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

This is a Category A project because it is a project with significant risks and impacts on the environment and the way of life of the local communities. Key issues that the Company will be required to manage during the various phases of the project include resettlement and livelihood restoration, surface and ground water resources, dust and other emissions, biodiversity, use of hazardous materials (cyanide), naturally occurring arsenic, non-hazardous and hazardous waste management, security, labor, community health and safety, potential population influx, strategic community development and stakeholder engagement.

In addition for any future activities that significantly alter the scope or footprint of the project, Aureus will conduct additional Environmental and Social Impact Assessments (ESIAs) in compliance with the laws of the country of operation and in accordance with the IFC Performance Standards. Examples of such additional ESIAs would be for any expansion of the mine license area or development of exploration.

IFC’s due diligence indicates that the investment will have impacts which must be managed in a manner consistent with all Performance Standards with the exception of Performance Standard 7 (Indigenous Peoples). Based on the analysis of reviewed documentation as part of the ESIA for the project and supporting social baseline and impacts studies, indigenous peoples are not present in the area of the project.

Aureus is committed to meeting the requirements of IFC’s Performance Standards as demonstrated through the ESIA and environmental and social management plans. In addition, Aureus will implement the attached ESAP as part of this investment. Aureus has also committed that any of its future projects will also be developed in accordance with IFC Performance Standards.

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.

Policy



Aureus has developed a number of key policies including Environmental, Health & Safety and Community Policies, which specifically incorporate and commit to meeting the requirements of the IFC Performance Standards. These policies are the basis for the project-specific Environmental, Social and Health and Safety (ESHS) Management Plans and Standard Operating Procedures (SOPs) which are being implemented through an Environmental, Social, Health and Safety Management System (ESHSMS) which is aligned with ISO14001 and OHSAS 18001 standards.



The Company has committed to also become a signatory of and follow the principles of the International Cyanide Management Code (ICMC). Aureus will work with Afritech to undertake a pre-construction certification audit and subsequently work towards certification by December 31, 2016.



Identification of Risks and Impacts



An Environmental Impact Study (EIS) for the New Liberty Project was developed by Golder Associates in 2012. Following an optimization study and an update to the Project’s Feasibility Study, in 2013 the Company hired Digby Wells Environmental (South African consultants) to update the EIS into a full ESIA. This incorporated significant changes in the mine layout, including the location of the tailings storage facility (TSF), the waste rock dump and the mine accommodation camp. IFC has worked with the Company and its consultants to strengthen the 2013 ESIA in order to meet IFC Performance Standards which has resulted in an ESIA Addendum being prepared.



The 2013 ESIA assessed the construction, operation and eventual closure and rehabilitation phases of the Project.



Key considerations for the construction phase were the assessment of: (i) resettlement of local communities (Kinjor and Larjor); (ii) potential contamination of surface and ground water resources, (iii) the clearance of vegetation and potential fragmentation of habitat; (iv) soil erosion and maintaining of water quality; (v) increased ambient dust, vehicle and generator emissions; (vi) a 3.7 km diversion of the Marvoe Creek; (vii) increase in traffic along the Daniels Town Public Road and safety concerns; (viii) government-led resettlement of some local residents from within the Right of Way (RoW) of the Daniels Town Public Road; and (ix) social and economic development benefits, which include local employment at the mine, improved living conditions for the affected villages, increased markets for local entrepreneurs, improved access to services as well as community development opportunities.



Additional considerations for the operations phase were assessment of: (i) management of naturally occurring arsenic in the tailings stream; (ii) management of cyanide in accordance with the ICMC; and (iii) community development.



As part of Aureus commitment to adhere to ICMC principles, independent consultants have carried out detailed studies relating to the fate and transport of cyanide. Additional studies also as
sessed management of the naturally occurring arsenic in the area. These have led to the development of specific Arsenic and Cyanide Management Plans. Finally, the Addendum has been updated to make sure the Environmental and Social Management Plan section meets Good International Industry Practice (GIIP) by demonstrating how the mine will be operated in accordance with the IFC Performance Standards, as discussed below. Similarly, on the social side, after detailed discussions between IFC, the Company and Digby Wells, and ongoing consultations with the affected communities, the Company provided an updated Resettlement Action Plan (RAP), CDP and SEP as well as an update on the implementation of the resettlement project.



Diversion of Marvoe Creek



The design of the project includes a 3.7 km diversion the Marvoe Creek. The diversion channel will divert the flow of the Marvoe Creek from an area upstream of the proposed mining activities; follow a natural valley around the northern side of the open pit until it re-joins its original natural alignment to the south of the open pit and other mining infrastructure. The diversion channel has been deepened to accommodate peak flow. The design uses a cascade system with small holding dams to minimize erosion. The diversion is expected to have minimal environmental and social impacts and does not affect water flow. Aureus commit to maintaining the current downstream flow of the Marvoe Creek. Water quality and quantity will be monitored to ensure the stream remains suitable for use by the downstream communities.



No changes in water flow are expected during construction of the diversion channel. In order to prevent fluctuations of water level during the construction and filling of the diversion creek, the Company installed a bypass pipe in each dam which will continuously allow water to pass through the wall until such a time as the water has built up sufficiently high in order to flow over the spillway and into the diversion channel. Water users along the Marvoe Creek (closest community is Jikando, which is 4 km away) will not be affected by the diversion. The community currently uses a well as an alternative source of water as the quality of the water in the Marvoe Creek is already impacted by artisanal mining operations. The river diversion should actually improve the conditions for the downstream users as artisanal mining will cease in the current open pit area. The diversion area has never been mined or disturbed by artisanal miners and the water quality should thus improve. The Company is committed to ensure that alternative sources of water are supplied to communities downstream in case of any impacts from the diversion.



Management Programs



The Company’s ESHSMS framework is intended to be dynamic in nature and is based on the plan-do-check-act cycle of continuous improvement which reflects the key elements of ISO 14001 and OHSAS 18001.



The systems are designed to transition from const
ruction to operations and include; the identification of legal requirements; ESHS risk assessment and risk management planning; occupational health and safety hazard identification; a process to establish ESHS objectives and targets; operational control (evolving ESHS management plans and SOPs); organizational capacity; emergency preparedness and response; monitoring and reporting; stakeholder engagement and external communications. The Company is committed to develop these in full compliance with IFC Performance Standards (See ESAP Action 1).



Specific Environmental Management Plans developed by the Company include: Solid and Liquid Waste Management Plan; Hazardous Materials Management Plan; Erosion Control and Re-vegetation Management Plan, Footprint Management Plan, Biodiversity Management Plan; Non-compliance/Corrective Action Procedure; ESHS Training Plan; Pollution Prevention Plan (air, dust, noise, spills, etc); Water Management Plan; Environmental Compliance Monitoring Plan; Contingency/Emergency Response Plan and a Transportation Management Plan. Specific Social Management Plans include a Security Management Plan; Labor Management Plan; Resettlement Action Plan; Community Development Plan and a Stakeholder Engagement Plan / Grievance Procedure. The plans are designed to be periodically reviewed and updated in response to the changes that will occur in various phases of the project life cycle.



In addition, the project’s EPCM contractor (DRA) has a corporate ESHS Management System which includes management plans and SOPs to address risks and impacts from its current construction activities and which it implements at all its operations.



The Company will ensure alignment between its ESHS Management Plans (approved by IFC) and those of DRA by monitoring internalization of the requirements within DRA’s day to day construction activities (See ESAP Action 2).



Organizational Capacity



The project is run by a General Manager supported by Technical Services Manager and Country Manager.



A locally based Environmental, Health and Safety (EHS) Manager reports to the Technical Services Manager. There is also an Environmental Supervisor, an Environmental Officer, a Safety Officer and the site medical contractor who report to the EHS Manager.



The Exploration Manager and the Resource Manager also report to Technical Services. The Country Manager oversees the work of the Human Resources Manager, the Finance Manager and the Community Relations Manager. The General Manager and the Country Manger report to the Company’s Chief Executive Officer (CEO).



On the community relations side, the Company has a Community and Media Relations Officer who reports to the Community Relations Manager, who, in turn, reports to the Country Manager.



The Company’s senior management values the relationship with IFC in assisting the Company to carry out its mine development in line with IFC’s PSs and GIIP.



As part of IFC’s involvement, the Compan
y has agreed to strengthen its ESHS capacity and to engage a full time on-site EHS consultant, with international experience in the application of IFC’s Performance Standards and GIIP in the mining sector to train and build the capacity of Aureus team (See Action 3 of ESAP). Also, as part of IFC’s and lenders’ requirements, the Company will engage an Independent Environmental and Social Consultant (IESC) to carry out regular ESHS audits of the project and of the development and implementation of the ESHS MS (See Action 4 of ESAP).



Community Development



Aureus undertook an extensive process of stakeholder engagement program as part of preparation of the project ESIA in determination of potential community development activities. These involved communication with local communities, state authorities, and other stakeholders. For a detailed description, please refer to the PS5 and Stakeholder Engagement sections of this ESRS as well as the CDP and SEP which are disclosed alongside the ESRS on the Aureus website. The main impact of the project is the resettlement of two local villages and economic displacement of a number of small-scale artisanal miners of gold (ASM). These impacts were evaluated in close consultations with the affected communities and mitigation measures developed and agreed with the affected stakeholders. A strategy for socio-economic development of the affected communities was devised and formalized in the CDP in a participatory manner.

Aureus currently employs about 200 people, with development of the New Liberty mine this will increase to approximately 600 people, of whom 65% will be Liberians during the construction phase. Approximately 300 people will be employed during mining operations with approximately 80% of these being Liberian nationals, which will comprise skilled, semi-skilled and unskilled personnel. For semi-skilled and unskilled personnel, Aureus is aiming to train and recruit predominantly from the nearby communities and encourage its contractors and subcontractors to do so. Expatriate workers will only fill employment positions that cannot be filled locally. With sufficient training during the construction phase, it is expected that a proportion of the local workforce can transfer to operations. Employment decisions for unskilled and short-term support are undertaken in consultations with the local communities to ensure equity in labor participation for the local community members and quality of labor. Training priorities will be identified and monitored throughout the life of the mine.



Aureus policies and procedures governing labor and working conditions are in line with the requirements of IFC Performance Standard 2. Aureus has developed a Human Resources policy, which is included in each employee’s induction pack and is available upon request. The terms of employment are also detailed in each employee’s employment contract.



Aureus has developed an Employee Handbook describing recruitment, terms of employment, compensation and benefits provisions, employee relations, performance management and training, as well as employee’s responsibilities in performing their duties. A number of Policies and Procedures were also developed including Safe Working Environment, Employees Grievances, Disciplinary Procedure, Code of Business Conduct, Whistle Blower Policy and Procedure, and Anti-Bribery Policy and Procedure.



During construction, the requirement for maximizing local employment will be written into the contractors’ contracts. During operation, Aureus will implement strategies to develop its workforce such that employees are trained and skilled to the mutual benefit of the project and its employees.



Occupational Health and Safety



The EPCM Contractor has developed a number of Standard Operating Procedures (SOPs) related to worker occupational health and safety. Since the start of construction, DRA has carried out in excess of 12,000 hours of training and which has included 1,490 employees. Among the training received, has been training in firefighting, first aid, working at heights, safety and refreshers plus environmental monitoring.



Specific protocols and procedures are established for camp life, including a prohibition on drugs or alcohol for staff on duty, no unauthorized possession or removal of camp or Company property, no sexual harassment or unlawful harassment, and no use of Company equipment at any time without proper approval. All
employees have been issued with the correct Personal Protective Equipment (PPE). First Aid is available at the camp and a qualified doctor and paramedic medic are present at any time. The Company has a malarial protocol for all employees and visitors.



The Company’s exploration camp is currently hosting its own employees as well as employees of DRA and sub-contractors. The camp, being within the footprint of the future mine, will be demolished and the Company is currently constructing a mining camp with improved accommodation conditions which will host its operational staff, in line with international good practice.



DRA will be required to meet the requirements of PS2 and it will be the responsibility of Aureus to ensure that this occurs, by including the requirements in contracts as well as through regular monitoring and enforcement of Company protocols and procedures. Contractors’ employees will be trained on the use of the Company’s Employee Grievance Mechanism and the Company will use a regular monitoring of contractors’ OHS performance.

Ambient Conditions



The New Liberty Mine site is located approximately 40 km from the coast, in an area of gently undulating topography. The area is classified as comprising a mosaic of primary and secondary forest, with large areas of swamp vegetation. All the forest areas around New Liberty have been subjected to some encroachment. Elevation at the site ranges from 50 meters above sea level in the south, gradually rising via rolling topography to 80 meters above sea level in the north. The project area has a tropical climate with wet and dry seasons with an annual average rainfall of approximately 3,500 mm per year.



Key issues to address during the various phases of the project include surface and ground water management, pollution prevention (air and water), cyanide and arsenic management (see water resources section below), non-hazardous and hazardous waste management, potential impacts on biodiversity in the areas of influence (see PS6), and occupational health and safety.









Air Quality



Dust is considered a potential impact from project activities, especially related to traffic along the route of the mine. It is expected that fugitive dust will be generated mostly during the dry season although the heavy rainfall (~3.5 meters per year) and short dry season in the area of New Liberty will reduce this risk. During dry periods, the Company has included several mitigation measures within its environmental management plan including the use water trucks to limit the generation of dust, established speed limits and the need for adequate maintenance of the roads. Also, surface treatment materials (such as polymers) could be used if required. Monitoring of the impacts of dust in the community is already taking place and the information from this monitoring program will guide any subsequent dust management measures if they are found not to be working satisfactorily.



The New Liberty mine will operate diesel generators with a capacity of 9 MW (with an average operational demand of 5.5 MW). Gaseous emissions (eg: NOx) are being monitored using Radiello Passive/diffusive samplers and will be compared to baseline conditions to enable any impacts on sensitive receptors to be mitigated. The nearest receptors are Camp David which is 1.5 km away from the plant site and the next nearest around 2.5 km away, with a large area of thick forest between this.



Impact is estimated to be limited to the plant and power generation plant area and can be readily mitigated with regular generator maintenance and tuning of the combustion equipment and reduction of engine idling/start-up times. Any worker exposure to emissions will be monitored as part of normal OH&S procedures.





Monitoring of dust is currently being carried out at six sensitive receptor locations which is providing monthly, seasonal, and inter-annual data. A site meteorological station has also been recently installed to generate site specific data (wind speed, wind di
rection, rainfall, temperature, relative humidity, and pressure) to assist in the future assessment of pollutant suspension and subsequent transport from the source. The monitoring program will assist the company in assessing any potential impacts on these receptors and to put in place the necessary mitigation measures to address any impacts.





Water Resources



The Company has developed a comprehensive Water Management Plan for the New Liberty Project to consolidate and compile the data obtained to date including baseline information, water balances and climatic information and to develop a robust monitoring program to assess water quality and quantity for the project. This Plan includes specific requirements for monitoring and reporting of surface and ground water, on a quarterly basis, to assess potential changes in water quality and quantity during the life of the mine.



Although the ore body contains naturally occurring arsenic, ground and surface water sampling has shown average arsenic levels to be well below the World Health Organization (WHO) recommended limit for potable water (0.01 mg/l). Two samples of surface water only reflected arsenic levels slightly elevated above this limit.



Based on geochemical analysis of waste rock as part of the ESIA process, it has been determined that the waste rock is non-acid generating with ARD potential being low due to the Sulphur content being less than 0.02%. As part of this geochemical assessment, the Company carried out both static and kinetic testing of representative waste rock samples (60 samples for static and 1 combined sample for kinetic testing). Kinetic tests were initially run for 26 weeks and showed that there was a steadily declining level of metals in solution. Arsenic is present in the ore body with the kinetic testing showed a steadily declining level of arsenic in solution. At all times the arsenic concentration was below the discharge levels recommended in the WBG EHS Guidelines for Mining. The results further indicated that the waste rock’s acid neutralizing capacity is greater than its ability to generate acid, confirming the low potential for acid rock drainage



Water for construction is being obtained from boreholes, for the operational phase, recycling of water from the TSF will be maximized with make-up water as required being obtained from the Marvoe Creek diversion dam. All water abstraction will be in accordance with Liberian national regulations.



According to the Marvoe Creek Diversion, Flood Hydrology and Hydraulics Design Report (Epoch Resources), the diversion system will have two flood control dams / reservoirs, referred to as “Dam 1” and “Dam 2”. “Dam 1” will be constructed in the Marvoe Creek and “Dam 2”, will be constructed in a tributary of the creek. A trench will be cut between the two dams to ensure “Dam 1” overflows into “Dam 2”.



The proposed dams have a total storage capacity of approximately 11 million cubic meters, of which 7 million c
ubic meters is flood storage. The maximum wall height is anticipated to be 11 meters. The flood storage capacity relates to the temporal storage between full supply level (FSL) at 70.00 m.a.s.l. and non-overspill crest level (NOC) at 73.00 m.a.s.l.





Tailings Storage Facility (TSF)



The TSF has been designed by Epoch Resources, a South African based mine residue and environmental engineering consulting company. It is designed to be able to store a total of 9.35 million dry tonnes of tailings expected to be generated over a period of 8.5 years. The facility comprises combined initial valley containment and a self-raising paddock system. The geotechnical test work carried out to date indicates that settlement/consolidation of the tailings will be reached within 24 hours of deposition and hence, the facility lends itself to being developed using a self-raising paddocking system. The total footprint of the TSF is 120 hectares. The facility will also include a concrete encased penstock decant arrangement, with an emergency spillway; and a 2,000 m3 return water sump into which the decant water from the facility is discharged and returned to the plant or released.



The geotechnical investigations for this facility indicate that completely weathered rock is overlain by laterite in the higher ground, whilst the laterite is replaced by alluvium in the valley floors. From the test pit and borehole profiles, the alluvium or laterite extends to a depth of ±4.0mbgl. Below this depth, weathered rock (Gneiss) is encountered. Estimated permeability for the laterite is 1.6 x 10-7 – 4.0 x 10-8 meters per second. Estimated permeability for the weathered rock (Gneiss) is 1.0 x 10-6 – 1.0 x 10-7 meters per second. Risk Assessment of the facility design by a reputable independent engineering consultant and ICMC review with the intent of eventual certification is sufficient to give comfort that the level of risk to groundwater resources is acceptable.



In March 2014, SLR Consulting carried out an assessment for Aureus of the studies, investigation and design work for the TSF including the exposure pathways for arsenic and cyanide. This audit concluded that the overall design of the TSF is appropriate and the work to date is adequate, conforms to good practice and will enable ICMC certification in due course (after operational experience and plant process stability is achieved). The report further states that the fact that the TSF is unlined is deemed acceptable given the site specific characteristics, geochemical characteristics of the tailings and the proposed engineering mitigation measures. The report does provide several recommendations relating to the stability of the TSF, freeboard, pollution prevention design recommendations, etc, which are being incorporated into the final design of the facility (See ESAP Action 5). ICMC oversight provides additional confidence that the risks are being appropriately managed.



As part of IFC’s involvement th
e Company will appoint consultants (approved by IFC) to carry out regular and ongoing independent audits of the TSF every four months during construction (and every six months during operations) to ensure that design, construction and operation of this facility follows GIIP (See ESAP Action 6).



Arsenic Management



One of the key issues to address during operation of the mine is related to the management of naturally occurring arsenic in the ore body.



Following IFC’s guidance and request for further studies in order to meet IFC discharge guidelines, the Company has carried out several additional risk assessment studies to fully characterize arsenic behavior, including additional arsenic balances and modeling, taking into account specific geological, hydrogeological and climatic conditions and a comprehensive Arsenic Management Plan was developed.



The Arsenic Management Plan includes requirements for reducing soluble arsenic concentrations in the tailings stream within the process plant using Ferric Chloride to precipitate the arsenic. Drainage from the TSF will pass to an engineered wetland system downstream of the TSF to polish the discharge water to below the WBG EHS Guideline discharge level of 0.1 mg/l arsenic.  In parallel, the Company has committed to develop a robust surface and ground water monitoring program to assure operational parameters of the TSF and the engineered wetland are met and concentrations of arsenic are monitored for compliance with IFC discharge standards (at the exit of the wetland for surface water and at surface and deep water boreholes immediately down gradient of the wetland system for ground water).



Cyanide Management



To ensure adherence to GIIP and IFC requirements, the Company has developed a Cyanide Management Plan which follows the principles of the ICMC for all stages of transport, storage, handling, use and disposal. The Company will sign up to the International Cyanide Management Code before IFC invests and will seek ICMC Certification for the Project by December 31, 2016 in order to ensure safety of cyanide management throughout its operations (see ESAP Action 7).



The Company will use the INCO SO2 process to reduce concentrations of cyanide in the tailings slurry pipeline leaving the process plant. The system is being designed such that discharge from the TSF will be acceptable to ICMC and maintained below the WBG EHS Guideline effluent discharge standard of 0.5 mg/L WAD Cyanide. The surface and ground water monitoring program will monitor concentrations of cyanide and ensure ICMC requirements are met, especially with respect to the removal of all hazardous exposure pathways.



All project infrastructure (such as the process plant, detoxification plant, tailings pipeline, TSF and associated facilities) will be designed to comply with the requirements of the ICMC. Prior to the transport and use of cyanide, the Cyanide Management Plan will be fully implemented to ensure all ICMC requ
irements are met.





Solid and Liquid Non-Hazardous and Hazardous Waste Management

For the management of hazardous and non-hazardous waste, the Company has adopted a waste management strategy - operationalized through a Hazardous and Non Hazardous Waste Management Plan - focused on prevention, minimization, reuse, if possible, recycling, and final disposal.



Liquid waste such as sewage will be managed through septic systems and the installation of a sewage treatment plant at the accommodation camp and the processing plant areas. Solid non-hazardous waste, which includes tins, cans, bottles, paper and cardboard, inert bulk waste, timber, piping and fittings, and scrap metals, among others, will be segregated for reuse or possible recycling. The Company will construct a landfill site at the New Liberty accommodation camp where non-hazardous waste will be compacted and backfilled after all potentially recyclable material has been removed. This site will be designed using internationally accepted standards for waste disposal. The general waste landfill site will be fenced and properly demarcated with proper signage boards. Disposal of waste in non-licensed landfills will be strictly prohibited.



Hazardous waste including waste oils and greases, oily rags, contaminated soils, dry cell batteries, waste from the assay laboratories, fluorescent light bulbs etc. will be delivered to an approved hazardous waste management facility or, if this does not exist within Liberia, the Company will make arrangements for appropriate long-term storage until appropriate mechanisms for their safe disposal can be identified.



Energy Use



It is envisaged that electrical power for the mine and processing infrastructure will be supplied by multiple diesel or heavy fuel oil generators, operating in parallel, with step up transformers to a reticulation voltage of 11 kV. The power plant will have an installed capacity of approximately 10MW. It is estimated that fuel consumption will be approximately 90 million liters of diesel during the 24 month construction phase and 11.5 million liters per year during the operations phase. It is expected that greenhouse gas (GHG) emissions for the project during construction will be around 2,000 tonnes CO2 equivalent per year and during operations 83,000 tonnes CO2 equivalent per year. All emissions are from vehicles and the diesel power generators.



Emergency Preparedness and Response



As part of its ESHSMS, the Company has prepared an Emergency Preparedness and Response Plan (EPRP) in order to be able to respond appropriately to incidents and accidents during construction and operation of the mine. These include incidents and accidents related to fires and explosions, toxic releases, hydrocarbon spills, disease outbreaks and transportation accidents. This Plan includes specific information on responsibilities, emergency response actions, training and reporting requirements to manage these risks. All employ
ees of the Company together with DRA and other subcontractors will undergo training on the EPRP through camp inductions and periodic more specialized training on incident and accident scenarios and response.

Community Health and Safety



The main community health safety and security risks from the project include those associated with mining and transport operations, such as open excavations, movement of heavy equipment, road traffic, transporting, handling and use of hazardous materials and tailings dam management.



Tailings Storage Facility (TSF)



The TSF has been designed by Epoch Resources to be able to store a total of 9.35 million dry tonnes of tailings expected to be generated over a period of 8.5 years. The total footprint of the facility is expected to be 120 hectares and the height of the dam has been determined to be 20 meters.



Based on the information reviewed, the New Liberty site is located in a region of relatively low historical earthquake occurrence and relative geological stability. The United States Geological Survey (USGS) seismic hazard map was also considered in the design.



The dam has been designed taking into consideration the maximum probable flood event which is the WBG EHS Guideline for Mining requirement.



Seepage and slope stability analyses (static, dynamic and rapid drawn down) for the TSF have also been carried out by Epoch and indicate that the facilities are considered stable with a low probability of slope stability failure.



The closest community downstream from the New Liberty site is Jikando located approximately 3 km downstream. Based on a review by Epoch, the risk of potential impacts from any dam failure on this community are not considered significant as Jikando is not located in the drainage path of the Marvoe Creek but on an elevated high ground (+13 meters) and approximately 168 meters from the Creek. The selection of the current location of the tailings storage facility also considered the reduced risk to downstream receptors compared with the original mine layout. During operations monitoring, the need for a revised flood routing analysis will be considered based on any changes to communities downstream of the dam.





Traffic Management and Use of Roads

The Company is using national and local access roads during construction and operation of the mine. In order to minimize risks for local communities from project-related traffic, the Company developed a Traffic Management Plan (Code of Practice). The Plan includes identification and addressing traffic risks within and outside of project fence and provides guidance for safe traffic operations. The Company upgraded parts of existing access roads to increase safety of traffic. It installed signage on access roads and implemented defensive driving training. Contractors and suppliers must follow safe driving provisions including mandatory seat belt use and ban of cell phone use while driving and ban on night driving.



Use of Security Services



The Company is currently using a Liberian qualified and licensed security company at its facilities, construction site and equipment as well as exploration sites. Security guards carry n
o firearms. The security services provider employs mostly local community members for night guard positions and provides training to its personnel.



As part of ESIA development, the Company undertook a Human Rights Impacts Assessment (HRIA) in order to identify the main Human Rights contextual risks in Liberia that the project may encounter and incorporate mitigation measures where feasible in the RAP, CDP, SEP, as well as Security Management Plan.



The Company has developed a Security Management Plan in order to reduce the security risk of conflict and to maintain good relationships with both its staff, and the local communities and will require its personnel to comply with the Voluntary Principles of Security and Human Rights. Security operations and Aureus must fully comply with SEP and follow up any grievances lodged. Should it appear that violence could escalate, the security services should be alerted and if required, the emergency response mechanism implemented.



Upon completion of construction and start of production operations, Aureus may require additional security on site including the possibility of armed guards securing most sensitive facilities and processes. Aureus will issue a tender for its security operations internationally and conduct a selection among international reputable security providers. The Company will require its personnel and security services providers to be guided by good international practice including UN Code of Conduct for Law Enforcement Officials and UN Basic Principles on the Use of Force and Firearms by Law Enforcement Officials as well as the Voluntary Principles for Security and Human Rights (See ESAP Action 8).



Influx Management

As a result of mine development and increase of employment opportunities in the region, the improvement of living standards and local public services around the mine, as well as due to the improvement in road conditions, additional potential influx of population into the area is expected. Exploration activity has been taking place over the past 20 years or so and while accurate census data has not been found, subjectively it is thought the population has increased over this time. In order to mitigate potential social, health and safety and environmental impacts from such project-induced impact, the Company is developing an Influx Management Plan, which will be discussed and agreed with the local stakeholders as well as government authorities to define strategies aimed at minimizing influx (See ESAP Action 9).

The New Liberty mine is located in a broad region of high biodiversity importance under high threat (Forests of Upper Guinea Biodiversity Hotspot) as defined by Conservation International. The extent of Natural and Modified Habitat affected by the project was mapped and documented in the ESIA. Biodiversity related studies referenced by the ESIA include work by Golder Consultants, this was later supplemented by fauna and flora surveys by Digby Wells. These have been reviewed by IFC and led to an updated report by Digby Wells together with a Biodiversity Management Plan. It is estimated that about 378 hectares (67% of impacted area) of Natural Habitat will be impacted due to project activities.





IFC’s review of available biodiversity information indicates that the area has the potential to be Critical Habitat for possibly 3 endangered species which appear in regional data, although further work is required to confirm whether they are present in the immediate project area. Based on the available data endangered species listed as potentially present in the area: Jentink’s Duiker, Red Colobus (primate), and Monocyclanthus vignei (tree). Additional triggers of Critical Habitat may also be identified following the collection and assessment of additional data, which was requested by IFC.



The information provided in the above mentioned consultants’ reports identifies key impacts on biodiversity, bushmeat hunting, habitat loss due to logging and human influx into the area. Aureus developed a Biodiversity Management Plan (BMP) in order to mitigate these impacts. This includes generic mitigation measures on reforestation, access control and prevention of hunting. However, there may be significant residual impacts on biodiversity after on-site mitigation measures are implemented, which if Critical Habitat is defined by IFC will require a Biodiversity Offset Strategy to achieve Net Positive Impact (NPI) as per PS6. The Company will need to secure a fund or financial strategy early on to ensure that the Offset Strategy can be implemented over time. The World Bank is currently piloting an aggregated offsets program in Liberia and Aureus is currently in dialog with the facilitators of this program. Aureus committed to undertake additional biodiversity impact studies and update the Biodiversity Management Plan (BMP) as well as develop in partnership with a recognized biodiversity institution, a PS6 aligned Biodiversity Offset Strategy (See ESAP Action 13).



The Company is also working on exploring areas to the northeast of New Liberty (Ndablama/Weaju) which are located in mostly Natural Habitats, close to existing protected areas, and that are likely to qualify as Critical Habitat. Much of this area is thought to have high bio-diversity values and pre-assessment will be critical prior to any invasive exploration activities. As part of IFC’s involvement, the Company must, to the satisfaction of IFC, design and carry out a PS6 aligned biodiversity
assessment, including targeted field surveys, in the areas being explored. The biodiversity data collected must be used to identify biodiversity values as well as to assess and mitigate impacts on biodiversity during the exploration stage. In addition, the data should also be used to design future project infrastructure and subsequent Biodiversity Management Plans in order to avoid and manage impacts on biodiversity if the projects move towards development (See ESAP Action 14).

As part of the ESIA development Aureus undertook archaeological field surveys of the areas affected by the project, including areas cleared for drilling and access, and exploration routes that had been cut through the forest for the purposes of establishing a diversion route for the river. In addition, interviews were conducted by the team with the village elders of the surrounding villages of Kinjor, Larjor, Jawajei and Jakindo to identify sites of cultural significance and with their permission the team were taken to their most sacred sites to record their location and form. The archaeological survey was limited to recording above-ground visible remains. As a result of the study, no archaeological remains or sites were identified.



A total of 26 cultural heritage sites were identified including Poro and Sande bushes, cultural prayer sites, burial grounds, shrines, public meeting places, churches and mosques, from which shrines and cultural prayer sites are rates with highest importance for the communities.



The footprints of the proposed mine areas have the potential to have a direct impact upon five cultural heritage sites identified from the baseline field work comprising: Site 2 - Larjor cemetery; Site 3 - Kinjor cemetery; Site 4 - Kinjor church; Site 5 - Kinjor mosque; and Site 6 - Kinjor townhouse.



The cultural sites located in Kinjor and Larjor, which include modern burials (late 20th and 21st century), will be impacted directly. Aureus made a decision to relocate the cultural significance sites in Kinjor and Larjor as part of the villages’ resettlement process. Aureus has included the cultural heritage considerations in the development of the RAP and consulted and agreed with the local communities on the culturally-appropriate way to relocate the sites and ensure access to them by the community members in the new settlement. The Company will ensure successful implementation of these provisions of the RAP as part of the independent audit of RAP implementation (See ESAP Action 10).



The ancestor site located on the western periphery of the development proposals should be protected from potential disturbance. Access to the cultural sites at Jawajei for the other villages (Kinjor, Larjor and Jakindor) may be affected by the project and suitable mitigation strategies will be developed to ensure community access is maintained during construction and operational phases.



Throughout the life of the project, Aureus will implement its Cultural Heritage Chance Finds Procedure. This Procedure will be in place at the onset of construction, and will be communicated and enforced with all operators and contractors.

Aureus has implemented a transparent procedure for both internal and external communications and stakeholder engagement will be consistent with the requirements of IFC Performance Standards.

As part of preparation of ESIA and management plans, Aureus undertook comprehensive stakeholder engagement with affected communities, regional and traditional authorities, and government agencies process such as Environmental Protection Agency; Ministry of Lands, Mines and Energy; Forestry Development; Hydrological Service of Liberia; and Ministry of Internal Affairs. The process was designed to satisfy the requirements of Liberian regulations and comply with IFC Performance Standards. Community stakeholders including residents, the Chiefs, elders and spiritual leaders, representatives of youth and women’s groups and the general population in each village were also consulted in the areas around the project.

Early stakeholder engagement activities for the RAP development expanded on the environmental and social studies undertaken by Golder during 2011/2012 for the Environmental Impact Statement. SEP has been developed and implemented as part of ESIA preparation and is disclosed alongside with their ESRS.

Stakeholder engagement activities are undertaken by Social Manager and Community Liaison Team (CLT) with guidance from the General Manager, Administration and Government Relations. The implementation mechanism for the SEP have been developed for the periods of construction and operation, resettlement and land acquisition as well as for community development activities. A Grievance Mechanism has also been developed and implemented by the project. Means for internal communications include formal and informal meetings with workers, bulletin boards, and boxes for suggestions. Employees will be able to make confidential comments.

The ESIA and an Addendum to the ESIA have been disclosed and can be viewed on Aureus’ web-site
(aureus-mining.com/investors/technical-reports).

The key environmental and social documents will also be available for public review in Aureus project site and in Aureus Office in Monrovia and Aureus corporate offices in London at the following addresses.

Aureus Mining, Liberia
Allison StreetCongo TownMontserrado County,
LiberiaTelephone: 231-886-533039

Aureus Mining, UKBurleigh House, 355 Strand, WC2R 0HSUnited KingdomTelephone: +44(0) 20 7010 7690

Please note that IFC is in the process of assessing broad community support for the project under consideration. The information on broad community support will be disclosed as soon as it becomes available.

Title	Anticipated completion Date
Environmental and Social Management System. Aureus will finalize the development of Environmental, Social and Health and Safety Management System (ESHS MS), including all necessary Elements and Programs in alignment with the requirements of ISO 14001 and OHSAS 18001.	09/30/2014
ESHS Management Programs. Aureus will require the EPCM Contractor to incorporate the requirements of its ESHS Management Plans into Contractor’s Management System and implement them in the construction activities.	08/01/2014
Organizational Capacity. Aureus will engage a full-time EHS consultant present on site with international experience in the application of IFC Performance Standards and GIIP in the mining sector to implement the ESHS MS for the Project.	07/01/2014
Independent Environmental and Social Monitoring. Aureus will undertake audits of construction activities and ESHS MS implementation by a qualified Independent Environmental and Social Consultant (IESC) on a TOR modified to address IFC Performance Standards and agreed with IFC (at agreed frequency of the audits*).	08/30/2014
Safety of TSF and tailings management. Aureus will incorporate the recommendations from independent engineering consultant (SLR) into the design of the TSF in order to meet GIIP	07/01/2014
Safety of TSF and tailings management. Aureus will appoint a specialized consultant to carry out regular and ongoing independent audits of the Tailings Storage Facility (TSF) every four months during construction and every six months during operations to ensure that design, construction and operation of TSF follows GIIP.	07/01/2014
Cyanide Management. Aureus will obtain International Cyanide Management Code (ICMC) Certification for the Project.	12/31/2016
Use of Security Forces. Aureus will include in Security Management Plan and the contract with the security services provider and in the requirement to adhere to GIIP, such as the Voluntary Principles for Security and Human Rights	07/01/2014
Influx Management Plan. Aureus will update the Influx Management Plan based on the project operations and consultations with the local communities.	12/30/2014
Resettlement Management Plan (RAP). Aureus will implement the requirements of the RAP for resettlement of Kinjor and Larjor villages and conduct an ongoing independent audit of the outcomes of the resettlement process and livelihoods restoration by qualified social consultant.	08/30/2014
Community Development Plan (CDP). Aureus will implement the CDP for resettlement of Kinjor and Larjor villages and initiate an ongoing independent audit of the outcomes of the resettlement process and livelihoods restoration.	08/30/2014
Resettlement from ROW of Daniel town road. Aureus will ensure, to the extent possible, the compliance with the objectives of PS 5 of the government-led resettlement from ROW of the Daniels Town road and provide support for ensuring such compliance.	08/30/2014
Biodiversity Management. Aureus will conduct additional biodiversity assessment, including review of available regional data and targeted field surveys in the study area in order to clarify the Critical Habitat status for the three species from the project area listed as globally endangered and any additional biodiversity values which could trigger Critical Habitat	07/01/2014
Aureus will update the Biodiversity Management Plan (BMP) aligned with the requirements of PS 6 based on new biodiversity data and including an updated assessment of Critical Habitat, and specific mitigation measures for biodiversity values.	12/30/2014
Aureus will develop and implement Biodiversity Monitoring and Evaluation Program (BMEP) aligned with the requirements of PS6	12/30/2014
Aureus will develop and implement, in partnership with a recognized biodiversity institution, a Biodiversity Offset Strategy, aligned with the requirements of PS 6 and integrate it with country-level aggregate offsets scheme in Liberia, if feasible.	12/30/2014
Biodiversity Management for Exploration Areas. Aureus will carry out biodiversity surveys at existing exploration areas (Ndablama/Weaju) to assess biodiversity values and Critical Habitat, identify sensitivity, and guide infrastructure design to avoid impacts on biodiversity.	12/30/2014