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

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
PS 5 – Land Acquisition and Involuntary Resettlement
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
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 Roxgold’s area of operations. PS7 is not applicable at this stage as there are no indigenous people in the project’s area of influence. Equally, PS8 is not applicable because no site of significant cultural or historical value was identified within the project footprint. (Please refer to Identification of Risks and Impacts under PS1 below for information on PS8).

This is a Category A project because it has significant environmental and social (E&S) risks and impacts which must be managed in a manner consistent with IFC’s Performance Standards (PSs). The key E&S issues include economic resettlement and livelihood restoration, surface and ground water resources, dust and other emissions, use of hazardous materials (cyanide), non-hazardous and hazardous waste management, security, labor, community health and safety, potential population influx, strategic community development and stakeholder engagement.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Policy: Roxgold has a well-documented environmental and social policy. Through this policy the company is committed to conducting its business in a responsible and sustainable manner and maintaining a balance between environmental and socio-economic priorities of all aspects of the company as well as the priorities of the communities affected by its activities. There is also a health and safety policy in which the company commits to provide a safe and healthy work environment for its employees. Through its corporate social responsibility policy, Roxgold is committed to being a responsible corporate citizen and strives to follow best corporate governance practices in attaining its Social License to Operate.

Identification of Risks and Impacts: Roxgold commissioned a Burkinabe based consulting firm to prepare an ESIA in conformity with Burkina Faso environmental law and regulations as well as the IFC PSs and the World Bank’s Environmental Safeguard Policies. The final three-volume draft ESIA (which includes an Environmental and Social Management Plan - ESMP, a Monitoring Plan, a Stakeholder Engagement Plan and a Grievance Mechanism) including a Resettlement Action Plan (RAP) was submitted to the Burkina Faso Ministry of Environment for approval on June 10th, 2014.

The ESIA was reviewed against the World Bank Group operational policies, IFC PSs and the Equator Principles III (EPIII) by an Independent Engineer (IE) on behalf of an international finance services company to assist in evaluation of the project in connection with a proposed financing. The review, which was produced in August 2014, culminated in a detailed analysis of the project compliance against EPIII and an EPIII action plan. The action plan also considered the project status and alignment with IFC PSs. Some of the corrective actions in the action plan include the design and implementation of an Environmental and Social Management System (ESMS) for the project, for both the construction and operation phases, enhancing EHS capacity, consideration of vector borne diseases, and independent monitoring etc. Roxgold is progressively implementing the action plan. Overall, however, the review found that the project ESIA is broadly compliant with EPIII (and by inference the IFC PSs) and the project has controllable impacts, and presents manageable risk. No major environmental issues or fatal flaws were noted.

No regionally or nationally significant cultural sites have been identified within the Roxgold concession. However, three “ethnographic” and one archaeological site have been identified within the mining permit perimeter. In addition, there is a “sacred site” known as Sinle, and a graveyard of fourteen artisanal miners noted in the ESIA located within the footprint of the project area. All of these sites are of local importance only. They have no official protection status. None of these sites will be destroyed or disturbed by the mine itself. They have already been fenced off and mar
ked. Roxgold has committed to agree with local communities on a policy to access these sites. In addition to this, and to manage unexpected finds during construction activities, Roxgold has developed and is implementing a chance finds procedure, in accordance with PS8.

Management Programs: Roxgold is currently developing an ESMS which is based on its policy, ESIA and legal register. The ESMS will be aligned with requirements of ISO 14001 and OSHAS 18001. An aspects and impacts framework has been developed whilst objectives and targets are still being developed. In addition to this, the company is currently developing a broad range of appropriate policies and procedures aimed at ensuring that the project is implemented in compliance with good international industry practice (GIIP) and the company’s commitments with respect to its environmental and social obligations. These documents outline actions and aspects to be considered, environmental and social sensitivities associated with potential land disturbance, waste minimization and management, monitoring and mitigation measures, health and safety, and community interaction, etc. These policies and procedure documents provide appropriate and applicable guidance for the project and form the basis on which detailed standard operating procedures will be developed.

Some of the specific procedures currently at different stages of development include waste management plan, water sampling, spills procedures, dust control on access roads, land clearance, land erosion, etc. Given that construction is already under way Roxgold will be required, as part of an IFC investment, to expedite the finalization and implementation of key ESMPs such as Construction Management Plan; Traffic Management Plan; Occupational Health and Safety Plan; Emergency Preparedness and Response Plan; etc. The company will also be required to ensure alignment between its ESMS and those of its contractors. This is stipulated in the ESAP.

Organizational Capacity and Competence: Roxgold’s CEO has overall responsibility for E&S for the company. However for the project site, the General Manager has overall responsibility for E&S issues. The General Manager is supported by a Country Manager, Project Manager, CSR Manager, Procurement Manager, Security Manager, Processing Manager and Mining Manager. There is an Environmental and Community Relations (CR) Coordinator who reports directly to the Country Manager and by dotted line to the General Manager. The Environmental and CR Coordinator is supported by a CR Officer, two assistant CR, a senior Environmental Technician and an Environmental Assistant. There is also a Safety Coordinator who reports to the General Manager and oversees the site medical clinic. There is provision in the organogram for two Safety Officers, each dedicated to the mining and milling operations respectively, to support the Safety Coordinator.

Roxgold’s management team values a relationship with IFC in in assisting th
e company to carry out its mine development in line with IFC’s PSs and GIIP. The team has extensive experience in the sector, ranging from project acquisition, through exploration and resource definition, to financing and production. As part of IFC’s investment, the company has agreed to strengthen its Environmental, Health and Safety (EHS) and community relations capacity and to engage additional EHS and CR consultants, with international experience in the application of IFC’s PSs and GIIP in the mining sector to assist with the finalization and implementation of key environmental and social management plans discussed above, train and build the capacity of Roxgold’s team. The EHS and CR specialists will support the above-mentioned Roxgold project team in consolidating the EPIII action plan, the ESAP and related corrective action plans arising from the various audits and gap analyses into a single time based action plan. This is stipulated in the ESAP. The company is also committed to fill the vacant EHS positions with suitably qualified and experienced personnel.

Emergency Preparedness and Response Plan (EPRP): As discussed under Management Programs above, the EPRP for the project is currently being developed with input from the key contractors. A draft EPRP based on the four elements, namely: prevention; preparedness; response; and recovery has been produced. The draft EPRP, which is based on GIIP, identifies potential EHS risks that could result in emergencies at all of Roxgold’s operations. 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 currently being put in place with clearly defined roles for emergencies. As part of IFC’s investment, Roxgold will finalize its EPRP and provide training to key personnel on site to provide 24-hour coverage for emergency response. Subsequent to the finalization of EPRP, the company will schedule and conduct emergency drills regularly to identify potential areas for improvement. The drills will also be undertaken to ensure that all site personnel are conversant with the EPRP procedures. Records of these drills will be kept. No significant incidents have been recorded since the company started operating at Yaramoko.

Monitoring and Review: Once developed and implemented, the effectiveness of the EHS system including procedures and programs, will be subject to continuous monitoring and review, in response to changing circumstances as well as internal practices. This will include regular internal EHS inspections performed by the EHS officer and external EHS legal compliance audits performed as appropriate by various government departments. The audit reports, incorporating corrective actions, will be submitted to relevant operations senior management teams who, together with the EHS officer, will be responsible for implementation of all corrective actions. Roxgold’
s senior management will review and evaluate the system on a regular basis.

Currently, monitoring and reporting to the government is strong on EHS issues though will need to be strengthened as with regards to social matters, in particular the reporting of community impacts and grievances. The internal management system will need to be modified with monthly operational reports to provide updates on the consultation process and a monitoring mechanism for resolution if grievances.

In addition to the above, a significant amount of environmental monitoring work is currently ongoing. This includes water quality (groundwater and surface), groundwater levels, vibration and noise, dust, suspended particles, pm10 and pm2.5 and fauna. The company also has a weather station on site.

Artisanal-Small Scale Miners (ASM): While Burkina Faso’s mineral resources are relatively untapped, historical documentation of artisanal-small scale gold mining in the country goes back to the late 1800s. It has become a particularly important part of the economy in the past three decades, following the devastating Sahel drought of the 1970s - 1980’s and the sector today is well established, with thousands of sites across the country. It is usually informal and unauthorized, characterized by hand tools, manual labor, rudimentary production and undeveloped processing techniques.

As the first step, Roxgold sought to deepen its understanding of the history, context and nature of ASM in the Bagassi area. The Burkina Faso Mining Code states that artisanal mining, while not requiring a mining title, does necessitate an official administrative authorization, bestowed on either an individual or legal entity. However, despite this sector formalization, the costs, time and resources necessary in the acquisition of such a short-term authorization make it tedious for often illiterate, itinerant or illegal miners to register.

Though the ASM activities in the Yaramoko concession are, like many in Burkina Faso, unauthorized, informal, illegal and unsustainable, the company acknowledges that this is an important livelihood source for the population of Bagassi commune. Using a multi-stakeholder approach and well-informed risk mitigation, Roxgold seeks to appropriately manage ASM relationships to achieve business and development goals, minimize broad-ranging negative impacts with targeted social development initiatives and create a secure environment for both company operations and surrounding ASM activities.

Understanding that the 55 Zone is a significant ASM site on the concession, Roxgold has developed an ASM action plan recognizing the importance of generating a comprehensive management strategy in advance of the development of the Yaramoko Gold Project at the 55 Zone. Guided by both Roxgold’s own stakeholder engagement and philosophies from the International Council on Mining and Metals (ICMM), the IFC’s CommDev and Communities and Small-Scale Mining (CASM), this document presents
an update on the outline of the current state of activities and the company’s related engagement strategies. The focus of this updated issue will continue to be on the 55 Zone. Roxgold’s broader, future ASM management is beyond its scope and will be further elaborated in a later version.

While there are only a few established artisanal mining sites throughout the Yaramoko concession, there are remnants of ASM activity and isolated pits scattered throughout the area. Roxgold has inventoried a total of about 3 000 pits across the exploration permit, over 80% of which are non-active, varying between 50 centimeters and 30 meters in depth.

Roxgold will facilitate and maximize a transition to alternative sustainable livelihoods wherever possible, including to mining-related and agricultural sectors, in concert with Roxgold’s community development initiatives. Acknowledging that ASM will remain ongoing in the area and is a valuable livelihood source, Roxgold seeks to continue to co-exist side by side in harmony with the existing community, working at arms-length but addressing the concerns, needs and interests of this stakeholder group. This responsibility will rest largely in the hands of the Community Relations Department, supported by the Corporate Social Responsibility Manager, with collaboration from the General Manager and other Yaramoko project staff as necessary. Further, the team will continue to strategize and seek guidance based on philosophies and case studies of respected international bodies, including the ICMM and the IFC’s CommDev.

In April 2014 an agreement was reached with the landowners of Zone 55 and the local Association of ASM to fully liberate Zone 55 by mid-June 2015 and ensure no more ASM activities at that location.

Human Resources Policies & Procedures: Roxgold currently employs approximately 120 direct and 230 contractor staff. The company has contracted Global 24-7 Consultant to develop Human Resources (HR) policy and management forms. The policy should 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 will also need to be developed and will need to be compliant with local legislation and best practice. Roxgold 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.

Roxgold reports that 100% of the unskilled employees (Roxgold and Contractors) are Burkinabe nationals. The Local employment policy states that Roxgold will favor locally-hired unskilled labor 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. For all unskilled labor, Roxgold’s local hiring targets are as follows: 80% immediate vicinity of the mine; 10% regional; and 10% national. Through a local hiring committee, coordinated by the host communities, Roxgold 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. Currently there is no documentation to describe this practice or indicate metrics or evaluation criteria.

Working Conditions and Terms of Employment: Standard employee working conditions and terms of employment are consistent with “Arrêté No. 2007/MTSS/SG/DGT/DER/ fixant les modalités d’application de la semaine de 40 heures dans les établissements non agricoles”. The future HR policy and employee handbook will need to also be consistent with PS2 requirements.

On the job training and support to skill training are in place to support this commitment. Roxgold is funding an apprenticeship program since January 2014, in order to build the capacity of the local youth in specific mining sub-sectors (currently almost all those who do this work are expatriates) for Roxgold needs and in line with future needs in Burkina Faso''s mining industry. Twenty young people from the various villages in the project area are currently taking a two-year training program in Ouagadougou and other mining sites in the country; their first year was completed with the South African entrepreneur, Group Five, and they are now completing the remainder at the Regional Professional Training Centre of Zinaire (CFPR-Z), also used by other mining companies in Burkina Faso for employee training an
d skills development. In addition to this, the company plans to support the education sector in a broad sense through the funding of certain educational activities (scholarships, teacher training, literacy, etc.). For example, Roxgold has a scholarship program already underway for primary school students and this program has just completed its second year.

Camps and accommodation for permanent non-local staff run by Roxgold are consistent with industry good practice and are managed by an international camp services company active across multiple countries.

Workers Organisations: Currently there is no collective bargaining agreement. Roxgold will not oppose workers organizing themselves to defend their moral and material interests in accordance with the laws in force in Burkina Faso and those of the International Labor Organization (ILO).

Non-Discrimination and Equal Opportunity: The new HR Policy being developed will need to confirm Roxgold is an equal opportunity employer, does not discriminate in hiring.

Retrenchment: Employment is anticipated to decrease Q2 2016 onwards as construction activities come to an end and short term contracts are completed. Roxgold will need to develop a redeployment strategy for locally hired un-skill 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 program and community commitments.

Grievance Mechanism: Roxgold 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: Roxgold is currently developing a Health & Safety Management Plan (HSMP) consistent with its OHS policy briefly described under the PS1 above. The HSMP framework, which is consistent with GIIP, clearly defines roles and responsibilities, business partner management, health and safety process implementation, objectives and targets, general safe work practices, personal protective equipment (PPE) etc.

The majority of the labor force at Yaramoko are contractors - local, national and international. Health and Safety for these contractors is specified under the business partner management of the HSMP. Business partners and service providers whose operations or services fall under Roxgold control or supervision undergo a pre-award evaluation as part of the procurement and award process which includes the requirement for them to develop an approved and appropriate HSMP aligned to Roxgold’s HSMP and relevant to their scope of works. Roxgold’s Safety Coordinator, in consultation with the General Manager, is required to carry out an assessment to determine the potential business partners’ ability to meet H&S performance requirements and s
tandards. The company will finalize and implement its HSMP as stipulated in the ESAP. In addition to this, based on the OHS audits of an Independent Engineer on the ground, Roxgold and the contractor will close any identified gaps in compliance with labor practices of IFC Performance Standard 2 and the WBG EHS Guidelines.

PPE 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. The company has not recorded any serious accidents since commencing exploration at Yaramoko and OHS performance has been consistent with the international gold sector. The company is committed to achieve zero injuries and zero harm at all times in its operations.

Resource Efficiency: As noted under the project description above, electrical power supply to the mine will be obtained from the national grid. A 4 km 90 kVA line will be constructed from the grid to the mine and stepped down to 11 kVA for reticulation around the operations. This grid electricity supply will be backed up by standby generators. About 130 000 liters of diesel fuel will be kept on site. This fuel will be used in the gensets, mine fleet of light vehicles, mining equipment, and trucks, etc.

Water for the mine and processing will be sourced primarily from the WSD and supplemented from the underground mining dewatering activities. The WSD is the main collection and storage facility for clean raw water on site, and is designed to store up to about 200 000 m3 of water at the maximum operating level. The WSD is intended to be recharged through rainfall runoff from the catchment and groundwater supply on site. The design of the WSD was based upon comprehensive hydrological studies commissioned by the company. A site water balance model was also developed for various wet and dry rainfall conditions for selected operational years. One of the key conclusions from the water balance modelling is that there will sufficient year-round provision of process water for the project without impacting the local community. Both the design of the WSD and the water balance were reviewed by the IE as part of the previous project finance process of other lenders and were found to be adequate. Water for potable use will be obtained from designated boreholes and treated at a water treatment plant to be located at the camp.

Pollution Prevention: Roxgold will produce a wide range of waste from its operations. This includes 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, cyanide boxes, paints, lead batteries etc.); medical waste; waste water; and top soil and overburden. All waste will be managed according to the company’s Waste Management Plan (WMP) which is currently being developed and will be incorporated in the ESMP. The WMP is being developed according to GIIP incorporating concepts of reduce, reuse and recycle.

As stipulated in the ESAP, Roxgold will install appropriate waste management infrastructure as part of the WMP. This will include a waste management facility (WMF) 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 rugs and small quantities and expired chemicals and chemical containers will be returned to the suppliers and recycled/reused as appropriate. There will also be an incinerator for medical waste; a packaged sewage treatment plant; and a top soil and overburden
stockpile. The WMF 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.

The packaged sewage treatment plant will be installed and used for the treatment of sewage from the site camps during the construction phase and all toilet facilities during the operational phase. All sewage water will be treated before the treated effluent is pumped to the TSF. The sewage treatment plant will be designed and operated to meet the WBG EHS Guideline for discharge of wastewater.

Diesel will be supplied and managed by a reputable international oil company. The fuel will be stored in above ground storage tanks. The above ground tanks will be installed with adequate bunding to collect any inadvertent spills.

Roxgold is committed to the systematic management of all of its mining and mineral processing waste (i.e. waste rock and tailings) in a consistent, environmentally sustainable and safe manner. Waste rock will be disposed of in the mine or used as backfill. In addition to this, results of the acid rock drainage test work show that the majority of waste rock can be classified as benign, i.e. non-acid forming material. Tailings will be discharged into the TSF by sub-aerial deposition methods, using a combination of spigots at regularly spaced intervals from the embankments. The TSF is designed to accommodate a total of 3.0 million tons of tailings. The TSF will be lined with high-density polyethylene - HDPE liner. The design of the TSF was reviewed by the IE and found to be adequate. In future, during operations, the TSF will be inspected and monitored for the ongoing raising and operation on a yearly basis by an independent consulting engineering firm. This is stipulated in the ESAP.

In addition to the above, Roxgold is committed operate within the scope of the International Cyanide Management Code (ICMC). To this end, the company will only source cyanide for its operations from suppliers which are signatories to the ICMC. Transportation of this cyanide will also be contracted to companies which are signatories to ICMC. As stipulated in the ESAP, the company will commission an ICMC accredited lead and/or technical expert to undertake an ICMC audit of its cyanide management system.

The conceptual water management system of the mine is designed for zero discharge. Two sediment dams are proposed to be constructed in the downstream reaches of catchments impacted by site infrastructure. One is downstream of TSF and the other is downstream of the plant site. Monthly groundwater quality and level monitoring, which was initiated in June 2013 alongside the baseline water quality sampling program, will continue through all phases of the project. The groundwater monitoring network includes boreholes from which the local community obtains water. There is currently no detailed information on surface water flow volumes in the sub-catchments aro
und the project site.

There are currently limited sources of environmental pollution in the project site which can contribute in the deterioration of air quality. Primary sources of air emissions from the implementation of the project will include particulates from mining and processing (particularly crushing), entrainment of dust by vehicles, especially on unpaved roads as well as fuel combustion. Based on air quality data collected as part of the baseline monitoring the average for both the 24-hour PM10 and PM2.5 were low and below the World Bank/IFC/WHO ambient air quality guideline levels of 50 μg/m3 and 20 μg/m3 respectively. Equally, the SO2 and NO2 monitoring results were below their respective World Bank/IFC/WHO ambient air quality guidelines. However, baseline dust fallout levels indicate that during the dry season dust fallout levels are naturally elevated in the area and can exceed WBG guidelines for residential areas. Roxgold will implement water based dust control measures within the mine area, on access roads and at the plant, where evacuation and filtration systems are not practical. In addition to this, the company will maintain and operate the dust fallout monitoring network that was setup during the baseline monitoring throughout all phases of its operations.

The baseline noise measurement results confirm that the present ambient noise levels in the vicinity of the project fall within the WBG guidelines. Primary sources of noise at Yaramoko will include excavation, blasting, drilling, rock crushing, vehicles engine and movement, stockpiling, etc. Roxgold will adopt in-plant shielding of noise emissions to ensure that noise levels at sensitive receptors are within the regulatory limits. In addition to this, the company will adopt good practice methods in the prevention and control of noise. This will include having all equipment for the plant designed to operate with low noise levels, without exceeding the maximum allowable noise level for the surrounding receiving land use.

Mine closure and rehabilitation: A conceptual closure plan has been developed assuming that the preferred final post-closure land use will be a savannah landscape 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. As stipulated in the ESAP Roxgold 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.

Infrastructure and Equipment Design & Safety: The principal risk to community safety is from population proximity to the operations (e.g. the road, mining operations, etc.). It is anticipated that local communities in some areas will consider dust generated from the operations as an irritant. Roxgold will need to address this in order to ensure that airborne emissions outside the mine boundary do not exceed IFC guidelines.

Community Exposure to Disease: Health risks associated with the area generally, which may be exacerbated by in-migration or other changes are Malaria, HIV/AIDS and other vector borne diseases. Roxgold will need to have an integrated approach to health and recognize the importance of improved health in communities as it is related to the wellbeing of the workforce. As stipulated in the ESAP, the company will develop and implement a comprehensive HIV/AIDs and communicable diseases plan for implementation during all phases of its operation.

Roxgold has not identified influx into Bagassi village and the communities around the mine operation, especially those who have received compensation, as both a risk and an impact. Local NGOs and other sources suggests that Bagassi village has already experienced significant population growth, and is experiencing the associated social problems, including inflation and increase in prostitution among others; the information on these impacts remains anecdotal. However, as stipulated in the ESAP, the company will develop and implement a Social Management Plan (SMP) whose objectives would be to avoid or minimize any potential social impacts. This SMP will encompass management plans on artisanal miners, influx management, stakeholder engagement and public consultation, local employment and procurement, community development, worker housing, and community health and safety.

Security: The Roxgold security force is unarmed. The team is headed by 2 former French Militaries. They are highly trained professionals, and include expertise in security training. There has been great emphasis on local recruitment. Supervisors have undertaken 3 months training certified by the “Ministère de la Sécurité” covering ethics code, human rights, contract, self-defence, etc. Frontline security personnel have undertaken 1-1/2 months training. The department is in the process of recruiting 2 women. Roxgold is committed to further develop its security management system in line with the requirements of Voluntary Code for Security and Human Rights. The company agreed to an IFC suggestion to review its current MOU covering co-operation with the Gendarmerie. As part of this process, Roxgold will communicate the security arrangements to its employees and the affected communities in the concession area. Communities can use existing grievance mechanisms to log any concerns related to security activities and conduct. Roxgold will use reasonable efforts to make inquiries to investigate employment and other available records for
security staff. In addition to the above, all mining and process operations including the TSF and WSD will be fenced with access control.

There have been no incidents of threat to the security of operations or the company’s personnel since the company started its operations at Yaramoko.

Stakeholder Engagement (SEP): Stakeholder engagement is managed by the Country Manager who reports directly to the General Manager Operations at site. As discussed under PS1 above, reporting to the Country Manger are the Environmental and Community Relations Manager and HR Manager. The Environmental & Community Relations Manager and his team have responsibility for developing and maintaining mutually beneficial relationships with project affected communities and other stakeholders. They are responsible for the implementation of the RAP including the upcoming livelihood restoration program.
The company has developed a Stakeholder Engagement Plan (SEP) for the current operations. The SEP is well-designed, but needs to include a solid identification of stakeholders both at local and national level, and vulnerable groups and a discussion of challenges to effective communication with different population groups. Roxgold will need to update the stakeholder mapping after the October 2015 election. As stipulated in the ESAP, Roxgold will update and disclose the SEP to be consistent with the requirements of the Performance Standards on informed consultation and participation. The SEP will ensure continuous engagement with stakeholders to inform, create awareness and understanding of the activities and potential impacts of the mining activities taking place around them. The updated SEP should include mechanisms and KPIs to evaluate its effectiveness and the extent to which PAPs and other stakeholders feel informed and understand the content of consultations.
There are no detail socio-economic baseline data available. As well, socio-economic information on herders and people that have been compensated is missing. This will be required to monitor their livelihood. There is a need to develop a Stakeholder Engagement Strategy with single point of accountability for each stakeholder with key messages, etc.)
The SEP is thus a live document such that Roxgold will be able to monitor progress and update it as the project progresses, to ensure that stakeholders and PAPs: (i) are fully informed of the expansion and the changing mine operation, (ii) are made aware of the impacts through disclosure of prior information and actions proposed to mitigate those in a timely fashion, (iii) have sufficient opportunity to understand the impacts early in the process ,and (iv) provide them with an opportunity to participate in the discussions and provide feedback on issues that directly affect them. Roxgold will incorporate into its decision – making processes feedback received and will develop procedures for reporting back to the affected communities on a regular basis.
Grievance Mechanism: Roxgold has a published grievance mechanism that has been in place since 2014 as required by the Burkina Faso Regulations. It is structured to be consistent with IFC requirements, ensuring transparency of the process, option of anonymity with clear procedures for resolution and mechanisms for third party conciliation by the “Comité Restreint” and finally for arbitration by the Government if required. The grievance mechanism is being implemented and during community meetings, local authorities indicated an awareness of the procedure and how to use it. Access appears consistent with good international industry practice.
A number of grievances have been filed since Roxgold began construction and the company has been addressing them through the agreed procedure, confirming that the system is being used. The principal grievances filed have included loss of agricultural land, impacts to crops, compensation and employment. Roxgold is monitoring the effectiveness and accessibility of the grievance mechanism to all PAPs and other stakeholders, and as part of a process of continuous improvement, will revise and strengthen the procedures as required to ensure that grievances are resolved in a timely manner and that reoccurrences are minimized. Roxgold has also integrated into the management system periodic analysis of grievance trends with feedback to operations and senior management to address the causes of legitimate grievances.
Roxgold will revise its grievance mechanism including a Roxgold review and analysis function so that operational changes to reduce grievances can be part of the process of continual improvement.

The Environmental and Social Review Summary (ESRS) and the ESIA will be made available via the World Bank Group’s InfoShop. Roxgold will be required to inform the public that results from IFC’s environmental and social review are available for access on its corporate website or provide a web-link to IFC’s disclosed ESRS. The company has also provided hardcopies of the ESIA at the company’s office in Ouagadougou and at Yaramoko project site office.
For inquiries and comments about the project contact:


Roxgold Head Office, Canada:

ROXGOLD INC.
360 Bay Street, Suite 500Toronto, Ontario
M5H 2V6Canada

Tel: +1 416-203-6401Fax: +1 416-203-0341
Email: mailto:info@roxgold.com
Website: http://www.roxgold.com
Roxgold Burkina Faso:

ROXGOLD SANU S.A.
438, Rue Worg-Ntondo, Zone du Bois – Secteur 22
01 BP 4861 Ouagadougou
Burkina Faso

Tel: +226 25 36 13 57

Broad Community Support is not applicable for this project

Yaramoko(36754) Appraisal Disclosure Snapshot – Version 2
Description	Anticipated Completion Date
Complete the Environmental and Social Management System (ESMS) currently being developed and ensure that all required aspects of the system are ready for implementation.	30-Apr-2017
Complete and implement the Environmental and Social Management Plans (ESMPs) currently being developed as part of the Environmental and Social Management System (ESMS). These include: (i) Labor and Human Resources (LHR) Plan; (ii) Occupational Health and Safety Management (OHSM) Plan; (iii) Construction Management (CM) Plan; (iv) Traffic Management (TM) Plan; (v) Waste Management (WM) Plan; and (vi) Emergency Preparedness and Response (EPR) Plan.	30-Apr-2017
Roxgold will ensure that all the above key plans are included in all final contracts. Roxgold will submit to IFC written confirmation, with copy of relevant section from tender documentation particularly for the construction contractor, for review.	31-Jul-2015
Engage suitably qualified and experienced EHS and CR consultants to finalize the development and implementation of the ESMS and the associated Environmental and Social Management Plans for the project.	30-Sep-2015
Update existing Stakeholder Engagement Plan (SEP) to identify and expand the company’s major stakeholders at both local and national levels, sustainability issues specific to each stakeholder, and frequency of engagement with each stakeholder group.	31-Aug-2015
Update 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 IFC Performance Standard 2 and Burkina Faso's Labor Laws.	30-Apr-2017
Include the relevant aspects noted under IFC PS3 and ESRS in the Waste Management Facility (WMF) construction process; following completion, submit detailed designs and operating strategy to a suitably qualified engineering consultancy firm for review and identification of any gaps to be rectified.	31-Mar-2016
Commission a specialized consultant to carry out regular and ongoing independent audits of the Tailings Storage Facility (TSF) every four months during construction and annually during operations to ensure that design, construction and operation of TSF follows GIIP.	31-Mar-2016
Commission an International Cyanide Management Code (ICMC) accredited lead and/or technical expert to undertake an audit to confirm the project has been designed and constructed in accordance with the ICMC standards and detail corrective actions where applicable.	31-Dec-2015
Upgrade the 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 plan, which will include closure costs provisions for immediate closure and life of mine closure, and decommissioning and restoration costs, will specify an appropriate accrual funding mechanism.	30-Apr-2017
Develop a comprehensive HIV/AIDs and communicable diseases plan, for implementation during all phases of the project.	31-Dec-2015
Develop and implement a Social Management Plan (SMP) whose objectives would be to avoid or minimize any potential social impacts. This SMP will encompass management plans on artisanal miners, influx management, stakeholder engagement and public consultation, local employment and procurement, community development, worker housing, and community health and safety.	30-Apr-2017
Updated RAP to explain the total cost figure, what specific gender issues were addressed, and state how many individuals are actually affected with detailled socio-economic baseline including monitoring and livelihood restoration programmes.	30-Apr-2017