPC and O&M contractor has conducted two (2) risk assessments exclusively focused on worker health and safety hazards and risks, excluding risks relating to site security, environmental aspects and risks associated with the community and health and safety of workers, for example, crossing water bodies using barges. Therefore, the PE will require the EPC and O&M contractor to conduct a comprehensive E&S risk assessment of the proposed Project to address expected E&S risks and impacts and develop a time bound plan to mitigate and manage E&S risks identified as per the ESAP.

ESL and EL

Per the national laws and regulations in Liberia and SL, Orange is required to develop an ESIA for developments under the telecom sector and obtain relevant environmental permits. The ESIA will have enabled Orange in both countries to identify E&S impacts and risks as part of the initial planning and permitting of the sites. In addition, the ESIA would have required that mitigation measures to avoid or reduce impacts be identified and that a plan be put in place to implement the measures as well as any conditions imposed by the government as part of the approval. Since, the ESIA and all the environmental and operating permits are still pending from Orange in SL and Liberia respectively. Therefore, the PE will be required to obtain environmental and operational permits for all sites from Orange, review their applicability to project operations, and establish measures to implement and comply with the permit requirements in line with national laws and MIGA’s requirements per ESAP. Moreover, the Projects in Liberia and SL have not conducted ES& risk assessments. Therefore, the PE will require the EPC and O&M contractor to conduct a comprehensive E&S risk assessment of the proposed Project to address expected E&S risks and impacts and develop a time bound plan to mitigate and manage E&S risks identified as per the ESAP.

As part of MIGA’s requirements the PEs will ensure that environmental, social and Health and Safety risks and impacts identified in the ESIA and in the permit requirements are appropriately addressed in the respective PEs ESMS’s. As part of addressing the permit requirements, the ESMS Management Plan (ESMS MP) will be further developed into a clear plan of action for the identified risks/impacts with assigned responsibilities and deadlines. This will also be implemented by the EPC and O&M contractor and sub-contractors.

Management Programs:

EDRC

In DRC the processes and procedures are detailed in the ESMS. However, in reviewing the documents, gaps were identified. As certain procedures are pending development and finalization. The PE in DRC will require the EPC and O&M contractor to develop a Project specific Environmental Social Management Plan (ESMP) to be in line with MIGA’s PSs and WBG EHS guidelines for the construction and operations phases per the ESAP. The ESMP will serve as a framework and will be part of the ESMS. The ESMP will include air quality, noise, water resources, solid waste, and health and safety amongst other topics. The management plans include details on monitoring actions, and the frequency of monitoring, along with the performance indicators and the responsible entity such as the EPC and O&M contractor.

ESL and SL

The PEs in Liberia and SL are newly established and are in early stages of developing business procedures and systems and related E&S management systems. As a result, the PEs in SL and Liberia will require the EPC and O&M contractor to develop Project specific ESMP in line with MIGA’s PSs and WBG EHS guidelines for the Project construction and operations phases per the ESAP. The ESMP will serve as a framework and will be part of the ESMS system. The management plans will include air quality, noise, soil, water resources, solid waste, and health and safety amongst other topics. The management plans include details on monitoring actions, and the frequency of monitoring, along with the performance indicators and the responsible entity such as the EPC and O&M contractor.

The PEs will ensure that workers understand the E&S requirements, measures, and protocols stipulated within the ESMPs through induction training and a workers’ manual that is translated into French and English. The PEs will also ensure that all E&S personnel are competent to carry out their duties through the hiring and selection process, or where necessary, arrange for suitable training to be undertaken to achieve this level of competency before construction starts and during the operations.

Organizational Capacity and Competency:

EDRC

The PE’s Country Manager will oversee the EPC and O&M contractor operations including E&S risk management. During construction and operations, the EPC and O&M contractor will be responsible for managing E&S risks and for implementation of the ESMS to improve E&S performance. The EPC and O&M contractor hired an EHS Manager in August 2017 to manage E&S risks and coordinate with field supervisors on EHS matters. Given the vast operations in DRC and the extensive regions to cover, the PE will require the EPC and O&M contractor to appoint an additional experienced EHS officer to support the EHS Manager to manage E&S risks in line with the requirements of MIGA’s PS1 during the Project construction and operation phases per the ESAP. Once appointed, the EHS officer will coordinate with operations and technical teams based in the field in different regions and provinces to ensure that E&S risks are managed adequately. Additionally, the EPC and O&M contractor will ensure that all the contractors and sub-contractors will meet and adequately implement E&S standards per contractual agreements.

ESL and EL

The PEs in Liberia and SL will be managed by a Country Manager who will be responsible to manage the operations in both countries and oversee the EPC and O&M contractor operations including E&S risk management. However, The PEs E&S organizational structure is not fully staffed, and the PEs in Liberia and SL are in the process of recruiting a dedicated EHS Manager. The EHS Manager would report to the Country Manager and would cover both Liberia and Sierra Leone in a shared arrangement. The PE in Liberia and SL will require the EPC and O&M contractor to appoint a qualified EHS Manager to manage both countries and additional EHS officers for Liberia and SL to manage E&S risks and impacts in line with the requirements of MIGA’s PS1 during the Projects construction and operations phases per the ESAP. The EHS officers in both countries will be supported by additional EHS staff as required to manage the risks identified. The EHS team will be responsible for the implementation of the ESMS and related plans and procedures including monitoring and reporting.

Emergency Preparedness and Response:

EDRC

As part of the ESMS, the PE will require the EPC and O&M contractor to update the Emergency Preparedness and Response Plan (EPRP) to address the facility wide risks including fire and other external emergencies during the Project construction and operations phases, per the ESAP. The EPRP will define the steps needed to collaborate with nearby communities, local government agencies, and relevant third parties to facilitate response to emergency situations to prevent and mitigate harm to people and/or the environment. In addition, the EPRP will detail emergency response procedures in the event of fire/explosion, severe traffic accidents, natural disasters, earthquakes, hazardous material spills, floods, landslides, forest fires, and violence and/or social unrest. The plan will include broad response principles; a description of roles and responsibilities and the chain of command; site-specific management and response procedures under different emergency situations and awareness training. During construction and operations, basic first aid training and kits will be provided on site.

ESL and SL

As part of the ESMS, the PEs in Liberia and SL will require the EPC and O&M contractor to develop the EPRP to address the facility wide risks including fire and other external emergencies during the Projects construction and operations phases, per the ESAP. The EPRP will define the steps needed to collaborate with nearby communities, local government agencies, and relevant third parties to facilitate response to emergency situations to prevent and mitigate harm to people and/or the environment. In addition, the EPRP will detail emergency response procedures in the event of fire/explosion, severe traffic accidents, natural disasters, earthquakes, hazardous material spills, floods, landslides, forest fires, and violence and/or social unrest. The plan will include broad response principles; a description of roles and responsibilities and the chain of command; site-specific management and response procedures under different emergency situations and awareness training. During construction and operations, basic first aid training and kits will be provided on site.

During ESDD, the MIGA and IBIS E&S team observed that, some of the Project sites did not have fire extinguishers. As a result, the PEs will require the EPC and O&M contractor to equips all sites with firefighting equipment including adequate fire extinguishers on sites that are regularly inspected and well maintained per the ESAP. Additionally, PEs will ensure that the EPC and O&M contractor will train all staff, in particular the security guards on how to operate the fire extinguishers in case of fire.

Monitoring and Review:

EDRC

The EPC and O&M contractor in DRC has established a monitoring and measuring procedure that describes the process for identifying EHS monitoring indicators. The EHS Manager in DRC conducts inspections twice a year to identify breaches in EHS procedures and assesses E&S performance. Per IBIS’s ESDD report, the EPC and O&M contractor has developed monitoring checklists that includes; first aid forms, Personal Protective equipment (PPE) inspection forms, EHS audit forms, ladder audit forms and fire equipment forms. The PE will ensure that the EPC and O&M contractor will undertake regular on-site EHS monitoring of the implementation of key EHS plans and programs during construction and operations in line with MIGA PS1 requirements. In addition, the EPC and O&M contractor will internally monitor implementation of key EHS plans and procedures during construction and operations. Additionally, the EPC and O&M contractor will monitor key environmental aspects that includes solid and hazardous waste materials management, OHS, life and fire safety equipment maintenance, energy use, and water usage. The EPC and O&M contractor shall systematically report all the findings to PE’s Management in DRC in a timely manner and will ensure that all identified correctives actions are implemented effectively and well documented.

ESL and EL

The PE in Liberia and SL are in the process of developing their ESMS and as such, formal processes to monitor and review environmental and social performance are not yet in place. The PE in Liberia and SL will ensure that the EPC and O&M contractor will undertake regular on-site EHS monitoring of the implementation of key EHS plans and programs during the Project construction and operation phases in line with MIGA PS1 requirements. In addition, the EPC and O&M contractor will internally monitor implementation of key EHS plans and procedures during construction and operations. Additionally, the EPC and O&M contractor will monitor key environmental aspects that includes solid and hazardous waste materials management, OHS, life and fire safety equipment maintenance, energy use, and water usage. The EPC and O&M contractor shall systematically report all the findings to PE’s Management in Liberia and SL in a timely manner and will ensure that all identified correctives actions are implemented effectively and well documented.

MIGA will also require periodic monitoring reports for the PEs that will evaluate E&S performance against MIGA’s E&S requirements and will include sections on E&S risks and impacts, updates on development indicators throughout the guarantee period.

Stakeholder Engagement:

Orange in DRC, Liberia and SL, owns the projects sites as operators of the telecom towers which will be managed by the PEs. Orange in each of these countries is responsible for active engagement with external stakeholders as is required by national regulations or permit conditions. The PE in DRC, Liberia and SL will engage with stakeholders within area of influence and related to specific activities they undertake, including the operation and maintenance of power systems. Stakeholders in this regard include people that might be affected by the Project activities (such as noise and air pollution etc.) during construction and operations phases. Since Orange will be required to develop a Stakeholder Engagement Plan (SEP) which covers its operations, the PEs in DRC, Liberia and SL will adopt Orange SEP and apply it to the project and develop and an External Communication and Grievance Mechanisms to address stakeholders concerns and issues per the ESAP detailed below.

External Communication and Grievance Mechanisms:

The PEs and EPC and O&M contractor typically have an ongoing presence at the sites, with security guards present on a 24-hour basis, as well as technicians (employees and contractors) routinely visiting sites to conduct scheduled and non-scheduled maintenance. Accordingly, these personnel and contractors are typically on the ‘front line’ for receiving any verbal or written grievances from affected communities or third parties. In addition, the EPC and O&M contractor in DRC currently supports Orange DRC with onsite supervision of contractors commissioned by Orange DRC for the construction and establishment of new sites. The EPC and O&M contractor is therefore likely to be the receiver of community grievances. Moreover, Liberia and SL are newly established entities that currently do not have a Project specific Community Grievance and External Communication Mechanism and the PEs will be required to develop per the ESAP below.

Therefore, the PEs will require the EPC and O&M contractor to develop a project specific Community Grievance and External Communication Mechanism in line with the requirements of MIGA’s PS1 for the Project construction and operations phases per the ESAP. The mechanisms shall include methods to receive, register, screen and assess, track, respond to, and act upon external inquiries and complaints from the public during construction and operations. The grievance mechanism shall ensure that grievances from affected communities and external communications from other stakeholders are responded to and managed appropriately.

PS2: Labor and Working Conditions

EDRC

In DRC, the PE will havea one (1) employee. In addition, EPC and O&M contractor has a total of 94 employees of which 5 are women and 89 are men. However, employees are not directly employed by the EPC and O&M contractor but are contracted through two employment agencies that manages HR functions. In addition, approximately 50% of maintenance activities are outsourced to subcontracted service providers. The workforce comprises of engineers, technical specialists, and various management functions.

EL

In Liberia, PE will have one (1) employee. The EPC and O&M contractor direct workforce comprises approximately of 42 employees of which 1 is woman and 41 are men. The EPC and O&M contractor’s 37 workers were transferred from Orange Liberia and integrated into the business. The transfer was done under authorization from the Liberia Department of Labor and with consultation with the worker union. The workforce comprises of engineers, technical specialists, and various management functions.

ESL

The PE will have one (1) employee. The EPC and O&M contractor direct workforce is comprised of approximately 69 employees of which 4 are women and 65 are men.

Working Conditions and Management of Worker Relationship:

EDRC

The EPC and O&M contractor as of part managing HR, have subcontracted the HR functions including hiring, payment of salaries and benefits to Servtec RDC SARL (60%) and Sesomo Services SARL (40%). These two (2) Congolese companies are based in Kinshasa. The employees have signed employment contracts with their respective subcontractors. The EPC and O&M contractor in conjunction with these employment agencies share responsibilities for HR management. The PE will develop Project specific Human Resources (HR) policy and procedures and the PE will require the EPC and O&M contractor to update their HR policy and procedures and ensure that they are in line with MIGA’s PS2 and DRC laws for the Project construction and operation phases per the ESAP.

The PE and EPC and O&M contractor will also ensure that the HR policy applies to their local subcontractors handling HR functions. The PE and EPC and O&M contractor will ensure that Servtec and Sesomo’s HR Policies and procedures are: i) aligned with the PE’s and EPC and O&M contractor’s HR policies and procedures and meets MIGA PS 2 requirements; and ii) include in employee contracts terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation, health insurance and end of service benefits per DRC national labor regulations. The HR policy will be provided as a hard copy to new hires together with an employment contract which outlines the terms and conditions of their employment. Working conditions (including health, safety and security), employee termination, prohibition of forced or child labor, disciplinary actions, non-discrimination and equal opportunity, workers’ rights and obligations, employer’s rights and obligations will be referenced. In addition, the PEs will include in their HR Policies language on HIV/AIDS, sexual harassment as part of the code of conduct of employees.

The HR Policies will be required to also cover rules of interaction with customers, the code of conduct will be amended to reflect respect for local beliefs and customs and with special attention for risks related to sexual harassment, sexual exploitation and abuse and gender-based violence (GBV). The PE will commit that all complaints of sexual harassment and GBV will be seriously investigated and disciplinary action will be taken. A training plan on the HR policy and procedures are to be included in the EPC and O&M contractor’s procedures and will be provided to all workers.

ESL and EL

The Liberia PE’s EPC and O&M contractor as of part managing HR, have subcontracted the HR functions including hiring, payment of salaries and benefits to PWC Liberia under an annual contract. The employees have signed employment contracts with respective subcontractors.

The SL PE’s EPC and O&M contractor directly employed 20 workers and remaining 20 workers were employed through Job search SL, an agency specializing in recruitment in SL. These workers were mostly transferred from the previous contract holder (Greenwish Energy). The EPC and O&M contractor Country Manager is responsible for HR management supported by a Project administrator. In both Liberia and Sierra Leone, the PEs will use a ‘flexible’ employment arrangement (e.g. using fixed-term employment contracts) to account for the future need to change the workforce skill set once the modernization process is complete and the operation shifts to O&M.

The PEs and EPC and O&M contractor in Liberia and SL will develop respective HR policies with procedures that are Project specific and in line with MIGA’s PS2 and respective national labor law per the ESAP. The PEs and EPC and O&M contractor will also ensure that these apply to their local subcontractors handling HR functions. The PE and EPC and O&M contractor will ensure that PWC Liberia and Job search SL’s HR Policies and Procedures meets MIGA’s PS2 requirements and national labor laws and are: : i) aligned with the PE’s and EPC and O&M contractor’s HR policies and procedures and meets MIGA PS 2 requirements; and ii) include in employee contracts terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity and paternity leave, vacation, health insurance and end of service benefits per DRC national labor regulations. The HR policy will be provided as a hard copy to new hires together with an employment contract which outlines the terms and conditions of their employment. Working conditions (including health, safety and security), employee termination, prohibition of forced or child labor, disciplinary actions, non-discrimination and equal opportunity, workers’ rights and obligations, employer’s rights and obligations will be referenced. In addition, the PEs will include in their HR Policies language on HIV/AIDS, sexual harassment as part of the code of conduct of employees.

The HR Policies will be required to also cover rules of interaction with customers, the code of conduct will be amended to reflect respect for local beliefs and customs and with special attention for risks related to sexual harassment, sexual exploitation and abuse and gender-based violence (GBV). The PE will commit that all complaints of sexual harassment and GBV will be seriously investigated and disciplinary action will be taken. A training plan on the HR policy and procedures are to be included in the EPC and O&M contractor’s procedures and will be provided to all workers.

On Grievance Mechanism, currently the PEs and the EPC and O&M contractor workers dependent on the subcontractors’ workers grievance mechanism. Therefore, the PEs will require the EPC and O&M contractor to develop and make available a worker’s grievance mechanism that will inform workers of the grievance mechanism process and in line with MIGA PS2 requirements as per the ESAP. In addition, the PEs’ grievance mechanism will clearly define the response timeframes to grievances and incorporate a grievance log as part of the grievance redress mechanism process. The grievance mechanism will also be accessible to contractors and subcontractors performing work in core business processes of the Project.

Currently the PEs security officers are hired by subcontractors to work 12-hour shifts. The PEs and EPC and O&M contractor will ensure that all workers and security officers hired through third parties work within legal and negotiated hours per national law in those countries and in line with MIGA’s PS2 requirements per the ESAP. Per the IBIS ESDD report, the small facility that provides shelter for security guards are in disrepair at some of the sites and basic amenities such as toilet facilities, night lighting is not always present. This situation is more prevalent in Liberia and Sierra Leone where operations have recently commenced and will need to be repaired and upgraded. In DRC, the EPC and O&M contractor and Orange have upgraded the sites and the improvements are 90% complete. Therefore, the PEs will coordinate with Orange and ensure that the security guard’s shelter facilities are refurbished and in good condition and they have access to facilities (such as basic toilets and night light) per the ESAP.

Protecting the Work Force:

The PEs and EPC and O&M contractor are committed to avoiding all forms of discrimination against their employees, based on age, gender, sexual orientation, health, race, nationality, political opinions or religious beliefs. The requirements of non-discrimination and equal opportunities will be extended to contractors and subcontractors as part of contractual agreements. The PEs and EPC and O&M contractor’s HR policy will exclude the use of any form of forced or compulsory labor and ensure to included PEs and EPC and O&M contractor HR Policies and procedures clauses that prohibit sexual harassment and gender-based violence in accordance with the respective countries national labor laws and MIGA’s PS2 requirements as detailed in the ESAP above under the working conditions and management of worker relationship.

On child and forced labor, the PEs and EPC and O&M contractor do not employ forced labor or children and have committed to enforcing this requirement per the respective national labor laws and MIGA’s PS2 requirements. The PEs and EPC and O&M contractor’s HR subcontractors will be required to screen all employees to ensure they meet the legitimate age to work. The EPC and O&M contractor will conduct further monitoring and verification of workers by verifying identification card and birth certificates to ensure all workers are of legal age. The EPC and O&M contractor will have strong oversight over its local subcontractors to ensure this is strictly enforced.

Occupational Health and Safety:

The PEs key OHS risks for the Projects include: slips and falls, working at heights, potential hazards from on-site moving machinery, heavy load lifting, exposure to electric shocks and burns, safety issues related to PV module assembly, workers travel risks (e.g. driving at night, driving on poor roads and river crossing using barges), working in security-sensitive areas prone to conflict and exposure to Malaria, Typhoid, Ebola and COVID-19 . Considering the hot and arid project locations, construction workers might be at risk of dehydration, heat exhaustion and heat stroke if not properly hydrated.
EDRC

The PE in DRC has established an OHS management procedure process which includes: i) identification of hazards; (ii) provision of preventive and protective measures; (iii) training; (iv) documentation and reporting of occupational accidents, diseases, and incidents; and (v) emergency preparedness and response. IBIS reviewed the OHS procedures and identified the following gaps: i) lack of PPE procedure (e.g. PPE use inspection and mandated use of life jackets when crossing water bodies); ii) working at heights procedure does not cover important details (e.g. specifying what height constitutes working at heights, use of ladders, inspection and maintenance requirements for harnesses, and requirements to be certified to be physically fit to carry out the project tasks); ii ) lack of documented process and measure to manage diseases (e.g. Malaria, Typhoid, Ebola and COVID-19).

Therefore, the PEs will require that EPC and O&M contractor to update and implements Project-specific OHS procedures for the construction and operations phases per the ESAP. These procedures will cover the following issues: i) hazard identification and assessment; ii) construction site safety, iii) specific procedures for hazardous works, worker’s safety and training iv) use of personal protective equipment; v) implement a worker’s health program to screen the health of workers and measures to manage diseases (such as Malaria, Typhoid, Ebola and COVID-19); vi) site supervision and audit procedures; vii) incident investigations and reporting system and intervention measures (medical surveillance programs and first aid etc.).

The PE in DRC has developed a system to record, monitor and investigate all the Projects related accidents and incidents per the Project Accident Reporting and Investigation Procedure and report to PE’s management for review for Project lost time injuries frequency rates and total recordable injury rates. No fatalities or major injuries or incidents have been reported for the project as of April 2020. Most of these incidents related to theft. Two incidents with injuries were reported: a fractured finger of a security guard and a minor injury during a vehicle accident; and a collapsed pylon with no injuries to EPC and O&M contractor personnel but resulted in injuries being sustained by members of the community.

ESL and EL

The PEs in Liberia and SL, OHS management procedures are yet to be established. Since the business operations just commenced, there are no Projects related fatalities or injuries reported. However, minor incidents/accident occurred related to road travel with motorbikes by the EPC and O&M contractor’s personnel. Therefore, the PEs in Liberia and SL will require that EPC and O&M contractor to develop and implements Project-specific OHS procedures for the construction and operations phases per the ESAP. These procedures will cover the following issues: i) hazard identification and assessment; ii) construction site safety, iii) specific procedures for hazardous works, worker’s safety and training iv) use of personal protective equipment; v) implement a worker’s health program to screen the health of workers and measures to manage diseases (such as Malaria, Typhoid, Ebola and COVID-19); vi) site supervision and audit procedures; vii) incident investigations and reporting system and intervention measures (medical surveillance programs and first aid etc.). The procedures will be designed to be specific to industry-specific hazards and the respective site. As part of the OHS Procedures for both the construction and operation phases, the OHS procedures will be aligned with the EPRP, which will include fire risk assessment and control systems, fire alarm systems and drills, and emergency preparedness and planning.

The Coronavirus Disease 2019 (COVID-19) has potential risks and impacts on PEs and their activities. To reduce the potential impact of COVID-19 on workers, customers and communities, EDRC, ESL and EL will update its policies and procedures to ensure that the risks associated with COVID-19 are adequately addressed per the ESAP.

Finally, the PEs will ensure that the EPC and O&M contractor assesses, tracks and records its OHS performance during construction and operations. The EPC and O&M contractor ’s EHS officer will record and track OHS incidents through an incident tracker and will include OHS performance in its monthly reports to PE’s management during the construction and operations phases.

Workers Engaged by Third Parties:

The PEs will take reasonable efforts to ascertain that third parties hiring third-party employees are reputable and legitimate enterprises and have an appropriate E&S management system that allows them to operate in a manner consistent with the requirements of MIGA’s PS. If not available, the third parties will adopt the EPC and O&M contractor E&S management. The PEs will require the EPC and O&M contractor to establish policies and procedures for managing and monitoring the E&S performance of such third-party employees per MIGA’s PSs, as well as incorporating these requirements in contractual agreements with third-party employees, as identified as per the ESAP.

Supply Chain:

The procurement of energy equipment for the PEs will largely be managed by the Project EPC and O&M contractor through and in coordination with Sagemcom France. Locally sourcing may be done for smaller items depending on in-country availability. The power equipment (including solar panels, diesel, generators, batteries, meters, cables, inverters and switches) to be used by the PEs will be manufactured mainly in France, China, Slovakia and Spain.

The PEs will ensure that the EPC and O&M contractor conduct a supply chain assessment of the nominated primary power equipment supplier to identify key E&S risks/impacts and ensure the supplier complies with the principles of MIGA’s PSs to appropriately manage E&S risks. Particular consideration in the assessment should be given to confirming the adequacy of the manufacturing facility’s management of hazardous material storage, waste storage/disposal, compliance with working conditions and occupational and community health and safety requirements to demonstrate that the project’s suppliers are complying with MIGA’s PSs and EHS Guidelines. The PE and EPC and O&M contractor will include a clause in main supplier contracts regarding applicable PS2 requirements on child or forced labor and OHS.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency:

During the Project construction and modernization phase, the PEs will use water mainly for construction activities (including concrete production and equipment cleaning), and domestic usage. During operations, water use will be mainly for solar panel cleaning and domestic usage. The operations phase will consume more water predominantly due to panels cleaning. However, the impact of water use will not impact other users since the water is supplied to each site from public water sources. The estimated water consumption during the construction and operations phase is expected to be approximately 3,000m3/year for DRC, 2,800m3/year in Liberia and 7,800m3/year in SL.

Water use will be a key performance indicator (KPI) and the EPC and O&M contractor will be required to keep track of water usage and report to the PEs. Moreover, the PEs will require the EPC and O&M contractor to develop a Project-specific water management plan (WMP), KPIs and evaluate alternative cleaning methods to minimize the amount of water used as per ESAP. The WMP will also include information on water quality testing and water quantity estimates.

Pollution Prevention:

The PEs modernization program involves replacement of older power equipment with new, more efficient and reliable equipment. The EPC and O&M contractor undertook a planning process, similar to the one conducted for Liberia, which involved inspection and audit of sites to determine power load requirements, site layout (to determine space available for power equipment placement) and the current state of equipment performance. The modernization program is currently in process in SL and DRC.

The PEs will require gensets on all sites as a back-up during operations. Usage of diesel gensets will locally impact air quality, gensets will be required to be in bunded areas to ensure containment. The PEs will be required to implement measures to manage fuel usage, spill management and storage. The PEs plans to modernize Project sites with energy efficient gensets and batteries and install solar panels. The use of renewable energy sources will reduce gensets running time, associated fuel consumption, air emissions and carbon footprint.

As part of pollution management and prevention, the PEs will ensure that the EPC and O&M contractor will develop environmental management plans and/or procedures per the ESMS, as detailed under the management programs section in PS1. The plans will be implemented at each site to manage pollution related aspects in line with MIGA’s PS3. The plans and procedures will include management of waste, hazardous materials, oil spillage, air emissions and occupational noise, etc.

During Project construction, the PEs solid waste generated will mainly consist of and include; paper, wood, and scrap metals. The PEs formal waste management procedures have not been established, nor have waste disposal service providers been identified. In DRC, wastes are returned to the supplier for recycling: used oil and spent oil filters to the distributor (Total DRC) and sold under cheaper brands; used batteries returned to Orange warehouses (as the current owner of the batteries), although the final waste disposal destination of the wastes has not been identified. The PEs will ensure that the EPC and O&M contractor in DRC, Liberia and SL will ensure that this waste will be collected by an accredited services provider to be disposed of in designated landfill sites. Per the Projects nature of construction and modernization, the overall volume of both solid and hazardous waste generated during construction is expected to be low. The PEs will require the EPC and O&M contractor in DRC, Liberia and SL to develop waste management procedures in line with MIGA’s PSs per the ESAP. The plan shall promote avoiding generation of hazardous and non-hazardous waste materials and where waste generation cannot be avoided reduce the generation of waste.

During Project operations, the PEs generated waste will be largely hazardous waste which will include fuel, used oils, used oil filters, lubricants, hydraulic fluids, batteries, broken solar panels, domestic waste, and waste generated from maintenance. In DRC, wastes are returned to the supplier for recycling. Used oil and spent oil filters are returned to the Total company (the distributor) for recycling. Currently, the used Project batteries are stored in Orange warehouses in DRC (as the current owner of the batteries). During modernization and operations, Sagemcom DRC will be responsible for the battery wastes storage and disposal. In SL the hazardous waste (including approximately 1000 liters of waste oil, 1000 used fuel filters, and 1500 used batteries) are being temporarily stored at Sagemcom SL facilities pending identification of a licensed waste disposal provider. In Liberia, the volume of hazardous waste accumulated (approximately 2500 waste batteries from modernization) is not high given that operations just recently commenced. The EPC and O&M contractor will ensure that the disposal of hazardous waste will be managed through a licensed third-party waste contractor. The PEs will require the EPC and O&M contractor to develop a comprehensive Hazardous Material (HAZMAT) plan per the ESAP. This plan will outline the process of managing hazardous materials and waste including but not limited to: disposal and storage of used oil, used oil filters, old batteries, broken solar panels, developing material safety data sheets, ensuring secondary containment during storage, proper labelling and signage, and local emergency intervention measures (spill kits etc.). This waste stream will be segregated, and the volume will be recorded per the EPC and O&M contractor’s procedures which will be included in the waste management plan. Hazardous materials will be stored in a dedicated area and handled with care and material safety data sheets displayed in French and English. PEs will require the EPC and O&M contractor to develop a procedure for managing the disposal of broken and ‘end of life’ panels, which will be in line with MIGA’s PS3 requirements and respective national laws per the ESAP.

Through the modernization of the energy systems, including implementation of solar PV solutions where grid electricity is unreliable or unavailable, it is expected that the businesses will achieve a major overall reduction in Greenhouse Gas emissions (GHGs). Greenhouse gas (GHG) emissions from the PEs during the construction and operations phase are expected to be predominantly associated with the use of fuels such as in gensets, EPC and O&M contractor trucks, on-site equipment, and machinery. The total GHG emissions is approximately 3,500t CO2/year in DRC, 4,000 CO2/year in Liberia and 2,200 CO2/year in SL and significantly less than 25,000 tons CO2e. The PE will be required to report to MIGA if the total GHG emissions exceeds 25,000 tons C02e.

The Project is expected to generate energy as follows; approximately 1,690 MWh per year in DRC, 1,760 MWh per year in Liberia and 4,930 MWh per year in SL.

PS4: Community Health, Safety and Security

Community Health and Safety

As part of the ESMS, the PEs will ensure that the EPC and O&M contractor will develop a Community Health and Safety Plan to ensure that communities are kept aware of the Project’s risks. During construction, community health and safety issues include noise vibration and increased EPC and O&M contractor construction trucks in the area. During operations, potential risks include fire and safety issues, oil spillages, accidents and electrical faults on the tower. Risks are minimized by restricting access to the sites and to hazardous equipment through physical security (e.g. fencing) and 24-hour security. Sites are fitted with fire extinguishers and security guards are trained in use of fire extinguisher. The PEs will ensure that the fire extinguishers are functional, well maintained, and are regularly inspected.

As part of the HR procedure, the PEs will develop and implement a Worker Code of Conduct which will also apply to all subcontractors to ensure they maintain high standards within the community. The code of conduct will be amended to reflect respect for local beliefs and customs and with special attention for risks related to sexual harassment, sexual exploitation and abuse and gender-based violence (GBV). The PEs will commit that all complaints of sexual harassment and GBV will be seriously investigated and disciplinary action will be taken. On potential for increased traffic risks and impacts to the communities, it is expected that the PEs will not cause any disruption to communities as the PEs will not transport any heavy loads on the roads to lessen potential for traffic or road blockages.

Security Personnel

The PEs respective Project sites and assets are secured by fencing, controlled access and guarded 24 hours per day by security guards. The security guards play a significant role in managing site security. The security services are outsourced to private security companies registered by the relevant authorities in the respective PEs country.

In DRC, the EDRC has hired Star and Kafakis, a local Congolese security company, which provides security services to all sites. EDRC ensures that the company has obtained necessary national licenses to operate as a private security company and abides by regulations established by the government authorities, such as the Ministry of Internal Affairs and Minister of Defense and Veterans. In SL, the ESL has hired BSE and Pendrax as security companies to provide security services to all sites. In Liberia, the EL has hired Empire Security, Meson, Seebro, and Titan Security as security companies to provide security services to all sites.

The scope of work for security services is documented in service contracts for EL and ESL. In EDRC, although the contract agreements are pending finalization, the site security processes, and detail procedures have been established to guide the security guards of their roles and responsibilities.

The PEs in DRC, Liberia and SL will require the EPC and O&M contractor to develop and implement a Security Risk Assessment and a Security Management Plan (SMP), in line with MIGA’s PS4 per the ESAP. Under the SMP, perimeter concrete fences with barbed wire will be installed, access will be controlled by the Network Operations Centre (NOC) and access will be restricted to one point of entry. To ensure alignment with MIGA’s PS 4 requirements for security arrangements, the PE and the EPC and O&M contractor will make reasonable inquiries to ensure that the private security service provider has not been implicated in past abuses. Moreover, the PEs will train security workers on the appropriate use of force and conduct toward workers and nearby communities. The PEs will also require security workers to act within the respective applicable national laws. The PEs will not sanction any use of force except when used for preventive and defensive purposes in proportion to the nature and extent of the threat.

The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.

• IBIS Consulting, Project Environmental and Social (E&S) Due Diligence (ESDD) for DRC, Liberia and SL, April 2020.
• Environmental and Social Impact Assessment (ESIA) for Orange DRC Ltd.’s Telecommunications Operations in Democratic Republic of Congo -June 2017.
• DRC ESAP Final
• Liberia ESAP Final
• Sierra Leone ESAP Final

The ESIA is available for viewing upon request from Orange DRC.

Project Contact Information

Contact: Alexander Alaniou

Position: Project Manager

E-mail:  alexandre.alaniou@sagemcom.com.

Address: Escotel Mauritius, Rue de l’Institut 4th Floor Ebene Skies Eben, Mauritius.

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MIGA supports its clients (as defined in MIGA Policy on Environmental and Social Sustainability) in addressing environmental and social issues arising from their business activities by requiring them to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities.

In addition, Affected Communities have unrestricted access to the Compliance Advisor/Ombudsman (CAO), the independent accountability mechanism for MIGA. The CAO is mandated to address complaints from people affected by MIGA-guaranteed business activities in a manner that is fair, objective, and constructive, with the goal of improving environmental and social project outcomes and fostering greater public accountability of MIGA.

Independent of MIGA management and reporting directly to the World Bank Group President, the CAO works to resolve complaints using a flexible, problem-solving approach through its dispute resolution arm and oversees project-level audits of MIGA’s environmental and social performance through its compliance arm.

Complaints may relate to any aspect of MIGA-guaranteed business activities that is within the mandate of the CAO. They can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of a MIGA-guaranteed business activity. Complaints can be submitted to the CAO in writing to the address below:

Compliance Advisor/Ombudsman
International Finance Corporation
2121 Pennsylvania Avenue NW
Room F11K-232
Washington, DC 20433 USA
Tel: 1 202 458 1973
Fax: 1 202 522 7400
E-mail: cao-compliance@ifc.org