29062 - Dutwa Nickel

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Environmental & Social Review Summary

Project Number

29062

Company Name

AFRICAN EAGLE RESOURCES PLC

Date ESRS Disclosed

Nov 9, 2011

Country

Tanzania

Region

Africa

Last Updated Date

Nov 30, 2016

Environmental Category

B - Limited

Status

Completed

Previous Events

Approved : Dec 16, 2011
Signed : Dec 23, 2011
Invested : Feb 6, 2012

Sector

Nickel

Industry

Metals and Mining

Department

Gbl Infrastructure & Natural Resources

Project Description

African Eagle Resources (“AFE” or the “Company”) is a publicly listed British junior mining company, which has early-stage and advanced exploration projects in Tanzania (nickel and gold) and Zambia (copper).

IFC’s main interest is the Company’s Dutwa nickel laterite project located in north-central Tanzania, approximately 100km east of Mwanza and 1100km northwest of Dar es Salaam, near Dutwa, a large village and administrative centre within Bariadi District.

A total IFC equity investment of around 3.1 Great British pounds (approximately $5.0 million) is proposed to contribute to the financing of the Bankable Feasibility Study (BFS) of the project and for other corporate purposes. AFE has commissioned baseline studies which will lead to the Environmental and Social Impact Assessment (ESIA) as part of the BFS. The baseline studies will commence in November 2011 and the consultants are currently finalising the scope of work for the studies. IFC will assist AFE in reviewing the scope of work to ensure that the company can develop the project in line with international best practice in environmental and social sustainability.

This Environmental and Social Review Summary (ESRS) covers AFE’s activities at the early exploration stage including feasibility studies.

Overview of IFC's Scope of Review

IFC’s review of the Dutwa project consisted of a three-day appraisal visit conducted in April 2011 to assess the Company’s operations, review environmental, health, safety, and social information submitted by the Company and understand their plans and commitments for the future development of the prospect.

The trip to site was undertaken by road to gain an impression of the logistics challenges related to raw materials and product transportation should the project proceed to development. In addition, as part of the preliminary logistics assessment, a jetty on Lake Victoria in the fishing village of Nyamikoma was also visited. Whilst in its early stages, the project could also draw water from this point. A potential groundwater abstraction area on the Duma River was also visited to gain an appreciation of potential water sources the company could consider for production.

The project area lies thirty to forty km west of the Serengeti National Park; to determine the possibility of adverse impacts on the Park, the IFC team drove east along a gravel road which runs from Dutwa towards the Park and also to the Ndabaka Gate of the Park on the main Mwanza to Musoma trunk road. The gravel road ends approximately 7 – 10 km from the Maswa Game Reserve which forms a buffer zone between Serengeti National Park and the surrounding communities. The land outside the Park is settled and used for agriculture (crops and animal husbandry – cattle, sheep and goats), and there was no evidence of wildlife migratory routes in this area.

Meetings were held with representatives of the community at Dutwa, the Director of Environment and senior representatives of Bollore Africa Logistics in Dar es Salaam. The community’s views on the exploration project were discussed including the community’s interactions with the Company to date. The purpose of the meeting with the Director of Environment was to engage with the relevant central government authorities at an early stage of the investment to solicit their views on the project and understand the directorate sector general views on environmental issues and their management. The meeting with Bollore Africa Logistics sought to strengthen the team’s appreciation of logistics related issues in Tanzania including hazardous materials transportation and associated spill, emergency preparedness and response plan requirements. The meeting also touched on Lake Victoria Barging as a potential option for transfer of both raw materials and finished product should the project progress to development.

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:

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:

While all IFC Performance Standards (PSs) are applicable to this investment, IFC’s environmental and social due diligence indicates that the exploration and feasibility studies to be financed by IFC will have impacts which must be managed in a manner consistent with the following Performance Standards:

- PS1: Social and Environmental Assessment and Management Systems
- PS2: Labour and Working Conditions
- PS3: Pollution Prevention and Abatement
- PS4: Community Health, Safety and Security

Performance Standard 7 is not applicable as there are no indigenous people in the project’s area of influence. Performance Standards 5, 6 and 8 are not applicable at this stage of the project but will be considered during ESIA preparation and would apply should the project proceed to development.

IFC’s Environmental Health & Safety (EHS) Guidelines applicable to this investment are:

- General EHS Guidelines, April 2007; and
- Mining EHS Guidelines, December 2007.

This is a category B project according to IFC’s Environmental and Social Review Procedure because the Environmental, Health & Safety, and Social (EHSS) impacts of the project are limited, site specific and therefore manageable through implementation of appropriate mitigation measures.

IFC’s categorization of this project is based on the impacts of exploration activities, which currently have a small footprint. The drilling activity is focused on the two target hills - Wamangola and Ngasamo. The hills, whilst fairly preserved, already have access roads that were developed by Telecom companies for the base stations that are currently on the hills. There has therefore been limited need for African Eagle to construct new access roads. There is currently no exploration campsite as the African Eagle staff resides in rented accommodation in Dutwa village.

The key environmental and social issues associated with the exploration drilling currently ongoing in Dutwa are: (i) management of exploration activities (specifically rehabilitation of the drill roads, and drill sites, safe disposal of oils, proper solid waste management, water and effluent management at the proposed exploration campsite); (ii) occupational health and safety; (iii) handling of hazardous materials (e.g. fuel); (iv) public safety and emergency preparedness & response; (v) temporary use of small fractions of communal land for drill pads, that has limited impacts on community use of the land – livestock grazing, collection of firewood and medical plants; (vi) community safety resulting from increase in vehicular traffic; (vii) potential project-induced in-migration and influx of job seekers and small scale service providers; (viii) adequate consultation with the potentially affected communities to manage expectations vis-à-vis potential project benefits, community development programs and understanding of mining activities; and (ix) implementation of appropriate control measures (screening, for prevention of communicable disease transmission).

Any IFC investment in potential future mine development undertaken by the company will be assessed as a new project and its categorization would be determined after the necessary due diligence. Even without an additional investment, as long as IFC remains an equity holder, IFC would require any future mine development to follow the approved ESIA which will be undertaken as part of this investment and to develop and implement a robust and auditable Environmental and Social Management System (ESMS). AFE will ensure that the ESIA is consistent with IFC Performance Standards and EHS Guidelines and be publicly available and consulted upon in accordance with IFC’s disclosure policy prior to the start of construction.

To address the above identified issues and meet the requirements of IFC’s Performance Standards, AFE has committed to an Environmental and Social Action Plan (ESAP) covering its exploration activities, feasibility and potential future mine development. The above issues will also be managed via the company’s Health, Safety and Environment and Corporate Social Responsibility (HSEC) Policy described below.

Environmental and Social Mitigation Measures

Management of risks discussed in this ESRS consists of those associated with the exploration phase as IFC is only financing exploration and feasibility study activities which have limited environmental and social impacts. AFE commits to meet IFC’s Policy and Performance Standards on Environmental and Social Sustainability.

PS 1: Social and Environmental Assessment and Management Systems

Environmental and Social Impact Assessment

AFE recognizes that it has primary responsibility to protect the natural environment where it is operating. Therefore, AFE strives to conserve natural resources and minimize the impact of its activities on the environment and communities through diligent application of appropriate technology and responsible conduct at all stages of its exploration activities.

In accordance with Tanzanian regulations, environmental analysis is undertaken for all activities that may pose a potential risk to the natural environment or the local communities. In compliance with these requirements, AFE commissioned the Environmental Association of Tanzania (ENATA) to undertake a preliminary environmental assessment of the exploration activities at Ngasamo which was submitted to the National Environmental Management Council (NEMC) in October 2009.

The impacts identified in the report (which are consistent with an early stage exploration project) include vegetation clearance for drilling access, oil spills, emissions from the drill rig and support vehicles, soil erosion, noise, in-migration, community safety (due to increase in vehicular traffic) and potential fire risk in the hills. A detailed Environmental and Social Management Plan capturing the impacts for each phase of the exploration programme, mitigation measures, responsibility and an estimated cost for implementation of the mitigation measures was also developed.

In addition, AFE is required to undertake a full ESIA as part of the BFS for the proposed development. AFE commissioned MTL Consulting Company Limited (HYPERLINK "http://www.mtlconsulting-tz.com"www.mtlconsulting-tz.com) to prepare and submit a Project Brief (a high level scoping exercise) required by NEMC to determine the scope for the ESIA. The Project Brief for the “Proposed Development of the Dutwa Nickel Mine in Bariadi and Magu Districts, Shinyanga and Mwanza” was submitted to NEMC in April 2011.
Consistent with the Performance Standards, AFE has committed to undertake detailed baseline studies prior to the commencement of the ESIA to collect environmental and social baseline data (including a stakeholder analysis and current usage of the hills), ecological survey of the two hills and meteorological data among others. This is addressed in the ESAP. AFE prepared the Terms of Reference (ToR) for the baseline studies and subsequent ESIA consistent with the requirements of the Performance Standards which was used to requested proposals from interested environmental consultancies operating in the region and internationally. African Eagle has appointed MTL as the lead Tanzanian environmental and social consultants and Citrus Consultants as the Company’s Quality Control Representative to oversee the Dutwa environmental and social studies and ensure consistency with both Tanzanian regulations and the IFC Performance Standards. To this end, both MTL and Citrus are currently working on finalising the detailed scope of work for the baseline studies and the ESIA. AFE will submit the scope of work to IFC for review and comment prior to finalising it.

AFE expects the baseline studies to commence immediately after the scope of the work is finalised which is envisaged to be completed in November 2011. The baseline studies will form part of the ESIA development and documentation. IFC will work with the consultants and AFE to ensure that appropriate environmental and social baseline data is collected, describing relevant existing physical, biological, socioeconomic, and labour conditions, including any changes anticipated before the project commences. The baseline data collected will feed into decision making regarding the project location, design, operation, or mitigation measures. As part of the Bankable Feasibility Stage, AFE will submit detailed ESIA documents addressing Tanzanian regulatory requirements and IFC Performance Standards to IFC for review and approval four months prior to start of any construction activity.

Health, Safety, Environment and Social (HSES) Policy

AFE has a Health and Safety Policy, an Environmental and Community Policy, a Corporate Social Responsibility Policy and a Bribery Policy. The Policies are supported by operating Guidelines that establish individual and management responsibilities. AFE regularly reviews its policies and guidelines to reflect changes in the project development and legislation.

The Company’s Environmental and Community practices are based on the “Excellence in Environmental Exploration” (E3) guidelines developed by the Prospectors and Developers Association of Canada (PDAC) (HYPERLINK "http://www.pdac.ca/e3plus"www.pdac.ca/e3plus), and on the AusIMM Guide to Good Working Practice. Health and Safety Policy and practices are based on UK Health and Safety at Work legislation, with AFE committing to undertake formal risk assessments to evaluate the material risks associated with its operations.

AFE has committed to review and update its existing policies to be consistent with IFC Performance Standards. AFE will extract aspects related to Human Resources in the existing policies and develop a standalone a Human Resources (HR) Policy document.

Management and Organization

As a junior exploration company, AFE relies on external consultants to undertake various studies with the responsibility for managing HSES matters shared between managers and exploration geologists.

AFE’s Board of Directors is responsible for preparing the Group’s Health, Safety, Environment and Social Responsibility Policy and Guidelines (Policy and Guidelines) and updating them as necessary. Responsibility for implementation of the Group’s HSES lies with the Operations Director and the relevant Country Managers are responsible for their respective areas of operations.

Most HSES issues can be managed via the existing policies at the current stage of the Project development. No reportable E&S incidents have occurred since the start of the exploration program. AFE is committed to undertaking its exploration activities in a manner consistent with industry good practice for mining sector governance, transparency and sustainability.

Monitoring

During IFC’s due diligence visit, AFE was in the process of identifying an appropriate meteorological weather station to measure rainfall, temperature, wind speed/direction and evaporation data to be used in the design of the process plant and effluent treatment circuit. The same data will feed into the baseline database. AFE also mapped community groundwater abstraction points located close to the Ngasamo and Wamangola target hills. The company will monitor the quality of this water against WHO drinking water standards as well as seasonal groundwater level fluctuations.

AFE will monitor the implementation of its exploration phase ESMP prepared as part of the preliminary environmental assessment for Ngasamo. AFE will also ensure implementation of the HSES Policy is consistent with the Tanzanian regulations and IFC Performance Standards.

Reporting

At present, no reporting is required by the Tanzanian government on environmental and social aspects of the operations. AFE also does not publish any report on its environmental and social performance. However, as noted above, the company commissioned a preliminary environmental assessment for Ngasamo exploration, and completed a Project Brief for the entire proposed mining and processing project. Both these reports were submitted to the Tanzanian authorities for review and approval and can be made available to relevant stakeholders.

Influx management

It is unlikely that project-induced in-migration will become critical until exploration activities are completed and mine development begins. Surrounding population centres provide a more than sufficient pool of labour, especially Dutwa, a commercial and administrative centre and a marketplace located 5 km from the proposed mining operation.

In order to manage the range of issues associated with potential in-migration during the development and operating phases of the project, AFE will undertake a risk analysis (as part of the ESIA) to understand the likely patterns of the in-migration phenomenon and identify and assess the potential environmental and social impacts of influx into the project area. After completion of the risk analysis, AFE will develop an Influx Management Plan that will describe project specific approaches and mitigation measures for project-induced in-migration.

Artisanal Mining

Small scale artisanal gold mining was observed during IFC’s site visit adjacent to the public road from Ngasamo to Dutwa approximately one km south of Ngasamo Hill. The current project activities do not interact with the artisanal mining activities (which AFE reports to be a small number of miners) and at present there are no impacts on the artisanal miners.

Artisanal mining in Tanzania is regulated under the same Mining Act 2010 as all other prospecting and mining activities. To carry out artisanal mining requires artisanal miners to hold a mining right license issued by the Ministry of Energy and Minerals. AFE reports that the artisanal miners in the project area do not hold such licenses.

The ESIA scope of work includes an assessment of the potential impacts the proposed nickel mine development may have on artisanal miners. Any need for the artisanal miners to vacate the areas needed for project activities will be undertaken through a negotiated process and consultation to identify any potential areas of overlap and/or areas that might require mitigation measures.

PS 2: Labor and Working Conditions

AFE is a junior mining company holding early stage exploration licenses in Tanzania. For its exploration drilling, AFE has a small team based in Mwanza and the project site at Dutwa.

AFE currently employs a total of 14 staff in Tanzania. All staff are based in Mwanza and as required are present in the project site on a rotation system. Currently between seven to nine staff is at Dutwa at any one time. AFE also employs day workers for various tasks during the drilling program.

Human Resources Policy

AFE will develop a Human Resource Policy and Procedures consistent with the requirements of Performance Standards 2 “Labour and Working Conditions” and requirements under the national labour law. The policy will include aspects related to terms of employment including at minimum, remuneration, benefits, hours of work, overtime, leave allowances (annual, sick, maternity etc.), medical insurance, provisions on non-discrimination and equal opportunity, performance evaluation and promotion, grievance mechanisms and whistle-blowing.

The Policy will also include provisions for non-employee workers performing core functions (i.e. short-term employees, contractors or day labourers used by for drilling operations are a core function of exploration).

AFE will provide a copy of the HR Policy to all its employees and undertake internal training on the HR policy.

Occupational Health and Safety

As mentioned earlier, AFE has in place a Health and Safety Policy and undertook a risk assessment to identify work related hazards. The responsibilities for conducting risk assessments, preparing Codes of Safe Working Practices and monitoring their implementation are also clearly outlined in the policy. This process allows for both a bottom-up and top-down approach. This bottom-up “risk triage” process results in the entire organization contributing to effective risk management. Employees are provided with and wear the necessary personal protective equipment (PPE) on drilling sites.

Whilst there have been no significant Occupational Health and Safety (OHS) issues at the time of appraisal, AFE did not keep OHS incident reports. The company will initiate formalized incident reporting going forward consistent with industry best practice.

Workers’ Organisation

There is currently no union representation at site. AFE and its contractors currently have a relatively small workforce comprising of geologists, drilling supervisors, etc. AFE does not restrict freedom of association, and the Company reported that representatives of the Tanzania Mining, Construction and Allied Workers Union (TAMICO) have visited the Company’s project site to solicit membership applications.

PS 3: Pollution Prevention and Abatement

Solid Waste

AFE generates minimal amounts of waste which is disposed of through the village channels consisting mainly of dugout pits. Some of the waste, such as empty plastic water bottles, is collected and reused by the local community. In future, and once construction of the exploration camp is complete, AFE will improve its waste disposal by segregating the waste and burying non-hazardous waste in pits, compacting the material and covering with soil.

Drilling & Drilling Waste

The exploration drilling program is undertaken by Ausdrill Limited (HYPERLINK "http://www.ausdrill.com.au"www.ausdrill.com.au), a diversified mining services company with operations in Australia, United Kingdom and Africa. Ausdrill currently has a Reverse Circulation (RC) rig onsite. Ausdrill has good environment and safety policies posted on its website. Ausdrill avoids spillage of used drilling media and lubricants into the surrounding environs through use of lined sumps. In addition, the drilling contractor uses biodegradable foams and drilling fluids.

Material from drilling sumps and pad stripping is stockpiled for use in the pad rehabilitation process as part of drill-hole closures. Rehabilitation of drilled areas, which was observed to be successful, is undertaken as soon as the areas are no longer required and includes backfilling the sumps.

With the exception of fuel, AFE do not ordinarily handle hazardous or toxic materials at this stage of the operation.

Energy Use

Power for the existing facilities used.
Energy Use

Power for the existing facilities used by AFE and its drilling contractor is supplied from a generator and the same will be applicable at the exploration camp. In future, and should the project move into development/production, it is anticipated that power will be obtained from a combination of Tanzania Electric Supply Company Limited (TANESCO), co-generation from heat produced from sulphur burning and standby generators. It is estimated at this stage the project will require approximately 15 – 20 MW.

Water Quality and Use

AFE uses an average of 20, 000 liters of water per day and this water is drawn from nearby ponds during the rainy season and the Duma River all year round. Contractors working on the Bariadi – Lamadi road upgrade and local communities use the same sources of water for construction activities and watering animals respectively. Bottled water is used for drinking. The company plans to drill a borehole at its proposed exploration campsite and will provide a standpipe to allow local communities access to the borehole water.

For production, the company is currently considering two potential sources for water, Lake Victoria (second largest freshwater lake in the world), approximately 30 km northwest of the targets, and groundwater from the Duma River basin, approximately 8 km south of the targets.

Preliminary studies indicate the existence of aquifers around the Duma River that could potentially provide adequate water for the project without adversely impacting the local communities who also depend on this groundwater. Detailed analysis of water availability will be undertaken as part of the ESIA for which the company has committed to assess the sustainable use of water and availability of water to local communities and mitigate potential impacts (if any) on the availability of water for the local communities. Process simulation to determine water requirements for mineral processing should the project develop to the production phase is currently underway.

As part of the ESIA baseline studies described above, AFE will investigate surface water hydrology and groundwater. These studies should lead to an understanding of groundwater and surface water interactions and inform the design process for potential mine development. The studies will delineate and characterize the aquifers, groundwater recharge and discharge processes, and groundwater flow of the project area, in the local and regional context. In addition, the studies should characterize the productivity and groundwater quality of existing community water wells.

AFE will implement an environmental monitoring program which will include both quality and water level fluctuations. The results of this monitoring program will be included in the AMR which will be submitted to IFC.

Air Quality

Dust from the drilling operations (especially when using compressed air) is carefully managed to avoid impacting the local communities and crops in the vicinity. Other emissions are from the drilling rig itself and the small fleet of light support vehicles both of which are regularly maintained.

Emergency Response and Preparedness Plan

AFE will equip all existing fuel and oil tanks with secondary containments to hold 110% of the tank capacity, and ensure all newly installed tanks are equipped with secondary containment at the time of installation.

PS 4: Community Health, Safety and Security

The two deposits – Wamangola and Ngasamo - are located 100 km east of the regional capital of Mwanza. There are a number of villages in proximity to the license areas, with the closest being the Ngasamo village (in Magu District). The licence areas fall under two administrative districts – Magu and Bariadi. The social baseline studies that will be undertaken as part of the ESIA will provide accurate information on the total population and the number of villages that are in the project’s area of influence.

The health concerns of the population include malaria, maternal and child health, diarrhoeal diseases and HIV/AIDS.

African Eagle recognises that future influx of potential job seekers to the area is likely to increase HIV/AIDS risk and in order to protect its employees and local communities, AFE will develop an awareness program that will (i) seek partnership with local nongovernmental organizations, associations etc, working on HIV/AIDS prevention programs in the area; and (ii) develop a holistic awareness and prevention program targeting employees and local communities.

AFE will review its existing policy on HIV/AIDS to include provisions on (i) employee rights and responsibilities; (ii) employee privacy and confidentiality of HIV/AIDS status; (iii) non-discrimination against employees with real or perceived infection; and (iv) no requirements for HIV/AIDS screenings of job applicants or those employed.

Access to the project site is via graded roads which traverse a number of villages with people, school children and livestock using the road. Presence of vehicular traffic associated with the project poses a safety risk to the road users. In addition, both hills (where there are ongoing exploration activities) are also used by the local communities for grazing and collection of medicinal plants. AFE will organise information campaigns on road safety and emergency response and preparedness.

As highlighted above, the project is currently renting a house in the Dutwa village in proximity to the commercial centre, with between 4 and 8 employees in residence at any time. The drilling contractor currently rents an adjacent house. Given this small number of project people, there are minimal negative impacts to the local community in Dutwa village. Positive impacts include procurement of local produce, employment of local people for housekeeping and rental of the premises.

The drilling contractor employs unarmed guards that are hired from the local community for protection of the drilling equipment. AFE also employs unarmed guards that are stationed at the project house. For the office at Mwanza, AFE has contracted a Tanzanian security company that provides unarmed guards stationed at the premises. AFE does not envisage using armed security guards as the area is safe and to date there are no issues related to security.

African Eagle has agreed to sink water boreholes which will help in the provision of clean drinking water. The Company has made its vehicles available for accident emergency hospitalisation of villagers and will continue to do so.

PS 5: Land Acquisition and Involuntary Resettlement

The project license area extends from Ngasamo village in the west to the main Bariadi – Lamadi road in the east. The Ngasamo hill belongs to Ngasamo and Imalamate villages and Wamangola belongs to Isenge village. The area is surrounded by farmlands and majority of the residents are engaged in agricultural activities (maize, cotton etc.) and animal husbandry. The baseline studies will determine the total population that will be affected by AFE’s operations during exploration and mine development stage.

According to the Tanzanian Village Land Act, village councils are entrusted with managing village lands on behalf of its residents (vis-à-vis land use and resource management). Under this act, customary rights to the land are also recognized. In accordance with this act, transfer of village land to general use is undertaken in consultation with the village whereby an agreement is reached on compensation. AFE has compensated the affected villages for use of the communal lands for its drilling program. In accordance with Tanzanian local government by-laws, 60% of the compensation was used for social service provision at the district level whilst the remaining is used at the village level for community development programs.

The Ngasamo and Wamangola hills are communal lands used for grazing, fuelwood and non-timber resources (including medicinal plants and aggregate). Designated areas within the hills are used for religious rituals and ceremonies. With the exception of fuel wood collection and medical plants, there are no restrictions to the use of the hills by other surrounding communities and all villagers have rights of pasture and non-timber resources. The woodland utilized for fuel wood collection (locally known as ‘Ngitri’) and the Savannah tropical grass (used for roof thatch) is regulated by the village executive officer (a government appointed representative for managing village affairs) and the forestry officer for sustainable use of the resource. The villagers are given a collection permit for a fixed fee calculated per bundle of wood. This fuel wood is not a main source of fuel but rather used to supplement other fuel sources during the rainy season. The collection season is July – December.

The current exploration activities have limited impacts on grazing and other activities undertaken in the hills. Should the project progress to mine development, the hills will be mined resulting in the loss of grazing grounds and non-timber forest resources. It is not envisaged that the project will lead to physical displacement – this will however be confirmed during the BFS and ESIA study.

AFE has commenced the process of assessing alternative options as a replacement for loss of resources from the hills. There is currently a pilot government reforestation program for Magu district for fuel wood plantation. AFE is considering a similar approach to mitigate the loss of the fuel wood from the hills. Replacement and/or compensation of non-timber forest resources and grazing lands will require an analysis of various options to offset loss of these resources. This analysis will be undertaken in the ESIA process in consultation with the local communities that own the hills and users of the resources. As part of the ESIA study, AFE will develop a Compensation Framework that (i) identifies all the affected population; (ii) provides an inventory of the different uses of the areas that the communities will potentially lose access to including an inventory of assets; (iii) a description of alternatives and methods for valuation and rates; (iv) schedule of land take compensation payments; (v) an appeals mechanism for the affected population.
AFE and its drilling contractor are currently renting two buildings at Dutwa village which they use as a temporary exploration camp. The company has acquired, through a willing buyer – willing seller process, a piece of land outside the village on which it will construct an exploration camp. Construction of the exploration camp is expected to be completed in the last quarter of 2011.

PS 6: Biodiversity Conservation & Sustainable Natural Resources Management

As described above, the potential development of a mine at Dutwa is not expected to have any adverse impacts on the Serengeti. In addition, the project is located in the same general area through which the alternative route to the proposed controversial Tarmac road across the Serengeti National Park would traverse.

AFE will commission a detailed ecological baseline survey to establish the general ecological profile of the hills and their vicinity. In addition to obtaining an inventory of the flora and fauna of the hills, the ecological baseline survey should also aim at providing insight into the ecological functions and importance of the habitats in and around the hills. Such a survey will involve the local communities, or at least their representatives to adequately understand use of commonly held natural resources. This survey will inform the impact assessment study which will include a detailed analysis of the short and long term impacts and an evaluation of natural resource use by local communities and development of appropriate management plan.

PS 8: Cultural Heritage

According to the preliminary environmental assessment, there are no known sites of cultural heritage or archaeological importance. A detailed study will be undertaken as part of the ESIA study.

There is one graveyard in the site proposed for the exploration campsite. The grave is that of a spiritual leader whom the villagers visit infrequently to pay tribute. AFE consulted with the communities and will fence the graveyard and will be accessible to the local residents.

Stakeholder Engagement

As part of the preliminary environmental impact assessment undertaken in 2009, AFE engaged with various representatives (at the district and local levels including community leaders) at the Magu district. A number of public consultation meetings were held at the district, ward and village level followed by site visits to the hills. The main objective of the meetings was to introduce AFE, the proposed drilling program and provide information on the project and gauge support from the villages that own the hills.

The key concerns raised during the consultation were the potential loss of grazing grounds and source of fuel wood and non-timber resources. Given that the exploration activities are short term, the potential impacts are temporary and within a limited geographical area. The communities continue to have access to the hills during the exploration activities.

During its appraisal mission, IFC held a consultation session with the village council and a number of the local government representatives. It was evident that AFE has built a positive relationship through its engagement program, recruitment of local labour, a number of community development initiatives, cooperation with the villagers for evacuation related to medical emergencies and petty commerce in the village centre (which is an existing commercial hub). Having said that, according to the village executive officer, the villagers are aware that some mining activity is ongoing in the hills but do not have a good understanding of the project or associated activities. The current activities have minimal impacts on the surrounding communities.

AFE will formalize its engagement program to ensure that the local communities (i) understand the basics of mining operations and the nature and scale of potential impacts; (ii) project information (including documents and plans) is provided and explained to ensure informed participation of the communities on matters that affect them directly; (iii) facilitate a process whereby the views of affected communities on issues that affect them directly are incorporated into the decision making process during the bankable feasibility stage; and (iv) manage community expectations vis-à-vis local employment, community development and compensation.

The consultation process will be inclusive and include members of the affected communities, community leaders, vulnerable groups and local representatives. Given the proximity of the operations to the local community, this is the key to building a positive relationship with the communities to minimize grievances associated with project activities in particular issues associated with the hills. AFE will also tailor a number of focused sessions to address issues related to the hills and potential loss should the project progress to mine development. The company will also explicitly explain to local communities its employment strategy, envisaged job opportunities during different phases of the project (current drilling program, feasibility, mine development).

AFE will hire a dedicated community liaison officer to build upon and expand the channels of communications and engagement established during the preliminary environmental assessment and spearhead the engagement program.

AFE will develop a Stakeholder Engagement Framework (SEF) that that describes the Company’s policies and procedures for consultation with all the relevant stakeholders and affected communities and disclosure of information. The framework will include Tanzanian regulatory requirements and be consistent with the Performance Standards. The SEF will include guiding principles and process for identifying stakeholders, strategy and schedule for sharing information, a grievance mechanism and roles and responsibilities. Subsequently, AFE will prepare a detailed Stakeholder Engagement Plan (SEP) documenting all engagement activities to date, proposed engagement schedule aligned with the project’s various stages. The SEP will include a detailed list of stakeholders, a process for engaging the communities during the ESIA, a schedule of disclosure of information, a process for receiving, documenting and addressing feedback and incorporating conclusions into project design and strategy. This will also include a system for documenting engagement sessions, feedback received, etc.

It will also include provisions for disclosure of project information to local communities dependent on project activities and information disclosure needs. The company will also report annually on progress made in implementing the company’s environmental and social action plan.

The following documents will be made locally accessible on the Company’s website:

- ESRS (Environmental and Social Review Summary)
- ESAP (Environmental and Social Action Plan)
- SPI (Summary of Project Information)

Inquiries and comments about the project can be made through the contact details provided below.

For inquiries about the Project, contact:

Mark Parker, Director
African Eagle Resources
2^nd Floor, 6-7 Queen Street
London EC4N 1SP
United Kingdom
Tel.: +44 20 72 48 60 59
Fax.: +44 20 76 91 77 45
Email: mark.parker@africaneagle.co.uk
Website: http://www.africaneagle.co.uk/

Local access of Project documentation:

Project office in Mwanza:
PO Box 1866, Mwanza, Tanzania
Plot 8 Block 41, Capri Point, Mwanza, Tanzania
Telephone: +255 282 500 727
Fax: +255 282 500 727
Project office at Dutwa site:
c/o Mashaka Mkingwa Maporu, Dutwa Centre, Bariadi District, Tanzania

Client Documentation

File Name	Actions
AFE_Dutwa_ESAP_Final_2011-11-06.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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