PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources is not applicable as the project does not entail the cultivation of living natural resources. IBAT confirmed that the site is not located in a Key Biodiversity Area; although project activities will entail conversion of natural habitat, IBAT did not flag impacted flora as species of concern; while IBAT suggests the potential presence of avian species of concern, habitat features of importance (for example, nesting or roost trees) are sufficiently widespread across the project area that it is unlikely that the impacted site itself would be considered to be Critical Habitat.

PS7: Indigenous Peoples is not applicable as no Indigenous Peoples have been identified within the company’s operational footprint. PS8: Cultural Heritage is not applicable as there are no cultural sites within the company’s operational footprint and no cultural heritage has been identified.

    This proposed investment is expected to have limited environmental and social impacts, which are expected to be site-specific and none is expected to be significant. Those impacts can be avoided or mitigated by adhering to recognized performance standards, procedures, guidelines and design criteria as described in the following sections. Thus, this is a Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability. The project is designed to avoid, minimize and manage E&S risks and impacts of the company’s operations in compliance with Malian legal and regulatory requirements, IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Construction Materials Extraction, and Cement and Lime Manufacturing) Environmental, Health and Safety (EHS) Guidelines.

The key E&S issues associated with this investment include the: i) adequate assessment of the project’s impacts; ii) need for enhancing the existing EHS management systems as well as CCM’s capacity to ensure effective implementation thereof; iii) labor and working conditions including occupational health and safety; iv) management emissions and wastes; and vi) focused and sustained stakeholder engagement, notably with the communities in the vicinity of the quarry.

   E&S Assessment and Management System

Given the company’s extensive prior experience in the mining sector and awareness of the importance of this, CCM developed elements of a strategy and framework for addressing environmental, health, and safety (EHS) issues from the start of the company operations. This approach is reflected in a number of different procedures related to different aspects of CCM operations (the quarry and the plant). The company plans to obtain ISO 14001 and OHSAS 18001 certifications.

Policy

CCM has developed a vision for good environmental, health, and safety practices; however, this has not been articulated into a clearly defined policy and has not been broadly disseminated across company operations. Per ESAP action #1, CCM will articulate an overarching policy statement on the company’s commitment to good environmental, health, and safety practices across operations.

Identification of Risks and Impacts

In accordance with Malian law, Africa Resources completed separate Environmental and Social Impact Assessments (ESIAs), dated September 2009, for the plant site and the Djikoye quarry. Africa Resources was granted environmental permits by the Ministry of the Environment and Sanitation on 16 November 2009; and it received on 22 March 2010 the authorization to mine an 84-square kilometer parcel where the Djikoye quarry and plant are located. The operating rights of both the plant and the quarry were subsequently attributed to CCM in September 2011. CCM was also granted on 30 December 2011 the authorization to extend the concession to a total surface area of 138-square kilometer to encompass the Gouroundape quarry. In March 2010, CCM was granted a 4-year, renewable permit for operations of the plant until depletion of raw materials; this was modified in 2014 to be valid for 10 years and was renewed again in March 2020 for 4 years.

Per ESAP action #2, CCM will undertake an environmental review of all current operations as well as activities contemplated under the project against the requirements of IFC’s Performance Standards (PSs) and applicable World Bank Group (WBG) General and sector-specific (Construction Materials Extraction, and Cement and Lime Manufacturing) Environmental, Health and Safety (EHS) Guidelines and shall develop a corrective action plan as needed. These corrective action plans will build upon the mitigation measures proposed in the ESIA documents, as well as other applicable legal requirements.

Management Programs 

As part of the ESIAs, CCM is required to implement general corrective measures for managing environmental and social aspects of operations in order to reduce impacts related to ambient air emissions, noise, handling and storage of used oils, land conversion and revegetation, traffic safety, occupational health and safety, and security measures related to blasting and fire prevention. While there are some efforts to implement some of these corrective measures in the form of procedures and work instructions that were developed (described in further detail in each of the sections below), there appears to be little evidence that this is being done as part of a management framework approach. Based on the findings of the environmental review and per ESAP #2, CCM will be required to develop additional management plans or to further expand the scope of the corrective measures listed in the ESIAs.

Organizational Capacity and Competency

CCM has designated an EHS coordinator with primary oversight for implementation of the EHS framework on a day-to-day-basis with the support of 3 temporary staff for the time being, but CCM plans to create 1 or 2 term positions as the overall EHS framework is enhanced. The EHS coordinator reports to the operations manager who in turn reports to the general director. Furthermore, the company benefits from the expertise of a qualified external consultant who was instrumental in helping CCM develop its EHS framework.

During IFC’s site visit and based on discussions with key individuals, staff seemed somewhat knowledgeable of EHS aspects of operations, but ongoing training is necessary. As per ESAP action #3, CCM shall formally retain the services of the existing qualified external consultant to help the company strengthen its EHS framework per the ESAP and support company personnel in enhancing their skills for implementing the tasks as reflected in the EHS framework, including day-to-day oversight of activities and reporting related to the development and implementation of the EHS management system at the plant and quarry.

Emergency Preparedness and Response

As part of the EHS framework, CCM has developed elements of an emergency preparedness and response plan that describe the need for identifying incidents to which the company is exposed to (for example, accidents, fire and explosion, natural catastrophes, and accidental spills) and the need to develop the necessary capacity for responding to these including undertaking similar exercises. There are instructions for responding to a fire, accident, and natural catastrophe. Staff have received training on the use of fire extinguishers and simulations have been undertaken but documentation to demonstrate this is not systematically kept nor is there a documented process in place for identifying and remedying gaps in implementation.

CCM maintains a detailed list of fire extinguishers across its operations, which reflects location, regular inspections in terms of integrity of the fire extinguisher, accessibility, and last inspection by an external service provider (undertaken every 6 months although there is no contract in place for doing so). The company is planning to request that the local fire authorities provide training on First Aid and handling emergencies.

CCM will update its emergency procedures to expand its scope to include both the plant and the Gouroundape quarry, per ESAP action #4. This would also include a more detailed review of potential emergency scenarios impacting both the plant and the quarry, and a response plan.

Monitoring and Review

There is a procedure that describes the need for monitoring EHS aspects of operations, but it does not further state which parameters to monitor and at what frequency. CCM tracks separately various EHS aspects of operations (such as fuel and water consumption, waste generation, and accidents/incidents), which are reported in a consolidated format (loosely based on GRI Reporting Guidelines) to the authorities on an annual basis. There currently is no documented procedure for monitoring and reviewing environmental, health, and safety parameters to assess the effectiveness of efforts to manage identified environmental, health, and safety risks across overall company operations; this is therefore required as per ESAP action #1.

   CCM currently has a total of 137 employees, made up of direct workers (21) and contracted workers (116). Of the direct workers, 5 are employed at the quarry, 4 at the plant, and 12 are employed at the administrative offices in Bamako, of which four are women. The contracted workers are employed at the plant (55 of which one is a woman), the quarry (31), and as unarmed security guards (30) across both the plant and the quarry. Moving forward, CCM plans to create approximately 10 additional positions to support the commercial aspects of operations. All recruitment is managed by the HR manager in Bamako.

For contracted staff, CCM has outsourced the human resources management responsibilities to S.D.S. (Société Diarra Services), an external employment agency (common in Mali), in charge of the recruitment process (following a preferential local hiring policy), which provides written contracts between the employees (the 116 contractors) and S.D.S., handles payroll, and registers workers with relevant government authorities (for social benefits) upon completion of a 3-months trial period in compliance with the national law; this is not the case for daily workers as they typically stay much less than 3 months.

CCM pays S.D.S. a fee for the provision of the administration of human resources and contract management. CCM defines the hiring needs and desired skill profile and is directly involved in the recruitment and selection of staff; this includes reviewing the contracts prepared by S.D.S. Once hired, CCM employees and S.D.S. workers work side by side at the plant and in the quarry; there is no distinction in the way they are treated at work, working conditions, and terms of employment (other than the administration of the contract and handling of payroll which is done by S.D.S.). As S.D.S. workers become more skilled, they may be hired directly by CCM as more skilled staff. Under the contract with CCM, S.D.S. is required to comply with the national labor code; however, the contract does not explicitly state that workers have to comply with CCM’s policies, such as on occupational health and safety, which would need to be revised per ESAP action #6.

Human Resources Policies and Procedures

CCM has internal procedures on human resources, which describes basic terms of employment (including working hours and rest time; over time, annual and sick leave and gazetted holidays; minimum wages), leave policy, equal employment opportunity, rules against discrimination and sexual harassment, and disciplinary action. CCM ensures no hiring of people under the age of 18 by checking documents, but this is not clearly included as a specific policy or procedure. CCM’s human resources policies and procedures also apply to all staff employed through S.D.S. S.D.S has also developed an internal code of conduct that specifically applies to the workers at the CCM plant and quarry, which addresses occupational health and safety, prohibited behaviors, disciplinary action, and harassment.

Per ESAP action #5, CCM will commission an external consultant to conduct a labor audit focusing on contractor management; how worker dismissals, resignations, and the strike were handled at the time of salary arrears; and a review of all salaries and benefits as well as related HR procedures. Based on the audit findings, CCM will agree with IFC on a timebound plan for implementing the findings of the labor audit.

CCM and S.D.S. need to strengthen its existing HR regulations and develop a comprehensive HR manual, including any additional findings of the labor audit per ESAP action #6. The policy and procedures need to include the following: staff responsibilities, rights, and benefits; equality of treatment; freedom of association; prohibition of forced and child labor; termination of contract and dismissal; right for collective bargaining; workers representation; and mechanism for workers’ grievances accessible to all workers (permanent, temporary, and seasonal) for all types of grievances including sexual harassment and in an anonymous and confidential manner. The HR policy and procedures are to be accessible and clearly communicated to all workers (in French and local language as necessary) to ensure that employees understand their rights under national labor and employment law.

Working Conditions and Terms of Employment

All CCM employees have written contracts, which are open-ended (CDI, Contrat à Durée Indéterminée) and in compliance with the national labor code. CCM has signed a collective bargaining agreement (last revised in 2016) with the national union (UNTM, Union Nationale des Travailleurs du Mali), which applies to all workers hired through S.D.S. Under CCM’s contract with S.D.S., S.D.S. provides term contracts (CDD, Contrat à Durée Déterminée) and daily contracts of which 66 are term and 3 are currently on a 3-months trial period before being offered a term contract, and 47 are daily. Daily workers are hired on an “as needed basis” (for example, assistant operators, security, and EHS) and may be converted into term contracts with S.D.S. depending on need. S.D.S. makes all the necessary deductions from worker salaries for the national pension (ITS, Impôt et Traitement sur Salaire), social security (INPS, Institut National de Prévoyance Sociale), and medical insurance (AMO, Assurance Medicale Obligtoire).

CCM has accumulated arrears for payment of salaries and social security contributions to direct workers and contracted workers due to financial difficulties. During this period, CCM management supported workers through paying part of their salaries, providing food, and financial support during family emergencies. As per ESAP action #7 CCM will pay all workers and contractors (with the exception of top CCM management) all outstanding amounts. In addition, as per ESAP action #7, CCM will enter into an agreement with the Government of Mali to contribute the pending social security payments and compensate workers and contractors for social security support that they were entitled to. 

At the time of hiring, CCM and S.D.S. ask workers about their payment expectations and adjust this in accordance with their capabilities and based on the salary scale (dated 2009) stated in the collective bargaining agreement.

Working hours differ by function. The kiln is operated in 3 rotating shifts and is operational 24 hours a day, 7 days a week. Shift work averages 35 hours a week; workers are not required to work overtime and no premium is paid for that part of the shift, which coincides with the night time as allowed under the national labor code. Shifts rotate through daytime and nighttime shifts but there is no extra compensation for doing so, which is consistent with the national labor code. The quarry operates 5 days per week during daytime hours only, with shifts working a total of 40 hours per week in compliance with the national labor code. All workers get a 2-hour break over lunchtime.

Every year, a representative from the Mali Labor inspectorate comes to inspect the plant (last date of visit is June 2019) to assess aspects related to worker accidents and safe working conditions. The inspectorate does not provide CCM with a report and CCM reported that to date, the company has not received any negative findings. Transport is provided to all workers between the plant and the surrounding villages, which benefits about 100 workers each day. There is an on-site canteen at the plant, which is accessible to all workers and provides free meals (except to daily workers who follow a different schedule than other plant workers); however, most workers prefer to bring their own lunch or go back to their village, which is close by. Worker facilities at the plant entail basic changing rooms with lockers and showers, where they are provided with the necessary protective equipment and blocks of toilets and showers.

Workers’ Organizations

Workers select 7 representative delegates (only among S.D.S. workers, representing different departments) and decide every year if elections are needed to change the delegates. Daily workers are also represented by the elected delegates. Delegates participate in discussions regarding primarily the dates of salary payments and in the context of the arrears, the arrangements that CCM made to pay for the meals of impacted workers. Each delegate is responsible for sharing information with workers about the outcomes of discussions. Currently, none of the S.D.S. workers are members of a union (UNTM, Union Nationale des Travailleurs du Mali) but they are free to join the union if they so wish.

Grievance Mechanism

CCM does not have a formal written process to resolve workers’ grievances. In practice, a worker submits a grievance to the HR representative at the plant. A worker can also submit a grievance directly to CCM plant management, either orally or written on a designated grievance card, which is available at the office. Both the HR representative on-site as well as the HR manager in Bamako are notified of all grievances, which are discussed with the S.D.S. representative in Selinkenyi; if the worker (or the grievance) entails a worker contracted through S.D.S., the S.D.S. representative will need to follow up on the grievance. At the time of recruitment, all workers (both CCM and S.D.S.) are provided with the phone number of the HR manager and HR representative in case they wish to voice a complaint directly, which would be handle in confidence. Neither CCM nor S.D.S. currently keep a written register of complaints and how these were handled. CCM will need to design and implement a grievance mechanism accessible to all workers regardless of their types of contracts to ensure that a formal grievance process is followed as per ESAP action #8. This will need to include i) procedures for documenting, managing, and monitoring their resolution; ii) involvement at appropriate level of management (including designated staff and accountability); iii) clear and timely management of grievances; iv) allow for anonymous complaints including sexual harassment to be raised in confidentiality and without fear of retribution; and v) inform access to other judicial and regulatory mechanisms available under the Mali law for workers. The mechanism shall be accessible by all workers, including daily workers. CCM shall inform all workers about the objectives and procedures of the workers’ grievance mechanism as well as inform all workers about the grievance mechanism and how it operates. CCM will need to keep a written register of all grievances and how these have been resolved.

Non-discrimination and Equal Opportunity

CCM has a policy for equal employment opportunity and non-discrimination. The recruitment of unskilled workers from local villages is prioritized before advertising positions further away, in the town of Kayes. Currently, a total of 63 workers come from the 3 surrounding villages. In terms of the recruitment of women, the company has tried to recruit women in the past but given the regional context, their husbands opposed to this practice and the women had to quit. Nonetheless, the company is open to hiring women who are interested in doing the type of work being offered at the plant and the quarry, though given the physical nature of the tasks involved, women are typically not interested.

Occupational Health and Safety

The EHS coordinator is responsible for oversight of workers’ health and safety at CCM with the assistance of 3 other staff (daily workers). There is an EHS committee on site, which is made up of 10 members and meets on a regular basis to implement activities to reduce risks in the workplace and analyze accident reports; however, there is no procedure that describes the function of this committee. The company does not currently have an up-to-date occupational health and safety (OHS) policy and there is no systematic process for analyzing OHS risks to workers across CCM operations.

There is a procedure for managing the issuance and use of Personal Protective Equipment (PPE) and a different procedure describes which PPE needs to be worn in different areas of operation as a function of the risk. The kiln manufacturer has provided a safety manual including general safety rules and a general risk analysis, but this is in English and there is no indication that this has been incorporated into a CCM EHS procedure. The area near the kiln is equipped with an eye-wash and shower station in case a worker comes into contact with live lime. However, there are no work instructions by function describing the risks, preventive measures, and what to do in case of an accident.

CCM has a procedure for providing training on a variety of EHS topics such as awareness raising on HIV/AIDS, malaria, bush fires as well as environmental issues such as waste management, air emissions, community relations, and accidents or any other topics that are selected on a monthly basis (for example, the need for taking regular breaks and hydrating during the hottest months). However, the company was not able to share a comprehensive annual training plan designed to address the risks associated with its operations nor provide an indication on the number of trainings and attendees that had been provided on various topics.

As per ESAP action #9, CCM shall undertake a job risk analysis across all company operations, develop the necessary procedures reflecting the OHS measures in place, including implementation of a training plan.

There is no procedure that outlines the steps to follow in case of an accident or injury; however, there is a comprehensive template to use for documenting the occurrence of an injury including identification of root causes and corrective actions; and all accidents are tracked in a log book. Since 2016, CCM has experienced 8 work-related accidents; in 2019, there were 2 accidents with lost time (7 days total) and 5 near misses.

First Aid kits are available in key locations and the EHS coordinator has been trained on First Aid. First Aid training was provided internally but there is no record to document this. Currently, there is no on-site infirmary but CCM is in the process of setting up an infirmary, which should be completed in 1-2 months. The company has already reached out to a female nurse who lives in a village nearby; she is expected to be on site 6 days a week. The company has a contract with a clinic in Selinkenyi to which CCM transports the injured or ill person in the event of an accident. All workers (both CCM and S.D.S. including daily workers) are eligible to receive health care through this clinic for work-related accidents. The company sometimes also pays for health care provided to family members of workers. CCM maintains a register of all medical issues treated (malaria, diarrhea, cuts, and accidents) and every worker undergoes a medical visit before starting work at CCM. Furthermore, as required by the national social security (INPS, Institut National de Prevoyance Sociale), workers are required to undergo a medical visit (pulmonary exam) on an annual basis but this was not done in 2019 due to budget constraints.

   Energy Consumption

The primary energy needs are for fueling the kiln to achieve the 1,100 degrees Celsius required to convert limestone into lime (calcination). CCM uses heavy fuel oil (HFO) as the primary combustible but since 2017, the company has been working with a supplier specializing in recycling used fuels, oils, and lubricants, to produce a cheaper heat source for the kiln, at an equivalent quality to HFO.

The remainder of operations at the plant are currently powered by electricity generated from two on-site generators (650 kVa each, operated in parallel) and one 350-kVa, all of which are powered by diesel and regularly maintained. The company is in discussions to install 2-MW of solar power to partially cover the energy needs of the existing operation and future expansion. Equipment at the quarry (such as crushers, drills, shovels, and loaders) is powered by diesel.

The plant is currently not connected to the national power grid. However, the national transmission line is pending extension by the authorities along the main road at which point the plant will be able to connect to it directly, without any additional transmission line. The quarry, at a distance of 1 km to the main road, would also be able to connect to it through an extension of the transmission line passing through the company’s property. It is anticipated that this would be completed by the end of 2020. Per the law in Mali, any transmission line has to be built along an existing road to benefit as many villages as possible and within the existing road right-of-way. No concerns are anticipated regarding the displacement of people especially given the rural nature of the location.

Water Consumption

CCM sources water from an on-site borehole at the plant and at the Djikoye quarry (another borehole is pending at the Gouroundape quarry). As the manufacturing process is predominantly dry, water is used primarily for dust suppression as well as for drinking water (also provided to the local community), in the kitchen, sanitary facilities for workers and temporary housing for up to 15 staff staying on-site or visiting. CCM has a written procedure for testing well-water quality; water is treated on-site and analyzed on-site every week and on a monthly basis for E. coli; the water quality was reported to comply with the potable water standards of the WHO (but this could not be confirmed). Water consumption is monitored on an annual basis and in 2019, the total water consumption was about 5,500 cubic meters.

Air Emissions and Ambient Air Quality

The main source of air emissions across CCM’s operations are from the HFO/used oil-fired kiln, operation of the generators, and operation of diesel-powered vehicles and equipment at the quarry. CCM has a maintenance plan for the kiln and generators. The only air treatment related to the exhaust from the kiln is the capture of particulate matter through a baghouse. Per ESAP action #2, as part of the environmental review, CCM shall conduct air emissions measurements for the kiln stack and compare parameters with the WBG EHS Guidelines for Cement and Lime Manufacturing for air emission levels (Table 2); if measurements exceed WBG limits, CCM will assess necessary corrective measures.

Estimated GHG emissions are calculated as 24,984 tons of carbon dioxide equivalent per annum for projected production at full capacity by 2023, which is below the IFC’s reporting threshold.

At the plant, dust is generated at different points of the process (loading/unloading lime, lime crushing, movement by conveyor belts, and filling operations); for the most parts, these processes are enclosed and where loading/unloading of material occurs, air extraction systems are in place to remove dust. As the yard is unpaved, water is periodically sprinkled to suppress the generation of dust. At the quarry, dust is generated during digging and excavating activities, crushing, and loading/unloading of material. Workers are equipped with PPE at both sites.

Wastewater Treatment

The manufacturing process is predominantly dry; limited volumes of wastewater are generated from on-site sanitation blocks (including the dormitory) and the kitchen and collected in 4 on-site septic tanks. Wastewater is decanted and treated with lime prior to discharge to a planted area on-site (vegetables and mango trees). CCM has a written procedure for managing wastewater, which states that sludge from the septic tanks is emptied on a regular basis by an external service provider. CCM tracks the volume of wastewater generated annually, which is also included in the report submitted to the national authorities (see section above on Monitoring and Review) but has not tested the quality of wastewater.

The site is inclined and naturally drains any storm water run-off into the planted area at the bottom of the slope. From there, stormwater drains outside the factory wall into a ditch that drains into a natural seasonal water way that flows under the main road.

Solid Waste Management

CCM generates the following waste streams in small quantities: defective bags (used for packaging lime), used tires, empty metal cylinders, packaging waste (cardboard, textile, paper, and plastic), and household waste. CCM has a written waste management procedure and tracks the volume of waste generated annually, which is also included in the report submitted to the national authorities (see section above on Monitoring and Review). According to the waste management procedure, solid waste also includes soiled rags (used to wipe oil and fuel); CCM disposes of the waste on a daily basis at a designated site near the plant, where it is incinerated; there is no regulatory requirement in Mali governing this. Limited quantities of hazardous wastes are also generated (see section below).

Hazardous Materials Management

CCM uses the following hazardous materials in its operations: i) Heavy Fuel Oil (HFO) and recycled oil depending on availability (for the kiln) and ii) diesel (for generators and to power vehicles/equipment). CCM no longer stores explosives (detonators and ammonium nitrate) for use at the quarries; instead, deliveries are scheduled for same day-use. Fuel consumption in 2019 related to operation of the kiln was 1,750,000 liters of recycled oil (no HFO was used given high levels of impurities in locally sourced material) and 450,000 liters of diesel for powering the generators and vehicles/equipment. At full capacity, fuel consumption is expected to be 6,500,000 liters of recycled oil/HFO and 925,000 liters of diesel.

HFO and recycled oil are each stored in a 500-cubic meter above ground storage tank; there is also an 80-cubic meter above ground storage tank to which HFO or recycled oil are pumped for direct use in the kiln (corresponding to an approximately 1-week supply)—all are surrounding by secondary containment structures. HFO and recycled oil are refilled by tanker truck as required; the area comprises a concrete slab. Diesel is stored in a 55,000-liter above ground storage tank, which is surrounded by a secondary containment structure. There is an on-site pump for dispensing diesel to vehicles; although the pump is covered by a small roof and is built on a concrete slab, the area immediately in front of it where the fueling takes place is not.

The company currently owns 4 trucks, 1 minibus, and 4 vehicles (cars), which are all maintained on site in a dedicated workshop area. For the most part, maintenance such as oil changes is undertaken over bare ground, and used oil, oil filters, and batteries are temporarily stored on site prior to removal by an external service provider who in turn sells the waste products to locals for reuse.

The integrity of the 500-cubic meter storage tanks was verified by an external service provider on August 17, 2016 and certified for the next 10 years. At the time of the site visit, stains from spills were noted around the tanker truck refilling area, the pump, the workshop, 25-cubic meter used oil storage tank and used oil filter drainage site, and the 80-cubic meter above ground storage tank, which also lacked the necessary secondary containment. CCM has a work instruction for managing a fuel spill including the need for completing an environmental incident form but there was no evidence of spill clean-up supplies nor signage directing workers what to do. The company will be required to develop a Hazardous Materials Management Plan including work instructions for spill prevention and clean up per ESAP action #10.

   The closest villages are located approximately 1 km to the northeast (Karaga) and 2 km to the southwest (Dibatoumania); there are no immediate neighbors adjacent to the plant. The Djikoye quarry (currently not exploited) is located 4 km from the village of Djikoye; the Gouroundape quarry is located 1.5 km from the village of Gouroundape. Thus, neither the plant nor the quarry is expected to pose a direct risk to communities due to company operations. The plant is built at the highest point of a sloping site such that all rain water drains downhill, away from buildings toward a drainage ditch running below the main road. This is effective to prevent the accumulation of rain water and consequent flooding of the facility.

Community Health and Safety

Neither the concession nor the site of the quarries is fenced off. Prior to CCM operations, the neighboring community would collect wood and let their livestock graze on parts of the land. This practice still continues today and CCM allows it as long community members do not cut down live trees (prohibited by law) or set bush fires (to promote the growth of grass and new shoots as livestock fodder). The company meets on a regular basis with the village chiefs to provide awareness training.

CCM undertakes explosion activities as necessary and at the start of quarrying to break up larger blocks, which are then further worked on with hydraulic hammers. The company has a written explosion procedure, but this does not include information regarding the steps taken to ensure that community members are warned ahead of time of the scheduled explosion and are kept at a distance. Nonetheless, in practice, CCM informs the community 48 hours ahead of time of a scheduled explosion.

Transportation Safety

Vehicle traffic between the quarry and the plant entails use of the existing national road, passing the villages of Karaga, Selinkegny, and Gouroundape, and is limited to CCM’s trucks (currently 2 but pending the acquisition of 2 more with the proposed expansion) that go back and forth to transport raw material and CCM’s bus, used to transport workers. CCM currently does not have a policy or procedure in place for ensuring the safe operation of vehicles (for example, screening drivers and providing formal training on safe driving) nor for documenting incidents and accidents involving road traffic. However, truck drivers transporting material from the quarry to the plant are told to slow down, not use their horn, and not stop on the way.

The transport of finished product from the plant is subcontracted and currently averages approximately 4 trucks per day or 125 trucks per month, depending on volume of product sold. CCM does not have a fixed contract with any subcontractor in order to have the flexibility to negotiate the best rate; however, the company generally tends to work with the same 2-3 drivers as their trucks meet the strict security requirements for accessing the mining sites of CCM’s clients. 

Security

The plant is surrounded by a 2.5-meter high, concrete perimeter wall and CCM employs 29 unarmed guards (subcontracted through S.D.S. and all members of the local community) at both the plant and the quarries, on site 24 hours per day, 7 days per week. They are responsible for access control and verification of people entering the site. CCM currently does not have a written security procedure to clarify the roles and responsibilities regarding actions for different scenarios such as a worker strike, social conflict with the surrounding community, or other disruptions and ensure the community is aware of the community grievance mechanism and can raise issues about security through that. The company will be required to develop a security procedure to apply to both the plant and the quarry per ESAP action #11.

   Stakeholder Engagement Plan

In the context of the ESIA for the Djikoye quarry, a public consultation was held on August 29, 2009 in the village of Djikoye to provide an overview of the project, collect concerns from the community, and discuss proposed solutions for addressing these. The meeting was chaired by the mayor of the Commune of Bafoulabe and was attended by members of the community, the village chief and his advisors, the Commune advisors, and the national directorate for sanitation and pollution control. Issues raised related to local employment opportunities, limiting environmental impacts and protection measures for the village, creating income-generating activities for women, and constructing key infrastructure (school and health clinic).

CCM developed a community development plan, which was agreed to by the community on 2 February 2015 and entailed the construction of 3 classrooms in the villages of Djikoye and Karaga; however, as the company experienced financial difficulties, this has experienced significant delays. Nonetheless, CCM has supported the community by providing assistance in the form of earthwork activities, donating school kits, contributions to the construction of a mosque, and planting acacia trees for income-generating activities.

CCM is required to continue undertaking stakeholder consultations and engagement activities throughout the implementation of the project. Per ESAP action #12, CCM will designate staff with oversight of stakeholder engagement activities and develop a procedure to: i) undertake and record stakeholder engagement activities including meeting minutes; and ii) determine how to address concerns.

External Communications and Grievance Mechanisms

Residents of the surrounding community know that they can approach any of the guards at the plant or at the quarry if they need to voice a complaint about any aspects of operations or the behavior of a company worker. Depending on the nature of the complaint, the guard then facilitates a meeting with the appropriate person at CCM. The company keeps a register of complaints received and how these are resolved, which is signed by all those impacted at the time of closure. CCM currently does not have a written procedure outlining this process. As per ESAP action #12, CCM will need to develop a written procedure to include the steps for receiving in a confidential and anonymous manner, processing, documenting, and addressing external grievances including those related to sexual harassment and gender-based violence or security, from all members of the community; the timeframe for doing so; and the assigned responsibilities for doing so.  

    Contact Person: Aminata Coumba Diallo

Company Name: CCM

Address: Faladiè Sema, Rue 841 porte 202, Bamako – BP 366

Email: diallomimi@chauxdumali.net

Phone: +22391889833