While all Performance Standards are applicable to this investment, IFC’s environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards 

PS 1 - Assessment and Management of Environmental and Social Risks and Impacts 

PS 2 - Labor and Working Conditions 

PS 3 - Resource Efficiency and Pollution Prevention 

PS 4 - Community Health, Safety and Security 

PS 5 - Land Acquisition and Involuntary Resettlement 

PS 6 - Biodiversity Conservation and Sustainable Management of Living Natural Resources 

PS 8 - Cultural Heritage 

PS7 is not applicable as there are no indigenous peoples, as defined by IFC Performance Standards, in the project area.

This is a category A project per IFC’s Policy on Environmental and Social Sustainability due to the potentially significant, diverse, and irreversible environmental and social risks and impacts associated with the project. The project areas are associated with Critical Habitat under Performance Standard 6. The project will also trigger physical and economic displacement and influx. It is also expected to contribute to cumulative regional impacts due to other bauxite mining activities. Thus, the key E&S risks and impacts include biodiversity and ecosystem services, physical and economic displacement, population influx, and cumulative impacts. 

Environmental and Social Assessment and Management System  : Since 2016 GAC has been developing an Environmental and Social Management System (ESMS) which is based on its Health, Safety, Security, Environment and Community (HSSEC) Policy, Environmental and Social Impact Assessment (ESIA) and legal register. The ESMS, which incorporates and integrates policies, plans and procedures, is aligned with requirements of ISO 14001:2004 and OSHAS 18001:2007. GAC has also retained the services of Borealis, a data management services provider, to develop systems to manage several social related issues including stakeholder engagement activities, grievances, resettlement, social investment, local employment and local supply chain development. 

CFB commissioned an ESIA for the railway expansion. An Environmental and Social Management Plan (ESMP) and Environmental and Social Monitoring Plan specific to the railway were developed. Detailed implementation arrangements for the coordination of ESMP among the users, concessionaire and owner of the railway are being developed. GAC commissioned its consultants to provide a bridging document describing the linkage between the railway ESMP and its own ESMP. Based on the final agreement, GAC will be required to incorporate HSSEC management of the railway into its ESMS and establish mechanisms to monitor that the railway ESMP is implemented in accordance with Guinean regulations and IFC PSs. 

Policy  : GAC has in place an overarching HSSEC Policy which establishes principles to guide sound environmental and social performance. Environmental, Health and Safety policies include an Environmental Policy and a Health and Safety Policy which outline GAC objectives for the protection of the health & safety of its employees, and environmental performance aimed at contributing to a sustainable development while conducting business with integrity. 

Identification of Risks and Impacts  : The project, under different ownership, was previously advanced to completion of a Bankable Feasibility Study along with approval of the ESIA. For the current project, GAC commissioned a reputable international environmental and social (E&S) consulting firm to prepare an ESIA Addendum in conformity with Guinea environmental law and regulations as well as international lender requirements, namely the IFC PSs, African Development Banks Integrated Safeguards System (Dec 2013) and the Equator Principles. The ESIA Addendum developed for the project aimed to complement the initial ESIA studies referred above and undertaken between 2004 and 2008. Whereas the 2004 – 2008 ESIA contemplated mining and refining operations in the northern part of the concession, the ESIA Addendum focused on the southern half of the concession and the specific infrastructures and activities of the project as currently defined. The ESIA also covered Transshipment. 

GAC commissioned the same E&S consultant to undertake an ESIA for its water supply dam and the MBS project. The Dam ESIA draws significantly on the previous 2008 SEIA. Risks and impacts associated with the existing railway upgrade are identified in the Railway ESIA which was commissioned by CFB.  

The ESIAs identified above were undertaken in accordance with Good International Industry Practice (GIIP) and comply with the IFC PSs. All ESIAs except those for the dam and rail (which are yet to be approved) were approved by Bureau Guinéen d’Etudes et d’Evaluation Environnementale (BGÉÉE), the agency responsible for approving the ESIA in Guinea. 

There is potential for cumulative impacts arising from the project and several current or potential bauxite mining operations in northern Guinea; such cumulative impacts were assessed during the ESIAs. These include loss of habitats, increased noise and air emissions, pressure on surface and groundwater resources and quality, socio-economic, etc. The cumulative loss of habitats, associated species and ecosystem services could be significant. Expansion of mining on the bauxite plateau could have significant impacts on bowal habitat, primates, and some restricted range species. Cumulative effects on water quality and resources and air quality could also adversely impact species. Social impacts related to in-migration to the mining area in search of jobs and other economic development opportunities as well as loss of agricultural and pastoral land are also potentially significant cumulative impacts. The World Bank is supporting a Cumulative Impacts Assessment in the region which will address these issues and will also support work that the Government of Guinea is undertaking to minimize these impacts, which have brought increasing social tension and pressure on local authorities.

The development of the refinery is in very early stages without any defined plans. However, as and when GAC progresses with the refinery it will ensure that the construction and operations of the refinery comply with IFC’s performance standards.

Management Programs  : Each of the ESIAs identified above has a dedicated ESMP. GAC has developed an integrated ESMP which consolidates all the different ESMPs into one single document. This will help the company to manage all E&S aspects of the project in a streamlined and consistent way. The integrated ESMP contain a register of the mitigation measures proposed by GAC in the ESIAs, to provide guidance for their implementation, as the project progresses. They set out the strategic framework while committing to general principles and procedures of specific management plans. For each identified environmental and social impact, the ESMP presents a set of mitigation measures to be adopted for the different phases of the project, monitoring indicators as well as the implementation project cycle timeline and responsible person/s, budgets for investment expenditure (capex) and operational expenditure. 

The actions defined in the ESMP form the basis for the operational controls to be incorporated into GAC’s HSSEC for the project. As such GAC has developed an HSSEC Program which is divided into six series of documents, each focusing on a different area or discipline of HSSEC. The six series are: HSSEC Policies and Programs; Safety Procedures; Health and Hygiene Procedures; Environmental Procedures; Community Procedures; and Security Procedures. The project’s mitigation measures are addressed under these plans, procedures and work instructions which are deemed adequate to manage the current level of project construction activities. All employees and contractors are required to implement the approved HSSEC program for all work performed on the GAC activities. Whilst most of these plans and procedures are fully developed the remainder are in draft form and need sign off by GAC senior management. Thus, as stipulated in ESAP # 1, GAC will finalize and implement all outstanding plans. Some of these plans are referenced in sections below where necessary.

Management of E&S for transshipment will be done by the Transhipper. However, the responsibility to ensure that E&S issues for transshipment are managed per IFC requirements will remain with GAC. As such GAC will be required to demonstrate this through contractual agreements with the Transhipper. This is stipulated in ESAP # 2.

Fluor developed an HSSEC plan specific to the construction phase. E&S responsibilities for GAC, PMC, and contractors are clearly defined in this plan. The construction phase HSSEC clearly stipulates that the PMC will be responsible for: overseeing that the ESIA is fully implemented for the duration of the construction works; auditing the implementation of the ESMP; verifying that all contractors are complying with the requirements stipulated in the HSSEC; and regularly reporting on performance to GAC, amongst other responsibilities. The HSSEC plan incorporates requirements for IFC PSs, General EHS Guidelines, and EHS Guidelines for Mining; Ports, Harbours and Terminals; AfDB’s Integrated Safeguards System, etc.

Organizational Capacity and Competency  : The project ESMP outlines the GAC planned organizational structure and capacity. The GAC CEO has overall responsibility for E&S for the company. As the project evolves from feasibility through construction to operations the company is progressively establishing an appropriate organogram for HSSEC. Under the proposed organogram there will be a Health, Safety and Environment (HSE) Director responsible for all HSE management plans associated with the integrated ESMP (including biodiversity) and for environmental awareness and training, health and safety training, security, waste management, regulatory compliance, compliance audits, etc. There will also be a separate Commercial and Stakeholder Engagement Director directly reporting to GAC’s CEO, with the responsibility to manage social risks and performance focusing on impacts and benefits to communities as well as working with other stakeholders at the commercial level. The Commercial and Stakeholder Engagement function will include Communities and Social Projects Portfolio. The Communities team will have three primary functions, namely: community relations; resettlement; and community investment. The Social Projects Portfolio team will also have three primary functions as follows: transformational and/or local content projects; regional development planning; and workforce housing.

The HSE and Commercial and Stakeholder Engagement Director positions as well as other key positions are currently vacant. As stipulated in ESAP # 3 GAC will fill all vacant HSSEC positions as per its staffing plan and maintain an adequate team throughout the tenure of IFC’s investment. 

In addition to the in-house capacity, GAC uses consultants for specific specialized tasks such as full biodiversity (flora and fauna) and Chimpanzee monitoring as applicable. A team of suitably qualified and experienced resettlement consultants provide additional support and complement monitoring activities of resettlement processes.

Emergency Preparedness and Response  : GAC has developed an Emergency Response Plan (ERP) to identify the potential for, and responses to, accidents, incidents and emergency situations and preventing and mitigating the likely associated illness and injury. The ERP contains procedures for specific emergencies such as fire, medical emergency, hazardous chemicals, civil/labor disturbances, unplanned explosions, etc. The ERP includes reporting procedures and responder roles. Emergency drills are scheduled regularly and conducted to identify potential areas for improvement. Records of these drills are kept. All employees and contractors are responsible for reporting any emergency incident(s) to their supervisor or the responsible person of the area. The ERP will be subject to continuous monitoring and review, in response to changing circumstances as well as internal practices. This will include the development and implementation of department specific ERPs as the project evolves. The ERP will also be updated to consider: impact analysis, and determination of the communities that could be affected by a dam failure: and the capabilities of communities, government agencies and related parties to respond to emergencies. This is stipulated in ESAP # 4.

Monitoring and Review  : The integrated ESMP includes an Environmental and Social Monitoring Program for the project, which is intended to cover all topics and requirements for monitoring. The Monitoring Program will be either implemented by the company or issued to contractors to develop their own contract-specific monitoring plans and procedures for implementation. Both internal and external monitoring are covered in the monitoring program for the project and contractor monitoring is a specific requirement. Monitoring will also include regular internal EHS inspections/audits and external EHS legal compliance audits performed as appropriate by various government departments. The audit reports, incorporating corrective actions, will be submitted to relevant operations senior management teams who will be responsible for implementing all the corrective actions. GAC’s senior management will review and evaluate the effectiveness of the ESMP on a regular basis, in response to changing circumstances as well as internal practices.  In addition to the above, the project will be subject to independent E&S monitoring as part of the lenders’ requirements.

GAC will develop appropriate Key Performance Indicators (KPIs) (such as diesel and water use, occupational, health and safety (OHS)) to evaluate the performance of the controls and proposed mitigation measures. The KPIs will be linked to specific targets based on GAC’s objectives or on the national regulation or international standards. GAC will also adopt a philosophy of adaptive management and continual improvement of monitoring the ESMP to ensure that the proposed specific management plans, embedded controls and proposed mitigation measures are consistently meeting project standards and KPIs.    

Working Conditions and Management of Worker Relationship  : GAC estimates employment figures (GAC employees and contractors) of 4,000 (3,100 are the local workforce) at the peak of the construction phase of the mine infrastructure, rail siding and the port terminal. Of which, GAC directly employs a total of 200 people mostly based in Guinea. For operations, GAC expects to have between 500 and 1,000 employees. GAC plans to expand and use its existing Pioneer camp to accommodate non-local workforce in line with IFC PS2 and overall workers’ accommodations standards are regularly assessed by GAC. The camp is located about 9 km from the plant site. The company will provide transportation for the workforce from the Pioneer camp and nearby communities to the plant site. For the port terminal, GAC will use a combination of lodges and temporary camps to accommodate contractors’ general workers and approximately 50 to 100 GAC employees during the construction phase. The company will also construct a permanent camp with capacity to host 160 people in line with IFC PS2 and relevant guidance on Workers’ Accommodation. There is a higher ratio of male employees; female employees represent 10% - 20% of the workforce. The local workforce represents 100% of the unskilled labor and about 86.5% of the skilled workers’ category.   

Human Resources Policies and Procedures  : GAC has adopted the EGA Human Resources Policy and through the Internal Regulations ( Règlement   Intérieur  ), and the Code of Business Conduct Policy, states its approach to complying with adequate working conditions, non-discrimination and equal opportunity, freedom of association and child and forced labor in line with PS2. GAC Internal Regulations (see details below under terms of employment) details employees’ rights, responsibilities and obligations in conformity with the Guinean Labor Code and GAC’s Code of Conduct. These rules are posted on all GAC premises and must be explained to all new workers. GAC employees, irrespective of their title or category, are to know and comply with the provisions of the Internal Regulations. An overarching and comprehensive Human Resource Policy specific to GAC will be developed, as per ESAP # 5, to organize and guide the existing various plans and procedures regarding labor, working conditions, collective bargaining and related documentation. This overarching HR Policy specific to Guinea will include provisions for collective bargaining, retrenchment, and grievance mechanism. 

In regards to the contracted workforce, GAC also has in place the Industrial Relations Management Plan mandating that the PMC and all its contractors abide to the labor and working standards and procedures, which include procedures on workers’ discipline; grievance; dispute resolution; absenteeism; and demobilization, among others. Audits of contractors and main suppliers are conducted by the internal audit team to ensure compliance with GAC policies, including respect for human and labor rights. In addition, GAC established a Suppliers’ Business Conduct, Procedure for HSE requirements for contractors, guidelines on tax regime which include provisions for payment of social security contributions for employees. 

Working Conditions and Terms of Employment  : GAC provides full-time employment through two types of contracts: (i) a CDI ( Contrat à Durée Indéterminée  ) with no specified end date to employment; and (ii) a CDD ( Contrat à Durée Déterminée  ) with a specified duration of employment. GAC provides benefits to full-time employees (both CDD and CDI), including life insurance, health care and medical insurance, disability and invalidity coverage, maternity leave (covered by both GAC and the National Social Security Fund), travel and education allowance, bonus (annually, based on performance), training, official holidays, sick and family leave, and annual leave of 25 days after 11 months of employment. All employees are also registered in the social security system ( Caisse National de   Sécurité   Sociale  ). These same benefits are applicable to permanent and fixed-term employees. Employees are required to pass a medical examination. Candidates for all positions are required to undergo a successful trial period, or three months for managerial positions and one month for all other employment categories. 

Workers’ Organization  : The 2014 Guinean Labor Code makes provisions for employee labor unions and the right to collective bargaining. Most of GAC’s employees are members of one of the four existing national trade unions present in the mining sector. GAC management meets formally with the union representatives (3 elected representatives and 3 additional deputies) three times a year to address any labour issue and ensure adequate working conditions in addition to discussing issues as they emerge in real time.  GAC has also provided in-depth training to the union representatives in August 2017 on the Guinean labour code. As part of the overarching GAC HR Policy, the right to collective bargaining is to be formalized, as per ESAP # 5. 

Non-discrimination and Equal Opportunity  : GAC’s Internal Regulations as well as the Business Code of Conduct (signed by all suppliers) prohibits discrimination and harassment of all forms, including those associated with race, color, religion, sex, age, nationality, ancestry or disability.  Such behavior will be cause of immediate dismissal if this is verified through an investigation. In addition, a system ensuring fair treatment of employees is ensured through Article 36 of the Internal Regulations and the Code of Conduct. 

Retrenchment  : While retrenchment is currently not envisioned, if and when required, GAC will follow the mining sector and the 2014 labor regulations in Guinea, which are also aligned with PS2 in principle. In broader terms, this include the development of a retrenchment plan to inform elected worker representatives ( délégués syndicaux  ) and labor inspectors of the details of the planned retrenchment, including any mitigation measures taken. GAC will also be required to consult with elected worker representatives or directly with workers over any planned workforce reductions due to economic reasons. In the event of such event, GAC will formalize procedures for retrenchment of the workforce in line with PS2 as per ESAP # 5 and will disseminate to the workforce so they have a clear understanding of the procedures and their rights. 

Grievance Mechanism  : GAC’s conflict resolution as per GAC’s Internal Regulations lay out the steps for which any full-time GAC employee can raise issues or grievances internally. Most often, labor grievances are communicated through the union representatives on issues regarding pay raise, allowance, and transport, which in turn, are discussed with GAC’s management where turnaround times are established for each of the stages of the grievance process. Additionally, employees can access the EGA-GAC compliance service “Your Voice” through a toll-free number or e-mail to report issues or concerns. Contracted workers can also access “Your Voice” mechanism and GAC will channel it to the relevant department. 

Occupational Health and Safety  : GAC has developed an Occupational Health & Hygiene Management Plan (OHHMP) consistent with its HSSEC policy described under the PS1 above. This is also reinforced through GAC’s Internal Regulations. The OHHMP framework, which is consistent with GIIP, clearly defines roles and responsibilities, business partner management, health and safety process implementation, objectives and targets, general safe work practices, personal protective equipment (PPE) etc. All employees and contractors are required to implement the approved OHHMP for all work performed on the GAC activities. In addition to this, GAC has a Risk and Opportunity Management/Job Hazard Analysis procedure in place.

Safety performance (covering GAC and subcontractors) is well tracked and includes details of the incidents and any follow-ups embedded in the tracking sheet. In addition, the incidence of malaria amongst local and expat workers, and days lost due to malaria, is tracked and incidence rates against the time of year plotted to assist managing the issue. Drugs and alcohol incidents are also captured in health and safety tracking. The company is committed to always achieve zero injuries and zero harm in its operations. The need for PPE dedicated to the particular workplace is defined by risk assessment and is provided and worn by workers. This may include safety boots, protective gloves, hard hats, lifesaving jackets, and ear or eye protection, according to workplace risk.          

Resource Efficiency  : The main resources utilized by the project include water (used to support the mining and processing operations) and hydrocarbon based fuel (used in electricity generation, mining processing and transportation). GAC will implement several initiatives to reduce consumption of these resources. These initiatives will include identifying areas for resource efficiency assessment; consideration of energy efficiency in the purchase criteria of the equipment; and ensure that water, energy and fuel consumption is precisely metered and reported always. 

Energy  : The main energy use by the project is diesel which will be mainly used for mobile units, trains, and power generation. Estimates of diesel use ranges between 27,000 and 52,000 m3/annum with the bulk of this (15,000 – 27,000 m3/annum) used by mobile plant at the mine site, and the second largest demand being the power generation at the port (8,000 – 16,000 m3/annum). GAC will use diesel generators to produce power at the mine and port. The maximum power demand is estimated at 10 MW for the mine and 25 MW at the port. In addition, a minor amount of diesel will be used to power the water pumps at the dam.  

Water  : The GAC mining process is a relatively simple one which does not require large quantities of water for the process. The large majority of water required is for dust suppression on the haul roads. Water demand at the mine site is currently estimated at 102,000 m3/month of which 87,000 m3/month will be used for dust suppression. The potable water demand is estimated at 2,400 m3/month throughout the year. The site will be equipped with a drinking water treatment unit. Water demand at the port terminal is estimated to be 450 - 600 m3/day and will be supplied by a Reverse Osmosis (RO) Plant which abstracts about 1,100 – 1,600 m3/day seawater from the adjacent Dougoufissa Creek. Reject water from the RO Plant will returned to a separate part of the Dougoufissa Creek.

Water supply studies are still ongoing, and the distribution of anticipated supply rates from the different potential sources is not yet finalized. However, at this stage the use of the dam is the preferred option to provide water to the project when the nearby Tinguilinta river levels are too low for abstraction. The dam is designed to store approximately 750,000 m3 of water at the maximum operating level. The dam is intended to be recharged through rainfall runoff from the catchment. The design of the dam was based upon comprehensive hydrological studies commissioned by the company. Groundwater is also a potential source of water supply and is currently under evaluation.  

GAC has developed an Integrated Water Management Plan (IWMP) which contains the interim water balance for various wet and dry rainfall conditions. GAC will finalize investigation of alternative water supply sources, including groundwater, and storage options; undertake detailed Ecological Flow Requirements (“EFR”) assessment at abstraction site (including field survey) to further refine EFR conditions; and hydrological (including flow) monitoring campaign and further refinement of hydrological model. The company will then update its water balance to define sustainable surface water and groundwater resources for the project that will ensure sufficient year-round provision of mining and process and other users including local communities. GAC will also implement key recommendations arising from these investigations including installation of monitoring boreholes in and around the mining area. This is stipulated in ESAP # 6.

GHG Emissions  : The estimated GHG emissions over the project lifetime (20 years) is approximately 4.4 million tCO2e or 220 000 tCO2e per year. The largest contributor (about 55%) to the overall GHG inventory is from the energy consumed to ensure project operations. This is followed by deforestation activities during land clearing operations, whose contribution accounts for about 40% of total GHG emissions. GHG emissions associated with marine dredging activities account for approximately 5% of total GHG emissions. Several GHG mitigation initiatives were recommended. These include where applicable, limiting the surface for which vegetation clearance is needed, rehabilitation and replanting the mined areas, and monitoring the restoration activities, and energy efficiency improvements. In addition, and as stipulated in ESAP # 1 GAC will finalize and implement its Air Quality and GHG Management Plan.  

Pollution Prevention  : As noted under PS1 above GAC is progressively developing specific management plans. Some of these plans are focused on pollution prevention. GAC will apply pollution prevention and control measures plus waste management practices that are supported by robust procedures and consistent with good practice. The effectiveness of these practices and procedures will be subject to continuous monitoring and review. Some of these measures and management plans are highlighted in the sections below. 

Air Emissions and Ambient Air Quality  : Primary sources of air emissions from the project will include particulates from mining and processing (particularly blasting, crushing and ore handling), entrainment of dust by vehicles, especially on unpaved roads as well as fuel combustion. Based on air quality data collected as part of the baseline monitoring the average for both the 24-hour PM10 and PM2.5 were low and below the World Bank/IFC/WHO ambient air quality guideline levels of 50 µg/m3 and 20 µg/m3 respectively. Equally, the SO 2   and NO 2   monitoring results were below their respective World Bank/IFC/WHO ambient air quality guidelines.  

GAC is committed to carrying out air quality monitoring necessary to adequately characterize baseline conditions and validate the air dispersion modelling used to predict future concentrations. In addition to this, the company will implement appropriate (water and/or chemical) dust control measures within the mine area, on access roads and at the plant, where evacuation and filtration systems are not practical.  

Noise and vibration measurements were performed at sensitive receptors at the mine, port terminal and marine sites. Mitigation measures are specified for sensitive receptors (human, ecological and marine) where the increase above baseline levels is greater than 3 dBA, or if the additional noise causes IFC guideline levels to be exceeded. In addition to this, GAC will undertake noise monitoring on an ongoing basis to verify the ability of the proposed mitigation measures. 

Wastewater Treatment  : Packaged sewage treatment plants will be used for the treatment of sewage from the site camps during the construction phase and all toilet facilities during the operational phase. This will consist in a packaged activated sludge sewage. The sewerage system will collect grey & black water from buildings as well as water that has been processed in the oil/water separator. Sewage treatment sludge will be recovered periodically. Given the absence of a municipal sludge treatment plant, GAC is currently investigating project-specific sludge treatment options such as drying beds, compost production for agricultural or mine rehabilitation use, natural biodegradation by spreading on a dedicated managed surface, etc. For the port terminal, the treated effluent will be blended with the reject stream from the RO Plant and discharged to the sea outfall. 

GAC will also apply specific wastewater controls and treatment methods at the mine and port terminal. Settlement dams (sediment basins) on each plateau (provisionally 2 per plateau) will be constructed for abatement of suspended solids from contaminated storm water runoff from mine terraces, including overburden and material stockpile areas. For contaminated storm water runoff from mine and port terminal infrastructure area, including re-fueling, workshop, wash bay and parking areas GAC will install appropriate settling tanks and oil separators. Sludge from storm-water collection and treatment systems will be deposited per the company’s waste management procedures. Overall GAC will design, implement and maintain a storm-water management system. Clean storm-water will be separated from potentially contaminated wastewater streams which are to be contained and treated prior to any discharge as noted above. GAC will also develop and implement appropriate storm-water management procedures which will be linked to the plan. This is stipulated in ESAP # 7. 

Solid Waste Management  : GAC will produce a wide range of waste from its operations. This includes office and household solid waste and non-hazardous industrial waste (paper, packaging material, kitchen waste, building rubble, non-hydrocarbon filters, etc.); salvageable/recyclable material (scrap metal, pipes, used tires, empty drums and scrap wood, etc.); hazardous waste (used hydrocarbons, expired and used maintenance chemicals, lead batteries etc.); medical waste; waste water – discussed above; and top soil and overburden. All waste will be managed per the company’s Waste Management Plan (WMP) which is currently being developed and will be incorporated in the ESMP. The WMP is being developed according to GIIP incorporating concepts of reduce, reuse and recycle. 

Currently, GAC produces about 3 m3 per week of general waste in Tinguilinta and the same amount in Kamsar. For Kamsar, the organic and recyclable material is sorted in KCT. Organic waste is composted in the restaurant composters and recyclable stored in yard. Non-recyclable waste is sent to Tinguilinta for burning in the dedicated storage yard, named the Henan China facility. The Henan China facility is temporary. Thus, as stipulated in ESAP # 8, GAC will install appropriate waste management infrastructure as part of the WMP. This will include a waste management facility (WMF) with separate compartments for different types of wastes, i.e.; an unlined non-hazardous waste landfill and a salvageable material yard. The WMF will provide for segregation, storage, recycling and disposal of inert, nonhazardous and hazardous waste. The WMF will be designed and constructed in accordance with the relevant national and international guidelines, and will include measures for storm-water management and dust suppression.

Used oil, lubricants, cotton rugs and small quantities of expired chemicals and chemical containers will be returned to the suppliers and recycled/reused as appropriate.  

Topsoil and overburden from the mining operations will be stored and reused for rehabilitation as the mining progresses. Overburden rock will be minimal and will be stored onto the mined plateau. Some excavated overburden material can also be used to construct haul roads that will be connecting the plateaus at the mine site. 

Hazardous Materials:   Hazardous materials will essentially consist of small quantities of chemicals used for water treatment (e.g. coagulants, disinfectants); and maintenance and repair (e.g. small quantities of cleaning products, oil, solvents, paint). It will also consist of medical waste. In addition, GAC will use ANFO as an explosive mixture for the blasting of rock at the mine site. GAC intends to use its existing ANFO storage facility in the northern part of the concession, located 9 km to the north of Pioneer camp. This facility is equipped to store explosives and detonators in dry and secure conditions. GAC will maintain a Hazardous Management and Spill Prevention and Response Plan.

Within the GAC port terminal fuel use and storage will be relatively significant with two 3,000 above ground tanks along with some smaller area day tanks. Diesel fuel will be supplied from the GAC port terminal at Kamsar by rail, using dedicated 50 m3 tanker wagons or road haul and stored in two 1,000 m³ tanks. The fuel storage and loading/unloading areas will be equipped with appropriate secondary containment. 

Medical wastes will be incinerated, and depending on the final design of the incinerator (e.g. single or dual chamber) other wastes such as solvents will also be incinerated. GAC will characterize the remaining ash as either hazardous or non-hazardous prior to disposal per its waste management procedures.

Mine closure and rehabilitation:   Currently no closure-specific commitments have been made to stakeholders. However, GAC will finalize and implement a Mine Closure and Rehabilitation Plan in consultation with local communities and the authorities. Rehabilitation of the mined areas will be completed as the mining advances on an ongoing basis. The plan, which will include the quarry, will be periodically updated in consultation with local communities and the authorities to consider changes in project configuration, legal obligations, corporate requirements, community expectations and technical knowledge. The mine closure will include closure costs provisions for immediate closure and life of mine closure, and decommissioning and restoration costs. It will also include the funding mechanism. This is stipulated in ESAP # 9. 

Pesticide Use and Management  : Pests are covered in the company’s Invasive Species Management Plan. GAC will undertake a full review of its use of pesticides to meet PS 3 requirements. The company has committed not to purchase, store, use, manufacture, or trade in products that fall in WHO Classification by Hazard Class Ia (extremely hazardous) or Ib (highly hazardous). For Class II (moderately hazardous) pesticides, GAC will ensure there are appropriate controls in place for their procurement, storage and use. 

Community Health and Safety  : Potentially negative community health impacts stem from dust and noise due to the movement of heavy equipment, materials and project personnel during construction. During operations, blasting and heavy trucks transporting ore could affect the population of rural villages and settlements within the vicinity of the mine. Community safety risks will also result farom a marked increase in vehicular traffic during both the construction and operational phases and the associated potential for accidents involving both humans and domestic animals. During the impact assessment, specialist noise, dust and air emissions studies were undertaken and quantified. As part of the ESIA, a Community Health and Safety Management Plan (CHSMP) was developed providing a clear set of actions and responsibilities for the control of impacts affecting the health and safety of the communities within the project’s area of influence- from Sangarédi to Kamsar. The CHSMP covers all phases of the project and is relevant to GAC, its contractors, suppliers and visitors working on its sites. The CHSMP also links with several other social, safety and environment management plans such as Project Induced In-migration Management Strategy; Traffic and Vehicle Management; Storage, Transportation and Handling of Explosives; Malaria, Ebola and HIV; Dust Control; etc. In addition, GAC will need to ensure the management of potential impacts to fishermen is implemented and the measures included in the site-specific RAP for Kamsar are followed.

As gender-based violence was identified as a potential risk, GAC counts with measures in the CHSMP, the Business Code of Conduct, the Internal Regulations, the Industrial Relations Management Plan and the In-Migration Management Plan to proactively manage the potential risks from various perspectives that could affect the communities by putting internal measures with its direct and contracted workforce as well as working with regional and local governments on the issue.  Measures range from raising awareness among the workforce and the community about the potential issues, trainings on cultural norms and behavioral conduct, to investigation, disciplinary actions and liaising with local law enforcement officials, when needed. 

Infrastructure and Equipment Design and Safety  : International codes are referenced in the design of infrastructure. In addition, and as infrastructure is built, safety analysis will be conducted and plans or procedures addressing community health, safety and security will be developed in accordance with GAC’s health and safety policy. Mine and port facilities will generally be situated to minimize potential risks to the public from operational and natural hazards. Proposed mining areas are away from communities and/or communities have been or will be relocated, additionally, the platform area has also required some relocation. The water reservoir dam on the Tiouladiwol River has been identified as a potential risk to downstream communities. The design of the dam was reviewed by the ITE and found to be adequate. Independent audits will be undertaken during the operation of the dam. This is stipulated in ESAP # 10. 

Hazardous Materials Management and Safety  : As noted under PS3 above all hazardous materials will be managed in accordance with the company’s Hazardous Management and Spill Prevention and Response Plan. GAC will also use its Hazardous Substances and Dangerous Goods Standard to ensure that controls are in place to minimize the risk to the lowest practical level of adverse health and safety effects to employees, customers, contractors and the public, from exposure to hazardous materials and chemicals used or produced as part of its operations. Transportation of hazardous materials is discussed in the Hazardous Substances and Dangerous Goods Standard. Procedures are also in place to identify, track and maintain an inventory and repository of material safety information, implement controls and respond to spills associated with petroleum and chemicals that represent hazardous materials.

Ecosystem Services  : The project will impact a number of ecosystem services and non-timber forest products (NTFPs) that are priority to local communities for their livelihood and socio-cultural use (please see further details under PS6) mainly due to the need to access land and consequently, economically and physically displacing communities and shifting ecosystem services use to other areas. To manage these impacts, GAC has in place a Land Acquisition, Compensation and Resettlement Framework (“LACRF”) to guide the subsequent development of site-specific RAPs (Resettlement Action Plan), Community Investment Strategy and the Agricultural Development Strategy providing a combination of mitigation measures, compensation and community development activities. 

Community Exposure to Disease  : The main diseases affecting the local populations are malaria, diarrhea, tuberculosis, tetanus and respiratory diseases (asthma, bronchitis). The issues associated with HIV/AIDS and other STDs are also prevailing in the Kamsar area. The project may attract single men, thus leading to the coexistence of several STD transmission risk factors (risky and predatory behaviors). The presence of the large project workforce is likely to increase the risks of transmitting diseases. GAC has in place a number of mitigation measures through the ESMP together with the CHSMP, the Code of Business Conduct, the Project Induced In-Migration Strategy (PIIMS), the Community Investment Strategy (CIS), and the Health, Safety and Hygiene Plan. A key mitigation measure is to develop a Local Development Plan to support improved access to and quality of health care infrastructure and services, and raise local communities’ awareness on hygiene, health and communicable diseases (i.e. HIV/AIDS, malaria). Monitoring and reporting will be facilitated through continuous engagement with local communities and the use of the grievance mechanism to ensure measures are effective. 

Emergency Preparedness and Response  : As highlighted under PS1 above GAC has in place an Emergency Preparedness and Response plan. This is also addressed in the CHSMP. The Emergency Preparedness Response, like all other plans, will be a “live” document that will be amended periodically considering operational changes and learning experiences during its implementation. As such, and with respect to community health and safety, the plan will be updated to consider (i) impact analysis, and determination of the communities that could be affected by a dam failure, and (ii) the capabilities of communities, government agencies and related parties to respond to emergencies. This is included in the ESAP # 4 above. 

Security Personnel  : GAC commits to respect human rights at all levels of its workforce through its policy of zero harm to communities and workers and GAC’s Code of Conduct, for which training and refreshers is provided to all employees. As part of the ESIA, GAC conducted a Human Rights assessment and identified security as one of the key issues. This relates to the potential abusive use of force by the private security companies and the public security forces in case of social tensions leading to conflict. Incidents of social unrests in the areas of Kamsar and Boké are requiring the intervention of the police and the national security forces (Gendarmerie) leading to social conflict. Given the context in which GAC operates and in order to ensure clarity of roles and responsibilities, GAC signed a Memorandum of Understanding (MoU) with the Government of Guinea on March, 2017, for the national security forces to provide security for the Project in line with the Universal Declaration of Human Rights, the United Nations Code of Conduct for Law Enforcement Officials, the United Nations Basic Principles on the Use of Force and Firearms by Law Enforcement Officers and the Voluntary Principles on Security and Human Rights. 

In addition to the above, GAC and the Ministry of National Defense of the Republic of Guinea identified jointly a Colonel of the Guinean Armed Forces as military counsellor and liaison who has a thorough understanding of protecting human rights to interface with public security forces. In addition, a Guinean private security firm (Laguipres Sécurité) provides security services at all GAC sites, offices and accommodations facilities. GAC will finalize the overarching Security Management Plan in line with PS4 for the mine concession and port areas, including the transportation route, as per ESAP # 11, to clearly outline rules and procedures, roles and responsibilities, for the private security and the national security forces. Surrounding communities will be informed of the security and crisis management measures and procedures put in place as per ESAP # 12 to minimize conflict and ensure clear rules of engagement to avoid violence within the control of GAC.

Protection and Conservation of Biodiversity  : The study areas (mine concession, rail corridor and port area) sit within the Guinea Forest-Savanna mosaic and Guinean Mangrove ecoregions. They comprise a mix of natural and modified habitats including wooded savanna, bowal, gallery forests in the valleys, agricultural land, freshwater and marine habitats including mangroves, mudflats and estuary. Remaining natural habitats have been significantly degraded through harvesting of wood, shifting agriculture and the planting of oil palm and cashews, nevertheless they still support several species of concern. Gallery forests and headwaters areas support highest numbers of species of concern and act as protection for the local watercourses.

Extensive surveys have been undertaken in the study area to understand the biodiversity and ecosystem services baseline. Surveys of the Critically Endangered sub-species of chimpanzee, the Western chimpanzee, Pan troglodytes verus were undertaken over a four-year period between 2010 - 2014 by the Wild Chimpanzee Foundation (WCF). The WCF estimated the population to be in the range to be 152 – 277. Updated transects and a detailed genetics study are now being undertaken to refine these estimates and allow for more targeted on site mitigation and habitat restoration. Biodiversity surveys covering other species and habitats were undertaken as part of the ESIA in 2014 and 2015. Further more detailed pre-clearance biodiversity surveys were carried out in 2016 for the water reservoir area, the water pipeline route, resettlement areas, and the process plant. 

A Critical Habitat Assessment (CHA) was completed in 2016 and updated in 2017. Critical Habitat is triggered for threatened species, restricted range species and unique/threatened ecosystems. This is based on the presence of gallery and mangrove ecosystems which are considered highly threatened in the Guinean context, and 7 terrestrial species and 1 marine species including the Western chimpanzee. The Endangered Pinto’s puddle frog Phrynobatrachus pintoi, and the Critically Endangered gecko Hemidactylus kundaensis who are found in the gallery forests and headwaters also trigger Critical Habitat. One individual of the Temminck’s Red Colobus Piliocolobus temminckii. was observed in gallery forest in the northern concession and is not thought to be resident. A significant population of the Vulnerable Atlantic Hump-backed Dolphin Sousa teuszi routinely use the estuary. This species is currently being upgraded to Endangered status.

A number of priority species which do not trigger Critical Habitat thresholds have been identified, including three species of Critically Endangered vultures, the hooded vulture Necrosyrtes monachus, the white-backed vulture Gyps africanus and Rüppell’s Vulture, Gyps rueppellii, and a number of restricted range fish Malapterurus teugelsi and Paramphilius teugelsi. 

Impacts at the mine site include direct and indirect loss and degradation of habitats including fragmentation, noise, air pollution, and the potential for invasive species. There may also be impacts to water quality and flow and consequently effects on freshwater ecology and loss of ecosystem services. Direct impacts include the loss of 3,200 ha of habitat including 1,592 ha of wooded savannah, 1,013 ha of bowal and 15 ha of gallery forest, however indirect impacts which are difficult to accurately define will likely result in further loss. Species such as the Pinto’s puddle frog and the gecko are not likely to be significantly impacted as a result of habitat loss as they inhabit the gallery forests and watercourses that are in the valleys (100 - 300m) from the mined plateaus. The Temminck red colobus was found in the northern concession which will not be mined as part of this project. The loss of preferred feeding habitat is not expected to significantly impact vultures as they are such wide ranging species. Pre clearance surveys will be undertaken to ensure that there is no loss of possible nesting sites. 

There will however be direct impacts on chimpanzees as they use a variety of habitats including those that will be lost to mining. Chimpanzees rely on several hundred different plants and ripe fruit, as well as trees for building their nests. Furthermore, fragmentation of the habitat may prevent the migration of females between groups, disturbing reproductive patterns. The concession will be under increasing human pressures linked to the expansion of the operations and other mining projects around the concession. These are likely to result in cumulative negative impacts to chimpanzees. 

Impacts at the port sites, include loss of mangroves, dredging and increased collision with marine mammals although it should be noted that the estuary is currently dredged and naturally has high suspended sediments. Piling could impact marine mammals such as the Atlantic humpback dolphin. Impacts along the railway corridor are not significant, as the corridor is already heavily degraded.

GAC has prepared a comprehensive Biodiversity Management Plan (BMP) and a Monitoring and Evaluation Management Plan (BMEP) to mitigate and monitor activities on the mine concession and port. GAC has also hired a biodiversity specialist to implement these measures to meet PS 6, further information on human resources is covered in PS 1.  

The Project has placed emphasis on avoidance through the development and implementation of ‘avoidance buffers’ around priority habitats and features. Avoidance buffers includes 50 m buffer from any waters, a 100m buffer from high ecological value sites and from the Tinguilinta River, 250 m buffer from wells, and a 300m buffer around headwaters feeding into gallery forests. This has resulted in some sterilization of ore. These buffer areas will help to avoid the majority of impacts on freshwater-restricted range fish, amphibians and reptiles. Careful monitoring, supported by an adaptive management approach and regular revision of management plans, will assess mitigation success and identify alternative mitigations where required. 

GAC is also implementing a disturbance protocol which requires surveys to be undertaken prior to disturbance in high risk areas. A comprehensive monitoring program includes not only the Critical Habitat values mentioned above but also other priority species such as vultures. In the marine study area, underwater noise modelling is being undertaken as well as the use of trained mammal observers and a dredge management plan is also being implemented. The area will be monitored for the presence of marine mammals and turtles. Ecological flow requirements are being set on any watercourses that might be impacted by the project. GAC has committed to progressively rehabilitating the mining plateaus with natural vegetation taking into account the needs of local communities for agricultural crops and this has been covered under Mine Closure and Rehabilitation in PS 3. 

Residual impacts after mitigation are unlikely to be significant for most species, and as long as monitoring verifies that impacts to the species habitat are not significant, no further action is required above the mitigation measures described in the BMP. GAC will update the BMP to incorporate the findings of the 2017/2018 Chimpanzee Survey. This is stipulated in ESAP # 14.

Some impacts however, will be difficult to avoid due to the location of the ore body and restoration will take time. Residual impacts on the Western chimpanzee, gallery forest and mangroves will be significant. The Biodiversity Consultancy (TBC), (2016) estimated residual impacts to be in the order of 30 - 60%, resulting in the loss of 50 to 160 Western chimpanzees. These estimates however are contingent upon the effectiveness of mitigation measures and could be influenced by human in-migration.  

As a result of these residual impacts, GAC has been working extensively with their partners, the neighbouring mining company Compagnie des Bauxites de Guinée (CBG), WCF, the Government of Guinea (OGUIPAR), TBC, their consultants and IFC to put in place a new National Park in Guinea. This will enhance the protection of an existing but threatened chimpanzee population and avoids predicted future losses of chimpanzees due to clearance of habitat for agriculture, charcoal and future mining and other development projects. This will offset residual impacts on chimpanzees arising from the mining projects. Work undertaken has included: a nationwide survey of potential offset site options; further surveys of a short list of offset sites; a pre-feasibility study to look at the feasibility of net gain at a few selected sites; a detailed feasibility study of final selected site to look at the technical, social and political aspects of implementing an offset, which is a new national park Moyen Bafing. The area currently supports around 4,400 chimpanzees which represents over 25% of all the chimpanzees in Guinea and around 13% of the estimated global Western Chimpanzee population in 2017. The offset area also supports extensive areas of very similar habitat to that impacted on the mining concession and should provide a net gain in habitat as well as providing an offset for chimpanzees. 

An Interministerial Commission was set up by the Government to carefully consider the establishment of a new protected area. The Commission approved the  Arrêté Temporaire   which establishes the boundaries of the park and stipulates how the Park will be established. It will take approximately two years for the National Park to secure the full decree status. The implementing partners for this phase will be OGUIPAR and WCF, although other partners will be brought in as required. A task force has been set up for this interim phase of two years which includes the companies, independent experts, WCF, the government and IFC to ensure collaboration between parties and to provide independent technical advice on proposed park activities and management. During these two years, there will be further detailed consultation with the local communities, and an ESIA will be undertaken to assess the implications of the National Park on local communities. In addition, a range of environmental and social projects will be undertaken such as afforestation and support for local community projects. GAC and CBG have committed to financing the Park and a Trust Company has been set up along with the appropriate governance structures to manage these funds. IFC provided additional funds to undertake a review of potential governance structures for the Implementing Partners. The Implementing Partners will prepare management plans and report on outcomes and compliance with PS 6 every year. GAC will incorporate a Trust Company or equivalent vehicle, for holding funds segregated for the purposes of the offset and enter into an Implementation Organization Agreement with the Trust Company and the implementing partner(s). This is stipulated in ESAP # 15.

Regarding the loss of Mangroves, GAC has set up a mangrove offset (68 ha) in the estuary (Taïgbé et Taïdy) which is currently being managed by local communities and an NGO. Improvements will be made to the management of this offset to ensure effective outcomes.

Protected or Recognized Areas  : The northern section of the mining concession which will not be mined as part of this project does marginally overlap with the Boulléré KBA which was designated due to presence of the Western chimpanzee. The existing rail corridor passes through the Kamsar KBA. This area was designated due to the presence of chimpanzees and the endangered purple marsh crab Afrithelphusa monodosa. The site appears to have degraded since its designation, nevertheless the site was avoided as part of the rail expansion so will not be affected by the project. Rio Kapatchez is at the southern tip of the marine study area and comprises a large expanse of mudflats, mangroves, sand dunes, freshwater marsh and rice fields. It is a KBA and Ramsar site due to the presence of significant numbers of both the Near Threatened Lesser Flamingo Phoeniconaias minor and the Greater Flamingo Phoenicopterus roseus and wintering waders. The project does not intersect with the site. 

Alien Invasive Species  : GAC have developed an Invasive Species Management Plan, which also contains requirements on contractors to develop their own invasive species plans and protocols.  This is applicable at both the mine and port site, and includes GAC’s maritime activities related to import and export operations of equipment and items for construction and operation of mining activities. The scope includes weeds, pests, fauna and flora pathogens e.g. Phytophthora, Chytrid, and quarantine. GAC has developed a biodiversity booklet which is a photo-guide including invasive species, mangrove species, threatened species within GAC.

Management of Ecosystem Services  : The study areas are used for a range of ecosystem services including medicines, drinking water, fishing, grazing, wild foods, wood for construction and energy and cultural services such as sacred sites. A stand-alone Ecosystems Services Assessment document was developed in 2015 and updated in July 2016. In recognition of the links between indirect impacts that in-migration and resettlement of communities can have on the ability of the environment to provide ecosystem services for local communities, close coordination between the GAC Environmental and Social (E&S) teams have taken place to mitigate impacts on ecosystem services. Measures to align social and environmental programs of work are therefore also included in the BMP. Consultation was held with local communities to accurately reflect the development of priority services. Of particular importance are freshwater and marine artisanal fishing and wood fuels which are the most frequently used energy source consumed by households. Project design and mitigation measures were done to specifically address stakeholder concerns about impacts on and access to ecosystem services. Other related mitigation measures include developing programs for improvement of agricultural practices and economic diversification, and providing support for the creation of community forests. Development and implementation of a RAP will also support conservation of ecosystem services, see PS 5 for further information.

If the BMP and BMEP are implemented effectively and the offset is managed well, they will not only address the key biodiversity and ecosystem service risks of the project but also provide a significant conservation gain for the Western chimpanzee. However, offsetting in Guinea is still in its relative infancy and the success of any offset will require the successful collaboration of the Company, Government of Guinea, NGO’s and communities.      

Protection of Cultural Heritage in Project Design and Execution:   For the mine concession area, a total of 230 cultural heritage sites were identified which include 156 sites of genies’ residences; 73 burial sites; 1 historic site (a natural cave). Out of the 230 sites identified, 89 are considered to be non-replicable by the communities. Most identified sites will not be affected by the project as they are not located on the bauxite plateaus or are considered replicable. This is the current case of the sacred forest that will be impacted by the construction of the dam. GAC is consulting with the communities to discuss and agree on required cultural and ceremonial arrangements to relocate the spirits. As for the port area, no cultural heritage features were identified that may be affected by the construction or operations of the project facilities in Kamsar. To manage these potential impacts, GAC will complete its Cultural Heritage Chance Find Procedure with a detailed Cultural Heritage Management Plan, as per ESAP # 16, to protect and manage sites and objects of cultural importance in consultation with local communities in accordance with IFC PS8 and Guinean legislation. GAC will ensure operators are trained according to the procedures.                                                 

Consultations  : GAC conducted and continues to have extensive consultations and information dissemination activities with surrounding communities around the mine site and port areas during the scoping and development of its first ESIA in 2001 and during the Addendum ESIA in 2014 - 2015. The engagement for the concession included parts of the sub-prefectures of Sangarédi and Tanéné in the Boké Prefecture and comprised 155 settlements as well as camps of transient cattle herders that cross the concession to reach the coastal area in the dry season. As for the port area, the engagement included the city of Kamsar, settlements located in the Sub-Prefecture to the south of the urban areas and part of the estuary of the Rio Nuñez. Potential project impacts on communities were discussed as well as economic and physical displacement, impacts on overall livelihood, job expectations, impact on water and fishing resources, and potential health and safety risks to communities and young girls. Specific concerns from communities relate to potential social frictions with other villages due to differences in support received by the project, adequate compensation and support for loss of land and livelihood, expectations for local employment for youth in particular, concerns on cultural heritage and burial sites being affected, and high expectations to benefit from the project. These concerns raised by the communities influenced GAC’s key actions in establishing the local recruitment centers, assessing alternative routes for access roads to avoid villages and sacred sites when feasible, establishing recruitment procedures prioritizing employment for PAPs and from surrounding communities, among others. Engagement was undertaken and continues to be held in the local language and with the help of graphics to ease understanding. GAC prepares and distributes a “Community Information Bulletin” every two months in villages within the concession area. GAC also organizes meetings with villages twice per year to discuss GAC’s support to local community development projects and review results as part of the Community Investment Strategy (CIS). GAC also engages with villages to meet and discuss specific concerns, such as access to employment or safety. All meetings, issues raised and interactions with communities are recorded in detail through the Borealis database system to track, internal follow up and assess trends. 

In regards to the offset and subsequent establishment of the National Park (refer to PS6 for further details), a process of informed consultation and participation (ICP) with the communities in the Moyen-Bafing area will be carried out as per IFC PS1. Communities will be involved throughout the entire process, specifically in key decision-making milestones, namely in identifying and thoroughly understanding the potential impacts; in discussing trade-offs and agreeing on alternatives in relation to access and use of natural resources, in determining the final boundaries of the national park and its three protection areas, in the communities’ role, obligations and involvement in the National Park, in clarifying the land tenure arrangements, in establishing conservation enforcement measures, and in including long-term livelihood programs according to their own aspirations for development. 

Stakeholder Engagement Plan  : GAC has conducted a stakeholder identification and analysis (refer to PS1 for further details) to guide its engagement process at the mine, port and rail areas as per the Stakeholder Engagement Plan (SEP) in line with PS1. The SEP will be updated on a regular basis as needed, and specifically when major events occur such as change of project phases (e.g. construction to operations) and new stakeholders are identified. The plan includes provisions for on-going liaison with regulatory authorities, establishment of local community liaison groups to inform and maintain open communications at the local level, publication of regular reports on environmental and social performance and monitoring. Stakeholder engagement activities will be monitored to ensure consultation and disclosure measures are effective through audits, monitoring of consultation activities, monitoring of the effectiveness of the engagement process in managing impacts and expectations by tracking feedback received from communities including grievances.  Quarterly and annual reports will be produced based on feedback and grievances received. GAC (not the contractors) conducts all direct engagement and consultation processes with the local communities at the mine concession and port areas. Engagement and consultation will continue throughout the project construction and operation phase ensuring that a long-term relationship is built with the surrounding communities and consistency of approaches (including management of expectations) are implemented. 

Stakeholder mapping/analysis  : As per the SEP, the following stakeholder groups were identified as they relate to the project: (i) the regional, prefectural and sub-prefectural authorities; (ii) local communities, including traditional authorities, village heads, community members, women’s and youths groups as well as fishermen and herders’ associations; (iii) general populations in the surrounding towns of Tinguilinta, Sangarédi, Boké and Kamsar; (iv) technical services at prefectural and sub-prefectural levels (water and forestry, fisheries, rural development, promotion of women and children, education, labor inspection, quality control, etc.); (v) port authorities (in Kamsar); (vi) the state security services (police, customs); (vii) health and education facilities staff; (viii) local private companies; and (ix) representatives from civil society (health committee, Islamic league, women's associations, agricultural groups, youth associations, NGOs, etc.).  

External Communications and Grievance Mechanisms  : GAC’s Grievance Mechanism (Managing Community Complaints) is in place and in line with IFC PS1. It is based on easy accessibility by communities, culturally adequate by being available in local languages (Poular, Sousou, Landouma), assurance of confidentiality, clear and transparent processing, and a mechanism that is simple and easy to use. A step by step grievance management is laid out from receiving the complaints, followed by their registration and handling by the Community Superintendent and the Stakeholder Engagement Director whereby the case is to be resolved within a specific time-frame. Tracking the case to its resolution and closure is also included as an important step. There is also a procedure for appealing the outcome of the grievance through Community Mediation Committee. Local communities can also have access to “Your Voice” mechanism to report any misconduct or grievance in relation to GAC and its employees. In reality, local communities reach out in person to the GAC’s Community Relations Officers to communicate any concerns or grievances in relation to the project, which in turn, the Community Relations Officers proceed to record and follow the internal grievance mechanism procedures as described.  

Information Disclosure  : As part of the approval of the ESIA addendum, BGÉÉE organized and conducted public hearings with the support of GAC: (i) on February 8, 2016, held at the Sangarédi Cultural Centre with the attendance of about 170 representatives from the surrounding communities; and, (ii) on February 11, 2016, held in Conakry with the participation of the Technical Committee of Environmental Analysis. For the ESIA for the MBS, a public consultation was held in Kamsar on September 6, 2016 and a Public Hearing in Conakry on September 14, 2016. The ESIA for the Rail was submitted in April 2017. It is awaiting approval from BGÉÉE and public hearings to be conducted accordingly. All ESIAs are available on GAC’s website as well as at the project site offices (mine, port and rail) and on IFC’s webpage in accordance with the Access to Information Policy. Copies of the ESIAs can also be requested by the general public through the BGÉÉE office in Conakry.

Contact person:

Daniel Pop, Chief Operating Officer
Company name: Guinea Alumina Corporation S.A. (GAC)
Telephone Number:  +224 626 268 256
Email: dpop@ega.ae

Mailing address:

P O Box 5090
Conakry, Republic of Guinea
Telephone: +224 62 323 8065                                                

Project documentation can also be accessed at the following sites:
Conakry         
www.gacguinee.com