Environmental and Social Review Summary
Orange Guinea Conakry Ltd.
This Environmental and Social Review Summary (ESRS) is prepared by MIGA staff and disclosed in advance of the MIGA Board consideration of 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 the MIGA Board of Directors. Board dates are estimates only.
Any documentation which 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.
MIGA has been requested by Sonatel SA (Sonatel Group) to proceed with underwriting a guarantee to cover Orange Guinea to support its existing telecom and mobile money operations, enable further expansion, renovation, upgrades, and introduction of new services.
The Sonatel Group is a Senegal-based company with its core business in providing telecommunication services. It is experienced in developing and growing telecoms operations having successfully established itself as a market leader in Senegal and expanded to 5 other countries in Africa (Mali, Guinea Conakry, Guinea-Bissau, Sierra Leone, and Cote d’Ivoire). Orange Guinea Conakry (“Project Enterprise or PE”) was established in November 2007 with Sonatel as the majority shareholder and the remaining shares owned by CMTO, Spacetel and Orange Guinea Conakry (OGC) employees. Orange Finances Mobiles Guinea (OFMG) was established as a separate entity in 2019 to provide mobile money services and OGC is the majority shareholder.
Sonatel Group requested that MIGA’s guarantee cover 90% of their equity investment of EUR 207.3 million of existing and new investment in the form of equity and retained earnings, as well as future investment of EUR 200 million (under the standby option) for up to 6 years. The equity investments will be used to support the expansion of the OGC and OFMG network, increasing consumer access, upgrading, and renovating equipment, introducing new services (such as 4G/5G), and supporting the further expansion of mobile money. Currently, OGC operates 2 offices, 6 shops and 300 active network sites in Guinea. As the Project is aimed at upgrading and expanding existing and future assets involving the telecommunication network (towers, radio antennae, energy supply…) infrastructure, and services in Guinea, it is anticipated that these works will have limited environmental and social (E&S) impacts.
This is a Category B project according to MIGA’s Policy on Environmental and Social Sustainability (2013). The Project is expected to have potentially limited adverse environmental and social (E&S) risks, which will be few, site-specific, largely reversible, and readily addressed through mitigation measures.
Key Environmental and Social (E&S) issues associated with this proposed investment are: i) site E&S assessment; ii) labor and working conditions of the employees, contractors; iii) occupational health and safety (OHS) of contractors; iv) management and monitoring of waste and hazardous materials; and v) assessing and mitigating social risks of the company’s security arrangements vis a vis affected communities and, solar supply chain risks. E&S impacts will be managed through the development and implementation of the OGC Environmental and Social Management System (ESMS) and site-specific Environmental Management Plans (EMPs). Contextual risks are related to broader security risks in relation to Guinea Conakry and will be addressed in Project-level security management plans.
While all Performance Standards (PSs) are applicable to this investment, current information indicates that that the Project 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
All land required for the Project will be leased or purchased through a negotiated willing lessee/willing lessor or a willing seller/willing buyer agreement, and therefore PS 5 Land Acquisition and Resettlement is not applicable. In case PS 5 would be triggered, OGC will not select those sites. Orange has a corporate commitment to avoid sites where involuntary resettlement would be required and implements only long-term lease arrangements according to market conditions for land acquisition.
PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources is also not applicable as potential adverse impacts on biodiversity are not anticipated. No communities of Indigenous Peoples as defined in PS 7 were identified in the Project area of influence and therefore PS 7 is not anticipated to be triggered. No sites of cultural/historical value were identified, and PS 8 Cultural Heritage does therefore not apply. For any reason, if the planned sites’ E&S assessment identify any issues that could trigger PS 6 or PS 7, OGC will avoid those sites.
In addition to the World Bank Group General Environmental, Health, and Safety (WBG EHS), the IFC Good Practice Note: Environmental, Health, and Safety Guidelines for Telecommunications (2007) will be applicable.
MIGA environmental and social due diligence (ESDD) of this project consisted of reviewing the documents:
- Analysis of Environmental & Social Gaps and Environmental and Social Action Plan (Earth Systems, 2021
- Orange Guinea Health, Safety and Environmental Manual (June 2022)
- Health & Safety and Environmental Organizational Chart
- Emergency evacuation awareness report - Orange Guinea (May 2022)
- Work Injury Management Procedure - POG036/03 (March 2023)
- Orange Guinea Waste Management Procedure - POG133/03 (November 2019)
- Summary of the Compliance Review of the waste management service provider site (November 2021)
- Maintenance Contract for Fire Safety Equipments – Orange Guinea and Eurofeu Guineenne d’Equipement et de Distribution (Avril 2011)
- Raising awareness of the QSE approach among Orange Guinea external service providers (2023)
In addition to reviewing the above documents, MIGA conducted virtual due diligence from March – May 2023, including calls with key Engie representatives. MIGA also conducted site visit to Orange Guinea Conakry’s office and site locations in April 2023. During the site visit, MIGA held meetings at the headquarters of Orange Guinea, reviewed the E&S management at the corporate level and its implementation in Guinea.
MIGA’s due diligence review considered the E&S management planning process and documentation for the Project 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.
Key potential 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
OGC has developed an Integrated Environmental and Social Management System (ESMS) and Occupational Health and Safety Management System (OHSMS) that are certified to ISO 14001 and 45001. As part of these management systems Orange Guinea has elaborated a detailed Health, Safety and Environmental (HSE) Manual that defines roles and responsibilities at all levels of the organization while highlighting all the procedures and controls in place to manage risks and impacts to the extent possible ensuring safe working conditions for the workers and communities. Several procedures have been developed for this purpose
Ø Environmental assessment of a project - POG138
Ø Identification of aspects, evaluation and control of environmental, Occupational health and Safety risks - MO059 / MO060.
Ø Identification, monitoring and control of legal requirements and other requirements applicable to environmental aspects - POG110
Ø Assessment of compliance with legal and other requirements applicable to environmental and health aspects Safety - POG111
Ø Internal Quality, Safety and Environmental Audit - POG006
Ø Waste Management Procedure - POG133/03
OGC has also developed Quality, Safety and Environment (QSE) Clauses that clearly define the requirements for service providers in terms of strict adherence to procedures, including identification and reporting of risks and incidents, wearing of required PPE, working at heights, waste management, training, and competencies of their personnel. Orange Guinea also offers training sessions to its service providers to strengthen their capacity in QSE management. At any time, Orange Guinea reserves the right to audit service providers to verify their compliance with its procedures.
Upon MIGA’s request, an independent consultant conducted an E&S review of Guinea and Guinea-Bissau in 2021, including site visits between January and April 2021. As stated by the consultant and confirmed by OGC, projects involving transmissions, telecommunications in general are not currently listed as being subject to an Environmental Impact Assessment process in Guinea. It is therefore understood that no prior approval, or permit, is required by the Guinean authorities for cellphone sites, and there are no required E&S legal steps. However, the situation is evolving with the Decree of May 10, 2023, modifying the decree 1643 of July 22, 2022, which classify projects including the telecommunication sector in categories based on their potential E&S risks, and which clarify the required permitting process for each category. These new provisions will come into force as soon as the implementing decree is published. Upon the publication of the implementing decree, OGC will engage with the Guinean Ministry of Environment to confirm the Project’s environmental classification in accordance regulatory requirements (ESAP item).
Nevertheless, as part of the Orange Guinea HSE management systems, E&S matters come into play during site construction, with contractors required contractually to implement Orange Guinea HSE requirements.
There is currently no evidence of formal E&S screening criteria during the site selection process. Orange Guinea has therefore committed to fill this gap by developing E&S criteria for its site selection process as per PS1 requirements. These criteria will be included in the existing ESMS and project level environmental and social management plans (ESMPs) (ESAP item).
Identification of Risks and Impacts
During the construction phase of the Project, key risks, and impacts include health and safety (H&S) risks intrinsic to construction activities such as physical hazards related to the installation of communication towers, working at heights, and electrical components including exposure to live electrical current. Pollution of water resources may arise at construction sites due to accidental spillage or leakage of polluting materials (fuel, paints, chemicals), with potential impacts on ecology.
During operations, key environmental and social risks include impacts on water quality from diesel spillages, waste management, generator noise, site security and access control, and potential magnetic field/radiation risks associated with the antennas, if any.
OGC will identify and manage key risks and impacts through the implementation of its ESMS and ESMPs
According to OGC organizational structure, Quality Control, Quality Assurance, Occupational Health & Safety, Environment & Social are under the Department of Audit Management and Quality, reporting to the CEO. The Department is adequately staffed with a headcount of 4 persons to manage the E&S and OHS issues associated with OGC. The Department is also supported by Orange SA and Sonatel through
the corporate group policies. A Health and Safety Committee has been put in place as a mandatory requirement per corporate directive from the headquarters in France.
Emergency Preparedness and Response
Fire extinguishers are strategically positioned at the company’s offices/shop/network sites. Data and server rooms are fitted with smoke detectors, fire alarms and sprinkler systems. The Data Centre is installed with a firefighting (hydrant) system. Fire drills are conducted bi-annually for all staff with the National Fire Force. Eurofeu Guinea is contracted the supply, verification, and maintenance of the Orange Guinea’s fire security system. OGC agreed to review the procedures to include process for identifying emergency situations, such as potential threats to the surrounding communities, and include risk mitigation procedures in its Emergency Response Plan (ESAP item).
Monitoring and Review
Monitoring plans for resource use, waste emissions, noise and air quality (for sites where generators are likely to be operating for lengthy periods) will be included in the operations ESMS (ESAP item). This will include monitoring procedures for key parameters and indicators to evaluate potential adverse social and environmental impacts. The ESMS will also identify responsible parties, timing, and reporting requirements. As part of this Project, MIGA will also require annual monitoring reports throughout the guarantee period, specifying E&S risks and impacts, management responsibilities, training, and monitoring (ESAP item).
Stakeholder engagement activities are informal. OGC agreed to develop a stakeholder engagement plan (SEP), given its importance to meet the requirements of PS1 on disclosure and stakeholder engagement (ESAP item). This will allow the Project to verify that the local communities are properly informed of the various site developments, especially in relation to land.
External Communication and Grievance Mechanisms:
Like OGC’s practice in relation to stakeholder engagement, external communication and grievance mechanisms are informal and limited in scope. OGC do have a Grievance Redress Mechanism (GRM) for E&S complaints informally established within their Legal department, but this is not yet formalized. Hence, OGC has committed to formalize the project level community grievance mechanism within the SEP and include procedures for the receipt, recording, and responding to grievances from the public (ESAP action item).
PS 2: Labor and Working Conditions
As of April 2023, Orange Guinea has 484 permanent employees, and 74 subcontractors’ workers.
Human Resources Policies and Procedures
OGC has a human resources (HR) policy that applies to all employees. This policy is based on the Labour Code of Guinea and the International Labor Organization standards. Orange Guinea is also aligned with Orange Group HR policy and procedures, including Equal opportunity, Sexual harassment, LGBT, Disability and complies with Guinea requirements. There is also a zero-tolerance policy, when it comes to violence with dismissal without warning. HR policy applies to contractors who receive an HR audit and periodic checks.
Working Conditions, Management of Worker Relationship and Terms of Employment
The terms and conditions of service constitute a contract of employment between Orange Guinea and the employees. Each employee is expected to sign acceptance of these conditions when starting work. Each
employee is provided with a copy of the conditions. All employees are full-time, with contracts specifying the rights and responsibilities, compensation, and benefits, in line with Guinean labor law and MIGA PSs. The company has given a firm undertaking to retain all local staff based on performance and adherence to its code of ethics.
A comprehensive and times stated employee Grievance Redress Mechanism (GRM) is in place, including an online portal. This GRM is clear and permits anonymous complaints.
Orange is unionized with 400 out of the 484 permanent staff (83%) members of the union A Collective Bargaining Agreement is agreed every three years. The last one was agreed in January 2023. All employees benefit from the agreement, equal terms for union and non-union members. No current or outstanding Labor court cases were flagged. In addition, no retrenchment has occurred, and none is envisioned as the company is in a growth phase.
Orange Guinea has put in place a Welfare Committee comprising of staff representatives who can be the voice of the company and receive suggestions from staff. The company has also put in place a structured internal communication with at least three meetings per year and an open-door policy in the HR department.
Non-discrimination and Equal Opportunity, Protecting the Work Force
The Projects confirmed that their policies comply with national requirements and that both are equal opportunity employers. Orange Guinea recognizes its common law duties to provide a safe and healthy working place for all employee and lawful visitors.
Child and Forced Labor
Orange Guinea does not employ forced labor or children as consistent with national law.
Workers Engaged by Third Parties
OGC outsources construction of new tower sites to third party companies with E&S management systems. OGC provides precise specifications to contractors for durable construction of towers. The Company includes terms in its agreements with contractors requiring E&S management by the contractors, health and safety measures of workers and monitors compliance with those terms. Contract terms provide for termination of contracts in the event of noncompliance with environmental and social requirements. All suppliers are required to comply with Orange Supplier Code of Conduct.
Occupational Health and Safety
Key issues for telecommunications technicians include higher risk of exposure to electromagnetic fields, due to their proximity while working on cellular antennae or related equipment, and electrostatic discharge, and working at height on the towers. OHS management is practiced with provision of personal protection equipment (PPE) and use of warning signage.
The procurement of equipment for the Project is covered by the corporate level Orange Sonatel procurement strategy. 80% of all purchases in relation to technical and IT equipment are through the corporate level including solar panels. The solar panel supplier is based in Senegal and has been approved at the corporate level. The EPC is responsible for the installation of panels. Back-up diesel generators, lead-acid and lithium-ion batteries are also procured at the corporate level under the procurement strategy.
PS3: Resource Efficiency and Pollution Prevention
OGC has a strategy in place to solarize data centers and telecommunication towers through installing solar panels and has already reached 67% of solarization. OGC currently consumes water mainly for concrete bases during construction and cleaning solar panels during operations.
In the upgrade of the OGC ESMS, water use will be a key performance indicator which the EPC and O&M contractor will be required to keep track of. Furthermore, OGC will require the EPC and O&M contractors to develop a water management plan to evaluate alternative cleaning methods to minimize the amount of water used, water quality testing and water quantity estimates (ESAP item).
Greenhouse Gases: Through the solarization of data centers and telecommunications towers, it is expected that the businesses will achieve a major overall reduction in Greenhouse Gas emissions (GHGs). GHG emissions during the construction and operations phase are expected to be predominantly associated with the use of fuels such as in diesel generators, vehicles, and machinery. The total GHG emissions is approximately 12 tCO2eq/year, significantly less than 25,000 tons CO2e. OGC will be required to report to MIGA if the total GHG emissions exceeds 25,000 tons CO2e.
The main pollution risks of OGC operations are related to the use of generators for back up electricity supply. As the electricity infrastructure in Guinea is unreliable, company operations rely on diesel generators and batteries. However, Orange Guinea has a strategic plan for new sites to be 100% solar powered. The company has already achieved around 60% of its target and is ranked 2nd within the regional group of 17 countries. Diesel tanks are above ground and placed on raised concrete bases and are bunded to reduce the risk of fuel leakage. In addition, all sites are monthly visited by passive network operation and maintenance contractors and any environmental, health and safety issues identified are reported to OGC to implement corrective measures.
The major source of noise generated by the project is from the back-up diesel generators. There may be some noise created and dust generated during installation of the towers and equipment. However, the duration period for construction is quite short and activities will be limited to daylight operations only. In addition, the generators are sound insulated to minimize noise levels. Nuisance will be further minimized through measures including watering of the construction areas and effective preventative maintenance established to ensure all construction equipment is maintained in good working order. The service provider IPT Powertech owns the energy supply equipment and provides energy under an Energy Service Company contract. The towers and other equipment are owned by Orange.
Waste Management and Disposal
Project construction and operation will generate hazardous and non-hazardous waste. OGC has developed and implements a waste management procedure (POG133/03). This defines the identification, reporting and management of waste generated by the activities in the different OGC sites: acid lead and lithium batteries, broken solar panels, used cartridges, neon light bulbs, plastics and tires, biomedical wastes, cable, electronics, aerosol cans, paints and solvents. Waste streams have been identified with proposed handling, storage, and disposal methods for each stream. OGC will update its waste management procedure to ensure that the management and disposal of broken and ‘end of life’ panels is included and in line with MIGA’s PS3 requirements and respective national laws (ESAP item).
Waste/used oil from the repair of machinery and vehicles is collected and disposed of by the engineering contractors in charge of servicing and maintenance.
Orange Guinea has signed a contract with Centre de Gestion des Dechets Industriels (CEGEDI) an authorized local service provider for the collect, sorting, recycling, and disposal of its remaining wastes. As such, used batteries, predominantly lead-acid for reasons of cost and ability to recycle, are expedited in Senegal for recycling by Gravita, an authorized recycler. An audit in 2021 by Orange Guinea at the service provider waste storage and sorting site in Guinea highlighted poor management of batteries from an HSE perspective. Lithium-ion battery use is small, started only in 2022, and is limited to city sites that are grid connected. Orange stated that there is no recognized safe waste Li-ion battery handling option in the country.
Orange Guinea will ensure handling, storage and disposal of hazardous waste will reflect GIIP (Good International Industry Practice (ESAP item).
Guinea is vulnerable to a range of climate-related physical hazards, including extreme temperatures and flooding. According to climate projections from the World Bank and UNFCCC, Guinea is likely to experience more frequent and intense heat waves in the coming decades, which could pose significant challenges to the telecom infrastructure in the country. For telecom towers in Guinea to be resilient to climate change impacts, several measures are being taken by the client. These include site selection studies to locate towers in areas that are less susceptible to climate hazards, such as high winds and flooding. Design and construction of towers also considers using reinforced materials, such as steel frames for mounting solar panels, and elevating towers in flood-prone areas, where possible and applicable. Installing temperature sensors and fans to regulate the temperature inside battery systems is another mitigation strategy that the client is implementing to make the equipment climate resilient; a threshold for temperature is suggested by the manufacturer that is monitored by the client, which in most cases is set at 35 degrees Celsius. This helps to avoid getting sensitive electronic equipment damaged due to extreme heat and cause outages. Regular maintenance and monitoring by Operations and Maintenance (O&M) operator, as per client’s requirement, would be needed to enable the towers and related equipment to remain resilient over time, and backup power and communication systems could be further explored during sites expansion to provide reliable service during climate-related disruptions.
PS4: Community Health, Safety and Security
Community health and safety risks
Telecommunication towers are built in both urban settings, mainly on top of buildings and in rural locations. In urban areas tower height is typically 30 m and can reach a maximum 60 m in rural sites, though there are no height restrictions from the authorities. Tower height determination is based on connection to data centers. Warning beacons are placed on towers for warning aircraft, and they are lit at night.
Community health and safety issues identified during the construction phase include noise, vibration and increased traffic. During operations, hazards associated with telecommunications projects will include structural and site access issues, oil/diesel spillages, accidents, and electrical faults. Risks are minimized by restricting access to the sites and to hazardous equipment through physical security (e.g. fencing) and 24-hour security, and anti-climbing devices are fitted to masts and towers. Sites are fitted with fire extinguishers and security guards are trained in their use. OGC will ensure that the fire extinguishers are functional, well maintained, and are regularly inspected. Cell tower structures and components are
designed and installed according to GIIP, considering the potential frequency and magnitude of natural hazards. OGC is committed to develop a Community Health and Safety Plan as part of the overall ESMS to inform communities about Project’s risks, including potential magnetic field/radiation risks associated with the antennas. (ESAP action item).
Security Plan /Security Personnel
Currently, unarmed site security guards are provided by a specialist company DTP, that is contracted by the main civils contractor (Betelcom), therefore they are not directly employed by Orange Guinea. Remote sites are fenced off to prevent unauthorized access. In the event of a security incident, guards must call their management. No security incidents were highlighted as of April 2023, but material theft attempts occurred during construction. There is no evidence of a site security management plan or guards’ recruitment criteria and details of the required training. Therefore, OGC committed to assessed site security risk and develop site management plans to be consistent with the requirements of PS4 (ESAP action item). The risk assessment and management plan will ensure that safeguarding personnel and property is done in accordance with relevant human rights principles and to avoid or minimize risks to the affected communities.
The documentation listed below is available electronically as PDF attachments to this ESRS at www.miga.org.
The above documentation is also available for viewing at the following locations:
Contact name: Amadou Birama BADIANE
Position: Directeur Financier et Comptable E-mail: email@example.com
Address: Boulevard du Commerce – Almamya
Kaloum – BP 4549
Conakry – Guinee
Broad Community Support is not applicable for this Project.
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: firstname.lastname@example.org