PS 1: Social and Environmental Assessment and Management Systems
Social and Environmental Assessment - Management of risks discussed in this ESRS consists of those associated with exploration. IFC is financing exploration and feasibility study activities, which have minimal impact. Volta commits to meet the IFC Policy and Performance Standards on Social and Environmental Sustainability. If any of the exploration prospects proceeds to the mining development phase, Volta will prepare the environmental and social assessment documentation needed to demonstrate compliance with IFC’s Performance Standards, as per action item #5 of the Supplemental Action Plan.
IFC has already identified some issues that will have to be addressed in the social and environmental assessment documents should the Company move toward the development of mines. In view of a developing international water management regime covering the Volta River basin, water abstraction will be a key issue at all sites. In addition, issues typical of open pit mining such as land acquisition and income replacement as well as artisanal mining will need to be addressed. Where gold processing is to be undertaken the company will comply with the International Cyanide Management Code. There is thought to be a potential for acid rock drainage at Kiaka which will require careful management.
Artisanal mining – Based on paragraph 6 of PS 5, impacts on artisanal mining, particularly where the artisanal mining activity is not legal under national law, are addressed under PS 1, rather than under PS 5. At the same time, impacts on those activities are expected to be avoided, minimized, mitigated, or, in some cases compensated. Some artisanal mining was observed at all Volta prospects in Burkina Faso visited by IFC. Artisanal mining is reported to be present at other Company prospects in other parts of Burkina Faso, and in Ghana and Mali. A legally-recognized, artisanal mining concession is present on the Kiaka prospect. In all other instances, the artisanal mining activities on Volta concessions are considered illegal under national law. The major artisanal site within Volta’s Burkinabé holdings is found on the Kampti holding. In 2005, an estimated 15,000 artisanal miners occupied an area directly above the primary ore body. At present, artisanal mining co-exists with exploration activities. While the number of artisanal miners has fallen at the site, about 1000 artisanal miners remain. During exploration activities, the Company has first sought to avoid affecting artisanal mining operations, but where it has been necessary for people to move, the company carried out consultation. The artisanal miners have been willing to move their operations out of the way of exploration.
The Company (through its Burkinabé subsidiary, Wentworth) has carried out a qualitative socio-economic baseline study of the artisanal mining at Kampti in 2005. The study detailed the problems and benefits of artisanal miners in the Kampti region with respect to the local communities and the environment. Overall, the study suggested that the artisanal mining provides a major source of employment, but comes with high social and environmental costs. The study recommended that the Company assist in the formation of an artisanal miners’ organization, help to physically organize the site, provide technical assistance, and educate miners on health, hygiene, and the environment. The Company has assisted in the better organization of the site. The Company is supporting a new socio-economic study of the same artisanal mining area. For the exploration phase, and in the absence of definite plans for mine development, the Company’s current approach is adequate. The recommendation is, however, that Volta formalize its consultation procedures for artisanal miners. Full development of any prospect into a mine will require consideration of the impacts on artisanal mining and appropriate mitigation measures.
Environmental Policy: Volta has committed to create a Health, Safety, Environment and Community Policy and Procedures (“HSEC Policy”) document, to be developed with IFC assistance [as per action item #1 of the Supplemental Action Plan]. Volta has also agreed on a Supplemental Action Plan (SAP) to cover all HSEC aspects related to exploration activities, feasibility work, and potential future mine development. The Company will also prepare a Stakeholder Engagement Plan [as per action item #2 of the SAP] to ensure proper stakeholder relationships (including with artisanal miners), monitor community support, and identify needs and priorities for sustainable development.
Management and Organization: As an exploration company, Volta has historically relied on consultants to advise on HSEC matters. Most issues can be managed via the HSEC Policy defined above at the current stage of the project development. Volta’s Country Manager for Burkina Faso presently manages relations with local communities, particularly with respect to temporary land access and local hire. The level of consultation with local communities appeared to be appropriate given the limited impact of the exploration activities, and particularly the timing of activities during the dry season. As exploration activities expand both in extent and seasonality, the Company will need to identify a dedicated community liaison officer. The HSEC Policy will also address the need to appoint early-on full-time specialists for health and safety and environment, when and if the decision to start development of full-scale mining takes place.
Monitoring: As per action item #3 of the SAP, Volta will carry out regular monitoring of its assets and HSEC Policy implementation as well as compliance with Burkina Faso Law and IFC Performance Standards.
Reporting: Volta does not currently publish any reports on the environmental and social aspects of their operations. Volta will provide an Annual Monitoring Report (“AMR”) to IFC detailing environmental and social progress, incidents, and monitoring, as appropriate. The company will also be reporting regularly, at a minimum annually, to the local communities on progress made in implementing the Company’s environmental and social action plan.
PS2 Labor & Working Conditions:
Human Resources (HR): Volta will develop a Human Resources Policy and Procedures in line with IFC standards that include reasonable working conditions and terms of employment that - at a minimum - comply with national law, equal opportunity principles, and a grievance mechanism. It should be noted that Volta directly employees three women geologists as part of its exploration team. In addition to its regular employees, Volta uses contractors for its drilling operations, a core function of exploration. For this reason, the human resources policy will also include policies covering non-employee workers performing core function, which will be included in future contract. As provided for in PS 2, this aspect of the human resources policy will extend the same principles as for regular employees, with the exception of a grievance mechanism. This human resource policy will be finalized as per action item #6 in the SAP.
Occupational Health and Safety (OHS): While internationally accepted standards for occupational health and safety are being implemented by Volta and their contractors Volta did not, at the time of appraisal, keep Occupational Health and Safety (OHS) incident reports or environmental incident reports. The company will initiate formalized incident reporting going forward [as per action item #4 of the SAP]. There have been no significant OHS incidents in the last 12 months.
PS 3: Pollution Prevention & Abatement:
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.
Solid Waste: Volta generates minimal amounts of waste but it is all segregated appropriately. The company responsibly manages their waste streams and the final disposal methods. The main solid waste includes domestic and office waste and sewage. Domestic waste that cannot be recycled is disposed of by burial in a designated waste pit, which is compacted and covered by soil when full.
Liquid Waste: Includes mainly sewage effluent at the main exploration camp, storm-water runoff, and minimal amounts of used oil, grease, lubricants and drilling fluids from drilling activities. Cleaning of the septic tank is undertaken by a professional contractor. A sealed, cemented pit has been established at the base camps, which is used for final confinement of the small amounts of contaminated waste generated at the drill sites.
The company avoids spillage of used drilling media and lubricants into water channels via the construction and use of sumps and maintains monitoring of water quality. To prevent siltation of waterways, drilled areas are rehabilitated by revegetation as soon as they are no longer required. Natural growth is rapid in the area. The company does not generate significant amounts of hazardous or toxic substances at this stage of its activities.
Energy Use: Power for the camps and drill core handling areas is supplied either from the grid or from small generators. Fuel for the genset is currently stored in aboveground fuel tanks. The only other emissions are from the small fleet of light vehicles consuming less than 100,000 liters per year.
Water Quality and Use: The groundwater storages are discontinuous and are located in the shattered zones induced by the condensed network of faults affecting the substratum. Both surface water and groundwater are very vulnerable to various pollutants. They are also sensitive to the inter-annual fluctuations of the rainfalls.
Traditional sources of water for local communities are hand-dug wells (as well as ponds used in the rainy season). Today, groundwater is also abstracted by communities from a number of tubewells, typically equipped with hand pumps. Tubewells generally source groundwater from fractures within the basement complex, while hand-dug wells are largely sourced from the weathered overburden layer. Yields from tubewells and dug wells in the basement areas are generally low and many dry up seasonally.
Exploration boreholes intersect groundwater resources, which are approximately 15 meters to 40 meters averaging 25 meters below the surface. This is potentially a problem where such boreholes are located near local communities that access the same reservoir of underground water. If not sealed, the borehole acts as a potential pathway for contaminants to enter the groundwater both from surface runoff and from other (even lower) horizons. A baseline study of drinking water supplies/wells will be carried out by Volta and a barrier distance of 30 meters between boreholes and water wells has been adopted by the company. The sealing of boreholes with an impermeable medium (e.g., bentonite) will be considered through the groundwater bearing horizons. Where artisanal mining operations have penetrated the water table, fluctuations in water levels could add to the instability of any underground excavations. Contamination of soils and groundwater through the spillage of fuels and lubricants from the drilling equipment is avoided through appropriate management and barriers. The proximity of exploration boreholes to drinking water wells will be no closer than 30 meters.
Emergency Response and Preparedness Plan: As per action item #1 in the SAP, Volta will develop a separate Emergency Response Plan or Procedures (ERP). The key tenants of such a plan are included in the outlined HSEC Policy noted above
PS 4: Community Health, Safety & Security:
As mentioned under Performance Standard 3, dust from drilling operations is carefully managed to avoid impacting the local communities and crops in the vicinity. There is potential for vehicle impact on agricultural land and local vegetation. Non sustainable deforestation is a major concern in the area with land being cleared for agriculture, for use in support of artisanal mine workings, and for firewood.
Malaria is a main concern in the area, particularly for non-resistant staff. The Company will development a malaria prevention and treatment program for staff as part of action item #7. Furthermore, to ensure the protection of both staff and local communities, the Company will develop and implement an HIV/AIDS awareness program.
Volta will design and conduct training for its management and security personnel to ensure that the principles and procedures for compliance with the Voluntary Principles on Security and Human Rights are in place and understood [as per action item #8 in the SAP].
PS5: Land Acquisition and Involuntary Resettlement
The project is in its early stages and the only activities are further exploration drilling and completion of feasibility studies. While the areas under exploration are not densely populated, there are a number of communities in close proximity to the company’s exploration activities and some cropping of land. The Company carries out consultation with local communities to inform them of when and where they will be drilling. In general, exploration activities take place during the dry season and direct impact on crops is avoided by restoring drill sites before annual cropping starts. It is possible that some perennial crops, such as cashew and shea nut trees can be affected by exploration activities. Furthermore, as exploration activity is extended into the wet season, the likelihood of impacting annual cropping activity increases. Volta currently has an acceptable practice for dry season drilling activities, but needs to formalize that process into a written document that includes policies and procedures for addressing any economic displacement that may take place [as per action item #9].
