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

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

Cerro de Pasco is a relatively mining-friendly district with several mines operating in the region for decades. Cerro de Pasco also registers currently as having the lowest number of social conflicts in the country according to the Peruvian Ombudsman’s Report.

Any IFC investment in any future mining development would be assessed as a new project and its categorization would be determined after the necessary due diligence. Even without an additional investment, IFC would require any future mine development with major impacts to follow PS1 in its requirements for a full ESIA as well as independent monitoring of the project’s social and environmental performance and stakeholder engagement. Tinka will ensure that social and environmental assessment documents associated with such a development will be consistent with IFC’s Performance Standards and EHS Guidelines and be publicly available and consulted upon in accordance with IFC’s Access to Information Policy prior to the start of construction.

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. To address the identified issues and meet the requirements of IFC’s Performance Standards, Tinka has committed to developing a comprehensive Health, Safety, Environment & Community (HSEC) Policy relevant to the exploration phase. As part of this HSEC Policy, the Company will develop a Management System commensurate with the risks and impacts of this phase together with relevant ESHS management plans and procedures to address said risks, including stakeholder engagement plans and activities relevant to the level of activities. In addition, the HSEC Policy will include a requirement for the Company to develop an ESIA compliant with IFC’s Performance Standards prior to any mine development.

Environmental Policy:

The Company has developed an Occupational Health and Safety Management System and several components, plans and procedures in order to address occupational and health and safety risks. As part of IFC’s involvement, the Company will sign on to a comprehensive HSEC Policy to identify, assess and adequately manage existing ESHS risks and impacts. This will include the enhancement of the existing OHS Management System to include environmental and social components as well as the necessary management plans and procedures relevant to exploration activities.

The HSEC Policy will be developed with assistance from IFC, with key components, including the overall manual, incorporation of additional management plans and standard operational procedures (SOPs) developed by Tinka with support from an external consultant experienced in the use of good international industry practices (GIIP) for this phase of work (See Action 1 of the ESAP).

Based on the findings of the site visit, key management plans and/or SOPs to be developed or enhanced include those addressing pollution prevention (fuel management, spills, dust, noise, etc), solid and liquid waste, erosion control and re-vegetation, footprint management, biodiversity management, surface and ground water resources management, environmental monitoring, emergency response and contingency planning, road safety and transportation, archeological chance finds, stakeholder engagement, grievance mechanism, code of conduct, land access procedure, a specific drilling contractor ESHS management procedure and a Non-Compliance Corrective Action Procedure, among others (See Action 1 of the ESAP).



Identification of Risks and Impacts:



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



The Company wholly owns the concessions of Colquipucro and Ayawilca where drilling efforts are focused. Peruvian regulations require the development of an Estudio de Impacto Ambiental Semi-Detallado (EIA-sd) to be approved by the Ministry of Energy and Mines (MINEM) for any mining exploration work. This EIA-sd for both projects includes a characterization of works to be conducted and an impact assessment evaluation. The Company has obtained the necessary environmental permits (EIA-sd) for current exploration work at both sites. Reporting on environmental monitoring as part of the EIA-sd is submitted by Tinka on a semi-annual basis to the Ministry of Energy and Mines and the environmental regulator - Oficina de Evaluacion y Fiscalizacion Ambiental (OEFA).



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



The Cerro de Pasco Department has historically been a prolific mining region in Peru with communities familiar with mining. Having said this, community needs and expectations, in particular related to employment, are high. The Company is aware of this and is taking steps to engage with the local communities to provide relevant information on the project in order to manage expectations. The development of a formal Stakeholder Engagement Plan and Communications Plan as part of IFC’s investment will support the project in providing adequate and timely information to local communities and other key stakeholders, receiving feedback, adequately addressing any concerns or grievances and managing expectations and perceptions.



Temporary Land Access:



The concession area is characterized by communal land (superficial lands are owned by the communities of San Pedro de Pillao and Yanacocha). For communal land, communities assign parcels to its members for their use as residential, farming or grazing purposes.



Temporary access to communal lands have been negotiated by Tinka for its exploration program in the community assemblies and documented in written agreements (called Convenios). Land access agreements of Tinka with both communities were signed in 2012 and are valid until June 2015. The agreements outline a number of commitments to be carried out by the Company as agreed with the communities, such as employment of local workers and community development programs, among others.



The environmental studies developed between 2012 and 2014 for the exploration program described the socio-economic context of the direct and indirect area of influence of the Ayawilca-Colquipucro project. However, the studies do not specify the households and subsistence activities located within the ‘project boundaries’. Therefore, as part of the ESAP, Tinka will develop a supplemental socioeconomic baseline study, focused within the defined ‘project boundaries’, with the following components: (i) socioeconomic context of households; (ii) number of dwellings and other structures (such as wells, boreholes, fencing); (iii) land used for (subsistence) agriculture and farming; (iv) community resources such as water sources, pasture, woodland, medicinal plants, fisheries (if any); and (v) a description of how San Pedro de Pillao and Yanacocha communities assign land internally (See ESAP Action 2). The study will also map the legal boundaries of both communities. The supplemental study will be based on the existing EIA-sd, registered maps, secondary data from official sources and a household survey with the families that will be immediately (or in the near future) impacted/displaced.



In addition, Tinka will develop a Land Acqu
isition, Compensation and Resettlement Policy Framework to outline the principles, guidelines and approaches that will be followed for temporary and permanent land acquisition and compensation activities in accordance with Peruvian legislation and IFC PS5 requirements (See ESAP Action 2).



Historic Mining Liabilities:



As mentioned above, the Colquipucro Project area was mined since Spanish colonial times and, more recently, by several private mining companies. Because of this, there currently exist a number of historic legacy issues related to these prior extraction activities which include a number of waste rock dump sites and existing acid rock drainage from one of the small historic mining adits. The Company has declared and reported these historic liabilities to the Ministry of Energy and Mines with no legal responsibility to remediate these areas. The exceptions are two small areas (totaling 500 tons) which Tinka has committed to remediate.



Although no legal responsibility exists on the part of the Company to remediate the existing historic mining areas, it will be important for the Company to better understand the geochemical characteristics and potential environmental impacts from these extraction areas and, hence, has agreed to conduct additional environmental studies to characterize the extent and nature of these materials (See ESAP Action # 3).



Peasant Communities



Both the Colquipucro and Ayawilca projects are located in land of the communities of San Pedro de Pillao and Yanacocha. Part of these community members speaks the Quechua language, possess customary cultural, social and political institutions and, and have collective attachment to their land. As part of the ESAP, Tinka will hire an external social specialist to conduct an assessment to determine whether the communities of San Pedro de Pillao and Yanacocha could be considered Indigenous Peoples under Peruvian legislation and/or PS7 criteria. If Indigenous Peoples are identified, the Company will tailor their Stakeholder Engagement Plan to conduct an Informed Consultation and Participation (ICP) process in order to obtain their Free, Prior, and Informed Consent (FPIC), as well as develop an Indigenous Peoples Plan (IPP) in accordance with PS7, which will detail actions to avoid, minimize and compensate for any adverse social and/or economic, impacts and identify opportunities and actions to enhance positive impacts of the project in a culturally appropriate manner (See ESAP Action 4).



Management Programs:



Even though several procedures and documentation have yet not been formalized, there is an adequate level of environmental, social and health and safety management on-the-ground at the Colquipucro and Ayawilca sites. However, the Company has not yet developed or formalized several of their current environmental, social or health and safety practices and procedures to manage existing risks. As part of the HSEC Policy to be developed, the necessary man
agement plans and/or SOPs will be developed to incorporate GIIP practice into the project (Action 1 of the ESAP).



Organizational Capacity:



The Company’s current organizational structure includes a CEO, several Directors, a Country Manager and a Vice-President (VP) of Explorations. The Company’s senior management values a relationship with IFC to assist the Company carry out its exploration activities in line with GIIP.



In terms of ESHS personnel, the Company has one health and safety supervisor and one environmental specialist who report to the Country Manager. In terms of community relations staff, the Company has 3 community relations officers (CROs) who oversee the social aspects of both projects. The level of ESHS supervision is deemed adequate for this phase of work but will need to be complemented as work progresses in the future. Also, Tinka will hire an experienced ESHS consultant to support the initial development/enhancement of the various plans and procedures part of the HSEC Policy.



Training:



A certain level of environmental, social, and health and safety training to staff and contractors is done at the Colquipucro and Ayawilca projects as noted in the existing OHS Manual. However, a more comprehensive ESHS Training Plan to include other environmental and social topics has not yet been implemented. The development of the HSEC Policy and a ESHS training plan (Action 1 of the ESAP) will address the necessary competency training requirements for this phase of work including frequency, training topics and documentation necessary to assess the level of environmental, social and health and safety awareness of direct workers and contractors.



Monitoring and Review:



As part of the EIA-sd the Company (through an independent consultant) has undertaken environmental and social baseline data collection at both sites. This has included data collection for air quality, hydrology and hydrogeology, soil, flora and fauna, social aspects and archeology. Following approval of the environmental permit for Colquipucro and Ayawilca, the Company is carrying surface water monitoring (2 points at Ayawilca and 12 points at Colquipucro), air quality (2 points each at Ayawilca and Colquipucro) and noise (1 point at Ayawilca and 2 points at Colquipucro) on a semi-annual basis for reporting back to the government. No additional environmental or social baseline studies are being carried out by Tinka at the time.



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



Reporting:



As part of the environmental permit conditions, the Company submits an
environmental report with the results of the environmental monitoring program to the Ministry of Energy and Mines and the regulator for mining activities - OEFA on a semi-annual basis. Reporting on health and safety issues to the government is also required. The Ministry does not require reporting on land access (i.e. land take, number of land owners etc.).



As part of internal reporting, formal reports on EHS matters are provided to Country Manager on a monthly basis. However, limited information on statistics and key performance indicators (KPIs) is provided both on environmental and health and safety matters. On the social side, the community relations officers in the field have constant communication with the management in Lima, providing information, at least on a weekly basis, on communications with the communities and any issues that may require intervention from management. As part of the management system to be developed, specific report formats on social performance will be established together with a schedule for their submittal.



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

Tinka hires local unskilled workers on a rotational basis in accordance with agreements signed with the local communities to allow for a wider distribution of benefits locally. In addition, there are approximately 20 local workers hired by a contractor (S&C) who is undertaking the drilling activities.



Human Resources Policy:



Tinka does not have a Human Resources (HR) Department and this function is managed by administration personnel and overseen by the General Manager. The Company has a manual that describes roles and responsibilities within the organization and a Code of Ethics applicable to all the employees, which includes statements regarding ethical behavior, sexual harassment and fair treatment. However, the Company does not have HR policy or formal HR procedures. For employees on permanent and contract basis, Tinka follows the Peruvian Labor Law (which is aligned to ILO’s core labor standards) for management of its Human Resources. The law includes aspects related to employment contracts (verbal and written), working hours and shifts, minimum wage and overtime, employment age, vacation, maternity leave, termination, social security among others. The local workers’ contracts are signed between Tinka and the communities, in accordance with the Peruvian Labor Law and community agreements.



Tinka has agreed to develop Human Resource Policy and relevant Procedures consistent with the requirements of Performance Standards 2 and the requirements under the Peruvian Labor Law (See ESAP Action 5). The policy and procedures will be tailored to the nature and size of the project and it will cover all type of workers, including direct workers, contracted workers and community workers. It will also include aspects related to terms of employment including, at a minimum, remuneration, benefits, hours of work, overtime, leave allowances (annual, sick, maternity etc.), medical insurance, provisions on non-discrimination and equal opportunity, performance evaluation and promotion, termination, grievance mechanisms and whistle-blowing; as well as aspects related to working conditions and training.



Tinka will provide a copy of the HR Policy to all its employees and undertake internal training on the policies and procedures in place. For those that cannot read, Tinka will explain verbally the terms of employment and working conditions.



Working Conditions and Terms of Employment:



As mentioned above, working conditions are governed by the national labor law. All Tinka permanent staff is covered with medical and life insurance, as well as retirement contribution, provided by the Company. Tinka will standardize its contractual agreements consistent with the policies and procedures to be established (see above).



Workers’ Organizations:



The Peruvian Labor Law recognizes the rights of employees to form and join unions of their choice. There is currently no union representation at Tinka’s sites. However, the Company does not restrict
freedom of association and should the employees decide to organize, Tinka will not discourage unionization.



Non-Discrimination and Equal Opportunity:



The HR policy and procedures to be developed (See ESAP Action 5) should include principles of equal opportunity, fair treatment and non-discrimination with respect to any aspects of the employment relationship, such as recruitment and hiring, compensation, working conditions and terms of employment, access to training, job assignment, promotion, termination of employment or retirement, or disciplinary practices. Procedures should be developed to promote equal opportunity and prevent and address discrimination and any kind of intimidation.



Grievance Mechanism:



Employees can raise workplace concerns with their immediate supervisor, Occupational Health and Safety (OHS) Supervisor, Community Relations Supervisor or the Project General Manager. However, the Company does not have a structured grievance mechanism in place. As part of the enhancement of its Management System, Tinka will establish a grievance mechanism through which employees may raise their workplace concerns (See ESAP Action 5). The mechanism will establish the procedures for receiving, managing and addressing grievances promptly. The mechanism will allow for anonymous complaints to be raised and addressed Tinka will inform and train the employees on the availability of this mechanism. The procedure will recognize the rights of employees to access the national system for labor complaints and disputes of the Ministry of Labor.



Occupational Health and Safety (OHS):



Tinka has formalized an Occupational Health and Safety Management System which is applicable to all direct employees, community workers and contractors. All employees are submitted to pre-placement, periodic and exit medical examination by a qualified physician. At the end of medical examination the practitioner gives recommendations on the health status of employee, fitness to work, and if there are occupational diseases for compensation purposes.



Employees are provided with and use the necessary personal protective equipment (PPE) on drilling sites and in the workshop at camp. Tinka has established a formal health and safety incident reporting system to document and track incidents and implement corrective and preventative measures as required. Occupational injuries and illnesses are reported monthly to the General Manager, who reports any relevant information to the Ministry of Labor. To date, there have been no significant OHS issues and/or incidents. Safety dialogues take place daily and an OHS Committee has been established to monitor all health and safety issues.



Management of Contractors:



The current drilling company on site (S&C) currently operates three drill rigs. This drilling contractor is responsible for the management of environmental, health and safety issues at the drill sites and in maintaining the drill sites in adequat
e condition. Tinka oversees OHS and environmental management of these areas and undertakes site inspections along the drilling operations. As part of the HSEC Policy, the Company will formalize all applicable environmental, social and health and safety requirements relevant to the drill contractors into a single “ESHS Contractor Management Procedure” for inclusion into the legal agreements with these contractors.

Exploration activities currently being carried out at Colquipucro and Ayawilca include the construction of drilling platforms, short connecting access roads and drilling activities (currently using 3 rigs).



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



Solid and Liquid Waste:



Tinka generates minimal amounts of solid waste mainly from the camp and from the drilling sites. Waste is collected in containers at the camp and at each drill site and transported by a licensed waste company (Empresa Prestadora de Servicios de Residuos Solidos – EPSRS) to an authorized waste disposal facility. The Company does make an effort of segregating waste and in providing training to staff and contractors on adequate segregation.



Hazardous waste generated at the camp and drill sites is minimal and consisting mainly of spent rags and oil products. Hazardous waste is currently collected on site and transported by a licensed hazardous waste transportation company to a licensed hazardous waste treatment and disposal facility in the capital, Lima.



Regarding sanitary liquid waste generated at the camp, this is directed to a septic system also within the boundaries of the camp. At the drill sites, liquid sanitary waste is managed through the use of latrines.



Water Quality and Use:



Water for drilling activities is obtained from a local spring, surface lake and existing mine drainage. Tinka has a permit from the government agency responsible for water management (Administracion Local de Agua – ALA) to extract a total of 2007.5 m3 of water for current exploration work at Colquipucro and 6,000 m3 for the current exploration phase at Ayawilca. Used water from the drilling activities is temporarily stored in a series of lined pools to allow for solids to settle and for as much recycling of water as possible before release. Also, drilling activities use biodegradable drilling muds to avoid impacts on surface and/or ground water resources. There is not current evidence of any community opposition to the current use of local water resources although, based on the visit, there exists concerns from the community over potential impacts on water quality and quantity if the mine gets developed in the future.



Monitoring of surface water is carried out by an independent consultant (SGS) on a semi-annual basis. Samples are tested for physical, chemical and microbiological parameters. As part of IFC’s involvement, Tinka has agreed to enhance the existing water monitoring program to make it participatory in nature in order to involve key stakeholders in the process and maintain these stakeholders informed o
f water quality and quantity trends as the project moves forward (Action 6 of the ESAP).



Restoration and Re-vegetation:



Restoration and re-vegetation of drill pads is carried out at all sites following the completion of work. As approved by the Ministry of Energy and Mines, drilling platforms are limited to a 10 meter by 10 meters area. The process initially begins with the removal and protection of topsoil prior to construction activities. Once drilling is completed, restoration of the land to the original condition is carried out and the planting of species of grasses to aid the natural re-vegetation process. As part of the HSEC Policy, the Company will formalize its erosion control, topsoil management and re-vegetation practices into a formal Erosion Control and Revegetation Plan to support the establishment of these sound practices.



Management of Hazardous Materials (Fuel):



Fuel at the drill sites is currently stored in plastic drums with secondary containment systems provided. At the camp site, fuel is stored in 250-gallon containers fitted with secondary containment and covered. MSDS for all hazardous waste products at the camp are kept at the office building on site. Currently fuel is transported from the town of Yanahuanca to the camp site by means of dedicated and authorized fuel trucks. As part of the HSEC Policy, the Company will develop a Pollution Prevention Plan to formalize specific procedures for the storage, handling and transportation of fuel products and requirements in case of accidental spills.



Energy and Fuel Use:



Current supply of energy for the camp is obtained from a diesel generator (32 kW) with an additional generator available as backup. With regards to fuel consumption the Company uses approximately 2,000 gallons of diesel per month for all camp and vehicle use.



Noise:



Current noise generated from exploration activities is limited with the distance to any households or single potential receptors (such as local land owners) being several hundred meters to several kilometers away. Tinka will continue to monitor noise levels to ensure noise permissible levels are not exceeded in community receptors. At the drill sites, drilling operators and helpers are required to use hearing protection in areas of high noise levels.



Emergency Preparedness and Response:



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

Community Health and Safety:



The drilling activities at Colquipucro and Ayawilca are located a few kilometers from San Pedro de Pillao and Yanacocha communities. During exploration work, potential impacts from Tinka’s activities to surface and ground water, soil and air and, subsequently to human health, are limited and can be adequately managed through the establishment of the necessary EHS practices.



Diesel is procured, transported and handled by an authorized diesel provider from Yanahuanca located approximately 15 km from the camp. With regard to hazardous materials management, the Company has a hazardous materials storage protocol in place and a contingency plan to manage emergency situations.



Tinka hires experienced drivers with the required driver licenses to carry out their work. As part of the enhancement of its Management System, Tinka will formalize a road safety procedure in order to promote road safety among project personnel and communities. The procedure will require project drivers to be trained in defensive driving when necessary and inspections should be undertaken by the project OHS team.



Security Personnel:



Tinka employs local people to guard project facilities and equipment under the supervision of a Security Supervisor. There are no armed guards at the project site and the Company does not have an agreement with the public security forces. To date, there have been no incidents involving security personnel and the local community.



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

Peruvian regulations require the development of an Estudio de Impacto Ambiental Semi-Detallado (EIA-sd) to be approved by the Ministry of Energy and Mines (MEM) for any mining exploration work. As part of the EIA-sd, Tinka has undertaken a series of stakeholder engagement activities with the local communities to raise awareness about the Company, the exploration program and drilling activities, and the land access agreements with Yanacocha and San Pedro de Pillao communities.

Tinka is implementing a number of social and economic development projects through existing land use agreements with San Pedro de Pillao and Yanacocha communities where the Company is conducting exploration. The monthly workshops undertaken as part of the agreements implementation are also used to disclosure relevant information and to gather community members concerns.

In addition, Tinka maintains communications with members of the affected communities through the work of the community relations team. Tinka has an office in both communities and a dedicated permanent staff - comprised of a coordinator and 3 assistants - in contact with the local population. The team participates in community meetings (asambleas) to deliver information about the project and to provide clarifications when requested.

In accordance with the ESAP Tinka will formalize its engagement program to ensure that the local communities are kept up to date with the exploration program, manage community expectations with respect to employment opportunities and issues associated with land access and compensation, community development programs and environmental management. As part of this, Tinka will develop a Stakeholder Engagement Plan (SEP) and Communications Plan that describes the Company’s policies and procedures for consultation with all the relevant stakeholders and affected communities and disclosure of project information and documentation. The Plan will include Peruvian regulatory requirements and be consistent with the IFC Performance Standards. The key components will include (i) principles and process for identifying and prioritizing stakeholders; (ii) key stakeholders identified and prioritized for engagement; (iii) strategy and schedule for sharing information and consulting stakeholders during the exploration program; (iv) grievance mechanism for the affected community to receive and resolve complaints (see below); and (v) organizational roles and responsibilities for implementing stakeholder engagement activities (See ESAP Action # 7). The SEP and Communications Plan will be scaled to the project risks and impacts and development stage. The client will document all engagement activities to date and the process of engaging the communities during the development of the EIA-sd and implementation of the monitoring programs (including receiving, documenting and addressing feedback received during the impact assessment and incorporating into project design and strategy).

External Communications and Grievance Mechanism for Affected Communities:

The communities of Yanacocha and San Pedro de Pillao raise any concerns directly with the community relations team. As part of the ESAP Tinka will established a formal grievance mechanism to receive and facilitate resolution of affected communities’ concerns and grievances about the project (See ESAP Action # 7). The grievance mechanism will be scaled to the risks and adverse impacts of the project and will include methods to (i) receive and register external communications; (ii) screen and assess the issues raised and determine how to address them; (iii) provide, track, and document responses; and (iv) adjust the management programs, as appropriate. Tinka will inform the affected communities about the mechanism in the course of the stakeholder engagement process.

Ongoing Reporting to Affected Communities:

Tinka provides periodic newsletters to the affected communities (every 3 months) to report progress with the implementation of the land agreements and to disclose relevant information about the project. The Stakeholder Engagement Plan (see above) will include all ongoing and planned reporting activities to affected communities.

Tinka will make a copy of the ESRS and the attached ESAP available in the following locations: in Tinka Lima office and Tinka core yard facility for a period of 30 days starting on [IFC will fill out].

For further information, questions or comments please contact:Contact person: Fernando Alva Address: Irma Gamero de Planas 225 – Surco - Lima
Telephone: 51 1 241 1928Email: mailto:falva@tinkaresourcesperu.com

Contact person: Graham Carman
President and CEO (Australia based)Telephone: +61 423355469
Email: mailto:gcarman@tinkaresources.com

Contact Person: Mariana Bermudez
Company Secretary (Vancouver based)
Location: Vancouver, BC V6E 3V7 CanadaTelephone: +1 (604) 699 0202 Fax: +1 (604) 683 1585
Email: mailto:mbermudez@chasemgt.com

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Sign on to, and disclose upon approval by IFC on the Company’s website, a Corporate and Project-Specific Health, Safety, Environment and Community (HSEC) Policy that defines how the Company’s projects will be operated in line with the requirements of IFC’s Performance Standards, EHS Guidelines and Peruvian legislation appropriate to the level of activities. This will include broad commitments in principle for each potential stage of future phased development through exploration and development.	05/24/2015
Retain an experienced ESHS consultant to satisfaction of IFC to support the company with the development and enhancement of the necessary Elements/Programs and ESHS Management Plans/SOPs of the HSEC Policy which are aligned with GIIP to address existing environmental, social and health and safety risks form current exploration activities	01/25/2016
Develop a supplemental socio-economic baseline study, focused within the defined ‘project boundaries’ to include: (i) socioeconomic context of households; (ii) number of dwellings and other structures (such as wells, boreholes, fencing); (iii) land used for (subsistence) agriculture and farming; (iv) community resources such as water sources, pasture, woodland, medicinal plants, fisheries (if any); and (v) a description of how San Pedro de Pillao and Yanacocha communities assign land internally. The study will also map the legal boundaries of both communities.	11/25/2015
Develop a Land Acquisition, Compensation and Resettlement Policy Framework to outline the principles, guidelines and approaches that will be followed for temporary and permanent land acquisition and compensation activities in accordance with Peruvian legislation and IFC PS5 requirements.	05/25/2016
Carry out an environmental (including geochemical) site assessment of the existing historic mining areas within the Company’s concession to characterize the extent and nature of these areas.	11/25/2015
Hire an external social specialist, with experience in working with Indigenous Peoples in Peru, to conduct an assessment to determine whether the communities of San Pedro de Pillao and Yanacocha are considered IPs under the Peruvian legislation and/or PS7 criteria.	11/25/2015
Hire an external social specialist, with experience in working with Indigenous Peoples in Peru, to conduct an assessment to determine whether the communities of San Pedro de Pillao and Yanacocha are considered IPs under the Peruvian legislation and/or PS7 criteria.	03/25/2016
Develop Human Resource Policy and Procedures consistent with the requirements of Performance Standards 2 and requirements under the Peruvian Labor Law.	11/25/2015
Develop a grievance mechanism through which employees may raise their workplace concerns. The mechanism will establish the procedures for receiving, managing and addressing grievances promptly. The mechanism will allow for anonymous complaints to be raised and addressed.	11/25/2015
Retain an experienced institution to satisfaction of IFC to support the company with the design and implement a surface and ground water participatory monitoring program to identify existing water quality and quantity conditions in the area, communicating these to the local population and to serve as baseline for the future ESIA.	11/25/2015
Tinka will develop a Stakeholder Engagement Plan (SEP) that describes the Company’s policies and procedures for consultation with all the relevant stakeholders and affected communities and disclosure of project information and documentation. The Plan will include Peruvian regulatory requirements and be consistent with the IFC Performance Standards. The key components will include (i) principles and process for identifying and prioritizing stakeholders; (ii) key stakeholders identified and prioritized for engagement; (iii) strategy and schedule for sharing information and consulting stakeholders during the exploration program; (iv) grievance mechanism for the affected community to receive and resolve complaints and (v) organizational roles and responsibilities for implementing stakeholder engagement activities.	05/25/2016
Hire a qualified international consultant to satisfaction of IFC to develop an ESIA which is in alignment with IFC’s Performance Standards prior to mine construction and which is fully integrated into the Feasibility Study of the Project. ESIA to be publically disclosed for a minimum of 60 days prior to start of mine construction.	05/25/2019