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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




PROCESS DESCRIPTION                                                 The operation of a cable or satellite television
                                                                    network typically has a low environmental
This guideline covers the establishment and                         impact. The installation of such systems,
operation of the terrestrial elements of satellite                  however, often entails secondary activities which
and cable television networks.                                      have much greater effects on the environment.
                                                                    Such activities include:
It does not cover the manufacture of set top
boxes. For these impacts please refer to the                         •   The excavation of cable trenches;
Electrical Goods guideline. It also does not cover
the construction or launch of satellites or the                      •   Placement of satellite transmission and
construction of surface based satellite                                  receiver dishes; and
transmission stations.
                                                                     •   The placement of above ground cables.
Cable television refers to the method of
providing television services to customers via                      KEY ENVIRONMENTAL, HEALTH
radio frequency signals transmitted to televisions                  AND SAFETY RISK/LIABILITY
through fixed optical fibres or co-axial electrical                 FACTORS
cables as opposed to the over-the-air method
used in traditional television broadcasting (via                    Waste management
radio waves) in which a television antenna is
required. Many cable television networks also                       Waste associated with cable television operators
provide associated services such as telephone                       would include primary, secondary and tertiary
lines and internet access.                                          packaging associated with the manufacture and
                                                                    distribution of cables, set top boxes, and remote
Fibre-optic lines provide substantially greater                     control devices. There is also a stream of waste
bandwidth (information transmission capability)                     associated with end-of-life of cables and set top
than co-axial cables, but have drawbacks in                         boxes.
terms of their fragility and the need to convert
from optical transmission to electrical                             Co-axial cables could contain metal (such as
transmission prior to delivery to receiving                         copper) and plastic or rubber wire casing. For
equipment.                                                          example a common insulating material is PVC,
                                                                    which does not biodegrade. Therefore three
Cables can be placed either above the ground on                     primary options exist; burial, incineration and
poles or underground in trenches. Whilst                            recycling. Incineration releases carbon dioxide
underground placement has significant                               and can release toxic substances (such as
advantages in relation to the protection of the                     dioxins). PVC might also contain lead and
cable and reduced requirements for                                  cadmium as stabilisers which will be released
maintenance, it may require substantially greater                   into the air or into the ash (which is landfilled).
initial investment than overhead placement,
particularly in areas with shallow bedrock.                         Set top boxes should be responsibly disposed of
                                                                    as they may contain hazardous substances (such
                                                                    as brominated flame retardants and heavy

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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




metals). These can cause soil and water                             Environmental impacts which may occur as a
contamination if disposed of in landfills, and air                  result of damage to other utilities include:
pollution if incinerated improperly. There is
increasingly legislation at the national and                         •   The release of hazardous or contaminating
international level that regulates the disposal of                       substances such as oil or sewage into the soil
waste. Examples of such legislation that are                             and groundwater;
relevant to the cable television sub-sector are the
EU Waste Framework, Hazardous Waste and                              •   Destabilisation of foundations, root systems
Landfill Directives.                                                     and embankments due to the action of high
                                                                         pressure water from water mains;
Visual impact
                                                                     •   The generation of explosive atmospheres
Adverse visual impact may result from the                                either within/around the excavation or in
placement of over-ground cables or of satellite                          other nearby voids (including basements,
receiver dishes in sensitive locations. The degree                       sewers and subsurface utilities chambers);
of impact is largely a subjective issue; however,
inconsiderate placement of these items may                           •   Additional excavation work to repair the
result in the generation of considerable bad                             damaged line.
feeling within the community. In particular,
there is a need to check if the area is listed or                   It should also be recognised that damage to
protected from an architectural, historical or                      utility lines may have substantial health and
natural perspective, which may impose planning                      safety implications for workers.
restrictions on the erection/installation of over-
ground cables or satellite receiver dishes.                         Occupational Health and Safety

Damage to other utilities                                           Health and safety issues in the cable television
                                                                    sector could include:
Intrusive work associated with the placement of
cable networks has the potential to result in                        •   Risk of electrocution during instalment or
damage to existing underground services such as                          maintenance of cables if contact is made with
electricity cables, sewers, gas mains, oil pipelines,                    underground or overhead electric power
water mains, telephone lines and storage tanks.                          distribution or transmission lines;
Damage may result either from trenching
activities required for underground cables or the                    •   Physical harm associated with vehicle use,
placement of poles to support over-ground                                cable laying, warehouse operations and
cables.                                                                  manual loading of equipment;

                                                                     •   Exposure to low level electromagnetic
                                                                         radiation.




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                                          Sub-sectoral Environmental and Social
                                          Guidelines: Cable Television




OTHER POTENTIAL                                                     Damage to vegetation
ENVIRONMENTAL ISSUES
                                                                    Trenching associated with the placement of
Energy use and climate change impacts                               underground cables may affect local vegetation
                                                                    through the following means:
Cable television operations consume energy and
cause the emission of greenhouse gases such as                       •   Direct damage to root systems resulting in
carbon dioxide.                                                          reduced stability and a decrease in capacity to
                                                                         accumulate nutrients and water;
Energy consumption may be associated with:
                                                                     •   Alteration of subsurface drainage patterns
 •   Operation and maintenance of buildings and                          resulting in either a reduction in the water
     site (electricity use for lighting, IT                              supply available to the plants or flooding of
     infrastructure in data centres);                                    root systems.

 •   Business travel (air, rail, road);                             Responsible timber sourcing

 •   Vehicle fleet (for installation of set top                     Over-ground cable routes frequently use timber
     boxes, maintenance etc.);                                      for cable supports. Care should be taken to
                                                                    ensure that timber supplies are sourced from
 •   Gas and diesel (for back-up generators);                       sustainably managed forests and are not
                                                                    associated with illegal logging.
 •   Set top box use (downstream impact);
                                                                    KEY SOCIAL, LABOUR AND
 •   Inbound logistics (e.g. for set top boxes,                     COMMUNITY RISK/LIABILITY
     cables etc.).                                                  FACTORS

Companies can reduce the climate change                             Community health concerns over
impacts of their operations by implementing                         electromagnetic radiation
energy efficiency in their operations (such as
optimised distribution networks, energy efficient                   Concern with regard to potential impacts on
lighting and heating systems, greener vehicle                       health as a result of exposure to low intensity
fleet, reduced business travel), and products (e.g.                 electromagnetic fields is growing. At present,
set top boxes with auto stand-by). Companies                        the available evidence to support this concern is
can also reduce the carbon intensity of energy                      fragmentary and it is considered unlikely that
used by exploring the use of renewable forms                        such exposure is a significant health issue.
of energy.                                                          Public perception may, however, result in
                                                                    resistance to the placement of cables in some
                                                                    areas. Use of underground cables and
                                                                    replacement of traditional co-axial cables with
                                                                    fibre-optic lines is likely to overcome concerns.



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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




Responsible programming                                             to be given preferential treatment by the
                                                                    government.
The content of programming could also be
contentious. This is especially true when certain                   OTHER POTENTIAL SOCIAL, LABOUR
content is not deemed appropriate for children.                     AND COMMUNITY ISSUES
Functionality is often provided that allows
parents control over the programmes that their                      Waste disposal in developing countries
children have access to. Responsible
programming might also include advertisements                       Export of waste electronics equipment to
shown during prime time viewing slots for                           developing countries has impacts on
children (too many advertisements encouraging                       communities in those countries. There is a waste
the consumption of unhealthy food products for                      stream, legal and illegal, that extends from the
example).                                                           developed countries to developing countries like
                                                                    China, India, Nigeria and Ghana. These
Community engagement                                                countries often lack the facilities to process these
                                                                    waste streams which leads to dumping without
Educating consumers and changing behaviour –                        processing. There are often poor working
Cable television operators have access to                           conditions in scrap yards and recycling centres.
thousands of viewers. Through the choice of                         According to a Greenpeace report, the workers,
programming content operating companies have                        often children, are exposed to toxic chemicals
the potential to educate viewers on social and                      when waste products are broken down to extract
environmental issues (such as waste and                             valuable constituent materials (for example
recycling) and to encourage behavioural change.                     copper and other metals).

In the case of underwater cable work, potential                     Companies involved in generating electronic
impacts on fishery activities during the cable                      waste are increasingly being held to account for
work should be discussed with concerned and                         its disposal and therefore cable television
affected stakeholders involved in the fishery                       companies should understand the waste streams
sector. This can help ease obtaining planning                       and take responsibility for driving responsible
permission and can build the company’s ‘licence                     disposal with consumers and waste contractors.
to operate’ within the community.                                   This would enable companies to monitor and
                                                                    account for waste streams of set top boxes and
Ethics and bribery                                                  IT infrastructure (such as data servers).

Strong governance structures and transparency                       Labour standards
in reporting are also important, particularly since
charges of corruption and bribery can negatively                    Labour standards are rules that govern working
impact a company’s reputation and its ability to                    conditions and industrial relations. They may be
enter into business relations with partners. For                    formal, such as national level regulation and
example, companies may use unethical means                          international agreements, or informal, expressed
(such as bribery) to gain planning permission or                    through norms and values. In general, developed
                                                                    countries have more robust labour standards

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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




than developing countries where the associated                      impact the company’s operations and supply
risks are higher. The commonly accepted rights                      chain would incur costs as would any
and principles enshrined in the International                       operational or management changes that might
Labour Organization conventions are the right                       be required.
to collective bargaining, elimination of forced or
compulsory labour, abolition of child labour and                    Litigation and compensation
elimination of all forms of discrimination. In
addition fair wages and working hours and                           The company could incur costs if legal action is
acceptable working conditions should be                             taken against it. Action could be initiated by;
expected.                                                           employees over health and safety incidents, or
                                                                    accusations of discrimination; the government
Labour standards should apply to the company’s                      over non-compliance; or, local communities and
own employees as well as to all contractors and                     government agencies over environmental
sub-contractors engaged. In addition, labour                        contamination. For instance companies might be
standards should be expected to be enforced by                      liable for damage caused to property or utilities
key suppliers.                                                      while laying cables. Legal action might be taken
                                                                    over content that is perceived to be
FINANCIAL IMPLICATIONS                                              inappropriate.

Regulatory compliance                                               Reputational risk

Prior to the establishment of a cable network, it                   Damage to reputation (due to either
is likely that a substantial and costly process of                  environmental or social impacts or failures)
planning, regulatory consultation and permitting                    could damage the value of the company’s brand
will be required.                                                   and require long-running and costly efforts to
                                                                    attempt to restore trust and reputation, and
There might also be costs associated with                           reassure stakeholders such as investors,
complying with changing regulatory                                  shareholders, customers and the public. This is
requirements during operation of the business.                      in addition to associated litigation costs and
These costs might be associated with; managing                      compensation payments that might be incurred.
of waste streams and initiating recycling
programmes; emissions reduction technologies,                       Cable television operators could suffer
and; health and safety improvement measures.                        reputational damage if; the quality or suitability
Depending on national legislation non-                              of their programming is called into question by
compliance could have financial implications for                    their customers and the community; they have a
the business in terms of fines or planning                          poor labour standards record; or, they are
permission restrictions.                                            associated with poor waste disposal practices.
                                                                    There could also be a change of public opinion
For instance, understanding how EU Directives                       regarding the effects of cable television on a
such as WEEE (Waste Electrical and Electronic                       child’s development which could impact
Equipment), RoHS (Restriction of Hazardous                          viewership.
Substances) and the Landfill Directive would

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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




IMPROVEMENTS                                                             design, and developing reusable or recyclable
                                                                         packaging solutions.
Companies can implement improvements to
better tactically manage the environmental and                      Health and Safety
health & safety risks of their business. Examples
of such improvements are given below.                                •   Train employees on proper health and safety
                                                                         procedures;
Environmental
                                                                     •   Designate first-aid wardens and provide
 •   Consider low-energy options while upgrading                         additional training;
     equipment (such as IT infrastructure in data
     centres);                                                       •   Ensure adequate fire control and safety
                                                                         equipment is provided (fire extinguishers,
 •   Develop or switch to energy efficient set top                       first-aid kits);
     boxes;
                                                                     •   Reduce vehicle accidents through regular
 •   Consider using energy sources that are low                          maintenance of fleet and training for drivers
     carbon intensive (such as renewables,                               on safe driving methods;
     combined heat and power);
                                                                    Social, Labour and Community
 •   Consider implementing an energy efficiency
     plan to minimise carbon emissions from                          •   Ensure that fair wages, fair working hours
     logistics (distribution efficiencies, low impact                    and minimum age of workers are upheld;
     fuels for vehicle fleet);
                                                                     •   Develop a policy to ensure labour standards
 •   Plan for responsible disposal of equipment                          and human rights are respected upstream;
     that contain hazardous substances (such as
     cables, set top boxes) by working with                          •   Ensure that programming content is
     certified recycling or waste disposal                               appropriate for viewers;
     companies;
                                                                     •   Exercise choice over programming content
 •   Minimise environmental impacts of cable                             to educate viewers on social and
     laying by coordination of work with other                           environmental issues;
     utilities suppliers to avoid repeated
     excavation and by using existing utility                       In addition, best practice might include:
     routes;
                                                                     •   Support for local and SME suppliers through
 •   Reducing the visual impacts by using                                selective procurement policies;
     underground cables were feasible;
                                                                     •   Local skills development and capacity
 •   Reduce packaging waste (primary, secondary                          building.
     and tertiary) through innovative packaging

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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




GUIDE TO INITIAL DUE DILIGENCE                                       •   Have there been any recent (within the last
SITE VISITS                                                              three years) incidents on site or associated
                                                                         with operations (fleet) such as serious
The issues and risks associated with a site will                         injuries, fires etc. Is there insurance in place
vary depending on size of operation, site                                to cover such incidents?
location, country of operation and quality of
management. During an initial site visit to a site                  Labour issues
it will be important to assess the following:
                                                                     •   Check that labour standards, contracting and
Environmental, and Health and Safety                                     remuneration are in line with national law
                                                                         and are consistent with the average for the
 •   Check that the company has an official and                          sector;
     documented HR policy in place;
                                                                     •   Check that hours worked, including
 •   Are there processes in place to ensure that                         overtime, are recorded and that staff receive
     key suppliers comply with environmental and                         written details of hours worked and payment
     labour standard requirements;                                       received;

 •   Does the company need to comply with                            •   Has the Company received inspections from
     limits or other requirements on emissions to                        the local labour inspectorate in the previous
     air or water, or on management of waste?                            three years? Have these resulted in any
                                                                         penalties, fines, major recommendations or
 •   Does the company have a policy to help                              corrective action plans?
     track disposal of waste products and their
     impacts?                                                        •   Does the organisation have a grievance
                                                                         mechanism which allows employees to raise
 •   Does the company have a strategy to manage                          workplace concerns?
     energy use and carbon emissions?
                                                                     •   Are employees free to form, or join, a
 •   Check whether general health and safety                             workers’ organisation of their choosing?
     precautions are being taken. This would
     consider:

        o   Whether staff have appropriate
            training and have appropriate PPE;

        o   Whether appropriate signage is
            present around the site warning of
            health and safety dangers;

        o   Whether fire extinguishers and first-
            aid kits are available.

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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




Community engagement                                                 •   Implement a carbon management strategy to
                                                                         monitor and reduce energy use and carbon
 •   Is there a policy on responsible                                    emissions;
     programming?
                                                                     •   Implement a programme to monitor and
 •   Is there a policy to consult with affected                          reduce impacts associated with waste streams
     stakeholders to understand potential impacts                        and waste-to-landfill;
     of underwater cable work on fishery
     activities?                                                     •   Consider take-back and recycling of set top
                                                                         boxes.
 •   Is there a policy and process for regular
     consultation with local community                              Health and Safety
     representatives?
                                                                     •   Develop a formal Health and Safety policy;
 •   Is there a policy to prioritise community
     concerns and integrate into management                          •   Maintain a schedule to track training given to
     decisions?                                                          workers and managers on safety policy and
                                                                         procedures;
ACTION PLAN
                                                                     •   Develop Key Performance Indicators (KPIs)
An action plan would enable the company to                               for Health and Safety measures with
develop policies and processes that would                                monitoring, reporting and target setting;
strategically manage risks along its value chain.
                                                                     •   Encourage a culture of ‘safety first’ through
Environmental                                                            communication from the top;

 •   Develop an overall environmental strategy,                      •   Incentivise a culture of safety by linking H&S
     supported by functional level policies and                          performance to reward structures;
     targets (covering energy use and climate
     change, waste and packaging, cable laying, life                 •   Consider implementing a Health and Safety
     cycle impacts of products sold to customers);                       management system, certified to a recognised
                                                                         standard, such as the Occupational Health
 •   Communicate the company’s environmental                             and Safety Assessment Series OHSAS 18001
     strategy and progress against commitments                           or the International Labour Office ILO-OSH
     to stakeholders (as part of a separate                              2001 system.
     sustainability report or a section of the
     annual report);

 •   Implement an environmental management
     system certified to a recognised standard
     such as ISO 14001;



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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




Social, Labour and Community

 •   Design and communicate an appropriate
     code of business conduct that considers
     concerns of key stakeholders (shareholders,
     employees, government bodies, NGOs);

 •   Implement best-practice labour standards (in
     line with ILO principles); consider signing up
     to international frameworks such as the UN
     Global Compact;

 •   Implement a process to assess labour and
     human rights conditions for contractors, sub-
     contractors, and workers associated with
     supply chains of key suppliers;

 •   Develop a policy on responsible
     programming.




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                                         Sub-sectoral Environmental and Social
                                         Guidelines: Cable Television




REFERENCES AND ADDITIONAL SOURCES

International Labour Organization declaration              - http://www.ilo.org/declaration/thedeclaration/lang--
en/index.htm

UN Global Compact - http://www.unglobalcompact.org/

The World Business Council for Sustainable Development (WBCSD)                  - http://www.wbcsd.org/

The World Health Organization – Electromagnetic fields and public health fact sheet -
http://www.who.int/mediacentre/factsheets/fs304/en/index.html

EU WEEE Directive            - http://ec.europa.eu/environment/waste/weee/index_en.htm

EU Landfill Directive - http://ec.europa.eu/environment/waste/landfill_index.htm




Cable Television Sub-sectoral Environmental and Social Guidelines                                          Page 10
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