As the project is located in a remote area that is sparsely populated, no physical or economic displacement is expected and therefore, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable to this project. Prior to establishment of the mine, the area was primarily pastoral, and an area used for moving and grazing livestock. No physical or economic resettlement was required to develop the mine. Proposed expansion works will occur within the mine site initially fenced perimeter. The project area is located in a desert environment and prone to drought, and therefore it is not used for agriculture.

Artisanal mining is a recent phenomenon in the area and no artisanal miners were displaced for the development of the project. In 2016, a gold rush brought artisanal miners to the area around Tasiast whose activities are to the north and beyond the Tasiast property. Project security and the presence of the Gendarmerie have effectively prevented artisanal miners from encroaching on the Tasiast site. The project provides the artisanal miners emergency health services upon request from the Gendarmerie and continues to support government efforts to manage and minimize the environmental and social impacts of their activities.

No Indigenous Peoples, as defined by PS7 have been identified in or in the vicinity the project area. Therefore, PS7 is not applicable to this project.                                                  

 This is a Category A project according to IFC’s Policy on Environmental and Social Sustainability in consideration of potentially significant and diverse environmental and social risks related to the project construction and operations. Environmental risks which are considered to be significant include water abstraction and resource use; hazardous materials use (including cyanide) and hazardous waste generation (i.e. tailings); waste generation (including waste rock and general domestic waste); air emissions; security risks; impact on archaeology and cultural resources; population influx; labor issues and workers’ and community health and safety risks.                                                  

 PS1:  Assessment and Management of Environmental and Social Risks and Impacts

Environmental and Social Assessment and Management System: Project operations are based on the formal approval by Mauritanian authorities of several Environmental Impact Assessment (EIA) studies completed before and since mine commissioning in 2007. Under Mauritanian law, where projects present less significant environmental risks, an Environmental Impact Notice (EIN) is required. Consideration of potential social impacts is included in the project’s EIAs and EINs. TMLSA has prepared and submitted two EINs, two EIAs and one EIA addendum for the expansion works, all of which have been approved by the government. The EIAs and EINs prepared by TMLSA reference Mauritanian laws, the Performance Standards (2006 and 2012) and the World Bank Group EHS Guidelines.

Following the Kinross acquisition, an EIA was undertaken (March 2012) to assess an expansion of a mine operation of up to 60-70 ktpd, referencing the Performance Standards assessing on-site mine, process and infrastructure. Following the Kinross decision to scale back the scale of the mine plan, an addendum (2016) was undertaken.  The addendum addresses two incremental increases in production rates from 8 ktpd, namely production up to 15  ktpd and production between 30 and 38  ktpd, therefore covering recent completed project and any future development. These studies were undertaken referencing IFC’s Performance Standards and General EHS Guidelines.

Supporting the development of the EIAs baseline data were gathered for the initial permitting of the mine (2004) and have been updated through additional surveys in 2008, 2009, 2010, 2014.

Policy: At the corporate level, Kinross have developed and implemented overarching policies, corporate responsibility management system (CRMS) applicable to all operated assets.  The CRMS defines 10 guiding principles, which include i) “do no harm” in terms of workforce health and safety, environment, and community; ii) “make a positive contribution” through employment, local content, and community development; and iii) “act ethically and transparently” through adherence to standards of business conduct, respect for human rights, and engagement with stakeholders. As in all other aspects of its business, and as defined by its corporate policies, Kinross strives to continuously improve performance in the area of corporate responsibility.

TMLSA has defined its environmental duties, policies and procedures within a framework environmental management system (‘EMS’) that is outlined in an EMS manual. The document describes environmental management and compliance requirements and provides an overview of the EMS. The manual is aligned with the principal requirements of ISO 14001 and the imposed compliance conditions associated with the license to operate and the various regulatory obligations. The EMS is comprehensive covering exploration, mining, processing and development projects within the Tasiast project area. The EMS was initially developed to handle an estimated production rate of 8 ktpd. The TMLSA EMS Manual is consistent with the requirements of Performance Standard 1. As part of IFC’s financing TMLSA shall augment the existing EMS to reflect the 15 ktpd project as defined in ESAP #1a and update the project risk register per ESAP #2.

TMLSA has established a management program that describes mitigation, performance improvement measures and actions that address the identified social risks and impacts of the project. The programs apply across the organization. The management program includes action plans under the site responsibility plan, which defines desired outcomes and actions to address the issues raised in the risks and impacts identification process. The program considers elements of performance indicators, targets, or acceptance criteria that can be tracked over defined time periods, and with estimates of the resources and responsibilities for implementation. The progress measured against all objectives is successful, and the degree of site responsibility plan implementation is described as 100%.

TMLSA engages with semi-nomadic communities and urban communities in Chami and other towns and villages. Community programs resulting from feedback received in stakeholder engagement are designed to a) support community priorities, and b) support groups and activities which play a key role in community cohesion including local institutions, women’s’ groups, community associations. The program takes account of the outcome of the engagement process with affected communities.

Monitoring and Review: The expansion project EIA and the addendum have an environmental management section, which presents the provisional outline environmental management plan (EMP) for each stage of the project. It lists potential environmental and social impacts and proposed mitigation measures and provides the framework for implementing and monitoring those measures. These EMP’s were developed to be incorporated as appropriate into the TMLSA Environmental Management System. The framework action plan (or environmental commitments register) presented for each expansion of the project is integrated in the existing mine EMS/EMP via the TMLSA obligation register.

The site EHS department conducts daily inspections, which are scheduled to ensure all work areas are inspected on an at least monthly basis. The plan includes monitoring, sampling and analysis activities and establishes the reporting protocols, including quarterly and annual environmental data submissions to the relevant government ministries, Kinross corporate office, and annual performance reports to government. The monitoring plan is regularly reviewed and updated to ensure that it is in line with the project changes and that monitoring of any emerging E&S issues is incorporated.

In addition, the Kinross Corporate Office conducts a comprehensive EMS audit every two years to assess the site’s environmental performance and compliance against its management system. The next Kinross corporate audit at Tasiast is scheduled for second half of 2020. Government entities, namely Ministry of Environment and Sustainable Development (MESD) and Ministry of Water and Sanitation (MWS) also audit the project regularly.

Organizational Capacity and Competency:  TMLSA maintains an organizational structure that defines roles, responsibilities, and authority to implement the ESMS. Specific personnel, including management representatives, with clear lines of responsibility and authority have been designated, and the structure undergoes periodic reviews.

The general manager has overall responsibility for the Kinross Tasiast mine and the EMS, supported by heads of department at Tasiast mine, corporate management in Toronto and the board of directors. The Kinross board has responsibility for the stewardship of Kinross and has adopted a formal charter setting out the board’s stewardship responsibilities, including the Board’s responsibilities for the appointment, oversight and compensation of management, satisfying itself that management is maintaining a culture of integrity, strategic planning, risk management, board governance, oversight of health and safety, technical and operational, environmental and corporate responsibility matters and oversight of communications, financial reporting and reporting to shareholders. The board reviews Kinross’ long-term strategy not less than annually. There is also a Tasiast board that reviews all aspects of the mine’s performance, including environmental and social risks.

Emergency Preparedness and Response: The emergency response plan (ERP) for Tasiast project area (2016) has been prepared to align with the Kinross crisis management plan (KCMP), and associated Kinross crisis management system (KCMS). The plan complies with Kinross operations located in the United States and Canada. The KCMP and KCMS are implemented at the Tasiast mine by the site crisis management team (SCMT). The SCMT comprises a specifically trained group of staff that will be called upon in a crisis event.

The guidance provided within the ERP is intended to mitigate or protect Tasiast personnel (including staff, contractors and visitors) and the surrounding communities from injury, prevent/minimize damage to the environment, provide general guidance on the overall emergency response procedure and provide specific procedures for emergency scenarios.

Tasiast has a fire station located within the accommodation camp, staffed by trained emergency response personnel and a well-equipped and staffed site medical clinic.  A key component of the ERP is the cyanide emergency response procedure (CERP). The CERP is fully compliant with the requirements of the International Cyanide Management Code (ICMC). Security response team (SRT) and the on-site clinic are also trained and equipped to respond to cyanide emergencies.  

Cumulative Impacts: Potential cumulative impacts associated with the project expansion, including increased water use from the borefield, were considered at the time the risks and impacts identification process was conducted as part of the EIA.  Since the EIA was completed, in 2016 an exploration license was granted to a third-party explorer located 25km to the south east of the Tasiast mine operation.  With no current plans for new mining operations in the region, the potential for significant cumulative impacts is expected to be limited.

Also, under a Government of Mauritania program, the town of Chami (approximately 80 km southwest of the site and 20 km from the project wellfield) has been developed. This new town is located near the PNBA, and with support from the United Nations Educational, Scientific and Cultural Organization (UNESCO) and the World Heritage Council, the PNBA has obtained funding for a Strategic Environmental Assessment to assess the recent development of Chami. The terms of Reference of this desktop study were developed in 2018. The study was planned to commence in 2018 and IFC understands that it will be made public upon review and validation by the Government of Mauritania.

Closure and Rehabilitation: TMLSA maintains a preliminary rehabilitation and closure plan (PRCP) as part of its corporate governance as well as a legal requirement established in the EIA process. The PRCP was first developed in 2012 and was updated in 2013 to take into consideration environmental impact assessments and additional changes. The PCRP was developed to ensure safe closure of the mine at cessation of operations. The PRCP is based on a closure plan of eight years (three years for implementation and five years post implementation). Detailed closure plans for specific infrastructure are prepared on an ‘as needed’ basis and are submitted to the government for approval in advance of any closure activities. Closure plans were prepared and submitted for TSF­ 1 and TSF 2 and subsequently decommissioned and rehabilitated. The closure plans have been prepared in line with the WBG EHS guidelines for mining (Mine Closure and Post Closure).  TMLSA has letters of credit in place totaling $6.2 million, based on 2011 closure cost estimates. In 2016, TMLSA submitted an updated closure estimate of $37 million to reflect the planned expansion. The Government of Mauritania has requested an independent review of the estimate. Upon completion of the review, TMLSA will put additional financial assurance in place. Regardless of the financial assurance, Kinross has sufficient cash flow and reserves to cover the total estimated cost of closure. TMLSA has completed some aspects of closure included in the 2016 submittal, reducing the current estimate to approximately $33.2 million.

Grievance Mechanisms: TMLSA has also implemented a grievance redress mechanism to receive, respond to and seek resolution of stakeholder concerns in a systematic manner. Community members can log a grievance by calling the grievance department staff directly. Grievances are recorded in a grievance book (the community relations department maintains two grievance books – one in French and one in Arabic). Each original form has two carbon copies; the complainant retains the original form, with the community relations department retaining the second copy as a working copy, and the third is given to the department responsible for the grievance (e.g. if the grievance is related to noise from mining, the mining department will receive a copy of the grievance). When a complainant is unable to write his/her complaint, the TMLSA community relations officer receiving the verbal grievance is responsible for recording the nature of the compliant and all pertinent details. The grievance is then logged into the stakeholder management system and followed up until the grievance is closed. The mechanism requires the community relations department to respond to the complainant within 14 days.                                                  

The mine employs approximately 3,400 workers through TMLSA and its contractors (October 2018) and 94% of TMLSA employees are Mauritanians. TMLSA is implementing a Mauritanization plan to replace numerous expatriates by nationals who are being trained to acquire the appropriate knowledge and expertise. By 2020, the number of expatriates directly hired by TMLSA is expected to drop from the current 120 to 23.

Human Resources Policies and Procedures: TMLSA’s human resource (HR) policies and procedures are based on Kinross’ code of business conduct and ethics; disclosure, confidentiality and insider trading policy and whistleblower policy. These policies and procedures are consistent with, and in some cases exceed, the requirements of PS2. The relationship between TMLSA and its employees is governed by the following: (i) International Labor Organization (ILO) conventions ratified by Mauritania (ii) Law No. 2004-017, as amended, which functions as the labor code in Mauritania; (iii) Mauritanian general collective labor agreement (1974); (iv) collective labor agreement (2016) and (v) TMLSA staff regulations and internal rules.

Working Conditions and Terms of Employment: All TMLSA employees have employment contracts. There are different types of contracts including probationary workers engaged for a trial period and workers hired on either a fixed term or indeterminate period. Terms and conditions of contracts are supplemented by the staff regulations, internal rules and collective labor agreement.

Once hired, an employee undertakes an induction program, EHS training, training to refresh or upgrade skills if working in a technical field, and then area-specific training that pertains specifically to the job. To complete this training, employees participate in classroom computer-based training combined with field training led by an instructor. Field training is followed by hands-on training and, finally, on the job training. Employees designated for specific trades training are expected to enroll in a multi-year apprenticeship program.

Mine operations are continuous, and production workers are divided into three crews and work in 12 hour shifts to cover this schedule and on rotation. TMLSA provides accommodation, meals and laundry services for employees and contractors working at Tasiast. The accommodation is in accordance with the requirements of the IFC / European Bank for Reconstruction and Development Guidance Note: “Workers’ accommodation: process and standards.”

As established in the code of business conduct and ethics, TMLSA is an equal opportunity employer and does not tolerate any discrimination on the basis of race, color, religion, sex, national origin, age, sexual orientation or disability, or according to any other applicable laws and regulations in the jurisdictions where it operates. TMLSA is committed to fair employment, including equal treatment in hiring, promotion, training, compensation, termination and corrective action.

Worker’s Organizations: Currently there are four unions at Tasiast: (i) Confédération Mauritanienne Libre des Travailleurs (CMLT); (ii) Confédération Libre des Travailleurs de Mauritanie (CLTM); (iii) Confédération Générale des Travailleurs de Mauritanie (CGTM); and (iv) Union des Travailleurs Mauritaniens (UTM). There are no barriers to legitimate freedom of association through trade union membership and/or collective bargaining. There have been four legal strikes at Tasiast in 2006, 2011, 2012, and 2016. The most recent strike (2016) ended with mutual agreement on a 3-year Collective Labor Agreement (CLA). The current CLA will expire in October 2019. A new CLA will be negotiated between TMLSA and the unions upon expiration of the current one. The unions hold monthly meetings with management to discuss issues and follow up on commitments.

Retrenchment: No retrenchment is planned for the near future. If a need for retrenchment is identified, a retrenchment plan will be developed by TMLSA in accordance with the Government of Mauritania and PS2 requirements. Due to depressed market conditions, in early 2015 a retrenchment of approximately 220 staff (both expatriates and national staff) was undertaken. The retrenchment was carried out in accordance with local laws and PS2 requirements. TMLSA also developed a support program for laid-off national employees, which provided them with training and grants to start small businesses.

Grievance Mechanism: The code of business conduct and ethics and whistleblower policy provide the basis for TMLSA’s employee grievance redress mechanism. The whistleblower policy was developed to facilitate open communication and to ensure that employees have a means to report actual or suspected violations of Kinross policies or applicable laws without fear of reprisal. While the code indicates that issues such as unlawful discrimination, harassment, workplace violence, working conditions and other improper treatment can be addressed to an HR representative, the whistleblower policy encourages employees who are reluctant to report these issues to HR to report them directly (either verbally or in writing) to the senior vice-president HR, chief legal officer or senior vice-president & general counsel or to another member of the company’s senior management team.

Occupational Health and Safety: The activities undertaken for any mining operation present inherent health and safety (H&S) hazards. The physical environment where project activities take place presents additional potential H&S impacts, such as respiratory problems, heat and thermal stress, noise-induced hearing loss from excessive noise exposure; skin disorders and/or damage to internal organs from contact with a wide range of chemicals, and physical injury from accidents involving machinery and movement of construction materials and explosives.

Overall, occupational health and safety (OHS) management on site is the responsibility of the EHS Department. TMLSA’s H&S policy is founded on achieving zero harm through effective management. Kinross has implemented seven “cardinal rules” at all Kinross operations, applying to behavior that can lead to potentially fatal hazards. The seven rules are: (1) seatbelts must be worn while in a moving vehicle; (2) operators must be trained and authorized to use equipment; (3) entry into a restricted area requires proper authorization; (4) hazardous energy control requirements must be observed; (5) proper fall protection must be used when working at heights or near an open hole; (6) specialized work permit requirements must be observed; and (7) safety devices must never be removed, tampered with or bypassed. The project operates on zero tolerance policy for violations of the Cardinal Rules. While infractions are assessed on a case-by-case basis, the majority result in dismissals.

As a result, TMLSA’s H&S performance meets best international standards, with a total reportable injury rate of less than 0.3 per 200,000 hours worked (comparable to frequency rates in lower risk sectors such as insurance agencies / travel agencies). Workers adhere to safe working practices, for example, workers observe speed limits, use adequate personal protective equipment (PPE), and conduct “safe watches”. The safe watch program involves work safety observations of personnel to evaluate work place risks and includes space for commenting on safe and poor work practices and on actions to be taken to mitigate risk.

A medical clinic is currently in operation at Tasiast 24 hours per day, 7 days per week to provide medical advice and assistance to workers (staff and contractors) and the local community within 30 km of the site. The clinic has two doctors present on site plus two of either a senior medical officer, paramedic and/or chief medical officer; as well as four nurses, and one head nurse offering a full range of required medical support required for large scale mining operations. The clinic is equipped with 3 ambulances. In addition, TMLSA has provided emergency and medical response for ASM incidents when requested by government representatives, for example in the event of cave-ins and/or vehicle incidents.

TMLSA conducts health and safety monitoring to ensure that potential threats to worker’s health and safety are being adequately addressed or mitigated. Explosives are stored in dedicated explosive storage magazines separate from detonators, delays and detonating cord. Magazines have been fitted with lightning protection and locks, surrounded by earthen bund walls within a secure compound. Staff are informed of dates and times of planned blasting activity via signs at the entrance to the work site, and a 500 m exclusion radius is established and maintained during blasting activity.

Workers Engaged by Third Parties: While TMLSA performs a majority of the main production and maintenance activities of the project, contractors are engaged mainly in areas of logistical support such as catering and accommodation, security, medical services, flight services, fuel supply and distribution among others. In line with its business needs, TMLSA is assessing shifting more of its activities to contractors. Contractors are contractually obligated to adhere to TMLSA’ EHS requirements, and all contractor employees undergo the same site induction, and EHS training as TMLSA employees. For major contracts, bidders are prequalified to work on the project based in part on their H&S management system and prior performance. Bid evaluation criteria is established based on the associated H&S risks for the work package. For all work packages issued for tender, the EHS requirements for the subcontractors' document are included. These requirements include minimum levels of onsite supervision, requirements for contractor onsite H&S personnel, PPE and site pre-access medical requirements. The HR department also actively engages with all contractors to ensure consistency across the project with respect to labor standards (namely forced and child labor) and treatment of workers including adequate compensation in line with government of Mauritania labor code. The HR department regularly audits contractors to ensure compliance with project standards. Contractors are also encouraged to hire local employees.

Supply Chain: TMLSA screens potential suppliers as part of its pre-qualification process which includes but is not limited to EHS considerations and labor standards.  All suppliers are required to sign and adhere to Kinross’s supplier standards of conduct which commits suppliers to conduct their operations safely and to comply with the Kinross code of business conduct and ethics, including applicable anti-corruption laws, as well as the fundamental principles of the UN Global Compact respecting human rights, labor standards, environmental protection, and anti-corruption. In addition, TMLSA conducts audits of its suppliers to ensure compliance with the supplier standards of conduct. Every two years Kinross conducts site specific audits on the supply chain management system.

Slavery was only abolished and criminalized in Mauritania relatively recently (1981 and 2007, respectively), and reports indicate that such practices are still widely undertaken. While TMLSA has good systems and controls in place to ensure that there is no forced labor of its employees and contractor employees, further assurance mechanisms will be developed as part of IFC’s financing to assess the risk associated with potential forced labor within the second tier of the TMLSA supply chain and take appropriate management action. TMLSA includes E&S provisions in its agreements with suppliers and conducts due diligence and regular audits of its major suppliers. Thus far, TMLSA have not identified any indication of modern-day slavery in its supply chain. TMLSA will develop a procedure to assess its second-tier suppliers with regards to the non-use of forced labor within its supply chain, and where required implement corrective actions within their control per ESAP #3a.

As part of its local business integration plan, TMLSA provides an opportunity for local businesses to provide goods and services that are within the local capacity and capability. This includes review of in-country capabilities compared with project needs, characterizing all purchasing requirements based on potential source location, communicating with potential local suppliers, and offering training / capacity building programs for local business based on identified needs.

Workforce and Gender: Based on IFC Gender Based Violence (GBV) Risk Screening Tool, the project is located in a region and country where the risk of gender-based violence in the workplace is substantial. Further assessment of the project will be carried out by the project using IFC’s GBV Project Assessment Tool to assess the project specific risk level and propose adequate gender actions per ESAP #3b. TMLSA shall implement gender actions proposed as a result of the project GBV assessment if applicable.                                                   

 Water Consumption: The source of water for the Tasiast mine is a non-potable saline groundwater wellfield (Sondage) located approximately 65 km west of the mine, close to the Nouakchott-Nouâdhibou N2 highway. The wellfield is comprised of 43 production boreholes with current abstraction rates at c. 14,000 m3/ day (permitted to abstract at the maximum allowable rate of 30,000 m3/day).  The well field extracts saline to hyper-saline groundwater (TDS 18,000 – 53,000 mg/L).  The USEPA classifies salinity in water as fresh (<1,000 mg/L), fresh to brackish (1,000-3,000 mg/L), brackish (3,000-5,000 mg/L), saline (5,000-35,000 mg/L) and hyper-saline (>35,000 mg/L).  The raw water is used for the process. The raw water is treated (reverse osmosis) for use in the camp.

Only 15 to 25 boreholes are operational at any one time to meet the current water requirements of the mine. At the sondage, groundwater occurs at a depth of 45 m below ground surface. The water table in the region is approximately 5 m below sea level. The abstraction wells are completed in 5-10 meter thick layer of sand approximately 80 m below the ground surface. Water is pumped to tanks at the Sondage then conveyed to the mine site via three water pipelines (400mm, 450mm and 500mm pipelines) located adjacent to the access road. 

Studies indicate that the Sondage is abstracting fossil water. There are no other current users of this aquifer. Extensive modeling and monitoring confirm that abstraction of this water at the sondage will not affect users of “fresh” water zones located ~13 km north, and ~11 km south of the sondage.

Management of the groundwater resources at the Sondage is closely monitored by TMLSA, with regular reporting and engagement with the National Center for Water Resources. The monitoring program includes collection of groundwater level and water quality data from i) production wells at the sondage wellfield, ii) a network of observation boreholes installed by TMLSA to monitor the groundwater system at both a local and regional level in relation to the wellfield, and iii) selected community wells, including those closest to the Sondage wellfield which are located at Wad Chebka and Chami. The groundwater monitoring program has been designed to ensure that potential water supply issues are identified early (i.e. providing a lead time of at least three years to design and implement remedial measures). All monitoring and production boreholes are equipped with data-loggers, which record water level fluctuations every 3 hours. Monitoring wells also allow the project to detect any potential impact on nearby freshwater aquifers.

Solid Wastes: A waste management facility management plan (site services procedure) has been developed by TMLSA (in draft), outlining the waste management process for the Tasiast project.  The plan details processes for waste reception, treatment, storage, incineration and final disposal and defines the responsibilities for its operation.  As part of IFC’s investment TMLSA will finalize this management plan per ESAP #4.  There is also a contaminated and hazardous waste procedure, a general or uncontaminated waste procedure and a bulk waste management procedure. These documents provide instructions and procedures for safe collection, handling and disposal of hazardous and non-hazardous waste generated by the project.

Wastewater / Effluent: The project is a zero-discharge mine. The three wastewater treatment plants are designed to recirculate treated waters to the milling process at the CIL.  Tailings water is reclaimed into the CIL, the dump leach pads, and to the process solution ponds.

Tailings Management: As part of the expansion, a cyanide destruction circuit was installed reducing weak acid dissociable (WAD) cyanide to 45 ppm or less, meeting the ICMC standard.  Approximately 50% of tailings water is recovered and re-used for processing. There are 4 tailings storage facilities (TSFs) on site. TSF 1 and TSF 2 were built by others prior to Kinross involvement and have been decommissioned. Use of TSF 3 has been discontinued as part of the expansion, with TSF 4 now as the operational facility (having been completed in 2018 as part of the expansion).  TSF 1 has been non-operational since 2009 and was officially closed (as per the closure plan approved by the government) in 2016. Closure included using waste rock to cap the TSF, and the installation of a double-lined seepage pond to collect seepage from TSF 1. A monitoring program is in place to monitor the quantity and quality of seepage flow. TSF 2 has been non-operational since 2012. The closure plan was approved at the end of 2016 and was completed in 2018, representing a component of the overall mine closure plan. TSF 2 experienced historical seepage, and therefore, a program was put in place to abstract seepage water, monitoring cyanide concentrations in groundwater with groundwater concentrations and meet ICMC standards.  Use of TSF 3 was discontinued as part of the project, and currently the dam no longer stores water and is in the process of consolidation. Typical to mining operations in arid regions the deposited tailings, once dried, form a crust which prevents potential for windblown dust from the TSFs.

Waste Rock: Waste rock generated from the mining process is stockpiled in waste rock dumps, which have been designed, including overall slope angles, height restrictions, groundwater and surface water interaction and closure requirements, in accordance with Kinross standards for waste rock and the WBG EHS Guidelines for Mining.

Acid Rock Drainage (ARD): waste rock generated as part of the mining process exhibits a net neutralization capacity.  Coupled with the arid climate, lack of surface water and very limited groundwater indicate low potential for ARD or metal leaching to develop. As new pit areas are developed, additional analysis of ARD potential will be undertaken. If ARD is found to be a risk in certain materials, suitable measures will be developed and implemented to mitigate these risks. Similarly, analysis of tailings indicated overall neutralizing capacity.

Hazardous Materials: Hazardous materials are managed through a combined EHS approach which includes safe transportation and loading/ offloading, handling, storage and disposal as per the material safety data sheet guidance and appropriate training and use of PPE.

Cyanide Management: Kinross is a signatory of the ICMC.  In January 2017, Tasiast achieved ICMC certification for the procurement, transport and handling of sodium cyanide during the operation of the mine, including the subsequent expansion. The results of the audit undertaken as part of the certification process indicated that the project is in full compliance with the ICMC. 

Cyanide is received on site in conventional dry briquette form (nylon supersacks overpacked in plywood boxes in standard steel sea containers) via ocean transport at the port of Nouakchott, and then trucked to the mine site. TMLSA has developed, and continues to revise and update as required, a comprehensive suite of management plans and procedures for the management of cyanide facilities, which cover the storage of high strength cyanide solution separate from acids or other reactive materials; the implementation of secondary containment for all cyanide solution transfer, mixing, leaching and detoxification tanks; avoidance of accumulation of cyanide gas; and day to day monitoring and management of the ADR and CIL operations. Access is restricted to properly trained workers at cyanide facilities.  Cyanide is purchased from and transported by ICMC authorized producers and transporters. A secure burn area for disposal of cyanide packaging residues from both the ADR and CIL operations is also provided.

Pit Dewatering: The West Branch pit is currently excavated to a depth of approximately 210 m below surface (80 meters below sea level) and contains water in its base.  A pit-water pumping system evacuates rain water and groundwater inflows.  The long-term mining plan considers a pit floor depth of up to 700 m below the surface or about 650 m below the natural groundwater level; however, due to the low hydraulic conductivity of the basement rock, groundwater inflows are likely to decline over time.  The long-term average inflow rate is calculated at 1,400 m3/day and the drawdown cone is likely to remain within the mine boundary.

Air Quality: Current emissions include nitrogen oxides (NOx), sulfur dioxide (SO2), carbon monoxide (CO) and carbon dioxide (CO2) from power generation, mobile plant, road vehicles and airstrip operations. Due to the remoteness of the mine, air quality is not affected by any other surrounding industries. All ambient air quality parameters are below WBG General EHS guideline limits for ambient air quality, with the exception of PM10 which due to desert conditions are believed to average over 100 µg/m3, ranging to 1,000 µg/m3 or higher during dust storms (based on regional research Ozer et al. 2005). The WBG General EHS guideline limit for PM10 is 50 µg/m3 (24hr averaging period). The exceedance of PM10 is dominated by high baseline conditions of naturally occurring particulates, characteristic of desert environments.  Tasiast mining operations are considered not to materially elevate ambient PM10.

TMLSA has in place an air quality management plan, which includes monitoring stations and a dust management plan that includes measures such as watering roads periodically and temporarily stopping activities during a sand storm and also provides provisions for monitoring. A dust suppressant is used on some roads to increase the effectiveness of dust control measures.  Dust control at the existing crushing plant consists of a sprinkler system at the crusher loading bay and conveyer belts.

Electric power is provided by three plants (heavy fuel oil (‘HFO’) / light fuel oil (‘LFO’) generator sets) and is authorized to generate up to 50 megawatt-electrical (MWe). These three plants are connected to a 33 kilovolt (kV) distribution system.  For any future expansion, an additional power plant would be required to provide additional generation capacity of up to 70 – 80 MWe.  Fuel import sulfur limits are set at the national level, for petrol, diesel and HFO at 0.1%, 0.2% and 1.7 % respectively.

The TSF starter cell, CIL and ADR plants and existing dump leach facilities represent potential sources of hydrogen cyanide gas. There are stringent controls at these facilities to protect the health and safety of workers and the environment.

Greenhouse Gases (GHG): Greenhouse gas emissions estimated using standard methods based on fuel usage at Tasiast were 289,000t CO2e for 2018 (equivalent tons of carbon dioxide).  This estimate accounts for all fixed equipment, mobile equipment and the power station during the first quarter of 2018.  The power plant represents the largest emissions source for the site (around 70%). 

Noise and Vibration: Due to the project’s remote location, the closest sensitive receptor is TTV and site layout allows for adequate distance between noise-generating equipment and TTV. Noise levels at TTV have been assessed and are within WBG EHS Guideline values for residential areas daytime and night-time at 55 dBA and 45 dBA respectively.                                                  

 Community Health and Safety:  There are a low number of people located in the vicinity of the project; therefore, community health and safety risks associated with project operations are limited. There are no permanent community structures within several kilometers of the proposed blasting sites. Semi-nomadic structures also tend to be established at least 1 km from the Tasiast fence line.  

The main community health, safety and security impacts from the project include risks associated with hazardous materials and personnel transport from Nouakchott and / or Nouadhibou to site, risk of traffic accidents along the access roads to the SENISA, TML and SETSA concession areas, and health issues exacerbated by influx and interactions between workers and local communities.

Project reagents, including cyanide, are transported to site from Nouakchott via national road 2. TMLSA’s GR / CR team, through their existing stakeholder engagement processes, raises public awareness of traffic risks, and all reasonable measures are taken to ensure public safety during the transport of oversized equipment and/or hazardous shipments. The project and its transportation contractors are in full compliance with ICMC requirements for transportation of cyanide. Speed limits are strictly enforced. 

All project employees, with the exception of a limited number of people employed from Chami, including contractors, are housed within TTV and old town. There are no contractor camps or other staff accommodation facilities outside the mine perimeter or in the local communities. Employees from Chami are bussed to and form site daily. In general, due to the remoteness of the mine and the lack of water resources in the area, the potential for in-migration in the immediate vicinity is limited. Because of project mitigation measures and the natural conditions of the area, very little mine-related influx has occurred. Regular socio-economic surveys are undertaken to ensure that any changes in local populations related to project activities are captured.

Pre-employment medical screening and fitness-for-work programs minimize the risk of transmitting communicable diseases to members of the public exposed to TMLSA workforce. Furthermore, as part of its corporate responsibility activities, TMLSA allows residents within 30 km of the mine to use the on-site medical clinic and has funded a third-party mobile clinic to provide general medical services to Inchiri region residents. The mobile clinic provides both general services and specialized services, such as ophthalmology, cardiology, pediatrics, diabetes care, and x-ray services.

Community safety has been recognized as a core objective of the preliminary rehabilitation and closure plan. All closure works are designed to eliminate, or as a minimum significantly reduce the risk to public safety. Additional specific measures, if required, will be detailed in the final Rehabilitation and Closure Plan at least two years prior to closure.

Security Arrangements: Kinross applies its corporate global, Africa region and Tasiast specific security policies and standards to the project. Kinross global security standards are based on industry best practice, and establish the baseline security policies, procedures and practices that each Kinross location must implement. TMLSA has adopted the Voluntary Principles on Security and Human Rights (VPSHR). TMLSA regularly conducts risk assessments, training and monitoring consistent with the VPSHR to ensure security measures used at the project do not unintentionally cause, contribute to, or benefit from human rights abuses. Any security related grievances can be reported via the grievance redress mechanism.

TMSLA has its own security team, as well as two private contractors. One contractor functions as the site SRT, which provides support in areas such as journey management (including protection of gold shipments), protection details, investigations and information collection. The other, a large international security contractor, provides security officers to support access control and general day to day security activities. All security personnel on site, including contractors, receive training from Kinross Africa security, and are required to comply with Kinross security standards and policies. Training topics include appropriate use of force, de-escalation techniques, human rights, and engaging with the local community. Project security policies, procedures and standards are compliant with PS4 requirements.

The Mauritanian gendarmerie also has a dedicated unit stationed on site. TMSLA security team has established a good working relationship with the Mauritanian gendarmerie, and they have entered into formal memorandum of understanding and co-operation in intelligence gathering.

The recent development of artisanal and small-scale mining activities in Chami to the north and beyond the Tasiast property has increased community security risks for TMLSA. Forced removal of artisanal or small-scale miners by the Gendarmerie or other government security forces could potentially escalate into conflict situations, which could create reputational risk despite TMLSA not being directly involved in such security operations. As part of IFC’s financing, TMLSA shall develop an influx management plan consistent with the Performance Standards and IFC’s handbook for addressing project-induced in-migration.  The plan shall focus toward artisanal mining activities, and be aligned with and inform the project SEP, to engage relevant stakeholders and manage potential social, biodiversity and ecosystem services risks relating to influx per ESAP #1c.

Tailings Dam Design and Safety: Kinross has an internal standard for TSFs, which meet or exceed standard international practice. Kinross standards require facilities undertake a dam safety inspection by the external ‘engineer of record’ at least once per year. The most recent inspection, which was undertaken in 2018, indicated that all of the dams associated with TSF 3 and TSF 4 were in good condition with no apparent signs of distress. The process department is also responsible for undertaking daily inspections of the TSF operations.

Per international practice, the design criteria for dams are determined based on the hazard classification, which is determined from an assessment of the consequences of a dam failure. Although TSF inundation reports (break analysis) have not been undertaken for TSF 4, the dam has been designed to withstand the probable maximum flood (PMF) and the maximum credible earthquake (MCE), which are the highest possible standard of design and would typically apply only to dams determined to have an “extreme” consequence of failure due to nearby population and/or sensitive environmental receptors in the inundation zone. In the case of Tasiast, there are no surface or groundwater courses or local populations that could be affected by a tailings dam failure, and TSF 4 is therefore designed to a higher standard than would be required based on international practice (e.g. Canadian Dam Association).  TMLSA is currently undertaking a dam break and inundation zone analysis for TSF 4, which is the facility constructed for the 15 ktpd project.  Completion of this work is tied to IFC’s financing per ESAP #1d.

Use of TSF 3 has been discontinued as part of the 15 ktpd project. Like TSF 4, it is designed to the highest possible standard (PMF and MCE), despite the consequence of dam failure would not impact water courses or local populations.  Tasiast will undertake a dam break and inundation zone analysis for TSF 3 in parallel with the TSF 4 study, per ESAP 1d.                                                  

 The project is located within the Saharan-Sindian bioclimatic zone, which occupies up to three-quarters of Mauritania. It also falls within the north Saharan steppe and woodlands ecoregion.

The habitat present within the Tasiast site is of a gravelly regs type (i.e. desert landform of broad plans covered with sand and gravel), which is the typical habitat of much of the middle, north and north-east of Mauritania. Vegetation cover is sparse and comprised of relatively few plant species. The fauna (birds, mammals and invertebrates) is similarly of relatively low diversity. No protected species were identified by baseline surveys in the project area.

The footprint of the mine and associated facilities occupies approximately 2,517 ha, around 20% of the 12,300 ha within the fenced area that constitutes the mine site, and 8% of the 312 km2 mining license. Most of the current footprint had been disturbed prior to TMLSA’s acquisition of the mine and is therefore considered modified habitat as defined by PS6. A total of 283 ha was disturbed for the recent expansion (2016 to 2018) and was considered natural habitat. TMLSA minimized additional footprint and impacts to natural habitat by developing land adjacent to the existing industrial area. Given that the habitat type disturbed occupies a large part of Mauritania and the surrounding region, the project EIAs concluded that no significant residual impact on natural habitat is expected to have occurred as a result of the recent expansion. The surrounding areas and the remaining 80% of the fenced area are still generally considered natural habitat.

The baseline surveys presented some limitations such as lack of expertise in desert herpetofauna and small mammals and the lack of night time surveys. Despite these limitations, baseline surveys are considered sufficient to assess the site as natural habitat and develop appropriate mitigation for potential impacts.

The closest protected site is the PNBA, located 65 km to the west of Tasiast and less than 5 km west of Sondage well field. PNBA, which is designated as a RAMSAR Site and UNESCO World Heritage Site, comprises an area of over 10,000 km2 of intertidal flats and shallow inshore waters bordering the desert. It is thought to be one of the most important coastal wintering sites along the east Atlantic coast and one of the world’s largest concentrations of wintering water birds.

The project’s EIAs had concluded that there are no impacts on the PNBA. In particular, the 2011 environmental assessment looked at the potential impacts of the Sondage well field and concluded that the ecology and habitats of the PNBA are not dependent on groundwater; that the water table lies well below the surface within the PNBA and there is no hydraulic interconnectivity between the borefield aquifer and the PNBA; and that therefore there would be no impact on the PNBA from abstraction of water from the Sondage. In anticipation of IFC financing, TMLSA commissioned The Biodiversity Consultancy to undertake an independent ecohydrology assessment, to confirm or reject the conclusions of the 2011 EIA. The assessment was supported by an update of the regional numerical groundwater flow model developed by TMLSA’s consultants, Piteau. The study, which has been disclosed alongside this environmental and social review summary and will be provided to the PNBA, concluded that there are no plausible pathways for impacts on any coastal or intertidal ecological receptors (ecosystems and species) from the mine’s water abstraction, and therefore no impact to the outstanding universal values of PNBA (primarily associated with coastal and intertidal areas: seagrass beds, mudflats, mangroves and the species they support). The assessment further shows that although drawdown contours from the mine’s water abstraction have a limited overlap with the terrestrial areas near the boundary of the PNBA, the drawdown does not impact on water in the surface layers. The effect of the drawdown on the surface water availability for wadis and sebkhas is negligible compared to the evapotranspiration that occurs on the surface. Therefore, the assessment also concluded that none of the terrestrial habitats and species of the PNBA located in the proximity of the Sondage wellfield or over the drawdown contours could be impacted by the mine’s water abstraction. The assessment was undertaken for the duration of the life of the mine and the water abstraction permit (2034).

TMLSA has initiated engagement with the PNBA managers in the context of the ecohydrology assessment, the engagement of which will be managed via the project SEP and the Biodiversity Action Plan (BAP) per ESAP #1b and #5a respectively. The focus on the engagement will be to address concerns related to potential impacts of the mine whether related to water abstraction or other potential risks. TMLSA will share the results of the ecohydrology assessment and other monitoring results as appropriate as part of the engagement activities.

TMLSA has a biological resources management plan (BRMP) in place to ensure best practice is followed and potential impacts from the project to birds and other wildlife are minimized. As part of IFC’s financing, TMLSA will upgrade the BRMP to include additional mitigation identified through regular risk assessments that include biodiversity per ESAP #5b. The updated BRMP will be equivalent to a Performance Standards compliant biodiversity management plan (BMP) with the objectives of achieving no net loss where feasible and avoiding significant residual impacts to natural habitat and associated biodiversity. The updated BRMP will cover the mine site, infrastructure and their area of influence. Per ESAP #5c TMLSA will assign responsibility for the implementation of the BRMP and associated monitoring to a suitably qualified staff member who will report to the EHS manager on-site.

The updated BRMP will include an invasive species management and monitoring plan per ESAP #5b. If signs of invasive species are identified through inspections, TMLSA will implement measures to avoid spread into new areas and eradicate from natural habitats over which TMLSA has management control.

Current biodiversity monitoring focuses on recording incidences of wildlife mortality on site and investigating the cause of death. Migratory birds are attracted to the site because of the existence of artificial water bodies on site such as tailings and heap leach ponds. Since 2012, there have been 52 wildlife deaths on site (several species of birds, foxes and snakes). Only 10 of these were near cyanide facilities (e.g. TSF or dump leach ponds). TMLSA will expand their collision monitoring activities to cover the transmission line which extends from the Sondage wellfield to the mine site. If monitoring shows significant impacts, mitigation measures will be developed and included in the BRMP. A biodiversity monitoring and evaluation plan (BMEP) will be prepared by TMLSA and included in the BAP per ESAP #5a.

Ecosystem Services: According to TMLSA, the Tasiast mine represents 2.8% of the wadi catchment (Wadi Khatt Atoui) and the disturbed area is considerably less, about 0.6%.  TMLSA ensures that water is diverted away from the site so as to not impact surface water flows to natural areas.

At the time of the EIA completion, vegetation loss within the concession area was not identified to have a significant impact on ecosystems services. Some additional vegetation disturbance occurred due to the in-flux of artisanal miners in 2016. As discussed above, TMLSA has been cooperating with the government in the rehabilitation of areas disturbed by artisanal mining to minimize impacts on ecosystem services. TMLSA will include consideration of ecosystem services in the project influx management plan according to ESAP #1c. The updated BRMP and BMEP will also include specific mitigation and monitoring for impacts on Ecosystem Services per ESAP #5a and #5b.                                                  

Six archaeological studies have been undertaken at and in the vicinity of the project, and additional studies are undertaken as exploration continues outside of the Tasiast perimeter. The project area is characterized by three key types of archaeological sites: Neolithic settlements on old ogolian dunes, protohistoric tombs clustered on gravels and rocky ridges, and historic Islamic tombs. The surveys identified a total of 74 sites within the Tasiast project property. All of the archaeological sites identified at the mine are considered to be normal and typical of the region. None have been designated according to local, national or international standards in terms of their outstanding aesthetic, artistic, documentary, environmental, historic, scientific, social, or spiritual value.

TMLSA works with Mauritanian archaeologists from the Institute of Scientific Research (IMRS) to preserve and manage cultural heritage on site. TMLSA has an established cultural heritage management plan and chance finds procedure as required by PS8. Cultural sites with the potential to be disturbed are fenced to avoid accidental impact. When a site must be disturbed, IMRS is engaged to properly excavate and preserve any physical cultural resources. Training is provided to all staff (including contractor staff) regarding the importance of protecting archaeological sites and management of chance finds.                                                 

 External Communications: TMLSA conducted a stakeholder mapping and prepared a public consultation and disclosure plan (PCDP). Stakeholder mapping is regularly updated based on (i) consultations done during the EIA process; (ii) ongoing consultation carried out as part of its PCDP; and (iii) the experience of the government and community relations team.

There is continuous stakeholder consultation with the semi-nomadic residents and communities in the vicinity of the mine site. Stakeholder communications are carried out in Arabic and French. French is typically used for printed communications, official documents (such as the EIAs) and other correspondence with stakeholders. TMLSA also translates certain documents into Arabic, such as the non-technical summaries of public consultation documents, key messages on recruitment, and other community relations and corporate responsibility information. TMLSA uses “StakeTracker”, a stakeholder information management software, to maintain a comprehensive database of stakeholder contact information. The database is updated daily, and new stakeholders are added as they are identified. TMLSA’s community relations team has overall responsibility for all public stakeholder consultation and disclosure activities.

TMLSA conducted and continues to have extensive consultations and information dissemination activities with surrounding communities around the mine site.  In addition to public consultations associated with project permitting, there is ongoing engagement with key stakeholders to maintain open channels of communication. Overall, the public is generally supportive of the project. TMLSA engages with surrounding semi-nomadic communities and urban communities in Chami and other towns and villages. Community programs resulting from feedback received in stakeholder engagement are designed to a) support community priorities, and b) support groups and activities which play a key role in community cohesion (e.g., local institutions, women’s’ groups, community associations).

Stakeholder Engagement Plan: The company developed a stakeholder engagement plan (SEP) for the consultation process that occurred during the environmental assessment and permitting process (2011-2013). Public consultations were carried out as a requirement of the EIA process whereby the project is presented to the local authorities, local populations, governmental departments involved, NGOs and other relevant organizations. The EIA is made public and a register kept by the Hakem  and town Mayor to which the populations have access and are able to record any comments and suggestions for the project. The comments must be addressed in the EIA which is then reviewed by the Ministry of Environment and Sustainable Development. Where stakeholder engagement is the responsibility of the host government, TMLSA has collaborated with the responsible government agencies, to the extent permitted, to achieve outcomes that are consistent with the objectives of PS1. This has involved the Ministry of Social Affairs, and the Ministry of Health, as well as the gendarmerie, which is the competent security agency in the area. In addition, where government capacity is limited, TMLSA has played an active role in supporting the stakeholder engagement planning, implementation, and monitoring.

In conformance with company-wide procedures, stakeholder engagement is not limited to consultations associated with environmental assessment and permitting, but is an ongoing process that involves the following elements: stakeholder analysis and planning; disclosure and dissemination of information; consultation and participation; grievance mechanism; and ongoing reporting to affected communities. The nature, frequency, and level of effort of stakeholder engagement is proportional with the project’s risks and adverse impacts, and the project’s stage of development. The Plan has been adjusted to the project successive developments.  As part of IFC’s investment, TMSLA will update the project stakeholder engagement plan (SEP) to address stakeholder interests regarding potential impacts and/ or risks of mine activities on biodiversity, ecosystem services, vulnerable groups and communities per ESAP #1b.

The town of Chami was established by the government in 2013. The purpose of the town is to provide a base between Nouakchott and Nouadhibou for rural populations to receive services (health, education, etc.), and the government is actively encouraging people from the surrounding areas to relocate to the town. Unrelated to the project, Chami has recently experienced an influx from the artisanal mining activities. While the establishment and growth of Chami is not related to the project, TMLSA is working with the government to support sustainable development of the town through its corporate social responsibility programs.

External communications and grievance mechanisms: TMLSA grievance mechanism (managing community complaints) is in place and in line with IFC PS1. It is based on easy accessibility by communities, culturally adequate, assurance of confidentiality, clear and transparent processing, and a mechanism that is simple and easy to use. The grievance mechanism is scaled to the risks and adverse impacts of the project and has affected communities as its primary user. The mechanism seeks to resolve concerns promptly, using an understandable and transparent consultative process that is culturally appropriate and readily accessible, and at no cost and without retribution to the party that originated the issue or concern. The mechanism does not impede access to judicial or administrative remedies. The company informs the affected communities about the mechanism during routine stakeholder engagement. TMLSA implements and maintains a procedure for external communications that includes methods to receive and register external communications from the public; screen and assess the issues raised and determine how to address them; provides, tracks, and documents responses, if any; and adjusts the management program, as appropriate. In addition, TMLSA makes publicly available periodic reports on its social sustainability under its corporate responsibility report.                                                  

  Mr. Brahim M’Bareck

Vice President, External Relations

Tasiast Mauritanie Limited S.A.

ZRA 741, BP 5051

Nouakchott, Mauritanie