The Project footprint is within the Port boundaries operational since 1967, and no land acquisition have been undertaken for the Project; hence, there are no impacts identified to be managed in a manner consistent with PS5: Land Acquisition and Involuntary Resettlement. No impacts associated with PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources were identified. The project is located within the boundaries of the existing port. The environmental assessment identified that the project lies outside the Khor Al-Zubair Important Bird Area (IBA) and Key Biodiversity Area (KBA) with the closest point located 2.5 km from the southwest of the Project site and on the opposite bank of the access channel. The IBA/KBA was not affected by the Project construction and the dredging spoils were placed to a site close to Terminal 2, external to port gates, but within the control of GCPI. There are no indigenous people groups in the project area as defined by PS7: Indigenous Peoples. Given the location of the project, no impact was identified to be managed consistent with PS8: Cultural Heritage. The location of and access to a site used as children’s burial ground by the local community were not affected by the project construction and disposal site of dredged material.

 The Project involves development of a new terminal and its facilities within the premises of an existing operational port area. This is a Category B project, according to IFC’s Policy on Environmental and Social Sustainability, because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

E&S Policies and Management System

BMT has a set of E&S policies which are applicable to all Project activities and require compliance by employees, contractors, subcontractors, and visitors. Additional standalone policies cover non-discrimination, anti-bribery, compliance and business ethics, and drug abuse. All policies are signed by the CEO and available, in English and Arabic, to all workers. BMT also developed an Integrated Management System (IMS) which includes procedures and plans addressing E&S risks and impacts related to Terminal 1 activities. The system formed the basis of Terminal 2 construction phase documentation and will be extended to its operational phase. The main documents of the IMS include: the Quality, Health, Safety, Security and Environment (QHSSE) Policy, an Integrated Management System Handbook, an Occupational Health & Safety – Environment Management System Manual including management procedures, a Health - Safety - Environment Policy Manual, plans, Standard Operating Procedures (SOPs) and occupational health and safety (OHS) procedures. The QHSSE Management System is certified since 2018 with three major certifications including ISO 9000, ISO14000 and OHSAS 18000

BMT will, as mentioned under ESAP # 1, review and update its QHSSE Policy and IMS to meet the provisions of IFC Performance Standards, and be consistent with good international industry practice (GIIP) as per applicable and relevant parts of the World Bank Group (WBG) Environment, Health and Safety (EHS) General Guidelines, 2007 and the WBG EHS Guidelines for Ports, Harbors and Terminals, 2017. BMT will, as part of its IMS, implement procedures to periodically review the QHSSE policy and procedures.

The updated IMS will include: (i) updated Standard Operating Procedures, Work Instructions and Operational Control Procedures to incorporate changes in the legal register with reference to IFC applicable requirements; (ii) updated OHS risk procedures to include tiering of tasks and a permit to work procedure. The procedures will define KPI targets, aligned with GIIP, and allocate appropriate resources to achieve them; update safety supervision mechanisms; review and update current safety awareness and training sessions; and improve yard traffic plan along with enhancing safe driving practices; (iii) an updated waste management procedure covering construction of Terminal 2, including cleanup from construction debris waste, a plan to engage with the Port Authority on the stabilization and/or removal/disposal of the dredged material currently stored with the port site, and operations of both terminals. The updated procedure will include measures for solid and hazardous waste management and housekeeping measures. Subject to any prevailing restrictions (incl. relating to COVID-19, applicable laws and regulations and authorizations), BMT will undertake reasonable efforts to audit the waste management contractors and the relevant waste treatment and disposal facilities during operations; (iv) an updated contractor management plan with detailed procedures to monitor, audit and document contractor E&S compliance with relevant project EHS requirements and applicable IFC Performance Standards provisions; (v) in the context of the future engagement of external contractors, BMT will contractually require its construction and operations & maintenance (O&M) contractors to develop or, as needed, update their EHS Management Plan and implementation procedures in line with the updated IMS; (vi) updated Emergency Plan and Procedures in line with IFC PS1 requirements including the identification of areas where accidents and emergency situations may occur, designation of responsibilities, communication and dissemination of the plan and procedures via periodic training of the workforce, and recording of occurred events. BMT will also complete the emergency management procedures under the Health, Safety, Security & Environmental (HSSE) Emergency Response Plan by including spill prevention and management. The emergency preparedness and response activities will be periodically reviewed and updated, as necessary, to reflect changing conditions; (vii) update the environmental monitoring procedure for operations to integrate Terminal 1 and 2 monitoring, including air emissions, noise and vibrations, groundwater quality, and effluent discharges; (viii) the implementation of the updated IMS will be audited by an external auditor.

In addition, as discussed under Stakeholder Engagement, the IMS will integrate the stakeholder engagement and community grievance redress procedure in accordance with IFC Performance Standards.

Identification of Risks and Impacts

An environmental impact assessment (EIA) for the Project was not required by the national and local authorities. As per the legal agreement between GCPI and Aloreen signed in 2017, the Company was not required by the port authorities to undertake additional environmental assessments. GPCI confirmed that Aloreen met the technical conditions and requirements related to the Project and undertook the necessary detailed studies covering technical and environmental aspects of the project. Nevertheless, BMT developed an environmental and social impact assessment (ESIA) study covering the project construction, operation, and decommissioning phases. The ESIA is disclosed together with this ESRS and includes, among others: definition of the project area of influence; identification of an associated facility (the dredger berth, the location of which is not yet defined and may be constructed by BMT as part of the concession agreements but would be operated by GCPI/Iraq Port Authority (IPA, as discussed above); cumulative impacts; assessment of technical and environmental/ social alternatives; screening of transboundary risks due to project activities given the location of the port, approximately 4.5 km from the Iraqi-Kuwaiti border; and identification of social risks. The ESIA was prepared in 2018 during an early project phase, hence did not include some recent design modifications (e.g. final location of dredge spoils disposal area close to Terminal 2). The ESIA included an Environmental and Social Management Plan (ESMP) for both construction and operation. The ESMP was updated in January 2020 in line with IFC Performance Standards and is applicable to contractors and sub-contractors during the construction phase and will be implemented by BMT during the operational phase.

Management Programs

As indicated above, BMT has developed an ESMP as part of the ESIA. As part of ESAP #1, BMT will formally integrate the ESMP in the IMS, notably in relation to the Project’s operation phase, all aligned with IFC Performance Standards. In case the dredge berth is constructed, the ESMP will be updated to include an assessment of environmental and social risks and impacts , associated with the construction and operations of the berth, and BMT will be responsible for the implementation of the construction phase mitigations and relevant undertakings, provisions and agreements with GCPI relevant to the operations, consistent with IFC Performance Standard 1 on associated facilities.

The IMS will updated as described above and detailed in ESAP #1.

Organizational Capacity and Competency

BMT's QHSE team consists of four staff members, including the department manager that oversees safety, health, environmental, social and quality management at Terminal 1 and the construction project of Terminal 2. The other team members include an EHS superintendent, a QHSE trainer/supervisor, and an EHS supervisor in charge of yard management and supervision, as well as monitoring on reporting on key EHS KPIs. In addition, each department manager also has EHS responsibilities and periodically reports on these to the QHSE manager. BMT’s human resources (HR) team comprises of six staff members including a manager and five HR officers and coordinators. The organizational capacity and competency are considered adequate. 

Emergency Preparedness and Response

BMT has emergency preparedness and response procedures that address the management of both environmental and OHS emergencies within the site. The existing procedures also address external emergencies including natural disasters, security and health/medical emergencies.  They include: HSSE Emergency Response Plan, covering fire control, transportation, natural hazards, medical emergencies, Emergency Evacuation Plan, Port Premises Security Plan covering security at both terminals, and specific operation procedures relevant to vessel evacuation, operational area bomb threat and crowd control. BMT will review and update its Emergency Plan and Procedures as part of IMS update outlined under ESAP# 1.

Monitoring and Review

Performance monitoring related to the operations activities at Terminal 1 and construction activities of Terminal 2 are tracked and recorded, including OHS performance and environmental monitoring. IFC’s review of the IMS identified adequate procedures for periodic reviews of the management system.  

 Human Resources Policies and Procedures

BMT has about 335 employees and recorded a peak of 590 contract workers during Terminal 2 construction phase. The number of direct employees is expected to increase to 400 employees once the new terminal becomes fully operational.

The Company has a Human Resource (HR) policy outlining workers’ rights under national labor and employment laws.  The policy provides details in terms of procedures and approach to workers management in line with international standards and is appropriate to the size and workforce of BMT.  Furthermore, the Company’s Labor Management Plan addresses workers’ rights, induction, wages, overtime, working hours, social security, workplace hygiene standards, commitment to freedom of association, and non-discrimination and harassment aligned with PS2 requirements.  BMT has implemented these provisions at Terminal 1 since it became operational and will extend them to cover Terminal 2 activities for direct employees, contractors’ personnel, and expat workers.

Working Conditions and Terms of Employment

The HR policy, labor management procedures and employee handbook are made available, in Arabic, to all workers.

During the construction phase most labor was contracted locally; nevertheless the Project established a temporary workers’ camp, located within the Project’s yard, to accommodate around 200 non-Iraqi workers. BMT, as part of the construction labor management plan, developed a detailed accommodation plan that incorporated GIIP and relevant IFC guidelines.  Specific checklists for rooms, canteen, recreational and prayer areas were developed and implemented by BMT camp management to ensure full compliance.  BMT accommodation standards were also required to all contractors. In addition, the employer’s requirements policy, developed by the Company, sets out contractors’ rules to address labor requirement, their working conditions, and rights in line with PS2 provisions.

Workers’ Organization

Freedom of association and the effective recognition of the right to collective bargaining is protected by Article 6 of the Iraqi Labor Law and BMT specifically commits to this provision. BMT reported the proportion of workers (including contracted workers) adhering to the labor union or syndicate is approximately 40%.

Non-discrimination and Equal Opportunity

The HR policy and procedures include a non-discrimination policy. The code of conduct and business ethics policy state that the Company has zero tolerance to harassment and bullying.  BMT has appointed the QHSE manager as the dedicated focal point to receive allegations of sexual harassment in the workplace. Furthermore, BMT conduct in-house training on gender equality issues for all employees and contractors while managers are being trained on how to respond to incidents of sexual harassment in the workplace.

Retrenchment

The Project will result in expansion of BMT’s operations, requiring it to slightly increase its direct workers base; therefore, no retrenchment is foreseen at this point.  Contractors involved in the construction phase (e.g. ENKA) will scale down at the completion of activities. As per ESAP# 2, BMT will develop a framework demobilization procedure to ensure contractors demobilization plans are aligned with Company policies and follow good practice.

Grievance Mechanism

BMT has a grievance mechanism in place for employees working at Terminal 1 and 2 (either involved in operation or construction) to ensure that workers’ complaints are considered and resolved. All Project workers, including contracted workers (as stated in the employers’ requirements policy) have the right to file a complaint by filling the grievance form, by telephone, email, or handwritten note. In addition, taking into account the presence of unskilled workers who are illiterate, BMT uses other communication channels. As per ESAP #3, BMT will develop a structured procedure to ensure the grievance mechanism and all available channels are disseminated and well understood amongst direct employees and contractors’ workers.

Protecting the Work Force

Child and forced labour are prohibited under the Labour Law of Iraq; furthermore, Iraq has ratified ILO Conventions C138, minimum age convention (18 years), and C182, worst forms of child labour convention. These principles are included in the Company’s business ethics policy and code of conduct and BMT has procedures, including regular and random controls on its own workforce and on the contractors’ personnel, to ensure compliance.  Service suppliers are required to submit their lawful establishment documents, workers’ IDs and track record for BMT approval.

Occupational Health and Safety

BMT established, as part of its IMS, a safety management system, which is certified OSHAS 18001. The Company is in the process of replacing it with the ISO 45001 framework and expects to complete this process by early 2021 unless current pandemic restrictions and/or local security issues delay this process further. The management system addresses the relevant areas like training, auditing, personal protective equipment (PPE) management, risk assessment, drills scheduling, hazardous substances management, KPI identification, and recording.  The system does not formalize a permit to work procedure, which will be developed as part of ESAP #1. 

BMT requires its construction contractors to submit, 28 days before the starting date, a site safety plan. Contractors are required to review and update the plan as necessary during the construction phase. Furthermore, the Company requires contractors to develop a project specific E&S management plan, including but not limited to, all relevant OHS procedures and plans, training matrix, and KPI.  The contractors are required to appoint a site safety officer and attend monthly safety meetings. Site safety plan, project E&S management plan, and appointment of the safety officer appointment are subject to BMT approval.

For the operation phase of Terminal 1, BMT workers undergo general and task specific training; certificates are issued for each completed subject area to enhance future employment opportunities to personnel. Also, contractors are required to provide their personnel with appropriate training, and establish safety tool-box talks, to ensure awareness of safety risks, safe use of tools and equipment, and use of PPE. All staff receive a site safety induction. A site induction is also required for personnel from other organisations prior to accessing the site and carrying out their tasks.

BMT conducts and documents regular OHS meetings and periodic auditing. The audits are comprehensive and include checking for follow up actions related to identified gaps / non-compliances. At the time of IFC’s review, with about 85% construction completed, only one lost time injury was recorded.

The review of operational performance at Terminal 1 in the past two years identified areas of improvement to further reduce lost time injury frequency rates, which were 7.67 in 2018, 11.08 in 2019, and 2.59 as of H1 2020, and prevent fatalities, following two fatalities occurred in 2018 (fall from height) and in 2019 (electrocution). The measures agreed as part of ESAP #1 will aim at improving the overall performance, going forward.

BMT adopted the required measures to cope with current COVID-19 outbreak. The Company implemented specific workers protection measures, based on WHO guidance and as per the Iraqi Authorities' regulations. Measures included the development and distribution of relevant instructions and guidance to the direct employees and contracted workers, the establishment and implementation of crisis management procedures, implementation of travel restrictions, and issuance of clear protocols for suspected and confirmed cases.

Workers Engaged by Third Parties

All BMT contractors and main suppliers workers are bound by employment agreements to provide fair-working conditions and terms of employment compliant with BMT human resource and non-discrimination policies as well as the Company’s code of conduct and business ethics policy, all of which are in line with IFC Performance Standards.  Furthermore, they are required to have a functional EHS management system that complies with BMT's requirements. BMT’s contractor contracts include specific reference to BMT EHS policies, and applicable local or international laws and regulations of Republic of Iraq. 

Contractors’ self-verification and BMT’s audit process ensure proper implementation of these requirements that are regularly checked during site HSE induction, HR and corporate social responsibility (CSR) meetings, construction and coordination meetings; monthly reports (including human resource metrics) are used to communicate performance to Company management. Contractors are also required to develop a training plan and a local resourcing plan, whereby priority will be given to the hiring of local labour, that also includes clear communications on terms of employment and retrenchment/decommissioning procedures.   

Pollution prevention and control will be covered under the IMS and the Project ESMP, as updated under ESAP #1, including: management of air emissions and noise from Project construction, terminal equipment and transport vehicles; GHG emissions; treatment, containment and management of discharges on land or to the sea including storm water, sewage, spills and waste and dredged spoils storage and disposal.

Dredging

During construction of Terminal 2, BMT undertook dredging activities of the berth pocket up to 50 m from the shoreline. Dredging activities were performed by the EPC contractor and completed in accordance with an approved method statement. Dredging was undertaken by means of a Cutter Suction Dredger whereby approximately 1.25 million m3 of sediments were dredged. In addition, about 300,000 m3 of soil were excavated at the terminal site during the construction phase. Approximately 400,000 m3 of dredged sediments were used as fill material along with 400,000 m3 of imported fills.  Excavated soil and dredged sediment not used as fill (850,000 m3) were stocked within the port boundaries, north of Terminal 2, in an area of (500 x 1,000 m) made available by GCPI  . The area, which is not engineered, fenced or signposted, is being used as a general waste dump area by other operators and by IPA, for dredged spoils from maintenance dredging. Available in-situ analysis of sediments done as part of the ESIA did not identify any potential contamination.

 It will be responsibility of GCPI to undertake maintenance dredging (in operation) of dredged areas and approach channels. As per ESAP #4, BMT will engage with the Port Authority in respect of the management of the area utilized for the disposal of dredged sediments, based on soil and sediment testing to inform stabilization and monitoring of the area.

Air Emissions and Ambient Air Quality

In line with the EPC contract and the construction ESMP requirements, ENKA completed a baseline air quality monitoring before the start of construction. During construction, bi-monthly monitoring of ambient air concentrations was undertaken for sulfur oxides, nitrogen oxides and volatile organic compounds. Monitoring records indicate concentrations within national limits.

During the operation phase, given that Terminal 2 will be limited to container handling and Ro-Ro activities, air emissions are mostly expected from mobile sources associated with terrestrial and maritime traffic and operational vehicles; stand-by generators will be available but operated only on as needed basis in case of power outage from the electrical grid. As part of ESAP #1, BMT will implement air quality and emissions management and monitoring procedures to ensure that: (a) all equipment operated by the terminals are properly maintained and their emissions are within national standards and (b) truck dwell time (particularly engine idling time) is minimized. 

Noise

Project noise receptors include BMT accommodation camp, located 1,600 m from the construction area of the terminal, and residential receptors in Umm Qasr, the closest town located approximately 2,000 m from the terminal. Noise propagation was modeled in accordance to ISO 9613 and noise measurements have been taken during construction activities indicating no significant noise levels at receptors. As part of the ESMP, BMT developed a Noise and Vibration Management Plan which outlines noise control and mitigation measures to reduce construction and operational noise levels in line with applicable requirements. As part of ESAP #1, the Company will continue to monitor noise and vibrations levels during operations and will define action thresholds, consistent with national requirements and relevant and applicable WBG guidelines. 

Resources Use

During the construction phase of Terminal 2 electric power is generated by diesel generators installed at the construction site. Fuel consumption for Terminal 1 operations is mostly for equipment and vehicles, complemented by any fuel used for the operation of stand-by generators. The forecasted fuel consumption for both terminals is expected at about 1,800,000 liters by 2025. The fuel storage tanks at Terminal 1 are in a contained area. As indicated above, spill prevention and management procedures will be revised and updated as part of the IMS/ESMP update under ESAP item # 1. During operation, both Terminal 1 and 2 will receive power from the national grid via an underground cable with an estimated annual consumption of around 60,000KwH  (60MwH) on the basis of a volume handled of 400,000 TEUs.

Water used during construction of Terminal 2 is sourced from an abstraction well within BMT accommodation camp and drilled by BMT for the provision of non-potable water. The well will be shut down when the contractor completes the construction works. Subsequently, non-potable water will be supplied from Terminal 1’s facility when Terminal 2 becomes operational. Bottled water is available for potable use. 

Greenhouse Gas Emissions (GHG)  

GHG emissions during the construction phase based on overall fuel consumption as of the end of April 2020 were estimated to be less than 8,000 CO2 tons emission/year.  During operation, direct GHG emissions are expected to occur from the operational vehicles and will be limited. BMT forecasts that Scope 1 and 2 GHG emissions due to Terminal 1 and 2 operation until 2025 are expected to be about 60,000 tons CO2-eq /year.

Waste Management

BMT developed a waste management plan including guidelines for hazardous waste management applicable to its contractors, which is an integral part of the IMS. Solid waste generated by Terminal 1 operations is collected and segregated at site by BMT and then disposed of by external contractors at locations identified by the local authorities. The terminal’s waste storage area is located on a paved area and is fenced with controlled access. It includes adequate signposting. BMT keeps internal records on waste generated at site; however, no official document is issued by the collection truck and/or the receiving facility. This will be corrected as part of the upgrade of the IMS/ESMP under ESAP #1. 

During construction of Terminal 2, the project-generated waste includes: waste from construction activities (e.g. scrap metal, plastic, glass, paper and cardboard, packaging, etc.); domestic waste from the construction area and base camp; and hazardous wastes (e.g. used oils). While no environmental incidents or oil spills were reported during construction, areas of improvement in terms of construction waste management were identified, and this will be corrected as part of the construction debris cleanup actions under ESAP #1.

Activities expected at Terminal 2 will not include loading/unloading of liquids (e.g. goods or ship refueling), thus reducing the risk for spills. Secondary containment will be provided for fuel and hazardous material storage with containment capacity accommodating 110% of the largest container. Spill kits will be available at the site. Disposal of hazardous waste will be undertaken by an authorized party. Vessels do not discharge/dispose of any waste at the terminals.  The Project design entails the installation of oil separators along the drainage system to avoid the release of oily waters into the environment. 

Blast furnace slags were used as fill material during Yard 5 construction. Considering the arid climate of the Project area, slag’s leachate potential linked to infiltrating rainwater is not a credible risk scenario.  Slags may be in contact with some shallow body of groundwater or perched water. Given that the Project is located along the shore and utilization of the local (salty) shallow groundwater is unlikely, risks due to potential contamination are also considered negligible. Nevertheless, as per the updated IMS / operations ESMP under ESAP #1, BMT will monitor and report on groundwater quality through the existing piezometers.        

 Terminal 1 has constructed infrastructures and uses equipment that meet good industry practices. The same standards are and will be used for Terminal 2.

Community Health and Safety

The port is located adjacent to two main roads leading to/from Basra and Bagdad. It is expected that Terminal 2 operation will result in a measurable increase of truck traffic that will further increase pressure to an already stressed situation given the incremental growth of the port activities in the last 3-4 years. The Project ESIA highlighted three main risk areas related to traffic safety: improvement of the external access road; lack of drivers’ compliance to road rules; and poor traffic management at port access points. In line with public roads improvements being undertaken by Ministry of Roads, Terminal 1 has implemented a one-way traffic managements system.  Up until now, the two terminals have only been used to import good and for the foreseeable future volumes will remain almost exclusively import. Therefore, incoming trucks will mainly transport empty containers; therefore check in procedures at the gates are rather expedite.

While BMT emergency response plan includes road collision management and response, the Project operational E&S management plan only provides general guidelines on traffic management. As per ESAP# 5 BMT will develop a traffic management plan for the operational phase incorporating mitigating measures outlined in the ESIA including, but not limited to, identification of key stakeholders, both within the local/national authorities and local representatives, drivers training and safety measure, signage, and control measures.

While some labor influx took place during peak construction of Terminal 2, most non-local labor was housed at the on-site workers camp with minimal impact on the local communities and its infrastructures. 

Emergency Preparedness and Response

BMT has a comprehensive set of procedures for the management of emergencies, as described in the PS1 section.  These procedures describe measures to address specific emergencies, define the emergency response organization and responsibilities, and include include procedures for communication, response, reporting, debriefing, training, handling media, and system review. The Company has communicated its emergency and evacuation plans to district/local government emergency authorities.

Security Personnel

Security is a known regional contextual risk with the most recent country-wide social unrest occurring in 2019.  At the port, external security (e.g. road blocks and checkpoint leading to the port) is under the responsibility of an Iraqi naval division, headquartered at south of the port, while perimeter and internal security is under the Iraqi port security department (IPSD). IPSD is responsible for all port access gates and internal checkpoints. In addition, within the terminal area and the Project site, BMT has its own security team.  The team includes 70 armed and unarmed guards; personnel monitoring CCTV feeds, and two coordinators.  The BMT team controls access/egress and patrols the Company working area in addition to checks conducted by Iraqi Authorities. There is no direct contact between BMT security and the community as all activities are carried out within the port area.  All outgoing and incoming security information are managed by IPSD port center with BMT local liaisons management maintaining constant contact with IPSD and the Iraqi naval division.  Security at the construction camp is provided by a third-party company, licensed by the Minister of Internal Affairs, with extensive experience in providing security for international companies in Iraq. 

BMT has developed a security plan and several related procedures (e.g. operational security procedure, crowd control procedure, emergency evacuation plan) generally aligned with IFC PS4.  The plan is constantly updated/adapted to reflect current risk situations and takes into account consultations with security contractors. However, these documents are not fully integrated within the IMS, are not cross referenced or linked to BMT policies and relevant procedures. 

BMT, as per ESAP # 6, will review and update the security plan to: i) fully meet IFC PS4 provisions related to use of security forces; ii) verify that the plan is commensurate to the risks identified in the sensitivity analysis; iii) cross reference all relevant documents and procedures and integrate them in the IMS as well as the community grievance mechanism; iv) review Company security team procedures to include clear instructions on managing security related issues; v) include provisions requiring contractors security plans to be aligned with BMT security plan and requirements; and vi) formalize security training requirement and matrixes for the Company own security team.

Project security providers, whether directly contracted by BMT, or indirectly by a contractor on the Project, are screened by BMT.  All security personnel undergo formal induction and special awareness training on project risks and conduct requirements towards project workers. Training is reinforced through regular debriefings and performance reviews. In-house security team receive regular training and toolbox talks.

Armed guards need to be trained to the standard required to conduct armed guard force duties. The in-house security team have been vetted through the Minister of Interior, or by senior tribal leaders in the region. All new recruits are subject to a background check BMT as required by the Company security plan.

 A Stakeholder Engagement Plan (SEP) was developed as part of the project ESIA. The plan needs to be updated and operationalized, especially with respect to stakeholder mapping and consultation, including fishermen and women’s representation. As per ESAP# 7, BMT will undertake a review of the stakeholder engagement mapping and will review and update the Stakeholder Engagement Plan (SEP) in line with IFC requirements. The updated SEP will include, but not limited to; (i) delineation of stakeholder profile, including the fishermen and vulnerable groups,; (ii) a stakeholder consultation procedure; (iii) dissemination of information in culturally appropriate formats; (iv) stakeholder engagement log; and (v) reporting to affected communities.

As part of the SEP, BMT will collaborate with port authorities on continuous engagement with fishermen, during operations of the terminals and during the potential construction of the dredger berth; on any potential grievance or concerns related to fishermen livelihoods; and on monitoring maintenance dredging, including implementation of adequate procedures and mitigations as per GIIP.

Grievance Mechanism

BMT will update its community grievance mechanism as per ESAP # 7  to: (a) receive concerns and grievances from members of affected communities; (b) communicate to affected communities the channels/means for lodging concerns/grievances; (c) redress the grievances in a time bound manner; (d) upon redress communicate the decision to the aggrieved person/community; (e) provide a mechanism to appeal against a redress decision if the aggrieved persons/community is not satisfied by the redress proposed in the first instance; (f) document grievances received and redressed; and (g) analyze grievance related data to identify patterns and undertake systemic improvements as needed. 

Information Disclosure and Ongoing Reporting to Affected Communities

BMT, as part of the SEP mentioned under ESAP # 7, will assess the information needs of each stakeholder group and disclose relevant information through most appropriate channels including, where relevant, updates on ESAP implementation. The requirement for stakeholder consultation and ongoing reporting will be incorporated in the SEP for ongoing terminal operation, and will include procedures to inform the communities before commencing any construction or maintenance work required for the terminal operations that may have potential for impact on the communities.                                                  

      Contact Person: Erkan Erkocu – QHSE Manager

Company Name: Aloreen Investment Limited

Address: Umm Qasr North Port

Email:   Erkan.erkocu@bmtiq.com                 Phone:    +9647809202644