While all Performance Standards are applicable to this investment, IFCs 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. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
While all IFC Performance Standards (PSs) are applicable to this investment, IFC’s environmental and social due diligence indicates that the exploration to be financed by IFC will have impacts which must be managed in a manner consistent with the above Performance Standards:

Performance Standards 6 on Biodiversity Conservation and Sustainable Management of Living Natural Resources is not triggered at this moment due to limited impacts of current exploration activities. However, there is a potential for impacts on biodiversity at the latter stages of the project if the mine development proven feasible. To this effect, the Company will conduct an analysis of biodiversity in the area and undertake mitigation measures for exploration impacts as described in section on PS 6 below.

Performance Standard 7 is not applicable at this stage as no indigenous people were identified on the project’s area of influence. There are currently no known sites of archaeological or cultural significance, thus PS 8 is not applicable at this stage. Hummingbird Resources and its contractors will implement a chance find procedure for exploration activities on an ongoing basis.

This is a Category B project according to IFC''s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts, at this early stage of mineral exploration, which can be avoided or mitigated by adhering to the applicable IFC Performance Standards, relevant guidelines and design criteria.

IFC’s categorization of this project is based on the impacts of exploration activities, which consist primarily of construction of access roads and drill pads for exploration drilling, construction of a base camp for worker accommodation and site office, limited temporary land acquisition, emissions of dust and water, and waste streams from camp activities and machinery maintenance.

Any IFC investment in potential future mining development in Dugbe would be assessed as a new project and its categorization would be determined after the necessary due diligence. Even without an additional investment, IFC would require any future mine development with major impacts to follow PS 1 in its requirements for independent monitoring of project social and environmental performance and informed consultation and participation with project affected people. Hummingbird will ensure that social and environmental assessment documents associated with such a development will be consistent with the 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 any possible future mine development in Dugbe.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives. Key environmental and social issues relating to the project are summarized below along with specific information about how potential impacts will be addressed by the Company. The Company is currently in compliance with the Liberian environmental, health and safety, and labor laws and IFC PS requirements. The implementation of the environmental and social risk mitigation measured described below will assure the expansion project''s compliance with various environmental and social requirements, namely the law and regulations of Liberia, IFC''s Performance Standards and applicable WBG’s EHS guidelines.

The key social and environmental issues associated with the exploration activities currently ongoing in Dugbe are (i) management of exploration activities, specifically control of erosion and rehabilitation of drill roads and drill sites, safe disposal of oils and waste, dust control, water and effluent management, occupational health and safety, hazardous materials (e.g. fuel) handling and management, public safety and emergency preparedness & response, (ii) disturbance and noise resulting from movement of heavy equipment and drilling activities, (iii) potential impacts on economic livelihoods of the local communities associated with small scale agriculture and artisanal small-scale mining, (iv) potential impacts to local communities from use of local water sources, (v) potential influx of individuals seeking employment, (vi) managing community expectations with respect to potential job opportunities, (vii) ongoing community consultations and resettlement planning, (viii) potential impacts on biodiversity in the area.

To address the above identified issues and meet the requirements of IFC’s Performance Standards, Hummingbird has committed to an Environmental and Social Action Plan (ESAP) covering its exploration activities.

Environmental and Social Impact Assessment

The Dugbe F/Tuzon project is currently in the early exploration phase and while a gold deposit has been identified, its economic viability and the feasibility of mine development hasn’t been determined yet.

The Government of Liberia requires all mining projects of the scope of the potential Dugbe F/ Tuzon development to undergo an ESIA, based on Liberian legislation. The key agency responsible is the Environment Protection Agency (EPA). The EPA indicated that it will require an Environmental and Social Impact Assessment (ESIA) for the Dugbe F/ Tuzon project to comply with international standards, specifically the IFC’s Performance Standards and the World Bank Group’s Environment, Health and Safety Guidelines. The EPA will also expect Hummingbird to assist in national capacity building by offering suitable Liberian nationals the opportunity to work alongside international ESIA experts. IFC can assist the EPA in determining appropriate timing of ESIA completion.

Hummingbird commissioned Wardell Armstrong International in January 2012 to carry out an environmental and social scoping study against international standards as a precursor to an eventual environmental and social impact assessment (ESIA) The preliminary Environmental and Social Scoping Report was reviewed by IFC. No irreversible impacts (fatal flaws) were identified. However, the consultant identified surface and groundwater pollution and changes to flow levels; loss or changes to biodiversity, including internationally threatened and endangered species; influx and relocation; presence of established artisanal small scale mining activities; and cumulative impacts on the forest ecosystem, as key potential issues which will require careful consideration. Thus, the issues will form part of specialist studies for the ESIA to be undertaken in parallel to a feasibility study should a viable economic reserve be defined.

Hummingbird will also commission a qualified consultant to undertake a social baseline data collection. The objectives of the study will be to evaluate the social elements of community life, and to identify the positive (opportunities) and negative (risks) social and economic impacts associated with Hummingbird’s exploration activities.

Environmental Policy

Hummingbird has a clearly defined environmental policy in which the company makes commitments to managing its exploration activities so as to minimize the associated environmental impacts. Thus the Company will, amongst other commitments, undertake its exploration in compliance with applicable environmental laws and regulations and aim to follow all relevant and appropriate international guidelines on exploration best practice. This will include establishing grievance mechanisms for employees and stakeholders to report concerns about environmental issues and respond promptly to their concerns. There is an internal charter which stipulates that all Hummingbird project sites will have a Stakeholder Engagement Plan (SEP). The SEP will be accompanied by an appropriate Grievance Mechanism (GM); appropriately managed and monitored (checking performance against compliance); and reviewed and monitored bi-annually.

Operational procedures

Hummingbird is committed, in its environmental policy, to causing the minimum environmental impact during all stages of exploration and to leaving as little evidence of its exploration work as possible afterwards. To demonstrate this commitment, Hummingbird has in place detailed Standard Operating Procedures (SOPs) covering environmental and social, medical, health and safety, security, geology etc. Through these SOPS, potential risks and impacts of the exploration activities (access/line cutting, geophysical surveys, field camps, trenching/pitting, drilling, bulk sampling and exploratory mining) undertaken by Hummingbird 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, is required to familiarize themselves with the tables prior to commencement of any exploration activity. As Hummingbird has several potential projects locations throughout Liberia and each presents different potential risks, the Company will continue to evolve, the environmental, health, safety and social impacts of its activities; and the effectiveness of the SOPs are subject to continuous monitoring and review, on either every six monthly basis or following a change in operational conditions.

Organizational Capacity and Competency

Roles and responsibilities are clearly spelt out in the SOPs, where each identified activity is assigned to a specific portfolio in the Company. There is a health and safety committee comprised of the senior management team. The health and safety committee is responsible for formulating the Group’s health and safety policy and objectives, reviewing the Group’s performance, ensuring all directors are kept informed of their health and safety obligations and considering and making recommendations to the Board regarding the appointment of health and safety coordinators. The Country Manager is responsible for the maintenance, distribution and implementation of the SOPs, although responsibilities may be delegated as appropriate.

The Company has a Public Relations Officer (PRO) whose main responsibility is to engage with local communities, regional stakeholders and develop the relationship that exists between Hummingbird and the local communities. The PRO is supported by the Deputy Operations Manager and the Camp Manager.

Given the sensitive nature (with respect to biodiversity) of some Hummingbird’s exploration sites, the Company will engage and retain a qualified and competent environmental specialist to oversee the evolution and implementation of the SOPs and supervise work of consultants as applicable.

Monitoring and Review

Hummingbird has collected some limited weather data from the Dugbe Camp over the past two years. There is a more formal weather monitoring station at the FDA outpost in Doodwicken village, some 15km from the camp. However, Hummingbird collects and records EHS data including serious incidents, Loss Time Injuries (LTIs), malaria incidence, environmental and other incidents, training, internal audits, etc. The Company uses information derived from this data to continuously monitor the effectiveness of its SOPs. The Company will install a weather station capable of measuring a full suite of data and implement surface and groundwater monitoring as described below. Hummingbird will also continuously monitor the implementation of its SOPs in compliance with the Liberian regulations and the IFC PSs’.

Artisanal Small-Scale Miners

The project is located in an area which has experienced artisanal mining for over two decades. Many existing local residents are engaged in artisanal mining; future residents are likewise expected to do the same. Unregulated small scale artisanal mining is generally understood to be a risky livelihood strategy. Artisanal miners, whose activities are often informal, are prone to health and safety risks commonly associate with artisanal gold extraction.

Potential development of the Dugbe project may impacts the livelihoods of some of the artisanal small scale miners in the area. To assess its current and potential future impacts, Hummingbird will conduct an Artisanal Small-Scale Miners Survey and livelihoods study as part of the social impact assessment and develop mitigation measures to reduce the negative impacts from potential mine development project on artisanal small-scale miners working and living in the area. The results of this study will be integrated in Stakeholder Engagement Strategy (SEP) and Community Development Plan (CDP), as well as in the Influx management Plan (IMP) which Hummingbird will develop for the projects.

Employment

Hummingbird currently has approximately 200 employees in Liberia compared to approximately 50 a year ago. In addition the Group also has had up to 100 casual labourers at its projects in the last year. All employees have written contracts approved by the Ministry of Labor. All employment contracts conform with the labour laws of Liberia. The Company adheres to the principles of non-discrimination in its hiring processes as well as ensuring equal working conditions for all its employees. Approximately 50 indirect jobs have been created in 2011 as a result of the company’s activities. These are mainly subcontractors for exploration and drilling in Liberia. With an unemployment rate of 85% in the project surrounding areas, the Company has significant positive impact on the local socio-economic situation.

Remuneration rates are based on their qualifications and experience. Liberian employees receive salaries, which are significantly above local pay rates. The company’s casual labour rate is three times the national average for casual labour. All employees in Liberia receive free medical care, food, accommodation and transport when working away from home. They receive transferable skills in the form of training – first aid, maintenance, IT, geological etc.

Occupational Health and Safety (OHS)

The Company established a Health and Safety Committee, which is responsible for formulating the company’s health and safety policy and objectives, reviewing the company’s performance, carrying out routine health and safety reports, ensuring all Directors are kept informed of their health and safety obligations and considering and making recommendations to the Board regarding the appointment of health and safety co-ordinators, and concerning any questions of the resignation or dismissal of the health and safety co-ordinators.

Internationally accepted occupational health and safety standards are being implemented by Hummingbird and its contractors. The Company continuously assesses health and safety risk associated with its operations and has specific policies in place for risk assessment and workplace safety. General safety inspections are performed regularly and corrective action implemented. Before engaging in actual work, the Country Management has to be satisfied, so far as reasonably practicable, that all contractors employed have the necessary experience and competence to undertake their work in a safe manner and to a good standard. In addition, all contractors are required to make their Health and Safety policies available to Hummingbird Country Management on request. Any risk mitigation measures specified are to be identified and implemented.

Health and safety incidents are recorded in line with the Company’s SOPs. There have been some safety incidents in the past related to the drilling. These were fully investigated and corrective actions implemented. Employees are provided with and wear the necessary personal protective equipment on drilling sites and elsewhere as appropriate. Hummingbird employs a contractor to provide western-qualified medical personal for field deployment. The Company has a detailed Medical Evacuation Response Plan in place.

Training

The Company invests in developing local employees. It provides sponsorship to the geology students in the local university since 2007 and provides employment opportunities to graduates. In 2012 sponsorship is provided to 20 students and expected that majority will chose Hummingbird as their employer after graduation.

Resource efficiency

Hummingbird obtains water for its exploration camp from a dedicated borehole drilled and equipped by the Company, and rainwater harvested from the camp installation rooftops. The water is treated according to procedures specified in the SOPs. Bottled water is used for drinking purposes.

The Dugbe project area receives approximately four meters of rain annually – mainly during the wet season. Surface water flows are considerably enhanced during the wet season. The project area is drained by a dense, dendritic network of streams and rivers. The Jubo River forms the western boundary of the Dugbe Camp and is adjacent to the south-eastern extremity of the Dugbe F ore zone. This river is used as a water source and for fishing by local communities. The quantity and quality of water flowing in the river is currently unknown. No significant impacts on downstream users are anticipated at this stage. There is limited information available on groundwater occurrences in the project area; however, groundwater is regarded as a highly sensitive receptor because local communities partly rely on potable water from wells and boreholes. According to WAI’s scoping report, there is evidence of an artesian aquifer at a nearby village, Money Camp.

Hummingbird will commission baseline studies for surface and groundwater. This programme should lead to an understanding of groundwater and surface water interactions and should help evaluate the potential hydrologic and water availability and quality changes should the project progress to development and production. The hydrogeological programme 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 hydro geological baseline study should characterize the productivity and groundwater quality of existing community water wells. The surface water hydrology and groundwater baseline data collection will inform the establishment of an environmental monitoring programme which will include both quality and water level fluctuations. The results of this monitoring programme will be included in the AMR which will be submitted to IFC.

Pollution prevention

Waste. Hummingbird generates minimal waste through a variety of its activities, including offices as well as on site. This waste includes cafeteria, general waste (putrescent), recyclable waste (paper/cardboard, cans, bottles, milk cartons), construction waste, and contaminated waste (flammable materials, sealers). All waste is segregated, collected and stored at designated waste disposal areas. The camp has installed long drops which are positioned approximately 30 meters from the tented accommodation and to the perimeter of the camp. These latrines will be allowed to decompose naturally and will be filled in and sealed with soil when they reach maximum capacity as specified in the SOPs. As part of their rehabilitation, the backfilled latrines will be marked off to ensure the site is not reused on subsequent visits to the camp. Effluent generated from the washrooms and cleaning activities is collected and treated via a passive septic tank and soak-away system.

Hummingbird currently generates minimal hazardous waste which includes solvents, paints, used oil and batteries. This is responsibly recycled and managed in line with the SOPs. Fuel purchase, storage and handling is strictly governed by the Petroleum, Oil and Lubricants procedures also specified in the SOPs.

Drilling & drill site rehabilitation. The drilling contractor uses biodegradable foams and drilling fluids and avoids spillage of used drilling media and lubricants into the surrounding environs through use of sumps. Material from drilling sumps and pad stripping is stockpiled for use in the pad rehabilitation process as part of drill hole closures. Drill site rehabilitation begins immediately after completion of drilling. This includes temporarily capping the hole with a collar plug, removing rubbish from site, including any hazardous waste such as hydrocarbons which are disposed of at a designated facility. A photographic record of the site prior to disturbance and after rehabilitation is kept.

Air quality: Dust from the drilling operations (especially when using compressed air) is carefully managed to avoid impacting the crew and local communities where applicable. Other airborne emissions are exhausts from the drilling rig itself and the growing fleet of light support vehicles and heavy duty equipment all of which are regularly maintained. A full register of vehicle servicing and maintenance is kept in the office by the head of fleet and Operations Manager in order to maintain an accurate record of all work carried out on Hummingbird’s vehicles.

Risk of vehicular accidents involving humans and livestock is currently low due to low traffic numbers, remote location of the project and low numbers of peoples residing in the areas near operations. However, this can change with the potential development of the project and to this effect, Hummingbird introduced rules for safe driving for all its vehicles and contractors.

Availability of water and good sanitation practices for the local communities are poor in the areas near Hummingbird operations, as in many other places in Liberia, with many drinking water sources being unsafe. As with many villages in rural areas of Liberia, the nearby villages have access to working hand pumps, many of which were installed by NGOs operating in the county. Some villages, however, still rely on open wells or creeks. To alleviate the situation, Hummingbird installed two hand pumps in nearby village of Tuzon. The Company has also built community latrines in Monrovia via its sanitation programme which is part of the Company’s CSR.

To date, there were no security incidents around the project sites and no armed security is employed by the Company. Local community members serve as watchmen for the drilling rigs and the camp. If Hummingbird decide to employ professional armed security guards with potential future expansion of the operations, it will also implement the mechanisms for compliance with the Voluntary Principles for Security and Human Rights.

Any potential future mine development, particularly during the construction phase, is likely to result in population growth within a short time frame potentially leading to sudden and widespread resource shortages for local people, such as firewood, bush-meat, medicinal plants, formal and informal livelihood sources. While the nearby informal settlement of Money Camp is already a mixed and relatively cosmopolitan community, in-migration could impact on the other more traditional settlements, potentially causing far-reaching changes to family structures, governance structures and the influence of traditional community leaders. Intra-community conflicts, sexually-transmitted diseases, drug abuse and other vices, as well as increased crime levels are usually associated with this type of opportunity-driven population growth. To mitigate these impacts Hummingbird will develop and implement an Influx Management Plan in consultations with the local stakeholders and coordination with Liberian authorities. The development of the Influx Management Plan will be undertaken in parallel with ESIA.

The Dugbe F/Tuzon project is located about 20km south of Sapo National Park, an extensive area of protected primary rainforest which is home to threatened and endangered species such as the pygmy hippo and the western chimpanzee. The Company’s exploration license does not overlap the protected area and there are no plans to expand operations closer to or into the protected area.

The project area may have important biodiversity attributes as it is contiguous with Sapo National Park. Generally, the fauna and flora of the forest is not considered to have been comprehensively studied and no biodiversity surveys have been carried out by Hummingbird as part of its exploration activities. The watercourses in the area may also have high biodiversity value. Cumulative effects, particularly with commercial logging operations approaching the area, need to be considered, particularly in relation to increasing access to the forest and forest fragmentation.

Hummingbird follows good practice, as specified in its SOPs, aimed at minimizing the drilling footprint during its exploration activities. These include rehabilitating and using existing access roads previously used for logging purposes, and avoiding cutting down trees, where practical. The Company installs temporary stream crossing (bridge or culvert) to allow its equipment and vehicles to cross streams or watercourses without damaging the streambeds or channels and hence protecting stream banks from further degradation and sediment loss. The Company has also undertaken some scout drilling in the forest area using a man portable drilling rig.

Hummingbird is conscious of the sensitive nature (with respect to biodiversity) of the area it is operating in and has pioneered an initiative aimed at conserving the population of the endangered Pygmy Hippo and has founded the Pygmy Hippo Foundation. The foundation, alongside supporting the laws of Sapo National Park and sponsoring associated equipment and facilities, sponsors conservation research and park ranger training, raises awareness in local communities and the Liberian government, as well as opposing poaching and illegal mining within the park. It also aims to support the expansion of eco-tourism linked to the park. Hummingbird has started taking steps at this stage to establish a relationship with an internationally-recognized conservation group Leadership for Conservation in Africa (LCA) which will provide guidance to the Company on sustainability and conservation. In addition, the Company is committed not to conduct or be associated with any on-ground exploration or operations in the Sapo National park.

To enhance the initiatives noted above, Hummingbird will engage a suitably qualified consultant to undertake a Rapid Biodiversity Assessment and Scoping exercise for its concessions. The main objectives of this assessment is to obtain an understanding of the landscape, including the extent of anthropogenic modification and/or the ‘naturalness’ of each site; and identify if biodiversity of significant value might exist in these areas. In developing this assessment, the consultant will carry-out a robust literature review and consult with relevant stakeholders (e.g., conservation organizations, academic institutions, government); and conduct a rapid on-the-ground survey of each area to obtain a broad understanding of the major habitat types. If, based on the results of the screening, high biodiversity values are associated with exploration sites; the Company will identify and implement appropriate mitigation measures which will be designed to achieve no net loss of biodiversity where feasible.

If the project progresses to mine construction, IFC will require Hummingbird to commission an alternatives analysis in the ESIA that considers high biodiversity values based on the screening exercise carried out as part of exploration. This will be crucial to the identification of a mitigation strategy that follows the mitigation hierarchy. IFC will assist the Company to develop appropriate terms of reference to ensure compliance with PS6 requirements.

As an early entrant to post-conflict Liberia, the company takes its social responsibilities seriously and believes it is having, and will increasingly have, a major and positive impact in Liberia. The company believes in supporting the local community and working closely with all communities that it engages with during the exploration process.

The company is currently involved in local economic and social development works, including: (i) the building and rehabilitation of wells and town halls in village communities near the explorations projects, (ii) building 15 bridges, (iii) repairing 40km of road, (iv) a sanitation programme and building of community latrines in Monrovia, (v) sponsoring 10 geological students through university in Monrovia, (vi) sponsoring the full renovation of the library at the Liberian Geological Survey, (vii) sponsoring the Sinoe County Football Team.

Hummingbird will further develop and institutionalize its strategic approach to engaging with its local stakeholders and developing strategic contributions to the local social and economic development. To this effect Hummingbird committed to develop a Stakeholder Engagement Strategy (SES) and Community Development Plan (CDP) for its operations in Dugbe.

General information concerning the Company''s environmental, health and safety performance can be obtained for review from:
Hummingbird Resources (Liberia) Inc
Hummingbird House
Sophie Area
Congo Town
Monrovia
Liberia

Broad Community Support is not applicable for this project

Title	Anticipated completion Date	Status	Comments	Completion Date
Retain qualified Environmental Health Safety and Social Manager	03/31/2013 12:00:00 AM	Completed	Completed	03/31/2013 12:00:00 AM
Engage External Experts/Competent Professionals to Identify Project Biodiversity Risks and Impacts. Engage external competent professionals with regional experience to undertake a Rapid Biodiversity Assessment of concessions. Engage competent experts to undertake an RBA to identify if biodivesity of significant value might exist int eh areas, and develop and implement appropriate mitigation measurews designed to prevent net loss of biodiversity.	11/30/2012 12:00:00 AM	In Progress	Under discussion with IFC client
Community Engagement, Consultation, Disclosure. Develop and implement a Stakeholder Engagement Strategy scaled to identified project risks and impacts and development stages that is tailored to the characteristics and interests of the Affected Communities, and includes differentiated measures to allow the effective participation of those identified as disadvantaged or vulnerable. Stakeholder engagement shall verify that community representatives such persons do in fact represent the views of Affected Communities and that the representatives faithfully communicate the results of consultations to their constituents.	12/31/2012 12:00:00 AM	In Progress	Under discussion with IFC client
Community Grievance Mechanism. Develop, make public tpo the local communities and implement a procedure for external communications that includes methods to (i) receive and register external communications from the public; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses, if any; and (iv) adjust the management program, as appropriate. The grievance mechanism shall ensure that grievances from affected communities and external communications from other stakeholders are responded to and managed appropriately.	12/31/2012 12:00:00 AM	In Progress	Under discussion with IFC client
Develop a Social Impacts Assessment as part of ESIA with special focus on assessing potential impacts on the livelihoods of communities and/or community members involved in artisanal mining. This will include a census of associated activities and individuals involved, an economic assessment of their livelihood, the extent of negative impacts from potential development of commercial mining operations in the area as well as management plan for mitigating potential adverse social impacts.	12/31/2012 12:00:00 AM	In Progress	Under discussion with IFC client
Develop Community Development Plan in order to manage local expectations. The Plan will describe project’s strategic approach to enhancing its economic and development impacts on the local communities including identifying development needs, prioritizing and targeting company’s interventions, including but not limited to strategic community investments, building collaborating and partnerships with the local government and other parties, planning, implementing and monitoring effectiveness of community development projects.	06/30/2013 12:00:00 AM	In Progress	Under discussion with IFC client
Develop Influx Management Plan (IMP) for assessing and mitigating environmental, health, safety and security impacts from potential project-induced in-migration in the surrounding communities. As the part of this process, to assess the receiving capacity of the communities and adequacy of social infrastructure as well as necessary enhancements and required investments from the company and local government to minimize negative impacts.	06/30/2013 12:00:00 AM	In Progress	Under discussion with IFC client
Institutionalize Ongoing Reporting to Affected Communities. Institutionalize management-approved procedures that stipulate reporting to Affected Communities; reposts shall include progress with implementation Action Plans on issues that involve ongoing risk to or impacts on Affected Communities; issues raised through consultation or grievance mechanisms. If the management program results in material changes in or additions to the mitigation measures or actions described in Action Plans on issues of concern to the Affected Communities, the updated relevant mitigation measures or actions will be communicated to them. Reporting frequency shall be proportionate to the concerns of Affected Communities but not less than annually.	06/30/2013 12:00:00 AM	In Progress	Under discussion with IFC client
Develop and Implement Resettlement Action Plan (RAP). Develop a RAP that incorporates applicable requirements of PS5 regardless of the number of people affected. Include compensation at full replacement cost for land and other assets lost. Elements of the RAP shall be designed to mitigate the negative impacts of displacement; identify development opportunities; develop a resettlement budget and schedule; and, establish the entitlements of all categories of affected persons including host communities. Particular attention shall be paid to the needs of the poor and the vulnerable. Fully document all transactions to acquire land rights, as well as compensation measures and relocation activities.	12/31/2013 12:00:00 AM	In Progress	Under discussion with IFC client