27318 - Salamander UJV

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Environmental & Social Review Summary

Project Number

27318

Company Name

OPHIR THAILAND (E&P) LIMITED

Date ESRS Disclosed

Nov 25, 2008

Country

East Asia and Pacific Region

Region

East Asia and the Pacific

Last Updated Date

Nov 30, 2016

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Jan 7, 2009
Signed : Jan 14, 2009
Invested : Jan 20, 2009

Sector

Oil and Gas Exploration

Industry

Metals and Mining

Department

Gbl Infrastructure & Natural Resources

Project Description

Salamander Energy plc (Salamander or the company), an existing IFC client, is a young rapidly-growing independent oil and gas company exclusively focused on Southeast Asia. The company’s strategy is to build a sustainable upstream business through leveraging its regional knowledge and relationships; maintaining a balanced portfolio of production, development, appraisal and exploration assets; enforcing strict capital allocation discipline; and pursuing targeted acquisitions in addition to organic-led growth. Since its inception, Salamander has developed a broad set of assets, including producing and near-production interests in Indonesia and Thailand as well as exploration and appraisal properties in Indonesia, Thailand, Vietnam, Laos and the Philippines. Salamander is largely owned by institutional investors and is listed on the London Stock Exchange.

Salamander has invited IFC to acquire an equity interest (as an unincorporated joint venture partner) in certain of its operations in Laos and Thailand, by participating in a farm-in and development of Salamander’s interest in:
- the Savannakhet production sharing contract (“Savannakhet PSC”) in Laos and the adjacent onshore concession L26/50 in Thailand, as well as
- L15/50, another onshore concession in Northeast Thailand (together known as the “Project”).

Currently, the company holds a 70% share in the Savannakhet PSC and 100% interest in the Thai concessions, and is the operator for all three blocks.

The company is currently undertaking oil and gas seismic exploration in Laos and has a commitment to drill one test well. The company is also committed to seismic exploration in the Thai concessions and drilling of test wells in L15/50.

Overview of IFC's Scope of Review

The review of this project consisted of an appraisal mission in May 2008 to Salamander’s assets in Laos and review of the rapid environmental and social impact assessment for seismic exploration. The project sponsor is an existing IFC client. During April 2008, IFC undertook an appraisal visit to Salamander’s key assets in Thailand and Indonesia in respect of an earlier investment. IFC also held meetings with management and key staff from Salamander in Singapore and reviewed related technical, environmental and social reports. Please refer to the Environmental and Social Review Summary (Salamander: #26478) available on IFC’s website (www.ifc.org/disclosure) for a detailed description of the earlier investment.

Activities undertaken during the appraisal in Lao included:

- Discussions with Salamander on key environmental and social aspects of their assets in Lao;
- An overview assessment of environmental and social issues, community engagement and development activities to date;
- Field visits to the exploration assets in Laos and accommodation camps;
- Meetings with the department of mines, Provincial Governors (in Thaphangthong, Saravane and Savannakhet Provinces) and District heads; and
- Meetings with village head, Ban Nasano village.

E & S Project Categorization and Applicable Standard

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:

- Performance Standard 1: Social and Environmental Assessment and Management Systems;
- Performance Standard 2: Labor and Working Conditions;
- Performance Standard 3: Pollution Prevention and Abatement;
- Performance Standard 4: Community Health, Safety and Security;
- Performance Standard 5: Land Acquisition and Involuntary Resettlement;
- Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource Management; and
- Performance Standard 8: Cultural Heritage

Performance Standard 7 (Indigenous Peoples) is not applicable to the assets identified above under the project description as there are no Indigenous people in the area.

Environmental and Social Mitigation Measures

Salamander is a small oil and gas company that was recently established and is still in the process of maturing its environmental and social management systems. Salamander has committed to finalizing the company’s Corporate policies on environmental and social management in line with IFC’s Performance Standards. This commitment is reflected in the Action Plan that forms part of an earlier IFC corporate investment (Salamander #26478).

IFC undertook a due diligence to assess compliance of project’s exploration activities in Lao with the Salamander’s social and environmental management system and IFC’s Performance Standards in May 2008 and visited some of Salamanders assets in Thailand as part of an earlier investment. The company is committed to comply with national requirements of both Laos and Thailand for environmental and social management of their assets in the respective countries, and with IFC’s Performance Standards on Social and Environmental Sustainability.

IFC assessed the magnitude of the potential impacts associated with the projects. The environmental and social impacts from the projects will be addressed by the company upon the implementation of the management plans and the mitigation measures described below.

The key environmental and social issues are presented below along with proposed mitigation measures. Once mitigation measures (presented in the attached Action Plan) are implemented and corrective action undertaken, the project will comply with IFC Performance Standards and respective Laos and Thailand environmental regulations and requirements.

- Savannakhet PSC, Laos

The Savannakhet PSC has a mixed ecology made up of the Southeastern Indochina Dry Evergreen Forest and the Central Indochina Dry Forests ecoregions. The former is more appropriately called semi-evergreen forest because a significant proportion of canopy tree species are deciduous at the height of the dry season. The Southeastern Indochina Dry Evergreen Forests ecoregion occurs in humid and subhumid climatic regions where mean annual rainfall is generally between 1,200 and 2,000 mm, and a significant dry period of 3-6 months occurs each year. Semi-evergreen forest is the predominant forest cover in this ecoregion, but it often occurs in mosaics of deciduous dipterocarp or mixed deciduous forest communities. In addition, the Central Indochina Dry Forests ecoregion is extensive in coverage along the broad valley of the Mekong and its tributaries in central and southern Laos.

Two IUCN category 6 areas were identified in the Savannakhet PSC, Phou Xieng Thong (15 35 6N and 105 37 42E) Xe Bang Nouan (15 52 58N and 105 55 47E), National Biodiversity Conservation Areas. Category 6 is a “Managed Resource Protected Area”, that is a protected area managed mainly for the sustainable use of natural ecosystems.

The block has three Districts – Lakhonepheang, Thapangthong and Songkhone. Lakhonepheang Districts is made up of 84 villages but in the specific seismic survey area 38 villages with a mixed ethnic population, predominantly Lao loum/Laoland and Laotheung/Lao lowland. Thapangthong District has 17 villages in the specific seismic survey area, of these 7 villages are ethnic Laotheung/Lao lowland, and 10 Villages Laoloum/Laoland. Songkhone District has only 9 villages in the specific seismic surveyprincipally Laotheung/Lao lowland, and Laoloum/Laoland. Farming is the predominant practice in this low populated area.

- Blocks L26/50 and L15/50, onshore Thailand

The project area in Block L26/50 covers parts of Ubon Ratchathani Province in the north-east of Thailand and a full EIA was approved by ONEP in October 2008. The surrounding area is predominantly agricultural with limited forested areas and a sparse population. There are 78 villages, 11 temples, eight schools and eight dams/reservoirs located near the proposed seismic. For this project we have defined potential sensitive receptors as villages within 120 m of a line or temples, schools, dams and reservoirs within 200 m of a line. These distances are based on safety distances from previous seismic surveys in Thailand. Deciduous dipterocarp forest and evergreen forest cover a large part of the project area. Species diversity within Ubon Ratchathani province is limited. This is because the area used to be a concession for wood production and these floral species are now in the recovery state. Some parts of the forest has been transferred to land reform for agriculture for local people. Most of the project area is classified as agricultural (54.7%), whilst other land uses include 42% of forest, 3% of communities, and 2% of water resources. The L15/50 Block falls within the Chaiyaphum and Khon Kaen Provinces, and EIA project has been initiated in November 2008.

Social and Environmental Assessment and Management Systems:

- Salamander’s Health, Safety and Environmental (HSE) Policy

Salamander’s HSE Policy reflects its commitment to conduct its operations in compliance with appropriate Industry Best Practice that includes the safety and health of employees, protection of the environment, and consultation with the surrounding communities. Salamander requires all its contractors to develop their own environmental and social management systems in line with Salamander’s HSE requirements and policy which is reflected in all contractual agreements. Salamander is in the process of completing the development of its Environment, Health, Safety and Social Management System in line with ISO 14001, OSHAS 18001 and IFC Performance Standards. For more information on Salamander’s HSE policy and capacity, please refer to the Environmental and Social Review Summary (Salamander No.# 26478) available on IFC website (www.ifc.org/disclosure).

- Lao Environmental Protection Law

Lao’s Law on Environmental Protection establishes principles, rules and other measures for the management, inspection, rehabilitation and protection of the environment, natural resources and people’s health to ensure sustainable national socio-economic development. Environmental and Social Impact Assessments (ESIAs) must be drafted in compliance with relevant prescribed regulations for all development projects with potential environmental and social impacts, together with mitigation management plans, and submitted to an environmental management and inspection agency assigned to consider and issue environmental certificates.

Environmental and social impact assessments must involve local administrative authorities, public organizations and people who will be affected by the development project and its activities. EIA’s are required to address various aspects including: use of appropriate technology, construction and maintenance of infrastructure; natural resource utilization; protection of biodiversity; protection of cultural heritage, historical and natural resource conservation areas; pollution control; and environmental rehabilitation. In addition, the rights and duties of various stakeholders must be addressed, including District Environmental and Inspection Units; Village Administrative Authorities and the company in implementing environmental and social management plans.

- Thai Regulations for Environmental and Social Impact Assessments

Thailand has stringent environmental regulations which also include screening of socio- economic aspects of development projects. The Ministry of Natural Resources and Environment, the Thai environmental regulator, has recently issued two new guidelines on “Social and Health Impact Assessment” which are based on World Bank guidelines and policies.

The ESIA process includes a comprehensive public consultation program. The program is undertaken in a participatory manner that allows local communities to freely express their views and influence the decision making process on project design aspects such as pipeline route selection, etc. The public consultation process is divided into two phases. During Phase I, public meetings with project-affected communities are held in the early stages of the ESIA study. These meetings are open to all and include key representatives from affected villages, such as community headmen and teachers. The main objectives of these sessions are to:

- inform the local communities of the proposed project and associated activities and
- undertake an “Attitude Survey” (perceptions of local communities regarding the project).

Phase II involves presentation of the Attitude Survey results and proposed mitigation measures to the local communities and a question and answer session on the draft ESIA.

Subsequent to the completion of the consultation process, the draft ESIA report is disclosed to local communities for comment. The final ESIA report is submitted for approval to the Thai environmental regulator. The final ESIA and relevant baseline studies are available to the public. The right to information is established in Thai regulations which require that information is made easily accessible to the public.

- Environmental and Social Impact Assessment Studies

As detailed above a full and formal EIA was prepared for the L26/50 seismic program and received sanction from ONEP in October 2008. The L15/26 seismic EIA was initiated in November 2008.

For the seismic activities in Laos, Salamander undertook a high level environmental and social impact screening. The screening included a management and mitigation plan for seismic activities and installation of temporary camps. Salamander worked with the Contractor and their sub-contractor to strengthen their capacity to manage issues such as solid waste and liquid effluents resulting from their operations. Salamander is currently strengthening its capacity to manage contractor performance and ensure compliance with its environmental and social policies and IFC Performance Standards.

As the project progresses towards achieving commercial viability and reaches field development stage, Salamander will conduct Environmental and Social Impact Assessment Studies proportionate to the nature and scale of the proposed development’s potential impacts and in accordance with Lao and Thai regulations, and IFC’s Performance Standards.

Labor and Working Conditions:

Salamander’s Code of Business Conduct outlines it’s commitment to appropriate business practices, including working conditions. The code applies to Salamander as well as its contractors. The code outlines Salamander’s policy with respect to employment which includes the following main aspects:

- equal opportunity,
- competitive terms of employment,
- safe and healthy working environment,
- compliance with national labor laws, and
- adherence to and respect for human rights principles.

The seismic exploration activities for the Savannakhet PSC in Laos were completed at the end of July 2008. The seismic team was based onsite for a period of 4 months. Temporary camps were installed to accommodate a workforce of approximately 500 workers. The camp was decommissioned but not dismantled. It will be used to accommodate the drilling crew that will commence work in January 2009.

The main contractor, a French company called CGGV subcontracted all camp management services to Sodexo. The CGGC camp was established to accommodate up to 500 workers. All the workers were accommodated in very basic temporary dormitories with separate accommodation facilities for female workers.

There was a well supplied clinic in the camp staffed by a doctor and nurse, available to all workers free of charge. Health awareness training, including occupational health training, was provided to workers. Common ailments were gastro-intestinal and respiratory infections. There is limited occurrence of malaria in the area, and workers were not taking prophylactics, but all were issued with bed nets. There was limited occurrence of sexually transmitted diseases amongst the workforce and very few cases of HIV/AIDS amongst the local population. Awareness training for HIV/AIDS issues is limited. According to the clinic doctor, the issue is very sensitive and there are only a few recorded cases in the district.

Workers for the seismic survey were employed from three districts within which the survey is taking place. Approximately 50 of the 500 workers were women (employed in the camp for cleaning and cooking purposes). Initially workers were employed on a rotation basis (six weeks on and two weeks off) but Sodexho changed this arrangement to a daily rate scheme. While workers originally had a two week break, the new scheme resulted in a continuous work schedule. This system was contrary to the needs of the workers, who with the onset of the planting season, needed to return home to help their families prepare the rice paddies. Subsequently, Salamander with Sodexho developed and implemented flexible work schedules to rotate workers to allow them to return home and undertake land preparation and crop planting activities. Wages paid by Sodexho were in line with the labor market rate for Southern Laos but remuneration rates for similar work in nearby Thailand are considerably higher. In May Sodexho had difficulties in finding sufficient workers and employed 40 personnel seconded from the Laos military to work in a civilian capacity.

There is a grievance mechanism for workers to voice their concerns and issues.

IFC is working with Salamander to improve camp standards in line with IFC’s Performance Standards and international best practice. Salamander is preparing a Corporate Labor and Working Conditions Procedure.

Salamander will develop a Corporate Code of Conduct that explicitly describes contractor and sub-contractor requirements for labor and working conditions. The Code of Conduct will also take into account local needs such as flexible work schedule to enable workers to continue their farming activities. This Code of Conduct will be included in all contractual agreements with contractors and any other third parties that Salamander will engage. The Code of Conduct will be in line with Performance Standard 2 and international best practice.

Salamander will develop a supervision and monitoring plan to monitor contractor compliance with the Code of Conduct and the requirements of PS 2 and follow-up on the implementation of corrective actions to mitigate non-compliance. As part of the monitoring plan, Salamander will develop a schedule for Labor Audits that will be undertaken every 3 months once exploration activities recommences.

The Company Code of Business Conduct and Corporate Labor and Working Conditions procedures will specifically include provisions on non-discrimination and equal opportunity, wages and benefits, preferential local hiring, disciplinary practices, grievance mechanism and adequate working and living conditions. These procedures will be communicated to all employees in an appropriate manner.

All accommodation camps that will be installed for exploration activities will be designed such that environmental, health & safety, and social impacts associated with camp activities are minimized. Living conditions in the camp will be achieved and maintained in accordance with IFC Performance Standard 2 and international best practice.

Pollution Prevention and Abatement:

Salamander’s HSE Policy reflects the company’s commitment to the protection of the environment and compliance with international best practice and national regulations. For its Laos operations, Salamander is strengthening its capacity to supervise contractor compliance with its HSE requirements and policy.

Salamander requested the contractor to discontinue the practice of discharging wastewater and sewage to nearby rice paddies (undertaken subsequent to the owners’ consent since they saw value in added nutrients for crop growth). An abandoned local quarry site was used for disposal of sewage and liquid waste. As part of the Corrective Action Plan, Salamander is addressing environmental issues associated with liquid effluent disposal as well as soil and groundwater contamination issues and solid waste disposal. The action plan is also included in the IFC corporate investment Action Plan (refer to Salamander: #26478). Salamander has already started taking remedial action and installed monitoring wells around the septic pond at the quarry to monitor potential groundwater contamination. Salamander will rehabilitate the liquid effluent disposal site at the quarry.

Community Health, Safety and Security:

As mentioned earlier, Salamander has installed monitoring wells to investigate whether there are any instances of groundwater contamination and assess any potential health risks to the surrounding communities.

Salamander has in place adequate safety and defensive driving training for employees. There are also strict regulations for vehicle and journey management. Emergency Response plans are in place which Salamander will communicate to local communities for future exploration activities.

The explosives store (used during seismic surveys and now fully decommissioned) was located approximately 1 km from the camp close to the quarry site used for waste disposal. As part of the Government requirement, a detachment of the Laos military guard the explosives store at all times. Unarmed private security guards were employed at the camp.

For all future exploration activities, Salamander and their contractors will assess the health and safety risks to nearby communities. This assessment will include impacts associated with increased traffic, noise, vibration, waste disposal and health related issues such as communicable diseases, open pit waste burning. Salamander will also conduct preventive health awareness campaigns for communicable diseases etc. that may affect the communities and migrant workers.

Land Acquisition and Involuntary Resettlement:

Laos and Thailand have established procedures for compensation for land acquisition and damage to crops at local market rates.

There is no long term or permanent land acquisition associated with seismic surveys. The seismic survey involves only temporary access to land on two instances - to undertake clearance activities of any unexploded ordinance (UXO) from previous conflicts in the area associated with the Vietnam War, and to undertake the seismic surveys. The clearance for the survey lines included clearing grass, bushes and saplings but avoided built structures and any trees with a diameter of more than 10cm. The seismic survey was undertaken during the dry season during which there was no damage to crops. In addition, there is no damage to fences, irrigation ditches, roads or any other built structures.

The accommodation camp was located on a previous camp site used for a road construction project. The site is owned by the Provincial Government and was made available for establishment of the CGGV camp.

Should the surveys be successful in finding potential oil and gas resources, then land will need to be acquired for well drilling, camp facilities, access roads and other infrastructure requirements.

For all future seismic and exploration activities, Salamander will ensure adequate staff is in place to oversee land acquisition activities and the compensation process.

As part of IFC corporate investment with Salamander, Salamander has prepared a Corporate Framework Land Acquisition and Compensation Plan (LACP). The LACP outlines the principles, guidelines and approaches that will be followed for land acquisition activities. The LACP also requires that each country operation prepare a national LACP that meets national regulations and IFC Performance Standards.

Biodiversity Conservation and Sustainable Natural Resource Management:

Portions of the seismic survey lines cross protected forest under IUCN category six (6), which allows for the sustainable use of the forest area by other land users. The Company’s activities have not had any significant impacts on these protected forest areas. The environmental screening report (HSE-020G Environmental Screening Savannahkhet PSC 2D Seismic 20-01-08) identified environmental protection measures which include a restriction on felling of trees larger than 10 cm in width in the course of seismic exploration and survey lines are re-routed to avoid large trees.

Cultural Heritage:

Several sites of cultural heritage were identified within the seismic exploration survey area in Block L26/15 as part of the EIA process. As part of the Action Plan for IFC’s corporate investment in Salamander, the company prepared a “Chance Finds Procedure” for its operations. The company is required to implement the Chance Finds Procedure in all Salamander operated assets.

Stakeholder Engagement

Lao government structure is very hierarchical with strict protocols. Salamander has established very good relations with the Provincial Governors and their senior staff (including Departments of Mines), and local District Heads. There is government and local administration support for the project and hope that current seismic surveys will identify exploitable oil and gas resources. Salamander needs to manage raised expectations associated with the project.

Currently interaction with local communities is being spearheaded by local district heads and village heads. The degree to which local villagers are aware of the project appears to be dependent on the extent to which each village head shares information and provides feedback. Salamander has had public meetings at the district level as required by Lao ESIA procedures. There is also interaction with villagers with respect to employment opportunities on survey teams, and in preparation for, and during the unexploded ordinance (UXO) clearance exercise and seismic surveys. While existing consultation is satisfactory, for any subsequent phase of well drilling, Salamander will design a consultation process that will ensure community participation and engagement.

There is an established process in Thailand for consultation with local communities and local authorities at the provincial and municipal levels. Community engagement is a requirement by Thai law and is undertaken with local communities, community leaders and local authorities located adjacent to project developments to provide information on project impacts identified in the ESIA, and related aspects (hazards, emergency procedures, opportunities for employment, etc). The consultation program also includes a perception survey to gather feedback from the local communities on the proposed project development. It commences during the ESIA stage and continues throughout the construction and operation phase.

As part of IFC corporate investment, Salamander prepared a Framework Public Consultation and Disclosure Plan (“PCDP”) to ensure that stakeholder engagement is conducted in accordance with national regulations for respective countries, IFC’s Performance Standards and international best practice. Salamander will prepare country specific PCDPs for its operations in Laos and Thailand respectively.

Client Documentation

File Name	Actions
Action Plan .pdf

**Information on IFC's Policy and Performance Standards on Environmental and Social Sustainability can be found at www.ifc.org/sustainability

IFC supports its clients in addressing environmental and social issues arising from their business activities by requiring its real sector clients to set up and administer appropriate grievance mechanisms and/or procedures to address complaints from Affected Communities in relation to environmental and social issues arising from IFC's clients' business activities. Since 2012, IFC's Financial Intermediary clients applying the Performance Standards are required to develop External Communications Mechanisms to receive and review inquiries or complaints from any interested party regarding the E&S risks and impacts of their operations.

For IFC projects that are active or under consideration, individual(s), or their authorized representative(s), who allege they have been or will be adversely affected by E&S risks or impacts arising from IFC's clients' business activities, may submit a complaint to IFC directly for consideration. When receiving an E&S complaint, IFC engages with complainants and works with its clients to find solutions to E&S concerns as quickly and efficiently as possible.

Complaints can be submitted to IFC online at www.ifc.org/escomplaints or by email to EScomplaints@ifc.org.

IFC complaint response is separate from and complementary to IFC’s clients’ project level grievance mechanisms and IFC’s Independent Accountability Mechanism (CAO). Lodging a complaint directly with IFC does not, at any time, restrict access to CAO.

Affected communities have unrestricted access to the Compliance Advisor Ombudsman (CAO), the independent accountability mechanism for IFC and MIGA. CAO facilitates the resolution of complaints related to IFC and MIGA projects and sub-projects, undertakes reviews of IFC’s and MIGA’s environmental and social compliance, fosters public accountability for their commitments, and enhances the environmental and social performance of IFC and MIGA.

Independent of IFC and MIGA management and reporting directly to the IFC and MIGA Boards of Executive Directors, CAO helps resolve issues raised about the environmental and social impacts of projects through a neutral, collaborative, problem-solving approach via its Dispute Resolution function. It also reviews IFC’s and MIGA’s compliance with environmental and social policies, assesses related harm, and recommends remedial actions through its Compliance function. Additionally, CAO provides advice to IFC, MIGA, and their Boards to enhance environmental and social sustainability performance and minimize the risk of harm.

Complaints may relate to environmental and social harm regarding any aspect of the planning, implementation, or impact of a project or sub-project, and can be made by any individual, group, community, entity, or other party affected or likely to be affected by the environmental or social impacts of an IFC- or MIGA-financed business activity.

Complaints can be submitted by any of the following methods:

Online form: available at https://www.cao-ombudsman.org/
Mail/Hand Delivery to: 2121 Pennsylvania Avenue, NW, Washington, DC 20433, USA
Voice mail: +1 202 458 1973
Email: cao@worldbankgroup.org
SMS, WhatsApp, Telegram, and Signal: +1 202 650 2627

CAO receives and addresses complaints in accordance with the CAO Policy, which can be accessed at: https://www.cao-ombudsman.org/policies-guidelines.

This Environmental and Social Review Summary (ESRS) is prepared by IFC to disclose its findings and recommendations related to environmental and social considerations regarding potential investments. Its purpose is to enhance the transparency of IFC's activities. For any project documentation or data included or attached herein, whether prepared by the project sponsor or otherwise, authorization has been given for public release by the project sponsor. IFC considers that this ESRS is of adequate quality for release to the public, but has not necessarily independently verified all of the project information therein.
It is distributed in advance of IFC Board of Directors' consideration and may be periodically updated thereafter. Board dates are estimates only and this document should not be construed as presuming the outcome of the Board Directors’ decision. The following ESRS is disclosed in accordance with IFC's Access to Information Policy (AIP).

The map is for illustrative purposes and does not imply the expression of any opinion on the part of the World Bank, concerning the legal status of any country or territory or concerning the delimitation of frontiers or boundaries. Country borders or names do not necessarily reflect the World Bank Group's official position. In some cases, available project location information is limited to the country of the project's activities. Locations are approximate.

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Environmental & Social Review Summary

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Overview of IFC's Scope of Review

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Environmental & Social Review Summary

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