While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

This is a category B project according to IFC’s Environmental and Social Review Procedure because the environmental and social (E&S) impacts of the project are limited, site specific and therefore manageable through implementation of appropriate mitigation measures. This categorization is based on the impacts of the DFS activities described above. Project management includes noise, dust and emissions, pollution prevention, surface and groundwater protection, management of fuel, oil and waste, transportation safety management, occupational and community health and safety, etc. which are reversible and can be properly mitigated by Peak. The company currently manages its impacts mainly through implementation of its Ngualla Project Management Plan, Occupational Health and Safety (OHS) system comprising the OHS Policy and guidelines for implementation of OHS Policy. In addition to this, the company maintains a good working relationship with the local Ngwala village and government authorities.

In view of the DFS, Peak recently (June 2014) commissioned a local Tanzanian consulting company registered with the National Environment Management Council to conduct various baseline studies which will feed into a full ESIA to be undertaken as part of and in parallel with the DFS.

PS5 is not applicable at this stage as there is no physical and/or economic displacement due to the project. The land on which the exploration camp is located is leased from an individual on a willing buyer/willing seller principle. PS6 does not apply because there are no national parks or reserves and no protected or vulnerable species of fauna and flora have been recorded within Peak’s operations. Hunting of any wild animals in the area is managed through allocated hunting concessions. PS7 is not applicable at this stage as no indigenous people were identified on the project’s area of influence. There are currently no known sites of archaeological or cultural significance, thus PS8 is not applicable at this stage. However, Peak and its contractors will implement a chance find procedure for exploration and feasibility activities on an ongoing basis.

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.

Environmental and Social Policy: As noted above, Peak currently manages its impacts mainly through implementation of its Ngualla Project Management Plan, OHS system comprising the OHS Policy and guidelines for implementation of OHS Policy. As part of IFC’s investment, Peak will consolidate and formalize its existing E&S policies and community practices to ensure consistency with Good International Industry Practice.

Identification of Risks and Impacts: As part of the guidelines for implementation of OHS Policy the company is committed to completing a site risk assessment annually. The identified risks/impacts together with the associated mitigation measures are captured in a comprehensive Master Risk Assessment Register. All staff (including contractors), especially field staff, are required to familiarize with the risk register prior to commencement of any exploration activity.



The scope of the baseline studies referred to above includes, flora, fauna, heritage, air quality, noise, surface/ground-water and socio-economic studies. A range of atmospheric conditions (temperature, wind, pressure and rainfall) are recorded on an ongoing basis using a weather station at the Ngualla camp. Water quality tests were conducted in 2012 at three points around Ngualla and water flow monitoring was conducted on the outflows from the Ngualla hill during 2013 and 2014. Data from the baseline studies and monitoring campaigns will feed into the ESIA which is required under the Tanzanian regulations prior to the grant of a mining license for the project. The company will hire a suitably qualified and experienced E&S consultant to manage and coordinate the ESIA process. In addition to this, IFC will work with Peak on the scope of work and terms of reference for the ESIA to ensure that the ESIA is undertaken to IFC Performance Standards requirements.



Management Programs: The aim of the Ngualla Environmental Management Plan is to promote responsible land use practices by outlining a series of guidelines designed to address and minimize any potentially adverse environmental impacts and allow the company and its contractors to undertake exploration and feasibility activities in an effective and efficient manner. The Plan provides guidelines to be followed during surface clearing, exploration drilling and associated activities, and rehabilitation. In addition to this, risks/impacts such as pollution and environmental degradation, noise, dust etc. related to environment, health and safety are captured in the Master Risk Assessment Register for the project. The Master Risk Assessment Matrix is used to identify high risk activities and where better controls are needed to reduce the risk to an acceptable level. Major and common risks are communicated through the induction program. One of the controls identified to mitigate/reduce these risks is the implementation of Standard Operating Procedures (SOPs) for the main exploration and feasibility tasks carried out at N
gualla. Preparation and formalization of SOPs is currently in progress. This will include preparation and implementation of a chance find procedure for cultural and historical artifacts for exploration drilling and feasibility studies.



Organizational Capacity and Competence: The project manager has overall responsibility for E&S issues whilst the exploration geologists are responsible for monitoring and enforcing the implementation of the exploration guidelines and practices stipulated in the Environmental Management Plan on a day-to-day basis. The project manager reports to the technical director in Perth. All employees (direct and contractors) are encouraged to report any E&S issues to the project or camp manager who then passes on the concerns to management. In addition to this, Peak has an OHS committee tasked with identifying and discussing health and safety issues. The OHS committee representatives are trained by Occupational Safety and Health Authority (OSHA) of Tanzania. The committee meets on a regular basis in compliance with OSHA requirements. Minutes of the OHS committee are provided to the technical director, who reports any incidents and issues to the board. The project manager also chairs the OHS committee.



The company accepted a recommendation to form a team of key Peak employees, a suitably qualified and experienced consultant and Tanzanian environmental sub-contractors to oversee the development of an ESIA compliant with IFC Performance Standards. Beyond DFS, and should the project proceed to engineering design & procurement, construction and production, Peak will put in place an E&S team appropriate to the scale of the project.



Emergency Preparedness and Response: Peak has a comprehensive Emergency Response Plan (ERP) which is updated on a continuous basis with help from specialist companies and government departments. The ERP contains procedures for specific emergencies such as medical, fire, snake bites, and vehicle accidents. Emergency drills are scheduled regularly and conducted to identify potential areas for improvement. The drills are also undertaken to ensure that all site personnel are conversant with the ERP procedures. Records of these drills are kept. There is a gravel airstrip close to the Ngwala village. It is approximately 2 kilometers south of the Peak camp and can be used in case of an injury requiring emergency evacuation and assistance which is provided through AAR Insurance Tanzania. The ERP also contains specific instructions on roles and reporting in the event of an emergency. The project manager (or the next most senior person on site) will initially take control and coordinate the first response to the emergency. All employees and contractors are responsible for reporting any emergency incident to their supervisor or the responsible person of the area.



Guidelines to be followed in the event of hydrocarbon spills are specified in the exploration drilling section of the Environmental Managemen
t Plan.



Monitoring and Review: Peak’s OHS Policy and Guidelines include a number of internal inspections such as weekly drill rig and vehicle inspection by experienced personnel. Periodic OHS focused inspections by the Tanzanian OSHA are conducted and feedback is provided to Peak. These include building, electrical and hygiene inspections. The project and camp managers then assign tasks to correct any non-compliance. The company keeps a register of all health, safety and environment related incidents and accidents.



Peak completed a performance and compliance review against the relevant statutory requirements and regulations. The review considered the following specific requirements and regulations: Occupational Health and Safety (OHS) Act No. 5 of 2003; Mining (Safety, Occupational Health and Environment Protection) Regulations 2010; and Fire and Rescue Force Act No.14 of 2007 and Regulations “Fire Safety and Certificate Regulation of 2008, Amendment 2012 and 2014”. The company is currently in compliance with these regulations and requirements.



Stakeholder Engagement, External Communications and Grievance Mechanisms: Peak has established and maintains an excellent relationship with the local community and local and national government authorities. Representatives from Peak attend regular village committee meetings where enquiries can be put directly to Peak. Questions that cannot be answered immediately or require input from Perth senior management are recorded and answered at the next meeting. The company has engaged and consulted with all levels of local government since commencing exploration. Minutes are compiled and kept for all meetings. No formal complaints have been received from community members. Peak does however receive regular enquiries including requests for financial assistance of community projects, building materials, village health and transport.



As part of IFC’s investment, and to strengthen its ongoing consultation and communication processes with local community and government authorities, Peak will formalize its existing engagement process into a Stakeholder Engagement Plan (SEP). The formalized SEP will identify the company’s major stakeholders, sustainability issues specific to each stakeholder, and frequency of engagement with each stakeholder group. Peak will also adopt an appropriate grievance mechanism to accompany the SEP.

Human Resources (HR) Policies and Procedures: Peak has 7 permanent staff and 2 contractors based in the Perth office. In Tanzania, Peak employs 2 permanent staff and 9 staff on formal contracts. Of the permanent and contract staff 25% are female. Almost all of Peak’s employees (with the exception of the project manager) who are based at the project site are Tanzanian. Peak also employs 10 camp staff (security and camp maintenance) on a casual basis and from time to time a larger number of up to 30 additional workers from the local villages during active periods of exploration and feasibility in the dry season for sampling, drilling and other programs. All employees are issued with contracts which specify the terms of employment and employee working conditions (e.g., recruitment, training, remuneration, termination, hours of work, etc.) and benefits (e.g. salary advances and loans, medical, life and disability). For Tanzanian employees the contracts are consistent with the provisions of Tanzania’s labor laws. Terms of employment for Perth based staff are governed by Australian employment law and national employment standards. Casuals from the local village are employed on a rotating lottery system every 3 to 5 days to ensure a fair distribution of employment to local people.



Peak is an equal opportunity employer and does not discriminate on the basis of gender, age or religion. Whilst none of the employees are unionized the company does not interfere with the legal rights of its workers and supports the right of employees to join organizations of their choosing. The company displays the rights of employees under Tanzanian law on the exploration camp noticeboard. Peak does not make use of child labor and/or forced labor in its operations.



The company does not have a formal (i.e. documented,) HR policy. Thus Peak will formalize and communicate its existing HR practices with a guidance note setting out key HR Principles. This should include a workplace grievance mechanism and should be consistent with the requirements of Performance Standard 2 and Tanzania’s labor laws.



Occupational Health and Safety: OHS risks of Peak’s operations and the effectiveness of the management systems are subject to continuous monitoring and review in accordance with the company’s OHS Policy and Guidelines. Identification of OHS risks and hazards occurs during pre-start meetings, in formal safety discussions and when writing work programs. Employees are encouraged to identify any hazards and report them to the project manager, OHS committee representatives or to management. Peak performs its own internal OHS audits on a regular basis whilst OSHA actively and routinely visits the company’s operations for inspections. Various OHS related training programs are undertaken on a continuous basis. These include the mandatory OSHA OHS representative training; First Aid; and firefighting and fire awareness training. All senior personnel at Ngualla have undergone First Aid
Training which was provided on site by an external specialist consultant.



Personnel Protective Equipment dedicated to the particular workplace is provided and worn by workers. This may include safety boots, protective gloves, hard hats, and ear or eye protection, according to workplace risk. If there is a workplace injury, formalized systems of review are used, with the objectives to identify the type of risk, nature of the accident, injured area of the body, causes of the accident, and areas of follow-up which are allocated to individuals and tracked until completed. In addition to this, Peak provides medical insurance which covers hospital and medical costs as well as emergency evacuation. The company has not recorded any serious accidents since commencing exploration at Ngualla.

Resource Efficiency: The company uses a combination of solar panels and two diesel gensets to generate electricity which is used to power the exploration camp.



The company has an agreement with the Ngwala village to draw water from the village supply. The village water system consists of a 300 000 liter tank which is gravity fed by spring water and distribution pipeline to selected points in the village. The camp draws about 3 000 liters per day from the village supply system. Water quality has been tested and found suitable for human consumption. Potable water for camp use is further treated by a reverse osmosis process. The company routinely assists with maintenance and repair of the Ngwala water supply system. This arrangement is adequate for the current operations.



Peak has committed to commissioning a comprehensive hydrological study as part of the DFS to: identify groundwater location and flows; prepare water balance to define sustainable surface and groundwater resources that will ensure sufficient year-round provision of process water for the project without impacting other users; and implement key recommendations arising from these investigations including installation of monitoring boreholes. Parallel to this, the company will undertake further detailed studies on beneficiation, recovery and separation to determine technical options. This may include the production of a concentrate on site (for further processing elsewhere) which would significantly reduce the amount of water required.



Pollution Prevention: Putrescible camp refuse and combustible material is burnt in a pit and then covered with soil, while other waste is buried. Waste water and sewage is adequately treated using septic tanks and a soak-away.



The drilling contractor (note that there is currently no drilling taking place) has avoided spillage of used drilling media and lubricants into the surrounding environs through use of lined sumps. In addition, the drilling contractor used biodegradable foams and drilling fluids. Material from drilling sumps and pad stripping was stockpiled for use in the pad rehabilitation process as part of drill hole closures. Any hydrocarbon spills and contaminated soil was bagged, collected and buried. Controls for reducing the likelihood and consequence of spills included rig inspections, matting under rigs and adequate bunding for stored liquids, including the large diesel tank on site. Rehabilitation of drilled areas, which was observed to be successful, was undertaken as soon as the areas were no longer required and included backfilling the sumps.



With the exception of fuel, Peak does not ordinarily handle hazardous or toxic materials at this stage of the project. Unlike nearly all other rare earth ores, the Ngualla mineralized zone contains only very low-levels of radioactivity which equate to less than 1 Becquerel per gram (Bq/g) and so are not classified by the International Atomic Energy Agency as radioactive. Managemen
t of radioactivity in subsequent processing will be further evaluated as part of the DFS and ESIA taking into consideration that recovery could be done off-site.

Dust from any drilling operations (especially when using compressed air) is carefully managed. Other limited airborne emissions are exhausts from the drilling rig itself and the small fleet of light support vehicles all of which are regularly maintained.

Community Health and Safety: The main potential risks related to the community from Peak’s current operations are vehicular accidents involving humans and livestock, noise and dust due to vehicular movement through the local community settlements. The significance of these risks is currently low due to low traffic volume, and isolated location of the project. However, this can change with the potential development of the project and to this effect; Peak maintains and enforces rules for safe driving for all its vehicles and contractors.



Any potential future mine development is likely to result in further population growth (particularly during the construction phase). Management of such influx by the company in conjunction with regional authorities will be needed to avoid resource shortages for local people, such as land, firewood, medicinal plants, and formal and informal livelihood sources. The company will also develop and implement a comprehensive HIV/AIDs and communicable diseases plan for implementation prior to construction, should the mine development proceed.



Security Personnel: The Ngualla camp is fenced off and is manned 24 hours a day, all year round, by unarmed security guards recruited from the local village. The guards are managed by the project manager and camp manager. The guards have been trained by a village security officer, camp manager and Ngwala prison staff. For remote field work an armed ranger from Ngwala village accompanies the team to protect personnel from potentially dangerous wild animals. This is not required in camp or on the main site of the deposit. There have been no incidents of threat to the security of operations or the company’s personnel and the current security arrangements are considered adequate. However, should the project progress to construction and production, additional security will be required and this will be put in place in line with the requirements of Voluntary Code for Security and Human Rights.

Peak has established and maintains an excellent relationship with the local community and local and national government authorities. Representatives from Peak attend regular village committee meetings where enquiries can be put directly to Peak. Questions that cannot be answered immediately or require input from Perth senior management are recorded and answered at the next meeting. The company has engaged and consulted with all levels of local government since commencing exploration. Minutes are compiled and kept for all meetings. No formal complaints have been received from community members. Peak does however receive regular enquiries including requests for financial assistance of community projects, building materials, village health and transport.

The Environmental and Social Review Summary (ESRS) and the attached ESAP will be made available via the World Bank Group’s InfoShop. Peak will be required to inform the public that results from IFC’s environmental and social review and ESAP are available for access on its corporate website or provide a web-link to IFC’s disclosed ESRS and ESAP.

For inquiries and comments about the project contact:
Peak Resources Limited
Level 2, 46 Ord Street
West Perth
Western Australia 6005
Telephone +61 8 9200 5360
Facsimile +61 8 9226 3831
Email: mailto:info@peakresources.com.au

Or

Peak Resources Limited
Ako Law, 11th Floor, Golden Jubilee Tower,
Ohio Street, Dar es Salaam, Tanzania

And

Peak Resources Exploration Camp,
Ngualla Project, Ngwala Village,
Chunya District, Tanzania

For enquiries and comments about IFC;
General IFC inquiries
IFC Corporate Relations
2121 Pennsylvania Avenue, NW
Washington DC 20433
Telephone: 202 473 3800
Fax: 202 974 4384

Broad Community Support is not applicable for this project

Ngualla(35868) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
Formalise existing E&S and Community policies and practices to ensure consistency with Good International Industry Practice. The policies should indicate: (i) process framework; (ii) compliance with the applicable laws and regulations or other internationally recognized standards, practices etc.; (iii) assigning of responsibility; and (iv) communication of the policy.	30-Jun-2015	Completed	Completed	8/13/2015
Develop a detailed ESIA document addressing local regulatory requirements and IFC Performance Standards. The ESIA, which will be integrated with the DFS, will be available to the public at project site and office in Tanzania and online.	31-Mar-2016	Completed	Completed	6/14/2019
Engage a suitably qualified and experienced E&S consultant to manage and coordinate the ESIA process	31-Mar-2015	Completed	Completed	1/12/2015
Establish a chance find procedure for cultural and historical artifacts for exploration drilling and feasibility studies and ensure compliance with the procedure.	31-Mar-2014	Completed	Completed	3/30/2015
Formalize existing engagement process into a Stakeholder Engagement Plan (SEP). The SEP will identify the company’s major stakeholders, sustainability issues specific to each stakeholder, and frequency of engagement with each stakeholder group. The SEP will also include a grievance procedure for the local communities and wider range of stakeholders.	30-Apr-2015	Completed	Completed	3/30/2015
Formalise and communicate existing HR practices with a guidance note setting out key HR Principles. This should include a workplace grievance mechanism and should be consistent with the requirements of Performance Standard 2 and Tanzania’s Labor Laws.	30-Jun-2015	Completed	Completed	8/13/2015