stakeholder engagement plan for the … copy file:sep_aureus contact at stakeholder engagement plan...

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File:SEP_Aureus Contact at www.aureus-mining.com

STAKEHOLDER ENGAGEMENT PLAN FOR THE NEW LIBERTY

GOLD MINE, LIBERIA

A/BMMC-SHEQ-SEP-001

AUREUS MINING INC.

March 2014

Revision Prepared by Approved by (position) Signature of Approver Date

SHEQ Manager and

Technical Manager

BEA MOUNTAIN MINING CORP.

New Liberty Gold Mine

STAKEHOLDER ENGAGEMENT PLAN

Document No: SEP 001

Issue Date: Mar-25-2014

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This document has been prepared by Digby Wells Environmental.

Report Title: Stakeholder Engagement Plan for the New Liberty Gold

Mine, Liberia

Project Number: AMI2252

Name Responsibility Signature Date

Nestus Bredenhann SEP Writer

July 2013

Nic Boersema / Jan

Perold Review July 2013

This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose

without Digby Wells Environmental prior written consent.






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EXECUTIVE SUMMARY

Aureus has identified the need to develop and implement a Stakeholder Engagement Plan

(SEP) as part of the Environmental and Social Impact Assessment (ESIA) update and to

comply with requirements of the International Finance Corporation (IFC), and specifically that

of Performance Standard 1 (PS1). The development and implementation of the SEP are not

merely to adhere to requirements of international institutions, but to provide structure and

guidance for on-going engagement with stakeholders. It aims to:

■ Build on an understanding of previous stakeholder engagement activities undertaken

in the project area;

■ Identify the stakeholders, concerns and interests to be engaged with;

■ Clarify detailed goals and objectives for engagement;

■ Discuss various engagement mediums to be utilised; and

■ Provide an implementation plan.

In order to adhere to the above mentioned objectives, the SEP comprises of three main

components which are described in further detail below.

Strategy

The strategy gives direction to the SEP and individual components included therein. A vision

for SE has been proposed focussing on NLGM being a mining company recognised and

welcomed, contributing towards social, economic and environmental development. Two long

term goals have been defined for areas of social and environmental requirements to be

achieved. In brief, these include attaining a formal licence to operate and a social licence to

operate which provides the basis for development of the short term objectives to be

formulated. Five specific objectives have been put forward in the SEP which revolves around

inclusivity, establishing relationships, participation, internal capacity of the Organization and

stakeholder concerns.

Regulatory requirements for Liberia and International Finance Corporation (IFC)

The Environmental Protection and Management Law, 2002, is the Liberian regulation dictating

activities which has an impact on the direct environment, albeit social or natural. Under this

regulation various sections highlight the requirement for public consultations and also provides

for an opportunity for the Environmental Protection Agency of Liberia (EPAL) to take the lead

by means of calling for public hearings.

The IFC prescribes a set of Performance Standards which need to be adhered to in order to

be considered for funding opportunities. These lender requirements speak directly to

stakeholder engagement activities and provide clear objectives and good practice guidelines.

Performance Standard 1 is focused on Social and Environmental Assessment and

Management Systems (PS1) while Performance Standard 5 is concerned with Land

Acquisition and Involuntary Resettlement (PS5).






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Summary of stakeholder engagement activities

Engagement with stakeholders was undertaken as part of the EIS process and development

for the RAP. Consultation as part of the EIS process was focused on:

National government

� Environmental Protection Agency;

� Ministry of Lands, Mines and Energy;

� Forestry Development;

� Hydrological Service of Liberia; and

� Ministry of Internal Affairs.

Regional and district government

� Superintendent of Grand Cape Mount County and his/her representatives.

Community stakeholders (i.e. the public, including the Chiefs, their elders and representatives,

youth group leaders, women’s group leaders and the general population in each village) were

consulted at the following locations:

� Mecca, Cape Mount County;

� Kinjor and Larjor Villages;

� Jawajei Village; and

� Sinje Town.

This consultation followed a structured process by means of project announcement via a

Background Information Documents, letter and radio advert, followed by consultation with

stakeholders.

Consultation undertaken for the RAP development included majority of the stakeholders

mentioned above with focus placed on additional town authorities, district authorities,

Ministries and civil society bodies.

Key Issues Identified

Key issues raised by stakeholders during the EIS update were identified and supplemented

by interviews. These were identified by means of:

■ Desktop review of existing reports (feasibility studies, stakeholder related documents,

social and/or stakeholder related plans); and

■ Interviews with local consultants.

The summary of these issues were categorized into 10 key issues which included social

concerns, environmental impacts and institutional challenges. Main RAP grievances and

concerns received to date are also discussed as part of this section.

Key Contributors

A number of similar SE activities are used across the various Implementation Plan

components and are regarded as key contributors to the SEP. These include:






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� Stakeholder identification and analysis;

� Information disclosure;

� Stakeholder consultation;

� Grievance management;

� Stakeholder involvement in project monitoring;

� Reporting to stakeholders; and

� Management functions.

Engagement Medium

All SE activities are supported with the use of various engagement mediums. These mediums

are specific to the requirements of stakeholders affected by the project and aims to enable

stakeholders to participate in SE processes meaningfully. These mediums have been divided

into five categories, namely:

� Process driven;

� Media;

� Stakeholder meetings;

� Written / visual communication; and

� Other.

In total, 22 different types of mediums have been proposed to be used with implementation of

the SE activities.

Implementation Plan

The implementation plan takes into consideration the background and supporting information

provided in the situational analysis in order to devise the appropriate SE activities to be

implemented. The implementation plan is comprised of seven components, these include:

■ Corporate Stakeholder Engagement;

■ SE Implementation Plan for Mine Lifecycle;

■ SE Implementation Plan for Issues Resolution;

■ SE Implementation Plan for the ESIA update;

■ SE Implementation Plan for Community Development Plan;

■ SE Implementation Plan for the RAP; and

■ Grievance Mechanism.

Corporate Stakeholder Engagement

As part of the corporate level stakeholder engagement plan, stakeholders having an interest

or affected by the project has been identified and profiled to engagement purposes. As part of

this section the various levels of public participation goals have been detailed, being; Inform,






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Consult, Involve, Collaborate and Empower. Internal enablers provide the needed

Organizational mechanisms required for effective implementation of the SEP and include

Systems, Structure, Skills and Staff. Each of these enablers will have its own SE Activities,

Objectives, Key Performance Indicators (KPIs), Timeframes and Engagement Mediums. In

this section an Organizational structure and management functions are proposed which need

to be established in support of effective implementation of the SEP. These include:

� Social Manager;

� Community Liaison Team (CLT);

� Administration; and

� Integration and support.

Stakeholder analysis

The approach whereby stakeholders have been identified is described in this section of the

SEP and is mainly associated with the Environmental Impact Statement (EIS) that was

compiled and consultations completed for the RAP. Stakeholder groups identified are

categorized according to:

� National Government;

� County / District Authorities;

� Traditional Authorities;

� Town Authorities;

� Communities;

� Civil Society and Non-Governmental Organizations;

� Commerce and Industry; and

� International Organizations.

A draft stakeholder database has also been developed from the Golder EIS Report and

consultations undertaken as part of the Resettlement Action Plan (RAP). This database needs

to be updated throughout the NLGM lifecycle.

SE Implementation Plan for Mine Lifecycle

The mine lifecycle is defined according to six distinctive phases, namely, Exploration, Pre/ and

Feasibility, Construction, Commissioning, Operation and Closure. Under each of these

phases, specific SE activities need to be implemented to ensure that the mine reaches the

two main goals. Similar to the Internal Enablers, each SE activity will be guided by an

Objective, and aligned with required Timeframes and communication Mediums. Although the

Exploration, Pre-feasibility and Feasibility phases of the project are already complete, the SE

activities for these are included for completeness.

SE Implementation Plan for Issues Resolution

Stakeholder issues identified, as highlighted in Section 4.3.1, will be addressed by means of

implementing SE activities. These activities will be aimed to either resolve issues identified or

to capitalise on the situation, turning it into opportunity for the Organization. Each SE activity

will target specific stakeholders, using preferred engagement mediums.

SE Implementation Plan for ESIA Update






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It is proposed that stakeholders be consulted as part of the ESIA Update process because of

IFC considerations and as such, to conduct subsequent stakeholder meetings. The ESIA

Update Report will also be made available to the relevant stakeholders for comment (if

required). A short Background Information Document needs to be developed describing the

updates in the ESIA and giving a brief overview of the EIS process that was completed.

A presentation will be developed to convey the ESIA Update details for meetings with

Ministries and where applicable, the Superintendent and District Commissioner. This

presentation will be printed on a full colour A1 poster set (maximum 4 pages) for community

meetings, which will include the traditional and town authorities. All comments raised during

these stakeholder meetings will be captured in a Comment and Response Report (CRR).

SE Plan for Community Development Plan Implementation

The SE section in the CDP provides a clear indication of what SE activities needs to be

undertaken and who the relevant stakeholders are. As part of the Implementation Plan further

SE activities for each of the main CDP activities are discussed and structured into a formal

plan. In total eight CDP activities are selected for the SE implementation plan and these are

focussed to support implementation of community development projects. Details around the

SE objectives, stakeholder to be targeted and communication mediums to be implemented

are also provided.

SE Plan for the RAP Implementation

SE for the RAP is focussed on the RAP implementation. Sub tasks under the RAP

Implementation have been assigned specific SE activities, affected stakeholders and needed

engagement mediums to be utilised. In order to provide more context, notes under the SE

activities have been included where applicable.

Grievance Mechanism

Stakeholder issues need to be managed proactively and follow a structured approach where

stakeholders can raise their concerns and receive the needed feedback in a timeous manner.

A grievance mechanism is required according to the IFC Performance Standards 1, 2 and 4.

This grievance procedure, as provided in Appendix 2, consists of five main steps.

Step 1: Lodging a grievance

A grievance is lodged through the prescribed method i.e., Community Liaison Officers or

suggestion boxes where it will be evaluated to ensure that the potential risk of the grievance

is quantified. This evaluation will be completed using a measuring impact severity and impact

magnitude matrix. The grievance will be captured in a grievance issues database.

Step 2: Acknowledgement

Formal acceptance of receipt of the grievance will be provided to the aggrieved party and a

copy thereof will also be made available to this party. A reference number will be assigned.

Step 3: Investigation

The applicable investigation will be undertaken and where possible, grievances will be

resolved within 30 days of receipt.






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Step 4: Resolution and signoff

With completion of the investigation, the details thereof will be explained to the stakeholder

and a course of action will be proposed. Should this be accepted, then the grievance will be

closed formally and logged on the issues database. Should the proposed outcome not be

acceptable, then the grievance will go into mediation.

Step 5: Mediation

Grievances that could not be resolved would need to be investigated by a grievance

committee. An independent arbitrator needs to be appointed to address these grievances

which could not be resolved.






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TABLE OF CONTENTS

1 BACKGROUND ................................................................................................................ 1

1.1 INTRODUCTION ......................................................................................................... 1

1.2 SEP FRAMEWORK .................................................................................................... 2

1.3 PROJECT DESCRIPTION ............................................................................................ 2

1.4 PROJECT LOCATION .................................................................................................. 4

1.5 KEY CONTRIBUTORS ................................................................................................. 8

1.5.1 Stakeholder Identification and Analysis ............................................................ 8

1.5.2 Information Disclosure ..................................................................................... 8

1.5.3 Stakeholder Consultation ................................................................................. 8

1.5.4 Negotiation and Partnerships ........................................................................... 9

1.5.5 Grievance Management ................................................................................... 9

1.5.6 Stakeholder Involvement in Project Monitoring ................................................ 9

1.5.7 Reporting to Stakeholders................................................................................ 9

1.5.8 Management Functions ................................................................................. 10

1.6 CONTEXT OF THE SEP ............................................................................................ 10

2 STRATEGY ..................................................................................................................... 11

2.1 VISION ................................................................................................................... 11

2.2 GOALS ................................................................................................................... 11

2.3 OBJECTIVES ........................................................................................................... 11

3 REGULATION AND REQUIREMENTS .......................................................................... 12

3.1 NATIONAL AND INTERNATIONAL STANDARDS FOR STAKEHOLDER ENGAGEMENT ......... 12

3.1.1 Liberian Requirements for Stakeholder Engagement during the ESIA Process

12

3.1.2 International Finance Corporation (IFC) Performance Standards ................... 13

4 CONSULTATION ACTIVITIES UNDERTAKEN TO DATE ............................................. 14

4.1 APPROACH TO RELOCATION AND RESETTLEMENT FOR THE PROJECT ......................... 14

4.2 LAND ACQUISITION AND RESETTLEMENT COMPLETED FOR THE PROJECT- .................. 15

4.3 RESETTLEMENT ACTIVITIES ON-GOING FOR THE PROJECT ........................................ 15






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4.3.1 Key Issues Identified ...................................................................................... 18

4.4 ENVIRONMENTAL IMPACT STATEMENT...................................................................... 20

4.4.1 Summary of stakeholders consulted .............................................................. 20

4.4.2 Summary of SE activities ............................................................................... 21

4.4.3 Stakeholder Database ................................................................................... 21

4.5 INTERNAL STAKEHOLDER COMMUNICATIONS FOR THE PROJECT ................................ 21

5 ENGAGEMENT MEDIUMS ............................................................................................ 21

6 IMPLEMENTATION PLAN.............................................................................................. 24

6.1 CORPORATE STAKEHOLDER ENGAGEMENT PLAN ..................................................... 25

6.1.1 Stakeholder identification and plan for further consultation ............................ 25

6.1.2 Project Stakeholders ...................................................................................... 27

6.1.3 Approach to Stakeholder Identification ........................................................... 27

6.1.4 Stakeholder Groups ....................................................................................... 28

6.1.5 Internal Enablers for SE ................................................................................. 34

6.1.6 Management Functions ................................................................................. 42

6.2 SE IMPLEMENTATION PLAN FOR MINE LIFECYCLE ..................................................... 45

6.3 SE IMPLEMENTATION PLAN FOR ISSUES RESOLUTION ............................................... 56

6.4 SE IMPLEMENTATION PLAN FOR THE ESIA UPDATE .................................................. 62

6.4.1 Stakeholder Database ................................................................................... 62

6.4.2 Background Information Document ................................................................ 62

6.4.3 Presentation Posters ...................................................................................... 62

6.4.4 Stakeholder Meetings .................................................................................... 62

6.4.5 Comment and Response Report .................................................................... 63

6.5 SE PLAN FOR COMMUNITY DEVELOPMENT PLAN (CDP) IMPLEMENTATION ................. 63

6.6 SE PLAN FOR RESETTLEMENT ACTION PLAN (RAP) IMPLEMENTATION ....................... 68

1 GRIEVANCE MECHANISM ............................................................................................ 80

1.1 INTRODUCTION ....................................................................................................... 80

1.1.1 Step 1: Lodging a grievance .......................................................................... 81

1.1.2 Step 2: Acknowledgement ............................................................................. 83

1.1.3 Step 3: Investigation ...................................................................................... 83






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1.1.4 Step 4: Resolution and sign-off ...................................................................... 83

1.1.5 Step 5: Mediation ........................................................................................... 83

LIST OF FIGURES

Figure 1: Implementation Plan .............................................................................................................. 25

Figure 2: Liberian Authority Hierarchy .................................................................................................. 31

Figure 3: Proposed Organizational Structure for SE ............................................................................ 42

Figure 4: Impact Severity–Issue Magnitude Matrix ............................................................................... 82

Figure 5: Grievance Procedure ............................................................................................................. 84

LIST OF TABLES

Table 1: Summary of key stakeholder meetings ................................................................................... 16

Table 2: Summary of key issues identified ........................................................................................... 18

Table 3: Main RAP grievances and concerns received to date ............................................................ 19

Table 4: Engagement Mediums ............................................................................................................ 21

Table 5: Levels of Public Participation .................................................................................................. 26

Table 6: Internal Enablers for SE .......................................................................................................... 36

Table 7: SE Implementation Plan for Mine Lifecycle ............................................................................ 47

Table 8: SE Implementation Plan for Issues Resolution ....................................................................... 57

Table 9: SE Plan for Community Development Plan Implementation .................................................. 64

Table 10: SE Plan for RAP Implementation .......................................................................................... 69

Table 11: Grievance Mechanism as related to IFC Performance Standards ....................................... 80

LIST OF PLANS

Plan 1-1: Regional setting

Plan 1-2: Local setting






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LIST OF APPENDICES

Appendix 1: Draft stakeholder database

Appendix 2: Grievance Mechanism






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LIST OF ACRONYMS

Acronym Definition

BID Background Information Document

BMMC Bea Mountain Mining Corporation

CBOs Community Based Organizations

CDO Community Development Officer

CDP Community Development Plan

CIL Carbon in Leach

CLT Community Liaison Team

CRR Comment and Response Report

EIS Environmental Impact Statement

EPA Environmental Protection Agency

EPAL Environmental Protection Agency Liberia

EPML Environmental Protection and Management Law

ESIA Environmental and Social Impact Assessment

FDA Forest Development Authority

I&APs Interested and Affected Parties

IFC International Finance Corporation

KPI Key Performance Indicators

LEITI Liberia Extractive Industries Transparency Initiative

LRRRC Liberia Refugee Repatriation and Resettlement Commission

MoLME Ministry of Lands, Mines and Energy

NGOs Non-Governmental Organizations






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NLGM New Liberty Gold Mine

PS Performance Standard

RAP Resettlement Action Plan

ROM Run-of-Mine

SE Stakeholder Engagement

SEP Stake Holder Engagement Plan

TSF Tailings Storage Facility






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1 BACKGROUND

1.1 Introduction

Aureus Mining Incorporated (Aureus) wholly owns Bea Mountain Mining Corporation (BMMC),

a company registered in Liberia and which holds a Class A mining license to mine the New

Liberty Gold Mine (NLGM) deposit within Liberia. Aureus has identified the need to develop

and implement a Stakeholder Engagement Plan (SEP) and Grievance Mechanism to comply

with the requirements of the International Finance Corporation (IFC), and specifically that of

Performance Standard 1 (PS1), and to provide structure and guidance for on-going

engagement with stakeholders.

It is a requirement that a plan is prepared and implemented detailing how stakeholders are

identified and consulted with during the NLGM projects. This Stakeholder Engagement Plan

(SEP) has been designed to guide current and future stakeholder engagement activities within

Aureus Mining Inc. in relation to the project. In preparing this SEP, it is recognised that:

� Primary responsibility for engagement with stakeholders affected by the gold

production in the country lies with the Ministry of Land, Mines and Energy,

Environmental Protection Agency and Forrest Development Authority;

� Making drawings available and assisting with environmental / geospatial planning –

Ministry of Public Works and Ministry of Lands, Mines and Energy;

� Approval and managing the process for relocation of graves and heritage sites –

Ministry of Health and Social Welfare and Ministry of Internal Affairs;

� Approval of and guidance on Environmental and Social Impact Assessments (ESIAs)

– Environmental Protection Agency;

� Demarcation of lands and boundaries – Ministry of Public Works and Ministry of Lands,

Mining and Energy;

� Determining compensation for lands – Ministry of Agriculture and Ministry of Internal

Affairs;

� Involvement in the process of community resettlement – Ministry of Internal Affairs,

Ministry of Health and Social Welfare; Ministry of Public Works, Ministry of Agriculture,

Land Commission and Environmental Protection Agency;

� Assistance and guidance with development of the Community Development Plan –

Ministry of Health and Social Welfare, Ministry of Internal Affairs and Ministry of

Agriculture;

� The requirement for the diversion of rivers and water supply – Environmental

Protection Agency, Ministry of Internal Affairs, Ministry of Land, Mines and Energy and

Ministry of Public Affairs.






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The following sections detail the existing arrangements for stakeholder engagement for the

NLGM project and identify the actions that will be taken to establish a SEP that will be adopted

for use in planning and implementing mining activities. They provide:

� A description of the regulatory and other requirements for consultation and disclosure;

� A summary of the Liberian and IFC framework regarding public consultation, public

access to information and project disclosure, particularly in respect of activities

required under local permitting processes;

� A brief record of key consultation activities undertaken to date with respect to the

development of the NLGM project; and

� An identification of potential stakeholders identified for the Project.

� Implementation plans for further consultation and disclosure during the preparatory,

construction and operational phases of the project, including details such as the format

for effective and culturally meaningful interaction with different stakeholder groups; and

� Proposals for a grievance mechanism and a mechanism for addressing stakeholders

Comments

1.2 SEP Framework

The approach in the compilation of the NLGM SEP comprises six main components, namely:

� Background, which provides a brief description of the proposed project and describes

the contributors to be considered for successful development and implementation of

the SEP;

� Strategy, which describes the SEP vision, goals and objectives;

� Regulation and requirements, which provides an overview of the regulatory drivers;

� Consultation history, which summarises consultation activities undertaken;

� Engagement mediums, which describes proposed mediums to be used during

stakeholder engagement activities; and

� Implementation plan, which describes the various SE plans forming part of the SEP.

1.3 Project Description

The NLGM will involve an open pit gold mine (the first commercial gold mine in Liberia) that is

expected to operate for approximately eight years, with an ore production and treatment rate

of approximately 3,000 tonnes per day. The mining method will be conventional open pit

mining using excavators in backhoe configuration to load haul trucks. All material will require

drilling and blasting. According to current planning, the mining operation will be managed by

Aureus, with drill and blast, load haul and dump operations undertaken under contract.






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A gold processing plant is proposed to be constructed as part of the Project. The gold ore will

be treated through a conventional Carbon in Leach (CIL)1 process plant to produce gold bullion

which will be transported off site for refining. Waste will be deposited onto waste dumps

surrounding the mine pits. The tailings will be pumped to a Tailings Storage Facility (TSF).

Run-of-Mine (ROM) ore will be stockpiled on a ROM Pad, or delivered directly into a ROM bin.

The ROM stockpile will be reclaimed to the ROM bin by front-end loader. Water for the

processing plant will be sourced from the Marvoe Creek and holding dam. As the mine site

develops, return water from the TSF will be used in the processing plant. Power for the mine

and processing infrastructure will be supplied by diesel or heavy fuel oil generators.

The Marvoe Creek dissects the proposed mine pit areas, flowing in a general north-south

direction. A diversion of the Marvoe Creek is therefore required, which will involve a series of

interconnecting excavated channels and above ground constructed berms.

The ESIA update required that additional specialist studies be undertaken and amendment of

Environmental Impact Assessment and associated Management Programme for the project.

Changes to project layout and upgrades which have been assessed as part of the ESIA update

include the following:

■ Moving of the processing plant to the south;

■ Waste rock dump to be located around the pit instead of being located to the south of

the pit;

■ Tailings storage facility (TSF) to move to the south;

■ Marvoe Creek River Diversion (MCRD) alignment change with a change in the storage

dam capacity;

■ The upgrade of the Daniels Town – New Liberty main access road (the 21 km gravel

section of the road;

■ Storage dam;

■ Village Re-settlement site;

■ New mine camp;

■ Waste Landfill area (including the location of the incinerator);

■ Construction of a new access road from Jikando Village to the village re-settlement

site;

1 Carbon-in-Leach is a method of recovering gold through which gold is leached from gold ore pulp by cyanide and simultaneously adsorbed onto activated carbon granules.






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■ Re-alignment of the access road (re-alignment of the road is required as the road is

located within the open cast mine footprint); and

■ Construction of a truck stop and an associated access road.

Indirect benefits from the re-design and relocation of infrastructure include upgrading and

creation of support infrastructure in the area. Skills will also be transferred from individuals

that have been trained to aid in the development of small to medium businesses and providing

goods and services to the mine as well as potential educational programmes that will be

developed.

1.4 Project Location

The NLGM is located in the north-western portion of Liberia within the Gola Konneh District of

Grand Cape Mount County (see Plan 1-1). The Project is located approximately 145 km north-

west of the capital, Monrovia, and between longitude 7º30’ and 11º30’ west, latitude 4º18’ and

8º30’ north. Sinje and Daniels Town are relatively large towns located to the south of the

project area.

The NLGM area is about 8 km² in extent. It is situated within the south-western part of the

greater BMMC MDA area. Some of the villages located in the vicinity of the Project include

Kinjor, Larjor, Jikando and Jawajei (see Plan 1-2). These villages fall under the jurisdiction of

the Darblo Clan, while the respective town chiefs report to the General Town Chief, which is

located in Jene Brown. Kinjor and Larjor towns will be directly affected by the proposed NLGM

as they are currently located within the proposed mine pit.






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Plan 1-1: Regional setting






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Plan 1-2: Local setting

1.5 Key Contributors

SE is an umbrella term encompassing a range of activities and interactions over the life of the

project. These can be divided into eight key components which will be expanded on in different

sections of the SEP and are regarded as key contributors to the successful development and

implementation of the SEP. The contributors are detailed below.

1.5.1 Stakeholder Identification and Analysis

In Section 6.1.2 stakeholders are discussed in greater detail and profiles are provided where

available. Understanding stakeholders who will be impacted by, or who have the ability to

influence the NLGM, is vital for the engagement process. These stakeholders are driven by

specific interests, e.g. compensation, resettlement expectations, employment expectations,

regulatory compliance, environmental protection, social development etc. As the project

develops through the lifecycle interests of stakeholders will also shift, which could potentially

cause stakeholders to move from support for, to opposition against the project. For this reason

it is imperative to continue stakeholder identification and analysis throughout the mine’s life.

1.5.2 Information Disclosure

It is regarded as international good practice, referring to the IFC Performance Standards, to

ensure that information is provided to stakeholders in a way that would enable them to make

contributions meaningfully. These contributions are usually formalised during the feasibility

phase of a life of mine when impact studies are undertaken, but should be welcomed

throughout the life of mine. The SEP provides for various means of disclosure of information,

and what / where these should be used, is set out in detail in the seven components of the

Implementation Plan. Section 5 highlights the different mediums through which information

can be disclosed. The Internal Enablers also provides guidance on how information should be

managed and shared within the Organization.

1.5.3 Stakeholder Consultation

A brief history of the stakeholder consultations undertaken to date are described under Section

4. The approach to consultations going forward are encapsulated under the different

Implementation Plan components in Section 6. The proposed SE activities take into

consideration issues raised by stakeholders and have been developed to addresses the

specific requirements of the Mine Lifecycle, RAP, CDP, ESIA update and grievance

mechanism. It is important to note that through continuous stakeholder analysis consultation

methods and approaches can be amended to adapt to the changing interests of stakeholders.






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1.5.4 Negotiation and Partnerships

Negotiation and partnerships play an important role in the CDP since external support would

be required for the establishment of community development projects. In some instances

agreements which will affect people’s lives would need to be reached through a process of

negotiations e.g. resettlement compensation, land acquisitions, site selection, livelihood

restoration, development projects, etc. For many of these actions or initiatives, external

partnerships or support would be required, e.g. working in conjunction with the National

Housing Authority, Ministry of Public Works or Ministry of Agriculture to collectively decide on

a preferred approach for resettlement or identification of community development projects. SE

activities included in the Implementation Plan components will ensure that good relationships

can be developed in order to provide the needed support to future negotiations and

partnerships.

1.5.5 Grievance Management

The grievance mechanism developed as part of the Implementation Plan (see Appendix 2) is

proposed for the full lifecycle of the mine. Although implementation of a grievance mechanism

is a vital component of an Organization’s SE process, it must be said that resolving grievances

should be regarded as a last resort for SE; effective engagement with stakeholders need to

be able to pre-empt, proactively identify and resolve potential grievances or risks. More so,

effective implementation of a grievance mechanism and facilitation of grievances is reliant on

well-structured internal Organizational processes and information sharing channels. It is

important to note that part of the internal processes, the management of grievance records

and associated documents, e.g. attendance registers, grievance log, close-out notes, etc., are

vital to safeguard the Organization against any potential litigation.

1.5.6 Stakeholder Involvement in Project Monitoring

The various Implementation Plan components provide opportunities where stakeholders, and

specifically communities, can partake in discussions about project progress. In many cases

these take the form of feedback mechanisms such as suggestion boxes and grievances which

can provide the Organization feedback through an open channel to gather views and

comments on project progress. These are important throughout the mine lifecycle as it ensures

that the mine remains transparent and allows a participative process. Allowing stakeholders

to provide comments and participate holds strategic value since stakeholder and project risks

can be identified and addressed early.

1.5.7 Reporting to Stakeholders

Similar to stakeholder involvement in project monitoring, the implementation plan provides

various opportunities where Aureus need to provide feedback to stakeholders throughout the

mine’s lifecycle. Reporting back to stakeholders enables the Organization to resolve potential






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project risks which were identified as discussed in Section 4.3.1 and ensure that the

Organization can achieve its environmental and social objectives.

1.5.8 Management Functions

As part of the Corporate Stakeholder Engagement Plan (see Section 6.1) it is advised that an

internal team responsible for all SE and related functions be established (SE Activity 16 in

Table 6). Such a structure is proposed in Section 6.1 for consideration. The motivation for

establishing a well-defined structure is that structure needs to support strategy implementation

– the SE Implementation Plans described as part of the SEP needs to be implemented by an

internal team, supported by the Organization’s internal processes. This structure might need

to adapt and change as the NLGM progresses and interests of stakeholders shift.

1.6 Context of the SEP

The SEP is designed to provide guidance to NLGM in terms of engagement with external and

internal stakeholders during all phases of development. The SEP aims to:

� build on an understanding of previous Stakeholder Engagement (SE) activities

undertaken in the project area;

� identify stakeholders, concerns and interests to be engaged with;

� clarify the strategy for engagement with stakeholders with detailed goals and

objectives; and

� provide an Implementation Plan comprising of various components addressing

existing and future NLGM requirements.

Stakeholders include external Organizations/individuals and individuals/structures within

Aureus who may be affected by or have an interest in the project. These may include elected

representatives, government authorities and other public bodies, traditional entities, affected

people and their representatives, communities, commercial and community enterprises, non-

governmental Organizations (NGOs) representing environmental, social, labour, commercial

and other interests, academic and research Organizations, international bodies,

representatives of civil society or community based Organizations (CBOs), the general public

and administrative, operational and management employees of Aureus, stakeholders

associated with Lake Piso (including fishermen).

The SEP sets out the approach which the project will follow to implement a robust engagement

programme with all these different groups of stakeholders in accordance with Liberian

legislation, IFC Performance Standards and Aureus requirements. This SEP takes into

consideration and will build on SE activities undertaken to date.

The SEP is a live document which will be developed progressively and needs to be updated

as the project progresses through the various phases of planning and implementation by






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means of both lessons learned and understanding of the project and environmental / social

risks identified during the SE process.

2 STRATEGY

2.1 Vision

The vision for the relationship between NLGM and its stakeholders in this project is set out

below:

New Liberty Gold Mine: A trusted partner for sustainable development.

“NLGM and the Bea Mountain Mining Company will be recognised and welcomed as a

Liberian Mining Company contributing towards social, economic and environmental

development, with inclusion of all relevant stakeholders”.

2.2 Goals

Stakeholder engagement for the NLGM will be driven by the following goals:

� Attain a formal licence to operate by ensuring that all legal, regulatory and any other agreed good practice requirements are achieved; and

� Attain a Social Licence to operate by ensuring that stakeholders endorse and support NLGM’s presence and operations.

2.3 Objectives

The various engagement plans included in the SEP is aimed to achieve the objectives

provided below. These objectives are not highlighted individually within each plan, but rather

utilised as an overall umbrella to collectively drive effective stakeholder engagement.

1 Inclusivity: Pro-actively identify, analyse and include all relevant stakeholders in engagement

processes.

2 Stakeholder Concerns and Grievances: Respond to stakeholder concerns and grievances with a

view to seeking resolution in a timely manner.

3 Enable Participation: Facilitate stakeholders to engage willingly and freely. Also, aim to build

capacity of stakeholders to engage in the process

4 Internal Capacity: Create the required capacity to effectively engage with stakeholders, including the

necessary internal staffing, systems, skills and processes.

5 Sustainable Relationships: Create and maintain relationships with stakeholders that can allow for

mutual benefit and trust in the company.






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3 REGULATION AND REQUIREMENTS

3.1 National and International Standards for Stakeholder Engagement

The NLGM SEP takes into account the existing institutional and regulatory framework within

the context of Liberian Law. Applicable laws with relevance to land tenure and ownership, as

well as compensation and resettlement in Liberia are discussed below.

3.1.1 Liberian Requirements for Stakeholder Engagement during the ESIA

Process

The Environmental Protection and Management Law, 2002, (EPML) is the prominent

legislation in Liberia governing SE pertaining to feasibility studies and is utilised by the EPAL.

Section 11 of the EPML public consultations should be conducted prior to preparing an

environmental review or impact study or impact statement in order to:

� Identify, inform and obtain input from Interested and Affected Parties (I&APs);

� Identify significant environmental issues and alternatives related to the different phases

of the proposed project or activity early in the ESIA, in order to be adequately

addressed as part of the assessment;

� Ensure that SE takes place early in the ESIA process;

� Provide guidance to consultants responsible for completing the ESIA to prepare the

Environmental Impact Statement (EIS).

Sections 17 (Public Consultation for the ESIA) and 18 (Public Hearing) of the Environment

Protection and Management Law provides more detail to the SE requirements.

Section 17

For the purposes of section (16) (3) (b) above, the Agency shall:

a) By notice published for the consecutive days, invite comments from the public;

b) The public notice shall state the particulars of the project as set out in section (14) above;

c) The comments under sub-section (a) shall be received by the agency within 30 days of the publication of the notice or within such extended period as the Agency may grant by published notice.

Section 18

1) Upon receiving the comments of the public and the Line Ministry or other agencies to whom a copy of the environmental impact statement was sent, or upon the expiry of the period stipulated for receipt of comments, and on considering the opinion from the comments, the Agency shall decide whether to hold a public hearing and:






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a) The Agency shall hold a public hearing if five or more persons submit written request for a public hearing or if the agency determines that controversy about the project makes a public hearing necessary;

b) The public hearing shall be presided over by the County Environment Officer or a suitably qualified persons appointed by the Agency to be known as the presiding officer;

c) The public hearing shall be attended by the Agency and Line Ministry representatives, and relevant County Environmental Offices;

d) The public hearing shall be held at a venue which shall be convenient to the persons who are likely to be specifically affected by the project;

e) The date and venue of the public hearing shall be published;

f) On the conclusion of the hearing the presiding officer shall compile a report of the views presented at the public hearing and make factual findings;

g) The presiding officer shall determine the rules of procedure ground rules for the public hearing although any person may attend and make an oral presentation at the hearing within time limits to be determined by the presiding officer.

2) The applicant shall be given an opportunity to make a presentation and to answer presentations made;

3) The presiding officer shall collect all comments and make a record of the deliberations of the public hearing an as may be stipulated by the Agency;

4) The presiding officer shall make a summary report of all comments and the deliberations of the public hearing and forward them to the Agency within a reasonable time as may be stipulated by the Agency.

3.1.2 International Finance Corporation (IFC) Performance Standards

3.1.2.1 Introduction

In the development of the SE plan, guidance was taken from the International Finance

Corporation (IFC) including the SE Good Practice Handbook in order to adopt international

good practices for both the process of developing the plan as well as its structure and format.

3.1.2.2 IFC Performance Standard 1: Social and Environmental Assessment and

Management Systems (PS1)

IFC Policy requires project proponents to engage with affected communities through

disclosure of information, consultation, and informed participation, in a manner commensurate

with the risks to and impacts on the affected communities. PS 1 contains clear requirements

for community engagement, disclosure of information and consultation.

Objectives of IFC Performance Standard 1

■ To identify and assess social and environmental impacts, both adverse and beneficial,

in the project area of influence;






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■ To avoid, or where avoidance is not possible, minimise, mitigate, or compensate for

adverse impacts on workers, affected communities, and the environment;

■ To ensure that affected communities are appropriately engaged on issues that could

potentially affect them;

■ To promote improved social and environmental performance for companies through the

effective use of management systems.

3.1.2.3 IFC Performance Standard 5: Land Acquisition and Involuntary Resettlement

(PS5)

Although SE is not the main focus for PS5, it is regarded as an integral part of, and is functional

in, the application of the standard. Considering the main focus on this PS, the proponent needs

to engage with affected and host communities through the process of SE in PS1. Relevant

information should be provided and participation of these communities and persons should

continue during the planning, implementation, monitoring, and evaluation of compensation

payments, livelihood restoration activities, and resettlement to achieve outcomes.

Aureus has committed to implement resettlement in accordance with the applicable Liberian

laws and regulations, as well as IFC Performance Standard 5 (PS5): “Land Acquisition and

Involuntary Resettlement”. The NLGM RAP describes the objectives, principles, procedures

and measures that will be implemented prior to, during and after the resettlement of Kinjor.

A grievance mechanism, which is consistent with PS1, has been implemented. This will allow

the proponent to receive and address specific concerns about compensation and relocation

raised by displaced persons or members of host communities in a timely fashion, including a

recourse mechanism designed to resolve disputes in an impartial manner.

4 CONSULTATION ACTIVITIES UNDERTAKEN TO DATE

Majority of engagement with stakeholders has been associated with formal environmental

regulatory processes and divided into two main events, namely, SE for the EIS process

completed in June 2012 and the SE required as part of development of the RAP and CDP

during 2012/2013. The activities associated with SE are set out below.

4.1 Approach to Relocation and Resettlement for the Project

Development of the NLGM will require the resettlement of Kinjor and Larjor residents (2 077

people in January 2013), as well as the replacement or compensation of all dwelling- and

business structures, community facilities, economic trees agricultural fields, graves and

sacred sites located within the proposed mine footprint and associated 500m blasting zone.

In undertaking responsibilities for resettling individuals and households and in relocating public

facilities, NLGM have adopted the following principles, for purposes of the SEP specifically,

based on existing legislation and company policy:






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� Respect for civil and political, economic and social rights of citizens during the

relocation of settlements in accordance with international conventions and national

legal standards;

� The right to timely information on the terms and conditions of resettlement;

� The right to reasonable relocation deadlines;

� The right to full and timely information on legal and other rights in the process of

resettlement;

� Clear definition of obligations;

� Encouraging economic and social development programmes that will include support

for employment of local population; and

� Encouraging economic multi-functionalities of the area, i.e. the stimulation of

production and service activities in order to diversify the economic structure, to improve

the social and cultural development and maintain satisfactory environmental quality.

4.2 Land Acquisition and Resettlement Completed for the Project-

The Spatial Plan for the area of the ESIA prepared for the open cast mine identified the need

for expropriation of lands and buildings being used for the following purposes, namely:

� 150 acres on which the household structures to be constructed, including:

o agricultural land;

o forest land;

o cemetery;

o housing units;

o markets and workshop working areas;

o church mosque and schools;

o landfill and sewerage areas; and

o relocation of remains.

4.3 Resettlement Activities On-going for the Project

Strengthen the approach for future stakeholder engagement activities by:

� working closely with the Ministry of Health and Social Welfare, Ministry of Public Works,

Ministry of Internal Affairs, Ministry of Lands, Mines and Energy and Environmental

Protection Agency in identifying the stakeholders that may have to be resettled as a

result of any future expansion of the Mining;

� taking part in consultations entered into by the relevant Ministries;

� maintaining continuity between these consultations and the process of detailed

planning and funding relocation/resettlement activities in conjunction with the relevant

planning authorities;

� seeking engagement with NGOs and other interested and affected parties (with

particular emphasis on vulnerable groups); and






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� ensuring that all relevant stakeholders are identified and mapped in an updatable

stakeholder engagement database.

Stakeholder engagement activities for the RAP development expanded on the environmental

studies and SE process undertaken by Golder during 2011/2012 for the EIS (refer to the RAP

report). Table 1 below provides a summary of the meetings that were conducted for the RAP.

Table 1: Summary of key stakeholder meetings

Government ministries and agencies

� 27 November 2011 – Meeting with leaders (including women and youth leaders) of Kinjor and Larjor to

introduce the RAP study and timeline

� 28 November 2011- Environmental Protection Agency Liberia (EPAL) to conduct an introductory RAP

meeting

� 13 December 2011 – Meeting with County Superintendent, District Commissioner, Ministry of Mines

and Ministry of Civil Affairs, the County Member of Parliament, the Paramount Chief, Clan Chief, town

chiefs, community structures and representatives from civil society to introduce the RAP study to the

broader community and authority structures and to announce a moratorium on further development in

Kinjor and Larjor

� 9 March 2012 – Meeting with the Marvoe Development Association to find out about land ownership

and land rights concerning the land that Aureus is proposing to develop, as well as to identify

stakeholders of the Darblo clan

� 7 May 2012 – Meeting with the Superintendent of Cape Mount County to explain company plans and

intent to marry international standards and local norms

� 8 May 2012 – Ministry of Public Works: Zoning Inspectorate and Infrastructure Implementation Unit to

ask about legislation on national standards on housing in Liberia

� 8 May 2012 – Liberia Refugee Repatriation and Resettlement Commission (LRRRC) to ask what

procedures or processes should be followed in terms of policies that the LRRRC has in place;

� 8 May 2012 – Liberia Extractive Industries Transparency Initiative (LEITI) to ask what role LEITI would

play in the RAP process;

� 8 May 2012 – National Land Commission to ask what policies they have in place with regard to

resettlement

� 8 May 2012 – Meeting with the Ministry of Agriculture to ask if there are approved price listing for crops

for compensation purposes

� 11 May 2012 – Meeting with General Town Chief to introduce the Project and the RAP, and to ask

about land acquisition

� 11 May 2012 – Meeting with the Paramount Chief and District Commissioner to ask where to relocate

the communities of Kinjor and Larjor, as well as how to proceed with land acquisition

� 16 November 2012 – Meeting with the Ministry of Agriculture to discuss the RAP and CDP

� 15 June 2013 – Meeting with EPAL to discuss the grave relocation programme

Affected parties

� 26 November 2011 – Meeting with Jikando and Jawajei leaders to introduce the Digby Wells/Earthcons

team






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� 27 November 2011 – Meeting with Kinjor and Larjor community to introduce the RAP study and

timeline

� 13 December 2011 – Community meeting to introduce the RAP study to the broader community and

authority structures, to initiate the RAP process and announce a moratorium on further development in

Kinjor and Larjor

� 20 January 2012 – Meeting with the Kinjor and Larjor to compile the RAP Committee

� 8 February 2012 – Meeting with the RS Committee to discuss the roles and responsibilities of the

committee and to receive grievances from the community;

� 28 February-1 March 2012 – Asset survey conducted of all affected private and community structures

within Kinjor and Larjor

� 8-9 March2012 – Meetings with the Chief, Mining Chairman, Imam, Pastor, Youth Chairman, Chairlady

and School Principal to discuss their roles in the community

� 10 May 2012 – Meeting with Resettlement Committee (RC) to explain the next step of the RAP

process, i.e. agricultural survey and asset voucher sign-off

� May 2012 – Agricultural survey conducted where all fields within 500 meter blasting zone were

surveyed, counted and measured for compensation purposes

� May 2012 – Asset vouchers were signed by affected individuals to verify the information gathered from

the Asset survey

� May 2012 – Workshops were held with the RAP Committee to discuss the following: Resettlement site

selection, house design and town layout, and a livelihood restoration plan

� 14 May 2012 – Consultation with EPAL director to discuss if a separate EIA should be conducted for

the resettlement site

� 19 May 2012 – Meeting with Jikando elders to discuss if Jikando will be resettled or not

� August 2012 – Agricultural voucher were signed by affected individuals to verify the information

gathered during the Agricultural survey

� August 2012 – A Grave registration was conducted to verify the location of graves within the affected

areas and to collected information pertaining to these graves

� 13 August 2012 – A workshop was held with RC to discuss the first draft of the town layout and house

design

� 15 September 2012 – Kinjor and Larjor community meeting to discuss town layout and design after the

first draft was presented. Town layout and house designs were agreed upon by the community and

subsequently signed off.

� 26 October 2012 – Meeting with the RC to explain the reason for the visit and the next steps in the

process i.e. Census, Grave voucher sign-off, Business owner interviews.

� 29 October 2012 – Meeting with grave owners to discuss the graves, next steps and what

requirements are needed for the grave relocation

� 26 March 2013 – Meeting with RC to show the new mine plan and announce a moratorium on the

affected areas

� 29 March 2013 – Meeting with Jawajei elders to discuss the damage to the sacred site on the river

diversion

� 10 May 2013 –Meeting with three members of the RC to discuss the location of grave relocation site.

� Week of 10 to 14 June 2013 – Meetings with RC to finalise compensation packages, revised town

layout plan and additional compensation option






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� Week 10 to 14 June 2013 – Meetings with RC and relatives of affected graves to discuss grave

relocation aspects

� August 2013 – Meetings with EPA to discuss grave relocation procedures

� 15 October 2013 – Meetings with RC to agree on the terms and conditions for temporary resettlement

of Kinjor and Larjor to accommodate NLGM project schedules (Memorandum of Agreement signed

� On-going: Meetings between Aureus CLO and RC

� On-going: Weekly meetings where possible between RC and Aureus

4.3.1 Key Issues Identified

Comments raised by stakeholder through the consultation process provided insight to various

issues applicable to the proposed project. These need to be managed proactively and in many

cases, effective communication and participative approaches when engaging with

stakeholders will prevent issues becoming grievances. In Table 2 below, these key issues are

listed and described. The proposed SE Implementation Plan for resolution is discussed as

part of Table 8 where each of the issues raised are addressed.

Table 2: Summary of key issues identified

No Issue Description

1 Availability of clean

drinking water

People use water for own consumption and that of their livestock. High

dependence on boreholes and hand pumps – it is expected from other

parties to provide this infrastructure.

2 Timber cutting regarded

as important means of

livelihood

People, usually men, make a living from logging and the mine’s

presence might be perceived as a threat to their future and ability to

provide since fields might be cleared.

3 Uncertainty about the

project’s impact on the

livelihoods of community

members

With high illiteracy levels it is difficult for people to envisage what the

mine will look like and how they will be affected. Because of this,

uncertainty is created around their future and food security.

4 Loss of artisanal mining This is regarded as a good form of income generation and people will

be more inclined to defend their “rights” to mine at specific areas.

5 Impact of project on forest

reserves

How much land will be used for mining operations and how will it be

managed is an important concern of the FDA.

6 Increased community

expectations

These expectations revolve mainly around social development

initiatives and employment opportunities.

7 Land belongs to the

communities / people

Everything above ground is regarded to belong to the people, hence,

communities. The FDA, Ministry of Internal Affairs and Land

Commission is well aware of this and people need to be consulted

before major decisions are taken that impact the environment.






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No Issue Description

8 Uncertainty around

displacement

Various aspects of people’s lives will be impacted and they aren’t

always sure how and when this will happen. The extent thereof and

their means to recourse are usually uncertain also.

9 Legacy commitments not

addressed

Promises were made by previous companies and not fulfilled. This

causes doubt and in some cases fear associated with a new company

engaging people.

10 Alignment between

Ministries

Ministries do not always engage with each other on matters that would

be beneficial to the project. Because of this important messages and

information are often lost, which causes misunderstanding and in some

cases, wrong decisions to be taken.

Specific concerns and issues identified and addressed during the development of the RAP

are discussed in Table 3 below.

Table 3: Main RAP grievances and concerns received to date

Grievance and/or concerns Comment

There are too many community meetings. Aureus should

proceed as soon as possible

Focus is now on weekly meetings with RC.

Community meetings will be called as

required.

Aureus should do more to provide employment, training,

bursaries to the Kinjor/Larjor affected people

Aureus has already, and will continue to

establish local employment projects as part

of the RAP and general NLGM

construction activities. Aureus will, through

its CDP and CSR Projects, promote

training and scholarships for affected

people

Individual claims that property owner was not present

during asset survey. Requested that Aureus should accept

late claims (i.e. claims received after the survey cut-off

date)

No claims were accepted after the RAP

cut-off date as was agreed with the

community and authorities

Individual claims that the asset survey did not record all

rooms/economic trees/graves

Claims were investigated and records were

adjusted if claims proved to be correct

Individual claims with regard to ownership of certain

properties

Claims were investigated and records were

adjusted if claims proved to be correct

Concerns with regards the placement and number of toilets

allocated at resettlement site

Aureus held several meetings with RC to

address this concern. An agreement was

reached based on environmental and cost

considerations

Tree compensation should be paid prior to resettlement Agreement was reached that

compensation payments will involve two

instalments, the first of which will be paid

prior to physical resettlement

There are too many consultations with regards the grave

relocation. People do not want to be involved – as long as

existing graves are not reburied at the resettlement site

Agreement was reached with affected

families and no further consultations are

required






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Business owners should not be penalised for the fact that

some run unregistered businesses from their house

This was agreed with RC and business

owners

The Resettlement Committee does not adequately

disseminate information to the community

The NLGM CLO and RC will ensure

adequate dissemination. This process will

be recorded in the RC minutes

Grievance lodged with regard to damage to sacred site by

NLGM contractor

A (written) agreement was reached with

the affected parties. All conditions have

been met by Aureus and compensation

payments have been made

Request assurance that temporary relocation will not alter

the entitlements of the RAP

Resettlement will be implemented in

accordance with the RAP. All RAP

entitlements will be honoured

4.4 Environmental Impact Statement

Volume 1 of the EIS, Section 14, contains information about the relevant SE activities that

were conducted as part of the EIS process. Further details to these consultations are provided

below:

4.4.1 Summary of stakeholders consulted

National government

� Environmental Protection Agency of Liberia;

� Ministry of Lands, Mines and Energy;

� Forestry Development Authority (EIA Department, Conservation Department, GIS

Department);

� Hydrological Service of Liberia; and

� Ministry of Internal Affairs.

Regional and district government

� Superintendent of Grand Cape Mount County and her representatives.

Community stakeholders (i.e. the public, including the chiefs, their elders and

representatives, youth group leaders, women’s group leaders and the general population in

each village) were consulted at the following locations:

� Mecca, Cape Mount County;

� Kinjor and Larjor Villages;

� Jawajei Village; and

� Sinje Town.

Environmental bodies, both authorities and NGOs, (for example, Conservation International)

and the media.






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4.4.2 Summary of SE activities

Project announcement

� Formal announcement of the project in September 2010 by means of a letter with

comment sheet and Background Information Document (BID).

� Radio announcement on 17 September on Radio Cape Mount for two weeks.

� Announcement materials were available on the Golder website

(www.golder.com/public).

� Three community meetings and five focus group meetings were held during this phase.

� BIDs and announcement letters were distributed at the following locations:

� Ministry of Lands, Mines and Energy, Monrovia;

� Forestry Development Authority, Monrovia;

� Ministry of Internal Affairs, Monrovia;

� Environmental Protection Agency, Monrovia;

� Mecca Village, Grand Cape Mount County;

� Kinjor Village, Grand Cape Mount County;

� Jawajei Village, Grand Cape Mount County;

� Radio Cape Mount; and

� EarthCons Offices, Monrovia.

4.4.3 Stakeholder Database

A draft stakeholder database has been compiled by making use of stakeholder information

gathered during the EIS development (undertaken by Golder in 2011 – 2012) as well as during

consultation undertaken by Digby Wells as part of the RAP development in 2012 – 2013. This

draft database is included in this document as Appendix 1. This database will however need

to be maintained and updated on a continuous basis, according to the guidelines set out in

Table 66 in Section 6.1.5.

4.5 Internal Stakeholder Communications for the Project

NLGM will ensure that a transparent procedure for both internal and external communications

is in place. Means for internal communications include formal and informal meetings with

workers, bulletin boards, and boxes for suggestions. Employees will be able to make

confidential comments.

5 ENGAGEMENT MEDIUMS

Table 4 below lists the spectrum of engagement mediums that would be applicable for SE

activities proposed as part of the various Implementation Plan components (see Section 6).

Table 4: Engagement Mediums






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Medium Description

Stakeholder meetings

Structured

agenda

This agenda is developed in association with the relevant stakeholders partaking in the

forum. It encourages participation and a sense of ownership in the SE process. Putting a

focussed agenda together will ensure that key strategic and risk items can be discussed

with important decision-makers and influencers in an effort to mitigate risk proactively.

Focus group

meetings

The aim of a focus group is to pull together stakeholders with the same interest into a

single meeting to discuss commune issues. Meetings usually have a very specific

objective which is aligned with the expectations and interest of the stakeholders present.

Workshops Workshops are ad-hoc outcomes based meetings and seek to find solutions for specific

issues facing the environment, social aspects and the project. In many instances, issues

identified through the ESIA process or Grievance process will be tabled at such a

workshop.

Forum A forum is established with specific set objectives and would comprise of a specific group

of stakeholders who would need to ensure that actions are taken and monitored.

One-on-one

consultations These consultations are focussed to identify and discuss stakeholder concerns or to

provide feedback using detailed information.

Written / visual communication

Report with

structured

content

This needs to be a short and concise document providing factual information of the

following:

� Project progress (Mine lifecycle)

� Concerns / issues resolved

� Social development programmes

� Employment process and statistics

� Engagement activities undertaken

� Planned activities going forward

Community

notice boards

Community notice boards are a good tool to use for communication of job opportunities,

and to inform communities of events, ensure transparency, build branding and addresses

challenges around illiteracy.

Suggestion

boxes

Critical tool for the successful implementation of the Grievance Mechanism. It must be

located at a central place, accessible to community members, and agreed upon upfront

by the community leadership. Suggestions boxes must be managed proactively and

continuously, whereby feedback is given either in the applicable stakeholder meeting or

via notice boards.

Maps Maps are effective when placing into context well known locations, linear and single site

developments, change of fixed locations for developments, location options for

developments and anticipated distances between developments or well-known locations.

Models /

examples

In many cases complex concepts need to be conveyed to an audience that has low levels

of literacy. Using physical examples in the form of small scale models or actual full size

examples of what will be developed or implemented provides accurate detail and dispels

any pre-conceived perceptions from stakeholders.






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Medium Description

Surveys Surveys can be used for various reasons, but should be managed carefully considering

the needed authorisation from village leadership. Stakeholder fatigue must also be kept in

mind since majority of community members are illiterate. Surveys can also be

misconstrued with job opportunities and it is very important that the intention and

outcome of surveys are clearly communicated before starting.

Letters Formal method of communication usually intended to convey very specific messages.

Alternatively, it is used as a formal method for request of information, and in Liberia,

stakeholder meetings are arranged by means of formal letters being submitted by hand.

Emails Using emails for in-country stakeholders can pose a challenge because of limited internet

access due to insufficient telecommunications and/or supporting IT infrastructure. NGOs

and most of the Government Ministries do have access to email which can be utilised for

communications, but arranging of formal meetings still requires hand delivery of letters.

Print materials Print materials will be in many cases the most frequently used medium when messages

are conveyed, especially when engaging with communities. In this instance materials

needs to include many pictures and limited writing, because of high illiteracy levels, and

should be kept as concise as possible. Materials needs to always take into consideration

the cultural context, specifically when disseminated, since making materials available to

stakeholders might need to follow a pre-established hierarchy / flow. Print materials can

include, but isn’t limited to:

� Letters

� Background Information Document (BID) (A5 or A4 size)

� Posters / notices (A3 or A2 size)

� Pamphlets (A5 size)

� Newsletters (A4 or A5 size)

Newspapers /

adverts

Newspapers are usually best suited for formal announcements or to reach a wide

spectrum of stakeholders quickly. It is however very important that the message content

is carefully compiled since it is a one-way communication medium and can quickly cause

misunderstanding or confusion if not clearly written.

Process Driven

Awareness

creation

campaigns

The nature of these campaigns is directly related to the objective to be achieved; whether

it be capacity building, information sharing, preparing for SE activities to follow etc. The

mediums discussed in this table can be utilised to aid in fulfilment of the objective.

Community

capacity

building

initiatives

These vary from notice boards, to information kiosks, to structured focus group meetings,

to dissemination of ad-hoc visual materials with minimal text.

Grievance

records

Grievance notes form an integral part of formal feedback from stakeholders and can

provide an indication of their expectations and underlying intentions. These records need

to be kept on file or in a database to prove that grievances were received and processed

should an audit be done. Keeping grievance notes will enable CLOs to analyse trends

over a period of time in order to track effectiveness of the existing grievance management

process.

Media






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Medium Description

Radio Radio is a good medium to stimulate awareness and prepare stakeholders for larger

events or refined communication to take place.

Online media Online media includes Facebook, Twitter, Blogs and various news sites. It is mainly

aimed to monitor media coverage about Aureus activities, identify industry trends and

risks and to establish what current opinions are about the company. This medium can

also be used to push positive messages out or to proactively address underlying issues

identified through media monitoring.

Other

Community

Liaison Team

(CLT)

The community liaison team is an extension of the Organization and is in many cases the

only real channel from where stakeholders can gain more understanding of the mine’s

activities and intensions or where they can seek resolution. The team also contributes

towards to building the Organization’s brand and the stakeholders’ perception of the

company. If information, issues and underlying intentions are gathered and identified by

the team, it will enable decision-makers in the Organization to gain a better

understanding of potential social and project risks.

Telephone Use of the telephone / mobile phone is still regarded as the preferred method for

communication because of accessibility and speed. Having a discussion over a phone in

order to ensure mutual understanding between two parties is quicker and easier

compared to sending an email, waiting for reply. The effectiveness of telephones during

the SE process are limited though considering that mobile phones signals aren’t always

available at communities and engagement with Authorities still require formal letters.

6 IMPLEMENTATION PLAN

The Implementation Plan for the SEP constitutes various components (see Figure 1) focussing

on internal Organizational capacity and various implementation plans, each with a different

focus. In this section the following is documented:

� Corporate Stakeholder Engagement Plan;

� SE Implementation Plan for the Mine Lifecycle;

� SE Implementation Plan for Issues Resolution;

� Grievance Mechanism;

� SE Implementation Plan for the ESIA Update;

� SE Implementation Plan for the Community Development Plan (CDP); and

� SE Implementation Plan for the Resettlement Action Plan (RAP).






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Figure 1: Implementation Plan

6.1 Corporate Stakeholder Engagement Plan

6.1.1 Stakeholder identification and plan for further consultation

Stakeholder engagement is recognised as an essential component of the appraisal,

management and monitoring of environmental and social issues associated with NLGM’s

programme.

NLGM consider stakeholder engagement to be an essential part of good business practice

and corporate responsibility, as well as providing a positive mechanism by which to improve

the quality of the Project. NLGM also recognise that effective community engagement is

central to successful management of risks and impacts on project-affected communities, as

well as promoting enhanced community benefits.

To this end, stakeholders have been identified for the preparation and operational phases of

the proposed Project. They include groups that:

� Have an interest in the project and its operations;

� Are affected by the Project;

� Have the ability to influence or affect the project and its operations.

� Stakeholders could be individuals and Organizations that may be directly or indirectly

affected by the Project either in a positive or negative way, and who may wish to

express their views.

Although the Liberian Ministry responsible for Lands and Mines has the primary responsibility

for identifying lands and properties that would need to be expropriated to allow the gold and

other mineral resources production, NLGM will undertake consultation additional to that

required by the disclosure process of the Liberian government.






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The key national stakeholders have been identified in the ESIA and SEA documents relevant

to the Project: however, as part of the identification of other relevant stakeholders, emphasis

is given to the direct effects/impacts on stakeholders, such as households that may need to

be resettled and other stakeholders that may be indirectly affected, including NGOs. The key

stakeholder groups identified for the NLGM project are detailed in Section 6.1.4.

In the context of public participation, a stakeholder can be defined as any person, or group,

who has an interest in the project or could be potentially affected by its delivery or outputs.

Each of these persons or groups require a specific level of participation throughout the project

lifecycle. These public participation levels can be broadly categorized as indicated in Table 5

below.

Table 5: Levels of Public Participation

Levels of Public Participation Goals

Level Description Stakeholders

Inform To provide the public with balanced and objective information to assist them in understanding the problem, alternatives, opportunities and/or solutions.

� Commenting authorities e.g. Ministry of Finance and/or Planning and Economic Development

� Internal stakeholders � International Organizations � Commerce and Industry � Communities / traditional leaders

Consult To obtain public feedback for decision-makers on analysis, alternatives and/or decisions.

� Social NGOs � Environmental NGOs � Commerce and Industry � Civil society � Communities / traditional leaders � Commenting authorities e.g. Ministry

of Finance and/or Planning and Economic Development

Involve To work directly with the public throughout the process to ensure that public concerns and aspirations are consistently understood and considered in decision making processes.

� Social NGOs � Environmental NGOs � Civil society � Communities / traditional leaders � District / County authorities � EPA / FDA � Liberia Refugee, Repatriation and

Resettlement Commission � Ministry of Health and Social Welfare � Ministry of Public Works � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Land, Mines and Energy

Collaborate To partner with the public in each aspect of the decision including the development of alternatives and the identification of the preferred solution.

� Marvoe Development Association � Internal stakeholders � Communities / traditional leaders � District / County authorities � EPA/ FDA � Ministry of Internal Affairs

Empower To place final decision-making in the hands of the public.

� Communities / traditional leaders � Internal stakeholders






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* It is noted that stakeholder groups might be categorized under different or more than one level(s) simultaneously, depending on the project phase or engagement activity.

6.1.2 Project Stakeholders

For the purposes of the SEP, a stakeholder is defined as a person or group who has an interest

in a particular decision or activity, either as an individual or as a representative of a group.

This includes people who influence a decision, or can influence actions, as well as those

affected by it2.

The objective of stakeholder identification is to establish which Organizations and individuals

may be directly or indirectly affected (positively and negatively), or have an interest in the

project. Stakeholder identification is an on-going process, requiring frequent review and

updates.

6.1.3 Approach to Stakeholder Identification

In order to develop an effective SEP, it is necessary to determine who the stakeholders are

and understand their needs and expectations for engagement, and their priorities and

objectives in relation to the NLGM. This information is then used to tailor engagement to each

type of stakeholder. As part of this it is particularly important to identify individuals and groups

who may find it more difficult to participate and those who may be differentially or

disproportionately affected by the project because of their marginalised or vulnerable status.

It is also important to understand how each stakeholder may be affected – or perceives they

may be affected – so that engagement can be tailored to inform them and understand their

views and concerns in an appropriate manner.

For the NLGM project stakeholders have been and will continue to be identified on a continuing

basis by:

■ Identifying the various categories of parties who may be affected by or interested in the

project; and

■ Identifying specific individuals or Organizations within each of these categories taking

into account:

� The expected area of influence of the Project, that is the geographical area over

which it may cause impacts (both positive and negative) over its lifetime, and

therefore the localities within which people and businesses could be affected;

� The nature of the impacts that could arise and therefore the types of government

bodies, non-governmental Organizations, academic and research institutions and

other bodies who may have an interest in these issues.

2 Reference is made to the IFC definition, 2007






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The process of identifying the individual and Organizations within each group is a continuing

one. To date a large number of potentially affected and interested parties have been identified

from:

■ Contacts that the project has already made with communities, government departments

and other Organizations as part of its public consultation, disclosure and government

interaction to date;

■ Undertaking of the RAP and CDP consultations; and

■ Consideration of the area of influence of the project insofar as it is currently defined in

the ESIA.

6.1.4 Stakeholder Groups

Stakeholder groups applicable to the proposed project are listed and described below. For the

Liberian Government, Figure 2 provides a hierarchy of authority.

6.1.4.1 National Government Authorities

National authorities are defined as those agencies of the Liberian Government who have the

power to regulate or influence the Project in terms of establishing policy, granting permits or

other approvals for the Project, and monitoring and enforcing compliance with Liberian Law

throughout the mine lifecycle. It is essential to engage and establish a continuing dialogue with

these national authorities at an early stage.

6.1.4.1.1 The Ministry of Lands, Mines and Energy

The Ministry of Lands, Mines and Energy (MoLME) is tasked to protect the sustainable

management and utilisation of the country’s lands, mines and energy resources. The Ministry

is mandated to ensure that all issues pertaining to the environmental and social aspects

related to mining operations are satisfied when a mining permit is issued. They are also

responsible to demarcate political boundaries and work closely with the Land Commission in

this regard. It is important to note that a license from the EPAL would first need to be obtained

before the MoLME will provide subsequent authorisations. It has been noted through

interviews that the MoLME can play a more active role in disseminating information to the

public and monitoring on-going mining activities.

6.1.4.1.2 Ministry of Internal Affairs

This Ministry oversees local governance, including interaction with traditional authorities over

land matters. The Ministry oversees and coordinates the activities of county superintendents,

who are assisted by district commissioners. The latter are assisted by paramount, clan and

general town chiefs. The Ministry of Internal Affairs (MoIA) is knowledgeable on cultural and

traditional aspects, specifically relating to communities. The Land Commission falls under the

MoIA, and it is understood that this Commission is in the process of establishing the needed






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structures for effective operations. The Land Commission works closely with the MoLME and

is responsible for the settlement of land disputes once demarcation is done.

6.1.4.1.3 Ministry of Agriculture

This Ministry oversees the agricultural lands sector and has established regulations whereby

equitable and just compensation are paid for the destruction of economic trees as a result of

government projects.

6.1.4.1.4 Ministry of Planning and Economic Development

This is the department of the Government of Liberia responsible for coordinating overall

development planning for the country. It is understood that this Ministry is in the process of

merging with the Ministry of Finance in an effort to streamline planning and resource

allocation functions.

6.1.4.1.5 Ministry of Public Works

This Ministry is responsible for land-use zoning and enforcement of government construction

and building standards. It has the responsibility to approve the design and construction of all

civil works. In addition, it undertakes urban and town planning and provides architectural and

engineering supervision for the construction of civil structures and waste management. The

Ministry of Public Works (MoPW) works closely with the MoLME and MoIA on zoning for cities.

In some cases the MoPW will liaise with the EPAL to determine environmental impacts or

provide comments on the latter.

The various procedures and standards prescribed by the Zoning Inspectorate, Infrastructure

Implementation Unit and Rural Housing Division of the Ministry of Public Works respectively

will be adhered to in the implementation of the NLGM SEP.

6.1.4.1.6 Ministry of Health and Social Welfare

This Ministry has a Department of Environmental and Occupational Health which manages

matters relating to water and sanitation as well as general environmental issues. Its mandate

requires that sanitary and working environments are conducive for all in the workplace, and

that the health and safety of workers and nearby residents are ensured. The Ministry would

be interested in how Aureus can assist with the development of health programs and building

of clinics. This ministry also needs to be involved with the relocation of graves and or remains.

6.1.4.1.7 Environmental Protection Agency of Liberia

The EPAL is responsible for the monitoring, coordination and supervision of the sustainable

management of Liberia’s environment. It is mandated to oversee the implementation of

environmental impact assessment for projects and activities that are likely to have significant

adverse environmental and social effects.






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The EPAL is further mandated to promote the preservation of important historic, cultural and

spiritual values of natural resources heritage and, in consultation with traditional authorities,

enhance indigenous methods for effective natural resource management. The EPAL works

closely with the Forest Development Authority (FDA) on aspects relating to Fauna and Flora.

6.1.4.1.8 Forest Development Authority of Liberia

The Forrest Development Authority (FDA) has been empowered by the Liberian Government

to address aspects relating to forest management / protection, biodiversity issues and manage

protected areas, all in conjunction with the EPAL. The FDA becomes involved when forest

areas needs to be cleared and intervenes when commercial arrangements need to be

formalised when local logging operations are impacted. This authority is also responsible to

provide a license for any clearing of fields.

6.1.4.1.9 Liberia Refugee, Repatriation and Resettlement Commission

The Liberia Refugee, Repatriation and Resettlement Commission (LRRRC), was established

as part of Liberia’s post war reconstruction programmes. As the name indicates, the LRRRC

is primarily concerned with the plight of war refugees. However, the Commission has also on

occasion taken on an oversight role for resettlement related to infrastructure projects. During

discussions with the LRRRC, it was advised that the NLGM consult the Commission on

matters related to resettlement.

6.1.4.2 County / District Authorities

Key role-players at the county and district levels are the offices of the County Superintendent

(County Planning), and the District Commissioner respectively. Both institutions are directly

involved in matters relating to land acquisition and town planning. In this, they are supported

by general town chiefs (representing towns within a particular area), who in turn are assisted

by the towns chiefs of the respective towns. A structure of the Local Government is provided

in the left-hand column in Figure 2 below.






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Figure 2: Liberian Authority Hierarchy

6.1.4.3 Traditional Authorities

Traditional authorities are directly involved in customary land administration in their areas of

jurisdiction, as well as in upholding cultural traditions, norms and practices. These authorities

include the offices of paramount chiefs and clan chiefs, who are assisted by a council of elders.

A diagram of the Traditional Authority hierarchy is provided in the right-hand column of Figure

2.

6.1.4.4 Marvoe Development Association

The Marvoe Development Association represents the towns of Jawajei, Gblein, Dieyili and

Jene Brown which are the deed holders (through the Darblo Clan) for portions of land located

within the NLGM area. The deeded land includes the locations of Kinjor, Larjor and Jikando

villages.

6.1.4.5 Project Affected Communities and Individuals

This group includes all people who may be directly or indirectly affected by the NLGM’s

presence. It includes communities located on land affected by the mine, communities adjacent

to the mine, as well as communities to be resettled and host communities receiving resettled

people.

As indicated earlier, the villages that will be directly affected by the project are Kinjor and

Larjor. Administratively, Kinjor is divided into three quarters, each with its own quarter chief

who report to the Kinjor Town Chief. Given the small size of the Larjor community (10 houses),

it is administered as a fourth quarter of Kinjor. However, Larjor Town has its own Town Chief






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with the same powers as the Kinjor Town Chief. Artisanal miners from Kinjor and Larjor are

represented by the Mining Committee Chairman.

The composition of the Kinjor Town Council consists of the following representatives:

� Six elders (councillors), one of which is the Dean Elder;

� Quarter chiefs and quarter elders;

� Religious leaders (Pastor and Imam);

� Education (Kinjor school principal);

� Women and the youth;

� Mining chairman;

� Marvoe Development Association; and

� Zoe Elder (priest representing Poro and Sande3 traditional societies).

Notes: There is potential for generating unfounded expectation of the level of compensation

that could be claimed and many stakeholders could be unaware of their rights to

compensation, how to register a grievance and how to obtain a fair settlement and additional

help that may be available to vulnerable individual or households.

6.1.4.6 Civil Society and Non-Governmental Organizations

This group includes smaller groups in society who may have an interest in the NLGM and its

social and environmental aspects, as well as NGOs representing particular interests. It

includes members of the wider general public in Liberia and further afield, civil society

Organizations such as religious groups, cooperatives, professional associations, cultural

groups, citizens’ associations as well as environmental and social groups. It also includes

universities and other academic and research institutions undertaking work relevant to the

NLGM project (e.g. on mining, sustainability, social and environmental issues, local and

regional development, etc.) who may have views on the project or information that will be

useful for the assessment and management of project impacts.

Opportunities for their participation in the project will be provided by direct contact with known

groups, and by wide publicity for the SEP and events enabling other groups and individuals to

make contact with the NLGM.

Consultation with civil society and local, national and international NGOs representing groups

and interests that may be affected by the project will be crucial to a credible ESIA process.

There are several Environmental and Social NGOs in Liberia who are actively involved with

communities and government entities to ensure that the environment and affected persons

are given a voice.

3 Traditional (‘secret’) societies for men (Poro) and women (Sande); these societies are actively involved in the preservation of cultural values and practices, as well as in the initiation of boys and girls.






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Notes: The public / civil society may be impacted through changes to the wider economics of

the region changes to the use of the public road.

6.1.4.6.1 Environmental NGOs

� Fauna and Flora International

� Society for the Conservation of Nature

� Conservation International

Notes: It would be important to establish and sustain communication with NGOs.

Environmental principles followed by Aureus needs to monitored constantly to ensure that the

correct image and messages are portrayed.

6.1.4.6.2 Social NGOs

� Green Advocates

� Independent National Commission on Human Rights

� Sustainable Development Institute

� Merlin

� The United Nations Children’s Fund (UNICEF)

6.1.4.7 Commerce and Industry

A range of different types of commercial Organizations may be interested in the project

including:

■ Local entrepreneurs in the immediate project area (including companies and individual

farmers, traders, merchants, etc.); and

■ Entrepreneurs and businesses from elsewhere in Liberia who may gain benefits by

providing goods and services to the NLGM and participating in social investments by

the Project.

These Organizations will be contacted through their local communities and via associations

representing business and industry.

Notes: Key individual businesses might be directly affected by the mine and business

Organizations/agencies should be identified having direct interest in the Project and

participating in the tendering procedure. Quality gold production will influence negative

environmental impact reduction.

6.1.4.8 International Organizations

Various international Organizations may have an interest in the NLGM project and may have

useful information/ knowledge or insight into local and national issues of relevance to the

project. These include UN agencies, as well as African and West African and other multilateral

and bilateral development agencies.






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6.1.4.9 Internal Stakeholders

Stakeholders who have an interest in the project and the ability to influence and be effected

by the operation of the project. An important group requiring continuous engagement include

decision makers responsible for environmental, communications, financial, social and human

resources management.

6.1.5 Internal Enablers for SE

The enablers listed below are mainly focussed on important components internal to the

Organization, which includes management functions for SE. These enablers aim to ensure

that supporting mechanisms are in place for SE to take place and include the following:

� Systems: will create approaches or tools that are required to ensure that SE activities

can be implemented seamlessly. Under systems specific engagement activities can be

planned in such a way that they keep on recurring and can even be made part of

employee performance indicators. Having scheduled SE activities in place creates

predictability in the eyes of the stakeholder and supports the fostering of a relationship

based on trust.

� Structure: will ensure internal alignment and coordination between all parts of the

company that are involved with SE. Putting a SE-focussed structure in place with the

needed decision-making authority will enable SE activities for quicker turnaround time

on Grievance feedback, responding to stakeholder questions and having key decision-

makers in the Organization to attend meetings with key stakeholders. If the

Organization is structured to put the concerns of stakeholders at the core of processes

and decision-making, then potential risks for the project can be identified and mitigated

early.

� Skills: are required in order to effectively engage with stakeholders at all levels in the

Organization and manage the SE process throughout the Mine Lifecycle. Internal

capacity for SE is a critical component for the implementation of the SEP, since many

of the activities are integrated with various departments within the Organization and

SE might not be the core focus of some of the employees.

� Staff: addresses the number and capabilities of staff and contractors required to

engage with stakeholders effectively. This enabler is closely linked to Skills and

Structure since the number of SE-focused employees needs to be organised into a

structure or team. It becomes even more important when making contractors and

consultants part of the process as they will be seen as an extension of the Organization

and stakeholders expect a constant style of engagement.

Internal enablers need to be measured to ensure that the Organization is able to execute SE

activities successfully. These measurable components are explained as:

� Activity: the various operational SE tasks that will be undertaken as part of the SEP;






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� Objective: the target that each activity needs to reach;

� Key Performance Indicator (KPI): a means by which achieving the objective can be

measured;

� Timeframe: the time horizons for completing an activity; and

� Medium: the method used by which SE will be done (where applicable).

The internal enablers for SE are described in Table 6.

Stakeholder Engagement Plan for the New Liberty Gold Mine, Liberia

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Table 6: Internal Enablers for SE

No SE Activity Objective KPI Timeframe(s) Medium

Systems

Engagement Plans / Actions

1 Update the SEP annually and Implementation plan twice a

year.

Ensure SEP is aligned

with changing

circumstances.

Approval of SEP, bi-

yearly update.

Update SEP yearly

and implementation

plan bi-yearly

� Internal workshops

2 Ensure alignment between the SEP and communications /

media plan.

Ensure that SE is

consistent with relevant

SEP components.

Implementation plans

aligned with

communications /

media plan.

Immediate and

update as needed


3 Establish external stakeholder forums and meet on a

quarterly basis for:

� Inter-Ministerial

� NGOs

� Communities

Ensure continued open

communication channels

with key stakeholders.

Established forums. Immediate and

update as needed

� Structured agenda

� Focus group meetings

� Workshops

� One-on-one

consultations

4 Develop quarterly SE feedback and project update report

(Notes: can be integrated with the various established

forums.)

Dispel any potential

misinterpretation of

project developments.

Standardised and

recognised feedback

report.

Immediately, on-

going

� Report with structured

content


� Forum

5 Implement internal stakeholder feedback process.

(Notes: the grievance mechanism which is proposed can

be used for this process, but not all feedback received from

stakeholders are regarded as grievances. Hence, a

separate process to manage stakeholder feedback needs

to be developed.)

Keep track of

stakeholder feedback

internally.

Stakeholder feedback

process for each

stakeholder group.

Immediately, on-

going


� Internal emails

� Suggestion boxes

� Surveys

� Community capacity

building initiatives

� Grievance records

� CLT


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Stakeholder Information

6 Regularly review stakeholder trends and update

stakeholder information.

(Notes: it would be important to ensure that the

communications / media plan is also focussed to identify

industry and/or stakeholder trends, especially considering

media, journalists, NGOs, activists, academics and

influencers situated inside or outside of Liberia.)

Understanding of

stakeholder interests and

expectation.

Updated SEP.

Regular stakeholder

research activities.

On-going

Quarterly



� One-on-one

consultations

� Surveys

� Online media / analysis

7 Identify issues that holds potential for stakeholder conflict.

(Notes: identification of opportunities or issues which holds

potential risk will come as a consequence of implementing

the various components of the implementation plan. What

would be a determining factor for effective management of

the issues identified is the internal process assigned for

managing issues / risks.)

Understand potential

areas of conflict with

stakeholders to ensure

proactive mitigation.

Updated SEP.

Regular stakeholder

issues research

activities.

Immediate, on-

going



� One-on-one

consultations

� Surveys


� Grievance issues

database

Database

8 Develop, implement and update stakeholder database tool. Access to updated

stakeholder information

and engagement history.

Implemented

stakeholder database

tool.

By end 3rd quarter

2013, on-going

N/A

9 Develop, implement and update issue database tool.

(Notes: identification of opportunities or issues which holds

potential risk will come as a consequence of implementing

the various components of the implementation plan. These

issues must be fed into the database continuously.)

Identify potential

stakeholder and project

risks.

Implemented issue

database tool.

Integrated with

Grievance

Mechanism.

Immediate, on-

going



� One-on-one

consultations

� Surveys


� Grievance issues

database

10 Develop a document management system for all SE

records.

Ensure compliance and

management of potential

Developed and

implemented

Immediate, on-

going


� Attendance registers


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(Notes: Physical attendance registers are important for the

continuous update of the stakeholder database and to have

proof that stakeholders were informed or met with, should a

legal dispute arise. The system needs to address

requirements for filling physical and electronic records,

especially grievances.)

project or stakeholder

risk.

document

management system.


� Meeting minutes

� Surveys

� Ad-hoc stakeholder

comments

Protocols

11 Integrate the stakeholder engagement policy with the

EHS&S policy

(Notes: the policy need to make clear the Organization’s

position on how SE will be conducted. From this policy

protocols will be developed. It is proposed that the SE

policy should include components of other communication

disciples e.g. media relations, public relations, marketing,

management of information and internal communications.)

Define and consolidate

Aureus Mining’s

communications in order

to adhere to the

Organization’s strategy.

Developed and

approved SE policy

November 2013 Internal workshops

12 Develop SE protocols for all employees, consultants and

contractors.

(Notes: protocols need to feed through to decision-making,

internal coordination, communication plans and the

grievance mechanism.)

Pro-active management

of stakeholders and

potential project / social

risks.

SE protocol

developed.

SE protocols

incorporated into

induction and training

material and sub-

contractor

agreements.

On-going

Immediate

N/A

Grievance Management

13 Implement and update a stakeholder issue and grievance

management process (see Appendix 2 for detail).

(Notes: the grievance management process needs to

integrate with decision-making, protocols, internal

coordination and issues database.)

Accurate and timeous

decision making on

issues and grievances.

Approved and

implemented

Grievance

Mechanism.

Immediate

Update every

quarter and at key

project milestones.


� Attendance registers


� Stakeholder meetings

� Surveys


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Communications Plan

14 Develop and implement a communications / media plan for

NLGM.

(Note: the communications plan can include components

such as disaster management communication, Public

Relations, strategic communications; but should be

underpinned by the Organization’s corporate strategy.)

Create an overarching

structure and general

direction for NLGM

communications.

Approved and

implemented

communication /

media plan.

Aligned with SEP.

By end 3rd quarter

2013.

Update quarterly

N/A

15 Continuous media monitoring and engagement.

(Notes: media monitoring would consist of three

components (a) monitoring for corporate risks (b)

monitoring for NLGM risks (c) identification of industry

trends and opportunities.)

Track external

developments and

mitigate potential risks.

Implemented media

monitoring program.

On approval of

ESIA update, on-

going

� Online media

� Print media

Structure

Establish Teams

16 Establish teams responsible for SE, resettlement,

community development and communications. These must

include the following levels of involvement:

� A project Owner/Sponsor

� Relevant business Directors/Managers

(Notes: more than often good SE initiatives are

implemented but do not reach potential because of lack of

top management support.)

Ensure integration and

coordination of all

communications

functions.

Established and

integrated teams.

Immediate – critical Internal workshops


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Internal Coordination

17 Establish an internal coordination structure for the

implementation plan components and on-going internal

interaction.

(Notes: it is assumed that a single team will be established

who would be responsible for all SE related activities. This

team would need to establish the needed relationships with

supporting departments e.g. HR, Logistics, Engineering,

Corporate Affairs, Finance etc. This team would also need

to have the needed Organizational support to be allowed to

provide valuable and strategic inputs at critical decision-

making milestones of the project.)

Ensure internal

alignment to identify and

mitigate potential risks

proactively.

Developed and

implemented internal

coordination

structure.

Immediate – critical Internal workshops

Decision Making

18 Formalise internal decision making procedures and

responsibilities with associated protocols.

(Notes: decision-making protocols need to reflect the

various components of the Implementation Plan.)

Ensure quick response

times to SE risks and

grievances identified.

Developed and

implemented decision

matrix with protocols.

Immediate – critical N/A

Skills

Skills Assessment

19 Identify SE skills requirements for project staff and

contractors.

Identify potential gaps for

NLGM SE.

SE skills requirement

matrix.

Immediate

Update for key

project milestones

Internal interviews


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Training / Capacity Building

20 Develop and implement specific training programme for SE

to enhance consultants and contractor SE skills.

(Note: the training content should include internal

protocols, grievance mechanism process, decision-making

process, culture and social challenges, stakeholder

information and internal coordination.)

Address skills

shortcomings for SE to

mitigate potential risks.

Approved and

implemented training

plan.

Once skills

assessment is

completed

Update for key

project milestones

N/A

Staff

Outsourcing

21 Develop SE selection criteria for contractors.

(Notes: criteria for selection should consider local cultural

sensitivities, language proficiencies, SE experience, team

composition, complexity of social risks and stakeholder

requirements.)

Ensure contractors with

the required SE skills are

employed.

SE selection criteria

incorporated into

contracts.

End of 4th quarter

2013

N/A

22 Identify third party mediators for conflict resolution. Strengthen conflict

resolution capacity.

List of external

facilitators and their

areas of expertise.

End of 4th quarter

2013

N/A


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42

6.1.6 Management Functions

In this section the proposed Organizational structure and management functions for the SE

function at NLGM are described. While Aureus may decide to adapt this structure according

its needs, it is emphasised that the various components described below should be

represented in the Organizational structure in order to successfully implement the SEP ((see

Figure 3).

� Social Manager, who is responsible for overseeing and coordinating all activities

associated with stakeholder engagement;

� Community Liaison Team (CLT), who will be responsible for implementing

community engagement activities;

� Administration, who will be responsible to manage all activities related to database,

documents and SE logistics; and

� Integration / support, which describes the interaction with other departments,

initiatives or projects.

Figure 3: Proposed Organizational Structure for SE


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43

6.1.6.1 Social Manager

The Social Manager (or a similar function) needs to oversee all activities that are planned or

being implemented for SE. Furthermore, this position needs to ensure that all aspects relating

to SE are kept on the management agendas within Aureus and addressed. Hence, it is

important that the Social Manager reports directly to the General Manager and is able to

interact freely with key decision-makers in the Organization i.e., HR Manager, SHEQ Manager,

Engineering Manager, Site Manager and Corporate Affairs Manager. Responsibilities of the

Social Manager include the following:

� Develop, implement and monitor all SE strategies / plans for NLGM;

� Oversee all SE related activities for NLGM (administration, CLT);

� Manage the grievance process;

� Interact with and support projects that require ad-hoc or intensive SE (CDP and RAP);

� Act as mediator between NLGM and stakeholders (communities, Government

structures, Traditional structures, NGOs, CBOs, commerce and industry and

international Organizations);

� Integrate with other Organizational managers to ensure that SE requirements /

protocols are understood; and

� Proactively identify stakeholders, project risks and opportunities and inform the

General Manager / management to ensure that the needed planning can be done to

mitigate or capitalise.

Notes: the Social Manager plays a critical role as internal change agent for social and stakeholder

related matters in the Organization. This becomes important if social and stakeholder risks identified

need to be escalated for decision-making on resolution. Playing a mediating role, the Social Manager

needs to remain actively involved with the CDP and RAP implementation in order to identify potential

risks or opportunities and ensure that the needed administrative support is provided. Moreover,

grievances submitted as part the RAP or CDP processes needs to be addressed by the Community

Development Officer (CDO), but with the needed support from and in collaboration with the Social

Manager. Since the Corporate Affairs Manager would also be interacting with stakeholders

(Government and Media), it is imperative that continuous interaction, and integration of plans, between

this manager and the Social Manager takes place.

6.1.6.2 Community Liaison Team

The Community Liaison Team (CLT) consists of Community Liaison Officers (CLOs) and

Community Contacts. The main purpose of this team is to engage with communities at

grassroots level on a continuous basis in an effort to strengthen relationships between NLGM

and communities / traditional structures. Responsibilities include the following:

� Provide feedback to the Social Manager on concerns raised by the community /

traditional structures;

� Provide feedback to the community / traditional structures on project developments,

concerns raised or important decisions taken by the NLGM;

� Identify potential grievances or project risks / opportunities;

� Assist the Social Manager with facilitation of grievances lodged;


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44

� Assist the HR Manager during the recruitment process by soliciting community

requirements;

� Identify community needs for social development or engagement requirements; and

� SE logistics (gather suggestions / grievances from suggestion boxes, delivery of letters

to traditional authorities, put up communication materials on notice boards, arrange

community meetings etc.).

Notes: the CLOs will be employed by NLGM and have offices on site from where they will operate.

These CLOs will need to provide feedback to the Social Manager on a weekly basis by means of a

structured field report. Proposed content of the field report: consultations undertaken, attendance

registers (where applicable), concerns raised, requests raised, concerns resolved, potential risks,

grievances or opportunities identified. It is proposed that CLOs are employed from local communities

to ensure that local language and culture needs can be supported. Community Contacts are members

from the community, employed by NLGM, who will remain in the community, having no office on site.

They will be responsible to assist the CLO with logistical arrangements within the community and very

importantly, to gauge the community’s status on potential risks e.g. employment and social development

expectations, attitude towards the NLGM, any changes in traditional leadership dynamics, potential

infighting between different communities, success of RAP and CDP implementation.

6.1.6.3 Administration

The administration team’s main purpose is to provide support to the SE process by ensuring

that all administrative requirements are managed effectively. Main responsibilities include the

following:

� Document management

� Capture and filing (physical and electronic) of SE document / records; and

� These include, but isn’t limited to: grievance records, attendance registers, letters,

post, emails notes, suggestions, complaints, memos, statements, reports,

strategies and plans, agreements, surveys, notification materials, maps, print

materials, adverts, articles.

� Database management

� Continuously update stakeholder information (contact details, Organizational

details, designation, engagement activities); and

� Continuously update grievance information according to the steps set out in

Appendix 2 (grievance records, grievance log, agreements, meeting registers).

� Logistics management

� Support with arranging accommodation and traveling where required; and

� Assist with printing of materials to be used during stakeholder meetings (posters,

pamphlets, BIDs, letters, attendance registers, maps, newsletters).

Notes: it is proposed that a dedicated administrative support resource be appointed to fulfil the required

activities. In many cases SE activities as part of the CDP and RAP implementation process will also

yield documents and the need for support on database updates and logistics. It is proposed that all

administration for all SE activities, including the CDP and RAP, is centralised. This comes as a measure

to mitigate any risk of loss of important records and to ensure that a standardised approach for SE

administration is followed. If all these SE administration activities are centralised, it will also ensure that


AMI2252

45

the CLOs and Social Manager remain informed of developments on CDP and RAP SE activities should

any queries be raised from internal management or external stakeholders.

6.1.6.4 Integration and support

Due to the fact that SE activities will influence other departments or require their inputs, the

Social Manager needs to ensure the various managers are included or kept informed on the

SE process. Decisions taken by managers might have a direct or indirect impact on

communities which would need to be communicated at the appropriate time, e.g. the Mine /

Engineering Manager might decide to construct additional access roads which could

potentially have an impact on communities and involvement of the MoPW would be required.

Anticipated SE roles for the various decision-makers are outlined below:

■ Corporate Affairs Manager: this manager will be responsible to sustain relationships

and communicate with Government entities and the media. These engagements will be

required throughout the mine’s live and decisions taken as a result of these

engagements could potentially impact NLG’s relationships with communities e.g. site

selection or compensation agreements during the RAP implementation.

■ HR Manager: opportunities for employment are a key concern for community members.

They are also very sensitive about appointing people from local villages opposed to

villages located further away from the project site. This requires that a defined process

of employment be developed and clearly communicated to community leadership and

members.

■ Site Manager: the Site Manager is often responsible for logistics, which include

transport to and from villages. These transport arrangements need to be supported by

the Site Manager and arranged accordingly is cases where extensive consultation with

communities are required.

� SHEQ Manager: how the mine interacts with the environment will have a direct bearing

on stakeholders perceptions. The SHEQ Manager needs to be able to interact with the

EPAL / FDA or environmental NGOs freely, providing the needed information on the

mine’s environmental policies and how they are being implemented.

■ Engineering / Mine Manager: these managers are more than often driven by mine

production targets and would need to be capacitated to understand the importance of

healthy stakeholder relations, even if it requires production stoppages due to

outstanding issues to be resolved around environmental or social impacts, for example.

6.2 SE Implementation Plan for Mine Lifecycle

The Implementation Plan needs to be updated and refined throughout the lifecycle of the

Project. During this process the focus and scope of the Implementation Plan will change to

ensure that the Organization addresses external changes and adhere to its strategy. The

implementation plan is included in Table 6.

The key elements to be considered when implementing stakeholder engagement during the

Project’s lifecycle are briefly discussed below.

� Exploration: the process of finding commercially viable minerals / ore to be mined.


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46

� Pre/ and feasibility: the regulatory process whereby the required authorisation and

licences are obtained for mining to commence.

� Commissioning: the process of assuring that systems and components of the mine

are designed, installed, tested, operated and maintained to prescribed / agreed

requirements.

� Operations: the process and activities involved with the extraction of minerals.

� Closure: the period when ore-extraction activities have ceased and decommissioning

are being completed.

It is recognized that, in the case of NLGM, the Exploration, Pre-feasibility and Feasibility

phases of the project are already complete. The inclusion of SE activities for these phases in

this document is therefore for the sake of completeness only.

The implementation plan for Mine Lifecycle constitutes the following components:

� SE Activity: the various operational SE tasks that will be undertaken as part of the SE

Plan;


� Stakeholder: the various stakeholders to be targeted during implementation of the SE

activity; and

� Medium: the method used by which SE will be done.


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Table 7: SE Implementation Plan for Mine Lifecycle

No SE Activity Objective Stakeholders Medium

Exploration4

1 Identify key stakeholders.

(Notes: these stakeholders would be responsible to

enforce environmental and mining legislation, make

decisions that would influence communities, have political

decision-making power or influence and local / traditional

authorities.)

� Understand stakeholder

compliment to determine

anticipated risks

� Understand stakeholder

base to determine

anticipated key messages

and engagement mediums

� National Government � Regional / District Government


� One-on-one consultations

� Letter

� Telephone

� Local Government � Traditional Authorities � Communities � Local consultants

� Letter


2 � Arrange meetings with key stakeholders.

� Develop the required print materials.

(Notes: print materials should provide background on the

proponent, background and intention to the proposed

exploration, proposed activities to be undertaken,

proposed schedule, information and contact details of

exploration implementers and anticipated SE process

involved.)

� Building relationships

� Understanding potential

project risks / opportunities

� Determine required

processes and way forward

� District Commissioner � Superintendent of Cape Mount

County � County Member of Parliament � Ministry of Lands, Mines and

Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission

� Letter


� Telephone

� BID

� General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities

� Letter


� BID

� CLT

3 � Refine exploration programme and SE process � Sustain relationships � District Commissioner � Ministry of Lands, Mines and

Energy

� Letter


(where applicable)

4 As mentioned above, the Exploration, Pre-feasibility and Feasibility phases of the project are already complete; SE activities for these phases are therefore included in this table for the sake of completeness only.


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� Provide feedback to key stakeholders shortly before

commencement of exploration.

(Notes: feedback from the various stakeholder meetings

needs to be fed back into the proposed exploration

program, SE process and project management team to

highlight / discuss any potential project and social risks /

opportunities. It would be important to note to

communities and traditional authorities that during

exploration no minerals will be extracted.)

� Provide surety and detailed

information about the

exploration and SE

processes

� Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission

� Telephone

� General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities � Affected communities

� Letter


� Posters

� CLT

4 Ensure continuous feedback to stakeholders during

exploration and implement grievance procedures for

communities.

(Notes: the detail and process of feedback should be in

line with stakeholder requirements and expectations as

identified in the previous steps.)

� Sustain relationships

� Provide clarity on progress

� Address grievances and

stakeholder comments

� District Commissioner � Ministry of Lands, Mines and

Energy � Ministry of Internal Affairs � Ministry of Agriculture � Environmental Protection Agency � Forrest Development Authority � Land Commission

� Letter


(where applicable)


content


� Letter


� Posters

� CLT

� Surveys



Pre/ and Feasibility

5 � Provide feedback to stakeholders on findings of the

exploration conducted.

� Develop the needed print materials.

(Notes: it is important to start managing expectations

from the Government on social / monetary contributions

and expectations from communities on employment.

Feedback should focus on the facts and also highlight

� Address previously

concerns raised

� Manage expectations

� Provide information on the

way forward


County � Ministry of Lands, Mines and

Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency

� Letter


� Telephone

� Maps


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that feasibility process needs to be completed before

mining can commence. The way forward should be

clearly stipulated for communities.)

� Forrest Development Authority � Land Commission

� Environmental NGOs � Social NGOs

� Letter

� Email

� Maps


� Letter


� Posters

� CLT

� Maps

6 � Conduct the SE process according to IFC standards

(if required) and applicable Liberian legislation as part

of the ESIA update.

� Develop the needed SE materials to be used for the

ESIA update.

(Notes: although the ESIA is only an update, it is advised

that stakeholders are still consulted to ensure that the

SEP objectives and goals are met. Ensuring that

stakeholders are informed about the relevant changes will

also adhere to the IFC Performance Standards. Detailed

SE activities are described in Section 6.4 of the SEP. It

would be important to discuss the proposed SE process

for the ESIA update is discussed with the EPAL to ensure

that the legislative requirements are met. All stakeholder

comments are captured in the Comment and Response

Report (CRR) which can be analysed for potential project

risks.)

� Adhere to legislative

requirements

� Ensure participation from

I&APs

� Identify potential project

risks



Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission � Environmental and Social NGOs

� Letter

� Emails

� Telephone


� BID

� Advert


� Letter

� Posters/Notices


� BID

� CLT

� Radio

� Advert (if applicable)

Construction

7 � Notify stakeholders that construction will commence.

� Establish a community forum.

� Develop the needed notification materials.


� Mange stakeholder

expectations



Energy

� Letter

� Emails


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(Notes: the following supporting information needs to be

included: construction schedule, reiteration of

employment process, details around the grievance

procedure and contact details of CLT. It is proposed that

community meetings be held to announce the

construction phase formally and allow for clarification on

potential uncertainties through discussions. Materials

used as explanation for the communities need to be very

visual with minimal text. The community forum needs to

be representative of the relevant hierarchical structures.

This forum needs to meet on a regular basis as agreed

beforehand and discuss matters as agreed beforehand.

The purpose of such a forum is to anticipate potential

grievances and manage project risk proactively.)

� Manage stakeholder risk � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission � Environmental and Social NGOs


� Letter

� Posters/Notices

� Pamphlets


� Forum

� CLT

� Radio

� Suggestions boxes


8 Regular updates to stakeholders on construction

progress.

(Notes: as part of the progress updates on construction

to the relevant authorities, social-development activities

and updates on employment need to be provided also as

it contribute toward achieving the social licence to

operate objective. Providing regular feedback to

stakeholders also contributes to the effort of managing

expectations. It is proposed that the key stakeholders i.e.,

EPAL, FDA and Ministry of Lands, Mines and Energy be

provided with feedback by means of meetings as agreed

with them. Feedback can also be in the form of regular

site visits for key stakeholders. Close attention should be

paid to addressing grievances as they are lodged. During

these update meetings, information which could have

potential impact on the project or the Organization’s

strategy needs to be fed through to the relevant internal

decision makers or other initiatives e.g. CDP.)



expectations


risks proactively

� Superintendent of Cape Mount County

� Ministry of Lands, Mines and Energy

� Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission

� Letter

� Emails

� Telephone


(where applicable)

� Site visit (if applicable)


� Letter

� Posters/Notices


� CLT



� Surveys


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9 Continuous integration with resettlement and community

development.

(Notes: various community initiatives might be running

simultaneously with construction. These need to be

identified before construction commences and shared so

that related SE tasks and stakeholders can be integrated.

A common and important medium to be managed will be

the grievance process since it can be used to determine

potential project risk proactively e.g. work stoppages.)

� Identify and mitigate

potential risk

� Internal decision makers and influencers

� Workshops � Emails � Telephone

Commissioning

10 � Notify stakeholders of the commissioning date and

process.


(Notes: the following should be included in this

notification: purpose of the commissioning,

commissioning schedule, process and methodology of

testing, post commissioning notification. Materials used

as explanation for the communities can focus on the

basic principles of the process and the fact that the mine

is committed to ensure safety of staff and surrounding

communities.)


� Mange stakeholder risk



Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Environmental and Social NGOs

� Letter

� Emails


� Letter

� Posters/Notices


(where applicable)

� CLT

11 � Provide feedback when commissioning is completed.



notification: purpose of the commissioning,

commissioning schedule, process and methodology of

testing, testing results, resolution measures implemented

and date for starting operations.)





Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency

� Letter

� Emails


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� Forrest Development Authority � Environmental and Social NGOs


� Letter

� Posters/Notices


(where applicable)

� CLT

Operation

12 � Notify stakeholders of the official date when

operations will commence.



notification: official date when operations will commence,

brief description of core operational activities and contact

details for relevant mine management and CLT. A site

visit for the official opening of the mine can be arranged

for key stakeholders, including traditional leadership of

communities who are directly affected.)





Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission � Environmental and Social NGOs

� Letter

� Emails


(where applicable)


� General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities � Affected communities � Resettlement Committee

� Letter

� Posters/Notices

� Pamphlets


(where applicable)




� CLT

13 � Engage stakeholders throughout the operations

phase.

o Establish a / sustain the existing community

forum.



expectations

� Manage stakeholder risks



Energy � Ministry of Internal Affairs

� Letter

� Emails

� Telephone


(where applicable)


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o Establish an authorities forum.

o Develop the needed SE materials.

(Notes: engagement with stakeholders during operations

needs to be structured. For the authorities forum the

following stakeholders are proposed (a) Ministry of

Lands, Mines and Energy (b) Ministry of Internal Affairs

(c) EPAL (d) FDA. The agenda and frequency of

meetings needs to be agreed by the forum. An agreed

outcome of this forum can be an annual report. Other

authorities and NGOs can be met with on an ad-hoc

basis. For the community forum the representatives,

agenda and frequency needs to be determined

collectively between the traditional leadership and mine. It

is proposed that a quarterly / bi-annual newsletter be

distributed to all stakeholders. It would be important to

also ensure that online coverage and print media of the

mine is actively tracked. Households resettled and host

communities need to be included for continuous

engagement post-resettlement.)


risks proactively

� Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission � Environmental and Social NGOs

� Forum


content


� Newsletter

� Online media

� Newspapers


� Letter

� Posters/Notices


� Forum

� CLT



� Awareness creation

campaigns



14 Develop disaster management communication plan.

(Notes: IFC PS1 makes provision that emergency and

preparedness systems be implemented to ensure that

potentially affected communities are safe. These systems

should be monitored and revised as needed. The PS1

also indicates that communities and authorities,

especially local, need to be involved as far as possible.

Mitigation and Response Protocols are the two main

pillars for disaster management, and communication is

regarded as a critical component to ensure successful

implementation and management thereof.)

� Manage potential

community health and

safety risks



Energy � Ministry of Internal Affairs � Environmental Protection Agency � Environmental and Social NGOs

� Letter

� Emails

� Telephone



� Letter

� Posters/Notices


� CLT




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campaigns



15 Continuous integration with community development and

media initiatives.

(Notes: various community initiatives will be implemented

during operations. These need to be identified early and

integrated with planned SE activities. The same needs to

apply for media activities and engagement e.g.

newspaper or radio adverts, articles being released,

interviews being scheduled etc. Releasing information

through the media will create perception and potential

expectations which could easily filter through to

communities. Therefore, proactive measures need to be

taken.)



potential risk



Closure

16 Align with social development and environmental impact

initiatives for closure.

(Notes: planned initiatives for communities in preparation

for mine closure need to be identified early, and should

be done in conjunction with environmental initiatives for

closure. Authorities, and is some cases NGOs, will have

very specific expectations on what should be done during

closure and also what the result should be e.g. how

communities and local economies will remain sustainable

post-closure, management of remaining mining

infrastructure post-closure, approach to rehabilitation etc.

These initiatives needs to be understood in advance of

implementation so that the needed SE activities can be

planned to ensure successful implementation.)


potential risk



� District Commissioner � Letter


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17 � Engage stakeholders throughout the closure process.

� Develop the needed engagement materials.

(Note: closure will take place according to the approved

EMP which will necessitate involvement of the relevant

authorities pre- and post-closure. These consultations

would be to ensure that the agreed closure activities are

still applicable and confirm the needed involvement of the

relevant authorities. For communities, social development

initiatives would have been implemented throughout the

operations phase in preparation for closure. Communities

would require sufficient time to gain the needed

understanding about closure e.g. process, impacts, post-

closure implications etc. Expectations would need to be

managed by means of regular meetings, awareness

creation campaigns and capacity building. It is expected

that many grievances will be lodged before and during

closure because of social development and employment

opportunities which will be stopped. The Ministry of

Internal Affairs and CLT will play an important role during

closure.)


potential risk

� Manage stakeholder

expectations



� Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � Land Commission � Environmental and Social NGOs

� Emails

� Telephone


� Online media

� Radio

� Newspapers


� Letter

� Posters/Notices


� CLT




campaigns




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6.3 SE Implementation Plan for Issues Resolution

Stakeholder concerns raised during the consultation process completed as part of the EIS

Report compilation were captured in a Comment and Response Report (CRR). These

concerns represent real life challenges stakeholders face every day, which will also become

evident during the RAP implementation, CDP implementation and life of mine activities. This

implementation plan aims to resolve or support the resolution of issues by means of various

SE activities. 10 main issues have been identified and are discussed in further detail in Table 2.

The implementation plan for Issus Resolution is detailed in Table 8 and constitutes the

following components:

� SE Activity: the various operational SE tasks that will be undertaken as part of the SE

Plan;


� Stakeholder: the various stakeholders to be targeted during implementation of the SE

activity; and

� Medium: the method used by which SE will be done.


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Table 8: SE Implementation Plan for Issues Resolution

No Issue SE Activity Stakeholders Medium

1 Availability of clean

drinking water

Continuous engagement with affected communities,

through appropriate channels, to manage expectations on

Aureus delivering solutions and identify potential

opportunities for assistance for clean drinking water.

� Affected individuals / communities � General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities

� Letter

� CLT

� Poster/notices


� Community capacity building initiatives

� Awareness campaigns

Create awareness of health risks associated with drinking

dirty water and what to do in cases of illness.

Ensure that the relevant authorities are aware of initiatives

to alleviate situations where clean drinking water isn’t

available.


County � Ministry of Internal Affairs � Ministry of Agriculture � Environmental Protection Agency

� Letter

� BID


� Telephone

2 Timber cutting regarded as

important means of

livelihood

Affected individuals must first be identified, followed by

determining their exact perceptions and expectations.

Address the perception and expectations around potential

deforestation by means of creating awareness of the mine’s

intentions. The relevant community structures need to be

included with development of solutions.

� Affected individuals � General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities � Resettlement Committee

� Letter

� CLT


� Maps


� Awareness creation campaigns



Inform the relevant authorities of the mine’s intention and

request guidance on proposed solutions, also ensuring that

the proposed solution fits in with the authorities’

requirements.

� Green Advocates � District Commissioner � Superintendent of Cape Mount

County � Ministry of Lands, Mines and Energy � Ministry of Internal Affairs � Environmental Protection Agency � Forrest Development Authority

� Letter

� Telephone

� Email



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3 Uncertainty about the

project’s impact on the

livelihoods of community

members

Continuous and well defined messaging should be provided

to communities. It is very important to track the perceptions

of people that are affected, since this will influence on-going

messaging.


� Letter

� CLT


� Maps





4 Loss of artisanal mining Engagement should be structured in such a manner that it

would always seek to understand the affected party’s

situation. This can be accomplished by one-on-one

meetings and focus group meetings where applicable. It

would be very important that when promises or decisions

are made, feedback is given.


� Letter

� CLT

� Maps






5 Impact of project on forest

reserves

Engagement in this regard should be focussed to always

include the FDA on project progress and development of

solutions. For this workshops can be conducted to discuss

technical designs / details and requesting the FDA’s input to

solution development.

� Forest Development Authority � Environmental Protection Agency � Land Commission � Ministry of Agriculture

� Letter

� Maps

� Structures agenda

� Telephone

� Workshop


6 Increased community

expectations

This is a critical issue to manage proactively by means of

clear and well defined messages, which is supported by the

needed Organizational systems. Messages must be

consistent and people must be reminded regularly about

� Ministry of Internal Affairs � Green Advocates

� Letter

� Focus group meeting

� Telephone

� Email


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the company’s position on expectations raised, especially

concerning employment. Failed promises can quickly turn

into grievances.


� Letter

� CLT






7 Land belongs to the

communities / people

The wider community needs to be consulted when big

environmental impacts are anticipated. Traditional

structures should be consulted as a first point of call. The

relevant Government entities mentioned should also be

consulted to seek approval of the consultation approach

and general acceptance / support of the various initiatives.

� Ministry of Internal Affairs � Forest Development Authority � Environmental Protection Agency � Land Commission � Ministry of Agriculture � Green Advocates

� Letter

� Focus group meeting

� Telephone

� Email


� Letter

� CLT





8 Uncertainty around

displacement

First and foremost it is critical to understand who the

relevant stakeholders are, since this will influence the

messaging and medium of delivery. Engagement needs to

be very structured and underpinned by specific objectives

that need to be achieved. The objectives will be related to

the mine / project’s strategic direction and the specific issue

associated with displacement. From this position the most

appropriate mediums for communication needs to be

identified and established. Dissemination of messages

� Green Advocates � Liberia Refugee Repatriation and

Resettlement Commission � Marvoe Development Association � Ministry of Lands, Mines and Energy � Ministry of Internal Affairs � Ministry of Agriculture � Ministry of Public Works � Environmental Protection Agency � Forrest Development Authority � National Housing Authority � Land Commission

� Letter


� Telephone

� Email

� Online media


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60


needs to be consistent and coordinated with SE activities

related to RAP implementation (see Section 6.6 below).


� County Member of Parliament � District Commissioner � RSC

� General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities � Affected individuals / communities

(incl hosts) � Resettlement Committee

� Letter

� CLT





9 Legacy commitments not

addressed

Messaging always needs to be consistent and supported by

the needed business systems and decision-making ability.

Engagement to address legacy issues will need to be

repeated a few times since perceptions need to be

changed.

� General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities � Affected individuals / communities

(incl hosts)

� Letter

� CLT





� Ministry of Lands, Mines and Energy � Ministry of Internal Affairs � Superintendent of Cape Mount

County � District Commissioner � Environmental Protection Agency � Forrest Development Authority

� Letter


� Telephone

� Email

� Online media

10 Alignment between

Ministries

It is proposed that an inter-Ministerial forum be established

where Aureus, represented by top management, meet and

discuss pertinent topics at these forums on a frequent

basis.

� Ministry of Lands, Mines and Energy � Ministry of Internal Affairs � Environmental Protection Agency � Forrest Development Authority

� Letter

� Workshop


� Report with structured agenda

� Telephone

� Email


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62

6.4 SE Implementation Plan for the ESIA Update

As mentioned already, at the time of writing this report it had yet to be confirmed whether SE

would be required as part of the ESIA updating process. Liberian legislation indicates that the

Government (EPAL) would be responsible for engagement with stakeholders. However, in

the light of IFC Performance Standards, it is advisable that the engagement be undertaken by

an independent consultancy.

The activities outlined below are premised on the assumption that the process would follow

international best-practice standards in terms of SE. It is, however, recommended that the

EPAL be consulted to determine the specific requirements for SE as part of this ESIA update.

6.4.1 Stakeholder Database

The stakeholder database referred to in Section 4.4.3 above will be used as basis to

determining who needs to be involved in SE related to the ESIA update.

6.4.2 Background Information Document

A Background Information Document (BID) will be prepared to provide non-technical people

with basic information and context relating to the ESIA update. The BID will include:

� Information about Aureus Mining and Digby Wells;

� Background to the project, including previous studies and consultation completed;

� A locality map of the proposed project area;

� Factors that necessitated the ESIA update;

� The process followed during the ESIA update;

� Main findings of the ESIA update; and

� SE process for the ESIA update.

Printed copies of the BID will be made available at the various stakeholder meetings and

contact details of Digby Wells and a local representative will be included.

6.4.3 Presentation Posters

An electronic PowerPoint presentation will be developed for meetings with Government

entities and NGOs and used where facilities permit. This presentation will be presented on A1

full colour posters when meeting with communities. It will be relying on pictorial images to

convey messages and supporting text descriptions where required.

6.4.4 Stakeholder Meetings

In Section 6.1.4 the various stakeholder groups are described. It is envisaged that meetings

with stakeholders will be undertaken in the following manner:


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63

� Monrovia: meetings with National Government Authorities, Civil Society groups and

NGOs;

� Grand Cape Mount County: meetings with the Superintendent and District

Commissioner; and

� Project area: affected villages located within the project area namely; Kinjor, Larjor,

Jikando and Jawajeh.

The ESIA Update Report will be made available to relevant stakeholders for public comment

for 30 calendar days. It is anticipated that the stakeholder meetings will be conducted during

the third week of the public comment period and will be completed within four days. Meetings

will be conducted in the sequence as indicated above and a detailed schedule will be compiled

with signoff on the ESIA Update Report.

6.4.5 Comment and Response Report

Comments raised either in writing, by email, by telephone and captured at the stakeholder

meetings will be captured in the Comment and Response Report (CRR). Responses to the

comments raised will be drafted and included. The CRR will be categorized into the disciplines

required for conducting specialist studies during the ESIA update.

6.5 SE Plan for Community Development Plan (CDP) Implementation

The CDP includes a SE section (see Section 6 of the CDP) which provides an overview of SE

activities required for implementation i.e., objectives, stakeholder identification,

communication function, engagement mechanisms and document management. In support of

the existing SE components mentioned as part of CDP, more detailed SE activities are

discussed in Table 9 for the following CDP activities:

� Establish partnerships in order to support project development and implementation.

� Implement measures that will encourage women and the youth to develop new, or

expand existing business opportunities.

� Help project recipients to identify markets beyond the life of the mine by linking them

with trade fairs, business chambers, and other development initiatives.

� Provide a platform for project recipients and local businesses to share lessons and

build their networks.

� Provide training to households who could be receiving formal community services.

� Meet regularly with government authorities to establish how Aureus could assist with

meeting the infrastructure requirements of the host communities.

� Beneficiary selection for project development and implementation.

� SE during implementation of development opportunities.


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64

Table 9: SE Plan for Community Development Plan Implementation

No CDP Activity SE Activity Stakeholders Medium

1 Establish partnerships in

order to support project

development and

implementation.

Identification of stakeholder that are:

� able to provide technical advice, mentorship and

coaching;

� have influence; or

� can provide relevant information;

considering the various components of the CDP.

(Notes: identification of the relevant institutional frameworks

will be combination of desktop research and gaining

knowledge from the local consultants.)

� Local consultants

(Notes: local consultants has local

knowledge and expertise to advise on

stakeholders to be included for

engagement as part of the CDP

implementation process.)

� Email

� Telephone

� Arrange meetings with the relevant stakeholders as

identified.

� Develop background materials on the CDP, proposed

initiatives and support requirements.

(Notes: it is proposed to consult with authorities and

agencies to obtain support and guidance before the

remaining stakeholders listed are engaged. Authorities and

agencies might have information about additional

stakeholders to be contacted or specific suggestions for

implementation.)

� Social and Environmental NGOs

� Ministry of Agriculture

� Ministry of Internal Affairs

� Ministry of Lands, Mines and Energy � Ministry of Planning and Economic

Affairs � Superintendent of Cape Mount

County

� Environmental Protection Agency

� Forrest Development Authority

� Land Commission

� Academic community

� Business and industry

� Email / letter

� Telephone

� Focus group meetings (where applicable)

2 Implement measures that

will encourage women and

the youth to develop new, or

expand existing business

opportunities.

� Identify key challenges through consultation with women

and youth.

� Consult with relevant stakeholders to identify external

influencing factors, potential solutions to already

identified challenges and proposed measures.







� Email / letter

� Telephone



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65


� Consult with women and youth from communities for

implementation of measures.

(Notes: stakeholders possessing local knowledge about the

proposed development initiatives would be able to advise on

implementable measures to encourage women and the

youth. These stakeholders would also be able to advise on

external influencing factors, together with solutions, which

might pose as potential risk to development initiatives.)

� General Town Chief � Clan Chief and Elders � Paramount Chief � Town Authorities

� Affected community members / groups

� Resettlement Committee

� Letter � Posters/Notices � Focus group

meetings � CLT � Community capacity

building initiatives � Awareness creation

campaigns

3 Help project recipients to

identify markets beyond the

life of the mine by linking

them with trade fairs,

business chambers, and

other development

initiatives.

� Develop the needed materials to facilitate engagement

between project recipients and stakeholders identified in

SE activity no. 1.

� Arrange meetings between project recipients and

stakeholders identified in SE activity no. 1.

(Notes: more than often town authorities would want to

become involved in initiatives which will affect their

community. This might involve some form of ownership in

any if the initiatives. To ensure that no disputes develop

between community members and town authorities or among

community members, consultation with the relevant

traditional / town authorities would be important in order to

understand expectations.)

� Stakeholders as identified in SE activity no. 1

� Email / letter

� Telephone


� General Town Chief � Clan Chief and Elders � Town Authorities � Affected community members � Resettlement Committee


meetings � CLT � Awareness creation

campaigns

4 Provide a platform for

project recipients and local

businesses to share lessons

and build their networks.

� Consult with stakeholders already earmarked to be

involved in development initiatives in order to determine

the preferred platform.

� Establish platform for sharing lessons learnt and building

of networks.

(Notes: as mentioned above, traditional and/or town

authorities might be interested to become involved in the

establishment of and partaking in the platforms. Government

authorities such as the Ministry of Planning and Economic

Affairs and Ministry of Internal Affairs could play an important

supporting role to assist with establishment of the platform.)

� Stakeholders as identified in SE activity no. 1

� Email / letter

� Telephone


� General Town Chief � Clan Chief and Elders � Town Authorities � Paramount Chief � Affected community members � Resettlement Committee


meetings � CLT


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5 Provide training to

households who could be

receiving formal community

services.

� Identify households eligible for formal community

services.

� Meet with town authorities and households.

(Notes: as mentioned above, traditional and/or town

authorities might be interested to become involved in the

establishment and partaking of the platforms. Government

authorities such as the Ministry of Planning and Economic

Affairs and Ministry of Internal Affairs could play an important

supporting role to assist with establishment of the platform.

Households resettled and host communities also need to be

considered for training.)

� General Town Chief � Clan Chief and Elders � Town Authorities � Paramount Chief � Affected community households � Resettlement Committee




6 Meet regularly with

Government authorities to

establish how Aureus could

assist with meeting the

infrastructure requirements

of the host communities.

� Determine infrastructure requirements of host

communities.

� Meet with the relevant authorities to discuss host

community infrastructure requirements.

(Notes: it would be important to understand the host

communities’ infrastructure needs and inform the relevant

authorities thereof for further discussion. During consultation

with the affected host communities it must be made clear that

consultation doesn’t constitute commitment for infrastructure

development.)

� General Town Chief � Clan Chief and Elders � Town Authorities � Paramount Chief � Resettlement Committee

� Letter � Focus group

meetings � CLT � Suggestion boxes

� National Housing Authority � Ministry of Public Works � Land Commission � Ministry of Lands, Mines and Energy � Ministry of Internal Affairs � District Commissioner

� Email / letter

� Telephone


7 Beneficiary selection for

project development and

implementation.

� Assign a CLO who will liaise directly with the “labour

desk” and Resettlement Committee.

� Communicate to town authorities and affected

communities.

(Notes: the CLO would be able to act as a mediator between

the labour desk and the community / Resettlement

Committee in an effort to determine requirements and

expectations.it would be important to ensure that the

beneficiary selection criteria is discussed and agreed with

the Resettlement Committee. In order to manage

� General Town Chief � Clan Chief and Elders � Town Authorities � Paramount Chief � Affected communities � Resettlement Committee

� Letter � Focus group

meetings � CLT


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expectations from communities and town authorities on

entitlement and potential selection for project development

selection, clear and precise messages needs to conveyed

during meetings.)

8 SE during implementation of

development projects.

� Provide feedback to relevant authorities and key

stakeholders on progress of implementation of


� Engage relevant communities early in in the project

development implementation process.

� Monitor implementation progress and effectiveness of


(Notes: feedback to relevant authorities and key

stakeholders would add value if it is aimed at improving

existing processes by incorporating their feedback. The

implementation of development projects need to discussed

and agreed with town authorities and follow-up with clear and

transparent communication to ensure that no infighting

between community members start. These notifications need

to be well in advance of implementation to allow time for any

grievances or queries to be resolved – in this process the

CLT will play a critical role. Constant feedback from project

recipients needs to be gathered to monitor effectiveness of

projects and to identify any potential risks proactively. The

latter can be applied to other projects to minimise risks.)




� Ministry of Lands, Mines and Energy � Ministry of Planning and Economic

Affairs � Superintendent of Cape Mount

County



� Land Commission



� Email / letter

� Telephone






building initiatives � Awareness creation

campaigns � Suggestion boxes � Grievance records � Surveys


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6.6 SE Plan for Resettlement Action Plan (RAP) Implementation

RAP implementation comprises a number of tasks and sub-tasks of which some require

engagement with stakeholders on different levels These have been listed below and reference

added which will correlate with Table 10, which advises on the required SE activities,

stakeholders to be targeted and the applicable mediums to be used. Section 7 of the RAP is

dedicated to SE and provides details on objectives, identified stakeholders and a summary of

SE already undertaken during RAP development. This sections deals specifically with SE

activities to be undertaken during implementation of the RAP. These are:

■ Introduce RAP implementation structures to affected communities (1)

■ Undertake feasibility studies for proposed community development projects (2)

■ Facilitate individual rights transfer and certificates for new houses (3)

■ Issue Notice to Vacate to affected property owners (allow for resolving of appeals) (4)

■ Relocate affected parties to replacement site (5)

■ Finalise sign-off on property transfer documentation (allow for at least one month

retention period) 6)

■ Clear and prepare agricultural land for implementation of community development

projects (7)

■ Initiate community development and livelihood restoration projects (8)

■ Monitor performance of RAP and CDP implementation (9)

■ Monitor the ability of vulnerable groups to adapt to resettlement (10)

■ On-going consultation with affected and host communities (11)


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Table 10: SE Plan for RAP Implementation

No RAP Task SE Activity Stakeholders Medium

1 Introduce RAP

implementation structures

to affected communities

� Arrange meetings with the various groups according to

the proposed meeting schedule.

� Develop the needed print materials and maps as leave-

behind information for communities to share with other

community members / families.

(Notes: Notices for communities need to include the

intention of the meetings, who needs to attend, who will be

undertaking the meetings, what is expected of community

members, how will it be conducted, when it will be

conducted. During this round of engagement it is advised

that communities be informed of the upcoming feasibility

studies for H.2.)

� Affected communities

� District Commissioner

� General Town Chief (RAP affected towns)

� Clan Chief and Elders

� Paramount Chief

� Town Authorities

� Letter


� Posters/ notice boards

� Pamphlets

� Maps

� CLT



� Capacity building initiatives

2 Undertake feasibility

studies for proposed

community development

projects


the proposed meeting schedule for the studies to be

undertaken.

� Develop the needed notices to provide background

information on the studies to be undertaken.


intention of the studies, who needs to attend, who will be

undertaking the studies, what is expected of community

members, how will it be conducted, when it will be

conducted.)

� Affected communities (including hosts)




� Paramount Chief


� Letter


� Pamphlets

� CLT


3 Facilitate individual rights

transfer and certificates

for new houses

Arrange meetings with the various individuals and relevant

authorities involved according to the proposed meeting

schedule.

(Notes: Information shared with community members and

traditional authorities need to be treated with needed

� Affected property owners )



� Paramount Chief


� Letter

� CLT




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sensitivity since it will potentially include personal

information.) � Ministry of Internal Affairs

� National Housing Authority

� Letter

� Telephone

4 Issue notice to vacate to

affected property owners

(allow for resolving of

appeals)

� Develop a letter to be issued to the relevant Ministries,

regional, local, traditional authorities and social NGOs

informing them of the notice to vacate.

� Posters/notices and pamphlets should also be made

available to affected communities containing the same

information as stipulated for the letter.

(Notes: In this letter, poster/notice and pamphlets the

procedure/process to vacate needs to be clearly stipulated

together with the community’s process foe recourse and

submission of grievances or request for more information.

The CLT should be readily available for community

questions or submission of grievances.)



� County Member of Parliament




� Paramount Chief


� Letter

� Focus group meetings (where applicable, appeals)


� Pamphlets

� Map

� CLT



� Rap Steering Committee (RSC) /

Resettlement Committee (RC)

� Letter

� Email

� Map � Green Advocates

� Liberia Refugee Repatriation and

Resettlement Commission

� Marvoe Development Association




� Ministry of Public Works




� Land Commission

5 Relocate affected parties

to replacement site

CLT needs to assist and be present during the relocation.

The team should also be available to address requests for




� CLT



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information, clarification of information or ready to facilitate

grievances.

� Paramount Chief



6 Finalise sign-off on

property transfer

documentation (allow for

at least one month

retention period)

Arrange meetings with the various individuals and relevant

authorities involved according to the proposed meeting

schedule.

(Notes: Information shared with community members and

traditional authorities need to be treated with needed

sensitivity since it will potentially include personal

information.)

� Affected property owners



� Paramount Chief


� Letter

� CLT







� Letter

� CLT


� Telephone

7 Clear and prepare

agricultural land for

implementation of

community development

projects

CLT needs to assist and be readily available during this

phase to address requests for information, clarification of

information or ready to facilitate grievances.

(Notes: Authorities, Agencies and NGOs only need to be

informed about the clearing and preparation which needs to

include a detailed schedule, who will responsible for

completion of the work, how will monitoring take place and

affected community’s process for recourse and/or

submitting grievances.)

� Affected and host communities



� Paramount Chief


� CLT



� RSC / RC � Letter

� Email

� Map � Green Advocates











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� Land Commission

8 Initiate community

development and

livelihood restoration

projects


the proposed meeting schedule.

� Develop letter containing details of the restoration

projects together with the proposed schedule. A

poster/notice and pamphlet should also be developed

for communities.


intention of the projects, who will benefit, how will they

benefit, who will be undertaking the projects, what is

expected of community members, how will it be conducted,

when it will be conducted. It must be noted that some of the

Governments proposed for consultation might already be

part of the RSC. It is proposed that Authorities, Agencies

and NGOs only be informed about the projects which

needs to include a detailed schedule, who will responsible

for completion of the work, how will monitoring take place

and affected community’s process for recourse and/or

submitting grievances.)




� Paramount Chief


� Letter



� Pamphlets

� CLT




� Email

� Map


� Green Advocates











� Land Commission




9 � Establish and actively manage feedback structures

which will enable efficient monitoring.




� Letter



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Monitor performance of

RAP and CDP

implementation

� Provide periodic feedback (proposed bi-annually),

using a structured report, to authorities and NGOs as

indicated.

� Develop monitoring database.

(Notes: feedback structures for monitoring would be mainly

based on the grievance mechanism, suggestion boxes, and

importantly, the Community Contacts who will be able to

provide more detailed information on how the affected

communities perceive the implementation of the SEP.

These can also include periodic focus group meetings with

the RSC to ensure that information provided is also

considered as part of the monitoring of performance. The

performance would need to be measured against set

criteria and objectives which will become the foundation for

structured feedback reports and identification of issues.

The monitoring database will enable management to

actively track progress against the set criteria and

objectives. Ensuring that the external agency assisting with

the monitoring and evaluation is present at the stakeholder

meetings would be important to showcase independency

and the high level of importance.)

� Paramount Chief


� CLT




� Surveys

� RSC










� Letter

� Email

� Report with structured content



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10 Monitor the ability of

vulnerable groups to

adapt to resettlement

� Establish and actively manage feedback structures

which will enable efficient monitoring.

(Notes: establish very specific engagement channels and

relationships with the vulnerable groups identified which

would ensure that these groups are not r neglected during

consultation. It is proposed that women be used as

Community Contacts to engage with vulnerable groups

specifically. Feedback to the identified stakeholders on

monitoring the ability of vulnerable groups to adapt to

resettlement will be part of activity 9 above. The IFC

provides engagement guidelines and steps for vulnerable

groups on their website. In brief: (1) Identify key individuals

and groups (2) Ensure correct and rightful representation

during consultation (3) Create a safe environment for

discussions.)

� Vulnerable groups

(Notes: visit www.eqavet.eu for more

information, guidance and definitions on

vulnerable groups.)

� Letter

� Focus group meetings / One-one consultations

� CLT




� Surveys

11 On-going consultation

with affected and host

communities

� Develop a schedule for consultation which needs to be

followed.

� Determine the important aspects which need to be

addressed with communities, local/traditional

authorities, regional/district authorities, NGOs,

authorities and agencies.

� Develop the needed print materials and/or reports for

regional/district authorities, NGOs, authorities and

agencies to provide an update on the RAP

(Notes: it will be critical to keep track on developments,

changes in expectations and intentions from affected

communities / traditional leadership and authorities /

agencies / NGOs. This can be done by means of ensuring

that feedback received, whether by comments or

grievances, are captured and analysed. This level of details

needs to be fed through to Aureus Mining’s decision

� Affected and communities



� Paramount Chief


� Letter



� Pamphlets

� CLT



� Surveys


� Email

� Telephone

� Map

� Green Advocates





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makers to ensure that social and project risks /

opportunities are identified.)








� Land Commission





� Report with structured content

� Online media

� On-on-one consultations (where applicable)

� Workshops (where applicable)



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Appendix 1: Draft stakeholder database


AMI2252

Stakeholder Name and Surname Contact Information

Government / Authorities

Ministry of Agriculture Dr. Sizi Subah

Deputy Minister for Technical

Services

Gardnersville, Montserrado County

Liberia

Ministry of Public Works Hon. Victor Smith

Deputy Minister/Acting Minister

Lynch Street,

Monrovia, Liberia

Ministry of Planning and

Economic Affairs

Mr. Harrison Luo

Deputy Minister

+231 886 746 744

[email protected]

Capital Hill

Monrovia, Liberia

Ministry of Internal Affairs Mr. William Jalleh

Director for Culture & Custom

Affairs/Administration

+231 886 110 447

Capital Hill

Monrovia, Liberia

Ministry of Transport Hon. Charles Nelson

Deputy Minister for Land & Rail

Broad Street

Monrovia, Liberia

Ministry of Lands, Mines

and Energy

Hon. Carlton Solo Miller

Deputy Minister of Planning

Camp Johnson Street

Capital Hill, MOnrovia

Environmental Protection

Agency (EPA)

Mr. Nathaniel Blama

Technical Advisor

+231 886 518 635

4th Street, Sinkor

Monrovia, Liberia

Lands Commission Dr. Cecil T. O. Brandy

Chairman

Jallah Town

Monrovia, Liberia

Forestry Development

Authority (FDA)

Hon. Harrison Kanweah

Acting Managing Director

Whein Town, Paynesville

Mont. Co. Liberia

NGOs

Green Advocates Broad & McDonald Streets

Monrovia, Liberia

Atty. Alfred Brownell

Managing Director

+231 886 444 472

Society for the

Conservation of Nature

Congo Town

Monrovia, Liberia

Mr. Alex Peal

Managing Director

Flora & Fauna International Congo Town

Monrovia, Liberia

Mr. Jens Lund

Country Director

Conservation International Congo Town

1000 Monrovia, 10 Liberia

Jessica Donovan-Allen

Country Director

Sustainable Development

Institute

P.O. Box 5678

Duarzohn Village

1000, Monrovia, 10, Liberia

Jonathan W. Yiah

+231 642 6271

[email protected]

Liberia Refugee,

Repatriation and


Hon. Abla Williams

Commissioner

9th street, Sinkor, Cheeseman Avenue.

P.O Box 10-9043. 1000 Monrovia-

Liberia

+231 886 510 542


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Liberia Extractive

Industries Transparency

Initiative

Mr. Sampson S. Tokpa

Head of Secretariat

Old Bureau of Budget Building Capitol

Hill, Monrovia, Liberia

Communities / CBOs

Marvoe Development

Association

Mr. Momo Samah

Acting Board Chair

Jene Brown, Grand Cape Mount

County, Liberia

Kinjor Town Council Mr. E. Siafa Fahnbulleh Kinjor Town,Gola Konneh District,

Grand Cape Mount County, Liberia

Kinjor Town Chief Hon. Varney Darbolo Kinjor Town, Gola Konneh District,


Larjor Town Chief Hon. Lahai Jackson Larjor Town, Gola Konneh District,



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Appendix 2: Grievance Mechanism


AMI2252

1 GRIEVANCE MECHANISM

To date a grievance mechanism has been put in place, as per this plan, and it will continue to

evolve based on the input from communities and the company systems.

1.1 Introduction

In accordance with the IFC PS1, a grievance mechanism needs to be developed when the

possibility exists that communities may be affected by a project. The aim of such a mechanism

is to receive and facilitate the resolution of grievances raised by affected communities. A

grievance is a complaint or concern raised by an individual or Organization who judges that

they have been adversely affected by the Project during any stage of its development.

Grievances may take the form of specific complaints for actual damages or injury, general

concerns about project activities, incidents and impacts, or perceived impacts.

The grievance mechanism described in this section is distinct from the Implementation Plan

for Issues Resolution presented in the previous section, in that the Issues Resolution Plan

focuses on steps to ensure that issues raised to date during SE activities are adequately dealt

with during current and future project phases. The grievance mechanism, by contrast, is a

system for ensuring that any new issues and concerns are recorded and adequately

addressed. Future grievances could possibly relate to issues already raised and addressed in

the Issues Resolution Plan; conversely, it may be meaningful to revise the Issues Resolution

Plan at periodic intervals to incorporate steps for addressing regularly-occurring grievances.

Grievances raised by stakeholders need to be managed through a transparent process, which

is culturally appropriate, understandable, readily acceptable to all segments of affected

communities, at no cost and without retribution. The mechanism should be appropriate to the

scale of impacts and risks presented by a project and beneficial for both the company and

stakeholders. The mechanism must not impede access to other judicial or administrative

remedies. Key requirements for developing and implementing a grievance mechanism are

highlighted in Table 11 below.

Table 11: Grievance Mechanism as related to IFC Performance Standards

Principle Key components

Performance Standard 1

Social and Environmental Assessment

and Management

“The client will establish a grievance mechanism to

receive and facilitate resolution of the affected

stakeholders’ concerns and grievances about the

client’s environmental and social performance”


Labour and Working Conditions

“The client will provide a grievance mechanism for

workers (and their Organizations,…) to raise

reasonable workplace concerns use an

understandable and transparent process that provides

feedback to those concerned”


Community Health, Safety and Security

“A grievance mechanism should allow the affected

community to express concerns about the Community

Health, Safety and Security”


AMI2252

This grievance procedure sets out the steps to be taken to resolve grievances, role players

involved in the process and timeframes to resolve grievances. The types of grievances people

may raise include but are not limited to:

■ Negative impacts on communities, which may include but not be limited to financial loss,

physical harm and nuisance from construction or operational activities;

■ Health and safety risks;

■ Negative impacts on the environment; and

■ Unacceptable behaviour by staff or employees.

In order to ensure consistency in processes and elimination of stakeholder uncertainty, the

steps used for the SEP and RAP are is the same. It is critical that communities understand that

all grievances lodged, regardless of the project phase or activity being implemented, will follow

the structure i.e., one mechanism needs to be followed to facilitate all grievances or complaints.

The Social Manager will have overall responsibility for addressing grievances, excluding

grievances received as part of the resettlement process. For resettlement related grievances

the Social Manager needs to work in collaboration with the Community Development Officer

(CDO). While it may be possible to verbally resolve some grievances, these must still be

recorded on the grievance log form for recordkeeping purposes. Where the Social Manager

cannot resolve grievances directly, these will be escalated to a grievance committee. If

grievances are still unresolved, the Social Manager will provide information to the affected

party on the mechanisms for addressing complaints via legal redress.

1.1.1 Step 1: Lodging a grievance

A formal grievance can be lodged at the NLGM offices located at the exploration camp.

Grievances may be lodged by a variety of different means including direct reporting to a

Community Liaison Officer (CLO), at suggestion boxes, at Project sites, by posting in

suggestions, by telephone, by mail or on the web. All Project staff are informed that they must

pass all submissions that could be considered to form a grievance to the Community Liaison

Team (CLT) as soon as possible after they are received.

Details of the person lodging the grievance will be noted. All grievances will be recorded by

the Social Manager who is in charge of the Grievance Mechanism and needs to be captured

in a central Grievance Issues Database where the status of the grievance captured will be

monitored. Community and village leaders and government departments will also be advised

to pass any complaints they receive to local CLOs from where they will be forwarded to the

Social Manager.

The CLO will record each grievance on a standard Grievance Form and will ensure that the

name of the village, the date recorded, the name of the complainant and the name of the

person that received the grievance are noted.

The complainant will be required to complete a grievance form with the assistance of the CLO

or Social Manager, who will record the grievance in a grievance log according to the category


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of grievances (for example unfair employment process being followed, loss of livelihood or

communication and information not transparent). A grievance can also be lodged by sending

a grievance form or written complaint directly to NLGM management. All grievances will be

logged in a grievance log file.

1.1.1.1 Issue Evaluation Methodology

The methodology assigns levels of relative risk (High/Medium/Low) to captured issues, to be

used as a basis for issue escalation through the grievance procedure outlined in Figure 4. The

following two criteria are used within this methodology:

� Issue magnitude: this is the extent to which an issue affects external stakeholders.

� Impact severity: this is the extent to which an issue impacts negatively upon the

Organization’s:

• mission to deliver a competitive and sustainable rate of return to

shareholders; or

• commitment to safely produce the resource mined for in a manner that

protects the environment, public health and support to communities.

Imp

act

Severi

ty

Issue magnitude

Low Medium High

Low Minor Minor Moderate

Medium Minor Moderate Major

High Moderate Major Major

Figure 4: Impact Severity–Issue Magnitude Matrix

The various categories for Issue magnitude and Impact severity are defined below:

� Issue magnitude

� Low: the issue involves or is related to isolated individual(s) or household(s).

� Medium: the issue involves or is related to a local community.

� High: the issue involves or is related to a regional or global community.

� Impact severity

� Low: no or little impact on the company’s ability to meet its mission or

commitment if the issue is not adequately addressed.

� Medium: the company’s ability to meet its mission or commitment could be

affected if the issue is not adequately addressed.

� High: the company’s ability to meet its mission or commitment will certainly be

affected if the issue is not adequately addressed.

Example: A single household that is

displaced by construction of an access

route would score Low for Issue Magnitude

because only one household is affected, but

would score High because the company’s

ability to meet its commitment would

certainly be affected if the issue is not

adequately addressed. The issue would

receive an overall evaluation of Moderate.


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1.1.2 Step 2: Acknowledgement

Once the grievance is recorded, the stakeholder will be provided with a copy of the Grievance

Form signed by the complainant and by the Social Manager. This copy serves as an

acknowledgment that the grievance has been received.

The Social Manager will acknowledge receipt of the grievance in writing within seven working

days. The letter will specify the name of the NLGM responsible person and process that will

be followed in addressing the complaint. The letter will also provide a reference number and a

probable date for resolving the grievance.

1.1.3 Step 3: Investigation

The Social Manager will consider and prioritise the grievance received. Where applicable, the

Social Manager or CLO will take photographs and/or interview any bona fide witnesses. If the

Social Manager is unable to resolve the grievance, he/she will forward the grievance to a

grievance committee. Where possible, grievances will be finalised within 30 days of receipt.

The complainant might be contacted during this time to clarify issues.

1.1.4 Step 4: Resolution and sign-off

Once a complaint has been investigated, a letter will be sent to the complainant, explaining the

outcome of the investigation and the proposed course of action to resolve the grievance. The

Social Manager will contact the complainant in person if this is required and explain the results

of the investigation and the proposed course of action. If the complainant is satisfied that the

complaint has been resolved, he/she will be required to sign a statement confirming that the

complaint has been resolved.

If the complaint has not been resolved by mutual agreement, a re-assessment may be

undertaken if new information becomes available in support of the claim/complaint. If the

complainant is still not satisfied with the resolution, the grievance will then go into mediation. If

applicable, the grievance committee will monitor the implementation of the resolution and the

claimant’s satisfaction with this implementation. Resolution and sign-off on the grievance

captured will be noted in the Grievance issues database. All grievances, regardless of their

status, will be kept since it will provide proof in case of litigation.

1.1.5 Step 5: Mediation

Unresolved grievances will be investigated by a grievance committee, which will include

members of senior management. This committee will only meet to resolve problems which

cannot be resolved during steps one to four. NLGM will provide for an independent arbitrator

if grievances cannot be resolved internally.

The grievance procedure is illustrated in more detail in Figure 5 below:


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Figure 5: Grievance Procedure