All land required for the Project is government owned and is not being used for any purpose and it is therefore expected that the Project will not result in impacts that must be managed in accordance with PS5. The Project will not result in impacts that must be managed in accordance with PS7 or PS8, given that neither indigenous peoples nor cultural heritage receptors have been identified within the Project’s area of influence.  

If IFC's investment proceeds, IFC will periodically review the Project's ongoing compliance with the Performance Standards.                              

 This is a Category A project as per IFC's Environmental and Social Sustainability Policy due to its potential significant adverse environmental or social risks and/or impacts that are diverse, irreversible, or unprecedented. 

Key environmental and social (E&S) aspects and potential risks associated with the Project are: (i) adequacy of E&S assessments in line with IFC Performance Standards; (ii) corporate and project-specific Environmental and Social Management System (ESMS); (iii) E&S oversight capacity during construction and operation of the mine; (iv) contractor management; (v) planned and unplanned labor influx; (vi) labor and working conditions; (vii) management of supply chain risks; (viii) use of natural resources; (ix) air emissions, including Greenhouse Gas Emissions (GHG) and air quality; (x) acid rock drainage and tailings management; (xi) community health and safety including transport and gender based violence and harassment (GBVH); (xii) biodiversity impacts; (xiii) cumulative impacts; and (xiv) stakeholder engagement and community grievance mechanism.                                                   

 PS 1 - Assessment and Management of Environmental and Social Risks and Impacts 

Policy 

The Company has adopted Barrick’s corporate E&S policies and developed an overarching policy framework to shape the Company’s management systems and procedures. Barrick’s E&S policies are publicly disclosed at www.barrick.com/English/sustainability/reports-and-policies/default.aspx and address, among other topics, Sustainable Development, Environmental and Biodiversity, Social Performance, Occupational Health and Safety (OHS), Human Rights and Tailings Management.      

 Identification of Risk and Impacts  

RDMC has conducted a comprehensive assessment of E&S risks and impacts as presented in the ESIAs that have been prepared for the Project. An early works ESIA was prepared by the Company and submitted to the environmental protection agency of Balochistan in February 2024 to obtain the necessary permits to start the preliminary works for the Project. The early works include the accommodation facilities for the full life of the Project, a water pipeline required to support the Project construction activities, a fence to be constructed along the boundary of the area for which RDMC holds surface rights, a water treatment plant, access roads to the water abstraction area, limited (15MW) power supply facilities, storage facilities for chemicals fuel and water and a wastewater treatment plant.  

A draft ESIA covering the full scope of the Project was submitted to the Pakistani and Balochi authorities in October 2024 and subsequently revised to take into consideration the progress on the engineering design of the facilities. The ESIA was prepared with due consideration of feedback obtained through engagement with stakeholders, which included four rounds of consultations with national, provincial, and district Government representatives, men and women from Project affected communities in the district and along the railway route, and with Civil Society Organizations (CSOs). The ESIA acknowledges the need to carry out additional studies concerning biodiversity and energy efficiency, which will be undertaken prior to start of construction and operation of the mine. An updated ESIA will be prepared by RDMC upon completion of the outstanding studies on power generation and biodiversity and to reflect any design changes that will take place in the near future, prior to commencement of the mining activities. 

Since 2023, the Company has voluntarily implemented several substantial local community development projects across the district focusing on education, healthcare access, water and environmental sustainability, food security, and economic growth. These projects are identified and executed in collaboration with Community Development Committees (CDCs) that act as advisory groups and consist of 95% elected community members. The Company’s Community Relations Officers provide general guidance and support to the CDCs.  In line with ESAP item #1, the Company will update their Community Development Committee Framework to include Terms of Reference so that each community project undergoes a comprehensive risk assessment that reflects relevant gender and vulnerability considerations. Monitoring and evaluation indicators will be defined along with a clear exit strategy, to effectively manage potential adverse risks and ensure compliance with national legislation and IFC Performance Standards. 

Management programs 

RDMC has in place a framework ESMS that includes a manual setting out: i) RDMC’s core E&S policies; ii) applicable local and international standards that the Project will comply with; iii) a list of Environmental and Social Management Plans (ESMPs); iv) details to implement the ESMS such as roles and responsibilities, training and communication, audit procedures, non-conformance and corrective action, and v) an Emergency Preparedness and Response Plan. 

The Environmental Management Plans that are listed in the ESMS are in various stages of development and address noise and vibration, air quality, hydrocarbon and hazardous materials, ground disturbance, waste management, emergency preparedness and response, biodiversity, and environmental inspections. The Social Management Plans address stakeholder engagement, OHS, service providers management, contractors’ management, employees’ handbook, security and gender.     

While a number of the above ESMPs are currently in ‘draft’ form, the structure and content is found to be partially aligned with the IFC PS, and any areas of improvement are described under the relevant sections of this document. All ESMPs will be regularly reviewed and updated as the Project develops. As per ESAP item #2, all draft plans will be finalized prior to start of construction, and the following plans will be prepared or updated to achieve full alignment with IFC Performance Standards, and the IFC Environmental Health and Safety (EHS) Guidelines (The IFC EHS guidelines that are applicable to the Reko Diq Project include the Environmental Health and Safety General Guidelines, the IFC’s EHS Guidelines for Mining (2007), the IFC’s EHS Guidelines for Thermal Power Plant and the IFC’s EHS Guidelines for Railways.):  

• Stakeholder Engagement Plan  

• Influx Management Plan 

• Road Transport Safety Plan 

• Water Management Plan (Construction phase) 

• Waste Management Plan 

• Construction Phase Biodiversity Management Plan  

• Worker Accommodation Management Plan 

• Contractor Management Standard (to include the need to inform contract workers of their terms and conditions and include GBVH prevention and management controls) 

• Labor and Working Conditions Monitoring Procedure  

• Worker Grievance Mechanism 

• Human Rights Management Plan 

• Supply Chain Management Plan 

• Gender Action Plan  

• Emergency Preparedness and Response Plan (to include climate related emergencies) 

• Environmental and Social Monitoring Plan, (including a detailed groundwater monitoring plan for the water abstraction area(s), the TSF and the WRD) 

• Community Grievance Mechanism (to include gender-based violence and harassment controls and child protection measures) 

• Occupational Health and Safety Management Plan (to include a Heat Stress Procedure and any additional measures deemed to be necessary as a result of a human health risk assessment) 

• Security Management Plan 

• Training and Development Procedure 

• Risk Management Procedure 

The following additional plans will also need to be in place prior to start of operation: 

• Mine Waste Management Plan  

• Water Management Plan (Operational and Closure Phase),  

• Operations-phase Biodiversity Management Plan (BMP), and 

• Mine Closure Plan. 

Organizational Capacity and Competency 

RDMC has in place competent resources within its Sustainability and Human Resources (HR) Department. RDMC acknowledges that resourcing will need to be expanded as the Project progresses and both the Head of Sustainability and the Head of Human Resources have a documented plan to address gaps in resourcing over the next 6-12 months, including resourcing needs to manage ESMPs that exist or are under preparation. These recruiting plans are appropriate to manage the E&S aspects of the Project.  

Emergency Preparedness and Response Plan (EPRP) 

RDMC has established an Emergency Preparedness and Response Plan. The plan describes designated roles and responsibilities for implementation and supervision, the minimum requirements for preparedness and response under different emergency scenarios, management and response training, emergency incident guides, etc. As per ESAP item #2, the plan will be updated to include climate related emergencies such as floods, extreme heat and sandstorms. A Medical Emergency Response Procedure is also in place that covers medical incident response and evacuation procedures, description of onsite and off-site medical facilities, transfer services to referral hospitals, international evacuation, etc.  

Monitoring and Review 

The Company’s ESMS manual includes adequate procedures to audit the Company’s and Contractors’ operations, to address non-conformances and to develop corrective actions. As per ESAP item #2, the Company will develop an Environmental and Social Monitoring Plan to complement the suite of ESMPs that have been drafted and are included in the framework ESMS. 

PS 2 – Labor and Working Conditions 

General  

As of March 2025, RDMC employed approximately 477 direct workers, with 86% being men and 14% women. The Project workforce will peak at approximately 10,000 people during the construction stage and the operational workforce is expected to comprise 6,400 people. 

RDMC has Human Resources (HR) policies that are broadly aligned with IFC PS2 requirements. They include details of the recruitment process, working conditions and written terms of employment, freedom of association, non-discrimination and equal opportunity, the definition of workplace harassment, the dismissal process, and a Code of Ethics and Human Rights Policy which reject child and forced labor. The working hours of all direct workers are recorded electronically and comply with national legislation.  

As per ESAP item #3, RDMC will develop and implement a Labor and Working Conditions Monitoring Procedure to monitor, assess and manage compliance risks related to national legislation and PS2 for both direct and contract workers. The Procedure will define the parameters to be monitored including the content of employment contracts, working hours, OHS controls, GBVH-related risks, the level of awareness and willingness of workers to use the worker grievance mechanism, freedom of association and collective bargaining activities, the support provided to vulnerable workers who may need assistance to understand their terms of employment due to a lack of literacy or other reason, and include a schedule of internal monitoring requirements including audits and inspections using checklists and worker interviews. Furthermore, the procedure will include a requirement for third party project labor audits to be conducted every quarter during construction and twice a year during operations. 

Worker’s Organizations 

RDMC’s HR policies recognize the right for a worker to form, or join, a worker organization and undertake collective bargaining activities and direct workers are informed of this right during their initial induction process.  

Non-discrimination and Equal Opportunity 

RDMC’s HR policies prohibit discrimination in the workforce and equal opportunity training is provided to all workers during their initial induction.  

Gender and Gender-Based Violence and Harassment (GBVH) 

Female participation in the workforce has steadily increased and to further promote gender equality, RDMC is implementing a Gender Action Plan (GAP) aimed at fostering greater inclusivity in the workplace and improving women's access to resources within local communities. In accordance with ESAP item #2 and #4, RDMC will conduct a Gender and GBVH Risk Assessment of RDMC’s operations and update the GAP using its findings. The assessment and updated GAP will apply to the direct and contracted workforce and cover gender risks associated with the Client’s local community development projects.  

Furthermore, as per ESAP item #5 RDMC will update its Human Resources policies to explicitly address and prohibit GBVH amongst the workforce and provide training to all workers on the GBVH and equal opportunity policies during their initial induction and annually thereafter. The updated Contractor Management Standard (ESAP item #2 and #6) will include the requirement for all contract workers to be provided with training on the prevention, management, and monitoring of GBVH in the workplace.  

Worker’s Grievance Mechanism 

RDMC has developed and implemented a Worker Grievance Mechanism. The mechanism includes an on-line and telephone-based reporting system managed by an independent third party, which allows anonymous grievances to be centrally recorded and tracked until they are resolved. Contract workers can, in principle, use this grievance mechanism, but awareness remains limited.  

As per ESAP item #7, RDMC will update its Worker Grievance Mechanism to include minimum requirements for all contractors to raise awareness of the worker grievance mechanism amongst their staff and encourage its use to report concerns promptly and anonymously if required. Additionally, multiple channels will be established for workers to raise a concern including in Urdu and Balochi, including a separate channel to raise sensitive cases (discrimination, harassment, GBVH), a central log of grievances will be maintained by RDMC that will reflect all grievances raised from the direct and contracted workforce, and those involved in managing grievances will be trained in the management of GBVH cases. Victims of GBVH in the workplace will be provided with support using trained personnel and referral pathways will be identified and accessible to all employees, including third-party workers.  

Worker Accommodation 

RDMC is currently providing accommodation to the on-site workforce at a main camp, and contractors have temporary camps at the locations where construction work is ongoing. The design and function of the main camp is generally aligned with the applicable IFC requirements. As per ESAP item #2, RDMC will prepare and implement a Worker Accommodation Management Plan that reflects IFC’s Guidance Note on Worker’s Accommodation: Processes and Standards, to improve living conditions at the contractor’s temporary camps and reduce overcrowding. The Worker Accommodation Management Plan will apply to both the direct and contracted workforce, include minimum standards for both temporary and permanent accommodation facilities, cover topics such as food safety, security, recreational facilities, and include a schedule of ongoing audits and inspections to provide high quality living conditions. 

Workers Engaged by Third Parties 

RDMC is currently using several third-party companies to provide security, services at the main camp, the physical expansion of the main camp and other construction works, and technical studies. All contractors are managed in accordance with the Company’s Contractor Management Standard although improvements are required in specific areas. RDMC’s HR policies apply to all contractors in accordance with the existing Supplier Code of Ethics, corporate Global Onboarding Standard, and Contractor Management Standard. To strengthen contractor management, as per ESAP item #6 RDMC will update the Standard to: 1) explicitly refer to HR policies including the Code of Ethics and Human Rights Policy covering Child Labor, Forced Labor, Freedom of Association and Collective Bargaining and Non-Discrimination and Equal Opportunity and GBVH prevention and management measures; 2) include details of the controls to be applied during the recruitment of local personnel that contractors use through third-party agencies; and (3) specify all working terms and conditions applicable to third-party project workers in line with national and PS 2 requirements. This will include provision of contracts, payslips, working hours, overtime, etc. These terms and conditions will be explained to workers using languages that they will understand and verbally using trusted representatives where literacy is a challenge. 

Supply Chain 

RDMC’s corporate Global Onboarding Standard includes a prohibition on the presence of child labor, forced labor, and poor life safety controls at the workplace of all suppliers of contractors, and of the suppliers used by these contractors. During construction, the solar panels will be procured along with general construction materials, by RDMC’s main contractors through their established suppliers. 

As per ESAP item #8, RDMC will prepare and implement a Supply Chain Management Plan applicable to all RDMC’s suppliers, requiring traceability of all procured goods and raw materials. RDMC will assess all suppliers for the presence of supply chain risks and will establish and maintain a supply chain map that reflects to the extent possible the contracted suppliers, based upon the services that they provide and materials they are providing. The supply chain map will subsequently be used to conduct a supplier risk assessment and develop a schedule of audits and inspections on high-risk suppliers. As per ESAP item #2, RDMC will update its Contractor Management Standard to also include controls on the risks to supply chain workers. 

Occupational Health & Safety 

RDMC has a Health and Safety Policy and an Occupational Health and Safety Management Plan that outlines OHS principles and emphasizes the importance of occupational safety and health commitments made by senior management. These commitments are actively promoted at all levels of the organization. The Company requires their contractors and sub-contractors to adhere to OHS controls aligned with Good International Industry Practice (GIIP) and develop and implement site-specific OHS plans and procedures. RDMC has OHS supervisors to provide oversight on their contractors and subcontractors, identify and centrally record deficiencies, and track corrective actions until resolved. All workers complete basic OHS training, have a medical fitness to work certificate, and receive medical screenings based on individual work functions. Supervisory staff and employees undertaking high-risk activities complete specific OHS training. RDMC’s OHS management system is broadly compliant with IFC requirements, and their OHS performance to date is higher than applicable industry benchmarks. 

As per ESAP item #2, RDMC will update its OHS management plan to include a Heat Stress Procedure, define OHS training requirements for specific roles more clearly in their Training and Development Procedure and Occupational Health and Safety Management Plan. 

In view of the potential exposure of workers to toxic and non-toxic particulate matter, at the workplace and at the accommodation camp, RDMC will carry out a human health risk assessment to determine potential adverse health effects to workers, based on the predicted level of exposure. Based on the findings of the assessment a determination will be made on the need increase the frequency and scope of workers’ health screenings and enhance mitigation measures, if required. All such measures will be reflected in the updated OHS management plan as per ESAP item #2. 

PS 3 – Resources Efficiency and Pollution Prevention 

Use of Natural Resources (Water) 

Mining operations, as well as water consumption for civil use, will require a water supply system that can deliver up to 50 liters/second (L/s), during the construction phase of the Project, increasing up to 800L/s during the first 6-9 years of operation of the mine. An aquifer (the Fan Sediments geological formation, or Northern Groundwater System), located approximately 70 km northwest of the mine site, has been identified as the primary water supply option for the Project. A key factor in selecting the Fan Sediments aquifer over other water supply options is because of its lower environmental and social sensitivities: the aquifer water is brackish to saline and therefore unfit for human consumption unless treated, is not used by communities and is not connected to wetlands or other ecological receptors. Several springs were identified in the Mirjawa Hills, located along the border between Pakistan and Iran to the west of the proposed borefield. The water feeding these springs originates from a different rock formation (fractured rocks rather than unconsolidated colluvial/fluvial sediments) and the springs are located at an elevation of approximately 500 m (or greater) above the groundwater level in the nearest Fan Sediments well. Consequently, the springs are unlikely to be impacted from the Project groundwater abstractions.  

Multiple field investigation programs have been completed for the Fan Sediments aquifer (including drilling and well completion, hydraulic testing, water level/quality monitoring, geophysical surveys and a hydro census), recharge mechanisms have been assessed, a robust conceptual hydrogeological model has been developed, and conservative numerical groundwater modelling has been completed. Based on the modelling results, the Company has determined that the Fan Sediments aquifer can supply water to the Project over the life of the mine, with negligible adverse environmental and social impacts. The model also predicts that transboundary depletion of groundwater levels may occur, although a significant amount of uncertainty remains regarding the timing, magnitude and extent of this potential impact. This uncertainty will remain until operational data is available from installed monitoring wells, which will subsequently allow model predictions to be confirmed or updated based on the comparison of actual observed data with previous model predicted results.  

The hydro census completed by RDMC identified no groundwater users in the predicted area of influence of the proposed groundwater abstraction system, except for a water abstraction well at the military (Frontier Corp’s) camp located close to the Afghanistan border. If the Frontier Corp’s camp well is negatively impacted, then the project will provide the camp with an alternative water supply, as per ESAP item #9.  

RDMC has committed to implementing a groundwater monitoring plan (included in the E&S monitoring plan as per ESAP item #2) that will enable the Company to re-calibrate its hydrogeological model and predictions of drawdown, detect any unplanned adverse effects associated with the long-term water abstractions and develop mitigation measures as part of their adaptive management procedure.  

While the Fan Sediments aquifer (Northern Groundwater System) is currently identified as the primary water supply option for the Project, RDMC is actively investigating alternative water supply options. Hydrogeological drilling/testing, geophysical surveys and groundwater modelling has previously been completed on a Southern Groundwater System, located approximately 100 km to the southeast of the mine site. An ongoing work program is focused on building a regional numerical groundwater model of the Southern Groundwater System, including an assessment of current and future water users, which will be used to assess the feasibility of reducing abstraction volumes from the Fan Sediments aquifer, obtain less saline water and reduce the potential to cause transboundary effects.  

Given that the proposed Fan Sediments water supply is a fossil resource and non-renewable over hundreds of years, efforts should be made to conserve water through process efficiency and recycling wherever feasible and cost effective to do so. Based on the current design, approximately 70% of the total water losses will occur through the TSF. There is a strong focus in the mining industry to develop and increase the scale of new technologies to improve the water efficiency of the tailings management. Alternative methods for dewatering tailings have been considered by RDMC, but they have been ruled out due to their unproven viability at the scale of the Reko Diq project. Over the life of the Project, the Company will monitor commercially available water saving technologies as they become available and will assess the viability of enhancing the technology to maximize water re-use and reduce consumption.  

Greenhouse Gas Emissions 

The ESIA incorporates a GHG emissions assessment, encompassing Scope 1, 2, and material Scope 3 emissions. The GHG assessment covers both the construction and operational phases. The initial three years are designated as the construction phase, while the subsequent thirty-nine (39) years reflect the operational phase. During the tenor of IFC’s investment (up to 15 years) the average annual Scope 1 and 2 emissions are estimated by IFC at approximately 850,000 tons of carbon dioxide equivalent (tCO2e), with approximately 75% attributable to direct emissions from the combustion of HFO and diesel fuel. The operation of a 150MW PV plant, which the Company plans to bring online shortly after commencement of operation, will achieve a yearly avoidance of GHG emissions of approximately 146,000 tCO2e. The overall net emissions during the tenor of IFC’s investment are estimated to be approximately 12.75 MtCO2e. 

Scope 3 emissions are mostly associated with transportation and further refining by off-takers of the concentrate produced by the Project and are estimated in the ESIA at approximately 3.0 million tCO2e per year (118.5 million tCO2e for the life of the mine).  

The assessment indicates that the Project’s operations could potentially increase Pakistan’s national GHG emissions by up to 0.26%. The ESIA acknowledges the Project’s contribution to global emissions while simultaneously highlighting its role in extracting copper, a metal critical for global electrification and renewable energy technologies, which could contribute to GHG emission reductions in other sectors. The ESIA describes several GHG emission reduction strategies currently being considered by RDMC, noting that some are constrained by technological availability and/or cost.  

In view of the significant residual GHG emissions associated with the Project’s power generation requirements, RDMC will develop a GHG Emissions Transition Plan, as per ESAP item #10, to gradually reduce its carbon footprint, with clear and timebound targets. The GHG Emissions Transition Plan will be finalized prior to financing and subject to approval by IFC and other Lenders.   

Non-GHG Emissions to Atmosphere  

The Project will generate emissions to the atmosphere from the following sources:  

• Airborne Particulate Matter will be generated through mining activities such as blasting and loading within the open mine pits, grinding of ore, from wind erosion of the TSF and WRD and through vehicular traffic on unpaved roads. Particulate Matter emissions will also be generated at the power plant. Emissions of airborne Particulate Matter will add to the naturally occurring windblown dust from the surrounding desert landscape.  

• Sulphur and Nitrogen oxides (SO2 and NOx) will be generated by the HFO power plant, and to a lesser extent, by mobile power generators and waste incinerators.  

Air quality impacts from the Project have been modelled in the ESIA using American Meteorological Society-Environmental Protection Agency Regulatory Model (AERMOD), an industry standard air dispersion modelling software package, to predict ground level concentrations of particulate matter (PM10 and PM2.5) and combustion gases (NOx, SO2) across the Project site, at the accommodation quarters, and at the closest communities. Modelling results indicate that elevated concentrations of airborne particulate matter can be expected throughout construction and over the operational life of the Project. However, the ESIA predicts that there will be no exceedances of either Pakistan Environmental Quality Standards (PEQS) or IFC EHS Guidelines at Humai or any other community beyond the surface rights area resulting from Project activities. RDMC will perform continuous online monitoring for PM10 and PM2.5 in Humai village, the closest community to the Project. A dust deposition gauge will also be installed at this location and dust fallout will be analyzed for a full suite of metals as a precautionary measure. Results of the air quality monitoring program will be communicated to local residents as part of the Stakeholder Engagement Plan (SEP). 

The ESIA predicts exceedances of both PEQS and IFC EHS Guidelines at the accommodation quarters under the scenarios modelled. The ESIA predicts that there will be exceedances of the IFC EHS Guideline 24-hour limit value of 50 micrograms/m3 for airborne concentrations of PM10 resulting from Project activities on 41 to 46 days of the year, in addition to 84 days per year when naturally occurring background conditions exceed this standard. The ESIA also predicts 12 to 21 annual exceedances of IFC EHS Guideline 24-hour values for PM2.5 at the accommodation quarters, in addition to 28 occurrences as a result of natural baseline conditions. 

RDMC has committed to undertake continuous ambient air quality monitoring and install dust deposit gauges at both the existing accommodation area close to the entrance gate and at the new accommodation quarters, implement an inspection program for door/window seals, install air filters rated for PM2.5 on air conditioning units and regularly replace the filters at onsite accommodation and offices. In addition, RDMC will carry out a human health risk assessment to verify the need for enhanced health screenings of the workforce and update the OHS management plan accordingly, as per ESAP item #2. 

Based on the modelling results, emissions of combustion gases from the power plant are not expected to lead to exceedance of ambient air quality standards as per the PEQS and IFC EHS Guidelines. As a result of the current configuration of the power plant and, due to the high Sulphur content of the fuel, the concentrations of pollutants at the stack are predicted to be in excess of the IFC EHS Guidelines. To overcome this, as per ESAP item #11, RDMC will assess the feasibility of procuring fuel oil with a low Sulphur content (<1%), as well as installing technology to achieve post combustion removal of particulate matter, NOx and SO2, to ensure compliance of the stack emissions with the IFC EHS Guidelines. RDMC’s Air Quality Management Plan includes provision for quarterly monitoring of air emissions from the HFO power plant, to verify compliance with the IFC EHS Guidelines during operation of the plant. As per ESAP item #2, the plan will be updated to include a method statement for emissions monitoring in line with the IFC EHS guidelines for Thermal Power Plants.  

Noise emissions 

As, reported in the ESIA baseline, ambient noise levels at the mine site were found to be significantly higher than the PEQS reference values, as a result of persistent windy conditions. Predicted noise levels that take into consideration construction and production activities were estimated to have an increase in sound pressure at the nearest receptors (accommodation camp and Humai) that would not be perceptible. Similarly, a comparison between baseline noise levels and predicted levels along the railway route and at the port facilities, does not indicate a significant change in the noise envelope at any of the studied receptors.   

Wastewater and Stormwater Runoff Management 

Wastewater will be generated at the accommodation facilities, at the processing plant and at the raw water treatment facility. All wastewater streams will be recycled after treatment, where necessary, into the processing plant water circuit, or used for dust suppression.  

Stormwater accumulating in the plant area, the mine pit and runoff from the TSF will be collected and conveyed to holding and settlement ponds for re-use in the mine’s processes and for dust control. The ponds will be designed to store 1:25 years storm events during the construction phase of the project and 1:100 years events during operation of the mine.    

General Waste Management  

The current waste management practices at the Reko Diq site involve the open dumping and burning of waste in an unlined pit located less than 1 km from the camp gate. The waste disposal pit, which has been in use since the early exploration phase, lacks essential control measures to prevent potential contamination of soil, water, and air, and presents health and safety risks to site workers. As part of the Construction works, RDMC will discontinue use of the existing waste disposal site and will rehabilitate the site to prevent air, soil and groundwater contamination, as per ESAP item #12.  

RDMC has developed a Waste Management Plan (WMP) that outlines a series of long-term management measures. The plan includes the establishment of a properly lined and managed waste disposal facility in compliance with the IFC Environmental, Health, and Safety (EHS) Guidelines for Waste Management Facilities. Additionally, RDMC intends to construct temporary waste storage facilities with adequate bunding, covering, and containment to mitigate potential environmental risks. 

As per ESAP item #13, RDMC will audit the waste handling and disposal processes of any third-party waste disposal facilities used by the Project and only use waste management providers that comply with GIIP. In the absence of suitable facilities, RDMC will install incineration facilities, implement waste segregation at source, and promote recycling of all materials for which there are opportunity for re-use. In the eventuality that incinerator facilities will be used RDMC will update the air quality impact assessment to consider the additional point source emissions to atmosphere.  

Groundwater contamination from Waste Rock 

The Company has carried out numerous sampling campaigns to characterize the geochemistry of the mine waste. The geochemical characterization indicates that most of the waste rock is acid generating, with some lithologies being more reactive, with a greater potential for acid drainage generation than others. The Company has developed a tailings management concept that foresees the storage of tailings on open ground. The storage areas would be unlined or lined depending on the grain size of the tailings and the potential for seepage of acid drainage into underlying groundwater aquifers.  

The ESIA states the low rainfall, depth to groundwater, current groundwater quality and lack of groundwater receptors means that no specific acid drainage management measurements are required, other than the monitoring of surface water runoff and groundwater seepage. A groundwater monitoring plan and a Mine Waste Management Plan will however be developed and implemented, as per ESAP item #2, to ensure early detection of adverse effects on underlying groundwater as a result of acid drainage from waste rock and unplanned failures of the lining system below the tailings.   

PS 4 – Community Health, Safety, and Security 

Workers Influx 

The Reko Diq operations will be the most significant economic activity in Balochistan, potentially leading to an influx of people seeking employment and improved economic opportunities in the region. Local communities have voiced concerns regarding potential risks to the cultural identity of the Baloch people, competition for employment opportunities, the introduction of alcohol into the region, and potential impacts on women’s privacy. Nok Kundi, the district’s largest settlement with a current estimated population of 15,000, located approximately 80 km southeast of the mine site, may experience the highest level of influx if such movement occurs. 

To manage this risk, the Project's construction and operational workforce, including contractors, will primarily be housed within the designated surface rights area which will include facilities capable of accommodating up to 6,400 construction workers. All recruitment will take place within individual communities and no hiring will occur at the mine itself. RDMC has already engaged with government agencies and community groups to develop strategies for addressing this challenge. As per ESAP item #2, RDMC will develop and implement an Influx Management Plan, incorporating feedback from relevant government authorities and communities. This plan will include monitoring activities and a commitment to developing Community Infrastructure Plans in areas where influx-related pressures are identified. 

Road and Railway Transport 

The use of the public road network to transport construction materials, mining equipment, and hazardous substances such as diesel, explosives used for mine blasting and HFO, and workers, will collectively generate community safety risks. Large trucks, some of which will carry oversized loads, will also be used to transport mining equipment from Port Qasim to the mine site. The existing public road network will be used from the port up to Nok Kundi, and the current access road to the mine site will be upgraded during the construction stage into a tar road. As per ESAP item #2, RDMC will develop and implement a Road Transport Safety Plan that reflects the outcome of a risk assessment, mitigation measures specific to each type of hazardous material transported, and a public road safety campaign amongst local communities intersected by the road network which includes direct engagement with children and other vulnerable people. The updated GAP will include control measures to mitigate potential gender risks to local women arising from the behavior of truck drivers transporting materials by road during the construction and operational stages of the project. 

The Project’s operations are expected to increase rail traffic by 8 train movements per day (4 up and 4 down the line). This is not expected to cause significant impacts on the north-south section of the rail between Port Qasim and Jacobabad, which already hosts a significant amount of rail traffic. However, these train movements represent a significant increase along the east-west corridor as current traffic amounts to 1-2 train movements per week.  

The use of the rail network will generate risks to community safety along the route, specifically at intersections between the railway and communities. Feedback during consultations with residents along the railway route raised concerns associated with the safety of people and livestock requesting additional control measures to be installed. The ESIA included a preliminary rail safety assessment which identified several locations where additional control measures are required.  

 As per ESAP item #14, RDMC will undertake an initial safety audit of the railway line in collaboration with Pakistan Railways (the government railway operator) and jointly develop measures that reduce community safety risks through a combination of engineering controls (e.g., safety barriers and warning signals) and public awareness raising in local communities. Specific attention will be given to raising awareness of railway risks to vulnerable people, such as children inside communities intersected by the railway. Thereafter, an annual audit in collaboration with Pakistan Railways will be undertaken to identify the need for additional controls that may be required in the future due to changes in land use adjacent to the line, or other reasons. 

 Security Personnel 

RDMC has contracted a private security firm to provide security personnel within the surface rights perimeter fence, and at vehicle entry and exit checkpoints to the main camp. RDMC also has a Memorandum of Understanding (MoU) with government-provided security force (the Government of Balochistan Levies and Government of Pakistan Frontier Corps) who are responsible for patrolling the outer area from the boundary fence. RDMC has implemented security policies and procedures that are generally aligned with the requirements of the Voluntary Principles on Security and Human Rights (VPSHR), such as the use of contractual clauses that protect human rights, and the private security provider has been trained in human rights. RDMC has a Human Rights Management Plan which includes control measures associated with the use of their public and private security providers. The Company’s Security Management Plan includes an assessment of regional risk sources but does not address the potential risks associated with inappropriate behavior by security personnel or the risk of GBVH towards local women. 

 As per ESAP item #2, RDMC will update their Human Rights Management Plan to include a requirement for independent, annual audits to be conducted on their security providers to check compliance with IFC PS4 and VPSHR requirements, and to provide training (addressing also GBVH to new security personnel who are rotating into the Project area for the first time, before they are deployed. As per ESAP item #2, RDMC will also update their Security Management Plan to include the risks associated with the use of security personnel and GBVH. 

PS 6 – Biodiversity Conservation and Sustainable Management of Living Natural Resources 

The Project is situated in the Registan-North Pakistan sandy desert ecoregion within the deserts and xeric shrublands biome. The ecoregion spans through southern Afghanistan, extreme eastern Iran, and part of northwest Pakistan, combining a series of demi-desert plant communities where trees are mostly absent. The mine site, borefield and facilities at Port Qasim do not overlap with Legally Protected or Internationally Recognized Areas. The existing road passes through Hazarganji Chiltan National Park Key Biodiversity Area (KBA)/Important Bird and Biodiversity Area (IBA) designated for raptors, and the existing railway passes through the legally protected Kinjhar (Kalri) Wildlife Sanctuary, which is also a designated Ramsar Site and a KBA/IBA characterized by migratory waterbirds and raptors.  

RDMC has commissioned independent consultants to carry out baseline biodiversity surveys (in 2022, 2023 and 2024) and identify risks and impacts on biodiversity values at the Project footprint. Surveys in 2024 were conducted also in the wider area specifically to gather further data on the distribution of threatened and restricted-range species. Types of Natural Habitat that overlap with the mine site and borefield are gravel plains, clayey plains, sandy plains/sand dunes, mountains and hills and dry streambeds. The road and railway pass through a mosaic of Natural and Modified Habitat. The facilities within Port Qasim are in converted coastal and terrestrial habitats, where the marine section of the port partially overlaps with a mangrove habitat.  

Priority biodiversity values associated with the Project include the natural gravel plain, clayey plain, and sandy plains/sand dune habitats, as well as threatened plants, restricted-range amphibians and reptiles, threatened migratory birds including raptors, and threatened mammals. Of these, the Goitered Gazelle (IUCN Red List – Vulnerable, Pakistan Red List – Critically Endangered), Sand Cat (IUCN Red List – Least Concern, Pakistan National Red List – Critically Endangered), Dead Sea Sparrow (IUCN Red List – Least Concern), Baloch Green Toad (IUCN Red List – Near Threatened), Alcock’s Toad-headed Agama (IUCN Red List – Least Concern), and three reptile species (Cyrtopodion sp., Eremian sp., and Eremias cf. scropta), which are tentatively new to science, are Critical Habitat biodiversity values. IFC Natural Habitat No Net Loss (NNL) requirements will apply to all priority biodiversity values, while Critical Habitat Net Gain (NG) requirements will apply to the above-listed species.   

RDMC will implement a comprehensive biodiversity risk management program to avoid and minimize risks. Based on available data and information, most of the Critical Habitat and priority biodiversity values likely to be impacted by the project do not overlap with the mine or borefield but occur in the broader area of the project footprint.  The Company will be conducting additional biodiversity surveys in April and May 2025, targeting Critical Habitat and priority biodiversity values, and taxonomic studies to clarify the statuses of the three tentatively new reptile species. As indicated in ESAP item #15, outcomes of these surveys and studies will inform additional assessments to supplement the ESIA, which will include a residual impact assessment for areas of Natural Habitat, Critical Habitat and priority biodiversity values. These assessments will include a demonstration of areas of Natural and Critical Habitat (including quantification and mapping), where avoidance, minimization and restoration measures will be implemented, as feasible, in line with the Project’s mitigation strategy.  

The Company will develop and implement a construction-phase Biodiversity Management Plan (BMP), which will be informed by additional surveys and set forth mitigation measures to avoid and minimize impacts on Natural Habitat, Critical Habitat and priority biodiversity values that overlap with the mine site, borefield, road, railway and Port Qasim facilities (ESAP item #16). The construction-phase BMP will incorporate a Ground Disturbance Approval Procedure to identify biodiversity values at construction areas prior to land clearance and implement relevant mitigation measures, where applicable. RDMC will appoint a specialized team of experts, who will be responsible for the surveys, and provide advice for management, and reporting of mitigation activities relating to the Project.  

 To minimize risk of collision and electrocution on bird species using the airspace that are subject to NNL objectives, mitigation measures will be implemented along the entire OHTL using best available technology (i.e., bird flight diverters and insulators). A bird-safe design will also be incorporated in placing the pylons. Along the road and railway, and at Port Qasim, NNL objectives will be achieved through implementation of GIIP captured in Project management plans and procedures, including implementation of erosion control, waste and overall construction management measures.  

In the operations phase of the Project, the Company will implement a post-construction fatality monitoring (PCFM) program based on GIIP to monitor bird flight activity along high-risk areas for bird species, assess effectiveness of mitigation, and identify any further measures to be taken in line with an adaptive management approach (ESAP item #17). The Company will contract an internationally recognized and specialized consultancy to design and develop the PCFM program in collaboration with a local consultancy. The program will take place for at least a two-year period, but the actual timeframe of the PCFM program may have to be revised based on fatality results. 

 In addition to the PCFM program, per ESAP item #18, RDMC will develop and implement an operations-phase BMP to identify measures to meet Natural Habitat NNL objectives. The operations-phase BMP will include a Habitat Management Program for the gravel plain, clayey plain, and sandy plains/sand dune habitats and associated priority biodiversity values. The Habitat Management Program will be informed by the residual impact assessment that will be conducted following the additional surveys, include recommendations for restoration measures in areas of Natural and Critical Habitat, where feasible, and opportunities to maintain biodiversity on-site to achieve NNL objectives. A qualified expert with international experience will be contracted to develop the Habitat Management Program.  

 With respect to the Critical Habitat biodiversity values, per ESAP item #19, RDMC will develop a Biodiversity Action Plan (BAP) and Biodiversity Monitoring and Evaluation Plan (BMEP). The BAP will include a loss/gain assessment informed by available data and the additional surveys/studies being conducted in 2025 and will define species-specific actions to meet NG objectives. In line with PS6, the BAP will also define requirements for offset measures and additional conservation programs to address residual impacts on Natural Habitat, Critical Habitat and priority biodiversity values, as identified. The ESIA sets forth a set of criteria for offset design and framework for offset planning and implementation, which the Company is committed to follow to meet offset requirements to be determined through the residual impact assessment. To address any offset requirement, RDMC will contract qualified experts with international experience on biodiversity offsets to: (i) define potential offset options, (ii) conduct an offset feasibility study, and (iii) develop and monitor implementation of a Biodiversity Offset Management Plan (BOMP), aiming to deliver measurable conservation outcomes. In support of this effort, RDMC (and Company’s consultants) engaged with local and national authorities, as well as IUCN Species Survival Commission (SSC) specialist groups to gather further information on biodiversity values, obtain their views on Project-related risks. The BAP will make further provisions for continued engagement and consultation with relevant stakeholders to inform the project’s mitigation strategy such as consulting with the Ornithological Society of Pakistan and BirdLife International. To inform potential additional conservation actions with respect to the areas traversed by the road and the railway, the Company will explore opportunities to support conservation programs within the Hazarganji Chiltan National Park and Kinjhar (Kalri) Wildlife Sanctuary KBAs.                                                   

 Stakeholder engagement has been undertaken by RDMC’s ESIA consultant during preparation of the Early Works ESIA and the ESIA prepared for the Project. Four rounds of consultations have been undertaken with national, provincial, and district Government representatives, men and women from Project affected communities in the district and along the railway route, and with Civil Society Organizations (CSOs). A SEP has been prepared that describes the future activities during the construction and operational stages of the Project.   

The SEP reflects the outcome of a detailed stakeholder identification and analysis activity and a review of the outcome of previous engagements to identify topics of interest including local employment opportunities, operation of the CDCs, concerns over women’s privacy from potential influx, and community risks from the use of the railway. Several Civil Society Organizations (CSO) have been engaged with concerning potential impacts to biodiversity and community developmental needs.  

Various methods have been used to disclose information associated with the Project and raise awareness of the community grievance mechanism, including posters and leaflets translated into Balochi and Urdu, and RDMC’s Community Relations Officers (CROs) have raised awareness of a community grievance mechanism. Whilst the engagement with community stakeholders has been extensive, further consultation and information disclosure activities are required to help manage key sources of E&S risk associated with use of the public road, railway network, transport of hazardous materials by road, potential influx that may occur and impacts on community infrastructure and women’s privacy, gender issues covering local recruitment, awareness of the community grievance mechanism, and GBVH. 

As per ESAP item #2, RDMC will update and implement the SEP to meet PS1 requirements regarding the disclosure of information and consultation concerning the management of potential E&S risks and impacts, and undertake engagements separately with women and vulnerable people, and CSOs. The SEP includes a commitment for ongoing reporting to affected communities and describes the formal community grievance mechanism that includes methods to: a) communicate the grievance mechanism to stakeholders; b) receive and register complaints including anonymous complaints; c) screen, assess and address issues raised; d) document and track grievances; e) provide feedback to stakeholders on grievance mechanism results; and f) monitor and adjust the grievance management process using KPIs.  

RDMC has implemented a community grievance mechanism and raises awareness among local people through a combination of distributed company documentation and verbal communication via their network of CROs. Grievances are centrally recorded and tracked until resolution. In accordance with ESAP item #2, RDMC will conduct awareness-raising campaigns on the grievance mechanism for local communities, including separate sessions for women. Additionally, CROs will be trained on the content of the GAP to ensure both male and female CROs can effectively discuss gender risks and opportunities related to the project with local communities.                                                   

Ashley Price, RDMC Head of Sustainability

Reko Diq Mining Company (Private) Limited

Tenancy 05, 06 & 07, 20th Floor, Sky Tower A – Block 5 West Wing, Dolmen City, Abdul Sattar Edhi Avenue, Karachi, Pakistan

 Project website can be found at: https://www.barrick.com/English/operations/reko-diq/default.aspx