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
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category B project according to IFC’s Environmental and Social Review Procedure because the Environmental, Social and Health & Safety (ESHS) impacts related to the investment in exploration are limited, site specific and therefore adequately managed through implementation of appropriate mitigation measures. IFC’s review did not identify any significant adverse impacts or high risk exposures.

IFC’s categorization of this project is based on the impacts of exploration activities, which consist primarily of construction of drill pads and access road for exploration drilling, limited emissions of dust and waste streams from camp activities and machinery maintenance, use of limited amounts of water for exploration activities. The key social and environmental risks associated with the exploration drilling currently ongoing at Neita are (i) environmental, social and health and safety management of exploration activities – specifically erosion control, restoration and rehabilitation of drill pads and access roads, safe management and disposal of waste and oils, dust and noise control, water and effluent management, management of flora and fauna resources, occupational health and safety, community safety and emergency preparedness and response, (ii) temporary use of small fractions of land for drill pads, that have limited impacts on livestock grazing, and reduced ground for agricultural use, (iii) adequate consultation with potentially affected communities and civil societies to raise awareness about mining activities and associated potential project benefits and opportunities; (iv) managing community expectations with respect to job opportunities and community investment and, (v) ongoing community consultations and land use compensation planning.

Any IFC investment in any future mining development 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 PS1 in its requirements for a full ESIA as well as independent monitoring of project social and environmental performance and stakeholder engagement. Unigold will ensure that social and environmental assessment documents associated with such a development will be consistent with IFC’s Performance Standards and EHS Guidelines and be publicly available and consulted upon in accordance with IFC’s Access to Information Policy prior to the start of construction.

To address the above identified issues and meet the requirements of IFC’s Performance Standards, Unigold has committed to developing a comprehensive Health, Safety, Environment & Community (HSEC) Policy which will contain management plans and procedures to address existing risks and impacts from the exploration phase with commitments relating to any future mine development. Any gaps with IFC Performance Standards will be outlined in an Environmental and Social Action Plan (ESAP).

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. Upon implementation of the necessary mitigation measures described below and in the attached ESAP, the project will comply with environmental and social requirements, namely IFC’s Performance Standards on Social and Environmental Sustainability and Access to Information Policy, and applicable World Bank/IFC environment, health and safety (EHS) guidelines.



Environmental Policy:

The Company will develop and implement a HSEC Policy to identify, assess and adequately manage existing ESHS risks and impacts from exploration activities. The HSEC Policy will be developed with assistance from IFC, with key components, including the manual, management plans and standard operational procedures (SOPs) developed by Unigold with support from an external international consultant experienced in the use of good international industry practices (GIIP) for this phase of work (See Action 1 of the ESAP).

Based on the findings of the site visit, key management plans and/or SOPs to be developed as part of the HSEC Policy include those addressing pollution prevention (fuel management, spills, dust, noise, etc), solid and liquid waste, erosion control and re-vegetation, footprint management, biodiversity management, surface and ground water resources management, environmental monitoring, occupational, health and safety, emergency response and contingency planning, road safety and transportation, stakeholder engagement, grievance mechanism and land access procedure. Other plans to be developed as part of the HSEC Policy and aligned with the continuous improvement cycle will include an ESHS training plan, an Impacts Identification Procedure and a Non-Compliance Corrective Action Procedure, among others (See Action 1 of the ESAP).



Identification of Risks and Impacts:



The management of risks discussion in this ESRS consists of those associated with exploration, as IFC is only financing exploration and feasibility study activities which have limited impacts on social and environmental receptors. If any of the exploration prospects proceed to the mining development phase, Unigold will prepare the necessary environmental and social impact assessment (ESIA) documentation to demonstrate compliance with IFC’s Performance Standards.



In 2010 about 34% of the population was at or below the national poverty line and this percentage has fluctuated over the years in line with the economic cycle, making expectations for support on improved living conditions and employment in the community high. The Company is aware of this and is taking steps to engage with the local communities to provide information on the Project and manage expectations. Furthermore, the development of a formal Stakeholder Engagement Plan and Communications Plan as part of IFC’s investment will support the Project in providi
ng adequate and timely information to local communities and other key stakeholders, receiving feedback, adequately addressing any concerns or grievances and managing expectations and perceptions.



The Company wholly owns the Neita Concession where drilling efforts are focused. Dominican Republic regulations require the development of a Declaración de Impacto Ambiental, (DIA) to be approved by the Ministry of Environment for any mining exploration work. This DIA includes a characterization of works to be conducted and an impact assessment matrix. The Company has obtained the necessary environmental permits (DIA) for current exploration work at Neita. Reporting on environmental activities as part of the DIA and mitigation measures carried out at the site is submitted by Unigold on a biannual basis to the Ministry of Environment.



As mentioned above, the development of the HSEC policy and management plans/SOPs will assure that exploration activities are carried out in alignment with GIIP and that performance is tracked by the Company.



The western edge of the Neita Concession is located along the Haitian border. At this stage of the development and given the low level of project activities, it is not envisaged that this will result in influx of people to the project site. To date, there has been no cross border migration either to the project site or the neighboring village. However, should the mine progress to development stage, the potential risks of cross-border in-migration will be assessed and the appropriate management approaches developed and implemented.



Management Programs:



Although there is an adequate level of environmental and health and safety management at the site, the Company has not yet developed or formalized any environmental, social or health and safety procedures to manage existing risks. As part of the HSEC Policy to be developed, the necessary management plans and/or SOPs will be developed to incorporate GIIP practice (Action 1 of the ESAP).



Organizational Capacity:



The Company’s current organizational structure includes a CFO, and Chief Operating Officer and Technical Director, and Vice-President of Exploration reporting directly to the President and CEO. In turn, the VP of Exploration oversees the work of a Senior Project Geologist who in turn oversees the contract geologist, technicians and community relations staff. The CFO oversees the work from the Director of Administration who in turn is responsible for logistics, accounting and the camp managing areas. The Company’s senior management values a relationship with IFC to assist the Company carry out its exploration activities in line with GIIP.



In terms of ESHS personnel, the Company has three part-time community relations staff who report to the Senior Project Geologist. Currently the Company does not have an environmental or a health and safety specialist and these responsibilities are carried out by the Senior Project Geologist.





In order to strengthen its E&S capacity, the Company will contract additional ESHS support in the form of an experienced international environmental and social consultant for development of the relevant plans and procedures as part of the HSEC Policy and to assist in their implementation and training. Also, Unigold will hire an experienced EHS specialist who will oversee the implementation of the HSEC Policy during the exploration phase (see Action 2 of the ESAP).



Training:



Health and safety training to staff and contractors on the use of PPE and the identification of risks is done on an ad-hoc basis. The development of the HSEC Policy and a training plan (Action 1 of the ESAP) will address the necessary competency training requirements for this phase of work including frequency, training topics and documentation necessary to assess the level of environmental, social and health and safety awareness of direct workers and contractors.



Monitoring and Review:



The Company was not required to undertake any environmental monitoring as part of the DIA application process. More recently, Unigold hired a local consultant (Empaca Redes) to carry out an environmental audit of the exploration camp which included the sampling of several environmental media. No additional environmental or social baseline studies are being carried out by Unigold at the time.



As part of the development of the HSEC Policy, a monitoring, inspection and audit program will be developed together with key performance indicators (KPIs) to track information on environmental, health and safety and social management, training, incidents and spills, etc. The Company will also develop an Environmental Monitoring Plan to establish monitoring requirements for this phase of work and in preparation for any future ESIA.



Community Investment:



Unigold has in place a community investment program for the communities in the Municipality of Restauración. During the year 2011 – 2012, Unigold completed a number of “quick-win” projects including support to local schools (through the provision of school uniforms, donation to the teacher appreciation day), supporting local supports teams, minor road repairs, installation of a water line, Christmas gift hampers, support to farmers for building canals and water ponds, support to the civil defense for hurricane preparedness.



Reporting:



As part of the environmental permit conditions, the Company submits an environmental report to the local and national offices of the Ministry of Environment on a semi-annual basis. These reports include information on exploration activities carried out during the reporting period, issues such as re-vegetation, any sampling done during the reporting period, management of waste and hydrocarbons, etc. Reporting on health and safety issues to the government is only required for major accidents. The Ministry does not require reporting on land access (i.e. land take, number of land owners e
tc.).



As part of internal reporting, reports on ESHS matters are provided to the Project Geologist and CEO on a weekly basis. However, limited information on statistics and key performance indicators is provided both on environmental and health and safety matters.



As part of IFC’s investment, Unigold will submit an Annual Environmental and Social Monitoring Report (AMR) to IFC to describe its environmental and social performance. As part of the Stakeholder Engagement Plan, the Company will also report regularly to local communities on the progress made on its activities and progress in implementing the Company’s Environmental and Social Action Plan.



Non Applicable PS



PS5 Land Acquisition and Involuntary Resettlement



Regarding PS5 (Land Acquisition and Involuntary Resettlement), this PS is not relevant as current exploration activities only require temporary use of land with limited impacts on local land holders and this undertaken on the basis of willing-seller willing-buyer.



Unigold holds exploration rights for the Neita concession block located in the municipality of Restauración. The area is mostly characterized by agricultural and grazing lands within a forested area. The majority of the users of the area hold customary rights to the land with some holding titles. Unigold plans to undertake a land use survey which will also include ownership patterns.



For its early exploration program (drill pads and small access roads), Unigold acquires access rights from land owners for temporary use of farmlands and grazing areas for a period of approximately three months. Based on information obtained from the Company, the majority of the land owners hold customary rights to the land. Temporary access is negotiated on a willing buyer-willing seller basis and Unigold signs a written agreement with each land owner. Unigold has established fixed rates for different project activities – drill holes, trenches and access roads. For standing crops, rates are negotiated based on current market prices.



In its agreement template currently used, Unigold will include provisions for reinstatement and restoration, the duration of the drilling activities, rates for standing crops, and compensation for lost crops if the drilling activities extend into the next planting season, and details of a contact person for logging grievances.



The Company will develop a Land Use and Compensation Plan (LACP) to outline the principles, guidelines and approaches that will be followed for temporary land access and compensation activities in accordance with PS5 requirements. See Action 6 of the ESAP.



Unigold will document the process followed for compensation of farmers during the early exploration program including records of number of landowners, status of land reinstatement and return of the land etc.



PS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources:



Regarding PS6 (Biodiversity Conservation and Sustaina
ble Management of Living Natural Resources), no sensitive habitats have been preliminarily identified in the project area with limited impacts from exploration activities on biological resources. However, the Company will carry out a Rapid Biodiversity Assessment (RBA) to evaluate any presence of sensitive amphibians in the area.



Based on a desktop review, the Neita Concession does not lie in any legally protected areas or internationally recognized KBAs/IBAs or AZE sites. The Concession does lie within the Hispaniola Endemic Bird Area (EBA) which stretches across the Dominican Republic and Haiti. Also, on a regional scale, the concession lies within the wider Caribbean Islands Biodiversity Hotspot which runs from Cuba and the Bahamas to Barbados and Grenada.



From a review of the available literature it was also noted that the area of the Neita Concession overlaps with habitat of an amphibian (Eleutherodactylus schmidti) considered as Critically Endangered (CR) by IUCN. This species had a restricted range in the Cordillera Septentrional and Cordillera Central in the Dominican Republic and the Massif du Nord in Haiti. Further review of literature indicates that extensive surveys have been conducted between 1998 and 2000 but no individuals of this species were found in the area and, therefore, it is considered as possibly extinct.



From a visit to several areas around the Concession it was noted that the general habitat is tropical rainforest which has been disturbed in many areas by clear-cutting, agriculture and farming with several areas also under reforestation efforts by the government. The habitat can initially be defined as both modified and natural with some forested areas also present mostly in the hills. It was also noted that timber is harvested in several areas for fuel.



In order to address potential biodiversity related impacts of current activities at Neita, the Company has agreed to carry out a Rapid Biodiversity Assessment (RBA) of its exploration areas with a focus on the identification of the Eleutherodactylus schmidti amphibian. Based on the results of this assessment, the Company will incorporate the necessary management and mitigation measures into its HSEC Policy program and management plans to avoid, reduce or mitigate impacts on sensitive biodiversity values in alignment with the requirements of Performance Standard 6. See Action 7 of the ESAP.



PS7 (Indigenous Peoples) is also not relevant to this project because of the absence of Indigenous People in the area of influence of the Company’s operations. Finally, regarding PS8 (Cultural Heritage), although no cultural resources have been identified the Company will prepare a “chance finds” procedure to be applied in the event of any accidental unearthing of paleontological/cultural relics.

For its early exploration drilling campaigns, Unigold has a team based at the project camp at the municipality of Restauración. The Company currently employs a total of 115 staff, of which 90 are local staff from nearby communities and the remaining staff are expatriates retained as consultants. Unigold is the largest employer in the municipality.



Human Resources Policy



Unigold follows the Dominican Labour Code (which is aligned to ILO’s core labour standards) for management of its Human Resources. The law includes aspects related to employment contracts (verbal and written), working hours and shifts, minimum wage and overtime, employment age, vacation, maternity leave, unionization, termination and severance pay, social security among others.



Unigold 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 a 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, termination, grievance mechanisms and whistle-blowing. See Action 4 of the ESAP.



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



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



Working Conditions and Terms of Employment:



As mentioned above, working conditions are governed by the national labour code. All local employees are registered with the Ministry of Labour. With the exception of the drilling staff, the local staff do not have written contracts. Discussions with the legal counsel responsible for labour affairs on behalf of Unigold indicated that it is common practice in the Dominican Republic to have verbal contracts as there are no legal requirements for written contracts. Discussions with the HR/Administration Clerk based in the camp also confirmed that it was common practice to have verbal agreements. All the employees are however registered with the Ministry of Labour and enrolled in a pension fund provided by the Government.



All Unigold staff and their families are covered with medical insurance provided by the Government.



All contracted employees have contracts that are negotiated/renewed on an annual basis. Unigold will standardize its contractual agreements consistent with the requirements of PS 2.



Unigold will develop an employee handbook that outlines employee rights and obligations and outlines the terms of employment and working conditions (wages and benefits, hours of work, overtime, medical insurance, pension, leave, termina
tion, grievance mechanism etc.). This handbook will be distributed to all employees.



Workers’ Organizations:



The Dominican Labour Law recognizes the rights of employees to form and join unions of their choice. There is currently no union representation at Unigold’s site. Discussions with the HR Clerk indicated that to date, the employees did not seek to form or join unions. Unigold is considered to be a fair employer that “values HR,” wages are established by the Company’s management and are above the national average. The Company does not restrict freedom of association and should the employees decide to organize, Unigold will not discourage unionization.



Grievance Mechanism



Unigold has an open door policy and employees can raise workplace concerns with the Camp Manager, the senior geologist on-site (who is essentially the site manager when the COO is not on-site) and/or the COO when on-site. To date, there are no reported grievances.



Unigold will establish a grievance mechanism through which employees may raise their workplace concerns. The mechanism will establish the policy and procedures for handling grievances, i.e., logging a grievance and mechanisms for resolution. Unigold will inform and train the employees on the availability of this mechanism. The procedure will recognize the rights of employees to access external administrative or judicial process such as an employment tribunal for resolution of complaints that is available under the national law. See Action 4 of the ESAP.



Occupational Health and Safety



Employees are provided with and use the necessary personal protective equipment (PPE) on drilling sites and in the workshop at camp. To date, there have been no significant Occupational Health and Safety (OHS) issues and/or incidents.



As part of the HSEC Policy, specific Health and Safety documents will be developed including detailed procedures consistent with GIIP to minimize accidents and incidents associates with these activities. The procedures will include provisions for worker health and safety training (including contractors), emergency preparedness and response and contingency planning. Unigold will also establish a formal health and safety incident reporting system to document and track incidents and implement corrective and preventative measures as required.



It is important that procedures be formalized within the HSEC Policy to manage existing risks on workers and communities. This in relation to use of PPE, safe working practices during the operation of drill rigs and other equipment, response activities in case of emergencies, etc.

Exploration activities currently being carried out at Neita include the construction of drilling platforms, short connecting access roads and drilling activities (currently using 3 rigs). To support these activities, a base camp has been built approximately 3 km from the community of Restauración which includes accommodations, a drill core shed and supporting services.



During exploration work potential impacts from Unigold’s activities to surface and ground water, soil and air are limited and can be adequately managed through the establishment of the necessary EHS practices. From a walk-through within the camp and the drilling areas good housekeeping was observed with some opportunities for improvements noted, mainly on pollution prevention issues.



Solid and Liquid Waste:



Unigold generates minimal amounts of solid waste mainly from the camp and from the drilling sites. Waste is collected in plastic containers at the camp and in plastic bags at each drill site and transported by a waste company to a waste disposal facility located approximately 5 km away. The Company does make an effort of segregating waste, with organic materials being used for compost and plastic bottles being sent to a recycler. It is understood that the disposal area for domestic waste is not a sanitary landfill but a “dump” and the Company will do additional efforts to minimize the amounts of waste generated and disposed of by reuse and recycling of materials as much as possible. Also, the Company will need to start evaluating other alternatives for disposal of waste at a more secure facility.



Hazardous waste generated at the camp and drill sites is minimal and consisting mainly of spent rags and oil products. Hazardous waste is currently collected on site and transported to a licensed hazardous waste treatment and disposal facility by the facility operator. The Company is in the process of building a new and more secure facility on site for the storage of hazardous materials including used oil.

Regarding sanitary liquid waste generated at the camp, this is directed to a septic system also within the boundaries of the camp.



Water Quality and Use:



Water for drilling activities is obtained from a local river located several kilometers away and within the wider concession and transported to the drill sites via pipe. Estimated use of water is 85,000 gallons per day. According to Unigold, no permit is required at the time for water extraction. At the drill sites, used water from the drilling activities is temporarily stored in a series of pools to allow for solids to settle before discharge to the environment. Also, drilling activities use biodegradable drilling muds to avoid impacts on surface and/or ground water resources.



Water for the camp is obtained from the main township system and stored within a 6,000 gallon reservoir located at an elevated portion of the site.



To date no monitoring of surface or ground water has been carried o
ut by the Company. However, once baseline studies begin as part of the ESIA process, the Company will make efforts to carry out monitoring programs for key components (such as for surface water) in a participatory manner to involve key stakeholders in the process and maintain these stakeholders informed of water quality and quantity trends as the project moves forward (Action 1 of the ESAP).



Restoration and Re-vegetation:



Restoration and re-vegetation of drill pads is carried out at all sites following the completion of work. This process includes restoration of the land form to the original condition and the planting of species of grasses to aid the natural re-vegetation process. As part of the HSEC Policy, the Company will develop and Erosion Control and Revegetation Plan to formalize existing practices for minimizing the footprint of disturbed areas, establishing preventative erosion control measures and establishing effective re-vegetation practices of disturbed areas.



Management of Hazardous Materials (Fuel):



Fuel is currently stored in large steel or plastic drums at each drill site with secondary containment system provided. At the camp site all above ground fuel storage tanks are fitted with secondary containment concrete structures. MSDS for all hazardous waste products at the camp are kept at the office building on site. As part of the HSEC Policy the Company will develop a Pollution Prevention Plan to set specific procedures for the storage and handling of fuel products and requirements in case of accidental spills.



Energy Use



Current supply of energy for the camp is via a diesel generator (55 KW) with another generator (95 KW) used as a backup. The estimated consumption of fuel for maintenance of the camp is about 6,000 gallons per month. The Company is currently evaluating the possibility of installing solar energy systems at the camp to reduce this current consumption.



Noise:



Current noise generated from exploration activities is limited with the distance to any households or single potential receptors (such as local land owners) being several hundred meters to several kilometers away. At the drill sites, drilling operators and helpers are required to use hearing protection in areas of high noise levels.



Emergency Preparedness and Response:



As part of IFC’s investment, Unigold will develop a robust Emergency Response Plan (ERP) outlining emergency scenarios and response actions, key contacts, responsible staff. The Company will also conduct training to employees and contractors on the information within this Plan.



Management of Contractors:



The Company currently has 3 different drilling rigs on site with plans to increase to 4. Drill rig equipment is directly owned by the company and the drilling crews are also hired directly by Unigold. A third party drilling company, Northstar, supports the Company in providing drilling management and oversight. Unigold is evaluating contr
acting out all drilling services to a third party and, if this is the case, will need to standardize drilling contracts and ESHS requirements within these contracts to provide clarity on the obligations of the contractors in this regard.

Community Health and Safety



The drilling operations are located in the Municipality of Restauración. There are a number of villages that are located within the concession area but none are in proximity to the drilling sites – Villa Anacona on the western border of the concession with a population of approximately 10,000 people, Carrisal and Cruz de Cabreme on the northern edge of the concession. Both these communities have a much smaller population of approximately 200 people. The camp is located 3 km from the municipal centre of Restauración.



During exploration work, potential impacts from Unigold’s activities to surface and ground water, soil and air and, subsequently to human health, are limited and can be adequately managed through the establishment of the necessary EHS practices. Access to the camp and the drilling sites is via graded and tarmac roads and although the current level of traffic to the site is relatively small (currently around 8 light trucks between Unigold and its contractors), there are potential risks of road incidents or accidents related to workers and to the local communities. The HSEC Policy will address road safety and the management of risks from transportation of any materials and personnel.



The drilling sites are located within agricultural and grazing lands. The presence of vehicular traffic and drilling activities associated with the project poses a potential safety risk to the livestock browsing and grazing the land and to road users. To date, there are no reported accidents. Unigold will provide defensive driving training to their employees and ensure that their contractors do the same. The drill sites will be properly barricaded to ensure that livestock and people do not wander into the sites.



The western edge of the concession is adjacent to the Haitian border. To date, there are no security concerns and/or any influx of people to the concession area.



Security Personnel:



Unigold employs 5 unarmed security personnel. The military is deployed to site during the holiday season as generally there is an increase in theft incidences. To date, there are no incidences involving local communities and/or any major security issues.



The Company will develop a Security Policy and a Code of Conduct for security personnel and public security forces consistent with the requirements of PS 4 (See Action 5 of the ESAP) incorporating the relevant guidelines of the Voluntary Principles on Security and Human Rights. The Code of Conduct should set clear objectives for the work of security personnel and permissible actions, and be based on applicable law and professional standards. These instructions will also be communicated as terms of employment and through periodic training.



Any grievances from the community relating to security incidents will be captured through the community grievance mechanism and will be investigated to identify any necessary corrected or preventative actions.

For its early exploration program, Unigold has undertaken a series of engagement sessions with the local communities in the concession area to raise awareness about the company, the exploration program and drilling activities and the land access process.
Unigold also held a number of community meetings with affected land owners to discuss temporary access and use of the land for the drilling operations. Unigold will formalize its engagement program to ensure that the local communities are kept up to date with the exploration program, manage community expectations with respect to employment opportunities and issues associated with land access and compensation. This is key to maintaining a positive relationship with the communities and to minimize grievances associated with project activities.

Unigold will develop a Stakeholder Engagement Plan (SEP) that describes the Company’s policies and procedures for consultation with all the relevant stakeholders and affected communities and disclosure of project information and documentation. The Plan will include Dominican regulatory requirements and be consistent with the IFC Performance Standards. The key components will include (i) principles and process for identifying stakeholders, (ii) strategy and schedule for sharing information, (iii) grievance mechanism for the affected community to receive and resolve complaints, (v) a high level schedule for engagement and disclosure of information aligned with the project’s various stages including the ESIA and (iv) a detailed list of stakeholder categories and (v) organizational roles and responsibilities. See Action 3 of the ESAP.

The SEP will be commensurate with the project’s risks and impacts and will document all engagement activities to date and a process for engaging the communities during the development phase ESIA (including receiving, documenting and addressing feedback received during the impact assessment and incorporating into project design and strategy).

The company will also report annually on progress made in implementing the company’s environmental and social action plan.

Unigold will make a copy of the ESRS and the attached ESAP available in the following locations in Santo Domingo and near the project site for a period of 30 days starting April 16, 2013.

Unigold Exploration Camp
Hwy 45, Km 2 Jimenez,
Restauracion, Dajabon Province
Dominican Republic

Garcia Campos
Local Counsel
Ave. John F. Kennedy
Edif. Plaza Compostela, 4th. Floor
Suite 415, Ensanche Paraiso
Santo Domingo, Dominican Republic
Phone: 809 541 4079
Fax: 809 566 5646

For further information, questions or comments please contact:

Andrew Cheatle
President and Chief Executive Officer
Unigold Inc.
Suite 504, 44 Victoria Street
Toronto, ON M5C 1Y2
Canada
Tel: 416.866.8157
Fax: 416.866.8674
Email: mailto:unigold@unigoldinc.com
Website: http://www.unigoldinc.com

Broad Community Support is not applicable for this project

Environmental and Social Management System
Sign on to a Health, Safety, Environment and Community (HSEC) Policy that defines how the project will be operated in line with the requirements of IFC’s Performance Standards, EHS Guidelines and Dominican Republic legislation appropriate to the level of activities.	Within 2 months of subscription.
Retain an experienced international ESHS consultant to satisfaction of IFC to support the company with:
a.     Develop the necessary Elements/Programs and ESHS Management Plans/SOPs of the HSEC Policy which are aligned with GIIP to address existing environmental, social and health and safety risks form current exploration activities.	Within 6 months of subscription.
b.    Design and implement a surface water participatory monitoring program to identify existing water quality and quantity conditions in the area, communicating these to the local population and to serve as baseline for the future ESIA.	When surface water baseline work begins as part of the ESIA
Disclose the HSEC Policy on Unigold’s website	Within 2 weeks of IFC’s approval of the HSEC Policy.
Organizational Capacity
Retain an EHS Specialist with experience in the application of GIIP to implement the HSEC Policy and build capacity with the local staff.	Within 4 months of subscription.
Stakeholder Engagement and Communications
Retain an experienced international social consultant to satisfaction of IFC to support the company with:
Develop a Stakeholder Engagement Plan, a Grievance Mechanism and Procedure and a Communications Program to identify/map key stakeholders and engage and communicate with the affected community and stakeholders in a frequent and effective manner. Reference: Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets (May 2007); “Addressing Grievances from Project Affected Communities: Guidance for Projects and Companies on Designing Grievance Mechanisms”, IFC, 2009.	Within 6 months of subscription.
Human Resource Policy and Employee Grievance Mechanism
a.     Develop a Human Resources Policy consistent with the requirements of PS 2 and disclose it on its website.	Within 6 months of subscription.
b.    Develop a Grievance Mechanism for workers in line with the requirements of PS2.	Within 6 months of subscription.
Security Policy and Procedures
Develop a Security Policy and a Code of Conduct for security personnel in line with the requirements of GIIP and the Voluntary Principles on Security and Human Rights.	Within 6 months of subscription.
Land Acquisition and Compensation for Exploration
Develop a Land Use and Compensation Plan (LACP) to outline the principles, guidelines and approaches that will be followed for land acquisitions and compensation activities in accordance with PS5 requirements.	Within 6 months of subscription.
Rapid Biodiversity Assessment (RBA)
Retain an experienced and recognized biodiversity consultant group or organization to carry out a Rapid Biodiversity Assessment (RBA) of upcoming exploration activities at the Neita Concession to evaluate the presence of the species Eleutherodactylus schmidti and provide recommendations for addressing any potential impacts from exploration activities.	Within 6 months of subscription