KPDC KRIBI POWER DEVELOPMENT COMPANY

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1 Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized Public Disclosure Authorized KPDC KRIBI POWER DEVELOPMENT COMPANY KRIBI POWER PROJECT ACTION PLAN No DESCRIPTION DUE DATE STATUS PS 1 Measures 1 1. Update KPDC Environment and Social Management Plan ( ESMP ) to include: Actions contained in this SAP, requirements stated in any government permitting document, and such other actions as KPDC may identify as part of its corporate commitment to good environmental practice. The actions will be time-bound; the CIPP, actions contained in this SAP, items identified by the external social and environmental monitor (see item #5 below), and such other actions as KPDC may identify as part of its corporate commitment to good social practice. The actions will be timebound. 2. Up-date and implement KPDC s ESMP annually in the event that there is any material change to the company's operation, risk profile, or potential E&S impact. In the case that there is no material change, KPDC will inform the Lenders to that effect in the AMR. January 15, 2012 Prior to the end of each fiscal year 3. Implement the ESMP Based on the schedule contained in the EMP As part of its corporate commitment to good environmental practice, KPDC has committed to drill 20 water wells to bring potable water in 20 villages along the project area. The process is underway and to date, 10 water wells have been completed, and the 10 remaining are due by 15 March 2012 There are no new CIPP actions to be reported at this stage No update The ESMP is being implemented as required. See Monitoring Report for more details 4. Report on ESMP implementation annually See Monitoring Report 2 1. Assign a KPDC Grievance Officer to the ESIA and Resettlement Coordination Unit (ERCU) Develop and publicly release a grievance mechanism for KPDC based on the RAP, but covering all aspects of KPDC s operations. Prior to first disbursement. Prior to first disbursement. Catherine Gaelle Minya has been appointed as KPDC Grievance Officer See attached in Appendix 1 2. Develop and backfill a grievance register that will list the name of the person registering the grievance, the nature of the grievance, track the grievance through the grievance mechanism, provide information about the outcome of the grievance and the length of time that it took to resolve. Prior to first disbursement Grievance register in place, updated daily 1

2 No DESCRIPTION DUE DATE STATUS 4 1. Develop Terms of Reference for an external social and environmental monitor acceptable to Lenders. Three months after first disbursement Preparation of TOR has been initiated 2. Release of Request for Proposal and deadline for receipt of proposals One month after approval of the Terms of Reference by Lenders 3. Final selection of external social and environmental monitors (and contract signed). 4. First visit of external social and environmental monitors to project area. 5. Semi-annual visits of the project external social and environmental monitors during period of construction, annually thereafter. 6. Close out audit, with final external monitor action plan PS 5 Measures 5 1. Provide monthly Contractors reports to the International Lenders and the Local Loan Facility Agent in respect of the Project and quarterly reports prepared by KPDC. June 2012 July 2012, thereafter the site visit by external E&S monitor should be conducted before the audit/verification report is provided to Lenders. Every six months after the first visit, and annually after the end of construction. The end of year visit shall be done no later than when the Annual Monitoring Report (AMR) is due to Lenders. The report should be received by the International Lenders and the Local Loan Facility Agent no later than 30 days after the AMR is due to the International Lenders and the Local Loan Facility Agent Three years after the date of financial closure Starting immediately after financial closure and monthly or quarterly, as applicable, thereafter until the earliest of (i) such time as KPDC and the International Lenders and the Local Loan Facility Agent agree to January 2012 and February 2012 construction reports provided 2

3 No DESCRIPTION DUE DATE STATUS amend the frequency of the reports; and (ii) the date falling 3 months after Commercial Operation Date. 2. If any other projects are developed under KPDC then KPDC will develop a good practice procedure for carrying out compensation and other resettlement activities for the relevant project PS 7 Measures 7 1. Provide to the International Lenders and the Local Loan Facility Agent a detailed implementation plan for the CIPP, with budget, staffing plan, and calendar-based implementation plan. Three months prior to any construction activity 4.5 months after first disbursement Not currently applicable 2. Carry out implementation plan for CIPP Based on schedule in the implementation plan PS 8 Measures 8 1. Provide to the International Lenders and the Local Loan Facility Agent a Cultural Heritage Management Plan for the Project to include, (i) specific time bound plans and procedures for managing impacts on sacred trees, graves, and other cultural heritage, (ii) a chance finds procedure for KPDC as a whole. Prior to disbursement See attached in Appendix 2 3

4 APPENDIX 1 GRIEVANCE MECHANISM The ESMP has considered three categories of grievance: Grievances by Project Affected People (PAPs) or their successors in relation to compensation and/or resettlement; Community concerns regarding environmental and social impacts of the project; and Employee workplace grievances. In order to ensure smooth and efficient treatment of all grievances in relation to the project, KPDC, in relation with the local authorities and according to the national regulations, has put in place and maintains grievance procedures that have been disclosed and are well understood by all PAPs, are transparent and ensure efficient resolution. 1. RESETTLEMENT GRIEVANCES Resettlement grievances registered during the compensation process are the following: Disputes over census of affected properties and compensation amounts; Disagreements between PAPs regarding ownership of assets for which there is a compensation entitlement; Disputes of successors of deceased PAPS for entitlement of compensation; Dissatisfaction of people whose assets have not been directly affected and who want to be entitled to compensation; In order to ensure that grievance procedures are known and understood by all PAPs and host communities, KPDC has hired and NGO, Cameroon Ecology to organize village meetings where compensation issues were discussed. These meeting were attended in each village by all PAPs, the traditional authorities (village Chiefs, Notables and Elders) and local authorities. The grievance procedure in the context of resettlement relating to the project is as follows: (i) A PAP with a grievance initiates the process by either: a. writing to the Divisional Officer, who subsequently informs KPDC on the existence of the claim, b. calling or writing to the KPDC Grievance Redress Officer, or c. speaking with Cameroon Ecology (or handing to them a letter addressed to the DO or KPDC) who relays the grievance to KPDC. (ii) Following receipt of the grievance, the KPDC Grievance Redress Officer will, in relation with the DO, organize a meeting of the Census Commission whose legal responsibility is amongst others to follow-up all grievances relating to the compensation process. The plaintiff (and any counterpart if applicable) is notified for the date and place of the meeting. These meetings are normally organized monthly, but this can be shortened to two weeks in case there is a great number of grievances; (iii) During the meeting, all parties have the opportunity to present their point of view, and if an agreement is reached, a PV is signed to settle the issue. In case it is necessary to make 4

5 a site visit, the Commission makes an appointment to visit the aggrieved party(s) within 7 days, accompanied by traditional authorities and with presence of the Grievance Officer; (iv) If the grievance remains unresolved after the site visit, the plaintiff(s) are asked to provide all documents supporting their claim and when received, the Commission then proposes a solution to resolve the grievance based on the additional received information; (v) If the grievance still remains unresolved following the above process, the plaintiff(s) are asked to seek legal redress through the courts. 2. COMMUNITY GRIEVANCES Grievances registered in this category relate to the following project impacts: Noise, air or water pollution during construction; Health and safety fears; Employment opportunities; and Concerns regarding behavior of workers during construction phase. A Complaint Register has been placed at the power plant site in Mpolongwe where most of these impacts have been registered. In addition, as regular meetings are organized by Cameroon Ecology with affected communities at the power plant site and along the transmission line corridor, any reported grievances are recorded and thereafter transmitted to KPDC who takes the necessary mitigation measures. 3. EMPLOYEE WORKPLACE GRIEVANCES All workers employed for the construction phase have been informed in meetings organized by the KPDC Construction Management Team of employee grievance procedures, according to the contractors and subcontractors policies, and workers rights under Cameroon law. Typical employee grievances registered are in relation to: Wage disputes; Unfair dismissal; Discrimination ; For the project, all workers were informed to firstly report any grievances to their supervisor, and in case they are not satisfied of the result, they can contact the KPDC HSE Officer who will liaise with the supervisor and seek resolution of the issue. If resolution still cannot be found workers are entitled to write to the management of the contractor and/or KPDC Construction Manager. In case both parties are unable to resolve the issue, the employee is free to take legal action in accordance with the law. 5

6 APPENDIX 2 CULTURAL HERITAGE MANAGEMENT PLAN The below procedures have been prepared in order to set the necessary actions to be implemented for the management of sacred trees, graves, cultural heritage symbols and for chance finds affected by the project construction activities. Management of sacred trees and other cultural heritage symbols In case a sacred tree (or any other cultural heritage symbol) is signalled by the population in the construction area, the contractor will avoid cutting it and will inform KPDC immediately. KPDC and the village chief will investigate to confirm the sacred nature, and agree with the owner on the required solution for removal of the spirits. Generally, a traditional ceremony will be organised after which the tree will be allowed to be cut. KPDC, in agreement with the village chief and the owner, will provide some gifts for the ceremony to be organised. Management of graves Two available management options have been agreed in case a grave is found on a project site: 1. Leaving the grave in place (preferred option), or 2. Displacement of the grave to another location defined by the owner. The two above options will be proposed to the owner, who will have to select one after all clarification on their management has been provided for each case. In case the owner prefers leaving the grave in place, the contractor will take the necessary precautions to avoid its destruction during the works. The contractor will therefore adequately mark the identified grave to make it visible by all workers, and protect it if necessary for any accidental damage. The works will be performed around the area with great precautions in order to avoid any disturbance of the grave. In case a grave is however accidentally damaged, it will be rebuilt at a standard at least equal to the existing. In case the owner prefers the relocation of the grave, KPDC will take all the necessary administrative steps to ensure that the corpse is taken out and re-buried at a replacement place indicated by the owner in accordance with the laws and local traditions. The cost of such relocation (including the traditional ceremony to be organised by the affected family) will be borne by KPDC. Chance finds management The probability of chance finds is higher on the plan site than in the transmission line corridor. For the power plant site, an archaeological study was done by IRD, a specialised archaeological company prior to the starting of construction, and all areas with potential artefacts were identified for further investigation. During the site clearance and levelling works, IRD was hired by KPDC to take care of the safe treatment of all areas containing artefacts. Therefore, IRD experts were on site during the initial levelling works, and when a potential archaeological site was identified, they surrounded it with a red tape banner and no excavation work could be done there until all artefacts have been properly removed in 6

7 accordance with best archaeological practices. The removed artefacts were then put in wooden cases and stored in IRC s premises for further disposal by the authorities in charge of culture. For the transmission line corridor, it was not possible to prior identify all towers locations and make the investigation as for the power plant site. It was therefore prescribed to the contractor that in case an artefact is found during towers excavations, the works will be stopped immediately and KPDC must be informed of the situation. KPDC will then promptly call IRD for further investigations, removal and disposal of any valuable findings. In the meantime, KPDC will investigate with the contractor the possibility to move the tower position to a nearby area in order to not delay the construction works. In case the displacement is not possible, the contractor will be authorised to continue working in the location only after IRD has removed all artefacts or chance finds from the site. 7