Harmoni Towers Environmental, Social and Governance (ESG) Policy

June 30, 2022

1. Introduction and objectives

Harmoni Towers (Harmoni) owns, operates, and builds mission-critical telecommunications infrastructure. At Harmoni, we are focused on the acquisition and construction of telecommunication networks and working with customers in a wide variety of situations, including monetizing existing assets and new site development. Our aim is to continue operating as a world class infrastructure company collaborating with wireless operators to deploy their networks and build assets while relieving them of the burden of raising investment capital.

We believe effective management of environmental, social and governance (ESG) topics plays an essential role in the success of our business and creating long-term value for our stakeholders.

Effective identification, evaluation, and management of material ESG topics helps us to better address risks, capture opportunities and efficiencies, foster innovation, create a safe, supportive, and productive work environment, create value for our stakeholders in the short and long-term and contribute to a more sustainable world.

Informed by these beliefs, we aspire to be among the leaders in the telecommunications infrastructure sector by integrating ESG measures in our business operations and creating lasting value for our stakeholders. We seek to operate and conduct our business with integrity and in an ethical manner while committed to minimize negative and maximize positive environmental and social impacts across our business.

This policy aims to identify and define our material ESG topics, present our commitments for each topic, and outline how we seek to meet those commitments through our business operations.


2. ESG commitments

To meet our objectives, we commit to identifying and managing ESG factors that are material to our business as they arise. We have identified ESG factors that we believe are highly material to our business and therefore commit to take steps to manage:


  • Regulatory compliance
  • Resource usage, land use and biodiversity
  • Climate change risk and opportunity management, including energy and greenhouse emissions


  • Diversity and inclusion
  • Health and safety
  • Community development and engagement


  • Ethics, integrity, and fairness in business
  • Risk management
  • ESG oversight


3. Implementation & Actions

To meet our commitments, we are dedicated to embedding ESG across our business including operations, new site development, sales, legal, human resources, real estate and lease administration, and finance and accounting. Specifically, we seek to take the following actions to implement our ESG goals:


  • Adhere to all federal, state, and local regulations as a course of business conduct and track and report on environmental compliance
  • Evaluate impacts on the natural environment for all new developments and seek to preserve and protect biodiversity and natural habitats
  • Reduce energy use and greenhouse gas emissions through investments in energy-efficient equipment and renewable energy technology, where possible
  • Monitor key environmental performance indicators and seek to improve performance over time


  • Foster a culture of inclusivity and diversity that promotes equality, respect, and a collaborative work environment
  • Seek input from employees on opportunities to improve practices and culture
  • Develop and communicate policies that promote safe, healthy work environment that is free of harassment, discrimination, and violence
  • Monitor employee health and safety incidents and implement procedures and controls to manage health and safety risks
  • Support local businesses and community organizations through partnerships, procurement, volunteerism, and philanthropy


  • Conduct affairs to the highest standards of ethics, integrity, honesty, fairness, and professionalism by reviewing responsible business management and operations policy annually
  • Report on ESG performance and best practices to Harmoni’s Board of Directors
  • Assign ESG oversight responsibility to senior management
  • Manage activities in a manner that meets or exceeds all applicable federal, state, and local environmental regulations and requirements, and other legal/regulatory requirements
  • Implement business continuity and emergency preparedness planning into operations


4. Scope and responsibilities

This policy covers all Harmoni Towers’ business operations and applies to all Harmoni Towers’ employees. We seek to convey the importance of our ESG Policy to our contractors and supply chain.

The Chief Executive Officer, Senior Vice President of Operations, and Manager of Human Resources are responsible for communicating this policy to employees and policy oversight. All employees are responsible for actioning policy implementation initiatives.

The ESG Policy shall be reviewed and revised every two years by Harmoni Towers’ management team and the Board of Directors.

Lawrence Gleason
Chief Executive Officer
June 2022