A preliminary E&S policy has been drafted by On Telecom, and the Company has various E&S terms in agreements with its different core contractors. As a condition of IFC?s investment, On Telecom?s E&S management system will be significantly improved, to include E&S procedures written (in Portuguese) for On Telecom employees to follow, and to cover relevant issues in the management of key contractors, in compliance with Brazilian E&S requirements and IFC Performance Standards.  

On Telecom?s E&S management system will provide for E&S review to be performed prior to the acquisition, development, and/or management of all sites and facilities, commensurate with the nature of each site or facility, and the level of E&S risks and impacts at each site/facility. E&S review will ensure that the On Telecom?s operations will comply not only with all applicable E&S laws and regulations, but also with IFC?s Performance Standards and IFC?s 2007 Telecommunications Environmental Health & Safety (EHS) Guidelines.

Under IFC?s investment, On Telecom will appoint at least one qualified person at its headquarters to be an E&S coordinator, responsible for implementing the company?s improved E&S management system. 

On Telecom will not proceed with the development of any site that cannot be expected to comply with applicable E&S standards, or before all relevant local permits are obtained. On Telecom will supervise E&S risks and impacts as they unfold in all of its operations for the duration of its involvement.  

On Telecom will screen potential key suppliers, vendors, and core contractors to ensure that they are well-established companies with solid track records in quality management and labor compliance. On Telecom will select only those who can use documented procedures consistent with IFC and local standards.  

On Telecom will include E&S terms in its agreements with key contractors, vendors, and suppliers.  Those terms will be consistent with IFC and local E&S standards, and will cover topics including labor and working conditions, and materials and waste management.  In the case of existing agreements in which E&S terms do not comply with IFC Performance Standards, On Telecom will ensure that appropriate new E&S terms are included as soon as any agreement can be renewed or rewritten.  On Telecom will monitor compliance with E&S terms in its agreements with contractors, and will require improvement in the event that non-compliance is identified.