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
If IFC’s investment proceeds, IFC will periodically review the project’s ongoing compliance with the Performance Standards. PS 5, 6, 7 and 8 are not applicable to this project as the conversion will occur within the boundaries of an existing power plant site and as such no incremental impacts related to land acquisition and resettlement, biodiversity, Indigenous Peoples or cultural heritage are anticipated. Future impact assessment related to the proposed 400 kV transmission line is dealt with under PS 1.

The conversion of the existing 1,000 MW Sulaymaniyah open cycle gas turbine (OCGT) power plant to a combined cycle gas turbine (CCGT) power plant will have limited environmental and social impacts since the conversion is taking place within the already developed OCGT power plant boundary, and no additional fuel consumption is involved. The conversion to CCGT will have the positive environmental benefit of improving the electricity generation efficiency and greenhouse gas emissions performance per unit of electricity generated. The power from the converted 1,500 MW plant will be evacuated through the existing 132 kV transmission lines until a new 400 kV transmission line connection is established by MoE KRG. The converted CCGT plant will use air cooled condenser cooling system to minimize water consumption. All considered, the investment is a category B project because of its potentially limited adverse environmental and social risks and impacts.

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 the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFC’s 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 implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental and Social Assessment and Management System:

In the beginning of 2008, MEGH was contracted by the Ministry of Electricity of KRG to construct SGPS producing 750 MW of electricity, which was amended later to 1,000 MW. The construction started in 2008, and at that time, SGPS was not required to conduct an environmental and social impact assessment by the KRG. In 2012, when gas turbines No. 7 and 8 were under construction, the Ministry of Environment recommended SGPS to prepare an Environmental and Social Impact Assessment (“ESIA”). SGPS prepared an ESIA only for an internal use of SGPS, and was never submitted to the authorities for review. This ESIA did not include any impact assessment such as air dispersion modeling, water intake impact assessment, etc. In 2013, MGES started the conversion of the SGPS from OCGT to CCGT, but no ESIA was required or prepared for the CCGT conversion. Despite this, SGPS project is considered to be in compliance with the local environmental requirements, according to official letter, dated May 21, 2014, issued by the Environmental Protection and Improvement Board of the KRG to MGES. SGPS, together with other two IPPs (Duhok OCGT and Erbil CCGT), are working to obtain ISO 9001 certification by the end of 2015.



As per ESAP action No. 1, SGPS will commission a Rapid ESIA which includes: (i) air dispersion modeling to confirm that CCGT operations will not have major adverse air quality impacts (and, if need be, to propose corrective actions, including the effects of water injection which is being considered by MEGH), (ii) social impacts of SGPS water use, including abstraction from two wells about 12 km from SGPS and water intake from Zab River through a 30 km water pipeline, (iii) ambient noise impact assessment for workers within SGPS site and residents of the closest settlements, (iv) preparation of an Environmental and Social Management Plan specifying mitigation measures and environmental monitoring programs, including retrofitting a continuous emissions monitoring system, and (v) preparation of a Stakeholder Engagement Plan.



In the future, SGPS will be required to send electricity from CCGT operation to the grid via the planned new 400 kV transmission line to be developed by MoE KRG. At this moment, the length or routing of the 400 kV transmission line is still to be determined. As per ESAP action No. 2, SGPS will endeavor to use its influence with MoE KRG to ensure that the connecting 400 kV transmission line will be developed with an appropriate ESIA, and in accordance with PS objectives.



Policy:

SGPS management established its “Environmental Policy Statement” in April 2013. This policy describes SGPS commitment to protecting human health and natural resources, promoting environmental stewardship, and implementing innovative environmental technologies and practices. Further, as part of its HSE Procedures, SGPS prepared “Health, Safety and the Environment Policy”, and “Sust
ainable Development Policy” to be formally adopted. SGPS will formally adopt these two policy documents as per ESAP action No. 3.





Management Programs:

SGPS OCGT units have been operational since August 2012. SGPS has extensive health and safety programs to maintain and improve performance in this area. SGPS OCGT units are operating mainly on gas with occasional usage of liquid fuel oil (about 6 to 14%). SGPS currently does not have any environmental monitoring activities. MEGH’s Vision document signed by Chief Executive Officer presents various objectives including “To monitor stack emissions, ambient air quality, noise level”. In line with this objective, and as described above, SGPS will establish and implement a detailed Environmental and Social Management Plan (ESMP) for the CCGT operation, describing the stack emission monitoring program, ambient air quality monitoring program, and noise monitoring program (for both the occupational noise levels within the plant and ambient noise levels at the closest residential receptors).



ENKA, the EPC contractor for the CCGT conversion, is using its “HSE Procedure, Environmental Management Plan for the Sulaymaniyah Combined Cycle Power Project” to manage environmental health and safety performance of the construction activities related to SGPS conversion to the CCGT plant. ENKA has a HSE Department and HSE Manager on site. No major HSE risks have been identified related to the CCGT conversion by ENKA.



Organizational Capacity and Competency:

SGPS has a Health, Safety and Environment (HSE) Department with 28 employees. Under the HSE Manager, there are four teams: (i) security supervision, (ii) health coordinator / nurses, (iii) fire-fighting, and (iv) safety management. At MEGH level, there is an HSE Director who oversees the EHS performance of all the three IPPs in their portfolio (Erbil, Dohuk, and Sulaymaniyah). Currently, since SGPS is not conducting any environmental management / monitoring activities, there is no environmental monitoring/management team at the HSE Department. SGPS will establish an environmental monitoring team within the HSE Department as per ESAP action No. 4.



SGPS provides trainings to employees on HSE areas. In 2014, training man-hours by HSE Department was over 2,000 man-hours, next to the training for operation (7,101 man-hours) or the training for mechanical aspects (5,435 man-hours).



SGPS has contracted Sulaymaniyah University to conduct water, transformer oil and turbine lube oil analysis, in addition to all other analysis in the specific time according to the manufacturer’s recommendations. In implementing the environmental monitoring activities, SGPS is considering to contact the same university to help enhance regional technical capacity in KRG.



Emergency Preparedness and Response:

The HSE Department of SGPS has responsibilities to (i) supervise the fire-fighting system and foam system, (ii) provide all staff with training
on emergency preparedness and response, (iii) check that the siren system is functioning properly, and (iv) install warning and emergency signs. SGPS HSE Procedures include three procedures “Emergency Preparedness and Response Program”, “Emergency Response” and “Crisis Management”. The first procedure describes type of emergency (fire, personal injury, rescue of personnel, rescue of personnel from confined space, chemical spill, oil spill and evacuation and mustering), operation, maintenance and testing of equipment provided (fire detectors and alarms, fire extinguishers, firewater pumps, sprinkler system, foam system, chemical spill kit, oil spill kit, etc.), and tests, trials and drills for emergency systems (fire-fighting, medical emergency, evacuation / mustering, and crisis management). The second procedure describes what procedures to be followed in the event of an emergency (site emergency alarms, mustering and accounting for people, emergency and chemical safety data sheets, fire, chemical / oil release, first aid & accident, leakage of fuel gas, bomb scare) and includes relevant action plans (fire fighting action plan, chemical spillage action plan, work accident action plan, medical emergency action plan). The last procedure describes procedures to be followed in the event of a serious emergency which constitute a major crisis for the company (significant harm to personnel or third parties such as fatalities or major disabilities, substantial property damage, such as associated with a major fire or explosion, significant environmental pollution or damage, terrorist threats or actions, sabotage and bomb scares, and natural disasters, e.g. earthquakes, flooding etc.).



Monitoring and Review:

The HSE Department of SGPS produces HSE Monthly, Quarterly and Annual Reports mainly reporting health and safety activities (medical attentions by the employees, statistics of total man hours worked, lost time injuries, HSE toolbox meetings, health and safety and firefighting trainings, work permits and risk assessment performed, implementation of Lockout/Tagout (LOTO) practices, updated HSE management structure). This shows that SGPS has established a system to manage and monitor health and safety performance of the SGPS operation, but does not have any environmental monitoring activities in place. SGPS has its own chemical laboratory to conduct fuel quality of the secondary liquid fuel. The ESMP to be developed as per the ESAP No. 1 will include detailed environmental monitoring programs for air emissions, ambient air quality, noise, liquid effluents, hazardous and non-hazardous waste generation and disposal in line with good international industry practice.

Working Conditions and Management of Worker Relationship:

SGPS has about 250 employees, of which about 20 employees live in an accommodation facility on site. In addition, there are about 30 employees of a private security company resident on site, about 60 people from the electricity police resident outside but close to the site, and about 120 Peshmerga (military) personnel residing outside the site. SGPS provides electricity, water and air conditioning service to their accommodation facilities of the private security company and the electricity police. Workers working at SGPS kitchen, gardening and cleaning are all employees of SGPS. No major worker relationship issues were identified during IFC appraisal.



In KRG, SGPS informed IFC that labor unions are very active (e.g. Kurdistan Labor Union), but at this moment, SGPS does not have any labor unions on site (though the company is committed to freedom of association for its workers). Recent labor related requests by SGPS employees included (i) quality of food provided to employees, and (ii) working hours during Ramadan.



ENKA, an EPC Contractor for the CCGT conversion, has about 800 workers at SGPS site, consisting of about 30 local workers, 650 to 700 workers from India, and the remaining number from Turkey and other countries. In 2014, when ISIS-related concerns were spread among workers from India, ENKA arranged 6 to 7 buses to be visible at SGPS site, so that in case needed workers were assured to be immediately transported to Sulaymaniyah airport to evacuate. The working time by ENKA is in total 10 hours, 7am to 12 noon (5 hours), one hour break (12 noon to 1pm), and then, 1pm to 6pm (five hours). The number of hours worked beyond 8 hours is treated as overtime.



Human Resources Policies and Procedures:

SGPS Operational Administration Procedures include (i) Hiring Staff procedures, and (ii) Employee Manual. SGPS does not have a documented HR Policy or comprehensive HR procedures and will prepare them in line with IFC Performance Standard 2 (ESAP action No. 5).



Grievance Mechanism:

The worker grievance mechanism is currently conducted through Department Meetings. SGPS will establish a worker grievance mechanism as part of SGPS Operational Administration Procedures as per ESAP action No. 6. SGPS does not have any pending legal cases or complaints related to labor issues.



Protecting the Workforce:

SGPS does not use forced labor or child labor. MEGH has a rule to require contractors that their workers be more than 18 years old.



Occupational Health and Safety:

Since 2011, SGPS of OCGT construction and operation did not have any worker fatalities. Lost time injuries in 2011-2015 were in the range of zero to 3 injuries per year. Since the start of the CCGT conversion by the EPC Contractor, no fatalities have been recorded, and five lost time injuries were recorded. The HSE Department of SGPS is working closely with HSE Manager of the EPC Contractor t
o monitor and maintain good occupational health and safety performance.



As part of improving occupational health and safety performance, SGPS has established a process to conduct a rapid risk assessment (e.g. types of hazard, hazard effect, risk, control measures, residual risk) for each work order processed.

Water:

Water for the SGPS OCGT operation is currently supplied from two wells located about 12 km from the SGPS power plant site. Considering that the SGPS power plant is located in a dry area, an air cooled condenser (ACC) was selected to condense exhaust steam from the steam turbine generators. A water treatment plant will be installed to treat, store and distribute water to the CCGT operation, including service water, domestic water and boiler feed water (make-up water). The water from the two wells is being delivered by trucks, but there is a new water pipeline being installed which will start operation this year. An additional water pipeline is being constructed to bring water from Zab River, about 30 km from the SGPS site. Water will be delivered to not only SGPS but also to other industrial users. The Zab River water pipeline will be owned by MEGH. As described in PS1, potential environmental and social impacts of the Zab River water pipeline will be assessed as part of the Rapid ESIA.



Resource Efficiency and GHG Emissions:

The eight gas turbines of SGPS (F9E) has an electricity generating efficiency of about 34% (LHV, gross) when operated on both natural gas and diesel fuel oil. Once SGPS is converted to a CCGT plant, the overall SGPL power plant electricity generating efficiency is estimated to be around 55 to 56% (LHV, gross). CO2 emissions performance is estimated around 590 gCO2/kWh gross (gas-fired OCGT) and 780 gCO2/kWh gross (diesel oil-fired OCGT), and these are estimated to improve to 360 gCO2/kWh gross (gas-fired CCGT) and 480 gCO2/kWh gross (diesel oil-fired CCGT), after the CCGT conversion is completed.



Air Emissions and Ambient Air Quality:

Although there is no ambient air quality data available, and also, no air dispersion modeling was conducted for OCGT or CCGT operation, the air quality of the surrounding environment of the SGPS is likely to be determined as not degraded, considering that SGPS is not located in an industrial area and is far away from any major city such as Sulaymaniyah (about 60 km away).



The quality of the diesel fuel oil (secondary back-up fuel) is analyzed at each batch of delivery. SGPS has three set of specifications depending on the liquid fuel supply contract. The sulfur content specifications are either 0.2%, 0.4% or 0.8% depending on the contract, and a delivery of liquid fuels above 0.8% sulfur content is rejected. This meets the IFC/WBG sulfur dioxide emissions guidelines (use of maximum 1% sulfur content fuel oil for new combustion turbines located in non-degraded air-sheds).



Based on the information provided by SGPS, NOx emissions from the gas turbines are in the range of 178 to 192 ppm when fueled on natural gas, and 225 to 261 ppm when fueled by fuel oil, which exceeds the current World Bank Group NOx emission guidelines for new gas turbines (25 ppm for gas-fired and 74 ppm for diesel oil-fired). To enhance power generation from gas turbines, MEGH is considering a
n option to retrofit water injection to the SGPS gas turbines, and with the water injection, electricity generation from each gas turbine is estimated to increase by 3 to 6%, and at the same time, the NOx emission is estimated to be reduced to 48 to 56 ppm (gas-fired) and 75 to 95 ppm (diesel fuel oil fired). Retrofitting with water injection, if so implemented, will increase the amount of water requirements, and as described above, MEGH is also considering installation of a water pipeline to bring additional water to site. As described under PS1 section, this environmental consequences of water injection in terms of NOx emissions reduction and enhanced electricity generation from gas turbines, and the impacts of bringing additional water to SGPS plant to the other water users in the region, will be examined as part of the Rapid ESIA



Over the last five years of operation (2010-2014), SGPS has been using mainly natural gas, supplemented by fuel oil. In 2012 to 2014, the fuel consumption ratio of diesel to fuel oil was in the range of 6 to 14%. Since the temperature of exhaust gas from CCGT operation will be reduced significantly from the OCGT operation (550 C), the ground level ambient nitrogen dioxide concentrations of CCGT operations are expected to be higher than the case of OCGT operation, considering that the stack height of CCGT power plant is about the same height as the OCGT power plant (40 m). Since no air dispersion modeling was conducted to date, as described in PS1, SGPS will retain an air dispersion expert as part of the Rapid ESIA to conduct air dispersion modeling for CCGT operation, to confirm that the ground level concentrations of ambient nitrogen dioxide is reasonably reduced (e.g. SGPS’s contribution is to be below 10 micrograms per cubic meters for annual average nitrogen dioxide, and below 50 micrograms per cubic meters for 1 hour maximum nitrogen dioxide).



ENKA, the EPC contractor for the CCGT conversion, is required to complete the conversion with the noise levels maximum 70 dBA at the SGPS site fence. No major settlement is present within 3 km of the SGPS site, and therefore, the ambient noise levels are expected to meet WBG ambient noise guidelines of 45 dBA nighttime. This will be confirmed by the Rapid ESIA described in PS1.



Wastewater Treatment:

Diesel fuel oil delivered to SGPS that passes the required quality (e.g. sulfur content) specifications

is treated by centrifuge to remove sludge. The effluent from centrifuge equipment is to be treated by an Effluent Treatment Plant (ETP), but this ETP is not functioning. Currently, residential wastewater is treated by septic tanks, whereas industrial wastewater from fuel treatment or washing the units is not treated, and is discharged to a small stream. As part of the CCGT conversion, an industrial wastewater treatment facility is being designed by ENKA and will be installed to ensure that the treated industrial wastewater will meet the WBG effluent g
uideline limits. As per ESAP action No. 7, SGPS will submit the final description of the wastewater treatment facility to IFC to demonstrate that effluents (including oil-contaminated effluents will be treated in compliance with WBG effluent guideline limits and will ensure share treated water monitoring results during operations as a check that the system is operating as designed.



Solid Waste Management:

Solid wastes are collected separately depending on types of waste (e.g. paper, plastics, metal). However, due to the lack of solid waste recycling system in the region, all the collected solid wastes are disposed at a nearby landfill site. SGPS has a hazardous materials and hazardous waste storage area with a lock. Collected hazardous wastes (e.g. used oils) are collected by a specialized company. The current hazardous materials and hazardous waste storage area is a container for temporary use. As per the ESAP action No. 8, SGPS will improve the hazardous materials and hazardous waste storage area from a temporary container to a permanent area with proper impermeable floors and containment bunding, and equipped with Materials Safety Data Sheets.

Security Personnel:

SGPS assets and workers are protected by three categories of armed security personnel:  (i) private security staff at the reception and gates, (ii) electricity police staff around the plant border, and (iii) Peshmarga army staff outside the plant border and its surrounding areas. The security supervisor of HSE Department conducts a regular supervision of private security personnel (e.g. performance monitoring, including adequate handling and storage of firearms) and makes necessary coordination (e.g. sharing information to maximize the effectiveness of the multiple security arrangement) among different categories of security personnel.  Since start of the OCGT operation in 2009, SGPS has not had any major incidents between security personnel and workers or communities (which are located 6 to 7 kilometers from the SGPS).   



In line with IFC Performance Standard 4, and as per ESAP No. 9, SGPL will (A) review the existing security personnel management procedures and develop a security personnel management plan incorporating PS4 requirements including (i) SGPS procedures related to hiring and vetting of private security personnel, (ii) SGPS code of conduct (including use of force) that will be required to the private security personnel, (iii) SGPS training programs for the private security personnel on the use of force (including firearms) and appropriate conduct toward workers and affected communities, (iv) SGPS monitoring of private security personnel, and (v) SGPS grievance mechanism for affected communities to express concerns about the security arrangement and acts of security personnel, and (B) review the past security risk review conducted and update the security risk assessment including a risk matrix, referencing both likelihood and severity.

Stakeholder mapping / analysis:
There are two towns within the area of influence as defined in the company’s internal ESIA: (i) Chamchamal with about 150,000 population (50,000 households) located about 7 km south of the SGPS site, and (ii) Takya with about 100,000 population (35,000 households) located about 6 km north of the SGPS site. The closest residential area is 3 km from the SGPS site.

Stakeholder Engagement:
In conducting the internal ESIA in 2012, the SGPS team interviewed local residents at these two towns, to obtain their opinions and observations about the SGPS. According to the ESIA, the communities consulted were of the opinion that the SGPS project is good for the area as a whole, and provided employment opportunities to the villagers either as unskilled workers or as security guards. None of the communities consulted raised any concerns or objections to the SGPS project.

Since these interviews were conducted in 2012, SGPS has not conducted stakeholder engagement on an ongoing basis, except for occasional meetings with government officials or town representatives. In line with IFC requirements, SGPL will prepare and implement a Stakeholder Engagement Plan to improve the level and quality of stakeholder engagement with the two major towns and other small settlements as per ESAP action No. 1. This will include identification of key stakeholder groups, disclosure of relevant project information – including identified E&S impacts and mitigation measures – and ongoing consultation on any areas of concern of collaboration.

External Communication and Grievance Mechanisms:
The Stakeholder Engagement Plan to be prepared by SGPS will include the details of how SGPL will conduct external communication with stakeholders (e.g. name of the community liaison officer, external communication program, and a community grievance mechanism to systematically receive and handle grievances as appropriate.

Ongoing Reporting to Affected Communities:
Considering the relatively long distance (6 to 7 km) from the SGPS site to the nearest two towns (Chamchamal and Takya), no major E&S impacts are expected to those communities from the normal operation of the SGPS plant. However, in accordance with the Stakeholder Engagement Plan to be developed, SGPS will disseminate the key E&S performance information of the SGPS, including the E&S monitoring results through SGPS website and appropriate regular meetings.

Further information can be obtained by:

Name: Mr Shadi Abulkhair
Title: Mass Group Holding Commercial Director, Sulaymaniyah Gas Power Station (SGPS)
Address: Wasfi Al Tal Street, Building
342 PO Box 546 Amman 11953 Jordan
Telephone Number: + 962 79 9045999
Email Address: abulkhair@massgroupholdong

Broad Community Support is not applicable for this project

MGES Power(37045) Supervision Disclosure Snapshot – Version 2
Description	Anticipated Completion Date	Status	Comments	Completion Date
ESAP action No. 1 (PS1): SGPS will commission and complete a Rapid ESIA which includes: (i) air dispersion modeling to confirm that CCGT operation with lower exhaust gas temperature with 40 m stack height with the current NOx emission levels of 178 – 261 ppm (at 15% excess oxygen) does not have major adverse air quality impacts, and if not, to propose corrective actions, including the effects of water injection which is being considered by MEGH, (ii) analysis of potential water use impacts of SGPS on other water users (including the existing wells about 12 km from SGPS and the proposed additional water from Zab River through 30 km water pipeline on the existing and future water users), (iii) ambient noise impact assessment for workers within SGPS site and also closest settlements, (iv) preparation of an Environmental and Social Management Plan (specifying mitigation measures and environmental monitoring programs, including retrofitting continuous emissions monitoring system), (v) preparation of a Stakeholder Engagement Plan (including a community grievance mechanism) and (vi) assessment of the other impacts of the proposed water pipelines (e.g. social, cultural and biodiversity impacts).	31-Mar-2016	Completed	Completed	8/31/2017
ESAP action No. 2 (PS1): SGPS will endeavor to use its influence with MoE KRG to ensure that the connecting 400 kV transmission line will be developed with an appropriate ESIA, and in accordance with PS objectives	31-Dec-2017	Completed	Completed	12/31/2017
ESAP action No. 3 (PS1): As part of its HSE Procedures, SGPS prepared “Health, Safety and the Environment Policy”, and “Sustainable Development Policy” to be formally adopted. SGPS will formally adopt these two policy documents and submit the dated and signed documents.	31-Dec-2015	Completed	Completed	1/28/2016
ESAP action No. 4 (PS1): SGPS will establish an environmental monitoring team within the HSE Department.	31-Mar-2016	Completed	Completed	7/28/2016
ESAP action No. 5 (PS2): SGPS will prepare an HR Policy and related Procedures in line with IFC Performance Standard 2 requirements.	31-Mar-2016	Completed	Completed	3/31/2016
ESAP action No. 6 (PS2): SGPS will establish a worker grievance mechanism as part of SGPS Operational Administration Procedures.	31-Mar-2016	Postponed	Changed project circumstances mandated a delay of this task
ESAP No. 7 (PS3): SGPS will submit the final design of the wastewater treatment facility to IFC to demonstrate that effluents (including oil-contaminated effluents) will be treated in compliance with IFC/WBG effluent guideline limits.	31-Dec-2015	Completed	Completed	1/27/2016
ESAP action No. 8 (PS3): SGPS will improve the hazardous materials and hazardous waste storage area from a temporary container to a permanent storage area with proper impermeable floors and containment bunding, and equipped with MSDS sheets.	31-Mar-2016	Completed	Completed	3/31/2016
ESAP action No. 9 (PS4): SGPS will (A) review the existing security personnel management procedures and develop a security personnel management plan incorporating PS4 requirements including (i) SGPS procedures related to hiring and vetting of private security personnel, (ii) SGPS rule of conduct (including use of force) that will be required to the private security personnel, (iii) SGPS training programs for the private security personnel on the use of force (including firearms) and appropriate conduct toward workers and affected communities, (iv) SGPS monitoring of private security personnel, and (v) SGPS grievance mechanism for affected communities to express concerns about the security arrangement and acts of security personnel, and (B) review the past security risk review conducted and update the security risk assessment including a risk matrix, referencing both likelihood and severity.	31-Mar-2016	Completed	Completed	7/20/2017