PS 1: Social and Environmental Assessment and Management Systems
EMX has recently developed a set of policies regarding community, environmental, labor and health and safety for exploration activities. It is based on the IFC PS as well as similar standards developed by Newmont for worldwide use, which sets the requirements for operational aspects of exploration activities in such a way that they are conducted consistent with established policies, including the protection of human health and the environment. EMX is committed to implement these policies for new projects that it manages. Generally JV partners (in particular Newmont) have standard procedures for the development of roads, drilling pads; and other facilities are defined and planned along with management practices for control of erosion and the minimization of sediment generation. Procedures and plans for the reclamation of disturbed areas are also defined. Most written policies and/or procedures stipulate that all activities should be conducted in a manner that is cognizant of biodiversity in the area and are protective of water quality (via sedimentation) and air quality. EMX has also developed a strategy document for stakeholder engagement.
EMX is committed to develop a corporate Social and Environmental Management System (SEMS) that will be applied for all future projects. For existing JV projects EMX will use reasonable efforts to work with its partners to implement the recommendations made by IFC in the Action Plan.
Haiti:
Socio-economic Baseline Studies - Although some information has been gathered at each exploration site concerning local socio-economic circumstances and land rights, there is no formal social baseline documentation. Given the relatively densely populated rural areas in which the exploration properties are located, the complex issues associated with land rights and land use, and with impoverished households largely dependent on subsistence agriculture, EMX will work with Newmont to ensure that key social baseline information is obtained and documented in order to address and implement adequate mitigation measures. With the agreement of Newmont, the company will undertake scoping socio-economic baseline surveys (SEBS) for each of the current exploration properties (La Miel, Gran Bois, and Treuil) and for any exploration properties that are acquired in the future. Each SEBS will clearly define and map the area of influence and footprint of exploration operations based on IFC’s PS definitions (including access roads, directly and indirectly affected communities, cumulative impacts, etc). Each SEBS will provide a comprehensive profile of socio-economic circumstances pertinent to current and proposed exploration and drilling activities, including information on current land use and livelihood activities, land rights, affected households, local demographic profile, etc. If any of the exploration sites develops into a mine, detailed socio-economic baseline studies will be undertaken as part of the Social and Environmental Assessment (SEA) for the greenfield mine.
Marien Mining Corporation (MMC), the local subsidiary of EMX, fully recognizes the extent of environmental degradation in Haiti and is well aware of the limited environmental regulatory capacity. The risk of poor management of unrealistically raised expectations is key for MMC, especially since poverty is most pronounced in the northeast of Haiti, followed by the northwest, where all properties are located.
Early ‘baseline’ studies will be undertaken to establish existing conditions prior to drilling in addition to meeting expectations by regulators on environmental work. Drilling will be undertaken by the end of the year using ‘man-portable’ rigs transported on roads constructed for ATVs, thereby minimizing footprint and environmental impacts. MMC and Newmont are demonstrating a responsible approach to the prevention of erosion/land degradation and to reforestation/re-vegetation by carrying out reclamation of all land disturbances of exploration works early on, and by constructing proper erosion control systems for new infrastructure (camps, access roads, bridge). Some recommendations were discussed relative to fuel management and effluent disposal to further improve environmental practices.
Environmental management is important for Newmont, which is implementing an Environmental Management System (EMS) for environmental practices at camps and in the field, based on its recent successful operations in Suriname. Initial water and sediment sampling was conducted in November 2008 and recently a second tranche of water/sediment sampling was completed, as well as initial data assembly and site review. Initial results show that sediment control is being managed within reasonable limits. Results indicate low metal levels (as expected) while currently bacteriological analyses are not possible due to long holding times from remote sites. EMX and Newmont have agreed to document appropriate key environmental baseline information in order to address and implement adequate mitigation measures.
The IFC team met with the Direction Générale de l’Environnement and the Bureau des Mines et de l’Energie in Port-au-Prince to inform key officials about IFC’s potential investment in EMX. The focus of these discussions was on how to mitigate, at an early stage, any impact on land use and local communities, as well as protecting the already severely degraded environment from any further soil erosion and surface water degradation, and contributing to rehabilitation measures.
Turkey:
Turkey’s Eurasian operations are well managed and there is high awareness of potential environmental and social risks as they relate to exploration activities, as well as solid experience as to how these risks need to be managed within the national regulatory context. The operations in Turkey are managed by both Eurasian directly and by Chesser and Centerra. All have long standing experience working in Turkey with the exploration programs of major companies such as Rio Tinto and BHP, and are knowledgeable about the national regulatory framework as it relates to mining and environmental permitting/management. EMX Turkey is proactively identifying and managing social and environmental risk, supporting Chesser and Centerra E&S work. EMX’s work with its Turkey JV partners is helping to enhance E&S management capacity and provide for the application of good international industry practice.
To date, the Company has formally assessed and managed risks related to water quality on their Sisorta and Akarca sites. Overall, the key for building on existing efforts and improving the management of E&S issues will be the development of a more formalized management system. This approach will allow the company to systematically assess, document, and monitor the impacts of its activities and the effectiveness of its responses to minimize and mitigate such impacts, and to develop a strategic approach to community consultation based on a better understanding of past performance, of community characteristics, and of the gaps in the current engagement process. EMX is working on a reasonable efforts basis to have Chesser and Centerra put in place management systems and procedures to provide for this more formalized approach to the management of E&S issues for EMX’s Turkey properties.
Monitoring and Reporting:
In Haiti, Newmont is in the process of putting together a monitoring plan for Gran Bois and La Miel as part of the implementation of the EMS. Reporting will be formalized under the HSEC/L policy. Annual reporting to affected communities on the progress made in implementing the ESAP will also be undertaken for each project site going forward. In Turkey, Centerra and Chesser are following similar processes in line with EMX HSEC/L Policy.
PS2 Labor & Working Conditions
Haiti:
MMC and Newmont have established an Employment Policy for the Northern Haiti joint venture, which is focused on providing a transparent policy for access to temporary employment opportunities, labor contracts, and contracts to provide local goods and services. The policy provides for non-discrimination in hiring and for remuneration and compensation that complies with Haitian law. The policy places emphasis on providing equal opportunities and hiring from local communities adjacent to exploration activities.
At the existing exploration sites in Haiti, local labor has been used for trenching, base camp construction, construction of access tracks and roads, carrying in supplies and portable drilling equipment. There is keen local competition for jobs, and in order to provide opportunities to as many local people as possible, a system of rotational temporary employment has been implemented. This keen competition and rivalry between communities, together with some misunderstandings, has resulted in some disputes. Eurasian Minerals and Newmont have addressed these disputes in a professional manner, successfully dissolving tensions. As part of the formalization of the stakeholder engagement process, Eurasian Minerals will give increased attention to labor issues and the establishment of appropriate site specific grievance mechanisms.
Current Eurasian permanent staff in Haiti is about 10 while Newmont has over 40 professionals in the field. In the past year, Eurasian has provided some form of direct employment at various times to about 900-1200 people. It is expected that in the next year it will continue to employ about 800 – 1000 people on a rotational basis.
Turkey:
While there is no specific policy on local hiring and procurement in place in Turkey, the approach is similar to the one applied in Haiti. EMX, together with Chesser and Centerra, works closely with the local municipalities and engages with affected communities, who agree on and make hiring recommendations to the Company with a view to spreading the benefits of local employment broadly amongst community households. Local labor has been used for sampling, trenching, construction, catering, etc. and, just as in Haiti, a system of rotational temporary employment has been implemented. The Company pays rates above minimum salary and in line with the regional market. In order to formalize this process and increase its transparency, EMX will develop a policy for Turkey and will include non-discrimination and equal-opportunities provisions, aiming to widen opportunities for employment amongst local communities, and especially to encourage the employment of women.
Current Eurasian permanent staff in Turkey is 6. During the busy exploration period in 2008, EMX had more than 13 permanent local hires in Sisorta and up to 25 casual workers, with an additional 30-40 laborers hired locally through the drilling contractor. In Akarca, there is one permanent local hire and in 2008 some 10 temporary workers were hired as well. These employment numbers, however, are highly variable and dependent on the levels of activities on the ground.
PS 3: Pollution Prevention & Abatement
Each EMX local operation and its joint venture partner are implementing a series of procedures to monitor the impacts of past and current exploration activities. The company is actively undertaking measures to reduce and minimize environmental impacts; where possible, existing tracks are used, and the containment of drilling fluids and the use of other prevention and control measures minimizes any impacts on natural waterways. EMX and its JV partners are putting in place a monitoring process including sampling and analysis of surface water and measuring air quality at all sites. Reclamation and re-vegetation work is pending final drilling results and future infrastructure requirements for development. EMX and its partners will proceed with rehabilitation of any disturbed land that is in excess of its needs.
At this early stage of exploration activities the pollution prevention activities are very site specific. Generally exploration can influence air quality through the generation of dust and due to exhaust from internal combustion motors. As part of the EMS, Newmont has in place a Procedure for Air Quality and Dust Control with the objectives to minimize the generation of dust as well the impacts due to combustion of fossil fuels. MMC and Eurasian Turkey are implementing similar procedures at their respective exploration properties.
In Turkey, water monitoring is undertaken routinely by SRK, a reputable environment and mining independent consulting company. At Sisorta, in order to define the chemical and physical characteristics of water, samples (12 surface waters and 3 spring waters) have been collected from 15 points periodically since May 2006. Additionally, samples are also taken from drinking water sources. Similar water sampling and monitoring has been undertaken in 11 locations at the Akarca prospect area since May 2007. As part of the HSEC/L policy that EMX will develop, monitoring will also be programmed with JV partners in respect of all other E&S risks and impacts identified.
At this stage of the exploration works the estimation of EMX GHG emissions is around 1676 tonnes of CO2 per year, comprising mostly diesel consumption, generators and purchased power.
PS 4: Community Health, Safety and Security
Haiti:
Influx Management - In a socio-economic environment where there are very limited livelihood and economic opportunities, there is significant potential for a major influx of people seeking employment and the establishment of enterprises associated with mining development. There has already been some minor influx of people seeking employment associated with existing exploration and access road construction activities. The Land Acquisition and Compensation Strategy will also address measures to manage and mitigate possible influx of newcomers seeking opportunities associated with exploration, drilling activities and possible eventual early mine development. Should mine development proceed at any exploration site, a detailed Influx Management Plan will be prepared prior to any mine construction.
Security forces – Given the political and social climate it is necessary to have personal bodyguards in Port au Prince and when travelling by car between the main cities. This is also the case at the main camps at La Miel and Gran Bois with armed security guards full time on site. EMX will review the requirements of the Voluntary Principles on Security and Human Rights (‘Voluntary Principles’) and ensure that these are addressed in corporate and country specific policies. The Voluntary Principles are regarded as best practice for extractive industry companies operating in difficult environments. This implies, amongst other things, that project-related security risks will be identified; private security personnel will be screened for prior human rights abuses and will be properly trained in how to deal with members of the public; the company will have specific policies and procedures in place in relation to the conduct and the use of force, providing only for defensive and preventative measures; that security-related incidents will be properly investigated and that perpetrators will be dealt with appropriately; and that the company will inform any public security agencies which may become involved in its affairs of its policies and preferences for dealing with third parties; and the company will use its influence to promote human rights, the appropriate use of force where necessary and the avoidance of violation of workers’ rights under national laws and ILO conventions.
Turkey:
The impacts on community health, safety, and security are limited at this stage of exploration to Sisorta and Akarca, and influx management is not a major risk in these areas. The most critical, albeit limited, potential risk is the possible impact on local water resources and this is already being closely monitored by the Company. Major improvement in community health was actually derived from EMX’s assistance in one of Sisorta’s host villages, by providing access to clean potable water, following baseline information that produced alarming results of high levels of naturally occurring aluminum and acidity.
Emergency Response Plans at exploration camps in Haiti and Turkey are updated regularly; equipment such as radio and cell phones, first aid boxes, fire extinguishers, communication equipment, and designated emergency response vehicles are regularly checked and maintained. A comprehensive first aid kit is available at each exploration or base camp, and with each drilling rig operating in the field. Site Managers, additional staff in the field and in the main Office in Port-au-Prince and in Ankara have official First Aid Qualifications.
EMX will develop a corporate document for Emergency Preparedness and Response Planning.
PS 5: Land Acquisition and Involuntary Resettlement
Haiti:
Exploration activities in prospecting blocks require certain land to be acquired on a temporary basis for exploratory work (access roads, tracks and roads, base camps, trenching and drilling pads of promising sites). If exploration sites prove to be viable, land will be required permanently for additional exploration and mine development. Haiti has an established policy and process for land acquisition and compensation, including damage to crops and other assets. Newmont has an established overall policy for land acquisition and compensation associated with the company’s various international ventures. These policies and procedures are being followed by MMC and Newmont with respect to impacts to land rights and land use at the active exploration properties in Haiti, but currently there is no formal land acquisition and compensation plan. Compensation is paid for use of land and any damage to crops (at least at prevailing market prices). In addition any improvements, such as base camp buildings, will be left for the land owner’s benefit if requested.
Land rights and land use issues are particularly complex in Haiti where population densities are relatively high, and where livelihoods of most households are largely dependent on subsistence agriculture. Whilst historically almost all land was distributed for use by individual households, records of subsequent inheritances and divisions of land rights have not been well maintained. It is common for multiple claims to a particular land rights parcel, although usually only one household currently crops the land. Thus while compensation to the owner of the crops damaged is relatively straight forward, compensation for use of land is more complex, and raises the potential for disputes. While surface rights belong to land right holders, sub-surface resources belong to the State, and this also contributes to complex issues over land and resource use. Land rights and land use issues will be addressed as part of the scoping socio-economic baseline study (SEBS).
In order to address these complex issues and to ensure a common approach to land acquisition in Haiti, a Land Acquisition and Compensation Strategy will be prepared. This will be based on a review of existing procedures being used, and will outline the principles, guidelines and approaches to be followed in acquiring or using land in order to meet the requirements of national regulations and IFC’s Performance Standard 5 (Land Acquisition and Involuntary Resettlement).
Since each exploration property has site specific issues, a Land Acquisition and Compensation Plan (LACPs) for each of the current exploration properties (La Miel, Gran Bois and Treuil) will be prepared, and also for any exploration properties that are acquired in the future. These brief and succinct plans will be based on the LACS and the SEBS, and will address site specific issues, including appropriate mitigation measures for loss of land and/or impacts to current land use activities (short and long term aspects), roles and responsibilities, grievance procedures, timeframe and budget. If, at a later date, any of the exploration sites develops into a mine, detailed LACPs will be prepared as part of the SEMS.
Turkey:
The areas in which EMX’s exploration concessions are located in Turkey are State-owned land, mostly governed by the Ministry of Forestry, and thus land acquisition is not a critical issue at this point. The Company will, however, commit to preparing a set of corporate-wide guiding principles on land acquisition, providing for the development of project-specific detailed procedures and plans should it become necessary at any point in the future.
