The BNGL site is located on a desert plateau that is heavily industrialized and the overall quality of the landscape and visual amenity is generally low. Surrounding the site, the landscape is flat and contains various anthropogenic structures including masonry security walls, overhead power lines and paved roads.

With regards to PS 6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), the project has decided not to proceed with a water intake pipeline which was identified in the BNGL ESHIA as having the potential to raise limited PS6 exposure. The revised project will not affect any designated or protected areas, nor any areas of particular known biodiversity sensitivity and no material PS6 exposure is therefore envisaged. On PS7 (Indigenous Peoples) & PS8 (Cultural Heritage), no Indigenous Peoples have been identified within BNGL’s project location and no impacts to cultural resources have been identified to date.

 This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability. The project is expected to have limited adverse environmental or social risks and/or impacts that are few in number, generally site-specific, largely reversible, and readily addressed through mitigation measures. The BNGL plant will be located within long established, sparsely populated oil field areas in southern Iraq and the impacts and risks of operating the new the plant will not pose significant risk to the surrounding environment or communities. Those risks can be avoided or mitigated by adhering to recognized industry standards, operating procedures, guidelines and design criteria as described in the following sections.

Key environmental and social considerations relate to; i) ensuring the contractors comply with the environmental and social management system and associated obligations and plans for construction including aspects related to occupational health and safety; ii) contractor compliance with Performance Standard 2: Labor and Working Conditions; iii) ensuring adequate emergency response for all project components; and iv) pipeline operations in accordance with good international industry practices (“GIIP”). BGC’s management systems and supporting procedures refer to and have been developed to align with the Performance Standards, WBG general EHS guidelines and applicable WBG industry sector guidelines.

Environmental and Social Assessment, Management System & Policy: Environmental and social regulatory approvals have been achieved for the BNGL project in compliance with Law No (27) of 2009 on ‘Environmental Protection and Improvement’ and structured in accordance with the Ministry of Environment’s ‘Sector-specific EIA Guidelines for Oil and Gas activities in Iraq’.

A “BNGL” environmental, social and health impact assessment (“ESHIA”) was completed in July 2018, and subsequently approved in December 2018. The BNGL ESHIA accompanies this disclosure. The ESHIA has been undertaken to comply with the PSs, incorporating the WBG general EHS guidelines and sector specific guidelines, including the WBG EHS guidelines for onshore oil and gas development. The BNGL ESHIA drew from baseline information collated in a preceding ESHIA for a larger scale plant in 2014, also developed to comply with the same standards as the BNGL project ESHIA. As required by BGC’s management system, described further below, the findings of ESHIAs feed into BGC’s project decision-making process and engineering processes, including the requirement for a completed and regulatory approved ESHIA ahead of BGC’s internal project approval.

Under the terms of its shareholder agreement, BGC is required to implement and maintain health, safety, security, environment and social performance (“HSSE&SP”) policies, standards, procedures and practices which are consistent with internationally accepted petroleum industry practices. To achieve this, BGC have developed a policy on health, security, safety, the environment and social performance. To implement the policy, BGC have adopted the Shell HSSE&SP Control Framework as its overarching management document.

Both the HSSE&SP policy and management system includes specific requirements regarding leadership commitment, policy, standards, manuals and specifications which apply to the BNGL project development and operations. The HSSE&SP management system defines organizational responsibilities and resources, emergency response, monitoring and reporting, with additional management system elements including, i) health, including alcohol and drugs, fitness to work and human factors engineering, ii) process safety, including asset integrity, iii) personal safety including confined space work, electrical safety, excavation, hot work, personal protective equipment (“PPE”) and working at heights, iv) security including adherence to the Voluntary Principles on Security and Human Rights (“VPs”), v) environment, including biodiversity management, flaring and venting, greenhouse gas (“GHG”) management, waste and waste waters, vi) contractor health, safety, security and environmental (“HSSE”) management, vii) impact assessment vii) transportation including road, driver and professional driver safety, viii) social performance, and ix) product stewardship including supply chain management.

As required by BGC’s HSSE&SP management system, BGC have developed a comprehensive procedure for the development of greenfield projects, referencing all Performance Standards, WBG EHS guidelines and applicable WBG industry sector EHS guidelines (including the WBG onshore oil and gas development EHS guidelines). These requirements are to be adopted and integrated into greenfield project design and construction. The procedure defines greenfield project development standards, applicable to the BNGL project, including design and construction requirements addressing i) health, including health risk assessment, hazards, noise, and thermal stress, ii) security, including adherence to the VPs and contractor security plan review, iii) environment, including soil and groundwater protection, waste, emissions and biodiversity, iv) social performance, including community engagement, human rights, social investment and cultural heritage, and v) impact assessment, vi) safety, including process, personal and road safety.

A construction and installation contractor and pipeline installation contractor have been selected to develop the BNGL project through a competitive bid process. Ground works and foundations are underway with delivery of all equipment modules expected by mid 2020, and commissioning scheduled to commence during the first half of 2022.  Appraisal and monitoring of contractors are carried out throughout the life of contract. Contracts are required to include requirements for management of HSSE&SP risks and BGC’s contractor selection is dependent on this. As required by BGC’s HSSE&SP management system and supporting procedures, contractors are required to implement their own environmental and social management system (“ESMS”) that are linked to BGC’s HSSE&SP management system via an agreed bridging document. BGC’s procedures also require contractors adhere to applicable Performance Standards and WBG EHS Guidelines.

Identification of Risks & Impacts: BNGL’s power requirements are proposed to be supplied via an 8 km overhead power line from the existing Rumailah independent power producer (“IPP”). The overhead power line is considered an associated facility to the BNGL project. The BNGL project ESHIA assessed the potential impacts of the overhead power line to be of low significance. In the event where Rumailah IPP is offline, BNGL would draw power from the national electricity grid via the Rumailah IPP. The BNGL plant will have diesel-powered emergency generators to supply power to safety critical equipment and to safely shut down facilities in case of loss of outside power supply.

Sulfur will be recovered at the BNGL plant during the processing of associated gas via a sulfur recovery unit (“SRU”). The SRU is expected to produce up to 43 metric tons per day (MT/day). To facilitate the sulfur production a temporary storage and research facility for agricultural field trials will be developed. The facility is considered to be an associated facility to the BNGL project. An environmental, social and health impact assessment (“ESHIA”) has been developed for the temporary storage and research facility project referencing i) the Performance Standards, ii) the World Bank Group’s (“WBG”) general environmental, health, and safety (“EHS”) guidelines and iii) the WBG's EHS guidelines for waste management facilities. BGC shall, seek to ensure the power line and sulfur management facility installation and operations are undertaken in a manner consistent with the requirements of PS1, Guidance Note 1 (GN52) and applicable WBG EHS guidelines, per environmental & social action plan (“ESAP”) item #1a.

The majority of the wider BGC facilities were developed in the late 1970’s and early 1980’s and are not associated facilities to the BNGL project.

Management programs: BGC have developed a corporate wide implementation roadmap to ensure compliance with the HSSE&SP management system. BGC shall roll out the HSSE&SP CF Implementation Road Map elements applicable to the BNGL project, supported by appropriate resources and training, and provide updates to IFC per reporting schedule per ESAP #2.

The BNGL project ESHIA has developed an environmental, social and health management plan (“ESHMP”). Complementing the ESHMP, additional framework plans have been developed including i) a security, road traffic, social performance and local content management plan; ii) a general emergency response plan; and iii) a community liaison, community health safety and security management plan, all of which have been developed in alignment with Performance Standards requirements. The management plans define potential environmental and social impacts and proposed mitigation measures and provides the framework for implementing and monitoring those measures.

The framework action plan (or environmental commitments register) for the BNGL project is integrated into the project obligation register. The ESHMP allocates commitments that have been identified in relation to the ESHIA management plans and describes how adherence to the plans will be monitored and audited. The definitive source for all commitments made in the ESHIA is the commitments register (Appendix 8 of the Basrah NGL ESHIA), supplemented by the environmental monitoring plan. The ESHMP is a tool designed to help implement those commitments. The constructing contractor, and subcontractors, will be required to develop topic-specific management implementation plans, including construction environmental management plans or method statements including control / mitigation measures that address the commitments and requirements in the ESHMP as described in ESAP item #3a.

Organizational Capacity and Competency: At the corporate level, BGC has implemented a Higher Management Committee composed of ten members representing the shareholders’ interests. Reporting to BGC’s High Management Committee are a number of technical committees which provide E&S oversight across the BGC business, including i) a human resources discipline committee; ii) the “make it safe” steering committee; iii) joint planning and coordination committee; iv) audit committee; v) tender committee; and vi) a projects review board.

At the BGC corporate level, the health, safety and environment (“HSE”) department is led by an HSE director supported by 464 staff working across the BGC business. As part of the BNGL project, the HSE department will be responsible for and have HSE staff dedicated to the project development and operations. The corporate HSE department has a number of sub-functions which report to the HSE director, including i) occupational health and medical services; ii) technical process safety; iii) environment, including personnel responsible for air emissions management, soil & water management, ESHIA development and implementation; iv) emergency response; v) safety discipline including incident investigation, competency and road safety; vi) an HSE management system assurance team; and vii) operational project HSE.

BGC’s security function is led by a corporate security manager, supported by an additional 507 security personnel covering all operational aspects of the BGC business. A separate corporate affairs department is led by a corporate affairs manager which includes responsibility for social performance. The social performance team has in place a function lead and is supported by field-based community liaison officers. BGC has developed a social performance and local content plan defining the roles and responsibilities for the development of the BNGL project.

Emergency Preparedness and Response: BGC has developed and implemented a three tier emergency response plan applicable to all operations including the BNGL project, namely i) minor emergency such as a local incident, considered to be a non-escalating situation to be managed by existing asset resources; ii) a major emergency where there may be moderate to significant threat to safety and the environment requiring the oversight and intervention of BGC’s incident command team or where external assistance may be required; iii) a crisis situation where an event has or could cause significant disruption to normal business activities. BGC has developed a number of memoranda of understanding with the Iraqi emergency response services to support BGC’s emergency response plans.

Monitoring and Review: As required by BGC’s internal audit charter, BGC has in place a rigorous audit program supported by periodic shareholder audits against BGC’s HSSE&SP management system requirements. Similarly, as required by BGC’s HSSE&SP management system, BGC has developed a performance monitoring and reporting procedure and specifications manual defining key criteria for monitoring E&S performance requirements applicable to all BGC projects and operations. The BGC HSSE&SP management system and supporting procedures defines how contractors will be monitored, as well as requirements that need to demonstrate compliance with Iraqi laws, international laws, and GIIP.

Decommissioning: The BNGL ESHIA considers decommissioning activities and includes decommissioning in the assessment of impacts and development of proposed mitigation. Specifically, at the end of the BNGL 25-year design life, or later should the life of the plant be extended, the operator will plan the decommissioning of the plant. BGC seeks to return the BNGL site to its pre-development condition following decommissioning, including the areas where the broadcut pipeline passes through agricultural land. The approach to decommissioning and schedule will be determined in a decommissioning program to be developed toward the end of the BNGL plant’s operational life. The BNGL ESHIA commits to ensuring decommissioning procedures will reflect industry best practices and the Iraqi Ministry of Environment regulations in place at the time of decommissioning as reflected in ESAP #3a.

Grievance Mechanisms: BGC has developed a community grievance mechanism in a manner consistent with PS1 requirements, seeking to record, address and resolve individual, stakeholder group and community concerns. The grievance mechanism is applicable to all BGC operations. The social performance function is responsible for reviewing grievances monthly to ensure timely actions and close-out along with undertaking trend analysis. A dedicated email and phone number are in place and have been shared with the communities in which BGC operates to allow grievances to be communicated via a variety of avenues. Providing oversight of the grievance mechanism’s implementation, BGC collates and tracks grievances and reports to BGC’s leadership team monthly. The BGC HSSE&SP management system and supporting procedures also defines monitoring and use of a community grievance mechanism to monitor any issues that may arise between contractors and local communities. These measures comply with PS1 requirements and GIIP.

Gender: Based on IFC’s Gender Based Violence (“GBV”) Risk Screening Tool, the project is located in a region and country where the risk of gender-based violence is substantial. BGC shall undertake a BNGL gender impact assessment, the scope of which shall include GBV and will complement the BNGL ESHIA.  BGC shall develop an action plan based on the results of the gender impact assessment where applicable, per ESAP #1c.                                                   

 During construction BNGL will engage up to approximately 1,000 workers through BGC and its contractors, of which no less than 50% of BNGL construction personnel will be Iraqi nationals. During operations, BNGL will require approximately 200 personnel and contractors of which no less than 50% will be Iraqi nationals. BNGL operations will be continuous, and production workers will be divided into three crews and work in 12 hour shifts to cover this schedule and on rotation.

BNGL provides accommodation, meals and laundry services for personnel working at BNGL. Worker welfare and workers condition will be based on international standards such as IFC Performance Standards, specifically PS1 and PS2. Accommodation is consistent with the requirements of the IFC/European Bank for Reconstruction and Development guidance note: “Workers’ accommodation: process and standards”.

Human Resources Policies and Procedures: As defined by BGC’s human resources (“HR”) policy manual, working conditions and employment terms have been developed consistent with national and international laws and standards. The HR policy manual requires BGC to ensure the BNGL project provides all workers, including supply chain workers, a safe and healthy work environment, taking into account inherent risks and specific classes of hazards in the work areas. These include physical, chemical, and biological as well as specific requirements for female workers including the monitoring and mitigation of gender-based violence in the workplace.

The BGC human resources policy manual requires i) workers are provided with documented clear information regarding their rights and any collective bargaining agreements; ii) the right to freedom from forced and compulsory labor; iii) there is no employed or contracted child labor as defined by International Labour Organization (“ILO”) and national laws, consistent with PS2 requirements; iv) the right to freedom of discrimination according to ILO standards and national laws; v) the right to freedom of association and collective bargaining as defined by ILO standards and national laws; vi) provision of adequate means to raise employment concerns without fear of reprisals through employee grievance mechanisms; vii) the provision of a living wage and minimum wage as defined by national law and international standards; viii) workers are provided with adequate food and fluids that comply with WHO standards and national law; ix) workers have access to primary health care and emergency medical services; and x) regular monitoring of workers’ welfare and working conditions and take necessary preventative and corrective actions.

For operations, BGC will assign personnel to the BNGL project. All personnel undertake an induction program, HSE training, training to refresh or upgrade skills if working in a technical field, and then area-specific training that pertains specifically to the job. During the construction phase, training and skill development opportunities will be provided to the existing BGC workforce and by BGC’s main contractors to their own personnel. BGC will monitor the type and duration of training provided by BGC and its main contractors during the project. BGC will record and provide training certificates to those who successfully receive training during the project development, so that they are able to demonstrate their competency to other employers in the future.

Working Conditions and Terms of Employment: the majority of BGC staff are seconded from the respective shareholders. In addition to the secondees, there are locally contracted staff who have employment contracts through a 3rd party manpower agency consistent with the provisions described above. There are different types of contracts including probationary workers engaged for a trial period and workers hired on either a fixed term or indeterminate period. Terms and conditions of contracts are supplemented by the staff regulations, internal rules and other legal facilities as per the applicable labor law. BGC shall implement and extend corporate working conditions, terms of employment worker grievance processes to the BNGL project consistent with PS2 requirements per ESAP 4a.

Non-Discrimination and Equal Opportunity: As established in the BGC code of conduct and general business principles, BGC is an equal opportunity employer and does not tolerate any discrimination on the basis of race, color, religion, sex, national origin, age, sexual orientation or disability, or according to applicable national laws and regulations. BGC is committed to fair employment, including equal treatment in hiring, promotion, training, compensation, termination and corrective action.

Women make up less than 10% of BGC’s workforce. In 2018, BGC established a Gender Diversity Network (GDN) to create a platform to enable members to develop and grow personally and professionally. The Network is built on the existing BGC polices and development opportunities and contributes to the inclusive and diverse environment in BGC regardless of gender or ethnicity. The GDN continues to support female development and works to enhance the representation of women in the company’s activities, where it is accepted that competition must be based on competency and not gender. The GDN aims to inspire women and men to work collaboratively together and support each other.

Occupational Health and Safety: The BGC HSSE&SP policy and management system requires the BNGL project prevent accidents, injury, and disease arising from, associated with, or occurring during work by minimizing, as low as reasonably practicable, the causes of hazards. BGC has developed and implemented a health hazard manual, which applies to all BGC projects and operations including the BNGL project development and operation. The manual is BGC’s reference document for managing occupational health and hygiene risks, through specific tasks, handling or being exposed to the products, consumables, raw materials and/ or activities of BGC or its contractors. For the BNGL project this has been implemented through a health risk assessment process, led by health risk assessment subject matter experts, identifying all tasks that have the potential for worker exposure to hazardous substances or agents.

Workers Engaged by Third Parties: As described previously, a construction and installation contractor (“CIC”) and pipeline installation contractor (“PIC”) has been selected to develop the BNGL project. As defined by the HSSE&SP management system and supporting procedures, CIC and PIC contractor and supply chain workers (personnel engaged by the BNGL project’s primary suppliers) are required to have written contracts and have appropriate training. Subcontractors and suppliers are required to comply with Iraqi laws, international labor laws, PS2 and human rights principles. BGC shall develop and implement supply chain management procedure for the BNGL project per ESAP #4b.

As noted previously, the BNGL CIC and PIC contractors are required to implement their own ESMS that are linked to BGC’s HSSE&SP management system via an agreed bridging document per ESAP #3b. Therefore, EPC contractors must apply appropriate control measures to minimize safety risks, environmental impacts and social disturbance and are subject to BGC assurance processes. Contractors are also required to monitor parameters agreed with BGC and communicate all E&S performance data and incidents.                                                  

 Since the Company's inception in 2013 to 2018, BGC greatly reduced greenhouse gas emissions from the non-BGC operated licensing-1 oil fields of West Qurna 1, Zubair and Rumaila, preventing 70 million tons of CO2e from entering the atmosphere, while turning previously wasted flared gas to much needed power generation for million homes in Iraq.

The BNGL project has been designed to meet the requirements of i) PS3, ii) WBG general EHS guidelines, iii) the WBG EHS guidelines for onshore oil and gas development, iv) the World Bank Group ‘Zero Routine Flaring 2030’ initiative, v) ISO 14000 environmental management standards, and vi) ISO 14064: measuring, quantifying, and reducing Greenhouse Gas emissions. To implement these requirements during construction and operations, the BNGL project ESHIA includes framework management plans addressing i) waste management ii) training in pollution prevention; ii) air emissions and dust management; iii) wastewater discharge, iv) noise and vibration management; v) oil and chemical management; vi) spill response; and vii) contamination monitoring and reporting.

Water Consumption: Water use at the project is primarily to support the water requirements for the demineralization and remineralization units of the BNGL process. The BNGL ESHIA estimates water use for construction and operations will be up to 200 m3/ d and 700 m3/ d respectively. BGC has decided not to proceed with a water intake pipeline which was identified in the BNGL ESHIA as having the potential to raise limited biodiversity exposure. An alternative water source has been selected via the installation of a 17 km water pipeline from the Al Nukhail water pumping station taking feed water from an existing surface water pumping station, Qarmat Ali to the east. 

Greenhouse Gases (GHG): Iraq is a signatory (Dec 2016) to the Paris Agreement to the United Nations Framework Convention on Climate Change to limit GHG emissions (subject to ratification). Iraq has also committed to the World Bank Zero Routine Flaring Initiative. The role of BGC and the development of the BNGL project is a component to realizing this commitment.

BGC has developed a corporate level GHG and energy management plan for all assets. The plan outlines BGC’s position regarding climate change impacts, emissions profile and abatement plans, and provides a framework for the analysis and management of GHG emissions as well as quantitative analysis and data on GHG reductions. The BNGL project will generate 450 kt CO2e/ year of GHG emissions from combustion equipment and power use. However, the BNGL plant will enable BGC to prevent over 9.5 MTPA of upstream gas flaring by 2025 (compared to 2020 levels). As part of IFC’s investment, BGC shall update the GHG and energy management plan specific to the BNGL project in line with PS3 and WBG general EHS guidelines (greenhouse gasses) as described in ESAP #5.

Solid & Hazardous Wastes: BGC have developed a corporate waste management plan applicable to all BGC operations, including requirements for storage, collection and transport, training requirements, monitoring and auditing, roles and responsibilities. A BGC waste manager is responsible for all waste related matters across BGC operations including the BNGL project development and operations. The BNGL project ESHIA assesses waste impacts, including hazardous wastes, and project level waste management planning referencing the BGC corporate waste management plan as the primary document for waste management standards. As part of IFC’s financing, BGC shall finalize the BNGL waste management plan for construction and operations as defined in ESAP #3a.

BNGL is expected to produce up to 25 metric tons per day (MT/day) of dry non-hazardous sulfur cake in the medium term, with a higher production possible into the longer term (up to 43 MT/day). A sustainable solution is currently being investigated for the produced sulfur, including the intended commercialization of the sulfur product for sale into agriculture as a fertilizer in Iraq. During the period between commencement of sulfur cake production and successful identification of the sustainable solution, a temporary (up to three years) storage facility may be required. An ESHIA, has been developed in a manner consistent with the Performance Standards as this is considered an associated facility for the project. This storage will also include a test bed for agricultural field trials. The sulfur storage and agricultural research area is expected to have a life-span of up to five years and decommissioned thereafter. The facility may further act as temporary storage capacity at times throughout the Basrah NGL plant lifetime to match production with supply and demand; therefore a renewal/ rolling approval of the facility may be sought throughout the life of the Basrah NGL plant.

Wastewater/ Effluent: The BNGL facility has been designed as a zero-discharge facility. No waste waters will be discharged to the environment during operations, rather all wastewaters will be discharged to evaporation ponds. During commissioning, as required by BGC’s greenfield development procedure, the BNGL project shall adhere to pollution prevention and control measures for waste waters and hydrotest water as articulated in the WBG general EHS guidelines, and WBG EHS guidelines for onshore oil and gas development respectively.

Air Quality: The project ESHIA undertook air dispersion modelling using the United States Environmental Protection Agency (US EPA) AERMOD modelling software. The modelling accounted for baseline ambient air quality conditions, determining that the maximum ground level concentrations of NOx, SO2 and PM10 at or beyond the Basrah NGL fence line will be within BGC’s air quality standards. BGC’s project’s emissions standards have been developed to comply with the WBG general EHS guidelines for small combustion facilities (table 1.1.2). Similarly, BGC have defined air quality standards based on Iraqi and WHO air quality standards (whichever the more stringent) and will thereby meet or exceed WBG general EHS guidelines requirements.

Noise and Vibration: As defined in BGC’s greenfield development procedure, the BNGL project has been designed to operate in a manner consistent with WBG general EHS guidelines for noise (table 1.7.1). For sensitive receptors, the noise level at the edge of the existing nearest settlements and the project's residential area has been designed not to exceed the guideline limit of 45 dB(A) or 3dB(A) above background at night (22:00 - 07:00) and 55 dB(A) or 3dB(A) above background during daytime operation. Noise modelling undertaken for the BNGL project ESHIA determines that under normal operations, noise exceeding the 70dB(A) industrial noise standard is limited to the BNGL site. In an emergency flaring scenario, which is a non-routine temporary event, there is potential for noise exceedances which may extend beyond the eastern boundary of the site. The ESHIA concludes that for these non-routine, temporary flaring scenarios, impact significance on residential receptors from elevated ambient noise is minor. As part of IFC’s financing the BNGL project shall develop and implement a contractor noise management plan for the development of the BNGL project per ESAP #3a.

 BNGL project’s structural elements, components and pipelines have been designed, and will be constructed, operated, and decommissioned in accordance with GIIP. The BNGL project design has been subject to a quantitative risk assessment, considering safety risks to workers, third parties or affected communities. The BNGL health risk assessment, quantitative risk assessment and emergency response plan all consider potential risks to communities which may be exposed to potential hazardous materials, substances or emergency events. BGC will evaluate the potential risks and impacts to the health and safety of Affected Communities during the project lifecycle and will establish preventive and control measures consistent with PS4 requirements and good international industry practice (GIIP).

In view of the Iraqi post conflict environment, IFC has assessed contextual security risks as high for the BNGL project. To manage these contextual risks, and as required by BGC’s HSSE&SP management system, BGC has in place a robust security management system adhering to recognized good international industry practice, namely the VPs. This is supported by a rigorous assurance process subject to internal and external audit and review. All audits undertaken to date have found BGC operates in a manner consistent with the requirements of the VPs. Since commencement of BGC operations in 2013 there have been no adversarial attacks on BGC assets or material disruptions to BGC operations.

Applicable to the BNGL project, implementation of the VPs is defined in BGC’s security standards and security manual. Consistent with the requirements of BGC’s HSSE&SP management system, a BNGL risk assessment has been undertaken and security plan developed for the construction of the plant. The plan complements and interfaces with the BNGL construction emergency response plan. BGC shall complete and implement i) a security plan ii) an emergency response plan and iii) health risk assessment for the operations phase of the project, per ESAP # 6b; 6c and 1b respectively.

At the corporate level, BGC’s security function is supported by 507 security personnel comprised of both BGC personnel and contractors. According to the security plan requirements, BGC’s security function have assigned dedicated security personnel for the development and operations of the project.

BGC undertakes regular training on the VPs for its security personnel and contractors. BGC also maintains relationships with the relevant Iraqi government security agencies responsible for the oversight of BNGL’s operations. These relationships have been established and formalized via memoranda of understandings, supported by regular BGC engagements with Iraqi security agencies on VP related issues. BGC has established a training program on the VPs for governmental security personnel.

Stakeholder engagement was undertaken as a part of the BNGL ESHIA process to meet regulatory, BGC corporate and PS1 requirements for stakeholder consultation and disclosure.  Stakeholders were identified and engaged using culturally appropriate methods to ensure regular and accessible access to information.

Engagement with affected households and businesses that may be impacted by BNGL has been undertaken as part of BNGL project baseline surveys. Recognising that stakeholder engagement is an ongoing process undertaken throughout the lifecycle of a project, BGC will continue to engage with relevant stakeholders, building on the activities undertaken to date in order to negotiate the different aspects of the compensation packages and make arrangements for the implementation of the final RAP per ESAP#7.

BGC has a social investment strategy that supports initiatives that addresses risks and opportunities associated with the business; provides measurable society benefits; are financially and operationally sustainable beyond the BGC investment and are in areas where BGC can make a significant and meaningful contribution. Current focus areas are vulnerable people, road safety, education and employment.

BGC’s flagship program – Khutwa (‘step’), aims to support youth employment by upskilling young women and men in highly demanded trades. By the end of 2019, BGC will have trained over 600 young people and supported them with their job search. Through this program, BGC works closely with academic partners and the many players in the oil & gas industry to help alleviate youth unemployment. Participants in the program have been identified in collaboration with Basra Provincial Council, with a portion of the training spots being held for those youth who are impacted by the BNGL pipeline.

An additional focus for BGC is education and safety. Creating a safer, more constructive environment for school children across the communities in which BGC operates. Since 2018, BGC has been involved in the rehabilitation and construction of five schools close to BGC’s operations and will expand its support in the coming years. Over 1,350 students are benefitting from these programs resulting in improved learning conditions. BGC’s social investment strategy is reviewed on an annual basis.                                                   

 Company: Basrah Gas Company

Point of Contact: Yogesh Yadav, BGC Head of Treasury

Email: communications@basrahgas.com

Mailing Address: P.O. Box 2705 Al Ashar Post, Khor Al Zubair, Basrah, Republic of Iraq

Website: http://www.basrahgas.com/