Based on IFC’s review and the ESIA, no risks and adverse impacts of the project that need to be managed consistent with PS7 (Indigenous Peoples) and PS8 (Cultural Heritage) were identified at this stage.                                                   

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability, as it is expected to have limited adverse environmental or social risks and/ or impacts that are limited in scale, few in number, generally site-specific and readily addressed through mitigation measures, by adhering to good international industry practice (GIIP) procedures, guidelines and design criteria, as described in the following sections. The project will use GIIP, meeting requirements established under the applicable WBG Guidelines.

Key risks and impacts of the project include limited scale: economic displacement of informal users of forest land, grazing land, tourist guides and fisherfolk households; biodiversity impacts including impact on natural habitat values (1ha); shadow flicker impacts on 199 houses; and environmental impacts associated with noise, erosion, waste and hazardous material management, occupational and community health and safety, labor working conditions, and transportation safety.                                                   

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

TAB does not yet have in place an Environmental and Social Management System (ESMS). The Company will draw upon the ESMS of the Sponsor (Total Energies & Adaro Energy) to develop a project specific ESMS. Further, as part of the ESIA for the project, an outline of a construction and operation stage environment and social management plan (ESMP) has been prepared. TAB will, as mentioned at ESAP # 1, prior to start of construction: (a) develop and implement a detailed construction stage ESMS including an ESMP taking into account the risks and impacts identified in the ESIA and aligned with IFC Performance Standards (PSs) and applicable and relevant aspects of WBG EHS Guidelines; and (b) contractually require the EPC and construction contractors to adopt and implement the company’s ESMS and the ESMP.  Further, as mentioned at ESAP # 2, TAB will: (a) develop and implement an operations phase ESMS that meets IFC PS requirements and applicable and relevant aspects of WBG EHS Guidelines; and (b) contractually require the O&M contractor to implement the company’s ESMS or have in place an ESMS that is aligned with TAB’s ESMS. The ESMS will among other aspects include standard operating procedures: to manage and monitor operation stage risks and impacts identified in the ESIA and any other risks identified subsequently; for responsibility allocation and resourcing; training and capacity building; contractor management; internal and third-party audits; and monitoring, reporting and management review. [The project equipment transport, civil construction, and operation and maintenance (O&M) contractors have in place an environment, health and safety management system certified to ISO 14001 and/or ISO 45001.]

The company will as part of the construction stage ESMS (see ESAP # 1) and O&M stage ESMS (see ESAP # 2) develop and implement a contractor management procedure in line with IFC’s GPN on Managing Contractor’s E&S Performance to incorporate E&S processes and requirements into contractor short-listing, procurement and bidding, proposal review, contract preparation, contractor oversight and performance evaluation.

A PS aligned ESIA has been prepared by a third party commissioned by the company covering risks and impacts for both construction and operations stage. An alternative analysis was undertaken including for the no project alternative, alternate site selection, alternate site selection for jetty, alternate overhead transmission line alignment, alternate turbine capacity and alternate source of power. The selected alternatives included: higher capacity turbines to reduce project footprint; jetty location furthest from the project site to avoid significant road/bridge upgrades and minimize impact on communities; and a transmission line alignment to minimize land acquisition, vegetation clearance and to avoid cultural property. The assessment has determined that cumulative impacts are not expected. Climate risk assessment (including transition and physical risks) has identified low to medium risks of flooding (relevant to substation), landslides (on the ridge where turbines are located), extreme heat, extreme precipitation, strong winds, lightning and wildfires. TAB, as mentioned at ESAP # 3, will put in place plans and procedures to address these risks as part of the ESMP, ESMS and the emergency response plan (for the construction and operations stage).

While TAB does not currently have in place an E&S organization, as mentioned at ESAP # 4, the company will: (a) put in place an E&S organization including at least two appropriately qualified environment, health and safety (EHS) staff and one community relations staff; and (b) require the construction and O&M contractors to deploy appropriately qualified EHS staff during construction and operation respectively. Further, as mentioned in ESAP # 1 & # 2, the ESMP and ESMS will have procedures for: training and capacity building of all employees including contract workers during construction and operation; and (b) periodic internal and third- party audits, monitoring, reporting and management review.

PS 2: Labor and Working Conditions

The company will, as mentioned at ESAP # 5, develop and implement HR policies and procedures in line with the Indonesian regulations, TotalEnergies & Adaro’s’s policies and IFC PS2 provisions. Accordingly, the company’s HR manual will include policies and procedures among others: compliance with applicable labor laws; working conditions and terms of employment; prohibition of child labor, forced labor; equal opportunity and non- discrimination; employee complaints/grievance mechanism; and prohibition/prevention and redress of Gender Based Violence and Harassment (GBVH), retrenchment and workers organization. The company will implement the HR manual and communicate it to employees through training including at new employee induction. TAB will require the EPC and O&M contractors to also adhere to these policies and inform its own employees. In addition, the company will  develop an enforceable worker Code of Conduct (CoC) which among others will include access to policies and procedures related to GM and GBVH and disciplinary measures in particular for GBVH related cases. Worker (CoC) will be included as part of the contractor agreement to be implemented by EPC and O&M contractor). The EPC and O&M contractors and the workers will need to sign the worker CoC and will be trained on the CoC provisions, including disciplinary measures in case of non-compliance especially in instances pertaining to GBVH related practices.

There are no plans to undertake retrenchment though the company will, as part of the HR policies articulate a retrenchment policy that meets PS2 provision and is applicable for any collective dismissals. The company will, as part of the HR manual, commit to complying with relevant laws related to employees/workers union/organization. The company will not discourage union formation and will ensure that workers engaged in union formation or collective bargaining do not face discrimination, harassment, or any reprisal risk.

The workforce required for jetty construction will be up to 50 persons, primarily unskilled individuals. For the remaining component up to 400 contract workers during peak construction period will be involved.   It is expected that about 50 to 70 percent of the workforce will be employed by the EPC contractors from the nearby villages as possible, with a further geographical radius to Pelaihari and Banjarmasin locations to fulfill resourcing and procurement requirements. The company will, as part of the construction stage ESMP (ESAP #1 ) and operational stage ESMS (ESAP #2), implement contractor management procedures (and refer to IFC Good Practice Note on Managing Contractors E&S Performance, including: (i) a compliance checklist against the applicable legal requirements and IFC Performance Standards; (ii) OHS performance criteria as part of contractor qualification and selection; (iii) a workers Code of Conduct and (iv) EHS monitoring and audit procedures to obtain assurance on contractor compliance with relevant requirements; and (v)   alignment of worker accommodation (if any) with IFC-EBRD guidance; implementation of grievance mechanism; protection of the work force, including engagement of migrant workers, if any, on substantially equivalent terms as non-migrant workers performing same work.

TAB does not foresee the need to set up separate workers accommodation on the project site. Workers coming from outside the project area will be accommodated by the EPC contractor in the nearby areas in rented houses. However, should accommodation be provided to the workers, onsite or offsite, the company will ensure that the EPC contractor develops and implements construction labor camp guidelines in accordance with PS2 provisions on workers’ accommodation (including IFC/ EBRD guidelines on worker accommodation- https://www.ifc.org/en/insights-reports/2000/publications-gpn-workersaccommodation) covering both their own and their sub-contractors worker including addressing risk related to GBVH either to contract workers mobilized for the project or GBVH risks to community because of the security/contract workers. Company’s own staff totaling up to 10 persons during operations stage will be provided accommodation near the project site (in one of villages or in Pelaihari), possibly near the PLN substation, which will serve as operations control center including direct employee accommodation.

The company will, as part of its HR Policy and Procedures Manual (ESAP #5), develop, communicate and establish a formal employee grievance mechanism (GM) in line with PS2 provisions which amongst other will include: provision for disclosure of the GM; multiple grievance reporting channels including provision for anonymous reporting without reprisal risk; grievance committee to handle grievances; detailed time bound steps to be taken upon receipt of a complaint; include an appeals procedure; and procedures for documentation, analysis and reporting of grievances received and resolved to senior management. Further, the company will as part of the ESMS implementation, maintain grievance records and will monitor redress of grievances. With respect to their contractors, including EPC sub-contractors and O&M stage contractors, TAB will ensure that a formal GM is accessible to all contract workers and will require regular reporting from its contractors on the implementation of the mechanism. The contract workers will have access to company’s GM, in case not satisfied with the EPC or O&M contractors GM.

As part of ESAP #5, The company will develop and implement appropriate GBVH procedures (including policy, grievance mechanism to specifically deal with sexual harassment cases) pertaining to prevention of sexual harassment in line with- “Guidelines for Preventing and Handling Sexual Violence in the Workplace (the 2023 Guidelines)” and IFC PS 2 requirements. The company will set up a task force and include representatives of both the management and employees (or labor union). The company will arrange regular training for all employees, particularly those in remote facilities/ locations ensuring that employees know about and have access to confidential reporting channels. The GBVH procedure will be designed and implemented to ensure: (a) multiple channels for registering grievances including anonymous reporting; (b) adequate disclosure of GBVH grievance mechanism; (c) system in place for receiving, acknowledging, tracking and addressing the grievances aligned with survivor centric approach; (d) training of staffs receiving and handling grievances including staff undertaking investigation; (e) training to staff and contractors as employees, codes of conduct, disciplinary measures, potential actions around worker/community interaction etc. The GBVH procedure scope will include the grievances received from the community related to actions of the contract workers, security personnel (hired by the company or EPC/ O&M contractor) and others.

The company will develop its own OHS management system as part of ESAP #1 and ESAP #2. However, as part of ESAP #6, the company will contractually require the EPC and O&M contractors to develop and implement a comprehensive site-specific occupational health and safety (OHS) management system including plans and procedures appropriate to their scope of work, and applicable to all the workers including sub- contractors'. The OHS plan for the EPC contractor and O&M contractor will be approved by TAB mandatorily before mobilization. The EPC and O&M contactor will implement an OHS management system along with the worker code of conduct including worker’s access to GM for working conditions, GBVH at work site, including worker accommodation (as applicable).

The company will source WTG parts and BESS from OEM suppliers. As part of ESAP # 7, the company will put in place a supply chain management system, which will include: (a) a supplier selection procedure aimed at screening any instances of child labour, forced labour and significant safety issues; b) a supplier mapping procedure in place to identify direct suppliers and sub suppliers; (c) Procurement policy and supplier code of conduct that explicitly prohibit child labor and forced labor and includes significant safety issues requirements for workers in the supply chain; (d) provision for contractual clauses in written agreements with suppliers requiring compliance with the procurement policy and the code of conduct; and (e) a process for supplier engagement, remedy or disengagement in case of non-compliance with the code of conduct. Additionally, the company will retain records of supplier screening and ongoing monitoring activities in line with the code of conduct.

PS 3: Resource Efficiency and Pollution Prevention

This is a renewable energy project. The GhG emission avoidance for the project is estimated at 132,700 tCO2e per annum.

The total water consumption for the construction phase is estimated at approximately 6,331 m3. Approximately 25% of the water may be sourced by well installed within the laydown area. However, the water for concrete production will be trucked in. Water consumption during operation phase is expected to be about 1.25 m3/day and will be sourced from a well or from a licensed vendor of potable water.

The environmental impacts from construction activities for the project are those typical of most construction sites and include: dust generation; soil erosion and sediment loading increases; noise; waste management; potential spills of hazardous and other material; construction debris disposal; domestic solid waste and wastewater; increased water usage; and construction vehicle traffic. TAB will develop and implement a ESMP (ESAP # 1), which will include specific mitigation measures, as per commitments in the ESIA, applicable aspects of IFC PSs and applicable and relevant aspects of WBG EHS Guidelines and the EPC contractors will be required to adopt and implement this ESMP.  

As part of the noise assessment for the ESIA it was determined that baseline day and nighttime noise levels at the nearest receptors are within national and WBG EHS Guidelines. Noise modeling for operation stage indicates that sensitive receptors are exposed to noise levels that are within WBG EHS Guideline limits requiring no further mitigation action.

Domestic wastewater is the primary wastewater stream during operation phase, which will be treated in a septic tank. Wastes (hazardous and non-hazardous) generated in the operation phase will be disposed to authorized entities. TAB will as part of the ESMS (ESAP # 2) implement procedures to segregate, label and store hazardous wastes within contained areas and dispose them through authorized entities for treatment, reuse/recycling or disposal. TAB will also as part of the ESMS, implement duty of care procedures to confirm that the hazardous material / waste operators are transporting, handling, storing, treating and disposing of the materials / wastes appropriately in line with GIIP.

Construction of the sand / rock stacked jetty (i.e rock gabions walling) which is planned to be built for transport of project equipment may result in minor shoreline changes. TAB will, as mentioned at ESAP #8, undertake a sediment transport and shoreline change modeling and build mitigation measures into the jetty design based on the findings of the modeling. Further, the jetty construction and O&M will impact marine water and sediment quality. The Company will, as part of the ESMP (ESAP # 1) include measures to mitigate any adverse impact in accordance with IMO requirements.

PS 4: Community Health, Safety and Security

Though the actual construction activities for the turbines will be on the ridge, the project construction activities may cause nuisance to communities from: traffic disruptions; noise; dust; illumination; drainage disruptions; and potential for impact on groundwater or surface water. The company will, as part of the ESMP (ESAP # 1), require the contractors to implement procedures to address community health and safety risks. Further, to address traffic safety risks, as part of the ESMP, (ESAP # 1), the Company will develop a Traffic Safety Plan, both for the traffic movement on the road as well as to get the WTG parts to the top of the ridge, which the construction contractors will be required to adhere to. In addition, for the movement of barges for jetty construction and for movement of WTG parts, the company will develop a marine transport plan (ESAP#1), which will include a separate traffic safety plan for the barge movement around jetty area and timely communication with the fisherfolk (in 2 villages) regarding movement of the barges.

There are three rest shelters built by grazers (who use the ridge top for cattle grazing during wet season), which are within the required safety setback zone as per GIIP is 278.25 m. The Company will, as mentioned at ESAP # 9, undertake a full inventory of all temporary rest shelters and other structures at the ridge and enter into a formal signed agreement with the owners of these shelters/structures to relocate outside safety setback area and significant impact zone.

Small groups of about 15 tourists visit and camp on the ridge occasionally. They will be exposed to noise levels exceeding WBG EHS Guideline limits for residential areas and safety risks if they camp within safety setback zone. The Company will, as mentioned at ESAP # 10, mark out on the ground the safety setback area around each turbine and require that patrol guards stop tourists from setting up camp within the safety setback zone.

Shadow Flicker modeling has predicted that 199 structures will experience the impact for durations exceeding WBG EHS guideline limits. It is expected that upon ground survey, the number of affected structures will decrease further due to direction of openings in the structures with respect to turbine alignment, presence of existing vegetative screens and presence of other physical barriers. No physical relocation of structures is envisaged due to shadow flicker. The Company will, as mentioned at ESAP # 11, complete a ground truthing survey of each of the 199 houses/receptors impacted by shadow flicker, identify all houses/receptors where impacts will exceed WBG EHS Guideline values and agree mitigation options for each such household that might include localized screening/ planting or moving the direction of windows/doors where feasible or provision of blinds etc..

Electromagnetic field (EMF) for 150kv overhead transmission line was estimated. Based on modelling, the calculated maximum EMF is below allowable public exposure limits in accordance with WBG EHS Guidelines.

The installation of wind turbines and movement of large construction vehicles for the project are identified as sources of visual interferences on the local landscape and existing elements. It is predicted that visual impact is negligible to moderate. Accordingly, additional mitigation measures are proposed including: good housekeeping of construction sites, stakeholder engagement to enhance landscape value and ensuring identical turbines in case of turbine replacement in the O&M phase.

Construction contractors will use groundwater for construction. Its use is not expected to adversely impact groundwater availability as assessed in the ESIA. Further, the construction and O&M contractors will implement measures described above in the construction stage ESMP and O&M stage ESMS to mitigate risk of ground water contamination.

It is expected that 50-70% of the workers will be from local villages as possible, with a further geographical radius to Pelaihari and Banjarmasin locations to fulfill resourcing and procurement requirements, therefore significant influx of workers is not expected. TAB does not expect to set up workers accommodations. However, to minimize the risk of increased incidence of communicable diseases the Company will as part of ESMP (ESAP # 1) put in place measures for health check-up of all migrant workers and provision of access to medical assistance/facility.

The facility will have its own security workers (contracted through third parties having proper licenses) who are unarmed and also trained in emergency response. TAB will, as mentioned at ESAP#1and 2, adopt a security management plan, in accordance with IFC PS 4. This plan will be guided by the principles of proportionality and good international practice and include procedures to assess risks posed by security arrangements including GBVH risk and adopt identified mitigations into a plan which among others will include: ensure hiring, rules of conduct, training, equipping, and monitoring of security personnel; provide for background verification on security personnel's individual character with no incidents of past abuses; train security personnel to exhibit appropriate conduct towards workers and neighboring communities including awareness on GBVH issues; train security personnel to manage mock sessions of labor unrest and protests; and to receive and resolve grievances about the security arrangements and acts of security personnel.

PS 5: Land Acquisition and Involuntary Resettlement

No physical displacement will result from project activities. TAB through the technical design process and ESIA, explored alternate options to minimize land acquisition and vegetation clearance; and minimize disturbance on agricultural activities. The total land requirement for the project (excluding RoW) is around 34 ha, which includes ~26 ha of government land (including the forest land) and ~8 ha of private land. The total number of land owners currently identified by the project to sell/ lease land/ provide right of way for OTL is around 77. The private land will be purchased on a willing buyer willing seller basis, while some land will be leased temporarily during construction stage. The company has not yet started negotiation with the land-owners though private land survey including drone survey of the land parcels is completed. The Company will engage a third-party valuer to establish land value and then start negotiation. The company has continued socialization activity through a local NGO.

The land take for the WTG will result in a limited and temporary involuntary displacement of 49 farmers who graze their cattle during wet season on the ridge where the WTGs will be installed. However, the grazing activity can be re-established once construction is complete, and turbines are operational estimated to be within 24 months from start of project construction. The farmers also have access to other areas for grazing and usually take the cattle back to the villages during dry seasons. Reportedly, about 5 persons take advantage from time to time to act as guides for tourists visiting the ridgetop and earn up to 2-3 USD per trip. While trekking activity may continue, the area on the ridge top will become restricted due to safety buffer requirements. There are 3-4 trekking routes identified to the top of the ridge, none of which will be impacted by the project. Socialization activity by the company however indicates that camping activity had stopped post covid; this will be confirmed as part of future engagements with local community members by the company. The areas used for NTFP collection or farming activity on the government/ forest land will not be impacted because of the project land take.

The jetty will be developed on government land and has a small footprint including a temporary exclusion area (up to 650 m x 650 m) along a 10 km coastline where shoreline fishing occurs, with temporary and short-term impact, if any, on a few fisherfolks. The project activity will be restricted to 3-4 months for jetty construction and movement of barges for stone transport and 2-3 months for transport of WTG part. The shoreline fishing is undertaken by around 130 fisherfolk from 2 villages (located at a distance of 3 km and 7 km from the jetty location). Though limited fishing happens across the year, near shore fishing and offshore fishing are mostly undertaken in the peak fishing season (peak fishing season is April to August, while less fishing happens from August to March) around 5 miles to 12 miles or further away. The fisherfolks can move along the coastline freely to other areas around the jetty while construction is underway. Construction of the Jetty will be over a period of 3-4 months and require about 80 barge trips and is planned during the non-fishing season to minimize impact on fishing activity of the fisherfolk. Once constructed, the jetty will be used for receiving WTG parts over a period of 3 months (a total of about 15 Barge trips) which will also to the extent possible be planned in the non-fishing season. Current requirement is to remove the jetty after construction is completed though client intends to talk to the government and seek permission to leave the jetty as it is so that it may be used by the government or others such as for fisherfolks from the community, if approved by the Government.

The company has prepared a Livelihood Restoration Framework (LRF): documenting the avoidance measures followed; likely impacts due to land take for the project; estimated number of affected households (HHs); and entitlement principles in line with IFC PS 5 requirements, to address impacts on the land users including grazers, tourist guides, fisherfolk. The LRF also includes documentation of the process to be followed for the willing buyer willing seller process for land purchase and lease process as per IFC PS 5 requirements. The company will, as mentioned at ESAP # 12, undertake 100 percent census survey and asset inventory for all the affected HHs and develop a livelihood restoration plan (LRP) in line with the LRF and PS5. The LRP will clearly document whether the land purchase process followed by TAB meets the willing buyer willing seller agreement as per PS 5 clearly establishing, among others (a) voluntary transaction by the seller; (b) no option of compulsory acquisition by TAB; (c) land markets or other opportunities for the productive investment of the sales income exist; (d) the transaction took place with the seller’s informed consent; and (e) the seller was provided with fair compensation based on prevailing market values. Should the census survey and asset inventory survey indicate impacts not already factored in the LRF, the entitlement principles will be updated as part of the final LRP. The LRF is based on detailed consultations across the project area with multiple stakeholders including fisherfolk, plantation owners, informal land users. As part of the LRP preparation, the company will undertake disclosure of entitlements matrix, grievance mechanism, eligibility criteria, incorporation of stakeholder feedback in the final LRP, and entitlements. The LRP will have a grievance mechanism to address specific concerns about compensation and rehabilitation measures raised by displaced persons in a timely fashion, including a recourse mechanism designed to resolve disputes in an impartial manner. The company has started socialization through a third-party NGO including detailed engagement undertaken as part of the ESIA preparation. The feedback from the socialization program and ESIA have been used to develop the stakeholder engagement plan including grievance mechanism (discussed further in the SEP section).

TAB will, as per ESAP # 13, appoint a specialized agency for LRP implementation and will monitor the LRP implementation (preferably through a third party), providing bi-annual monitoring reports to the lenders during the construction phase, and annual reports during operations (as part of annual E&S monitoring reporting). The monitoring report among others, will include documentation of the willing Buyer Willing Seller process for private land, progress on LRP implementation as per IFC PS 5 requirements and effectiveness of the GM. Within 2 years of start of LRP implementation TAB will engage a third-party consultant to undertake an independent completion audit to: (a) verify if all the LRP provisions have been met; (b) confirm whether livelihoods have been restored to pre-project levels or improved; (c) review the LRP mitigation measures implemented, a comparison of implementation outcomes against agreed objectives, and a conclusion as to whether the monitoring process can be ended (ESAP# 14).

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources.

The Project is in the Borneo lowland rain forests ecoregion consisting of lowland moist evergreen forests with a very high diversity of flora and fauna values. The terrestrial habitats have been heavily impacted by shifting agriculture and human settlements. 

The project sites are not within any protected areas or internationally recognized areas. Within a radius of 50 km of the Project, there are three Protected Areas (PAs) being the Sultan Adam Grand Forest Park (IUCN IV) and Pleihari Tanah Laut Wildlife Refuge (IUCN V) and Pleihari (Pelaihari) Tanah Laut Nature Recreation Park (IUCN V).

The wind turbines will be located on Talok Dalam Hill which has been cleared historically of vegetation.  An access road and internal transmission line are in a surrounding modified hillslopes and a construction jetty is located within natural coastal habitats to the south, which may be removed and rehabilitated once construction is complete.  Seasonal biodiversity surveys conducted for both aquatic and marine values identified several species of conservation concern, being Long-tailed Macaque Macaca fascicularis IUCN EN, Proboscis monkey Nasalis larvatus IUCN EN, and Javan White-eye Zosterops flavus IUCN EN.  Given that the Project is located mainly in modified habitats, forest dwelling fauna (such as the two species of monkey) are unlikely to be impacted.  The Large flying fox was also found not to fly at elevations where the wind turbines are located. The Black eagle Ictinaetus malayensis IUCN LC was identified as soaring along the ridgeline adjacent to the turbines and may be susceptible to mortality during turbine operation. Several IUCN LC bat species were also identified that may be at risk.

To manage impacts from the Project, the Company will prepare a Biodiversity Management Plan (BMP) that will outline measures to reduce risks during construction and operation [ESAP #15].  The BMP will outline measures to rehabilitate natural habitat areas, including the jetty area.  The BMP will include a Bird and Bat Adaptive Management Plan (BBAMP) that will monitor post construction fatalities for a minimum of two years and outline adaptive management measures if significant risks are identified. All actions will be monitored on their effectiveness.                                                   

The project as part of the ESIA, conducted around 45 Key Informant Interviews (KIIs) with some interviews involving more than one stakeholder, and engaged with 154 local stakeholders through Focus Group Discussions (FGDs), representing various community groups such as farmers, fishermen, informal leaders, community leaders, religious figures, youth, women, elderly, and government representatives as well as business and agriculture-related groups. The ESIA consultant and the company jointly prepared consultation materials such as Questionnaire and FGD tools, printed maps, Grievance forms, Grievance pamphlets to describe the Project’s information, including but not limited to: location, size, Project timeline, estimated required workforce, potential impact and proposed mitigation measures, employment opportunities, among other necessary information. With the support of the Project Proponent, the information was delivered to the key stakeholders before the meetings. In addition, the company hired an NGO to undertake socialization across all the villages regarding the project and its impacts, mitigation measures, and collecting feedback from the community. The company as part of ESIA has developed a Stakeholder Engagement Plan (SEP, building upon the ESIA), to include (i) stakeholder identification, analysis, and planning, (ii) disclosure and dissemination of information, (iii) community grievance mechanism, and (iv) ongoing reporting to affected communities and stakeholders, in a manner aligned with IFC PS1 requirements. The company will record details of stakeholder consultations and grievances including the redressal and analysis of systemic grievances and will share these as part of the annual reporting to lenders. Community GM will be able to receive complaints about GBVH regarding security forces, contractor’s and the contract worker’s behavior and others and mechanism to report bad behavior.                                                   

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