PS7: Indigenous Peoples does not apply as there are no indigenous peoples, as defined by IFC Performance Standard 7, within the project area.

The expansion project in area 1 represents incremental increases to an existing footprint and thus the risks and impacts do not represent significant incremental changes relative to the existing mining activities. However, similar risks are present in the area 5 greenfield development which will create significant impacts. Thus, the planned expansion project in total, will result in significant impacts including: dust generation; surface water and groundwater quality and flow conditions; noise; waste management; occupational health and safety; prolonged land take of land that would otherwise be rehabilitated and used for agriculture; habitat loss for great apes and priority biodiversity values; significant physical and economic displacement of communities; in-migration; and community health and safety related to project implementation and operation, including dam safety. Thus, this is a Category A project according to IFC’s Policy on Environmental and Social Sustainability.

The Company will update and strengthen its existing environmental and social assessments, management plans and reports, particularly for identified risks for its current, foreseen and planned and future expansions. In addition, SRL is committed to implement all the environmental and social action plans specific to the expansion project in accordance with IFC PS. 

Health, Safety, Environment and Community Management System (HSEC MS): Since the acquisition of SRL by Iluka in 2016 the company has been developing this system based on the Iluka Health, Safety, Environment and Community Policy, management systems and standards and three separate ESHIA. The HSEC MS, which incorporates and integrates policies, plans and procedures, is being upgraded to align with the requirements of ISO 14001:2004 and OSHAS 45001:2018. SRL has retained the services of Sustain Consulting, an environmental consultancy, to ensure coordination and consistency between the three consultancies engaged to complete the individual ESHIA’s covering the full scope of the project. 

The HSEC Management System covers the lifecycle of project activities from exploration, planning and project development, through to operation, closure and rehabilitation. This provides SRL with a risk-based procedural framework for implementing, achieving, reviewing and maintaining its environmental and community policies and all environmental and social management targets. The risk management system is the overarching framework which defines the management of risk for the project and ensures a consistent application of risk management across SRL operations.

The Environmental, Social and Health Management Plan (ESHMP) provides a link for the project between policy and implementation as a planning document summarising the legal requirements and obligations, international standards and guidelines, and environmental and social commitments outlined in the ESHIA, and presenting the management measures and monitoring programmes to be undertaken to achieve these.

Consistent ESHMPs are being developed for area 1, the haul road and area 5. Detailed implementation arrangements are also being developed for these ESHMPs including mechanisms to monitor that they are implemented in accordance with Sierra Leone regulations and IFC PSs.  The EHSMP’s cover management and / or mitigation measures that are being taken / will be taken to address impacts with respect to the current operations, the expansion phase and the decommissioning and closure phase. The EHSMP’s are considered to be living documents that will be periodically reviewed and updated by SRL.

Policy: SRL has a suite of corporate policies guiding the environmental and social management of the operation but which predate Iluka involvement. Updating of these Policies to align with Iluka Policy and international standards such as the IFC PS’s is ongoing and the full SRL ESHMP will only be completed once the area 5 ESHIA referred to above is completed. These policies include:

SRL Sustainability Policy (2015) – commits the company to implement management systems that make health, safety, environment and community responsibilities an integral part of business decisions and activities;

SRL Environmental Policy (2015) – commits the company to environmental excellence based on the promotion of open and honest communication on environmental and community issues, protection of the environment, promotion of sound and responsible practices and fostering of continual improvement;

SRL Occupational Health and Safety Policy (2015) – commits the company to “zero harm” to people and achievement of highest standards across its operations. This includes the compliance to Sierra Leonean law and alignment to the OSHAS 18001 system;

The overarching Iluka Policy is the Iluka Health, Safety, Environment and Community Policy (2017) which commits the company to operate in a sustainable manner by targeting high levels of performance and pursuing leading practice in the areas of health, safety, environment and community reflecting the company’s values of Commitment, Integrity and Responsibility.

Identification of Risks and Impacts: The SRL operation has existing Environmental Licences for area 1 and the haul road. Under previous ownership, SRL undertook ESHIA studies for their operations in 1992, 1997, 2001 with an update in 2012. When these studies where undertaken, the primary mining process was dredge mining, the transition to dry mining only commencing in 2013.

The 2001 ESHIA (volume 1) and ESHMP (volume 2) were prepared by Knight Piésold (USA) to fulfil the national environmental regulatory requirements of Sierra Leone as well as the international standards at the time, including the IFC Safeguard Policies. Of note, the ESHMP included a Resettlement Action Plan (RAP) for Foinda Village (started but not completed from 1994 onwards). The current Foinda resettlement which was undertaken in 2018 was under a completely new RAP approved by the EPA-SL.

In 2015 the Sierra Leone Environmental Protection Agency (EPA-SL) issued a notification to SRL instructing them to undertake an ESHIA and develop an ESHMP for their current and proposed dry and wet mining activities in area 1 including the proposed expansion areas. SRK Consulting (South Africa) (Pty) Ltd (SRK) was appointed by SRL in 2016 to undertake a scoping site visit and to develop a scoping report that met the Sierra Leone legal requirements. This scoping report was submitted to and accepted by the EPA-SL. Subsequent to the SRK appointment Iluka acquired the SRL operation and requested that the ESHIA and ESHMP be completed in accordance with Iluka’s corporate policies, which are aligned with good international industry practice (GIIP) including the IFC PSs. This ESHIA was completed and submitted to the government in March 2018 and was approved by the EPA-SL on 19 June 2018, it has also been reviewed and commented upon by IFC. Some gaps with the IFC PS were identified and SRL is addressing these by strengthening its approach to resettlement, community affairs and on biodiversity in particular. Specific timebound actions to address the gaps, acceptable to IFC, are set out within the ESAP.

For the proposed area 5 expansion, Cemmats Group Ltd, based in Sierra Leone were engaged to undertake an ESHIA and ESHMP for the haul road linking area 1 to area 5, this was also approved by the EPA-SL on 22 February 2018 and the licence issued on 28 March 2018. Both the area 1 and haul road ESHIA’s have been disclosed on the SRL website. Finally, Earth Systems of Australia, and Environmental Consulting Services (ECS) of Sierra Leone were engaged to undertake the ESHIA and ESHMP for area 5, this work is still in progress with an anticipated submission to government later in 2019 as per ESAP item 1.

There is potential for cumulative impacts arising from the combination of areas 1 and 5 and other current or potential mining operations in southern Sierra Leone; such cumulative impacts were assessed during the ESHIAs. These include loss of habitats, increased noise and air emissions, pressure on surface and groundwater resources and quality, socio-economic, etc. The cumulative loss of habitats, associated species and ecosystem services is not expected to be significant. Social impacts related to in-migration to the mining area in search of jobs and other economic development opportunities as well as increasing loss of agricultural land are also potentially significant cumulative impacts.

Restoration / Rehabilitation and Closure: As part of the ESHIA process, a detailed mine closure plan has been developed. The overall objective of the closure plan is to implement remedial measures in a manner that the land capability of rehabilitated areas is capable of sustaining a variety of post closure uses and with acceptable post-closure residual risks. Sub-objectives include ensuring the safety and health of all stakeholders during and post closure, utilising closure techniques that result in areas in a self-sustaining condition, addressing host community requirements, needs and concerns. Prior to closure, ongoing rehabilitation will be carried out and during September 2017, SRL held a workshop on rehabilitation to determine land capability and land use suitability of the different landforms. Outcomes of the workshop included a list of landform types and then to qualitatively assign potential land use and the potential level of difficulty in achieving that land use.  This information is presented in a matrix in the closure plan. SRL will undertake landform restoration with key mitigation measures and potential uses detailed for each identified existing landform. Financial provision has been made based on an estimate of liability prepared using a model known as the Standardised Reclamation Cost Estimator. The present closure obligation for SRL, prepared in 2017 in accordance with the requirements of the International Financial Reporting Standards is US $ 51.3 million. Iluka’s closure provision applies an additional contingency to this liability estimate which will be updated regularly.

Gender Issues: In Sierra Leone, women have been historically discriminated against and are under-represented in the traditionally male-dominated political and socio-economic decision-making structures, for which gender inequalities are further exacerbated, particularly with relation to marriage, property rights and sexual offences.  The legacy of the conflict in Sierra Leone, both in terms of widespread sexual violence and the changes in gender roles brought about by violence and displacement, has influenced the nature and extent of Gender Based Violence (GBV) in the post-conflict phase. Local police have special units to receive, investigate and prosecute gender-based violence cases but, in practice, adequate implementation may be limited.  It is against this backdrop that SRL has in place policies and procedures to promote gender equality in its workforce and protect the surrounding communities through its workers’ code of conduct, anti-sexual harassment policy, support health sensitisation programs, establish dialogue with the female workforce, and labour and community grievance mechanism (refer to PS2 and PS4 for further details).

Management Programs: Each of the ESHIAs identified above has a dedicated ESHMP. SRL is developing an integrated ESHMP which consolidates all the different ESHMPs into one single document. This will help the company to manage all environmental, safety and health aspects of the project in a streamlined and consistent way and to improve or enhance the compatibility of the project with the environment and surrounding communities.

For each identified environmental and social impact, the ESHMPs will present a set of mitigation measures to be adopted for the different phases of the project, performance indicators, monitoring and reporting requirements as well as the implementation timeline and responsible parties. 

All contractors working on site will follow SRL’s HSEC MS but it is likely that main EPC contractors will also bring their own management systems.  SRL will review the compatibility of their management systems and ensure that there are no gaps between these and SRL’s HSEC MS, and will develop HSEC MS bridging documents to facilitate implementation and monitoring. 

Organisational Capacity and Competency: The project ESHMP outlines the SRL planned organisational structure and capacity. The in-country CEO of SRL is currently overseeing all aspects of the project, supported by environmental and social consultants developing the ESHIAs who have been also supporting all aspects of environmental permitting and stakeholder engagement.

SRL proposes an organisational structure within its HSEC MS manual. The proposed structure is comprised of an EHS Manager who reports to the Chief Operating Officer (COO); Community Affairs and Resettlement Managers both report to the CEO. The Security section reports to the Risk Manager, who in turn reports to the COO. Personnel based in Australia are involved on a consulting basis, but also have a broad-based oversight role. There is also support provided from the South African office.  The proposed staffing plan includes the necessary HSEC MS resources in the field to adequately supervise and manage HSEC performance in all the components of the project.  

In addition to the in-house capacity, SRL uses consultants for specific specialised tasks such as biodiversity (flora and fauna) and chimpanzee monitoring as applicable. A team of suitably qualified and experienced resettlement consultants will be engaged to provide additional support and complement monitoring activities of resettlement processes.

SRL has a Community Affairs Department and a Resettlement and Social Development Department both reporting to the CEO. These departments responsibility is to adequately manage social issues and risks in area 1 and area 5 while allowing effective social inputs across relevant departments such as operations, rehabilitation, health and safety.  SRL plans to strengthen the Community Affairs Department by hiring additional staff for community engagement while the Resettlement and Social Development Department will be reviewed and upgraded prior to the start of construction on the Sembehun development. Other areas that will be strengthened include GIS, data management and community livelihoods as per ESAP item 3.  Additionally, SRL will include responsibility for the management of in-migration mitigation plans in area 5 within the Community Affairs Department.                                                   

Emergency Preparedness and Response:  SRL has developed an Emergency Response Plan (ERP) for area 1 to identify the potential for, and responses to, accidents, incidents and emergency situations and preventing and mitigating the likely associated illness and injury. The ERP contains procedures for specific emergencies such as fire, medical emergency, hazardous chemicals, civil/labour disturbances, etc. The ERP includes reporting procedures and responder roles. Emergency drills are scheduled regularly and conducted to identify potential areas for improvement. Records of these drills are kept. All employees and contractors are responsible for reporting any emergency incident(s) to their supervisor or the responsible person of the area. The ERP will be subject to continuous monitoring and review, in response to changing circumstances as well as internal practices. This will include the development and implementation of department specific ERPs as the project evolves.

Monitoring and Review: Internal and external monitoring of ES&H parameters is already undertaken. This includes: internal weekly inspections; environmental audits; monthly and annual management review meetings; physical monitoring (water quality and quantity, and rehabilitation, etc.); and incident and accident reporting and addressing external complaints. The Company is also subject to monitoring through scheduled and non-scheduled site visits by the EPA-SL monitoring team. However, SRK identified monitoring and reporting as an area requiring significant strengthening. Thus, as per the ESAP item 2, SRL has committed to compile and implement an updated and comprehensive monitoring and reporting plan, particularly for water quality and flows, air emissions, dust fallout and PM10, etc. The integrated ESHMP will eventually include all of the SRL operations including area 1, area 5 and the haul road.

Monitoring of the implementation of commitments made in the ESAP will be on-going through a regular Independent Environmental, Social & Health Consultant (IESHC) auditing process and through IFC supervision visits. Community stakeholders including Paramount Chiefs and other chiefdom authorities, local council authorities and civil society groups including youth and women’s groups will be included in participatory monitoring. On-going quarterly public consultation meetings, quarterly meetings held with Paramount Chiefs and local directors and various other community meetings will provide the opportunity for regular review and amendments of strategy.

SRL will develop appropriate Key Performance Indicators (KPIs) (such as diesel and water use, occupational, health and safety (OHS)) to evaluate the performance of the controls and proposed mitigation measures. The KPIs will be linked to specific targets based on SRL’s objectives or on the national regulation or international standards. SRL will also adopt a philosophy of adaptive management and continual improvement of monitoring the ESHMP to ensure that the proposed specific management plans, embedded controls and proposed mitigation measures are consistently meeting project standards and KPIs.    

Social Investment: Corporate Social Responsibility (CSR) spend is divided into mandatory and voluntary contributions. SRL’s voluntary contributions focuses primarily on education by enhancing access to junior and primary education as well supporting vocational training. SRL’s mandatory social and development initiatives are carried out through its Community Development Plan (CDP), which compliments the Community Development Agreement (CDA) describing SRL’s commitments for corporate social responsibility (CSR) activities as per the Mines and Minerals Act (2009).  The CDA establishes the overall structure, modus operandi and commitments of all parties involved, particularly the communities, in identifying and implementing community development activities, and setting up annual funding to support these activities. The CDA further includes commitments for assisting in the promotion of sustainable development, enhancing the welfare and quality of life of communities affected by the mine, as well as supporting the community participation on the negotiation and implementation of the CDA in a fair, transparent and sustainable manner.  Community development investments in infrastructure, education, health and agriculture proposed under the CDP are identified and implemented through the Community Development Committee (CDC) established in 2017. The CDC consists of: (i) representatives of the Bonthe and Moyamba District Councils; (ii) the Paramount Chiefs of Upper and Lower Banta, Imperri, Jong and Bagruwa; (iii) Members of Parliament; (iv) five Chiefdom land owners representatives; (v) five Chiefdom religious heads; (vi) five Chiefdom women’s leaders; (vii) five Chiefdom youth leaders; (viii) five farmers representatives; and, (ix) civil society representative.  SRL is also represented on the CDC but is an autonomous body and neither SRL, the government or the paramount chiefs can play a management or controlling role.

An ongoing challenge for SRL is to ensure that, through the CDC, community development investment is equitably distributed among the settlements and communities impacted by SRL while managing the various interests from stakeholders involved. In addition, SRL contributes to a mandatory Agricultural Development Fund (ADF) as per the Mines and Minerals Act (2009).

Working Conditions and Management of Workers’ Relations: SRL employed 2,478 people as at the end of December 2018, of which over 98 % are Sierra Leonean nationals. Of these there are circa 100 Sierra Leoneans in management positions plus a further 180 employed as senior staff members. About 90% of the workforce reside in the surrounding areas and housing to management and senior staff is provided through its Mobimbi and Kpanguma camps accommodating up to 440 people.  SRL also uses contractor companies to provide services such as fleet maintenance, corporate services, shipping and camp management.  An additional 300 jobs are expected with the commencement of construction and operation activities in area 5.  A key challenge will be for SRL to manage high community expectations regarding employment and prioritizing access to these jobs for people from the surrounding communities.

Human Resources Policy and Procedures:  SRL has in place a number of self-standing human resources policies (such as leave, benefits, remuneration, recruitment, overtime, disciplinary, promotion, travel, learning and career development, retirement, grievance, etc.), which support the core provisions stipulated under the Collective Bargaining Agreement (CBA) for general staff (below supervisor grade) signed with the United Mineworkers Union.  SRL is currently consolidating and updating all human resource policies into an HR Manual as per ESAP item 4.  In particular, SRL has a Sexual Harassment Policy in place, for which the handling procedures have been upgraded in the past 12-18 months to adequately manage cases.  SRL draws attention both to the anti-sexual harassment policy and to a zero-tolerance policy towards offenders in order to minimise and address the risk of female staff being harassed in the male-dominated site and society.  SRL will continue to look at ways to reinforce the message and to also encourage potential cases be brought to management’s attention. As per ESAP item 4, SRL will provide training of workers on the subject.

Working Conditions and Terms of Employment: SRL provides full-time employment through two types of contracts: (i) permanent with no specified end date to employment; and (ii) short-term with an employment duration not exceeding 2 years. Casual employment does not exceed the period of 3 months without a break and specific rights and obligations are stipulated accordingly through the relevant recruitment policy in compliance with Sierra Leonean labour law. SRL provides a number of benefits to permanent employees including leave (annual, maternity and urgent personal affair and compassionate leave), allowances (housing, food, electricity), end of service benefit, health care and medical insurance, travel and education allowance, among others. All employees are also registered in the National Social Security Insurance Trust (NASSIT) as required by the country’s labour code. Employees are required to pass a medical examination. All employees are required to undergo a successful probationary period of three months before confirmation of employment. SRL provides workers transportation to their work sites, including the MSP, from a number of small towns in area 1. 

Workers’ Organisation: The CBA (gazetted in June 2018) between Sierra Leonean mining companies and the United Mineworkers Union has been in place since 2012 (reviewed every three years) which sets up the terms and conditions of employment applicable to all employees below supervisory level. While casual workers are not formally covered by this agreement they do fall under Sierra Leone labour legislation covering terms and conditions of employment including hours worked and the union may pick up on their issues and represent them.  SRL management and the union executive (representing the 21 union shop stewards (18 male 3 female)) meet on a quarterly basis and also ad hoc depending on the issue.  

Non-discrimination and Equal Opportunity: The CBA and related policies (such as the Recruitment Policy) clearly states SRL’s commitment as an equal opportunity employer and to not discriminate against employees due to either being union members or engage in union activities, or due to race, colour, religion, tribe, sex and political affiliation.  Female workers make up a rather small proportion of the total workforce (under 7 %) and their union representation is limited (3 females out of the 21 representatives) for which women’s issues may be potentially overlooked.  There is, however, an SRL womens’ association comprised of a mix of general and senior staff which is active locally (promoting empowerment among girls in the community and raising money for bursaries). SRL plans to find mechanisms to better understand female staff members’ perspectives and concerns, in particular around key issues such as GBV and sexual harassment. 

Retrenchment: Retrenchment is currently envisioned for those dredge employees who are not re-deployed when this production unit ceases operation in March 2019. SRL will follow the provisions stated under the CBA. In broader terms, these provisions include (i) notification to the Secretary General of the union and the Commissioner of Labour of the details of the planned retrenchment; (ii) consultations with the union representatives; (iii) guidance on payments; and (iv) notification period.  SRL will formalise procedures for retrenchment of the workforce in line with PS2 as per ESAP item 4 as part of the development of the HR manual.

Grievance Mechanism: SRL has a grievance policy in place describing the procedures for handling a labour grievance, which is guided by the Wages and Industrial Relations Act of 1971 and the CBA between SRL and the Union.  Most often, labour grievances are communicated through the Union representatives on issues regarding pay raise, allowance, and transport, which in turn, are discussed with SRL’s management.  As part of the development of the HR manual, the updated grievance mechanism will allow for anonymous lodging of grievances as well as complaints related to sexual harassment and gender-based violence, as per ESAP item 4.

Occupational Health and Safety (OHS): SRL has developed an Occupational Health and Safety Management Plan (OHSMP) consistent with its HSEC MS described under the PS1 above. The OHSMP, which is consistent with GIIP, clearly defines roles and responsibilities, health and safety process implementation, objectives and targets, general safe work practices, personal protective equipment (PPE) etc. All employees and contractors are required to implement the approved OHSMP for all work performed on SRL activities. Where contractors have their own environmental, health and safety management systems, SRL will ensure that contractor practices are aligned with SRL’s HSEC MS as outlined above.

Safety performance (covering SRL and subcontractors) is well tracked and includes details of any incident’s and necessary follow-ups. In addition, the incidence of malaria amongst local and expat workers, and days lost due to malaria, is tracked and incidence rates against the time of year plotted to assist managing the issue. The company is committed to achieve zero injuries and zero harm in its operations. The need for PPE dedicated to the particular workplace is defined by risk assessment and is provided and worn by workers. This may include safety boots, protective gloves, hard hats, flotation devices, and ear or eye protection, according to workplace risk.

Resource Efficiency: The main resources utilised by the project include water (used to support the mining and processing operations) and diesel / marine fuel oil (used in electricity generation, mining processing and transportation). SRL is implementing several initiatives to reduce consumption of these resources. These initiatives will include identifying areas for resource efficiency assessment; consideration of energy efficiency in the purchase criteria of the equipment; and ensuring that water, energy and fuel consumption are monitored and reported. 

Energy: SRL produces its own electric power by means of a 28 MW power plant (4 x 7 MW Caterpillar V-16 units), there are also 3 x 800 kW standby diesel units. Marine Fuel Oil (MFO) is delivered by road tanker from Freetown or by sea, SRL is not responsible for emergency response in a spillage incident or accident on the national road network, however SRL supports where required (and also works on ensuring the suppliers response time and checking that their equipment is adequate).

Waste oil is disposed of by sale to Vimetco, a nearby bauxite mine which uses the waste oil as fuel in its dryers, currently there are no oil recycling facilities in Sierra Leone. SO2 and NO2 monitoring is undertaken at five locations within area 1. The results of quarterly monitoring reflect that both SO2 and NO2 remain well below the IFC EHS Guideline 1-hour limits.

Water:  This region of Sierra Leone has a Tropical or Equatorial monsoon climate and is characterised by a marked wet and dry season. In the southern province, there is significant rainfall in most months of the year with a short dry season with average annual rainfall of approximately 2 600 mm with annual evaporation of approximately 800 mm, illustrating a significant water surplus. The surface water resources at the mine have been significantly changed from natural flow conditions since the historical mining areas are largely ponded and the outflows into the natural river systems are via spillways from these impoundments. Analysis of these water bodies in the area 1 ESHIA suggests that where they are not impacted by current operations, the water quality is comparable with background water quality which is typical of rural areas in Sierra Leone and for which good baseline data is available. Where they are impacted by current operations, additional monitoring and controls are in place to ensure that any discharges meet legislative limits as well as international standards.

Due to the high rainfall, a robust stormwater system is essential for the sustainability of the mine and a Stormwater Management Plan has been developed. This covers the MSP; Gangama operation; Gbeni operation; and Nitti port. Presently SRL is managing stormwater through (i) stormwater diversion berms and channels redirect natural water away from new mining areas; (ii) natural water holding dams and attenuation dams in the low-lying topographical areas; (iii) mine impacted water collection berms redirect water to the appropriate containment facility (dredging ponds); and (iv) silt traps to collect sediment before discharge.

An integrated water balance has been developed to simulate water use at Lanti operations, Gangama operations and at the MSP. This simulates and optimises the main inputs and outputs of water in the system, it uses Goldsim Monte Carlo simulation software. The water balance predicts the water volume demands at each facility, the amount of water being utilised in the mining process and where the storage, shortfalls and excesses are in the system. Due to the high rainfall, SRL is able to utilise rainfall and natural inflows into the ponded areas as their water resource without impacting other users and without requiring abstraction from groundwater or other surface water resources. Generally, while there is a surplus of water, SRL strives to optimize its water use by recycling as far as possible. Since the mine processes use mainly gravity separation, water discharged from the processes is able to be returned to the ponds after settling.  According to the ESHIA most surface water sources, including the historical dredge ponds, are used by local community members for a variety of domestic purposes including for drinking. Shallow groundwater wells are also used by the communities and there is more than adequate supply with local people commenting that there is generally too much water. While the ponds largely meet drinking water standards and outflows meet appropriate national and international water quality standards, a key concern for the future is that lowering of pond levels (e.g.: as part of the current area 1 Mine Closure Plan) may possibly impact groundwater levels in nearby wells. This will be closely monitored by SRL to ensure that any abstraction points are identified before any adjustments to pond levels are made and where there is a likelihood of a drop in groundwater levels, appropriate mitigation measures will be undertaken such as deepening of wells.

GHG Emissions: SRL has adopted Iluka Group Standard No. 9 which states “Carbon and Energy: maintain and report complete, accurate and transparent energy use and greenhouse gas emissions data. Identify, assess and prioritise emissions minimisation opportunities, including improved efficiency in energy use”. The SRL reporting system accounts for and reports GHG emissions annually.

The estimated GHG emissions over the project lifetime (around 18 years) are approximately 2.86 million tCO2e. This ranges from around 85 671 tCO2e per year during construction to about 215 400 tCO2e per year after tripling of production capacity. The largest contributor (about 84 %) to the overall GHG inventory is from the energy consumed to ensure project operations. This is followed by GHG emissions from the mining fleet (about 14 %) and then deforestation activities during land clearing operations (6 %). Several GHG mitigation initiatives are under consideration. These include where applicable, limiting the surface for which vegetation clearance is needed, rehabilitation and replanting the mined areas, and monitoring the restoration activities, and energy efficiency improvements.

Pollution Prevention: The operations at SRL primarily use water for mining and processing and a minimal number of reagents are used in the MSP. Therefore, key pollution risks for the project are consistent with SRL’s existing operations and include potential hydrocarbon spills from storage facilities and vehicle/equipment wash bay and workshops, tailings facilities and roads, gases and particulates from the dry mill and powerhouse. Consistent with its commitment to strengthen its existing HSEC management systems and minimise the environmental impact, SRL is currently working with its consultants to finalise and implement ESHMPs as referenced that include specific pollution prevention and control measures plus waste management practices that are supported by robust procedures and consistent with good practice including Iluka group standards. The ESHMPs will be supported by a detailed and comprehensive monitoring and sampling plan for various relevant HSEC parameters which will be developed and implemented as part of the HSEC management system enhancement.

Air Emissions and Ambient Air Quality: Primary sources of air emissions from the project include mining and processing activities, haul roads; diesel fired drier; MFO power plant; and vehicles. It is anticipated that these will intensify both during project construction and later operational phase for area 5 but will be contained by mitigation measures such as dust suppression through road watering and use of appropriate respirators in plants.

The Company has implemented a detailed and comprehensive monitoring and sampling protocol within the overall EHSMP to monitor air quality. 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 have been consistently well below their respective World Bank/IFC/WHO ambient air quality guidelines.  

Air quality does vary significantly between the wet and dry seasons due to the influence of rainfall. Air quality improves during the rainy season and the first part of the dry season when there is sufficient moisture to suppress dust being generated. Air quality reduces during the late dry season (March and April) when the burning of subsistence farming agricultural fields prior to planting increases the particulate matter of the ambient air within the region. Dust is also a factor during the dry season due to vehicle movements on exposed soil roads, agriculture practices, and Harmattan wind effects. The company will implement appropriate (water and/or chemical) dust control measures within the mine area, on access roads and at the plant.

Environmental Noise: Noise and vibration measurements have been performed during ESHIA preparation at sensitive receptors at the mine, port terminal and marine sites. Ambient noise measured across area 1 during a 2017 baseline survey show that in local villages, levels generally did not exceed 55 dBA nigh-time / 45 dBA daytime limits. Apart from vehicle noise on roads passing through or near to villages, SRL operations generally do not increase noise levels at nearby sensitive receptors. Mitigation measures are specified for sensitive receptors (human, ecological and marine) if the increase above baseline levels is greater than 3 dBA, or if the additional noise causes IFC guideline levels to be exceeded. The EHSMP defines noise and vibration monitoring around the site and at sensitive receptors (e.g.: the villages closest to SRL operations and areas through which SRL vehicles are likely to travel). SRL will undertake noise monitoring on an ongoing bi-annual basis (supplemented by ad hoc inspections) to ensure compliance with the applicable standards. 

Wastewater Treatment: Three separate sewage treatment plants are used for the treatment of sewage from the site at Mobimbi camp, Kpanguma and the MSP. The sewerage system collects grey & black water from buildings as well as water that has been processed in the oil/water separator. The plants consist of settling and aeration cells. The ESHIA identified that the plants require to be upgraded to meet legal and IFC guideline effluent discharge standards and this is covered by ESAP item 11. SRL is currently investigating project-specific sludge treatment options such as drying beds, compost production for agricultural or mine rehabilitation use.

Solid Waste & Hazardous Waste Management: SRL has developed a waste hierarchy with five categories (i) prevention (ii) reduction (iii) recycling (iv) recovery and (v) disposal. The waste management plan incorporates general waste management principles which planning, objective setting, identification of waste, inventories, classification, risk assessment, application of the waste hierarchy, implementation and monitoring. The implementation of the expansion project will result in the production of waste which can be broadly classified into mineral waste, domestic, inert and demolition waste, sewage, and hazardous. The existing waste disposal facilities at SRL currently do not have enough capacity to handle the relevant additional waste streams generated by the project. However, SRL is building a new engineered waste management facility at Mokula to handle waste generated by the expansion project and will take cognizance of these and future waste streams when updating its waste management plan.

During operation, the main waste at SRL is mineral waste, essentially sand. The operations generate the following three major tailings streams: sand tails generated from the spiral separation process in the wet plant; slimes generated from the de-sliming process in the cyclone overflow; and screen oversize (plus 1.60mm) material rejected from the screens on the process plant. Gravity tails will be combined as far as practicable with slimes for co-disposal to form a sand beach. The combined tailings will be re-vegetated as part of on-going SRL land rehabilitation efforts. Historically these sands and slimes have proven difficult to rehabilitate and SRL are undertaking a number of trials by adding clay and topsoil to create a medium in which plant growth will occur. SRL have made a very ambitious commitment to rehabilitate as much of the previously mined areas as possible and return these to productive agricultural uses. Topsoils are very limited, historically being mined as the rutile mineral occurs right up to the ground surface.

There are four tailings streams generated from the MSP, namely: total gravity tailings – tailings from the spiral gravity concentrators; sulphide tailings – sulphide mineral laden froth from the flotation circuit; and total ilmenite tailings –tailings from the ilmenite plant in the dry mill. The fourth stream is electrostatic tailings – fine and coarse high-tension tailings from the dry mill electrostatic circuit which have value and so is sold. These waste streams will increase in volume due to the expansion projects. The first three waste streams referenced will be disposed of in existing tailings disposal facilities that will be expanded to accommodate extra waste streams generated from the expansion project and from the future area 5 operations.

Domestic waste includes putrescible waste, glass, plastic, paper, kitchen and garden waste, timber and sawdust, and packaging material etc. SRL is currently designing a new engineered landfill facility (Mokula landfill) and an ESHIA for this facility is being undertaken as detailed in ESAP item 18. This new landfill will have enough capacity to accommodate the additional waste generated from the expansion project.

Some inert and construction waste (including from homes demolished during future resettlement) will be generated during the construction phase for the expansion project Metal will be disposed of in the existing scrap yard for subsequent handing over to the scrap management committee (comprising of community stakeholders) for sale to potential scrap dealers. Other inert material and construction debris will be disposed of at the SRL landfill site at the new Mokula landfill. Other reusable materials such as boards and corrugated iron roofing sheets will be provided to the community members via the scrap management committee or the CDC.

Hazardous Materials: The construction and operations of the expansion project will add to the following hazardous waste streams: hydrocarbon wastes; paints, solvents and glues; batteries; medical waste; chemicals; oily wastes, etc.

There is currently no hazardous waste disposal facility in Sierra Leone and therefore certain hazardous wastes will be temporarily but securely stored on site until a suitable permanent treatment and or/disposal option can be found in consultation with the EPA-SL. These include batteries and obsolete chemical reagents. SRL will commission an expert engineering consultancy firm to design and construct a hazardous waste storage and handling facility. This facility will be commissioned as detailed in ESAP item 17.

Radiation: The heavy mineral assemblage contains small amounts of monazite which is a naturally occurring radioactive mineral, this does cause localised concentrations (especially in zircon concentrate and around the MSP) of low level / long life radiation. Staff wear dosimetry badges in accordance with a formal monitoring program and the assessment undertaken as part of the ESHIA does not indicate a need for any controlled radiological areas; currently levels are low and it is believed that simple ongoing dosimetry monitoring will be sufficient. SRL / Iluka are following the relevant International Atomic Energy Agency (IAEA) / International Commission for Radiological Protection (ICRP) international standards on radiological protection. 

Community health and safety: Potentially negative community health impacts stem from dust and noise due to the movement of heavy equipment, materials and project personnel during construction and operations particularly in area 5 that could affect the communities located within the vicinity of the mine. During the impact assessment, specialist noise, dust and air emissions studies were undertaken and assessed (please refer to PS3). Community safety risks will also result from an increase in vehicular traffic during both the construction and operational phases particularly in area 5 and the associated potential for accidents. Another key safety issue identified was as a result of the mine ponds and other mine related infrastructure, which changed traditional movement and access patterns to agricultural fields and villages as well as having reported several drownings incidents in mine ponds in the past in area 1.  SRL provides a boat taxi to cross a specific pond to access agricultural fields and villages, has put in place warning signages at the historical dredge ponds as well as maintaining access bridges and alternative routes to agricultural fields and villages. Additionally, SRL will need to ensure the management of potential impacts to artisanal fishermen in the Nitti Port in terms of ensuring safety (exclusion zone) and in relation to the proposed expansion.  Lessons learned from area 1 will be expanded and comprehensive safety measures will also be implemented in area 5.

Community Exposure to Disease:  As a result of the expansion project, it is likely that incidences of existing diseases will increase such as malaria, typhoid, HIV/AIDS, diarrhoea and other communicable diseases. Around 80 % of SRL’s workforce resides in local communities and therefore interacts daily with members of the public. The SRL’s clinic has a positive impact in providing comprehensive health services and education to SRL employees and up to five dependents each, while significant improvements in terms of equipment (e.g. ambulances), infrastructure (e.g. adequate delivery/maternity area) and staffing (e.g. clerks) of the clinic are planned.  However, key community health impacts, such as malaria and transmission of STDs, may be exacerbated by mine-related factors such as environmental risks (creation of pools of stagnant water, artificial ponds and heavy vegetation) or presence of a male-dominated workforce.  While SRL staff are well sensitised on related risks and can access relevant health services, other community members do not generally benefit from either sensitisation or treatment options. This disparity creates a particular risk for young women in local communities who live close to the poverty line and engage in transactional sex (including under-age sex) involving relatively wealthy male mine workers as raised during the ESHIA’s community consultations. As per ESAP item 5, SRL will establish clear guidelines in its workers’ Code of Conduct to address this risk.  Additionally, SRL’s grievance mechanism will facilitate the means to bring up potential cases of gender-based violence. 

Influx:  The development of area 5 is likely to attract migrants seeking employment and other economic opportunities from outside of the area significantly changing the current socio-economic, cultural and environmental landscape as witnessed in area 1 over the years.  There are significant risks associated with project-induced migration such as (i) unplanned development of human settlements posing increasing pressure on already scare housing and social infrastructure, (ii) increasing spread of communicable diseases and high-risk sexual practices, (iii) environmental degradation, and (iv) social conflict.  In order to manage these risks proactively and drawing lessons from area 1, SRL will develop an influx management plan as per ESAP item 6 in coordination with relevant stakeholders such as local government and surrounding communities. 

Security Personnel: All security personnel are now fully employed by SRL, significantly improving the management of security issues, as well as improving employment and working conditions for nearly six hundred security personnel.  Given the past history of the country, SRL has employees and contractors who are former local militia members and would have served to protect local communities during the civil war years. A Risk Manager will be employed by SRL, starting in March 2019 and part of his duties will be to put in place a process in accordance with international standards to screen out any persons (for security jobs) who may be associated with documented human rights abuses in line with PS4 requirements. This will be done on a best effort’s basis recognising the difficulties caused by past poor record keeping practices and potentially corrupt processes to obtain clearances (i.e. no guarantee the past records are correct. PS 4 and related international benchmarks such as the Voluntary Principles require that companies interact with any public security agency that the company depends on and seek to influence rules of engagement / training for security personnel deployed by these agencies in support of company operations. In SRL’s case the agency is the state police, and specifically the local branch referred to as the Rutile police. To date SRL has drafted a detailed Memorandum of Understanding (MoU) pending finalisation with the Government of Sierra Leone, which include provisions for code of conduct, rule of engagement and training of local police.  SRL will finalise the overarching Security Management Plan in line with PS4 covering area 1 and 5, including the hauling route, as per ESAP item 7, to clearly outline rules and procedures, roles and responsibilities, and training for SRL’s in-house security and the Rutile police. 

 Type of Habitat: The project overlaps the Guinean mangroves and Western Guinean lowland forests ecoregions. Biodiversity assessments for area 1 and the haul road have been completed as part of ESHIAs for each component. A similar assessment is underway for area 5, including Critical Habitat Assessment and a Biodiversity Action Plan. The level of information in the assessment is being updated to meet the PS 6 standard (e.g. input by taxonomic experts, targeted to clarify status of priority species suspected to occur).  Given the nature of the risks, international experts have been engaged to close the gaps and clarify the status of high priority species. IFC undertook additional screening using IBAT and other sources (e.g. Global Forest Watch, A.P.E.S. Database).

The area 1 Mine Lease Area (MLA) spans 290 000 ha and has been transformed by mining (since 1967) and community activities (e.g. farming, hunting, settlements). Most of the MLA (~75% of MLA) is farmbush typical of the region (e.g. croplands, fallow areas, and regenerating bush/forests up to 10m tall with invasive alien species) and mining infrastructure (e.g. pits, dams, roads). These impacts predate IFC investment and acquisition by Iluka in 2016. Limited ecological rehabilitation restoration has occurred within these areas but is planned by SRL as part of the new HSEC MS. Some areas of relatively intact mangroves, riparian habitats and ridge-top forests remain (~25% of MLA) and a sub-set of this area may qualify as Natural Habitat.  The majority of the MLA is likely Modified Habitat and a definitive classification of Modified vs Natural Habitat is being undertaken which will inform applicability of IFC requirements and facilitate establishing targets for mitigation. SRL is currently undertaking a mapping of Natural vs Modified Habitats, using existing ESHIA data as per ESAP item 12. Some parts of area 1 are suspected to support a number of priority species and has potential to be Critical Habitat for remaining threatened species (e.g. Western Chimpanzees, Western Red Colobus, Timneh Parrot, Slender-snouted Crocodile) and unique/threatened habitats (e.g. mangroves) and the current assessments are being undertaken to determine their status, as per ESAP item 13. SRL has retained qualified international experts to undertake a Critical Habitat Assessment to determine the status of suspected Critical Habitat triggers, including targeted field surveys for these triggers where necessary as per ESAP item 13. Where Critical Habitat is confirmed, SRL will develop a biodiversity action plan (BAP) with a Biodiversity Evaluation & Monitoring Plan (BMEP) to demonstrate application of the mitigation hierarchy with the aim of net gains for Critical Habitat values and no net loss for remaining Natural Habitats as per ESAP item 14. The BAP will also specify surveys to establish adequate baseline information for management and not rely on probability estimates. Should the biodiversity values identified not trigger Critical Habitat, they will likely, at a minimum, be treated as priority biodiversity values to be managed as part of on-site biodiversity management plan and subject to no net loss requirements where significant residual impacts to their habitats or populations are expected. Some priority biodiversity values (e.g. IUCN Vulnerable species) have already been identified on site and others are suspected to occur but require further survey effort to confirm. Key project impacts include further conversion of mangrove, riparian areas and farmbush areas to mining, and downstream impacts due to disrupted flows, damming, and erosion. The area to be impacted is yet to be fully quantified. Ongoing impacts associated with past mining include noise/light disturbance and traffic. Hunting and cultivation by local communities is widespread within area 1. Given past impacts, a key focus of mitigation will be rehabilitation of past and current mining areas to establish a multiple use landscape within the MLA. This rehabilitation will focus on community development priorities but is expected to include protection and rehabilitation of natural habitats likely to support priority biodiversity and ecosystem services. Similarly, avoidance and protection, ideally via community-based approaches, of remaining natural habitats likely to support priority biodiversity and ecosystem services (e.g. mature mangroves near Nitti, remnant ridgeline forest, sacred forest areas) will be part of such land use planning. These actions are likely to be sufficient to deliver no net loss and net gain against the current baseline conditions in area 1. Due to existing high hunting pressure within the region, the project will, as part of the BAP, establish a zero tolerance policy for collection, possession, purchase, sale, or transport by staff and contractors of any nationally protected, CITES listed, or IUCN Red List threatened species.

The haul road is largely aligned with an existing road, the exceptions being where there are deviations to avoid communities. An above-ground 46 kV transmission line (T-Line) is planned that will follow the road along its length. The existing right of way runs via farmbush with scattered forest patches and wetlands (known as inland valley swamp - IVS). Most areas have been impacted by past logging and ongoing community activities, including fishing and livestock. These areas are likely to be largely Modified Habitat with remnant Natural Habitat fragments, but this needs confirmation. A definitive classification of Modified vs Natural Habitat will be completed as part of ESAP item 12. The haul road triggers Critical Habitat for at least one threatened species (e.g. Epiplatys josianae, a Critically Endangered fish associated with inland valley swamps near Mosenesie) where a culvert will be built. Other priority biodiversity was identified which may also trigger Critical Habitat, but further clarification is required (e.g. Hooded Vulture, Western Chimpanzee). A Critical Habitat Assessment which includes the haul road is currently underway as per of ESAP item 13. Key project impacts include clearance of road-side habitats during construction, potential for erosion and disrupted flows in local streams and wetlands, potential for bird and primate electrocution by T-line collisions, increased traffic volume, and induced access for hunters. Mitigation actions have focused on avoidance during design phase, including re-routing to avoid or reduce wetland and forest crossings, speed controls, culvert installation, and erosion prevention measures. The T-line will have bird diverters and anti-electrocution measures installed.

The area 5 MLA is a mix of farmbush and remnant secondary forests, wetlands and mangroves. International experts (including IUCN Section on Great Apes affiliated experts) have been engaged by SRL to produce a definitive map of Modified vs Natural Habitat, this will indicate the extent of natural habitat, which, although degraded in many areas, is likely to be substantial. Community activities (e.g. hunting, fishing) have reduced biodiversity quality and quantity in the area but the MLA likely qualifies for Critical Habitat for threatened species (e.g. Western Chimpanzees), endemic species (e.g. undescribed fish species), and threatened ecosystems (e.g. mangroves). There is evidence of Western Chimpanzees in the MLA, and important populations occur nearby (ca. 5km), but presence within the mine development area appears seasonal and requires clarification by species specialists. The international experts referred to above are also determining the status of chimpanzees within area 1, haul road and area 5 as per ESAP item 13. On-site avoidance and minimisation will be prioritised but it is likely that offsets may be required to demonstrate net gains for chimpanzees and other priority values. Should the area 5 expansion be approved by the SRL board, full compliance will need to be demonstrated over time with requirements of PS6.

There is currently no biodiversity management function within the management structure. SRL will establish a biodiversity function to oversee implementation of the biodiversity aspects of the HSEC MS as part of its BAP as per ESAP item 14. Additional staffing may be required, depending on the findings of the area 5 ESHIA.

Protected or Recognised Areas: Area 1 overlaps Sherbro Marine Protected area (MPA). The MPA was declared after the MLA was granted and has yet to develop a management plan. SRL will develop a stakeholder engagement strategy with MPA authorities, including identifying efforts to support MPA activities where possible. Impacts to the MPA will be managed as part of requirements for Natural and Critical Habitat described above, as well as mitigation of water-related risks under PS3. Direct impacts to the MPA within the MLA include a total loss of up to 300ha of mangroves (0.4% of mangroves in the MPA). Estuarine fish communities appear to be somewhat impacted (e.g. diversity is typical of other estuaries in the region but with smaller sized individuals and fewer large predators) but experts have linked this more to high fishing pressure rather than direct impacts from upstream mining activities.

Alien Invasive Species: Alien species are present at all project components, likely due to past project and community activities, and include many species already established in Sierra Leone (eg. Lantana, Blue gum, Forest mangrove, Nile Tilapia). Control methods have been identified in most cases and will be implemented via an Alien and Invasive Plant Control Plan (AIPCP). Given the economic values of alien fish to local communities within pondage areas, these will not be impacted until mine closure when most mining related infrastructure will be rehabilitated as part of an integrated land use plan that considers community development needs. Further introduction and spread of these species to new pondage must be avoided. These measures will be extended to all project components (e.g. haul road) under SRL control, including efforts to manage risk of spreading such species to area 5.

Management of Ecosystem Services: Community reliance on natural resources in the regions around the project components is high. These include collection of timber (e.g. construction materials, firewood & charcoal), non-timber forest products (e.g. honey, medicinal plants), subsistence hunting of remaining small game, raffia palm leaves (for thatching), fishing, water (e.g. drinking, cooking, washing), and grazing. Any impacts on livelihoods linked to loss of natural resource access or value will be addressed under PS 5. Planned rehabilitation of previously mined areas is likely to increase natural resource access, and this will be a focus for rehabilitation and closure plans being developed as part of the HSEC MS. High cultural value is also placed on specific sacred forest areas as part of the “secret societies” widespread in many parts of Sierra Leone. Many of these areas sacred forests have been avoided in consultation with communities and this will continue under the HSEC MS.  Prioritisation and mitigation of impacts to these are addressed under PS3, 4, 5, and 7. Community consultations have raised concerns over alleged negative impacts to natural resources by project activities (e.g. erosion, water quality, fisheries, mangroves). Concerns also exist over planned decommissioning of some mining infrastructure (e.g. lowering/removal of dams) as they have now become import fishing sites for communities despite safety concerns raised by the company. These will need to be addressed within closure and rehabilitation plans that consider community development objectives.

Sustainable Management of Living Natural Resources; Not applicable.

Protection of Cultural Heritage in Project Design and Operations: SRL have currently been managing cultural heritage impacts in accordance with Performance Standard 8 based on the Foinda relocation experience. Though, based on communities’ account, sacred sites have been disturbed or damaged in the past prior to Iluka’s arrival. In area 1, no archaeological or cultural heritage sites were identified aside from the cultural sites (i.e. sacred bush) affected as part of the Foinda relocation.  In area 5, a total of 21 sacred bush sites, 5 Bondo Society Houses, 1 medicine bush, 1 prayer point and 1 sacred cave will be affected by the future construction and mining operations.  An additional 15 cemeteries and graves sites will be affected which is dealt with as part of the resettlement program (please see PS5).  To manage these potential impacts, SRL’s Cultural Heritage Management Plan and Chance Finds Procedure being developed as part of the area 5 ESHMP will be expanded to include the relevant practices (community consultation, agreement on necessary ceremonies, etc) to be used across all other current and future activities, including ongoing land acquisition around dry mining pits and the upgrade and expansion of the haul road, as per ESAP item 15, in accordance with IFC PS8 and Sierra Leone’s legislation.  SRL will ensure operators are trained according to the procedures.                                                   

Consultations: SRL conducted consultations and information dissemination activities with surrounding communities around in areas 1 5 and the proposed haul road as part of the 2017 and 2018 ESHIA preparations, respectively.  In area 1, approximately 1,329 stakeholders representing various sectors of society, including host communities in the study area and beyond, were involved in the information sharing meetings, similarly for area 5.  The key objectives of the consultations were: (i) to share information about the current operations and proposed expansion (Gangama and Lanti deposits) in area 1 and future development activities in area 5; (ii) to identify key issues and impacts from the various stakeholder perspectives; and, (iii) for stakeholders to comment and voice their views and concerns about the project.  Key issues raised in relation to area 1 were primarily focused on legacy issues regarding: (i) inadequate compensation for loss of land and livelihood; (ii) disagreement over crop assessments and compensation rates; (iii) surface rent payments seen as insufficient or not reaching other landowners; (iv) unmet commitments for community development activities; (v) high expectations for the new owners of SRL to honour commitments made by the previous company, and to remedy legacy issues; (vii) concerns about potential drowning in the mining ponds; (viii) employment opportunities; among others (a complete list of issues raised are found in the ESHIA 2017 for area 1).  As for area 5, a large portion of local people viewed the development of area 5 as beneficial in providing employment opportunities and improved infrastructure.  However, same legacy concerns raised in area 1 were also voiced by the communities in area 5 indicating that these past practices, particularly related to resettlement and crop compensation, be adequately managed in the future.  Other similar topics raised included (i) expectations for employment opportunities; (ii) improvement of social infrastructure (i.e. schools, clinics, water and sanitation); and, (iii) surface rent payments to be paid to the rightful landowners (a complete list of issues raised are found in the ESHIA 2018). As for the haul road and the transmission line, communities concerned focused on similar concerns such as adequate compensation for loss of land and crops as well as road safety issues and improvement of surrounding social infrastructure. 

Meetings with government stakeholders were conducted in English, while the public and community meetings took place mainly in Krio and Mende. Stakeholder engagement materials were prepared (such as Background Information Documents (BID), advertisements, notification letters, site notices), and public meetings, focus group discussions and consultation with affected communities undertaken. All comments, concerns, questions and suggestions raised by stakeholders during the information sharing meetings and in writing are recorded in an Issues and Response Report (IRR).

 Stakeholder Engagement Plan: SRL has conducted a stakeholder identification and analysis to guide its engagement process in area 1 and area 5 per the Stakeholder Engagement Plan (SEP) in line with PS1 but engagement procedures will need to be consolidated to ensure consistency of approaches in area 1 and 5 as per ESAP item 16, including engagement activities around the haul road.  The SEP will be updated on a regular basis as needed, and specifically when major events occur such as change of project phases (e.g. construction to operations) and new stakeholders are identified. The plan includes provisions for on-going liaison with regulatory authorities, establishment of local community liaison groups to inform and maintain open communications at the local level, publication of regular reports on environmental and social performance and monitoring. Stakeholder engagement activities will be monitored to ensure consultation and disclosure measures are effective through audits, monitoring of consultation activities, monitoring of the effectiveness of the engagement process in managing impacts and expectations by tracking feedback received from communities including grievances.  SRL has resumed regular (quarterly) public and key stakeholder meetings designed to keep communities and local government representatives up to date with SRL-related matters and vice-versa. The company also makes use of local media (radio, newspaper) to reach community members and discloses surface payment rents made to the landowners, district councils, paramount chiefs, chiefdom administration and the constituency development fund.  This practice began in 2017 and was repeated early in 2018 to support transparency and accountability. Also, the general staff resides in local villages and provide a mechanism for informally updating local stakeholders of mine developments. Successful engagement depends upon sufficient staffing (refer to PS1 under organisation and capacity).  Engagement with communities surrounding the Nitti port, especially with the artisanal fishermen, is needed in terms of ensuring safety (exclusion zone) and in relation to the proposed expansion as per ESAP item 16.

Stakeholder mapping/analysis: The following stakeholder groups were identified as they relate to the project: project Affected Communities and surrounding communities; land owners and businesses; government authorities (at all levels); District Council officials, Paramount Chiefs and Chiefdom Authorities; local religious, community and cultural leaders; key representatives of local empowerment groups (women, youth); educational, health and social workers; NGOs / CBOs, and the media. Potential host communities were also included in the consultation process.

External Communications and Grievance Mechanisms: SRL’s Grievance Mechanism has been recently updated and in line with IFC PS1. All grievances received (including those received anonymously) via this mechanism will be tracked by the SRL Grievance Officer through the SRL Grievance Register. A step by step grievance management is laid out from lodging the complaint through the various points (directly with SRL, the Paramount Chief, the Chiefdom Grievance Committee, the Town Chief or Section Chief), assessing, investigating and documenting the complaint, and finally resolving it within a specific time-frame.  The mechanism also includes provisions for reporting criminal conduction, violence or serious human rights violations. In reality, local communities reach out in person to the SRL’s Community Affair Officers to communicate any concerns or issues in relation to the project, which in turn, the Community Affairs Officers proceed to record and follow the internal grievance mechanism procedures as described.  Complainant also have the option to exercise their statutory rights to undertake legal proceedings.  SRL plans to disseminate the updated grievance mechanism, including the avenues for submitting a grievance, to communities in the local language (Krio and Mende).

Information Disclosure: As part of the renewed environmental approval process, SRL submitted the ESHIA reports to EPA-SL for the existing SRL operations in area 1 (inclusive of the Gangama and Lanti deposits) which was approved on 19 June 2018.  The ESHIA for the upgrade and expansion of the haul road linking area 1 and 5 was also submitted to EPA-SL and approved on 22 February 2018.  SRL plans to submit the ESHIA for area 5 within 2019 for government approval after the required public consultations are conducted.  For area 1, the scoping phase consultations were held between 15 and 21 June 2017, social surveys (focus group discussions, interviews, etc.) were held in August and September 2017 while the final public consultation and disclosure process occurred between 2 and 4 May 2018. All these consultations were held in with various stakeholder groups including government, civil society, traditional leadership and host communities in the Imperri, Lower Banta, Upper Banta, Jong and Bagruwa Chiefdoms. Consultation with government agencies were held in Freetown. For area 5, the ESHIA reports will be made available for public review and comment as part of the Public Consultation and Disclosure Process and the revised final ESHIA reports, with public comments, will be submitted to authorities.  The EPA-SL will be responsible for organizing and conducting the public consultations with the support of SRL with the relevant stakeholders in various locations around the mine, and in Freetown as per the country’s legislation.  The ESHIAs for area 1 and the haul road are available on SRL’s website as well as at SRL’s site office and on IFC’s webpage in accordance with the Access to Information Policy. Once approved by the government of Sierra Leone, the ESHIA for area 5 will be available on SRL’s website.  Copies of the ESHIA’s can also be requested by the general public through the EPA-SL office in Freetown.