Orange Guinea Bissau SA.

A.  Project Description

MIGA has been requested by Sonatel SA (Sonatel Group) to proceed with underwriting a guarantee to cover Orange Guinea Bissau (OGB, the Project Enterprise) 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). OGB was created in 2007 and is 89.85% owned by the Sonatel Group. OGB provides mobile voice, internet and data services along with mobile money services in Guinea-Bissau. Its mobile subscribers base increased by 110% over the last 5 years and accounted for 1.3 million customers in 2022, representing 60.9% of the market.

Sonatel Group requested that MIGA’s guarantee cover 90% of their equity investment of  EUR€26.5 million of existing and new investment in the form of equity and retained earnings for up to 4 years which will be used to support its existing telecom and mobile money operations, enable further expansion, renovation, upgrades and introduction of new services owned, leased and operated by OGB  over the period from 2022 to 2026. As part of its network expansion, OGB almost doubled its number of antennas from 160 antennas in 2020 to 310 antennas in 2021. From 2022 to 2026, OGB is planning to modernize the network, further roll out 4G in cities, expand coverage in the rural areas, further solarize sites (currently 73% of all sites in the country are solarized), further secure the core network and roll out 5G. As the Project is aimed at upgrading and expanding existing and future assets involving the telecommunication network, infrastructure, and services in Guinea Bissau, it is anticipated that these works will have limited environmental and social (E&S) impacts.

The Project is categorized as Category B according to MIGA’s Policy on Environmental and Social Sustainability (2013). The Project will have limited, site-specific adverse E&S risks, and/or impacts that can be readily addressed through mitigation measures and management plans. 

Key E&S risks are related to development and implementation of MIGA PS-compliant Environmental and Social Management Systems; E&S capacity; contractor management and related occupational health and safety issues; internal and external grievance management; community health and safety, in particular emergency response; hazardous and non-hazardous waste management and solar supply chain risks.  

E&S impacts will be managed through the development and implementation of the Orange Guinea Bissau ESMS and site-specific Environmental Management Plans (EMPs). Operational risks are related to contractor management and labor issues; occupational health and safety risks; grievance management and hazardous and non-hazardous waste management. Contextual risks are related to broader security risks in relation to Guinea Bissau that the Project is located in and will be addressed in the updated Project-level security management plans. 

While all Performance Standards are applicable to this investment, based on our current information, the investment will have impacts which must be managed in a manner consistent with the following Performance Standards: 

• 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, OGB will not select those sites. PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources is also not applicable as potential impacts on biodiversity were not identified. No communities of Indigenous Peoples as defined in PS 7 were identified in the Project area of influence and therefore PS 7 is not triggered. No sites of cultural/historical value were identified and PS 8 Cultural Heritage does therefore not apply. 

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 considered applicable. 

Other relevant guidance includes: 

• Good Practice Handbook: Use of Security Forces: Assessing and Managing Risks and Impacts (2017) 
• Good Practice Note: Managing Contractors’ Environmental and Social Performance (2017) 

The following documents were reviewed by MIGA:  

• Cartography elaboration procedures (2023) 
• Monitoring and measurement procedures (2023) 
• Code of Ethics 
• Activity Report CSR (2022) 
• Earth Systems: Analysis of Environmental & Social Gaps and Environmental and Social Action Plan (2021)  

In addition to reviewing the above documents, MIGA conducted a site visit to Orange Guinea Bissau’s Head Office and site locations in April 2023. During the site visit, MIGA held multiple meetings with key E&S staff and management, and regulatory authorities. In addition, MIGA met with contractors, security contractors and community members and landowners.  

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 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: Environmental and social risks are currently mitigated through the corporate level Orange Sonatel ESMS that is certified and compliant with International Standard for Quality Management Systems (ISO 9001).Per government requirements in Guinea Bissau, project level Environmental Management Plans (EMPs) are required for all cellphone tower sites to be approved by the Ministry of Environment (MoE) and these will be developed by an external consultant and shared with MIGA (ESAP action item). As a way of connecting the corporate level ESMS and the project level EMPs, a project level ESMS, in accordance with MIGA PS1, will be developed and implemented (ESAP action item).   

E&S risks are also addressed through OGB’s site selection process and approval for permits which occur after the EMP is approved by MoE.   OGB conducts the site selection process which includes a site survey, engagement with local community civil society organizations, technical design of the Project and land negotiation. Furthermore, OGB will develop a site screening procedure which details these steps and screens out high E&S risk items such as biodiversity, land acquisition, indigenous peoples and cultural heritage (ESAP action item). OGB must hold a site visit with representatives from Ministry of Environment (Autoridade de Avaliação Ambiental Competente) prior to agency approvals for permits to construct and operate.    

Policy: Orange Sonatel’s Quality, Environmental, Health and Safety Policy provides an overall framework Orange Sonatel’s activities, including those of its subsidiaries and contractors. The policy is communicated to employees when they are appointed, and during induction and regular training and awareness events.  

Identification of Risks and Impacts: OGB will identify and manage key risks and impacts through the implementation of project level EMPs (ESAP action item). The key E&S risks identified relate to construction or upgrading works for the telecommunication towers at the various sites: contractor management; occupational health and safety issues; and community health and safety, in particular emergency response. As a result, these E&S risks and impacts, amongst others, will be managed through the development and implementation of the OGB ESMS (ESAP action item). Furthermore, as part of the ESAP, the EMPs will be reviewed by MIGA. During operations, risks may include tower failures and collapse, unauthorized site access, road safety and Electro Magnetic Fields (EMF) exposure, and OGB will apply operations E&S procedures and practices included in its ESMS (ESAP action item). OGB stated that this Project will only include passive (amplifiers) antennas which are not associated with significant EMF exposure and that a study completed in 2021 confirmed that potential EMF are within regulatory standards. 

Management Programs: Although there is a corporate level Orange Sonatel ESMS in place, a project level OGB ESMS will be developed to manage and mitigate E&S risk accordingly. In addition, to procedures within the ESMS will provide detailed manuals for each topic and include: impact assessment and permitting; waste management; emissions control; water management; biodiversity; workers’ health and safety; monitoring and management of EMF; managing contractors; monitoring and reporting. Furthermore, the requirements of the standards will be in line with PS1, and will include a number of items such as Health, Safety & Environment policies, hazard identification and risk assessment, health and safety standards, environmental mitigation measures, etc. 

From a legal perspective, OGB will include E&S performance conditions in legal agreements with contractors, encompassing the requirements of Guinea Bissau regulations and corporate level Orange Sonatel’s policies. Indeed, OGB has committed to submit to MIGA all E&S construction related plans and mitigation measures within six months of contract signing (ESAP action item). Furthermore, OGB has committed to establishing internal and external compliance monitoring and reporting procedures during the construction/equipment replacement and operations phases at the subproject level that are consistent with PS1 (ESAP action item).  

Organizational Capacity and Competency: OGB will appoint a responsible and competent E&S manager to manage and mitigate risk through the Project life cycle (ESAP action item). Currently, responsibility for E&S risk management is split between the Technical Manager, Projects Manager and Site Security Manager.  Occupational health and safety are under the responsibility of the Technical Manager and Site Security Manager whereas, construction of new sites falls under the responsibility of the Projects Manager. Contractors are used for both construction and operations and maintenance phases of the Project. With construction typically taking place over a 60-day period and consisting of base and tower erection (30m to 50m in height); equipment and radio/cell system installation; and energy supply. The operations and maintenance contractor will then visit once a month to check batteries, clean solar panels and conduct any repairs.  

In addition to the appointment of the E&S manager, OGB’s ESMS will include E&S training procedures and content including an on-boarding program adopted to the position, mandatory training on the ESMS, development programs for technical staff and specialists, and competency and certification requirements for staff involved in work with specific occupational health and safety risks (ESAP action item).   

Emergency Preparedness and Response: Emergency Response Plans (ERPs) for the Project will be in line with Sonatel policies, Guinea Bissau regulations and consistent with the requirements of PS1 (ESAP action item). Risks identified in the ERPs will include fire, electrocution, flooding, roles and responsibilities, description of emergency capacity, training and drill requirements, communication procedures and documentation and reporting of incidents.  

Monitoring and Review: OGB’s ESMS will detail how both internal and external monitoring will be carried out verifying compliance with regulatory requirements and internal procedures. External monitoring at OGB will be incorporated within the EMP which requires monitoring of various impacts including cost, time and responsibility of each party in its implementation. Annual monitoring reports will also be developed and submitted to MIGA (ESAP action item). 

Stakeholder Engagement: Stakeholder engagement activities are informal. Presently, OGB conducts limited stakeholder engagement activities as part of the application process when the Project submits additional sites to the Ministry of Environment. OGB has therefore committed to develop and implement a stakeholder engagement plan (SEP) for the Project to verify that the local communities are properly informed of the various site developments, especially in relation to land. The SEP will include stakeholder mapping and assessment, consultation and engagement strategies, grievance mechanism, roles, and responsibilities (ESAP action item).  

External Communication and Grievance Mechanisms: Like l0OGB’s practice in relation to stakeholder engagement, external communication and grievance mechanisms are informal and limited in scope. Externally, the Ministry of Environment can receive complaints from the public or landowners. OGB do have a Grievance Redress Mechanism for E&S complaints, but this is not yet formalized. Hence, OGB 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).   

PS2:  Labor and Working Conditions 

As of March 2023, OGB directly employs 270 people. Indirectly, OGB contracts workers under the Engineering, Procurement and Construction (EPC) and under the Operations and Maintenance (OM) contracts. Human resources (HR) function was previously centralized, but it is now managed at the country level with support from the corporate level.  

Working Conditions and Management of Worker Relationship: OGB is in the process of establishing its own HR policies and procedures in line with national requirements. OGB currently has a Code of Conduct, a Performance Evaluation procedure and system and a Competency Development Plan in place. Based on a HR Policy diagnosis conducted in collaboration with Orange Sonatel at the corporate level, OGB will develop their HR Strategy for 2023. As part of the development of OGB’s HR Strategy and related systems, OGB is committed to aligning its policies and procedures within national legislation and PS2 for both OGB staff and contractors (ESAP action item).  

OGB’s policies include the workers’ right to freedom of association and collective bargaining. The union for OGB employees is the SINTOB, and approximately 42% of OGB staff are members of the union. The Union Collective Bargaining Agreement is negotiated every three years and will be renewed in 2023. The union also has a grievance mechanism available for OGB staff and some of the contracted workforce, administered through union representatives.   

A grievance redress mechanism for employees is in place but is not yet formalized. Therefore, OGB has agreed to develop a grievance redress procedure for both OGB staff and contractors. This procedure will provide instructions for filing grievances and will include the provision of anonymous grievances and other PS 2 requirements (ESAP action item).  

Occupational Health and Safety: OGB is implementing the corporate level Orange Sonatel occupational health and safety (OHS) Policy and requirements. OGB will use this as the basis to develop a project level OHS management system (OHSMS) in line with national legislation and the requirements of PS2 (ESAP action item). Additionally, OGB will develop an OHSMS manual and related procedures including risk assessment and mitigation, roles and responsibilities, monitoring and reporting, near miss systems in subproject sites, and training of staff (ESAP action item). Once established, OHS requirements will also be applicable to contractors and enforced through contract conditions and obligations.  

A health and safety induction is held for all employees, contractors. All staff are provided and obliged to wear appropriate Personal Protective Equipment (PPE), and contractors are contractually obligated to provide their staff with appropriate PPE, and automatic fire extinguishers are to be available at all sites.  

In addition, for new telecommunication towers, the Ministry of Environment requires Environmental Management Plans to be provided. 

Workers Engaged by Third Parties: OGB will extend its OHSMS requirements related to environment and health & safety to its contractors and suppliers. Third parties are obliged to meet Guinea Bissau regulatory requirements. This Project will also be required to meet the requirements for third party workers as outlined in PS 2. 

Supply Chain: 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. The corporate level procurement strategy also extends to the future procurement of solar panels. 

PS3:  Resource Efficiency and Pollution Prevention 

Resource Efficiency: OGB has a strategy in place to solarize data centers and telecommunication towers through installing solar panels with a total capacity of 180 kWh at macro sites, and 75 kWh at rural sites by 2025. Current energy supply is from the grid in urban areas with back-up diesel generators and in rural areas, from solar and battery storage units. OGB currently consumes water for concrete bases during construction and cleaning solar panels during operations.  

In the development of the OGB ESMS, water use will be a key performance indicator which the EPC and O&M contractor will be required to keep track of. Furthermore, OGB 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 action 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 annual total GHG emissions is not yet available but will be significantly less than 25,000 tons CO2e. OGB will be required to report to MIGA if the total GHG emissions exceeds 25,000 tons CO2e.   

Pollution Prevention: The primary pollution issues associated with the Project include pollution associated with construction and operations are hazardous (acid lead and lithium batteries, broken solar panels) and non-hazardous waste (paper, wood, and scrap metals), potential leaks or spills of hydrocarbons, air emissions from heavy vehicle and equipment use and noise. OGB has committed to develop specific Waste Management Procedures and Environmental Management and Monitoring Plans to mitigate pollution derived from construction and operational activities (ESAP action item). OGB will also 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 (ESAP action item). 

Climate Change   

Guinea Bissau is also vulnerable to a range of climate-related physical hazards, including extreme temperatures, high winds, and flooding. Guinea Bissau is likely to experience more frequent and severe floods in coastal areas in the coming decades1, which could pose significant challenges to the telecom infrastructure in the country.  For telecom towers in Guinea Bissau to be resilient to climate change, several measures are being implemented. These include careful site selection to locate the towers in areas that are less susceptible to hazards, such as high winds and flooding. Since majority of new towers would be in rural sites, the structure of these towers and solar panels would be elevated to avoid any flooding events. Proper site selection process, whereby sites that are highly susceptible to flooding and winds would be excluded from the network, is a measure to mitigate impacts from flooding events.  At some sites, temperature sensors would be installed with fans to regulate the temperature inside backup and battery systems to avoid equipment malfunction due to extreme heat; proper maintenance and monitoring would be needed to enable that these sensors and equipment remain in working condition over time.  

PS4:  Community Health, Safety and Security 

Community Health and Safety: Telecommunication towers are built in both urban settings and in rural locations. OGB is committed to develop a Community Health and Safety Plan as part of the overall ESMS to inform communities about Project’s risks. During construction, these issues include noise vibration and increased traffic. During operations, potential risks include fire and safety 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. Sites are fitted with fire extinguishers and security guards are trained in their use. OGB will ensure that the fire extinguishers are functional, well maintained, and are regularly inspected.   

As part of the HR procedure, OGB 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 (ESAP action item).  

Security Personnel: Security measures for both offices and project sites will be stipulated in the ESMS, and include fencing, demarcation, use of security guards, security assessment, security training etc. in line with risk exposure at each site. Security services are outsourced to private security companies registered by the relevant authorities in Guinea Bissau. To align with the requirements of Performance Standard 4, OGB has committed to develop and implement a security risk assessment and security management plan for the Project to align with PS4 including rules of engagement and codes of conduct for security forces (ESAP action item).  

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

• Cartography elaboration procedures (2023) 
• Monitoring and measurement procedures (2023) 

The above documentation is also available for viewing at the following locations: 

Contact name: Birassi BA 

Position: Directeur Financier et Comptable 

E-mail: birassi.ba@orange-sonatel.com 

Address: Praça dos Herois Nacionais 

 Guinea Bissau 

Broad Community Support is not applicable for this Project. 

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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