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
PS5 does not apply as the there are no villages or community land within the mining concession and the project will not result in any physical or economic displacement. PS6 does not apply because there are no sensitive habitats, endangered species or protected areas recorded within the project area. PS7 is not applicable as there are no indigenous people in the project area. Equally, PS8 is not applicable because no site of significant cultural or historical value has been identified within the project footprint.

This is a category B project according to IFC’s Environmental and Social Review Procedure because the Environmental, Social and Health & Safety (ESHS) risks and impacts relate to expansion of an existing asset and are limited, largely site specific within the existing footprint and are adequately managed through implementation of appropriate mitigation measures. The project requires a public disclosure period of at least 30 days prior to consideration by the IFC Board.

The mine is a small existing operation and the IFC investment will fund the removal and rehabilitation of old tailings storage facilities and installation of new engineered facility coupled with a small increase in production capacity. A secondary outcome will be better energy and water efficiencies within the same surface footprint. The investment will not result in any significant new impacts. Pre-existing environmental, health and safety issues associated with the project include: occupational and community health and safety; dust control; waste management, including hazardous waste and management of mine residue deposits; water management; hazardous materials management and transportation risks on roads leading to the site. The company has mitigated these risks by commissioning and implementing a PS gap analysis completed by an international consultancy during 2014.

The main pre-existing social risk relates to managing community expectations and potential in-migration in a post-conflict society where local and regional government capacity is limited. The company will mitigate these risks through strengthening its community engagement and community investment initiatives.

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. IFC’s appraisal considered environmental and social management plans for the expansion project (and the existing operation) and gaps if any between these plans, IFC requirements and Tiger’s corporate policies. 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 the agreed Environmental and Social Action Plan (ESAP). Through implementation of these management plans and the ESAP the SEK project as well as any exploration or development activities of Tiger Resources are expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System



SEK manages the risks and impacts of the Kipoi operation through its Environmental, Social and Safety Management System. This is appropriate to current operation but will be updated to align with the nature and scale of the expanded project and for consistency with Performance Standard 1. The Tiger and SEK environmental, health & safety and community related policies and systems were developed in parallel and are fully aligned. The system includes the following elements;



Policy



Tiger / SEK will update and formalize their environmental, community and health & safety policies. Through these aligned policies the company is committed to conducting its business in a responsible and sustainable manner and maintaining a balance between the environmental and socio-economic priorities of all aspects of the operation as well as the priorities of the communities affected by its activities. Through its corporate social responsibility policy, Tiger is committed to being a responsible corporate citizen and strives to follow GIIP in maintaining its social licence to operate.



Identification of Risks and Impacts



The provisions of the national 2002 Mining Code require projects such as Kipoi to undertake an Environmental Impact Assessment (EIA) including an Environmental Management Plan (EMP). This was completed by a DR Congo based consultancy in 2008 and was updated in 2009 and again in 2011 to cover both Stage 1 and 2 of the project. The EIA includes a social section but does not cover health & safety. There are several differences between the DR Congo EIA requirements and the IFC Performance Standards. Therefore, IFC has assisted SEK in drafting the Terms of Reference and identifying suitable consultants for completion of a fully revised ESIA consistent with the IFC Performance Standards. Engagement of the consultants occurred during mid-2015 and the finalized ESIA is due for completion by mid-2016. The new ESIA will be subject to public consultation and disclosure in accordance with IFC policies. In the interim, an IFC Performance Standards gap analysis on the existing project has been undertaken and the company has developed this into an Action Plan which defines the mitigation measures which will be implemented to bring the current operations up to the level of GIIP and the IFC Performance Standards within an acceptable period. An Engineering & Costing Study (ECS) has also been completed during 2015 with assistance from independent consultants, this includes an environment section which aligns with the workstreams outlined above.



An external independent audit will be undertaken once the expanded project is in full operation to assess implementation of the revised ESMP.



Management Plans



SEK has developed both an Environmental Management Plan and a Corporate Social Responsibility (CSR) Management Plan which are being combined as an Environmental & Social Management Plan (ESMP). T
his comprises key plans and procedures that enable the company to maintain a good level of control over the risks at the site and are in accordance with national legislation. However, in order to achieve GIIP and meet the IFC Performance Standards for the project expansion an adaptive management approach will be followed whereby some additional plans and procedures will be developed with full implementation of an updated system anticipated by mid-2016 informed by the outcome of the revised ESIA process. The company is committed to implementing recommendations of the ESIA process and given that all construction is within the existing site, and that the key risks and costs have been identified as part of the ECS process, the adaptive management approach is considered to represent an acceptable risk.



Organizational Capacity and Competency



In order to support the above process, in late 2014, SEK engaged an Environmental Manager, a Social Manager and a Security & Safety Manager. All are highly experienced industry professionals and give the company a solid and competent foundation for its management of these functional areas. Some further strengthening of resources will be undertaken, in particular to provide adequate managerial coverage during times when these individuals take rotation breaks off-site.



Emergency Preparedness & Response



Emergency Preparedness at SEK is the responsibility of the Safety & Security Manager in conjunction with the key security contractor. The plan is based on four key elements: prevention; preparedness; response and recovery. For each of the potential emergency situations, plans and procedures to ensure that there will be appropriate and adequate response to any emergency incident have been identified. Emergency teams are in place with clearly defined roles for emergencies. As part of IFC’s investment, SEK will update and finalize an Emergency Preparedness Plan (EPP) and provide training to key personnel on site to provide 24-hour coverage for emergency response. Subsequent to the finalization of EPP, the company will schedule and conduct emergency drills regularly to identify potential areas for improvement. Records of these drills will be kept. It should be noted that no significant incidents have been recorded since the company started operating at Kipoi in 2011.



Monitoring & Review



DR Congo environmental legislation is broadly categorized into land use, natural resources and conservation, pollution related legislation and environmental management legislation. An annual environmental report to meet these legislative requirements is submitted annually to the authorities. This covers the following;



• Environmental incidents/accidents.

• Ground and surface water monitoring and results

• Environmental awareness programs and waste management

• Vegetation management and rehabilitation

• Topsoil stockpiling

• Ambient air quality and dust monitoring

• Onsite meteorological/weather monitoring.



• Environment Committee Meeting



Copies of such annual reports were provided to IFC for review. Data monitoring provided in these reports indicate good environmental performance with no material non-conformance with either national legislation or IFC guidelines. However, in order to meet GIIP some additional monitoring will be required for example further baseline data (eg: groundwater) which will be collected as part of the revised ESIA process while further regular monitoring is being implemented. The environmental manager is taking a progressive approach to monitoring which has included the purchase of a drone which is being used to monitor and photograph the site. It is planned to extend use of the drone to include remote download of monitoring data (eg: from boreholes).



A Corporate Social Responsibility (CSR) annual report is prepared and recent copies were reviewed by IFC. However, the 2014 gap analysis as well as IFC’s review identified both stakeholder engagement and community development initiatives that needed to be strengthened including increased monitoring. Although SEK has implemented a grievance system it will also be updated with better tracking and defined resolution times. These improvements will be defined in the strengthened ESMP.



Land Acquisition and Involuntary Resettlement



There are no villages or land used by the nearby permanent communities within the mining concession and thus the IFC investment will not result in any physical or economic displacement and thus PS5 is not currently applicable. The nearest permanent communities are all along the main Route Nationale (RN) with the nearest, Kangangbwa (850 residents), being about 9 km distant from the mine site. There is an artisanal mining village at Kileba railway siding (adjacent to the main railway line) which is within the concession (approximately 8 km from the site) although artisanal activity is currently minimal, and this village is not currently impacted by SEK operations.



SEK complies with DR Congo legislation when negotiating access to land. However, a new Land Acquisition Policy will be developed to define how any future land acquisition would meet IFC PS5, should such acquisition be proposed.



Biodiversity Conservation and Sustainable Management of Living Natural Resources



While no sensitive habitats have been identified within the project area to date, the Katanga copper belt features “copper clearings” which are areas with high levels of copper in the soil and which host certain rare flora. Two such species have been identified on a copper clearing in the area (but outside the concession). While SEK is not impacting this area, the company has contracted with Lubumbashi University for the provision of botanists and has contacted Kew Gardens in the UK and Liege University in Belgium for further advice on the conservation status of species within the mining area and is committed to apply the provisions of PS6 should any impacts be identifi
ed within the concession area. SEK is also undertaking flora mapping within the concession and will consider impacts on fauna as part of the revised ESIA process. A specific mitigation measure already identified is the provision of nets on the leach solution ponds to prevent potential bird fatalities.



The new tailings facility will require clearance of vegetation from an area of approximately 10 ha within the existing project area. Botanical studies of this area have been undertaken and no habitat of value was identified.



Cultural Heritage



Although no cultural resources have been identified in the working areas, the Company will prepare a “chance finds” procedure to be applied in the event of any accidental unearthing of paleontological/cultural relics.



Regarding PS5, 6 and 8 the project will be regularly re-assessed under these Standards during supervision and, should these PS’s become applicable, IFC will work with the company to implement appropriate mitigation measures.

Working Conditions and Terms of Employment



Standard employee working conditions and terms of employment are consistent with DR Congo regulations. As part of the project a formal HR policy and employee handbook will be developed to be consistent with PS2 requirements. On the job training and support for skill training are in place to support this commitment. SEK Camps and accommodation for staff are consistent with IFC Performance Standard 2 and the Guidance Note on Accommodation and are managed by an international camp services company. SEK has developed a local employment policy which includes the use of village committees headed by the Village Chiefs and which identify appropriate community members for employment. Of the local staff 352 are currently from the five nearest villages and all casual workers are locally hired.



Human Resources Policies & Procedures



During February 2015, SEK had 17 ex-pat staff, 276 local staff and 414 contractors for a total of 707 persons on site. All DR Congo legislation is complied with and there are five unions represented on site with freedom of association. The HR policy will include a disciplinary policy, conflict of interest policy, equal opportunities and harassment policy, a grievance mechanism as well as a whistleblowing procedure. A company Employee Handbook is also being developed compliant with local legislation and GIIP. SEK will ensure that all employees have an understanding of its grievance process, procedure and mechanisms, and that all employees will have access to the information via monthly workplace forum discussions and quarterly briefings.



SEK strives to ensure that the unskilled employees (both SEK and Contractors) are drawn from local communities. The local employment policy states that SEK will favor locally-hired unskilled labour over those from outside the region, as well as seeking to emphasize locally available materials and equipment that meet company needs, holding its consultants and contractors to the same standard whenever possible. Through a local hiring committee, coordinated by the Chief in the host communities, SEK is working closely with local authorities and other local stakeholders to pinpoint locally available personnel (either skilled or unskilled, depending on company needs vis-à-vis available local skills) and strive to spread the benefits of direct and indirect employment as broadly as possible in the local area. SEK will develop documentation to describe this practice which will also indicate metrics and evaluation criteria.



It is considered that the project may encourage in-migration, to minimize this SEK has developed an In-migration Strategy and is implementing this in several areas. This will include a census of local villages and quarterly meetings with village chiefs to discuss relevant issues. SEK will also undertake a baseline health impact assessment



Workers Organisations



Currently there is no collective bargaining agreement. SEK will n
ot oppose workers organizing themselves to defend their moral and material interests in accordance with the laws in force in DRC and those of the International Labour Organization (ILO).



Non-Discrimination and Equal Opportunity



The new HR Policy being developed will confirm SEK is an equal opportunity employer with no discrimination in hiring.



Retrenchment



SEK will develop a redeployment strategy for locally hired un-skilled labor to manage local expectations regarding employment. The company plans to reduce the number of expats it currently employs over a period of time and in line with the skills development programme and community commitments.



Employee Grievance Mechanism



SEK will ensure that all employees understand its grievance process and procedure and that all employees have access to a workforce grievance process that is consistent with the requirements of PS2, including provisions for anonymous complaints and an independent mechanism for logging and resolving complaints.



Occupational Health & Safety



SEK has been monitoring rolling LTIFR (Lost Time Injury Frequency Rate) which has been zero for the past 12 months (over 1 million man-hours) and rolling TRIFR (Total Reportable IFR) which reduced from 18 to 1.3 over the same period. The Head of Safety & Security intends to change to monitoring AIFR (All IFR) which is now standard practice in Australia, the rolling AIFR rate was under 10 in March 2015 having seen a continuous drop over the past year. These figures are all below the equivalent industry averages in Australia. SEK has also implemented an employee HIV intervention programme. A safety induction is required for all staff and visitors prior to site entry, with variations in detail depending on the specific activities anticipated.

Housekeeping and site management at the existing project are compliant with DR Congo legislation and generally follow good practice. However, in some areas, the company has committed to mitigation measures in order to bring the operation up the level required to meet the IFC Performance Standards. As part of the process to identify these measures, SEK is developing an Environmental Risk Register. Proposed actions are outlined below.



Resource Efficiency



The only watercourse on the site is the Sofumwango River on the southern perimeter of concession some 7 km from the mine site. Water needs are met from this source and minor boreholes, permitted by the authorities at a rate of 200 m3/hour. The site is designed for zero water discharge with waste water recycled for use in the plant. A key gap in data relating to the current operation is a baseline of water resources. Evidence from the existing boreholes on site and the water level in the open pit suggests there are no near surface aquifers with the shallowest being some 60 m below surface. A detailed hydrological survey is being undertaken as part of the revised ESIA from which a detailed operational water balance and water utilization management plan for the project expansion will be prepared.



A leading international consultancy has undertaken kinetic / static column testing for Acid Mine Drainage (AMD) potential from drill cores, pit material, waste materials and stockpiles. Any acid generating material identified will be appropriately segregated but it should be noted that the virtually all broken rock is on the leach pad which is fully lined and contained.



Potable water for site personnel is currently provided in bottles but a potable water plant including UV filtration is being installed to reduce the use of plastic bottles.



With regard to power, the project is currently served by 11 containerised 1 MW generators for which CO2 equivalent emissions are tracked and monitored (approximately 1500 tonnes CO2 for every 1000 tonnes of copper produced). The national power provider SNEL is currently not in a position to provide reliable power but an interesting energy efficiency joint venture with Megatron (South Africa) is aiming to resolve this. Megatron’s business is power optimization and they are engaged in a Government supported programme to replace light bulbs in Lubumbashi, Likasi and Kolwezi with low wattage fluorescent bulbs. It is anticipated that the power demand saving will be in the order of 50-80 MW and that this will enable SNEL to supply the power requirements of SEK which would be able to reduce or eliminate its reliance on generators.



Pollution Prevention



SEK produces a range of waste typical of a small mining operation. This includes small amounts of office and household solid waste and non-hazardous industrial waste (paper, packaging material, kitchen waste, building rubble, non-hydrocarbon filters, etc.); salvageable/recyclable material (scrap metal, pipes,
used tires, empty drums and scrap wood, etc.); hazardous waste (used hydrocarbons, expired chemicals, paints, lead batteries etc.); medical waste and waste water. All waste is managed according to the company’s Waste Management Plan which is currently being updated and incorporated in the ESMP. The plan is being developed according to GIIP incorporating concepts of reduce, reuse and recycle. There are procedures in place to cover the various waste streams although the lack of any recycling or hazardous waste disposal sites within the DR Congo has meant that the company has had to develop some on-site disposal facilities (eg: a medical waste incinerator has been installed).



SEK will install further appropriate waste management infrastructure as part of the Waste Management Plan. This will include a waste management facility with separate compartments for different types of wastes, i.e.; an unlined non-hazardous waste landfill and a salvageable material yard. Used oil, lubricants, cotton rags and expired chemicals and chemical containers will be returned to the suppliers and recycled/reused as appropriate. The facility will be designed and constructed in accordance with the relevant national and international guidelines, and will include measures for storm-water management and dust suppression. Diesel fuel is supplied and managed by a reputable international oil company. The fuel is stored in above ground storage tanks with adequate bunding.



Kipoi Stage 1 produced tailings from the DMS facility and these were deposited in Tailings Storage Facility (TSF) 1 which is an engineered facility within the plant site boundary. The facility was built with laterite walls and although no longer in use, further engineering work is planned to provide better drainage and a spillway until it is reclaimed. Excess water that collects in TSF 1 is currently pumped out into the process water pond and there appears to be adequate freeboard to cope with any extreme rainfall event. Below TSF 1 lies TSF 2 which has a larger catchment area. The company will install automatic warning systems for water level as well as a spillway. In addition the impoundments will be equipped with lifebelts and emergency egress ladders. The company has committed to independent technical review of both these facilities to confirm their safety until they are reclaimed as part of the expansion project.



The key hazardous material used is sulphuric acid for the leach pads, this is delivered by road with planned consumption of approximately 700 tonnes / month. Diesel Fuel is also delivered by road with approximately 1.5 m litres consumed per month. Both materials are appropriately stored and used on site with appropriate staff training and MSDS available.

Community Health and Safety



As noted above the nearest communities are some 9 km distant and there are limited direct interactions between these communities and the project. Road traffic impacts resulting from company operations present a risk that is managed through strict driving rules for all employees (eg: driving within all posted speed limits, use of seat belts, no after dark driving and no cell phone use while driving). The role of the Safety & Security manager includes responsibility for emergency response plans as noted under PS1.



Security Personnel



Mine security is primarily managed by a reputable private firm that provides unarmed guards for all roles. In addition, the Government requires the presence of Mines Police, they are armed although the contingent at SEK is small, consisting of 24 people and each is accompanied at all times by one of the private firm’s unarmed guards. All security staff have been trained in the Voluntary Principles. Training has also been extended to the Mines Police.



Mine closure and rehabilitation



A topsoil register has been prepared along with vegetation mapping across the concession. A nursery has been established and has to date produced some 50 000 seedlings of 6 local species with an 80 % success rate after planting. The Waste Rock Dump and other available slopes are being rehabilitated with these plants. SEK is also undertaking bulk composting using waste organic matter. A conceptual closure plan has been developed assuming that the preferred final post-closure land use will be return to Miombo type dry forest commensurate with the surrounding land uses. Currently no closure-specific commitments have been made to stakeholders. However, in accordance with GIIP, stakeholders will be involved in the closure planning process throughout the mine life. SEK will upgrade its conceptual mine closure plan to a comprehensive Mine Closure and Rehabilitation Plan based on GIIP and in accordance with the relevant in-country legal requirements and IFC Guideline requirements. The mine closure will include closure costs provisions for immediate closure and life of mine closure, and decommissioning and restoration costs. It will also include the funding mechanism.

Stakeholder mapping and analysis

The project site is in an area of relatively low population density with most of the nearby communities being adjacent to the Route Nationale. There are five villages with which SEK has undertaken stakeholder engagement, Kangangbwa (the nearest - approximately 9 km distant), Luafi, Katanga, Bungu Bungu and Lukutwe. Stakeholder mapping has been undertaken and has identified the Village chiefs / Grand Chef de Katanga, Civil Society / NGOs, education sector, religious leaders, youth, women, SEK employees, community groups, agriculturists, and the health sector as key stakeholders. Engagement is managed through a communications plan that defines the scope and frequency of meetings with local communities and officials as needed and as required by DR Congo legislation. The company is working with IFC to strengthen this plan, in particular so that it provides a process for individual community members to express their views and ask questions. As well as adopting IFC standards SEK has also taken the additional step of commissioning two external studies to provide recommendations to improve their stakeholder engagement.

SEK has displayed a strong commitment to GIIP in respect of its implementation of a series of social support measures locally and regionally. The Company’s management is seeking to adopt best practices in its social systems and community investments and has also asked for IFC’s advisory services support. As part of the due diligence process, IFC facilitated a two-day Strategic Community Investment (SCI) workshop at the Kipoi site in July 2015. The workshop has set the foundation for potential ongoing advisory services and a second workshop is proposed for November/December 2015.

IFC has assisted SEK in identifying issues and defining mitigation measures to strengthen its community activities. These were identified jointly with SEK during the two IFC visits which included the 2-day SCI workshop, a community meeting in the village of Kangambwa and a meeting with Government representatives.

Stakeholder Engagement Plan

SEK’s stakeholder engagement has been at the level of village chief and his advisors plus various community associations. Examples of some of these associations are (i) Action Feminine Chrétien (AFC) a sub-group of the Mouvement Ouvrier Chrétien de Congo (MOCC) which organizes monthly training on life issues, agriculture, tailoring, soap making and literacy; (ii) Union des Mutuelles de Santé du Congo (UMUSAC), a sub-group of MOCC, a health co-operative; (iii) COPAGEL, a farmer’s cooperative, and (iv) COOPEC a savings cooperative. These groups all share a link with MOCC and SEK will need to expand and diversify dialogue to community members that are not a part of an association as it is not clear how representative MOCC is of individual villagers.  There has also been some confusion over coordination between MOCC and SEK as both are supporting the same groups without clear definition of responsibilities. For dissemination of information about the project, SEK has also installed communication boards at nearby communities.

More broadly, the Grand Chef Katanga (GCK) has also established a Regional Committee to serve as an interface between the communities in Katanga and various mining companies including SEK. There is a need to clarify the roles of the GCK Regional Committee and of SEK, since the company will need to be able to continue engaging directly with communities rather than working through the Regional Committee. During September 2015, SEK held two meetings with the GCK at which it was proposed that village level working groups be formed and these groups then report to the GCK Regional Committee. The GCK has accepted this proposal and SEK is working on establishment of the process.

In addition, SEK has commissioned reports from international consulting firm, Critical Resources, and a local NGO, Détectives Experts pour les Droits au Quotidien (DEDQ), to better understand project stakeholder issues. The Critical Resources study looked at Kipoi in a regional and national context while the DEDQ study focused on the five villages in the vicinity of the SEK project: Kangambwa, Luafi, Katanga, Bungu Bungu and Lukutwe Katanga I, Katanga II, Kangambwa, Luktwe, Lwafi and Bungu Bungu. Both reports were finalized during 2015 and found that the communities were supportive of the project due to social investments but highlighted the need to broaden and deepen stakeholder engagement at the village level.

SEK has committed to the following actions;

Establishment of a framework to define community-SEK interactions and the development of appropriate measurement and reporting on both stakeholder engagement and community development programmes;
Strengthening of SEK’s processes to understand the needs and concerns of nearby communities and whether key stakeholders have been correctly identified;
Definition and communication of SEK’s role, commitments and obligations to the communities around the Project. This will include multi-stakeholder engagement to ensure community needs and concerns are incorporated. This is considered an important element of building understanding and trust between SEK and its stakeholders.

Consultation and Grievance Mechanisms

The SEK grievance mechanism to date has been largely informal with SEK community officers being informed about grievances during consultation at village level. In order to improve the responsiveness of SEK to community complaints, the company has begun the implementation a rapid assessment reporting process that will highlight issues to company management as they arise. The key elements of this will be;

Establishment of a community consultation mechanism that includes capacity building for community representatives to identify and communicate stakeholders’ concerns and priorities to the company;
Development of a long-term community strategy based on outcomes of the consultation mechanism, the use of participatory learning for action/participatory rural appraisal tools, and the planned social impact assessment work (as part of the revised ESIA);
Enhancement of the Community reporting process by increasing the frequency of reporting from annually to monthly and using the reports to show progress against the Company’s community strategy and long-term objectives.

Existing Community Development Programmes and Strategy

SEK has made several social investments in the area surrounding the project as well as regionally. This includes a commitment to allocating 0.5 % of SEK annual revenue to community development projects. Some examples of SEK’s social investments include:

Community wells including a water pump in Kangambwa;
Construction of a school and clinic in Kangambwa;
Partnering with CURE who are a large provider of donated medical supplies and equipment to developing countries to supply medical equipment to various clinics in the Katanga region plus support with a maternal health programme
Agricultural development projects for farmer’s cooperatives, women’s associations and youth associations in four villages plus irrigation, material and equipment
Provision of seeds, material and technical support for AFC’s agricultural activities although in 2015 there have been challenges in securing access land to rent. AFC also supplies fruit & vegetable to SODEXO, SEK’s camp catering contractor.
Technical support to COPAGEL

SEK is engaging with the relevant regional government authorities for formal transfer of the school and clinic constructed by SEK to the regional education and health systems, this is to address challenges relating to the operational funding of these facilities. In discussions with SEK, the Ministry of Health has identified that UMUSAC will be responsible for managing the clinic.

Finally, SEK is working with the Chamber of Mines in Lubumbashi on development of a Corporate Social Responsibility guide that will help develop best practices for mining companies operating in the region.

Ongoing reporting to affected communities and future strategic community investment

The development of the SCI workshop agenda was based on the IFC E&S appraisal site visit, review of recent CSR Reports and feedback from the SEK community team. The objective of the workshop was to facilitate SEK’s development of a future community investment strategy, create internal understanding and alignment within the company and share IFC’s knowledge of industry trends & best practices. The workshop considered SEK’s stakeholder analysis and an analysis of the existing community investment programs. The key outcomes were as follows;

Commitment to development of a process to ensure that SEK’s community development activities are designed and coordinated with representation from a wider group of stakeholders. This will include a process for identifying opportunities for joint activities and the related processes of partner selection/due diligence and formalization of multi-stakeholder engagements;
Establishment of formal procedures covering individual community activities i.e. exit strategy, results measurement framework and vetting against project selection criteria to ensure strategic relevance of the engagement;
Evaluate staffing needs of SEK community team in order to ensure requisite skills and experience.

While there was general agreement on the key stakeholders, SEK will focus on consistency of communication with stakeholders especially those identified as priority stakeholders. IFC is also discussing additional advisory services with SEK to facilitate development of a comprehensive community investment strategy.

In addition to longer term objectives, SEK has identified some short term measures such as resolution of the operational funding for the Kangambwa school and clinic which is considered as a priority. Specifically for the school (or any other future education projects), SEK will develop a formal written agreement with the community, national government and other relevant parties which clearly delineate SEK’s exit strategy, teacher transport issues, assessment of particular education needs of the community that will benefit from the school, mechanism for stakeholders to provide feedback on the education project, identification of opportunities for community participation in project (i.e. school maintenance) and the indicators to be tracked and used for evaluation purposes (these should be gender disaggregated). For any future SEK investment in the education sector, the company will assess and align with local/regional plans for development including assessment of population influx attributed to school’s establishment and any associated pressures on community infrastructure.

SEK’s current agriculture programme will also be expanded through a joint-venture with the UK government and the international NGO, Adam Smith International. This will enable SEK to improve the quality of the programme as well as broaden its reach to about 500 farmers.

SEK will make a copy of relevant documents including as appropriate the ESRS and the attached ESAP available in the following locations in Lubumbashi and near the project site for a period of 30 days. Key documents will also be available at the following link http://www.tigerresources.com.au/environmental

La Société d’Exploitation de Kipoi
8935 Avenue Tiger, Q/Kimbeimbe, Commune Annexe
République Démocratique du Congo

SEK Temporary Office
Adjacent to Police Station and Chief’s Office
Bungu Bungu Village

For further information, questions or comments please contact:

Mr Brendan Moseley
General Manager
Email: mailto:bmoseley@tigercongo.com
Tel: +243 848 429 995

Broad Community Support is not applicable for this project

Kipoi Copper (36313) Appraisal Disclosure Snapshot – Version 4
Description	Anticipated Completion Date
1.       SEK will complete a revised ESIA including an ESMP for the Kipoi Project that is consistent with the IFC Performance Standards. The ESIA will be submitted to IFC for review and will be publically disclosed in accordance with IFC policies. The ESMP will include compliance criteria and the location of compliance points for physical, chemical and biological target limits for the expanded operation.	31-Jul-2016
2.       SEK will fully implement the revised Environmental & Social Management System including revised policies	31-Dec-2017
3.       SEK will establish a procedure for coverage of managerial off-site rotations with defined roles for Acting Environmental, Community and Security and Safety Managers	31-Oct-2015
4.       SEK will engage an independent geotechnical specialist for review and ongoing monitoring of the SEK Tailings Facilities to demonstrate that they meet IFC mining guideline provisions. The frequency of inspection to be determined by the initial risk review.	31-Dec-2015
5.       SEK will install water level monitoring alarms in all containments without existing spillways and install spillways for all Tailings Facilities during next shutdown	31-Dec-2015
6.       Establish a framework to define community-SEK interactions and the development of appropriate measurement and reporting on both stakeholder engagement and community development programmes	31-Jul-2016
7.       Strengthen the current community grievance mechanism to facilitate identification of material issues relevant to individual stakeholders, and development of a system to track Company response to reported grievances	31-Jul-2016
8. Establish an accrual funding mechanism (eg: escrow account, sinking fund) for the a Mine Closure & Rehabilitation Plan and include details in the ESMP.	31-Jul-2016
SEK will implement a time bound action plan agreed with the IFC, principally to address Environmental and social risks related water management at the tailings and process water facilities. This will include an Emergency Water Management Response Plan (“EWMRP”) that is consistent with IFC Performance Standards, WBG General EHS Guidelines, and Mining EHS Guidelines, as appropriate for the context at the Kipoi mine site and as per good international industry practice, as well as necessary infrastructure investments to ensure it can be actioned. The Engineer of Record will provide oversight, opinions, or a review and sign-off on all relevant actions, as agreed by SEK with the IFC.	31-Dec-2019