Environmental Protection Policy
ITSA will manage the environmental effects of its ICT procurement, offices, travel, hosting choices, installations and equipment lifecycle. This policy directs practical pollution prevention, lawful disposal and efficient use of resources, with particular attention to Namibia's water scarcity, sensitive environments and long travel distances. It applies to personnel and contractors working for ITSA.
1 Responsibilities and legal framework
The Managing Member is accountable for resources, objectives and review. Project Leads must identify environmental risks and approvals before work, explain site controls and supervise contractors. Personnel must follow controls, prevent avoidable waste and report incidents. Suppliers must meet the Third Party Code of Conduct and relevant contractual obligations.
Comply with the Environmental Management Act 7 of 2007, applicable listed-activity and assessment regulations, permit conditions and relevant local-authority requirements. Screen proposed construction, facilities, fuel storage, waste handling and other potentially listed work for environmental-clearance requirements before starting. Obtain and comply with required clearance or permits; a customer instruction does not override them. Record who holds each approval and who monitors its conditions.
2 Planning and prevention
Assess environmental aspects before a project or material change, including waste, batteries, packaging, energy, water, fuel, dust, noise, land disturbance and accidental releases. Consider the sensitivity of the location and nearby people, drainage and habitats. Select controls proportionate to the risk and include them in the method statement and subcontractor brief.
Avoid unnecessary disturbance and work within authorised boundaries. Agree access, waste storage, working hours, reinstatement and emergency arrangements with the site owner. Do not clear vegetation, excavate or interfere with drainage without permission and required screening. Stop work when an unassessed material risk or missing approval is identified.
3 Equipment batteries and electronic waste
Prioritise suitable durable equipment, repair and reuse where technically safe and economically reasonable. Disclose refurbished equipment accurately and confirm support and security suitability before redeployment. Do not donate obsolete or unsafe devices merely to transfer a disposal burden to a community.
Segregate electronic waste, batteries, lamps, toner and hazardous materials from general refuse. Store them securely to prevent leakage, fire, breakage and unauthorised removal. Use competent lawful collectors or recyclers, verify their downstream arrangements proportionately and retain handover or disposal evidence. Do not burn, dump or place hazardous electronic waste in ordinary waste streams where prohibited.
Before disposal, obtain authority to remove equipment, record custody and sanitise storage media using a method appropriate to its sensitivity. Where reliable sanitisation is impossible, arrange secure destruction. Keep a record of assets, method, responsible person and receiving party. The Privacy Policy and customer instructions also apply.
4 Energy water procurement and travel
Select infrastructure and cloud configurations suited to the workload, avoiding unnecessary always-on resources and excessive capacity. Configure safe energy-saving settings and review idle equipment. Energy efficiency must not compromise security, cooling, backups or availability requirements. Assess data-centre environmental claims using evidence; do not imply ITSA owns or certifies an upstream facility.
Use water sparingly, repair reported leaks and avoid unnecessary cleaning or cooling consumption. Consolidate deliveries and site visits where practical and use remote support where safe and suitable. Maintain vehicles and equipment to reduce leaks, fuel use and emissions. Consider packaging reduction, supplier repair options and responsible end-of-life arrangements in purchasing decisions.
5 Pollution incidents and emergency response
Store fuels, oils and chemicals in suitable labelled containers with appropriate containment. Keep spill equipment and fire arrangements matched to the material and task. Personnel must know how to isolate an area and summon competent help. Do not wash a spill into a drain or attempt an unsafe clean-up.
Immediately stop the source if safe, protect people, contain the release, notify the Project Lead and site representative, and obtain specialist assistance where needed. The Project Lead must assess notification duties to authorities, arrange lawful cleanup and record cause, impact, action and follow-up. A serious incident must be escalated to the Managing Member without delay. Good-faith incident reporting must not attract retaliation.
6 Measures review and accountability
The Managing Member must set practical annual objectives after establishing a baseline, with an owner and due date. Measures may include e-waste transferred with evidence, assets safely reused, recorded environmental incidents, energy consumption where measurable, travel fuel and corrective actions closed. Do not publish invented baselines, savings or carbon-neutral claims.
Train staff for the risks of their tasks and include environmental responsibilities in contractor induction. Review significant incidents and this policy at least annually and after material operational or legal change. Record findings, actions and responsibilities. Environmental complaints may be raised with [email protected]; suspected concealment or serious misconduct may be reported under the Whistleblower Policy.

