PS1: Social and Environmental Assessment and Management Systems
Social and environmental assessment: Helio has not yet instituted environmental and social baseline studies: the project is still in its early stages. Helio, however, produced Standard Operating Procedures (SOPs) for Helio Resource Corporation and its subsidiaries as of the 24th of November 2006. Annex II of these SOPs contains Environmental Guidelines (EGs) which form an integral part of the SOPs. The EGs further contain guidelines for field-based operations (based largely on the work of environmental consultant Alex Speiser, 2005) and guidelines for office or accommodation-based activities (based on the work of Steve Smith, 2006).
Potential impacts of the activities undertaken by Helio are identified and tabulated, and for each impact, a series of mitigation and/or recommended actions are detailed and explained. All staff, especially field staff, must familiarize themselves with the tables prior to the commencement of any exploration activity.
The environmental impact of the Company and the effectiveness of the EGs are subjected to continuous monitoring and review, and the EGs are reviewed and updated at least annually in January of each year or as and when issues arise.
Helio has started preparation for baseline data collection; it is slowly putting together a weather station to use on-site. Undertaking this at such an early stage in the project (prior to any decision to go forward with mining) affords Helio the opportunity to identify issues that may become relevant if development of a mine goes ahead (any such development would however, require a full ESIA).
As part of their SOPs, Helio does not trench but instead prefer drilling. Trenches still remain uncovered from previous exploration activities dating back approximately over 50 years ago. Pads and sumps used during exploration drilling are rehabilitated by backfilling soon after the completion of the drilling. The rehabilitation is undertaken by the drilling contractor and is overseen by Helio in line with the contractual agreement between the two entities. Helio, in the majority of cases, has not commissioned drilling in active community fields despite having communities within and around their target areas. However, the Company recently tested the Kasuku Target, which had a very limited impact on some farmed land. Helio received written permission from the landowner and compensated him by donating seeds to plant on the field we worked on.
Helio had a Community Liaison Officer in their employ but unfortunately the individual passed away in December 2008. A new appointee was employed in this role in August 2009.
Artisanal Miners: There is artisanal mining activity in the license area but the numbers fluctuate from time to time and as a result the total number of artisanal miners is unknown. During appraisal field visits in February 2009, a few artisanals (less than 10) were identified in the area. Helio currently co-exists with the artisanal mining activities. Helio will commission a census to establish the number of artisanal miners in its concession area and to better understand their activities. The resultant information will be used in future to determine whether these (illegal) artisanal miners will be impacted by any proposed projects and how to deal with this eventuality.
Management systems and training: The SOPs are designed to act as a stand-alone document which should be employed in the activities of the Company by all employees and contractors. The SOPs consist of the main body, i.e. five sections:
Administrative tasks
Travel and vehicles
Data management
Field and geological procedures, and
Contractors
There are three annexes to the SOPs as follows:
Annex I – Health and Safety Guidelines
Annex II – Environmental Guidelines, and
Annex III – Data Entry Guidelines.
The SOPs identify the need for all new employees to be given an induction which should include awareness-raising of the Company’s aims and activities, and training relevant to their expected position where required. All staff have recently been trained in First Aid and drivers are required to attend a 4 x 4 driving course where applicable.
The SOPs are comprehensive and contain a lot of what IFC’s Health, Safety, Environment & Community (HSEC) Policy for this type of exploration project, would normally include. The main disparity is the Human Resources (HR) Policy and the Community Policy which are not included in Helio’s SOPs but which the Company will now add.
Organization: As an exploration company, Helio does not yet have any E&S capacity, relying to date on consultants as highlighted above. This is not yet an issue on environmental matters as these can be easily managed via the SOPs discussed above. As noted above the Company has engaged a local community liaison officer to assist with community engagement.
The Project Geologist (or other such responsible person, e.g. Country Manager in some cases) is responsible for monitoring and enforcing the implementation of the EGs on a day to day basis. Any violation of the EGs are recorded and reported to the Country Manager or Senior Management Team (SMT) where no Country Manager exists. The Country Manager is responsible for mitigation and remediation measures.
Environmental Policy: Helio has developed an Environmental Policy statement. Helio commits to adhere to all applicable in-country environmental legislation, develop and adhere to a set of standard Environmental Guidelines, continuous improvement, monitoring and constructive approach to all landowners, local communities and any other stakeholders. Helio were also taken through IFC Performance Standards and have committed to work within the PSs’. An electronic copy has been presented to Helio.
Monitoring: Baseline data collection has not been implemented yet although Helio have initiated the process by having had a weather station on site for over a year. Presently seasonal data on rainfall and ambient temperature has been recorded. Going forward, it is likely that the station will be upgraded to collect more information.
Reporting: Helio is not required by legislation to report on the environmental and social aspects of their operations at this stage. In future, Helio would be asked to submit a brief Annual Environmental & Social Monitoring Report (AMR) to IFC on an annual basis detailing environmental and social progress, incidents and monitoring, as appropriate.
PS2: Labor and Working Conditions
Human Resources: Helio had a total of 20 employees on site at the time of the site visit of whom only one is expatriate whilst the rest are Tanzanian. This number reflects retrenchments that were implemented in the last quarter of 2008 in response to the financial crisis. Helio also reduced their drilling activities during the same period and began drilling again in May 2009. Current staff compliments include an expatriate Country Manager, 3 expatriate and 3 Tanzanian geologists, and up to 50 national staff. Despite the reduced work in the beginning of 2009 Helio increased the training initiatives they had implemented since 2007. These involve students from the United Kingdom (UK) and the MADINI Institute in Dodoma and now also geological students from University of Dar es Salaam. At peak drilling activity the headcount is estimated at 100 employees including the drilling contractors.
All Geological Technicians, the accountant and all three Tanzanian Geologists are provided with company accommodation as they come from northern Tanzania. They are also assisted with transport money to go back home during breaks. All employees are on one year employment contracts. Helio has a bias towards local hiring where the skills are available and only hire from further off where local skills are inadequate as in the case with the Geologists and Geological technicians. The local education and skills levels are reported to be generally low.
Workers’ Organization: None of Helio’s employees are unionized though Helio does not discriminate against unions. It was reported that a union representative had been to site but was rejected by employees (this was not verified). However, all employees are required by regulation to sign up for National Social Security Fund (NSSF) and contributions are split between the employer and employee.
Non-Discrimination and Equal Opportunity: Helio states in their SOPs under Staffing Matters in Section I – Administrative Tasks that potential staff will not be discriminated against on grounds of e.g. age, disability, race or sex, unless such grounds mean they are unable to perform required tasks.
Occupational Health and Safety (OHS): No Occupational Health and Safety (OHS) incidents were recorded since Helio started the exploration program in the area about three years ago.
Helio has developed an OHS policy which commits to:
provide adequate control of the health and safety risks arising from work
consult with employees on matters affecting their health and safety
provide and maintain safe plant and equipment
ensure safe handling and use of substances
provide information, instruction and supervision for employees
ensure employees are competent to do their tasks, and giving adequate training
prevent accidents and cases of work-related ill-health, and
review and revise the policy as necessary at regular intervals.
At the time of the appraisal, all employees had just gone through a fire drill.
Safety meetings are held frequently but in an ad hoc manner. Safety talks are held all the times before a task is executed. Geological meetings are held on a weekly basis whilst local labor meetings are held bi-weekly. The geological and labor meetings are all documented.
Grievance Mechanism: Helio has in place a whistle blower policy which allows employees to speak directly to the SMT and report any accounting related violations. Employees are also encouraged to speak to their peers to address issues that may arise during their employment and these can then be taken up with management should the peer level engagement fail to resolve the issues. It is anticipated that, should the company expand and develop a mine, a full blown Human Resources (HR) function would be developed including formal HR policies and a formalized employee grievance mechanism, in keeping with IFC Performance Standard 2.
PS3: Pollution Prevention and Abatement
Solid Waste: Helio demonstrates a full understanding of all of their waste streams (inventory) and the final disposal methods. The main solid waste includes used batteries, domestic and office waste, topsoil and vegetation from stripping for drilling purposes, sewage sludge, plastic water bottles and other wastes as may subsequently be identified.
Liquid Waste: Includes mainly sewage effluent at the main premises in Mkwajuni, storm-water runoff, used oil, grease, lubricants and drilling fluids, and other wastes as may subsequently be identified.
Waste Management System: Waste is segregated into three main categories, i.e. waste for “incineration”, biodegradable and recyclable. Color coded plastic bins are used to separate the waste at source. Waste for “incineration” is placed in a blue bin whilst biodegradable materials are placed in red bins. Waste for “incineration” is burned in an open fire whilst the biodegradable waste is taken to Mkwajuni waste disposal site. Employees are given the first opportunity to collect recyclable waste for reuse e.g. plastic water bottles. Used batteries have been recycled through Helio’s Namibian operations where used battery recycling systems are better developed. It is important to note that at this stage of the project there is little waste produced.
Sewage is currently treated using a septic tank/soak-away system at the main camp and field camp. Once full, the septic tanks are evacuated. When required fly camps are used at remote sites, where long drop latrines are used. These long drop latrines are closed and sealed off once they are full.
Topsoil and organic material from drilling sumps and pads stripping is stockpiled for use in the rehabilitation process as part of drill hole closures. Helio also tries not to open new drilling site access tracks but instead prefers to use the old existing tracks wherever possible.
Pollution Prevention (including Ambient Considerations): When Helio took over occupation of their main premises they took seven samples from the compound to check for contamination as the premises had been used to process for gold at a small scale by the central bank of Tanzania. The main objective of the exercise was to minimize any potential cross contamination of the drill core that is housed in the compound. Mercury contamination was found to be relatively high and the area under the core shed was sealed off with concrete.
There is currently no baseline data on either surface or groundwater quality. Helio avoids spillage of used drilling media and lubricants into water channels via the construction and use of sumps. Further, Helio does not ordinarily handle hazardous or toxic waste at this stage of their activity and biodegradable drilling fluids are used in their drilling activities to minimize surface and groundwater contamination. Fuel is stored in underground tanks at the main premises in Mkwajuni.
To minimize dust releases to air from the drilling activities, dust suppression water may be used and continuous re-vegetation of non active drilling sumps and pads is implemented when drilling is complete.
Energy use: Power is supplied from the main grid and a diesel fuelled standby generator is in place for use during power outages.
Water Use: Storm-water runoff from the main building is harvested during the rainy season and used to supplement potable water which is otherwise purchased from local water vendors during the dry season.
Emergency Response and Preparedness Plan: The SOPs stipulate that the handling of all hazardous substances must be done in accordance with the law of the country in which the operations take place. In addition to any legal requirements all hazardous substance, e.g. oil, lubricant, diesel, etc. stored on site is kept in their original containers and placed on a drip tray. Emergency procedures are in place should an accidental spill occur. A drip tray is used when handling hazardous substances. Spills are collected in a designated drum, which is placed on a drip tray, and disposed at an official waste site or workshop.
Staff is trained to be familiar with all chemicals used on site. Only trained staff is allowed to work with hazardous material.
Fuel used on site is brought to site in a diesel truck or 200l drums or 20l canisters. All handling takes place on drip trays.
The Project Geologist is responsible for the implementation of these procedures.
PS4: Community Health, Safety and Security
Surrounding Communities: Helio’s license area cuts across three villages namely; Ngombe (approximately 1 000 people), Patamela (approximately 2 000 people) and Saza (approximately 5 000 people). Malambangombe village (approximately 6 000 – 10 000 people) lies to the south-east of the license and Mkwajuni, to the south of the licence area, is the main population centre with approximately 6 000 – 10 000 people. Saza village is a legacy of the previous mining activities whilst Ngombe, Patamela and Malambangombe are traditional villages and Mkwajuni is a development centre. Services including health centers, schools and water are fairly well developed and Mkwajuni has a new hospital.
Security Personnel Requirements: Helio currently employees three security guards with a provision for two more in the near future. The guards are not armed and Helio has a no weaponry policy. Helio will also look in to professional security at the office for liability reasons – still no weapons.
Helio maintains a good relationship with the police. Prior to Helio commencing exploration activities in the area, there were incidents where armed robberies were carried out on travelers on buses coming from the area as they were suspected to be carrying gold for sale in Mbeya. Helio does not produce, buy or sell gold and does not keep any gold on site. There have been no security related incidents since Helio started operating in the area.
Emergency Preparedness and Response Plan: In addition to the Emergency Preparedness and Response Plan described above, an emergency evacuation for expatriates is included in Helio’s insurance.
Client’s Stakeholder Engagement
Helio currently engages the community via the village committee made up of community leaders. Meetings are held between the village community and Helio management. On occasions, representatives of MADINI have also participated in such meetings as well. In recent times, due to previous misunderstandings caused by poor translation minutes of these meetings are taken. District committee discussions are also held with Chunya representatives whilst regional engagement takes place at Mbeya level with MADINI – the mining authority. All donations to local initiative are carried out in conjunction with the District Commissioners office. Currently, all these meetings are ad hoc.
As noted above, in December 2008 Helio’s community liaison officer passed away. This post was not filled until August 2009, after the time of appraisal. The current incumbent is reported to be continuing the good work his late predecessor initiated. The latest community meeting was in November 2009, when the MADINI officer from Chunya also attended with Helio’s CLO to hold meetings. Helio has also arranged an “open day” in late-November 2009 to host a meeting with all the relevant local community representatives, and District authorities, to improve awareness of the activities of the company and to address issues of managing expectations. This meeting will be repeated as frequently as is required.
Helio were also advised to start considering an Environmental and Social budget and to proactively be involved with the community. The IFC team met briefly with key community representatives including the Member of Parliament of the area. The community was advised to note that Helio were still in exploration stage and did not have a big budget to support big requests. The local Member of Parliament (MP) agreed to speak to the committee immediately after the meeting with IFC to stress the need to tone down on requests. Over and above this, the community wants Helio to carry on their work and is hoping that this could lead to a mine developing.
Helio has a signed agreement from the community giving permission to BAFEX Tanzania Ltd (Helio) to continue unhindered with their mineral exploration in the Saza area, as required by law. BAFEX Tanzania Ltd is wholly owned by Helio.
Displacement (Physical and Economic Displacement): The current projected resource indicates no relocation will be required if a mine developed in the future as a result of the current exploration program. Of the villages listed above, only Ngombe village is located close to a potential drill target, and Helio is aware of government plans to tar the road that cuts through the concession. Indications at this stage are that the road could potentially cross an area where resources may be proven. Should this be the case, any upgrades will have to be considered and studied in detail. Going forward and as more drilling results become available, this issue needs to be monitored carefully.
Land use in the area is predominantly agriculture with both pastoralists and cultivation. Small herds of cattle are an increasingly common sight in the area due to an influx of Sukuma herders into the area, resulting in inevitable negative environmental impacts, especially whole-scale clearance of native woodland.
