chapter 14 | stakeholder consultation and public involvement

Chapter 9 | Biological Impacts and Management Measures

Chapter 14 | Stakeholder Consultation and Public

Involvement

Mako Gold Project

Environmental and Social Impact Assessment

FINAL

Chapter 14 | Stakeholder Consultation and Public Involvement

14 STAKEHOLDER CONSULTATION AND PUBLIC INVOLVEMENT ............................ 14-1

14.1 Introduction ............................................................................................................................................................. 14-1

14.2 Objectives ................................................................................................................................................................. 14-1

14.3 National and International Stakeholder Engagement Context ............................................................. 14-1

14.3.1 National Legislation ................................................................................................................................ 14-1

14.3.2 IFC Guidelines for Stakeholder Engagement ................................................................................. 14-2

14.4 The Company’s Approach to Stakeholder Engagement .......................................................................... 14-3

14.5 Stakeholder Identification and Analysis ........................................................................................................ 14-3

14.6 Stakeholder Engagement Structures .............................................................................................................. 14-4

14.6.1 Inter-ministerial Committee................................................................................................................. 14-5

14.6.2 Independent Group of Experts ........................................................................................................... 14-5

14.6.3 Local Consultative Committee ............................................................................................................ 14-5

14.7 Information Disclosure ......................................................................................................................................... 14-5

14.7.1 Technical baseline study results ......................................................................................................... 14-5

14.7.2 ESIA Terms of Reference ........................................................................................................................ 14-6

14.7.3 Preliminary ESIA and Feasibility Study results ............................................................................... 14-6

14.7.4 DFS/ESIA report and Management plans ....................................................................................... 14-6

14.8 Stakeholder Consultation Completed to Date ............................................................................................ 14-8

14.8.1 Summary of Consultation Outcomes ............................................................................................ 14-14

14.9 Continuing Consultation for completion of the ESIA ............................................................................. 14-19

14.10 Grievance Management ..................................................................................................................... 14-21

14.11 Stakeholder Involvement in Project Monitoring ....................................................................... 14-22

14.12 Reporting to Stakeholders ................................................................................................................ 14-22

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14 STAKEHOLDER CONSULTATION AND PUBLIC INVOLVEMENT

14.1 Introduction

Throughout the ESIA process, consultations and disclosure of Project information has been undertaken with

National, Regional, Department and Sub-prefecture government officials, the local community, and a variety of

other key stakeholders. Formal consultations included workshops and meetings. Informal consultation

included regular discussions and the inclusion of local residents and local government staff in studies and

surveys. Project information has been disclosed through various means including formal reports, workshops,

village assemblies and focus group discussions. Consultation for this Project builds upon existing community

and government relationships formed through exploration activities.

This chapter summarises the consultation undertaken and the associated outcomes before and during the

drafting of the ESIA. Strategies for ongoing consultation throughout the life of the Project, as well as a

description of the proposed grievance mechanism, are also discussed. Planning for further stakeholder

engagement to support construction and operations is presented in the Stakeholder Engagement Plan

(Volume C).

14.2 Objectives

The overall goal of stakeholder engagement for the Mako Gold Project is to improve Project design and

implementation strategies, build understanding to ensure the long-term viability of the Project and to enhance

potential Project benefits. The specific objectives of the stakeholder consultation for the Mako Gold Project

ESIA are to:

1. Provide a structured means for the local community and government to have input into the ESIA

process;

2. Ensure that stakeholders are informed of the Company activities regarding the Mako Gold Project;

3. Actively seek community input into the assessment of potential environmental and social impacts of

the proposed Project mine activities and identification of management/mitigation measures to ensure

consideration of stakeholder interests in the planning and development of the Project; and

4. Reduce the potential for community disaffection that can result from a lack of understanding of the

Project and the permitting process.

14.3 National and International Stakeholder Engagement Context

14.3.1 National Legislation

In Senegal, stakeholder engagement in the ESIA process is defined by the 2001 Environment Code as the

“involvement of people in the decision making process and has three stages including information,

consultation and public hearing”. Article L53 of the Code states that “the participation of populations reflects

the desire to democratize the process of decision making and is guaranteed by the state in the direction of

decentralization and regionalization”. The 2003 Mining Code also requires that the mining titleholder consult

with the concerned local government.

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Ministerial Order No. 9468 defines procedures for public participation in the ESIA process. The Order presents

public participation as a component of the Environmental Impact Assessment which is required at all stages of

project ESIA’s to improve decision making.

14.3.2 IFC Guidelines for Stakeholder Engagement

Stakeholder consultation should be conducted throughout each phase of the Project life cycle, from Pre-

construction through to Closure. Ideally, a good consultation process will be (IFC, 2007):

Targeted at those most likely to be affected by the Project;

Early enough to scope key issues and have an effect on the Project decisions to which they relate;

Informative, as a result of relevant information being disseminated in advance;

Meaningful to those consulted because the content is presented in a readily understandable format and

the techniques used are culturally appropriate;

Two-way so that both sides have the opportunity to exchange views and information, to listen, and to

have their issues addressed;

Gender-inclusive through awareness that men and women often have differing views and needs;

Localised to reflect appropriate timeframes, context, and local languages;

Free from manipulation or coercion;

Documented to keep track of who has been consulted and the key issues raised;

Reported back in a timely way to those consulted, with clarification of next steps; and

Ongoing as required during the life of the Project.

The IFC identifies eight key components of good stakeholder engagement, as illustrated in

Figure 14-1 below.

The following best practice guidelines will also continue to be considered by the Company in the

implementation of future stakeholder engagement activities:

Stakeholder Engagement: A Good Practice Handbook for Companies doing Business in Emerging

Markets. IFC (2007)

Doing Better Business through Effective Public Consultation and Disclosure. A Good Practice Manual.

IFC (1998)

Handling and Resolving Local Level Concerns and Grievances. ICMM (2009)

Community Development Toolkit. ICMM (2005).

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Figure 14-1 Key components of stakeholder engagement (IFC, 2009)

14.4 The Company’s Approach to Stakeholder Engagement

The Company aims to meet IFC standards which require that informed stakeholder consultation and

participation should be conducted throughout each phase of the Project life cycle, from Pre-construction

through to Closure (IFC, 2007).

The Company’s approach to stakeholder engagement focusses on the following core values:

Proactively engage to enable the early identification of potential issues and risks;

Generate ideas and alternative solutions on early design questions; and

Respect local culture and established political, social and economic relations.

14.5 Stakeholder Identification and Analysis

The IFC (2012) defines stakeholders as “persons or groups who are directly or indirectly affected by a project, as

well as those who may have interests in a project and/or the ability to influence its outcome, either positively or

negatively”. The following section provides an overview of Project stakeholders.

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For the Project, key stakeholder groups include Project Affected Villages, downstream water users, villages

along the site access route and the Government of Senegal (at local, regional and national levels). Additional

stakeholders include Project employees, financiers, insurers and shareholders, investors in other development

projects planned for the Project region, and non-government and other civil society organisations operating

in the region.

Key stakeholder groups have been identified and are presented in Table 14-1.

Table 14-1 Summary of key stakeholder groups

Stakeholder Groups Key Interests

Project Affected Villages/persons:

Downstream villages;

villages along access route;

host communities for Project

induced in-migration

The amenity of the Gambia River including water quality;

Access to social infrastructure (potable water, health posts, etc.);

Artisanal mining sites;

Employment and skill development;

Access routes;

Air quality and noise;

Cultural heritage;

Agro-pastoral activities.

Commune of Tombotonkoto:

Other villages in the

Commune of Tomboronkoto

Commune Council of

Tomboronkoto

Local development actors /

NGOs


Access to social infrastructure (potable water, health posts, etc.);

Artisanal mining sites;


Economic development;

Access routes;

Community health and safety;

Agro-pastoral activities.

Department of Kedougou;

Departmental Council of

Kedougou



Access to social infrastructure (potable water, health posts, etc.)

Community health and safety.

Government and Multi-lateral

Institutions:

Administration and technical

agencies

OMVG, UNESCO and other

institutions


Biodiversity values of the Gambia River and the Niokolo-Koba

National Park;


Community health and safety;

Cultural heritage;

Access to social infrastructure (potable water, health posts, etc.).

Conservation interests for Protected

Areas and Threatened species:

Research institutions

Conservation NGOs

Biodiversity values of the Gambia River and the Niokolo-Koba

National Park;

Threatened species and habitats.

14.6 Stakeholder Engagement Structures

A number of formal structures were established by the Company to facilitate information disclosure and

stakeholder consultation. The key structures are described below. Stakeholder engagement was also

conducted through a variety of other channels; these are described in Section 14.7 and Section 14.8.

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14.6.1 Inter-ministerial Committee

An Inter-ministerial Committee at the National level including representatives of relevant National

Departments was established in September 2014 under the direction of the Mining and Geology Department

of Senegal. The main objective of the Inter-ministerial Committee is to facilitate the Project approval process

including the ESIA.

14.6.2 Independent Group of Experts

An independent group of experts (GEI) was established in December 2014 to review the technical, social and

economic feasibility of the Company’s management framework for the protection of biodiversity associated

with the Mako Gold Project. The GEI is comprised of ecology specialists with backgrounds in academia, research,

government, consulting and non-government organisations.

14.6.3 Local Consultative Committee

In November 2014, the Company established a Local Consultative Committee (Groupe de Contact) to facilitate

consultation with representatives from Project Affected Villages. The Groupe de Contact has provided a forum

for the Company to present Project development plans and seek feedback from the community on potential

impacts, issues and opportunities. The Groupe de Contact comprises elected representatives (including women

and youth) from the villages of Mako, Niemenike, Tambanoumouya and Linguekoto; and two representatives

from the Municipal Council of Tomboronkoto.

The Company also established various ad hoc technical working groups (Groupes Techniques) to support the

analysis of specific issues, namely: economic development and employment; rural livelihood; urban livelihood;

artisanal mining; and livestock. These groups comprised key informants from Project Affected Villages. The

outcomes of the Groupes Technique were reported back to the Groupe de Contact to inform higher level

decision-making.

14.7 Information Disclosure

This section identifies key elements of information disclosure through the ESIA and feasibility phases of the

Project. Table 14-3 below presents a summary of disclosed information for each stakeholder group.

14.7.1 Technical baseline study results

The Company commenced technical baseline studies in August 2012 and continuing through 2013. This

included: surface and ground water quality monitoring; ecology surveys; air quality and noise monitoring;

socio-economic, land and water use surveys; archaeology and cultural heritage surveys. The results of these

surveys defined priority environmental and social features, key issues and potential impacts. These broad

studies subsequently informed the design and conduct of targeted technical studies in 2014 and 2015.

The results of these baseline studies have been shared with a range of stakeholders at key Project milestones,

including:

Disclosure of technical baseline reports on ecology and water resources to relevant government

departments, research agencies, multi-lateral agencies and non-government organisations;

Multi-stakeholder workshops on terrestrial and aquatic biodiversity; and

Village level assemblies and focus group discussion on land and water use;

Dissemination of the draft Terms of Reference for the ESIA.

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14.7.2 ESIA Terms of Reference

In March 2014, the Company submitted an environmental and social scoping document and draft Terms of

Reference (TOR) for the Mako Gold Project ESIA for approval by DEEC. The scoping document and draft TOR

was distributed to various government and non-government organisations. A copy of the scoping document

and draft TOR is provided in Volume A (Appendix 1).

Public consultation was undertaken to disseminate the scoping document and draft TOR at the local,

Commune and Regional levels from March 4 to March 21, 2014. The Company was supported in this

consultation by the Direction of Mines and Geology, and the administrative authorities of Bandafassi Sous-

prefecture. A summary of the consultations that took place are outlined below in Table 14-2 and a record of

consultation is provided in Volume A (Appendix 9).

Table 14-2: Summary of initial government consultation

Date Meeting Venue Participants

4 March 2014 Tomboronkoto

Commune workshop

Rural Council of

Tomboronkoto

Rural Council (now Commune) of Tomboronkoto,

representatives from the Project affected

settlements (Tambanoumouya, Linguekoto,

Niemenike and Mako) and NGOs

5-6 March 2014 Village level assembly Tambanoumouya,

Linguekoto,

Niemenike and

Mako

Community

11 March 2014 Regional workshop Kedougou Kedougou Administrative and Technical

Agencies

17-21 March

2014

One-on-one meetings Kedougou Non-government organisations

The draft TOR was updated based on feedback received by the Company during this consultation and formal

comments received from DEEC and DMG in May 2014 (refer Volume A, Appendix 1). A revised TOR was

subsequently submitted to DEEC in August 2014 and approved.

14.7.3 Preliminary ESIA and Feasibility Study results

The preliminary findings of the ESIA and Feasibility Study were presented to 13 villages located within 10 km

and/or downstream of the Project Development Area from January 26-30 2015. Information disclosed at these

village assemblies included the preferred Project design arrangement; potential issues and impacts; the Project

permitting process; and mechanisms for community feedback.

From April 20 to May 11, and as recommended by the Inter-ministerial Committee set up for the Mako Gold

Project, the preliminary ESIA findings were presented to various Government technical agencies and

administrative authorities at regional and national levels, including the Municipal Council of Tomboronkoto.

Minutes and meetings held during this process are included in Appendix 9.

14.7.4 DFS/ESIA report and Management plans

In accordance with Senegalese regulations, the draft ESIA report for the Mako Gold Project was submitted to

the Government for approval. Refer Chapter 3 (Section 3.3.3), for a description of the permitting process for an

ESIA. An integral component of the permitting process is public consultation, including the requirement for a

public hearing (audience publique). The public hearing for the Project was conducted on 21 November in

Kedougou. The meeting was attended by Project-affected villages. The meeting minutes are provided in

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Volume A, Appendix 9. Feedback received during this consultation has been incorporated into the preparation

of this final ESIA report and is summarised in Table 14-9.

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Table 14-3: Summary of disclosed information

Phase of Disclosure Information Disclosed Stakeholder Groups

Scoping and screening Project design options;

Preliminary baseline study findings.

Project affected villages

Commune of Tomboronkoto

Government and non-government

agencies

Pre-feasibility Project design options and preferred

design;

Baseline study results;

Key issues and potential impacts;

Draft Terms of Reference for ESIA


Commune of Tomboronkoto:

Government technical and

administrative authorities

Multi-lateral institutions

Research organisations

Local development actors / NGOs

Feasibility and ESIA Project design;

Baseline study results;

Impact assessment results.


Commune of Tomboronkoto:

Government technical and

administrative authorities

Multi-lateral institutions

Research organisations

Local development actors / NGOs

14.8 Stakeholder Consultation Completed to Date

The Company’s approach to engagement is participatory and emphasises a high degree of engagement with

all stakeholders and regular and direct consultation with those most affected by the Project. The Company has

aimed to provide those affected with as much information about the Project as possible – and ensure that all

major inputs, conclusions and recommendations are shared with and validated by those affected by the Project.

Key stakeholder engagement activities conducted during the pre-feasibilty, feasibility and ESIA phases of the

Mako Gold Project include, but are not limited to:

Disclosure of the Terms of Reference for the Environmental and Social Impact Assessment.

Consultation with local villages in the design and implementation of preliminary environmental and

social baseline studies. This has included household surveys; key informant interviews; focus groups

discussions and village meetings. Information has been collected in this way on socio-economic

conditions, water use, cultural heritage, artisanal mining, local ecological knowledge etc.

Conduct of comprehensive environmental and social baseline studies involving a range of research

institutes and scientific organisations, including: the ISE (L'Institut des Sciences de l'Environnement,

Université Cheikh Anta Diop); IFAN (Institut Fondamental d'Afrique Noire, Université Cheikh Anta Diop);

IUCN (Union internationale pour la conservation de la nature); Faculty of Science and Technology

(Université Cheikh Anta Diop) and UNESCO (United Nations Educational, Scientific and Cultural

Organisation).

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Collaboration with the Direction of National Parks and Direction of Forestry in the conduct of terrestrial

ecology surveys both within the Exploration Permit Area, and adjacent areas of the Niokolo-Koba

National Park.

Participative impact and mitigation planning with local villages, particularly relating to livelihoods, land

and water in the vicinity of the Mako Gold Project.

Development of livelihood pilot programs in Tambanoumouya and Linguekoto villages particularly

relating to livelihoods, land and water in the vicinity of the Mako Gold Project.

Partnership with the Tomboronkoto Commune in the realisation of its Local Development Plan including

activities that have improved access to clean water, health services, education materials and

opportunities for income generation.

Implementation of a grievance mechanism to assist in the validation and resolution of complaints arising

from Project exploration activities.

These activities have helped build mutually beneficial relationships in the Project affected villages and

informed preliminary design decisions. A summary of consultation completed to date can be found in Table

14-4 below. A detailed description of consultation activities is provided in the technical baseline reports

(Volume A, Appendices 1 to 9).

Plates 14-1 and 14-2 Women’s Focus Group Meetings in Sibikiling (left) and Segueko Bassari (right)

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Table 14-4 Summary of consultations and surveys undertaken for the Mako Gold Project to date

Consultation Participants Method of Engagement Period

Draft ESIA Terms of Reference Project Affected Villages, Commune Council of

Tomboronkoto, government and administrative authorities,

Multi-state institutions, Research organisations, NGO

representatives

Village assemblies, workshops,

one-on-one meetings,

dissemination of reports

March – July 2014

Preliminary ESIA results Project Affected Villages, Commune Council of

Tomboronkoto, government and administrative authorities,

multi-state institutions, Research organisations, NGO

representatives




April – May 2015

Preliminary Project design and key

impacts

Project Affected Villages, Commune Council of

Tomboronkoto, government and administrative authorities




January – February 2015

Draft Biodiversity Action Plan Commune Council of Tomboronkoto, government and

administrative authorities, Research organisations, NGO

representatives

Workshop, one-on-one meetings,


August 2015

Biodiversity ‘no net loss’ strategy Commune Council of Tomboronkoto, government and

administrative authorities, multi-state institutions, Research

organisations, NGO representatives

Workshop, one-on-one meetings,


November 2013

Socio-economic, land and water use

assessment

Project Affected Villages Household surveys, population

census, focus group discussions,

village assemblies, key informant

interviews, field surveys and

ground-truthing

November 2012 and September

2013, August 2014

Women and youth Project Affected Villages Focus group discussions, key

informant interviews

November 2012, February and

March 2015

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Artisanal mining surveys Artisanal miners, village chiefs, government authorities,

NGO representatives

Focus group discussions, key

informant interviews, field surveys

and ground-truthing

20 – 26 November 2012 and

March 2015

Participatory land-use surveys and

mapping

Project Affected Villages Focus group discussions, village

assemblies, key informant

interviews, field surveys and

ground-truthing

April and September 2013,

August 2014

Archaeology and cultural heritage

assessment

Project Affected Villages, research organisations Focus group discussions, key

informant interviews, transect

surveys and test-pitting

November 2012, April 2013, May

– June 2014

Terrestrial and aquatic ecology assessment Project Affected Villages, government authorities, research

organisations

Workshops, one-on-one meetings,

dissemination of reports, focus

group discussions, key informant

interviews, transect and

reconnaissance surveys

February, August-September

2013, June- July 2014

Social impact and mitigation planning,

including local economic participation

planning

Project Affected Villages, Commune Council of

Tomboronkoto, Chamber of Commerce, Chamber of

Trades, Microfinance organisations

Workshops, focus group

discussions, key informant

interviews, meetings,

demonstration and pilot

programmes

December 2014 – March 2015

Downstream water use assessment Project Affected Villages Focus group discussions, key

informant interviews, ground-

truthing

February – March 2015

Cumulative impact assessment Commune Council of Tomboronkoto, government

authorities

One-on-one meetings March 2015

Public audience Project Affected Villages Public meeting 21 November 2015

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Plate 14-3 Water use survey – Men’s focus group in Kerekonko

Plate 14-4 Water use survey – Women’s focus group in Wassadou

Plate 14-5 Village consultation (youth) in Bomboya

Plate 14-6 Village Consultation in Badian 1

Plate 14-6 Village consultation in Soukouta

Plate 14-7 Village consultation in Dalakoy

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14.8.1 Summary of Consultation Outcomes

Consultation has confirmed that Project stakeholders, including potentially affected villages are generally

supportive of the Project and appreciative of their involvement in the design and planning phases. The

opinions and suggestions of stakeholders obtained through the Stakeholder Engagement process have been

considered in the design of the Project and associated management plans.

Table 14-5: to Table 14-8 below presents specific concerns raised during consultations with villages, specific

groups (women, youth) within villages, and government. Detailed minutes of meetings are included in

Appendix 9 of Volume A.

Throughout the design and planning stages of the Mako Gold Project, the Company has actively addressed the

issues and concerns raised during stakeholder consultation. For example, stakeholder consultation has directly

informed:

The location of the TMF and the decision to avoid impacts to the Wayako valley which is an important

area for agro-pastoral activities;

The alignment of the Main Access Road to avoid impacts to sensitive chimpanzee habitat and

minimise impacts to agricultural land;

The formulation of the social management plans including the Livelihood Restoration Plan and Local

Economic Participation Plan; and

The formulation of the Biodiversity Action Plan, including the draft Biodiversity Offset Strategy.

Table 14-5: Summary of village level concerns and where each of these issues have been addressed in the ESIA

Stakeholder

Group

Consultation Outcomes ESIA Section

Reference

Project Affected

Villages

(Tambanoumouya,

Linguekoto,

Niemenike, Mako;

Dalakoy and

Kerekonko)

Compensation for impacts to livelihood, land and water resources (agro-pastoral activities, artisanal mining, forestry resources);

Sections 11.2 to 11.8 and Livelihood Restoration Plan (Volume D).

Access to employment opportunities; Section 11.1 and Local Economic Participation Plan (Volume D).

In-migration and the impact on host villages (safety, public health, access to infrastructure and services);

Section 11.11.

Cultural heritage; Sections 11.9 and 11.10.

Skill development for the youth; Section 11.1 and Local Economic Participation Plan (Volume D).

Income generating activities for women; Section 11.14 and Local Economic Participation Plan (Volume D).

Public health and safety (road safety, hazardous materials, water quality, air quality, blasting);

Sections 11.12 and 11.13.

Livestock health and access to pasture; Section 11.3.

Pollution of water resources including the Gambia River. Section 11.7.

Downstream

Villages

(Bomboya and

Soukouta)

Pollution of water resources including the Gambia River; Section 11.7.


Section 11.11.

Public health and safety (hazardous materials, water quality); Sections 11.12 and 11.13.

Compensation for impacts to livelihood, land and water resources (agro-pastoral activities, artisanal mining, forestry resources).

Sections 11.2 to 11.8 and Livelihood Restoration Plan (Volume D).

Surrounding

Villages


Sections 11.2 to 11.8 and Livelihood

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(Badian I, Badian II,

Badon-Sibikiling,

Senodji, Saint-

Etienne –

Niarikondo,

Laminia –

Sindakha)

Restoration Plan (Volume D).

Pollution of water resources including the Gambia River; Section 11.7.

Land rehabilitation following closure of the mine; Section 11.4 and Rehabilitation and Conceptual Mine Closure Plan (Volume E).

Skill development for the youth; Section 11.1 and Local Economic Participation Plan (Volume D).

Cultural heritage. Sections 11.9 and 11.10.

Table 14-6: Summary of concerns from the women’s focus groups (February – March 2015) and where each of

these issues have been addressed in the ESIA

Village Women’s Consultation Outcomes ESIA Section

Reference

Tambanoumouya,

Linguekoto,

Niemenike and

Mako

Compensation for impacts to livelihood, land and water resources, in particular artisanal mining and forestry resources;

Sections 11.1 to 11.8.

Cohabitation with the heavy vehicles, accessibility issue to Wayako valley;

Section 11.13.


Section 11.11.

Public health and safety (road safety, sexually transmitted diseases);




Cultural heritage.


Table 14-7: Summary of Concerns from the Youth’s Focus Groups (February – March 2015) and where each of


Village Youth’s Consultation Outcomes ESIA Section

Reference

Tambanoumouya,

Linguekoto,

Niemenike and

Mako




Public health and safety (road safety, air quality, noise); Sections 11.12 and 11.13.


Youth training; Section 11.1 and Local Economic Participation Plan (Volume D).

In-migration and the impact on host villages (safety, public health, access to infrastructure and services).

Section 11.11.

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Table 14-8: Summary of consultation outcomes from regional and national agencies (April – May 2015) and

where each of these issues have been addressed in the ESIA

Authority/

Agency

Issues / Recommendations ESIA Section

Reference

Prefet de

Kedougou

Informed consultation with Administrative authorities; Sections 14.4 to 14.8.

Consider the establishment of an artisanal mining corridor to improve coexistence with artisanal miners;

Section 11.5.

Respect management commitments; Section 15.2.

Improve access to community infrastructure and services. Sections 11.1, 11.11 and 11.12.

Conseil

Departemental

de Kedougou

Support skill development programmes for local youth; Section 11.1 and Local Economic Participation Plan (Volume D).

Improve access to community infrastructure and services; Sections 11.1, 11.11 and 11.12.

Respect management commitments. Section 15.2.

Brigade Puits et

Forages de

Kedougou

Improve access to community infrastructure and services (Mako village has a significant deficit in the availability of potable water);

Sections 11.1, 11.11 and 11.12.

Strengthen the capacity of community water management committees;

Section 11.7.

Service

Regional

d’Appui au

developpement

local

Informed consultation and participation of government agencies; Sections 14.4 to 14.8.

Support the Tomboronkoto Council with the elaboration of the Commune Development Plan;


Respect management commitments.

Section 15.2

Sapeurs

pompiers

Public safety (transport of hazardous materials and bushfires).


Conseil

Municipal de

Tomboronkoto

Respect management commitments in Operation and post-Closure phases;

Section 15.2.

Support the Tomboronkoto Council with the elaboration of the Commune Development Plan;


Improve access to community infrastructure and services.

Sections 11.1, 11.11 and 11.12.

IREF de

Kedougou

Under the biodiversity offset programme, consider the broader area including the ZIC (Zone d’Intérêt Cynégétique);

ESIA Section 10.2.2 and 10.3.2. In addition, the biodiversity offsets programme has considered the broader area, including areas currently impacted by poaching, to develop and implement offsets that will achieve no net loss on biodiversity. The cultural value and use associated with biodiversity by the community is addressed in the Livelihood Restoration Plan (Volume D).

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Authority/

Agency


Reference

Develop research programs in preparation for the rehabilitation phase.

Rehabilitation and Conceptual Mine Closure Plan (Volume E), Sections 4.2 and 6.3.

Service

Regional Mines

et Geologie

Consider the establishment of an artisanal mining corridor to improve coexistence with artisanal miners;

Section 11.5.

Support artisanal miners, especially women, to comply with national regulations.

Sections 11.5 and 11.14 as well as the Livelihood Restoration Plan (Volume D).

DREEC de

Kedougou

Provide technical documents with details on design and construction standards;

Key technical details on design and construction standards are provided in Sections 4.1 to 4.5.

Respect the regulatory requirements for classified installations; Sections 4.1 to 4.5 and Risk Assessment (Volume B).

Evaluate the capability of the Regional Environmental Monitoring Committee and strengthen the capacity of this institution as appropriate.

Section 15.2.4.

Service

Regional

Securité Sociale

et Travail de

Kedougou

Provide a detailed breakdown of job opportunities and recruitment planning during different phases of the development of the Project.


Service

Regional

Elevage de

Kedougou

Under the livelihood restoration programme, integrated agriculture and livestock management is considered a favourable activity.

Livelihood Restoration Plan (Volume D), Section 6.

Direction

Regionale du

Développement

Rural (DRDR)

Under the livelihood restoration programme, market gardening is considered a favourable activity;

Livelihood Restoration Plan (Volume D), Section 11.2.

Support skill development programmes for local youth.

Section 11.1 and Local Economic Participation Plan (Volume D).

Gendarmerie Government is planning to strengthen public security through the establishment of a Gendarmerie post in Mako village;

Noted.

Consider the establishment of an artisanal mining corridor to improve coexistence with artisanal miners.

Section 11.5.

Service

Regional Action

Sociale

Develop a good communication system with local populations; Chapter 14 and Stakeholder Engagement Plan (Volume C).

Support local health authorities with the implementation of their public health programs in the Project area;


Take into account vulnerable groups as part of the Company’s social activities.

Section 11.15.

Support local health authorities with the implementation of their public health programmes in the Project area;


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FINAL 14-18

Authority/

Agency


Reference

Service

Regional de la

Santé

Target women in the implementation of public health programmes.


Sous-Prefet de

Bandafassi

Prepare local populations for the potential impacts of in-migration; Section 11.11.

Respect the administrative process for the occupation of land by Project infrastructure.

Section 11.4.

Service

Régional

Hydrologie de

Tambacounda

Informed consultation and participation of technical agencies in work programme.


Service

Régional

Hygiène de

Tambacounda

The Hygiene Services have to the authority to monitor drinking water quality provided by the Company to Project personnel;

Noted.

Informed consultation and participation of technical agencies in work programme;


Strengthen the capacity of the Commune of Tomboronkoto to manage solid waste.

Section 11.11.

Service

Régional de

l’Hydraulique de

Tambacounda

Support the operation of the Regional Environmental Monitoring Committee and strengthen the capacity of this institution as appropriate;

Section 15.2.4.

Respect all regulatory requirements concerning the use of water resources by the Company.

Section 3.3.1.

Service

Régionale du

Parc National du

Niokolo-Koba

Avoid negative impacts on the Gambia River and the NKNP Biodiversity Action Plan (Volume C).

Collaborate with the NKNP Monitoring Division on biodiversity monitoring in the NKNP ;

Biodiversity Action Plan (Volume C).

Respect management commitments as presented in the ESMMP; Section 15.2.

Allocate appropriate resources to rehabilitation of the Project area.

Rehabilitation and Conceptual Mine Closure Plan (Volume E).

IUCN Support the government of Senegal with the provision of the Project ESIA report;

ESIA Study Report (Volume A).

Specifically assess the impacts of the Project on the Gambia River, chimpanzee habitat and gallery forest;

Sections 10.1 to 10.4

Ensure that the Project is compliant with IUCN guidelines on development adjacent to World Heritage site;


Any activities within the NKNP should be consistent with the recommendations of the UNESCO World Heritage Committee.


Direction de la

Gestion et de la

Planification des

Ressources en

Eau

Share all water monitoring data with the DGPRE; Section 15.2.5.

Request the Company to collaborate with the DGPRE on the monitoring of water resources.

Sections 15.2.5 and 15.3.

Direction des

Parcs Nationaux

Consider the potential impacts of Project induced in-migration on the incidence of poaching;


Consider cumulative impacts of the Project with others development in the region;

Chapter 13.

Assess the impacts of the Project on terrestrial and aquatic ecology, and propose management and mitigation measures.


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Authority/

Agency


Reference

Direction des

Eaux et For ts ;

Chasse et

Conservation

des Sols

Informed consultation and participation of government technical agencies, especially concerning the conservation of threatened species;


Consider measures to protect biodiversity values in areas outside of the NKNP.


Direction de la

Protection Civile

Appropriately mitigate the risks to public safety; Sections 11.12 and 11.13.

Prepare an emergency response plan for the Project.

Sections 11.12 and 11.13 (and provided in ESMMP, Volume C, and EDD, Volume B).

Table 14-9: Summary of concerns expressed during the Public Audience (21 November 2015) and where each of


Village Public Audience Outcomes ESIA Section

Reference

Tambanoumouya,

Linguékoto,

Niéméniké, Mako,

Dalakoy,

Kérékonko,

Bomboya,

Soukouta, Badian

I, Badian II, Badon-

Sibikiling, Sénodji,

Saint-Étienne –

Niarikondo, and

Laminia –

Sindakha

Compensation for impacts to livelihood, land and water resources Sections 11.2 to 11.8 and Livelihood Restoration Plan (Volume D).

Pollution of water resources including the Gambia River Section 11.7.

In-migration and the impact on host villages (safety, access to local resources including water and forestry products)

Section 11.11

Access to employment opportunities Section 11.1 and Local Economic Participation Plan (Volume D).

Youth training Section 11.1 and Local Economic Participation Plan (Volume D).

Income generating activities Section 11.14 and Local Economic Participation Plan (Volume D).

Land rehabilitation following closure of the mine Section 11.4 and Rehabilitation and Conceptual Mine Closure Plan (Volume E).

Ensure that standards are followed by Project Contractors Ch. 9 – 12.

Improve access to community infrastructure and services Sections 11.1, 11.11 and 11.12.

14.9 Continuing Consultation for completion of the ESIA

The preliminary stakeholder engagement program to be undertaken for completion of the ESIA and in

preparation for the commencement of Project Construction is presented in Table 14-9. This includes the

establishment of stakeholder engagement tools and direct engagement activities.

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Engagement processes are by their nature unpredictable, and so the program outlined below is a tentative

proposal for discussion with those affected, and therefore aspirational and subject to change.

Table 14-10: Preliminary Stakeholder Engagement Program

Objective / Activity Key Steps

Ensure that social and

environmental standards and

guidelines are followed by Project

Contractors

Develop social and environmental standards and guidelines for Project

Contractors

Detail stakeholder engagement requirements for Contractors

Ensure requirements are included in every Project contract

Monitor compliance

Put in place a consultation

database

Finalize engagement tools – what will be inputted into the database? How

will this information be collected?

Identify user requirements – who will use it? How?

Record all interactions with stakeholders

Monitor and maintain database – on-going

Set up the grievance management

system

Review grievance system structure

Advertise the system

Establish grievance register

Set up grievance system to receive and addresses concerns raised by

stakeholders

Set up Commitment Registry Review all Project social and environmental commitments, timeframe,

responsible, and cost as defined in the ESIA

Establish a simplified commitment registry

Recruit additional staff (pending

Project status)

Vulnerable Persons Officer / Grievance Management Officer

Procurement / Human resource outreach people

Other staff as needed

Disclosure of Permit Status Disclosure of permit approval – Regional, Commune, and village level

Formalise engagement with

Conseil Municipale and Groupe de

Contact

Reformulate the Stakeholder Engagement Structure at the Conseil

Municipale and Groupe de Contact

Validate through village Focus Group Discussions

Formalise Local Employment

Thematic Working Group (TWG)

Establish TWG – to meet on a quarterly basis.

Review Local Economic Participation Plan

Develop minimum requirements for recruitment and pre-employment

training

Build recruitment database

Hold discussions on local employment and provide an update on the

recruitment process and related skill requirement

Engage agency to implement recruitment process

Formalise Local Procurement


Establish TWG – to meet on a quarterly basis.

Review Local Economic Participation Plan

Determine minimum requirements for procurement

Develop registration and administrative process for procurement

Develop Local Supplier Database

Hold discussions on local procurement and provide an update on the

procurement process, requirements and provide trainings and guidelines

Formalise the Biodiversity


Establish TWG – to meet on a quarterly basis

Review Biodiversity Action Plan

Confirm the technical and social feasibility of the proposed biodiversity

offset sites

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FINAL 14-21

Objective / Activity Key Steps

Identify implementation activities to support the biodiversity offset

program

Formalise the Land Acquisition

and Livelihoods Restoration


Establish TWG – to meet on a monthly basis

Begin formal discussions on land acquisition and mitigation measures

Formal registration of land, assets and livelihoods

Prepare collective and individual agreements for the restoration of impacts

Finalise the Livelihood Restoration Plan

Commune Development Plan

(PDC)

In consultation with the Commune Council, confirm the process and

schedule for preparation of the PDC, and the scope of the Company’s

participation.

Mobilise technical and financial assistance to support the preparation of the

PDC, as agreed with the Commune Council.

Provide input to the preparation for the PDC as appropriate.

14.10 Grievance Management

The Company currently maintains a simplified grievance mechanism to support Project exploration activities.

The informal resolution process involves the Mako Exploration Camp Manager, village and commune-level

leaders, and the sous-prefet where necessary.

The Company will develop a Grievance Mechanism, adapted from the IFC’s Guide to Designing and

Implementing Grievance Mechanisms (2008).

A Grievance Mechanism receives and addresses concerns raised by stakeholders in a transparent, constructive,

timely, confidential (if desired), culturally appropriate and accessible manner.

This Grievance Management System will comprise four basic mechanisms:

First Order Mechanism:

Informal resolution process;

Stakeholder concerns discussed with Company representatives;

Questions and concerns likely to be resolved within these informal interactions.

Second Order Mechanism:

Formal management of difficult and/or written grievances by the Grievance Management

Officer through the following stages – Registration, Reporting, Validation, Investigation, and

Resolution.

Third Order Mechanism:

Presentation of grievances to a multi-stakeholder forum for example a Consultation

Committee (Groupe de Contact) with the involvement of the Sous-prefecture for discussion

and resolution;

Forum will serve as an important and trusted arbiter in complicated grievances;

Minutes and a written report will be provided to the complainant.

Fourth Order Mechanism:

Involves the formal judicial system;

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The Company will inform those who prefer litigation of their rights, entitlements and the

existence of any legal aid.

The Grievance mechanism is further detailed in the Stakeholder Engagement Plan (Volume C).

14.11 Stakeholder Involvement in Project Monitoring

The Project will require coordination with a number of institutional structures at all levels of Government. The

Company will work with the existing Regional Environmental Monitoring Committee (Comité Régional de Suivi

Environnemental et Social, CRSE) to enable the Government of Senegal to conduct independent monitoring of

the Project. The CRSE will be used to monitor current and future Company’s activity within the Kedougou

Region across the construction, operations and closure phases of the Mako Gold Project.

14.12 Reporting to Stakeholders

The Company will report regularly on the environmental and social performance of the Project to stakeholders.

The Company will prepare a quarterly operations report to summarise its environmental and social

performance and significant activities, incidents and events for that report. The report will include a summary

of stakeholder engagement activities and key indicators and will be submitted to the relevant Senegalese

authorities. The Company will also prepare an Annual Sustainability Report to summarise stakeholder

engagement activities, business and sustainability performance for each calendar year, which will be made

available to stakeholders.

Reporting practices are further detailed in the ESMMP and the Stakeholder Engagement Plan (Volume C).

chapter 14 | stakeholder consultation and public involvement

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