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
PS 8 – Cultural Heritage
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
PS 7 is not applicable as there are no indigenous people in the project area as defined by IFC policies.

This is a category A project due to the potentially significant, diverse, and irreversible environmental and social risks and/or impacts inherent to a project of this nature and scale operating in Guinea. The key concerns relate to the cross-cutting issues of water resources, biodiversity, community livelihoods and ecosystem services. The Expansion Project will also result in impacts from physical and economic displacement starting in 2016. The expansion and existing project areas are associated with Critical Habitat under Performance Standard 6. The Expansion Project is also expected to contribute to cumulative regional impacts for which other bauxite mining and infrastructure projects in the region are also contributors. The principal biophysical risks and impacts include (1) impacts on biodiversity and ecosystem services; (2) changes in surficial water balance and groundwater recharge; and (3) visual impacts from changes to landscapes. The principal socio-economic risks and impacts are: (1) significant ongoing resettlement and economic displacement; (2) competing claims for limited available land between biodiversity needs and community needs; and (3) legacy grievances associated with CBG operations since 1973, including past resettlement.. The project requires a public disclosure period of at least 60 days prior to consideration by the IFC Board.

Environmental and Social Assessment and Management System
For the Expansion Project, CBG is developing a management system that meets the IFC Performance Standards objectives. However, for its existing operations the Company already has an established Hygiene (Health), Safety, Environment and Communities Management System (HSEC MS) with associated plans, procedures and resources. The existing HSEC MS will be upgraded and integrated with the new system being developed for the Expansion Project. In this way, the whole CBG operation will eventually be brought to the same standard.

The existing HSEC MS is guided by the Mining Code of Guinea and Good International Industry Practice (GIIP) and its structure and content is detailed in CBGs HSEC Management Plan based on the "Plan Do Check Act approach to continuous improvement. The Plan includes the following system elements:

Quality, Safety and Environment Policy (QSE) Policy including community related issues
Risk Management (including hazard identification process/tools and identification of risk within change management process)
Legal Requirements and Other Commitments
Goals and Targets and Programs
Resources, Roles, Responsibilities and Authority
Training, Competency & Awareness
Behaviour and Observation
Communication, Consultation and Participation
System Documentation & Records Management
Contractor Selection and Management, including a contractor pre-qualification and approval process that includes consideration of CBGs HSEC requirements)
Accident/Incident Reporting and Investigation
Operation controls (a suite of safety, Health and Hygiene, environmental and community related procedures)
Emergency Preparedness and Response
Monitoring and Measurement
Nonconformity, Corrective and Preventive Action
Internal and External Audits
Management review

The HSEC MS has been developed in accordance with the requirements of OHSAS 18001:2007 Occupational Health and Safety Management Systems and ISO 14001:2004 Environmental Management Systems, although the system has not received formal certification. While the existing HSEC MS does include most of the elements expected in a system that meets IFC Performance Standards objectives, data monitoring and reporting (both baseline and operational) is limited. CBG has committed to an intensive monitoring program for the existing operations to better define current impacts and inform mitigation measures in the various plans and procedures.

Policy
Within the QSE Policy CBG has set itself several key objectives, including the implementation of a negotiated involuntary resettlement program for Project Affected Peoples (PAPs) in the area of the Expansion Project, which is in accordance with IFC Performance Standard 5. CBG has committed to retroactively assess legacy involuntary resettlement and to identify outstanding grievances relating to past compensation. The Environmental and Social Management Programs (described below) also make reference to over 50 procedures that underpin the HSEC-MS, skills and training requirements and the audit process. Many of these were provided for review during the due diligence process.

Identification of Risks and Impacts

Mining: The Expansion Project will necessitate an increase in the rate of vegetation clearance and overburden removal in existing areas within the CBG concession. The lateritic soils are stripped and removed for use in rehabilitation before overburden removal. Usually, the quantity of overburden is very low, as the bauxite ore is generally close to the surface. The total area for the Expansion Project is 3,200 ha, over which habitat (including farmed areas) will be lost/degraded. Mining is straightforward with extraction of bauxite ore typically using standard drilling and blasting techniques. The ore is trucked along dedicated haul roads to stockpiles at Sangarédi from where it is loaded onto trains. The expansion will also entail the acquisition of additional plant and equipment (loaders, trucks, bulldozers and water tanks) and additional workers. New mobile machinery workshop facilities will also be required. Improvements to the town infrastructure at Sangarédi (and Kamsar) will be made for the additional workforce. Construction of temporary construction camps within the industrialised and mining zones of Kamsar and Sangarédi is also planned.

Studies for the Expansion Project which state that they were designed to meet the requirements of Guinean law and IFCs Performance Standards, including an Environmental and Social Impact Assessment (ESIA) were developed by an international Canadian based consultancy during 2014. The studies cover the life-of-mine (assuming a production level from 18.5 to 27.5 mtpa) and were submitted, publicly disclosed including numerous consultations with local communities and approved by the Bureau Guinéen dÉtudes et dÉvaluation Environnementale (BGÉÉE) in May 2015. The environmental permit that allows for the Expansion Project was issued by the Government in June 2015. In addition for any future activities that significantly alter the scope or footprint of the project, CBG will be required to conduct an appropriate environmental and social assessment process in compliance with the same standards including full consultation and disclosure.

From the IESCs and ITEs draft due diligence reports (the IESC report is essentially a review of the project ESIA and associated HSEC MS documentation) as well as IFCs own review, gaps with the IFC Performance Standards were identified in the ESIA, especially a need to strengthen and expand baseline data. The framework management plans contained within the ESIA were also identified as requiring additional detail to enable better definition of project mitigation measures. These draft reports covered only the proposed Expansion Project but have since been updated to also cover review of the SIP including the existing operations. The revised reports were finalized in early November 2015 and have been reviewed as part of the appraisal.

Railway: The bauxite ore is transported from Sangarédi to the Kamsar plant via a railway operated under a concession granted to CBG by the Guinean government (through ANAIM, the State-owned entity that owns the rail infrastructure). The construction of a new rail yard, extension of the sidings and storage area in Parawi and associated facilities (road, bridges, railway) already planned by CBG in order to operate to the north of the N23 national road will be brought forward. An overpass, linking to the new bauxite storage area will be constructed to cross the national road. Key impacts relating to operation of the railway are noise and vibration as well as safety of nearby residents.

Currently, between five and seven trains per day, each comprising two 3000 HP locomotives and 120 loaded bauxite ore wagons leave the Sangarédi mine for Kamsar. Each wagon contains around 82 tonnes of bauxite ore. The expansion to 18.5 mtpa does not entail significant changes to the railway, the key impact being between two and four additional trains per day. These trains will comprise 130 wagons (an increase of 820 tonnes of bauxite per train). The ITE considers that use of the existing road locomotive fleet can be optimised to operate the heavier trains and increase the daily frequency to between seven and nine trains per day. No new passing loops are required but the existing loops at Tanéné (KP 72.7) will be extended by 600 m to accommodate the longer trains, but the other existing loop at Boké (KP 54.7) will not require major works.

A Multi-User Agreement has been established as a framework for other mining companies to potentially have access to the railway as long as defined criteria are met"CBG will continue to be in charge of maintenance, management and operation of the railway infrastructure as concessionaire.

The civil engineering work for the new and existing passing loops is all within the existing railway corridor, however impacts associated with potential physical and economic displacement due to the construction of the passing loops, opening of borrow-pits and quarries has been considered and will be included in the Resettlement Action Plans (RAPs) and Livelihood Restoration Plans (LRPs) being prepared for future resettlement as appropriate.

Kamsar Processing Plant: On arrival at Kamsar, the ore trains enter a marshalling yard from where the wagons are uncoupled and then individually emptied at the wagon dumper. This is time consuming as each wagon is hoisted up several metres before being inverted so that the ore may be tipped into the hoppers at the dumper from where it is fed by conveyor to the processing plant. The increased production levels will involve construction of a completely new wagon unloader that will include rotating wagon couplers so that the wagons may be tipped without uncoupling. This will also require some modifications to the track layout in the marshalling yards. The new wagon unloader area will be fully enclosed to reduce noise and fugitive dust emissions. A dust control system, including ventilation, curtains and fogging nozzles is planned in the unloader area to address fugitive dust emissions associated with the current operation.

The processing plant has a simple circuit. The ore initially passes through crushers which consist of hammer mills that crush the ore according to market specifications. For the Expansion Project, a new crushing facility will be located in the unloader area. A conveyor will then feed the ore to stockpiles via a new transfer tower. No changes will be made to the current stacking and ore reclaiming systems.

The bauxite ore is currently dried in heavy fuel oil fired rotary dryers to achieve a moisture content of 6.7% prior to shipping, these are equipped with dust scrubbers. Two new rotary dryers will be necessary for the processing of the additional ore, also fitted with scrubbers. The dried bauxite is stockpiled in a covered storage shed prior to shipment, and an additional storage shed will be built as part of the Expansion Project that will be located adjacent to the existing shed to provide capacity for 150 000 tonnes of ore. There is no waste from this process, however bauxite slurry from the scrubbers is currently discharged into a sedimentation pond from where it is removed, dried and recycled into the process as raw material.

The existing plant has historically generated significant quantities of fugitive dust as well as particulate and gaseous emissions from the dryer stack. This has generated complaints and grievances from residents in Kamsar town, although additional filters and scrubbers were installed on the dryer stack in recent years. The additional monitoring described above will allow the current baseline and impacts on Kamsar town to be fully characterised prior to the start of construction. The Expansion Project includes designs for enclosed conveyor systems and transfer points plus additional scrubbers so that dust emissions can be brought within defined air quality targets.

The project currently has heavy fuel oil powered generators at both Kamsar and Sangarédi. The energy needs associated with the expansion will increase demand from 22 MW to 29 MW. Heavy fuel oil is also used to fire the dryers and a steam boiler. The fuel is stored in large, fully bunded above ground tanks.

Port: Currently, the ore is transferred from the storage sheds by conveyor to a 275 metre long concrete jetty equipped with ship loading conveyors. This will be extended by a further 301 metres with a second set of ship loaders to enable the mooring and continuous loading of two Kamsarmax vessels (DWT of 70,000 and a ballast draft of 7 m). This quay will be extendable and therefore able to accommodate larger Cape size vessels (DWT of 150,000 and draft of 9 m) if needed in the future. The extended quay will comprise a concrete deck supported on foundation piles.

The channel and turning basin that provide access to the pier are currently dredged about once every two to three years (and have been since 1973). This turning basin is sufficient for the 18.5 mtpa expansion. This routine maintenance dredging generates around 100 000 tonnes of sediment. The sediment deposition area used historically (and for the Expansion Project) is at the mouth of the Rio Nunez estuary in deeper water that does not represent an important fishing area and is outside of the area considered to be representative of critical habitat. There will also be an increased number of support vessels, for example, a pilot boat and tug. The proposed dredging activities at the port (300,000 m³ of material), required as part of the Expansion Project, were assessed in the ESIA and various recommendations made, which CBG has incorporated in a Dredge Management Plan. This plan will be updated to meet GIIP including detailed specifications for dredging techniques and methods.

The shoreline around the port comprises extensive areas of mangroves, no additional physical impacts to these have been identified as a result of the Expansion Project. Monitoring of the mangroves, especially fish populations will be undertaken. Consideration of local fishermen is covered by the PS 5 section.

Specifically, CBG has committed to a number of mitigation measures that were made as recommendations within the ESIA, these include: (i) avoidance of the use of suction dredgers. If there is no alternative, a turtle deflector or other means to avoid impacts on marine life will be used; (ii) measures to reduce underwater noise to a minimum whilst dredging; (iii) completion of a study to determine the benthic fauna of the sediment deposition zone; and (iv) if possible, dredging will be avoided from August to January to minimise impacts to the Blackchin Guitarfish.

Cumulative Impact: The project is one of several current or potential bauxite mining operations in northern Guinea and while the risks and impacts are significant (though not yet possible to define accurately), this Expansion Project presents a significant opportunity for IFC and other potential partners to influence development in the region in a manner that aligns with the IFC Performance Standards. Furthermore, World Bank Group involvement can also be used to proactively build capacity within the Guinean government to help in the strategic and sustainable development of the countrys natural resources in a sustainable manner. A key opportunity is for IFC to assist with building a platform for broader linkages and sustainability in the management of cumulative impacts.

The potential cumulative loss of habitats, fragmentation and other associated impacts arising from CBG and other projects are likely to be significant regionally. This is against a background of ongoing biodiversity loss and encroachment as a result of other factors such as in-migration and growth in agriculture.

The ESIA includes a cumulative impacts assessment (CIA) that is stated to follow the guidelines of the Canadian Environmental Agency on CIA. Combined, the current and proposed mining projects in Guinea will have significant biodiversity, community and cross-cutting ecosystem services impacts and landscape level (even Country level) solutions will be required, especially around biodiversity off-set identification and management and its interaction with land requirements for resettlement. Proposals for off-sets within the concession and external to the concession will be competing for land with resettlement / livelihood restoration activities of the various companies.

Project-specific offsets are an important tool for addressing significant residual adverse impacts of a project, however because of the uncertainty around land tenure, competing land uses, and a rural population that is heavily dependent on forest resources, selecting offset sites that are politically, socially, and technically feasible to implement in or near the CBG concession area is likely to be challenging. The ability of any company to achieve compliance with PS 6 under such circumstances is uncertain and the timescale to reach a point at which Net Gains in biodiversity can be determined is likely at least ten years or longer.

CBG is working through the mitigation hierarchy and exploring a number of options to avoid, minimize, restore and offset impacts. It is possible that a landscape level solution is required, that might be phased over time and with other resources and partners who are, as yet, undefined. Work is underway by the Wild Chimpanzee Foundation (WCF) in the Fouta Djallon area of Guinea (the Bafing Nord area) to identify and establish a conservation area for the West Africa Chimpanzee to offset the impacts of mining and other development on chimpanzees. However, the land required is mostly owned by the Government of Guinea and it will require many additional partners to enable this to succeed. Discussions with the Ministry of Environment and the National Directorate of Parks and Reserve have already taken place.

Other agencies and institutions are known to be planning a project to focus on the implementation of the mitigation hierarchy and offsets in Guinea, including the development of national policy. Part of that work will be a focus on potential pilots that could work to inform that policy and effective approaches on the ground. The project may be able to use a CBG offset as a pilot and is very keen to develop partnerships with IFC and others around this initiative.

IFC and the World Bank have initiated a strategy group to help build a coalition of institutions, conservation organizations, national authorities and local populations. One initiative would be to start with a regional workshop including partners, government ministries, mining companies, national and international NGOs, to assist in the realization of a landscape level offset. CBG is committed to collaborating with and supporting such initiatives in respect of its own zone of influence and responsibility.

There are also likely to be significant social impacts due to displacement and reduced food security, and impacts on water quality and availability in some areas. The World Banks Mining Sector Governance Support project for Guinea aims to strengthen the capacity and governance systems of key institutions for managing the minerals sector in Guinea. There are a number of components including a regional aspect and will most likely focus on at least one "growth corridor, (iron-ore in the South-East or bauxite/alumina in the North-West). Part of this may include a Strategic Environmental and Social Assessment.

There are a range of other IFC investments and advisory initiatives in Guinea that could serve as a unique platform to convene the range of stakeholders around major environmental and social challenges to preserve stability and livelihoods in Guinea.

In the case of the railway, the Multi-User Agreement also defines a process whereby CBG, as concessionaire, is required to undertake the ESHS assessments necessary for other potential users. Such users are required to follow a process of notification and provision of project details to CBG to inform the ESHS assessment, at the current time no other potential users have done so.

Management Programs
IFCs appraisal considered the environmental and social management plan (ESMP) for both the existing operation and the Expansion Project, and gaps (if any) between these plans, IFC requirements and CBGs existing and proposed corporate policies, systems and procedures. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and in the agreed Environmental and Social Action Plan (ESAP). CBG has committed to implement these management plans and the ESAP so that the project as well as any future exploration or development activities of CBG are designed and operated in accordance with Performance Standards objectives. The initial ESMP for the Expansion Project was integrated with the ESIA and included (i) a summary of CBGs HSEC MS, plans and procedures; (ii) an explanation of the ESMPs integration with the broader HSEC MS, including the development of detailed environmental and social plans and procedures; and (iii) a list of mitigation measures.

The due diligence review and process of meeting lender requirements has resulted in CBG undertaking a significant upgrade of the ESMP, which is considered to be a live document that will require periodic update as actions are completed or new actions become necessary.

The revised ESMP (disclosed in the SIP) describes the mitigation measures to which CBG has committed in respect of its expansion activities (defined as the 27.5 mtpa future expansion rather than the 18.5 mtpa that IFC is financing). The actions defined in the ESMP form the basis for the operational controls to be introduced into the HSEC MS for the project and then for CBG as a whole. A monitoring and audit process will measure the performance of the project and of CBG in terms of compliance with the ESMP. A mitigation measures register is organized by topic and sub-topic, and indicates the phase and specific component addressed by each measure. The categories of mitigation measures are:

Management framework, programs and plans
Air quality
Greenhouse gases
Noise and vibrations
Water and sediment quality
Soil
Biodiversity Action Plan (BAP)
Social and demographic structure
Community safety
Community health
Infrastructure and basic services
Economic environment and household strategy
Access to land, resettlement and compensation (RAPs)
Governance and social
Communication and information
Traffic and transportation
Cultural heritage and archaeological sites

For each mitigation measure, the details of the undertaking; the phase during which the undertaking will apply (design, construction, operations or closure); and the project component to which the undertaking will apply (mine, railway or plant/port) are included.

A number of other plans, including: (i) a mine rehabilitation plan (Sangarédi); (ii) a harvest management plan for bushmeat; (iii) a management plan for the harvest of firewood; (iv) a forest protection plan (Sangarédi); (v) a plan to protect vegetation bowals; the Cogon corridor protection plan; and (vi) a plan to protect the estuary of the Rio Nuñez are in the process of being amalgamated within the BAP referenced above. Finalisation of the BAP and the preceding BAP Framework are a requirement of the ESAP. Accordingly reference to these plans is not included in the revised ESMP disclosed within the SIP.

Organizational Capacity and Competency
CBG has the structures appropriate for the management of a large mining company, it also has access to the resources of shareholders Alcoa and Rio Tinto who provide technical advice (including ESHS advice) through structures defined in the Management Agreement. There are functional department heads in key areas. Implementation of the Expansion Project ESMP will be the responsibility of the ˜HSEC Manager “ Expansion Project who is also the primary contact with the construction contractors and therefore essential to the implementation of the ESMP. However, in one area, strengthening of the team is required, the due diligence process identified that the Expansion Project is being planned and managed by a team separate from the existing operations. The need to build capacity that can manage the cross-cutting issues for the entire CBG operation, especially CBGs collaboration in the management of cumulative impacts will require additional resources, especially a dedicated Biodiversity Manager and a Monitoring Specialist supported by a team. CBG has in place a training program and development plans for its staff which are updated on an annual basis.

Emergency Preparedness and Response
CBGs current approach to emergency response is outlined in its Emergency Response Procedure issued in January 2015. The procedure is intended to cover all significant emergency situations including fires, explosions, spills of hazardous materials, release of toxic gases. The plan defines linkages with other organisations to be contacted/involved in an emergency response including communication with the public; roles and responsibilities within CBG and makes reference to the following specific plans within the procedure: (a) derailment of a train carrying hazardous materials (e.g.: fuel); (b) oil or fuel spills both onshore / offshore and oil, fuel or other hazardous material fire. The plans refer to response actions and also specific high-level requirements for training and periodic exercise drills. CBG is in the process of revising and updating the plans to include more specific detail and to make it fully operational as stipulated in the ESAP.

Monitoring and Review
The ESIA for the Expansion Project relied on a combination of monitoring and predictive modelling data to establish baseline pollutant concentrations. The IESC and IFC reviews identified a need to strengthen the database and for both air and water resources in particular, monitoring will be expanded both in terms of the number of locations and duration and frequency of monitoring. Baseline modelling of the existing operations will be expanded to include other existing sources of pollutants such as local traffic, other industrial sources and domestic heating. Some comparison of the monitored versus modelled pollutant concentrations has been carried out to validate the modelling, and whilst this shows good agreement (e.g.: for short term particulate concentrations), further monitoring will enable better validation of the models. The revised monitoring program (both baseline and emissions monitoring) across a wide range of parameters is defined in several actions in the ESAP but it will take at least a year to obtain full seasonal variations for the database. An adaptive management approach is being taken whereby environmental management plans will be modified as required as additional data becomes available.

Working Conditions and Management of Worker Relationship

CBG is Guinea’s largest private-sector employer, with around 5,000 workers. The due diligence has confirmed that the project complies with national labour legislation and respects human rights. The project has also committed to practices aligned with PS 2 although specific reference in this regard is being added to the ESMP and other relevant documents to align them with GIIP. In its updating process to ensure project documentation is aligned with PS 2, CBG will refer to the IFC (2010) Measure & Improve Your Labour Standards Performance. The ESIA considered PS 2 related impacts and mitigating measures including human rights. CBG workers have the right to freely associate in unions as well as a right to strike. In addition, an Accommodation Policy largely compliant with PS 2 was developed in 2014. This policy deals with allocation of housing for permanent staff, but not with temporary contracted workforce, which is an action item in the ESAP.



During the construction phase, CBG will build two accommodation camps which will house most workers: one in the N’Dangara mine area to accommodate 60 workers, and another in the industrial area of Kamsar for 600 workers. CBG will develop a plan covering the design principles and criteria to be applied to workers’ accommodation to ensure that PS 2 standards are being followed in terms of camp layout and facilities, as well as a consideration of the camp management policies and procedures to be applied. In this context, it would be expected that there would be reference to using the guidance/advice contained within the IFC (2009) Guidance Note entitled “Workers’ Accommodation: Processes and Standards”. For the operational phase, CBG has plans to build 388 dwellings reserved for future mine expansion-related employees and their families, including 133 houses in the town of Sangarédi and 275 in Kamsar, by 2017. CBG will continue to implement its Accommodation Policy developed in 2014 for its workers’ families, which has been reviewed and is largely compliant with PS 2.



Human Resources Policies & Procedures

CBG has developed a Code of Ethics and Business Conduct. The code covers issues relating to equal opportunities for workers, forbids child and forced labour, and deals with suppliers who use such labour. There is a staff handbook and a handbook on external recruitment. As stipulated in the ESAP, to ensure full compliance with PS 2, CBG has committed to review and update the HR Policies and the Code of Ethics and Business Conduct to include: (i) Confirmation that its scope of application for worker-related issues covers direct, contracted and supply chain workers; (ii) confirmation that migrant workers are also covered (to ensure that they are engaged on substantially equivalent terms and conditions to non-migrant workers carrying out similar work); (iii) a Grievance Mechanism for workers plus a whistleblowing procedure to be disseminated and impl
emented throughout the Company and its contractors; and (iii) an updated Retrenchment Plan covering the eventuality that collective dismissals of workers cannot be avoided (as per the IFC Good Practice Note: Managing Retrenchment).



Non-discrimination and Equal Opportunity

A Local Content Policy for the Expansion Project has been developed and has been implemented since October 2010. The policy emphasizes recruitment and includes positive statements about CBG being an equal opportunity employer (taking no account of ethnicity, religion, age, gender, or marital status).



Workers’ Organizations and Retrenchment

CBG has a Collective Agreement that covers relations between CBG and workers’ organizations and includes principles that are applied to all CBG employees. Additionally, there is a Policy for Rationalization that covers retrenchment issues with a focus on types of workers and compensation mechanisms.



Grievance Mechanism

A document entitled Complaints Procedure was produced that contains a summary of complaints/grievances, the responsible person for managing them and the actions taken to address them. CBG has committed to expand and strengthen this document so that it meets the requirements of PS 2 on a grievance mechanism including: (i) a trade-union agreement that provides for formal processes of communication with CBG management; (ii) a whistleblowing procedure as noted above; and (iii) appointed “worker relations advisors” for each CBG division. A complaints register was opened in 2015 and will be developed so that it forms a database of complaints.



Occupational Health & Safety

In terms of health and safety of workers/suppliers, various documents provide evidence of care for workers’ health and safety, such as cardinal rules; personal safety plan and contractor management plans. CBG has provided OHS data from 2004 until the present day, this has shown continuous improvement with monitoring and reporting following Rio Tinto group standards with the main KPI’s being Total Reportable Injury Frequency Rate (TRIFR) and Total Injury Frequency Rate (TIFR). The 12-month rolling TRIFR has fallen from 1.51 in 2012 to 0.20 currently, this compares well with global TRIFR performance in the sector. For the first nine months of 2015 CBG reported the following data regarding direct employee and contractor injuries: total recordable injuries totalled 14 while total injuries were 43. There were no fatalities. CBG records key details of every recordable incident in an Incident Register and prepares a monthly Incidents Report. CBG intend to further refine their OHS reporting by including comparisons with industry benchmarks for the sector.

Resource Efficiency

The ESIA assesses a range of Project-related energy efficiency issues.



Water

CBG has established a Water Management Framework that commits CBG to adhere to PS 3 and effectively manage water resources during each phase of Expansion Project, including the issue and implementation of a Water Management Plan (WMP) in accordance with the Rio Tinto HSE Standard E10. The WMP will add to the scope of the current surface water and sediment monitoring programs and the well network and monitoring program presented in the SIP, and will become part of the evolving ESMP. As part of the WMP, CBG has committed to preparing water balances for the Kamsar area and Sangarédi mining area, including development of a groundwater model to enhance understanding of the hydrogeological / hydraulic regime and to proactively assess potential impacts on local communities and sensitive habitats and species. CBG will also establish a broader and technically focused monitoring network for surface water, sediments and groundwater, which will be adapted based upon the information obtained and as the mining activities progress. The WMP will also include a Water Management Strategy and a monitoring register (including KPIs and action thresholds which, if breached, will trigger corrective actions), clear definition of responsibilities and training needs for staff, as well as establishment of a specific CBG team for water management.



The project is reliant on the implementation of the WMP to meet PS 3 requirements. This includes filling gaps in baseline data, completing impact assessments through modelling and monitoring, and reviewing mitigation measures, if/where necessary. A thorough and well implemented WMP should enable the key water-related risks associated with the project to be addressed. Given the evolving nature of the project, with mining progressing gradually across the various plateaux, the WMP will be reviewed by the IESC on a regular basis.



Greenhouse Gas Emissions (GHG)

The assessment concludes that gaseous emissions will increase with the Expansion Project at both Kamsar and Sangarédi due to the increased combustion processes and from blasting operations at Sangarédi. The GHG emissions assessment for the project is based on the methodology and values recommended in the 2006 IPCC Guidelines for National Greenhouse Gas Inventories. Current CBG GHG emissions represent 3% of national GHG emissions in Guinea and current projections are that the Expansion project will increase this to 3.6%. This increase in GHG emissions is not directly proportional to the production increase, as a more efficient production process is planned to be used in the Expansion Project. As a result of production efficiency improvements, CBG has estimated that during the final phase, CO2 emissions will represent 0.018 tCO2e/tonne of bauxite shipped compared with 0.020 tCO2e/tonne of bauxite shipped in 2012. These are equivalent to approximately 280,000 tCO2e in 2012
and 370,000 tCO2e for an 18.5 mtpa production. Several measures to reduce GHG emissions are in place including: (i) appropriate maintenance of trucks, vehicles and locomotives; (ii) optimization of locomotive haulage characteristics; (iii) a new locomotive cab-signaling system featuring automated speed control to reduce fuel consumption; (iv) consideration of GHG emissions performance criteria for the purchase of new equipment; and (v) the rapid rehabilitation of cleared areas once extraction is over. In line with IFC PS requirements, CBG has committed to annual reporting of Greenhouse Gas Emissions during the operations phase and a number of energy efficiency measures to reduce GHG emissions. The ESIA noted some use in the past of CFC refrigerants at CBG but a phase out program was completed during 2012.



Pollution Prevention



Air Emissions and Ambient Air Quality

The affected airshed at both Kamsar and Sangarédi is already degraded, with some baseline ambient air quality data already exceeding WHO limits, CBG is committed to carrying out the work necessary to adequately characterise baseline conditions and validate the air dispersion modelling used to predict future concentrations. Gaseous emissions and particulates are predicted to increase as a result of the Expansion Project at both Kamsar and Sangarédi due to increased combustion processes and from blasting operations at Sangarédi. Particulate concentrations would decrease to a certain extent at Kamsar due to improved dust control measures associated with the process facility upgrades. A number of air quality mitigation measures have been included within the ESMP and these will be upgraded as additional data becomes available,, in particular the definition of setback distances to protect villages during mining and blasting operations to meet GIIP. The impact of these additional mitigation measures on overall air quality will be subject to rigorous monitoring to enable a determination of ambient air quality with respect to the applicable air quality standards.



Noise and Vibration—the ESIA concludes that the Expansion Project will increase the current noise levels, although baseline noise already exceeds IFC guidelines for day and night time noise limits in some locations. Mitigation measures are specified for sensitive receptors (human, ecological and marine) where the increase above baseline levels is greater than 3 dBA, or if the additional noise causes IFC guideline levels to be exceeded. Additional noise monitoring will be undertaken by CBG in order to verify the efficacy of the proposed mitigation measures. The need for additional underwater noise assessment in the port and nearby marine areas is acknowledged by CBG and will be undertaken in the near future.



Wastewater Treatment

Other elements of the WMP (referred to above) will include: (i) a Stream Crossing Plan that includes procedures for management of construction and operation of mine road crossings to prevent sedi
mentation and deterioration of surface water quality; and (ii) installation of tertiary treatment at the Sangarédi wastewater treatment plant with upgraded monitoring of effluent discharges, including expansion of parameters analysed to ensure compliance with applicable standards plus upgrading of the laboratory analytical suite for monitoring of potable water to include a wider group of parameters in line with WHO guidance.



Solid Waste Management

The ESIA discusses hazardous and non-hazardous waste management, and following the IESC’s feedback on the management of waste, CBG has made available further documentation concerning its waste management practices. The new documentation highlights a number of good practices that CBG is either currently undertaking or has committed to undertake in the future. Nevertheless further studies (to which CBG has committed) will be undertaken on the suitability of certain non-engineered and temporary waste disposal sites and the level of environmental monitoring around waste facilities.



Reinstatement of Disturbed Areas—CBG has a Mine Reclamation and Closure Plan covering rehabilitation of mined areas by grading and revegetation. CBG aims to rehabilitate one hectare for each new hectare mined. A commitment, accompanied by measures to accelerate reinstatement, has been provided by CBG to overcome a backlog in rehabilitation that has occurred in previous years. The Mine Reclamation and Closure Plan will be updated to align with the IFC Guidelines for Mining. Specifically this will include details of mine restoration planning, with dated compliance targets for rehabilitated areas. The reclamation plan will be developed in conjunction with stakeholders and seek to balance the needs of communities with the need to restore ecosystem services and restore natural habitats.



Pesticide Use and Management

CBG will undertake a full review of its use of pesticides in order to meet PS 3 requirements. The Company has committed not to purchase, store, use, manufacture, or trade in products that fall in WHO Classification by Hazard Class Ia (extremely hazardous) or Ib (highly hazardous). For Class II (moderately hazardous) pesticides, CBG will ensure there are appropriate controls in place for their procurement, storage and use. The following pesticides used by the Company fall in either WHO Hazard Class Ia or II: Sarfac (contains cyfluthrin, a WHO Hazard Class Ia substance); Dethrine (contains deltamethrin, a WHO Hazard Class II substance); K-Othrine (contains deltamethrin) and Sarlothrine (contains lambdacyhalothrin, a WHO Hazard Class II substance). In addition CBG also uses Foxine (which contains aluminium phosphide) as an insecticide. Aluminium phosphide is a toxic gaseous fumigant not classified under the WHO classification and the WHO guidance indicates it should be subject to exposure limits set out by national legislation. No information on Guinean exposure limits for aluminium phosphide has been identified, nevertheless CBG will identify and adhere to an appropriate standard to the extent its use is continued.

Community Health and Safety

Community health, safety and certain security issues are being addressed by CBG and, for the Expansion Project, the ESIA includes a health risk assessment addressing impacts from CBG on local communities; a Social Impact Assessment; and a report on the potential impacts on human rights. Health risks have been assessed with emphasis on impacts related to emissions generated by CBG: specifically, changes in noise levels, air quality, and water quality on communities. The standards used for comparison are drawn from the WHO and US EPA. In order to meet the requirements of PS 4, CBG will develop a systematic approach that focuses on construction and operational activities and the alterations in health and safety risk profiles posed by these activities. Specifically, the approach will consider: (i) differential health risks arising from routine/non-routine activities; (ii) consideration of the impacts on vulnerable groups (e.g.: the impact of poor air quality on the elderly and the very young); (iii) health and safety risks as a result of interference with provisioning and regulating ecosystem services (for example, those health and safety risks arising from possible increase in flooding risk caused by project-induced alterations to topography or hydrological regimes); (iv) water-borne, water-based, water-related, and vector-borne diseases, and communicable diseases that could result from project activities, taking into consideration differential exposure to, and higher sensitivity of, vulnerable groups. In the future CBG will consider vector-borne diseases such as onchocerciais, schistosomiasis, ebola, malaria, HIV/AIDS, tuberculosis and lassa fever that all exist in West Africa and (v) consideration of hazardous material management and safety for communities including emergency preparedness and response.



Community Exposure to Disease / Emergency Preparedness and Response

Health and Safety concerns have been raised in community grievances in the past including: (i) a belief amongst community members that CBG is responsible for health effects such as respiratory diseases that they link to the air emissions arising from CBG’s operations; (ii) water contamination (by used oil, fuel) and impacts to local fish; and (iii) railway crossing safety, notably the lack of safe crossing areas. These concerns have been included in a memorandum, addressed to CBG management by local community representatives, requesting that CBG respect the laws regarding health and environment and take into consideration public health issues while conducting its Expansion Project. These concerns have been addressed and closed-out through enhanced stakeholders’ engagement.



CBG has also recognized traffic-related risks for which a Procedure for Traffic Management is in place. This sets out actions to be taken in relation to issues/actions such as: traffic routes; traffic controls and site entrances; delivery curfew; hazardous storage areas; driving and transport rules; temporary road closures; training and authorization; and driving related incidents. This procedure is backed up by two supporting procedures: (i) Procedure for Driver Training and Accreditation; and (ii) Procedure for Vehicle Journey Management.



In addition to these existing controls, the ESMP commits to a wide range of additional measures (some new and others building upon those already in existence) designed to address the concerns of communities and improve community health safety ranging from analyses of community risks to specific measures such as automatic barriers at railway crossings and the illumination of some sections of track.



The ESIA includes a human rights chapter that covers the relevant international human rights standards and establishes the applicable legal framework in which the project operates by documenting the links between the relevant international human rights standards and the national legal provisions. The implementation of this framework in Guinea is limited and CBG has committed to strengthening its protection of human rights as outlined in the national legal framework. Part of this will be to establish a comprehensive framework in which the Expansion Project will operate. However, CBG does have a number of long-established policies in place that serve to protect the rights of affected communities.



Security Personnel

CBG has also committed to undertake a full review of its security arrangements for compliance with PS 4 and for compliance with the Voluntary Principles for Security and Human Rights provisions. This will include consideration of issues relating to the provision of security personnel (whether provided by a company, its contractors or the state). Since 1992, CBG has implemented a security system of two tiers (i) a subcontracted security company providing security guards and (ii) two police (gendarmerie) units (each with six subunits) based at Kamsar and Sangarédi, overseen by a military advisor attached to CBG management. These units work alongside the security division of CBG and in collaboration with the security provider. The main mission of the security guards/police units is to protect workers and their families, to ensure the free movement of workers from their residence to their place of work, and to ensure the security of all CBG installations.



The ESMP will be updated to define measures that CBG will take to ensure that interactions between security provision and local communities are managed to avoid or minimize adverse effects on communities (such as vetting of security providers, and formulation of clear rules of engagement). The grievance mechanism for communities described in the PS 1 section will also cover any complaints related to security personnel.

Type of Habitat

The study areas (mine and port) comprise a mosaic of natural habitats including wooded savanna, bowal, non bowal grassland, gallery forests in the valleys, freshwater, marine and agricultural habitats. Although these habitats have been degraded through harvesting of wood, shifting agriculture and the planting of oil palm, the study area nevertheless supports 15 highly threatened and/or restricted-range terrestrial species including the West African chimpanzee and a further eight (8) threatened or restricted range marine species. The gallery forests support the most numerous species of concern and acts as protection for the local watercourses. There is thought to be a mean of 62 chimpanzees (min 33, max 118) with a confidence interval of 95% on CBG’s concession. Extensive additional surveys are being undertaken to clarify the population density. The chimpanzees use a range of habitats for nesting, foraging, and socializing.



The baseline studies took place from October to December 2013 and included flora, large and medium terrestrial mammals, freshwater fauna, birds, reptiles and amphibians, marine mammals, turtles, crocodiles and a marine fishing study. Socio-ecological studies relating to ecosystem services were also undertaken on firewood, charcoal and bushmeat. IFC as well as the IESC identified the need for additional baseline studies both in scope and duration and in agreement with the lenders, CBG has started undertaking additional studies to refine impacts and to further shape mitigation. This is discussed further in the section on mitigation.



A Critical Habitat Assessment (CHA) has been completed. Two separate terrestrial and marine Discrete Management Units (DMUs) were chosen for the project to account for potential impacts to both distinct environments. The terrestrial DMU covers both the area designated for mine expansion as well as the railway line from the mine to the port at Kamsar. A 20km buffer was placed around the zone in order to account for not only direct impacts, but the broader indirect and cumulative impacts. The total area of the terrestrial DMU was 6,990 km2. The marine DMU was chosen to cover any potential impacts from the port expansion and covers the Rio Nunez estuary and adjacent Ramsar sites, extending both inlands to include the main rivers and backwaters, and approximately 20km outwards to sea. The Ramsar sites were included in the DMU as they lie within 30-40 km of the port development which reflects distances travelled by artisanal fishing boats from communities providing fish to Kamsar.



The presence of 16 terrestrial species triggers Critical Habitat. Five of these species qualify for Tier 1 Critical Habitat and a further 11 species for Tier 2 Critical Habitat; 8 marine species and the presence of highly threatened mangrove ecosystems also qualify the estuary as Critical Habitat.



Threatened species: The Kamsar study area includes valuable mangrove swamps and estuarine habitats and supports a number of IUCN Red List Endangered species. This includes several species of Endangered fish, the dusky grouper Epinephelus guaza, the blackchin guitarfish Rhinobatos cemiculus, the Endangered green turtle Chelonia mydas, the Critically Endangered hawksbill turtle Eretmochelys imbricata, and the Endangered purple marsh crab Afrithelphusa monodosa. The IUCN Red List Vulnerable (possibly soon to be classified as Endangered) Atlantic humpback dolphin Sousa teuszii (up to 47 individuals) routinely use the estuary.



The Sangarédi study area also supports numerous threatened species including several groups of the Endangered chimpanzee Pan troglodytes verus. Also present are three species of Endangered vulture, Necrosyrtes monachus, Gyps africanus and Gyps rueppellii, the Endangered Pinto’s puddle frog Phrynobatrachus pintoi, and a number of other Vulnerable primate species such as the sooty mangabey Cercocebus atys. Two Endangered fish Epiplatys njalaensis and Nimbapanchax jeanpoli along with the Vulnerable Hippopotamus Hippopotamus amphibious are also present in the local rivers.



Endemic and Restricted Range Species: A number of endemic and restricted range species are present in the Sangaredi area including the Cassine River Worm Lizard Cynisca cf oligopholis (or possibly a new species) known from only two widely separated localities, a Critically Endangered gecko Hemidactylus kundaensis, known from a small number of sites including on building walls to forest areas. The Pinto’s puddle frog is known the study area and from three sites found in the neighbouring region of Telimélé. The sites are small forest patches within savanna. All of these species are likely to be endemic to north-western Guinea. Both endangered fish mentioned above also appear to have restricted ranges.



Congregatory Species: The large numbers of waterbirds counted indicate that this site is of international importance for birds. There is a significant population of Sanderling Calidris alba (1% of the geographic population) within the Kamsar Study Area and 4 other bird species whose population numbers are also close to 1%.



Protected or Recognized Areas

There are several areas of international importance in the study area. The Boulléré Key Biodiversity Area (KBA) in Sangarédi is partially within CBG’s concession. The Kamsar KBA is divided into several sites near the railway and near the northern tip of the Kamsar study area. Boulléré was designated due to the presence of significant numbers of chimpanzees and the West African red colobus, although it appears that in absence of protection, the conservation value of this area has deteriorated significantly. The Kamsar KBA was designated as a result of populations of chimpanzees and the presence of the purple marsh crab and again these sites appear to be degraded. Just beyond the southern tip of the Kamsar study area is the Rio Kapatchez Ramsar site and KBA. It is a complex of mangrove forests, intertidal mud/sand flats, freshwater marshes supporting various nesting waterbirds, two species of flamingos, and large numbers of wintering shorebirds.





Protection and Conservation of Biodiversity

Sangaredi: The largest significant direct impacts on habitats includes the loss of over 3,200 ha (excluding the road network) of primarily grassland habitat including bowal. Bowal is a form of grassland on lateritic crusts. It is seasonally inundated grassland and with an interesting assemblage of species, including some restricted to bowal. There will also be a loss of 297 ha of woodland, 244 ha of wooded grassland and 7 ha of dense forest. The vast majority of species of concern are not likely to be significantly impacted as a result of habitat loss as they inhabit the gallery forests and watercourses that are in the valleys (100-300m) from the plateaus. However, there will be direct impacts on chimpanzees as they use a variety of habitats including those that will be lost to mining. Chimpanzees rely on several hundred different plants and ripe fruit, as well as trees for building their nests. Furthermore, fragmentation of the habitat may prevent the migration of females between groups, disturbing reproductive patterns. The concession will be under increasing human pressures linked to the expansion of the operations and other mining projects around the concession. These are likely to result in cumulative negative impacts to chimpanzees.



Other potential impacts on species living in habitats adjacent to the mining footprint include increased noise from blasting, increased dust deposition ranging from minor to moderate over the life of the mine, increased erosion and sedimentation and possible raised aluminium concentrations in water courses. There could also be potential hydrological impacts (not quantified this stage) such as loss of smaller tributaries and springs. These may result in a temporary loss of habitat with avoidance and/or fish mortality, macro-invertebrates and ecosystem services. Other impacts include fragmentation and connectivity impacts and indirect impacts, especially increased hunting and wildlife trade. The loss of preferred feeding habitat is not expected to significantly impact vultures as they are such wide-ranging species, however any loss of nesting sites may be of concern. The Boulléré Key Biodiversity Area (KBA) may be impacted by noise and increased resource use as a result of in-migration.



Kamsar: There will be certain modifications at the quay (enlargement of the quay, new conveyors and dredging of the basin adjacent to the quay). The estuary is currently dredged, and has relatively high suspended sediments, however capital and maintenance dredging are likely to increase suspended sediments and affect marine habitats. Piling could impact marine mammals such as the Atlantic humpback dolphin. The increase in marine traffic could increase the risks of collision between ships and marine mammals. There will also be the potential for increases in accidental releases into the waters of the estuary. Most of these impacts are expected to be localized. There may also be impacts on artisanal fishing. None of the legally protected or internationally recognized areas in the wider area are expected to be impacted by the project.



Railway Corridor: There are no significant impacts on biodiversity or ecosystem services associated with the new passing loops as the area is already heavily degraded.



Cumulative Impacts: The cumulative loss of habitats, associated species and ecosystem services in this bauxite mining region could be significant. Expansion of the bauxite plateau could have significant impacts on bowal habitat, primates, and some restricted range species. Cumulative effects on water quality and resources and air quality could also adversely impact species. IFC will explore the possibility of supporting a landscape level assessment of the area that would help guide investment decisions in a manner that minimizes cumulative biodiversity risks. It will also support work that the Government of Guinea and others are doing in the region.



The Mitigation Hierarchy: CBG has committed to implementing a range of comprehensive measures to meet the PS 6. The outline action plans for the threatened and restricted range species, natural and critical habitats are laid out in the ESIA, the SIP and the Biodiversity Action Framework which sets out the structure and content of the project’s BAP. This will be followed by a detailed BAP that will also include an offset pre-feasibility study.



An intensive primate survey of 142 km of transects is currently being undertaken by the Wild Chimpanzee Foundation (WCF), a more focused survey of chimpanzee nests near the proposed mining areas and a survey of their use of plateau habitats on or near the proposed mining areas are also being undertaken. Additional studies are being carried out to fully understand the distribution of some of the other restricted range and threatened species such as the vultures, the Kunda half-toed gecko, the Cassine river worm lizard, Pinto’s puddle frog, the purple marsh crab and benthic surveys. There is also an expanded physical sampling program to include groundwater, stream discharge and surface water quality sampling, air quality, noise and engineering work to determine the optimum deposition zone for dredging. Together these will assist in quantifying the potential losses and define further opportunities for avoidance and mitigation strategies. These will include plans to protect important springs and riparian areas supporting biodiversity and the development of a forest protection plan and management plan for bushmeat hunting.



In the marine study area, underwater noise modelling is being undertaken to ensure that measures are put in place to minimize impacts, on marine mammals such as the Atlantic Humpback Dolphin. Depending on the results of the underwater noise modeling, appropriate mitigation measures such as the use of trained mammal observers and/or passive acoustic monitoring will be used during construction. A dredge management plan will also be implemented.



Some impacts however, (especially direct habitat loss, fragmentation and noise on chimpanzees) will be difficult to avoid due to the location of the ore body. Restoration will take place, but will take time and will need to balance the needs of local communities and the desire to restore natural habitats. It is therefore possible that there will be significant residual impacts to both natural and critical habitats. To achieve net gains on biodiversity, biodiversity offsets will need to be implemented. An offset pre-feasibility study is being prepared that will look at a number of options. Any offset will aim to adhere to internationally recognized good practice on offsetting. One option being explored includes contributing to the development of a protected area in the Bafing region of Guinea where an estimated 4,000 chimpanzees currently live. It should be noted however, that implementing an offsite offset in this area is complex and will require the collaboration of a range of organizations, communities, NGOs and the Government of Guinea. IFC will explore the possibility of building a coalition of actors and hold a regional workshop, in collaboration with the client. A monitoring framework will be developed as part of the BAP and includes important commitments that monitoring plans will include control mechanisms, threshold values and a mechanism to adapt the approach based on results. CBG will also be hiring a Biodiversity Manager to ensure that there is sufficient capacity within the Company to manage biodiversity risks.



Management of Ecosystem Services

An ecosystem review was undertaken, together with specific socio-ecological studies relating to firewood, charcoal and bushmeat. Twenty-five provisioning and regulating ecosystem services have been identified including those that are important to communities, and those that are useful for the project. The study areas are used for a range of ecosystem services including medicines, drinking water, fishing, grazing, wild foods, wood for construction and energy and cultural services such as sacred sites. Wild foods can be important source of income especially for women, but gathering represents a small proportion of total resources. Of particular importance are freshwater and marine artisanal fishing, wood for energy, herding and provisioning of freshwater. A third of the population is engaged with fishing and in rural areas, more than half the villages obtain water from rivers and ponds. Wood fuels are the most frequently used energy source consumed by households in Sangarédi for cooking. A number of management plans have been identified in the Biodiversity Action Framework including the harvesting management plan, water management plan, fisheries management and induced access management plans to help manage impacts on ecosystem services. An ecosystem service working group will also be set up.



Bushmeat is used for local consumption although this is not thought to represent a significant source of personal consumption. Smaller game, such as hares, mongoose, and francolins, are generally consumed within the household. Larger species such as porcupines, cane rats, duikers and bushbucks can also be sold. Primates are hunted including species of conservation concern, namely black and white colobus Colobus polykomos and the Guinea baboon Papio papio. Given Sangarédi''s excellent transport link to Boké and onwards to Conakry, the town is an also important regional hub for the national smoked bushmeat trade.



Sustainable Management of Living Natural Resources

If the BAP is implemented thoroughly and effectively, it will address the key biodiversity and ecosystem service risks of the project. However, offsetting is still in its relative infancy and the success of any CBG offset will require the successful collaboration of the Company, Government of Guinea, NGO’s and communities to meet the PS 6 requirement. In addition, ensuring that certain areas of the concession are maintained for biodiversity requires CBG to skillfully manage its relationships with host communities.

Protection of Cultural Heritage in Project Design and Execution

Certain gaps have been identified in respect to PS 8 by the IESC. CBG has demonstrated that the understanding and commitment exists within the Company to close these gaps. In particular, there is a key undertaking on the part of CBG to develop and publish a Cultural Heritage Management Plan (CHMP), including a Chance Finds Procedure, prior to further exploration and development activity. Development of the skills and capacity to both prepare the CHMP and to ensure its implementation across the on-going operations will have to be carefully monitored.



The ESIA report captures in large part the landscape of cultural heritage practices and resources in the concession areas. The ESIA recommends that the baseline studies conducted to date should be considered as a first step in the evaluation of local cultural practices linked with the sites, a recommendation with which the IESC concurs. The important next step is to ensure that these are fully developed and implemented as part of the CHMP.



The mitigation measures proposed have been accepted in full by the CBG as part of its commitment to developing and implementing a CHMP as set out in the ESMP. Access to cultural sites has been and is being taken into account by CBG during mine planning and operations, most notably through the existing and planned stakeholder engagement and resettlement planning procedures and practices. Furthermore CBG will periodically update the CHMP as operations progress.

Stakeholder Mapping / Analysis
In 2013 CBG prepared a Stakeholder Engagement Plan that applied to a wide range of local stakeholders and set out broad principles for engagement. However, subsequently a revised document, the Stakeholder Engagement Management Plan was produced which focused on the project implementation phase. The initial Plan was approved early in the ESIA process and the appraisal provided evidence that stakeholder engagement had been an ongoing process up to December 2014. Consultations occurred during scoping (with preparation of a Scoping Report), baseline study preparation and, then during the assessment of impacts. Post ESIA finalization, the agency responsible for approving the ESIA, the BGÉÉE conducted a series of feedback meetings on the ESIA and ESMP to selected communities in/near the mine area, in the factory/port area and along the railway. The two plans have now been linked and are known as the Stakeholder Engagement Management Plan (SEP).

Stakeholder Engagement Plan
The Plan shows that an appropriate range of affected community stakeholders were identified. During the RAP development phase, CBG will establish the socioeconomic baseline of affected communities. Baseline data collection will also permit the identification of any vulnerable households, who due to a variety of socioeconomic factors, are less able to improve or re-establish their livelihoods subsequent to the implementation of the resettlement or livelihoods restoration plan. CBG will use the following definitions of vulnerability: 1) female and child-led households; 2) households that do not own their place of dwelling; 3) landless households or those with limited land-access; 4) households where average income (monetary and non-monetary) is below the World Bank defined poverty line of US $ 1.25 per day. Vulnerable people will be a particular focus of CBG’s resettlement and restoration plan in order to ensure that, subsequent to RAP implementation, these individuals and households are able to improve or at a minimum maintain their level of wellbeing. The ESIA describes a number of public community meetings, but in the future CBG will also document the rationale behind the selection of the locations for the meetings as well as the type of invitees or attendees in terms of ensuring that these stakeholders are representative of their communities. There are two groups for which the potential impacts of the Expansion Project need to be fully established, these are the pastoral herders and fishermen. For these groups CBG will amend the CBG HSEC “Stakeholder Identification and Analysis Register”. It will be important that there is continuing consistency in terms of stakeholder identification and characteristics between the SEP and RAPs.

Information Disclosure and Consultation
CBG will follow a process of Informed Consultation and Participation (ICP) with affected communities subjected to potentially significant adverse impacts. The Resettlement and Livelihoods Restoration Policy Framework (RLRPF), prepared as a precursor to the first and subsequent RAPs (the first RAP is for villages of Fassaly Foutabhe and Hamdallaye) includes ICP as part of RAP/LRP preparation.

External Communications and Grievance Mechanisms
During preparation of the ESIA local stakeholders considered that the then current mechanism(s) for dealing with grievances required strengthening. The mechanism was subsequently updated in September 2015 to be compliant with PS 1 and PS 5 with its scope including communities, contractors and sub-contractors, companies and other stakeholders either living or working/operating within CBG’s area of influence. The key responsibility for managing the Grievance Mechanism rests with the Coordinator for Resettlement, Compensation and Grievance Management.

The Grievance Mechanism objectives are clearly stated and include the key principles and characteristics to align with PS 1 and GIIP. IFC and the IESC requested that CBG provide a status account relating to number of ‘open’ community grievances and progress being made to close them. Subsequently, CBG has reported in the SIP that since April 2014, the newly-formed department of Community Relations has been involved in ESIA- and RAP-related consultations and, as a result, in addition to grievances listed in the SIP, a number of unresolved community complaints (31) also came to light. All these complaints were registered at the time of reporting, 24 of the 31 complaints have been processed and closed. Work is continuing to close the remaining complaints in the near future. During the first IESC monitoring visit a review of grievance records (related to past compensation) will be undertaken to confirm the status of any open grievances with sample interviews with complainants to determine whether the resolutions are to their satisfaction. The IESC Monitoring Report will provide a clear statement of the status of all types of compensation related grievances.

For CBG to be in full compliance with PS 1 requirements, the Company has committed to the following amendments to its Grievance Mechanism process (i) provision of a clear statement that raising a grievance will involve no costs to a complainant and that there will be no retribution directed at any complainant; and (ii) provision of additional information on the range of ways in which a grievance can be submitted. It seems that contact (mostly verbal) with community liaison personnel is the method most likely to be initiated and, therefore, used. Other options should be provided such as boxes that could be located in selected communities in easily accessible sites or submission of grievances by email/text and methods by which communities and other stakeholders will be informed about the Grievance Mechanism, and how it will operate, should be clarified.

Ongoing Reporting to Affected Communities
The SEP ensures a systematic account of stakeholder identification and mapping and is supported by several other documents such as (i) Procedure for Stakeholder Identification, Analysis and Mapping; (ii) Grievance Mechanism Procedure and (iii) a template for recording the minutes of meetings. In September 2015 CBG approved new procedures for stakeholder identification analysis and mapping. Additional details, acceptable to IFC, have been provided on the range of stakeholders and the schedule for engagement activities. CBG will also shortly disclose the mechanisms for implementing the activities. The SEP is supported by a Stakeholder Identification and Analysis Register; and a Stakeholder Mapping Tool. The new procedures are included in the SIP which has been disclosed by CBG.

This procedure (and the register and mapping tool) will be used to support SEP implementation and periodic updating of the SEP, performance of which will be monitored/evaluated using a set of indicators to be developed by the HSEC Director.

CBG will make copies of relevant documents including as appropriate the ESRS and the attached ESAP available in the following locations in Kamsar and Sangardi near the project site for a period of at least 60 days. Key documents will also be available at the following link http://www.cbg-guinee.com

Address of location 1
Centre Culturel de Sangarédi

Address of location 2
Mairie de la Commune Rurale de Kamsar

For further information, questions or comments please contact:

Ms. Carine Gracia
Community Relations Manager
Email: mailto:carine.gracia@cbg-guinee.com
Tel: +224 623 233 175

Broad Community Support is not applicable for this project.

CBG Expansion(34203) Appraisal Disclosure Snapshot – Version 4
Description	Anticipated Completion Date
1. Develop a route map outlining major milestones (based upon actions, timeframes and interim deliverables), to bring operations up to a level consistent with IFC Performance Standards (ii). This route map will be informed by a ‘stand-alone’ gap analysis with respect to current systems and any additional items required for IFC compliance, and, also, recommendations arising from work done to implement the other ESAP actions (i). Align HSEC MS for existing operations with HSEC MS for the Expansion Project and bring current operations up to a level consistent with the intent of the IFC Performance Standards.(iii)	31-Jan-2024
2. Update and amend the structure of the Annual Monitoring Report template, taking into account Lender/IESC comments, in a form and substance satisfactory to Lenders	18-Nov-2020
3. Finalize and then disseminate the updated Human Resources (HR) Manual and Workers’ Grievance Mechanism to both direct employees and contractors	30-Nov-2020
4. Finalize and then disseminate the Code of Ethics and Business Conduct to both direct employees and contractors	18-Dec-2020
5. Extend and amend the Action Plan for Stakeholder Engagement 2019-2020 through to 31 December 2021 with contents changed, as appropriate, to ensure alignment with the MUOA-amended Stakeholder Engagement Plan (i). Disclose MUOA-amended Stakeholder Engagement Plan and amended Action Plan (ii). Revise and update the Stakeholder Engagement Plan (5G-HSEC-ESMP-PLN-SEP-001) to reflect current/future needs and lessons learnt since 2016. The revised and updated Stakeholder Engagement Plan should focus on the period 2022 to 2025 and on improving alignment to IFC standards (for example, the stakeholder analysis/mapping section). The SEP to include a communication program to report back to communities about the results of water and air monitoring (iii). SEP (inclusive of all SEP Action Plans) to be disclosed publicly by CBG in a form agreed between the Policy Lenders and CBG (iv).	30-Sep-2021
6. Employ a dedicated full-time Environment Manager. CV to be provided to Lenders for approval on a ‘no objection basis’ before confirmation of appointment followed by evidence of hiring.	30-Nov-2020
7. Prepare and implement a Time-bound Recruitment Plan (initially through to mid 2021 (Version 1) and subsequently up to 31 December 2023 (Version 2)) for the Community Relations and Resettlement sections to increase capacity for social risk management and to strengthen management of the grievance mechanism (i). The Version 1 Plan will include job specifications/SoW for each position in these sections. The Plan will specify urgent hires, including expertise in the following: grievance mechanism implementation, resettlement, stakeholder engagement, livelihood restoration, and data management. Evidence of recruitment to positions to be provided to Lenders (ii). The Version 1 Plan will present commitments to establish framework contract(s) with consultants for regular support in resettlement/livelihood restoration and data management. Scopes of Work for framework contracts to be submitted to Lenders (iii) to be followed by notification of signed contracts (iv). The plan will be updated in mid 2021 (Version 2) to cover the period through to end December 2023 (v).	30-Jun-2021
8. Prepare and implement a Time-bound Capacity Development and Resource Acquisition Plan Version 1 to mid 2021 (i) and Version 2 (ii) for the Community Relations and Resettlement sections, including resourcing for social risk management teams, purchase of equipment/resources (such as vehicles, GPS handsets, and data management software) and in situ/external training of staff members in use of acquired resources.	30-Jun-2021
9. Prepare and implement a HSECQ training programme including training on social matters, such as, as a minimum, topics as communication tools, resettlement practices, stakeholder engagement, data management), and management of grievance mechanisms. The training will be aligned with IFC good practice and provided by a specialist external entity.	31-Jul-2021
10. Complete establishment of a data management system to gather, record and track social-related aspects such as land take, socio-economic information, compensation payments, grievances, stakeholder engagement, compensation agreements, asset inventory. The system must allow analysis of trends and root causes with regards to social issues and grievances over time.	29-Jan-2021
11. Prepare a Memorandum providing clarification on the status of the ‘GAC siding’, the environmental and social sensitivities, and impacts and mitigation measures implemented to date/to be implemented by CBG. Any additional mitigation measures shall be incorporated within appropriate E&S management plans (save for those mitigation measures which fall under GAC’s responsibility).	18-Dec-2020
12.a. Update the E&S management plans to include MUOA amendments Update the Noise and Vibration Management Plan (D390-ENV-PLN-006) to reflect noise and vibration assessments reports to be undertaken which determine the incremental impacts from the MUOA Project and define mitigation measures.	15-Apr-2021
12.b. Update the E&S management plans to include MUOA amendments Water Management Plan (D390-ENV-PLN-001)	31-Jan-2021
12.c. Update the E&S management plans to include MUOA amendments Environmental Monitoring Programme (0390-MOT-PLN-003)	18-Dec-2020
12.d. Update the E&S management plans to include MUOA amendments Local Content Plan (D390-SOC-PLN-003)	31-Jan-2021
12.2. Update the E&S management plans to include MUOA amendments Cultural Heritage Management Plan (D390-SOC-PLN-004) Note: no amendments required to the accompanying Chance Finds Procedure (D390-SOC-SOP-002	30-Nov-2020
12.f. Update the E&S management plans to include MUOA amendments Community Development Plan (D390-SOC-PLN-001). Review by external third-party consultant of this Plan. The review will focus on ensuring that CBG’s community investment strategy is aligned with IFC best practice. SoW for the review to be submitted to Lenders/IESC (ii) and consultant to be approved by Lenders on a ‘no objection’ basis (iii). The Plan will be revised as necessary, following the review (iv). The Community Development Plan will be disclosed publicly by CBG in a form agreed between the Policy Lenders and CBG (v). The Plan will include tailored information-sharing approaches and methodologies for disseminating the Plan to targeted communities.	15-Sep-2021
12.g. Update the E&S management plans to include MUOA amendments Influx Management Plan (D390-SOC-PLN-002)	31-Jan-2021
12.h. Update the E&S management plans to include MUOA amendments Community Health and Safety Management Plan (D390-SEC-PLN-004)	28-Feb-2021
12.h. Update the E&S management plans to include MUOA amendments Road and Rail Safety Management Plan (D390-SEC-PLN-003-Rev01)	31-Mar-2021
12.j. Update the E&S management plans to include MUOA amendments Emergency Response Plan (D0390-SEC-PLN-002, EN, V00)	31-Mar-2021
13.i) Prepare an interim Air Quality Management Plan (AQMP) in accordance with the Scope of Work (Ref. AIR QUALITY Scope of Work ver 3). The Interim AQMP will be informed by the 2019 emissions data for Dryers 1-3 (and other sources) and dispersion modelling. The Interim AQMP will also propose stack emission limits and measures necessary to meet proposed limits and will include information on the necessary financial budgets to achieve the requirements within. Proposed emission limits will be agreed with Policy Lenders and the IESC. ii) Update the interim AQMP to include consideration of Dryer 4 emissions and additional sampling data collected for Dryers 1-3/other sources as applicable and in accordance with the Scope of Work to produce a Final AQMP.	29-Jan-2021
14. Prepare i) Worker Demobilization Plans and ii) subsequent Demobilization Close-out Reports, for future demobilization events, focusing on issues such as planning and monitoring procedures used to manage demobilization with emphasis on the process(es) used to notify workers of key demobilization dates, make and record final payments to workers and to manage grievances received and the procedures leading to grievances being closed out. iii) Demobilization requirements should be communicated to contractors via the CBG Contractor Management Plan which should be updated accordingly.	29-Jan-2021
15. Repair/upgrade the oil water separator located at the tank farm to achieve compliance with the applicable project standards. Design to be agreed with IESC.	30-Jun-2021
16. Develop a Scope of Work for an external consultancy (i) and a Request for Proposals issued. Commission a study and report (ii), to be conducted by a suitably qualified consultant, on the impacts on mobility and road traffic flows (in urban areas) due to increased train movement frequency, including livelihood impacts resulting from alterations to mobility/traffic flows. The study report to include recommended measures to mitigate adverse impacts (iii). Based on the results of the study, CBG shall seek to agree with the Policy Lenders on mitigation measures to be implemented by CBG (iv). CBG to seek the approval of the MUOA User’s Committee in accordance with Section 22 of the MUOA to address mitigation measures that need to be implemented (as agreed pursuant to (iv) above), including the roles and responsibilities of each of the parties with respect to such implementation (v).	30-Oct-2021
17. Finalize the Past Compensation Report (2010-2015), with recommendations to improve livelihoods of PAPs, which integrates comments provided by the IESC and Policy Lenders. The recommendations will form the basis of an Action Plan to be implemented. This Plan will be included in the final Report (i). The Past Compensation Report, including the Action Plan, will be disclosed publicly by CBG in a form agreed between the Policy Lenders and CBG (ii).	22-Jan-2021
18. Finalize CRPF taking into account Lenders/IESC comments. Approved CRPF to be disclosed publicly in a form to be agreed between CBG and the Policy Lenders.	10-Feb-2021
19. Finalize Kankalaré Resettlement Action Plan (including a Livelihood Restoration Plan). CBG to send a Notification (accompanied with an updated fieldwork schedule), to Lenders, as soon as COVID-19 restrictions are lifted in a manner that allows the required fieldwork to be implemented.	26-Feb-2021
20. Provide reports (interim and final) with photographic evidence of the finalization of infrastructure provision/improvement measures in relation to the Kankalaré PAPs’ host communities. The measures are: road to Parawi village, Telebofi footbridge over the railway; fencing along railway for the stretch where the railway passes beside Telebofi village; and iron-removal devices for wells.	30-Mar-2021
21. CBG to support the commissioning and execution of a third party independent review of all land acquisition processes initiated from 01/01/2016 through to effective date of the CRPF (as per ESAP item 18) and adequacy of related documentation (i). A Scope of Work to be prepared and approved by Lenders. For Hamdallaye and Fassaly Foutabhé this review to include an audit of the entire inventory and compensation payment process (timings, adequacy of inventories, recording of assets, any relocation delay implications for asset valuations, and phased payments of compensation). This independent review will result in a Report focusing on compliance of land acquisition processes against the requirements of the 2016 RPF and PS 5. The Report will identify non-compliances and include a time-bound corrective action plan with budget to cover implementation. CBG to complete implementation of the corrective action plan (ii).	31-Jan-2021
22. Prepare and implement a COVID-19 Plan for H2, 2020, with the key aim of ensuring that CECI resumes/increases activities, in agreement with the communities, as soon as possible while respecting governmental restrictions.	16-Nov-2020
23.i) Prepare and implement a time-bound Action Plan for housing and infrastructure repairs and other additional works related to the Hamdallaye resettlement site. ii) Environmental Monitoring Programme to be amended to include sampling and analysis of Hamdallaye water supply. Analysis of data, and any corrective actions needed. (iii) PAP satisfaction survey to be undertaken upon completion of repairs and works specified in the Plan and results provided to the IESC within ten (10) days from compiling the survey results analysis.	18-Dec-2020
24. Prepare (i) and implement a time-bound Action Plan, with biodiversity inputs, to implement the soil rehabilitation programme as per CBG’s report (RAP Hamdallaye & Fassaly Foutabhé: Project Status Report, 12 February 2020) including setting up a pilot field to build the capacity of the population on soil fertility management and finalizing the individual allocation of land (ii) to the respective affected people as per the RAP. The Action Plan, also, to include specific rehabilitation measures for: - the replacement crop-growing land (56 ha); - all land to be used for land-based livelihood restoration activities; and - land for household gardens and fruit/shade trees. iii) PAP satisfaction survey to be undertaken upon completion of measures specified in the Action Plan and results provided to the IESC within ten (10) days from compiling the survey results analysis.	29-Jan-2021
25A. (i) Prepare and submit scopes of work with respect to the Livelihood Restoration Plan (LRP) in 25A(ii) and 25B(ii) below. (ii) Provide confirmation that a Livelihood Restoration Plan (LRP) is being or will be prepared for PAPs and submitted prior to people being displaced in N’dangara, Kagneka and Parawi by proposed mining activities and haul roads. CBG agrees that no additional land take causing displacement in N’dangara, Kagneka and Parawi will occur until the LRP has been approved by Lenders. (iii) Draft LRP to be submitted for Lender/IESC review.	30-Jun-2021
25B. (i) Prepare and submit an LRP with respect to PAPs already impacted by displacement in Thiapikouré. This LRP will need to include a section assessing the impacts of the delayed implementation of livelihood restoration on the PAPs and the support offered by CBG to PAPs for the transitional period. (ii) Prepare and submit an LRP for review and approval by the Lenders with respect to PAPs affected by land disturbance through the streamlined process (Bouroré 1a, 1b & Parawi 2a). This LRP will need to include a section assessing the impacts of the delayed implementation of livelihood restoration on the PAPs and the support offered by CBG to PAPs for the transitional period. (iii) As an interim measure, prepare and submit an impact assessment of the economic displacement, for Bouroré 1a, 1b & Parawi 2a, and identification of those PAPs that are most vulnerable and for which transitional support will be provided. (iv) Formal written commitment by CBG not to disturb land before any LRP is in place.	30-Apr-2021
26. Develop a Biodiversity Action Plan (an update of Biodiversity Management System), including a Biodiversity Monitoring and Evaluation Plan, in alignment with revised Guidance Note 6 (to Performance Standard 6) including development of standard biodiversity metrics for no net loss (NNL)/net gain (NG) of biodiversity; update of estimates of significant residual effects and associated offset targets to considered following completion of the BMS review; presentation of interim targets for NNL/NG; and prioritization of on-site set aside. The BAP will be disclosed publicly, within 2 weeks of its completion, by CBG, in a form agreed between the Policy Lenders and CBG.	30-Jun-2021
27. Prepare a 5-year progressive rehabilitation plan, including resourcing of the biodiversity department, for full land restoration (budget and equipment) and staffing required.	28-Feb-2021
28. Develop a landscape-level plan for the concession, building on the existing Plateau by Plateau (PbP) approach, that integrates community development and biodiversity objectives. The intent is to provide strategic guidance to location and focus of rehabilitation, community development, and on-site conservation activities. This plan will require collaboration with affected stakeholders including local governments, representatives of communities/civil society organisations and neighbouring mining companies.	31-Dec-2021
29. CBG to arrange, at the request of any Policy Lender, a call with all of the Halco board members, to be held no more frequently than once per calendar quarter, to discuss the progress of E&S matters, including environmental and social governance matters, relating to the Project. All Lenders and the IESC will be invited to the call. The requesting Policy Lender shall provide a proposed agenda at the time of requesting the call. Calls will be quarterly as requested, to commence at the end of the first calendar quarter following the Effective Date.	30-Nov-2020