Health and safety, ethics and compliance – from policy to practicalities

Does operating a tower business in Africa require the turning of a blind eye toward a “Facilitation Payment” to expedite a lease negotiation or customs clearance? Or does it require a relaxed attitude toward health and safety? “This is Africa,” is often rolled out as an excuse. That excuse is not accepted at Helios Towers Africa. Compliance and Safety boss Nick Summers explains the policies and procedures that protect tower climbers, electricians and drivers, and that create a culture of zero-tolerance of bribery and corruption at Africa’s pioneering towerco.

TowerXchange: Thanks for speaking to us today Nick. Please tell us a bit about your background and your role at Helios Towers Africa.

I started off on the property and site acquisition side of the industry at Andrew Wilkes and Associates and then at Vodafone, where over nine years I progressed into the end to end management of site deployment, culminating in a 16 month stint at Vodafone Ghana as head of rollout. In Ghana a moratorium on new tower construction came into force, so I took the opportunity to move over and develop the policy and governance elements of site deployment.

I joined Helios Towers Africa two and a half years ago and after a stint in Ghana, I volunteered to assist with writing the group’s Health & Safety (H&S) manual, before adding responsibility for our Ethics & Compliance (E&C) and Corporate Social Responsibility (CSR) programmes. Helios Towers Africa has group-level EH&S governance, with a dotted line reporting to me from the Safety, Health, Environmental and Quality Manager in each local operation. We’ve also appointed Ethics and Compliance champions at each local operation to assist with driving forward group level requirements. CSR is coordinated locally with group level approval.

TowerXchange: What Health, Safety and Quality standards are used in Africa? Do requirements vary substantially from country to country?

It doesn’t vary much from country to country, particularly when using international standards. Helios Towers Africa is working towards achieving OSHAS18001, which is the Health and Safety equivalent of the ISO14001 Environmental quality standard. OSHAS18001 is internationally recognised, many of our customers recommend it, and our investors are fully aware of what it is, which is obviously beneficial.

Achieving OSHAS18001 means you have a risk based management system. It means that you can demonstrate that you know about the specific Health and Safety risks facing your business, and have a system in place to mitigate that risk. It requires creating a culture striving for continual improvement, while encouraging those working on your behalf to  work to the same standards and also obtain certification.

We have a Helios Towers Africa group Environmental, Safety, Health and Social Management System (HSESMS) with associated policies which our local operations must abide by. Each operation in turn develops its own management system to take into account specific legal requirements and local nuances in each country.

In Africa I have seen too many instances of people climbing towers without the right equipment, not attaching themselves on properly, and putting themselves in danger

TowerXchange: So where are the key areas of H&S risk in the African tower industry?

In our business in Africa I see the main areas of risk relating to climbing towers without the necessary training, supervision and protection; people working with electricity; and the risk of driving on Africa’s notoriously poor roads.

People must be trained in climbing towers, but if they are not properly supervised, or indeed not supervised at all, then they might take shortcuts and not protect themselves fully, they might not use the right equipment, and then there’s a much greater risk of falling, and that means a risk of fatalities. In Africa I have seen too many instances of people climbing towers without the right equipment, not attaching themselves on properly, and putting themselves in danger.

We take the safety of tower climbers very seriously – we’re talking about our staff, our contractors and our customers. On a multi-tenant site many people have legitimate access, so we put checks in place to ensure that everyone is certified, trained, supervised and medically fit to go up the tower.

There are also safety issues around the EMF (Electro Magnetic Fields) that come from antennas. In my experience, African operations appear to be lagging behind many other areas of the world where there appears to be far greater awareness of this issue. We work hard to increase the awareness of those needing to climb towers and ensuring that they do not put themselves at risk by manoeuvring in front of live antennas.

As well as working with towers and the risk to tower climbers, we’re also working with electricity and the risk to electricians. We only permit qualified, certified electricians that meet certain standards to work on our sites.

Finally, Africa has a terrible record for road safety in comparison to many other areas of the world. Helios Towers Africa encourages driver training – in our operations we make drivers pass a driving test. All our vehicles have tracking systems that monitor speed and where they are and enable us to ensure safe driving and to expedite rescue in the event of an incident. We encourage contractors to abide by our driving policies, and select vehicles suitable for the road conditions and load concerned.

My personal view is that Health and Safety standards in the African telecom industry are lagging behind the mining and international manufacturing industries in Africa. H&S is of paramount importance at Africa’s top mines and, for example, I’ve seen excellent practices in the Guinness breweries all over Africa. The controls in Mining and Manufacturing are not always as rigorously enforced in the telecoms sector. Helios Towers Africa is joining some of the big global operators in trying to change the Health & Safety mind-set in African telecoms, which can only be beneficial.

TowerXchange: Where does responsibility for defining and maintaining H&S standards fall between Helios Towers Africa and your subcontractors? How does H&S figure into procurement and partner selection processes?

Our view is that all of Helios Towers Africa’s suppliers should be OSHAS18001 compliant within a given period. The effort to achieve certification will raise the standard of our contractor base, and provides a level of reassurance that they’re conversant with what is required of them,

All our suppliers have Environmental, Health and Safety clauses in their contracts that align to Helios Towers Africa’s policy. Each local operation manages its own suppliers and audits their performance, while I in turn audit our operations to ensure that they are in compliance.

Helios Towers Africa conducts comprehensive due diligence  on every prospective new supplier covering the likes of Health and Safety, Ethics & Compliance, financial history, Human Resources et cetera. H&S features very highly, if a supplier cannot demonstrate that they can abide by our policies, they will not be selected.

On the rare occasion that it happens, we have had no qualms about preventing access if customer isn’t appropriately prepared with the right equipment or the right certifications

TowerXchange: Does having multiple tenants, and multiple teams, on a cell site multiply the EHS issues? Whose EHS policies apply?

It’s our site and we set the policies in conjunction with our customers. On our sites, Helios Towers Africa’s EHS policies set the minimum standards expected and customers and contractors are required to abide by them.  Our policies were defined taking into account the most stringent of our customer requirements, so in many instances we are very much aligned.

It’s written into tenants’ Master Lease Agreements that they must abide by our H&S policies, and our H&S managers at local operations work to make our customers aware of our H&S policies, and that our customers in turn make their subcontractors aware of the policies by which they must abide.

On the rare occasion that it happens, we have had no qualms about preventing access if customer isn’t appropriately prepared with the right equipment or the right certifications.

TowerXchange: I saw that Helios Towers Africa recently received an award for investing US$40m in energy storage and RMS to reduce your carbon footprint. Tell us about Helios Towers Africa’s carbon management strategy.

We won that award for installing Remote Monitoring Systems on all our sites and deep cycle batteries on about 40% of them.

Helios Towers Africa conducted a carbon footprinting exercise in 2011, and will use that as an initial benchmark to compare our 2012 data once it’s collated. So we’re actively monitoring our carbon footprint – developing KPIs with the aim of continually reducing our relative footprint will be our next step.

Incidentally, when we conducted that carbon footprinting study in 2011, we tried to benchmark against other towercos worldwide, but we could not find any evidence that any other towercos had conducted a similar exercise and certainly not in Africa.

TowerXchange: I’ve just read Helios Towers Africa’s Code of Business Conduct, which is downloadable from your website. Please could you summarise your ethics and anti-bribery policies, and talk about the practicalities of compliance?

We have to abide by two principal sets of legislation; the UK Bribery Act 2010, and the US Foreign Corrupt Practices Act 1977. There are six fundamental areas that need to be addressed and managed to ensure that we have adequate procedures in place to satisfy the legislative requirements. Having policies and procedures that are proportionate to the risks faced by the business is one of the fundamental areas.  Therefore our policies and procedures have been written taking into account the challenges and risks that we face in our business and they provide our employees with guidance and advice with how to overcome certain situations. Our Code of Business Conduct is not just about anti-corruption and anti-bribery as it also covers a number of other areas such as due diligence, work place conduct, conflicts of interest and so on.

Transparency International’s “Global Corruption Perception Index” (http://cpi.transparency.org/cpi2012/results) shows that Africa is a particularly challenging environment when it comes to corruption and bribery. Of the three countries in which we’re currently operating, Ghana is ranked 64th out of 176 countries, Tanzania 102nd and DRC 160th. We’re working in a difficult environment, in markets where the regulators know that opportunities for corruption and bribery are likely to occur and we have to be prepared for that.

TowerXchange: Where are the highest risk areas of the business where you might encounter issues of corruption or bribery?

Both in site acquisition and in the logistics of clearing customs there can be a risk of exposure to what are called Facilitation Payments, which are strictly prohibited under our code of conduct.

This is not specific to our business or industry.  Wherever there is the need for official paperwork or signatures there is the possibility that Facilitation Payments may be requested.

We have to do everything we can to mitigate corruption and bribery. We have a substantial education programme in which all staff are trained, but you can’t just train staff the once, you’ve got to keep a constant flow of information to keep these issues front of mind.  We aim to ensure that all staff within the business come into contact with some form of E&C education or literature once a quarter.

TowerXchange: What can towercos do to reduce fuel theft?

One of the primary steps we’re taking to reduce the amount of diesel we need to use is through the introduction of hybrid batteries. In Tanzania we have some LPG generators which have been trialled in Ghana too.

Diesel theft is an area of great concern for every African tower operator. Whether it’s by security guards, local people outside the site, maintenance people on site the site, or administrative theft, we all suffer diesel theft to greater or lesser extent. Helios Towers Africa are tracking fuel usage through the RMS that give alarms when an unusual amount of fuel is being drained from the tank, and we can cross check fuel usage against DG runtime and invoices to ensure there is no administrative theft. We’re also increasing access controls, giving NOCs greater control over who has access, when and for how long so that individuals can be pinpointed.

Ultimately all our maintenance contractors are responsible for site security too. The O&M contractor is the “single point of failure” and has the financial incentive to minimise pilferage as we only pay for diesel burned.  The Operations & Maintenance contractor is held financially accountable for any theft which gives them added incentives to ensure that security is properly maintained.

When towercos seek new funding, a lot of the focus of the due diligence is related to H&S and E&C. It’s important that we have the policies and management systems in place because we should be continually seeking to increase standards in Africa

TowerXchange: Thanks Nick, please could you sum up the importance of H&S, E&C issues for the African tower industry.

Our policies are driven not just by our own ethics but also by our investors. For example, the IFC have invested in us, and with their investment comes many obligations which we have to meet.

When towercos seek new funding, a lot of the focus of the due diligence is related to H&S and E&C. It’s important that we have the policies and management systems in place because we should be continually seeking to increase standards in Africa. We must be striving to leave a positive legacy and raise the bar in the African telecoms/towerco industry. “This is Africa” is not an excuse for accepting poor H&S standards or tolerance of corruption and bribery. We’re not saying we’re perfect, and it’s not easy, but we can all improve, and that’s what we’re continually trying to do.