Orange Telecom Project in Liberia

MIGA has been requested by Orange Cote d’lvoire Participations (“OCIP”) (“Guarantee Holder”), in Cote d’lvoire to provide a guarantee to cover its equity investments for acquisition of an existing telecom company and for expansion of telecom operations in Liberia (the “Project”). The Project involves the acquisition of Cellcom Telecommunications Inc (“Cellcom Inc”) by OCIP (OCIP is a wholly owned subsidiary of Orange Cote d’lvoire (“OCI”)). The requested guarantee is against the risks of Expropriation and War and Civil Disturbance, for a period of up to 9 years. Orange Liberia (OLIB)(formerly known as  Cellcom Inc)  is the Project Enterprise (“PE”) responsible for the provision of telecom services and investment for expansion of Orange telecom operations, which includes: (i) Operations of existing 388 telecom towers (approx. 68 telecom towers that had been constructed in 2021) ii) Construction of additional 444 telecom towers (from 2022-2025), (iii) Construction and installation of 850 km fiber optic cable (aerial and buried fiber optic cable installations) from 2022-2025 (earlier a total of 421 km had already been constructed as of end 2021) (iv) Information Technology (IT) and digital transformation (App, Web, Customer Relationship Management (CRM) technology, Digital Inside, Micro-services Layer, Identity and Access Management (IAM), Content management (CMS) software, workflow management, data, analysis, Orange Money Platform & Application Programming Interface (API) management  etc. ) in Liberia.  

The PE will be responsible for tower construction (including civil works, radio signal transmitters, transmission deployment tower, and transmission maintenance). Huawei and Nano technology  are the EPC contractors responsible for the fiber optic cable construction. Sagemcom will be the EPC and Operations and Management(O&M) contractor responsible for the power supply to Orange towers, power maintenance and provision of security during construction and operations. Sagemcom is also an EPC & O&M contractor of an existing MIGA supported project in Liberia managing power deployment for Orange telecom towers. 

The Project modernization program involves replacement of old power equipment with new, more efficient, and reliable equipment. The EPC and O&M contractor will deploy hybrid equipment such as solar photovoltaics (PVs), batteries, generator sets (gensets), and related electrical equipment for new and operational telecom sites owned by Orange in Liberia.  In order to supply power to the towers, the EPC and O&M contractor will install solar photovoltaics (PVs) powered batteries, generator sets (gensets) with the aim of reducing diesel consumption by upgrading and replacing exiting batteries and gensets to energy efficient options and other electrical equipment on approximately 882 telecom sites.

The Project is categorized as Category B and is expected to have potentially limited adverse Environmental and Social (E&S) risks, generally project-specific and readily addressed through mitigation measures. The key E&S risks and issues associated with the Project during construction and operation  are: (i) The PE’s E&S capacity (including hiring qualified and competent  E&S personnel) to manage E&S risks (including adequate contractor oversight and management), (ii) labor and working conditions (including occupational health and safety),  (iii) hazardous and solid waste management and disposal (including oils spills management), (iv) community health and safety, and  (v) security management.

While all Performance Standards (PS) 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. Land will be acquired through negotiated lease agreements between PE and the landowners . The land leasing process will entail signing commercial agreements with landowners in urban areas. In rural areas, mutual lease legal agreements will be signed with communities.

There are no impacts related to PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7 Indigenous Peoples and  PS8 Cultural Heritage, therefore these are not applicable. The PE will however be required to develop a  chance finds procedure if archeological/ cultural resources are identified during construction.

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)

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

• Environmental Social Management Framework for (ESMF) for Tower Construction , Maintenance and Decommissioning  (August 2020)
• Human Resources (HR) Policies and HR Handbook ( June 2017)
• Environnemental Audit Corrective Action Implémentation & Vérification Report (August 2020)
• Waste Management Plan (August 2020)
• Supply Contractual Agreements for Orange Liberia (December 2019).
• Transfer Agreements to Energy Optimization agreements for the network of Orange Liberia (November 2020).
• Orange Project Environmental Permits (July 2021)
• Land lease contractual agreements

In addition to reviewing the above documents, MIGA conducted an ESDD site visit in August 2022, which included meetings with Orange senior management, project managers, and technical teams and the EPC and O&M contractor team. MIGA also visited five randomly selected telecom towers. The telecom towers were not connected to the grid but powered by a combination of energy sources such as gensets, batteries and solar. For the 5 sites selected, some of the telecom towers were installed within private buildings in residential areas in Monrovia and some in rural areas at the outskirts of Monrovia. 

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:

The PE has in place an Environmental Social Management Framework (ESMF) for tower construction, maintenance, and decommissioning. However, in reviewing the documents, the following gaps in line with the PSs were identified: lack of clear E&S organizational structure and capacity, E&S policy, E&S procedures such as occupational health and safety, emergency preparedness and response plan among others. Therefore, the PE will be required to update the Project specific ESMS in line with Liberian laws and MIGA PSs, as well as applicable WBG EHS guidelines for construction and operations per the ESAP.

The ESMS will include the following items: (i) E&S Policy; (ii) E&S organizational capacity including roles and responsibilities; and (iii) E&S management plans and procedures including but not limited to emergency preparedness and response plan, occupational health, and safety (OHS), waste management plan (including management of hazardous and non-hazardous waste), land acquisition framework, stakeholder engagement plan, and grievance redress plan, among others.

The Project EPC and O&M contractor has developed an ESMS for the project aligned with the EPC and O&M contractor ’s 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).

The EPC and O&M contractor contract is a key tool for ensuring compliance with the Projects EHS requirements. The PE will include specific OHS requirements and E&S risk management clauses in the agreements with the EPC and O&M contractor. These clauses will include guidance on managing Project E&S risks such as handling hazardous materials and hazardous waste management, pollution prevention, working conditions and workers safety, and community health and safety. In addition, the EPC contract will include requirements to comply with MIGA’s PSs as well as a provision of E&S organizational capacity per the ESAP.

Policy:

An E&S policy will be developed and implemented as part of the ESMS update, to guide the Project to achieve sound environmental and social performance in line with MIGA PS 1 per the ESAP.

Identification of Risks and Impacts:

Per the national laws and regulations in Liberia, the PE is required to prepare an Environmental and Social Impact Assessment (ESIA) for telecom tower projects and obtain relevant environmental permits. Per national legal requirements, the PE obtained an operational permit granted by the Liberian Environmental Protection Agency (EPA) for the existing 320 telecom towers across Liberia. The permit is valid until January 2023. As required by law, the PE will renew the operational permit prior to its expiration.  However, for the additional 444 sites that the PE plans to construct (from 2022- 2025),  the PE will be required to develop  the ESIA for these additional  sites, obtain the environmental and operational permits for sites construction and establish measures to implement and comply with the permit requirements in line with national laws and MIGA’s PS requirements per ESAP.  As part of MIGA’s requirements, the PE will ensure that environmental, social, health and safety risks and impacts and the Project permit requirements are captured in the Project ESMS.

Liberia is recognized as highly vulnerable to climate change and impacts such as warming temperatures and heavy rains are already being observed across the country. Climate change projections for the country suggest that the intensity and frequency of extreme weather events such as heatwaves, floods, droughts and wildfires will continue to increase; chronic climate hazards such as sea-level rise, water scarcity and land erosion are also anticipated to worsen.   

The expansion and modernization of telecom towers will cover broad and heterogenous regions in Liberia. As such climate change risks and resilience measures will be highly specific to reflect the characteristics of the site and its surrounding area.  Per the ESAP, the PE will implement a climate risk management framework which will be used to conduct climate risk screening for prospective telecom towers and to identify the extent to which climate resilience measures are required.  The framework will consider if climate change risks are expected to materially impact the performance of the telecom towers, lead to adverse effects to workers, or exacerbate existing climate risks for adjacent communities.

Management Programs:

An Environmental Social Management Framework (ESMF) for tower construction, maintenance, and decommissioning was prepared for the Project by the PE. The framework describes the Environmental and Social Management Plans (ESMPs) to be develop for the construction, operation, and decommissioning phases of the Project. The ESMPs that are pending development include air quality monitoring, noise, water management, waste management , occupational health and safety management plan, stakeholder engagement plan, community health, safety management plan and security management plan, to mention a few. The PE will be required to develop the Project ESMPs in line with MIGA’s PSs and WBG EHS guidelines for the construction and operations phases per the ESAP. The ESMP will  be part of the ESMS and will also include  the frequency of monitoring, along with the performance indicators and the responsible entity such as the EPC and O&M contractor.

Organizational Capacity and Competency:

The Director of Legal Regulatory and Government Affairs and Chief compliance affairs currently oversees the PE’s E&S risk management and the EPC and O&M contractor operation including E&S risk management. To support the Director of Legal Regulatory and Government Affairs, the PE will be required to appoint an experienced and qualified Health Safety and Environment (HSE) officer to manage the Project E&S risks  in line with the MIGA PS1 requirements during the Project construction and operation phases per the ESAP. The HSE officer will be responsible for the implementation of the ESMS and related plans and procedures including monitoring and reporting.

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 has appointed a qualified HSE Manager to manage E&S risks and coordinate with field supervisors on HSE matters.

The PE will share the E&S requirements, measures, and standard operating practices stipulated within the ESMPs through induction training. The PE will also ensure that all 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

Emergency Preparedness and Response:

As part of the ESMS, the PE will develop an Emergency Preparedness and Response Plan (EPRP) to address the telecom towers risks including fire and other external emergencies during the Project construction and operations phases per the ESAP.

During the site visit, MIGA observed that, some of the Project sites did not have functional fire extinguishers. As a result, the PE will be required to equip all sites with regularly inspected and well-maintained firefighting equipment per the ESAP. Additionally, the PE will require the EPC and O&M contractor to train staff, in particular the security guards (due to their continuous presence on site) on how to operate the fire extinguishers in case of fire.

Monitoring and Review:

The PE has contracted an Environmental Consultant Agency to support on the E&S risk management and to monitor the project E&S performance. As indicated above, the PE is in the process of updating  their ESMS that will include a formal process to monitor and review E&S performance of the project. Once the ESMS is developed and monitoring process established, the PE will undertake regular on-site E&S monitoring of the implementation of key E&S plans and programs during the Project construction and operation phases in line with MIGA PS1 requirements. The PE will also oversee the EPC and O&M contractor and ensure that they undertake regular on-site E&S monitoring of  key E&S aspects including: (i) solid and hazardous waste materials management, (ii) OHS, (iii) life and fire safety (iv) equipment maintenance, (iv) energy use, and (v) water usage among others, and implement key E&S plans and procedures. The PE will also require that the EPC and O&M contractor systematically report the findings to the PE’s Management team in in a timely manner and will follow up on the identified correctives actions and that they are implemented effectively and are well documented.

MIGA will also require periodic Annual Monitoring Reports (AMR) from the PE  that evaluate E&S performance against MIGA’s E&S requirements and will include sections on E&S risks and impacts, updates on development effectiveness indicators throughout the guarantee period.

Stakeholder Engagement:

In line with local legislation, permit conditions and PS requirements, the PE is responsible for active engagement with external stakeholders. Stakeholders in this regard include people that might be affected by the Project activities (resulting in noise and air pollution etc) during construction and operation phases. Per MIGA review, the PE is currently developing  the stakeholder engagement plan. Therefore, PE will be required to develop a Stakeholder Engagement Plan (SEP) in line with the requirements of MIGA PS 1 for the construction and operation phases per the ESAP.

External Communication and Grievance Mechanisms:

The PE, 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.

The PE is currently formalizing the Project specific Community Grievance and External Communication Mechanism and will develop one for construction and operations in line with the requirements of MIGA’s PS1 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.

Given that the EPC and O&M contractor are active on site and are likely to be the receiver of community grievance, the PE shall require the EPC and O&M contractor to report any community related grievances directly to PE for response and action.

PS2: Labor and Working Conditions

The PE  plans to have approximately 13 employees dedicated to the project . Out of 13 employees , 12 will be men and 1 will be a woman.  

Huawei and Nano technology the EPC contractor responsible for the fiber optic cable construction will have 150 and 100 employees respectively. Sagemcom (EPC and O&M contractor) will have 40 employees during construction and operation.The workforce comprises of engineers, technical specialists, and various management functions. The PE will prioritize the recruitment of Liberian nationals.

Working Conditions and Management of Worker Relationship:

The PE has established Human Resource (HR) policies and procedures in line with the national requirements for the Project during construction and operation phases. The EPC and O&M contractor have also established the HR policies and procedures. The PE will require the EPC and O&M contractors to update and align its HR policy and procedures with the PE’s HR policies and procedures, national requirements and MIGA PS 2 per the ESAP.  In addition, as part of the HR policies and procedure, the PE will require the EPC and O&M contractors to develop a Project Code of Conduct for all employees and subcontractors during construction and operation phase per the ESAP. The EPC and O&M contractor’s HR policies will be applied to their workers and subcontractors and the EPC and O&M contractor shall ensure that all direct and subcontracted workers  are aware of its content.

The PE shall ensure that all employees sign the term of employments with the EPC and O&M contractor or their respective subcontractors. The PE’s  HR policy and procedures stipulates that the terms of employment, such as wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick leave, maternity leave, bereavement leave, vacation and holiday, health insurance, disability benefit, death benefit, and end of service benefits are established according to national labor regulations and PS2 requirements. During induction, the new hires will be made aware of the terms and conditions of their employment as part of the hiring package. Working conditions including health, safety and security, employee termination, prohibition of forced or child labor, disciplinary actions, workers’ rights and obligations, employer’s rights and obligations will also be included in the HR policy and procedures.

The Code of Conduct will be updated to include rules of interaction with customers and communities and reflect respect for local beliefs and customs. In addition, the code of conduct will include provisions related to zero tolerance towards  sexual harassment, sexual exploitation and abuse and gender-based violence (GBV) per the ESAP . In addition, the PE will require the EPC and O&M contractor to develop a training plan (to include HR policies and procedures) and provide to workers per the ESAP.

The PE, EPC and O&M contractor have in place workers’ grievance mechanism. Workers will be informed of the grievance mechanism as part of the training plan. In addition, the 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.  

Currently the Project security officers guarding the Orange telecom towers are hired by the EPC and O&M contractor’s subcontractors to work 12-hour shifts. During MIGA site visit,

some of the security officers raised complaints related to payment. Therefore, the  PE will require the EPC and O&M contractor to conduct a labor audit on the security companies to assess the  security officer labor and working conditions (including terms and conditions, wages, leave, health insurance and working hours etc.) to ensure it in in line with the PE’s HR policies/procedure, national laws and MIGA PS2 requirements per the ESAP.  In addition, during the site visit,  MIGA observed that the some of the old sites do not have a security guards shelter facility  and basic amenities  to be used by the security guards such as toilet facilities, water, and night lights. Therefore, the PE will be required to provide security guard’s shelter facilities for old sites and ensure that they are in good condition, and they have access to basic facilities (such as basic toilets, water,  and night light) and construct shelter facilities for the new sites per the ESAP.

Protecting the Work Force:

The PE is 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 PE’s  HR policy prohibits the use of any form of forced or compulsory labor. In addition, and ensure to include in EPC and O&M contractor’s HR policies and procedures clauses that prohibit sexual harassment and gender-based violence in accordance with the respective national labor laws and MIGA’s PS2 requirements as detailed in the ESAP above.

On child and forced labor, the PE and EPC and O&M contractor do not employ forced labor or children and have committed to enforcing this requirement per the national labor laws and MIGA’s PS2 requirements. The PE and EPC and O&M contractor will be required to screen all employees to ensure they meet the legitimate age to work as stipulated in the Liberian national labor laws. 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 key OHS risks for the Project 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.

During the site visit, MIGA discovered that OHS management procedures are yet to be established for the new planned sites. Therefore, PE will require EPC and O&M contractors to develop 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; and vii) incident investigations and reporting system and intervention measures (medical surveillance programs and first aid etc.). 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 PE has developed policies and procedures related to Coronavirus Disease 2019 (COVID-19). The PE will ensure to implement this procedure and plans in line with Liberian Ministry of Health and World Health Organization (WHO) guidelines to minimize the spread of COVID-19 to  workers, customers, and communities.

Finally, the PE 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 Manager 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 PE 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 PE 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 Project 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 diesel, generators, batteries, meters, cables, inverters, and switches) to be used by the Project will be manufactured mainly in France and  China.

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency:

During the Project construction and modernization phase, the project  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 is expected to be approximately 817 m3/year. During Operations , the estimated water consumption is expected to be approximately 6803m3/year . 

The EPC and O&M contractor have already established the  Project Water Management Plan (WMP) and will be required to implement it effectively. 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 PE.

Through the modernization of the energy systems, including implementation of solar PV solutions where grid electricity is unavailable, it is expected that the businesses will achieve a major overall reduction in Greenhouse Gas emissions (GHGs). GHG emissions from the Project during the construction and operations phase are expected to be predominantly associated with the use of fuels such as in gensets, the EPC and O&M contractor trucks, on-site equipment, and machinery. The PE will be required to report to MIGA if the total GHG emissions exceeds 25,000 tons C02e.

Pollution Prevention:

The Project  modernization program involves replacement of old power equipment with new, more efficient, and reliable equipment. The EPC and O&M contractor undertook a planning process in 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.

Given that PE’s telecom sites are all not connected to the grid, they will require a combination of gensets and solar to power the towers. Usage of diesel gensets will locally impact air quality, gensets will be required to be in bunded areas to ensure containment. PE will require the EPC and O&M contractor to implement measures to manage fuel usage, spill management and storage. As PE 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 PE will require the  EPC and O&M contractor to 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 Project solid waste generated will mainly consist of and include paper, wood, and scrap metals. The Project EPC and O&M contractor have established a waste management procedure(solid and hazardous waste). However, per MIGA review during the site visit, gaps exist in some process and  the implementation of the WMP was lacking. Therefore, the PE will require the EPC/O&M contractor to update the waste management plan to include a clear process how solid waste generated from each site is stored on site, segregated, and disposed to an approved landfill by a licensed vendor in line with MIGA PS3 requirements per the ESAP.

For Hazardous waste, MIGA observed that, all the  project hazardous waste is currently managed by the EPC and O&M contractor .The  EPC and O&M contractor is collecting all the hazardous waste (including fuels, lubricant, battery acids (sulfuric), fuel filters, used oils and used batteries) and storing them in their Monrovia’s office premises in a secluded area. The EPC and O&M contractor has engaged a licensed vendor to dispose of the hazardous waste to an approved landfill. The PE will need to review the permits/license of the vendor disposing of the hazardous waste on behalf of the EPC and O&M contractor    to ensure they meet the national and MIGA requirements.  Additionally, the PE will require the EPC and O&M contractor to develop a hazardous waste tracking and documentation system/mechanisms to ensure that the hazardous waste is disposed by a licensed vendor to an approved facility/landfill site per the ESAP.

PS4: Community Health, Safety and Security

Community Health and Safety

As part of the ESMS, PE 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 (ESAP). 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. PE will ensure that the fire extinguishers are functional, well maintained, and are regularly inspected.

As part of the HR procedure,  the PE will implement a Worker Code of Conduct which will also apply to all contractors and 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 and Harassment (GBVH). The PE  will commit that all complaints of sexual harassment and GBVH will be seriously investigated, and disciplinary action will be taken per the ESAP. On potential for increased traffic risks and impacts to the communities, it is expected that the PE will not cause any disruption to communities as the PE will not transport any heavy loads on the roads to lessen potential for traffic or road blockages.

Security Personnel

The Project sites and assets are secured by fencing, controlled access, and guarded 24 hours per day by security guards. The PE has contracted the EPC and O&M contractor  to manage the security of the sites which is subcontracted to private security companies in Liberia who manage security at the sites. The PE will require the EPC and O&M contractor to  confirm and verify that the selected private security companies have obtained necessary national licenses to operate as a private security company and abides by regulations established by the Liberian government authorities per the ESAP.

The PE will require the EPC and O&M contractor to develop and implement a Security Risk Assessment and a Security Management Plan (SMP) for the new sites  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 EPC and O&M contractor will train security workers on the appropriate use of force and conduct toward workers and nearby communities. The PE will also require security workers to act within the respective applicable national laws. PE 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.

No documents are attached.

Project Contact Information

Contact : Supu H. W. Cole Sr

Position: Dir. of Legal Regulatory and Government Affairs and Chief compliance officer

E-mail : supu.colesr@orange.com

Address: Haile Selassie Avenue, Capitol Bye Pass Monrovia, Liberia

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