1 PROJECT OVERVIEW. Quantum Power Ghana Gas Limited 1 Knight Piésold Consulting GMF

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1 1 PROJECT OVERVIEW Quantum Power Ghana Gas Limited (hereinafter referred to as Quantum Power) is a developer, owner and operator of electricity generation assets and power-related infrastructure throughout Africa. Quantum Power proposes to develop and operate a Liquefied Natural Gas (LNG) Project in Tema, in the Greater Accra Region of Ghana. The proposed Project will install, commission and operate the necessary infrastructure required to import, store, re-gasify LNG and deliver regasified LNG to Independent Power Producers (IPPs) and industrial consumers in the Tema area for an initial period of ten years. The proposed Project will comprise of the following components: 1. A Floating Storage and Re-gasification Unit (FSRU) 2. Offshore mooring and support for floating units (FSRU as well as LNG supply vessels) 3. Subsea gas pipelines 4. Landing facilities and distribution and 5. Ancillary infrastructure. The Tema LNG Project is anticipated to impact both directly and indirectly on communities and activities in the area of the proposed project in the following ways: People residing in area, and potentially within ancillary infrastructure right of ways, will be physically and/or economically displaced; Positive benefits that will accrue to the project affected communities through the provision of community development programs and social plans. Positive economic benefits may be experienced during the construction phase of the project as a result of short term employment opportunities and increased local spending potential. Negative impact on fish and fishery resources. This impact has the potential to influence the entire supply chain; from fishermen to fishmongers. Negative social impacts may result from construction activities with the in-migration and influx of people to the area and construction force presence. Negative impacts may result from construction activities as a result of exposure to dust, noise, vibrations, increased traffic and safety hazards. In this context, the impacts (both positive and negative) of the proposed LNG project can potentially affect the lives of surrounding communities, thus giving rise to grievances. These potential grievances may relate to any aspect of the project. They might be felt and expressed by a variety of parties including individuals, groups, communities, entities, or other parties affected or likely to be affected by the social or environmental impacts of the project. With this in mind, and in following international best practices and trends, Quantum Power is expected to establish suitable mechanisms, channels, resources, personnel and budget to manage Project-related grievances, via a Grievance Mechanism/framework. This document provides an outline of the proposed Grievance Mechanism for the Tema LNG Project which Quantum Power will have to implement throughout the development of the project. As part of the environmental and social impact assessment for the Project, a Grievance Mechanism will be set up as potential impacts of the project are likely to stimulate the raising of grievances. The Grievance Mechanism thus provides a structural framework and guidance with tools and approaches which Quantum Power can adopt to resolve all project conflicting issues. Quantum Power Ghana Gas Limited 1 Knight Piésold Consulting

2 2 INTRODUCTION TO GRIEVANCE MECHANISM A grievance can be defined as an actual or perceived problem giving ground for complaint. According to IFC requirements, a Grievance Mechanism:.addresses concerns promptly, using an understandable and transparent process that is culturally appropriate and readily accessible to all segments of the affected communities, and at no cost and without retribution. To establish strong community relationships at the earliest and most critical point, Quantum Power will implement its Grievance Mechanism to manage and appropriately address complaints made by the population located within the Project area of influence during its different phases (i.e. construction, operations and potential decommissioning). Engaging the communities early and providing a transparent mechanism to consider all of their views will be a unique experience for the Project Affected People (PAP) and provides a basis for establishing positive relationships between Quantum Power and the surrounding communities. To this end, the Quantum Power Grievance Mechanism guarantees confidentiality and specifies the time frames in which grievances should be resolved. The Grievance Mechanism will provide the process by which people affected by the Project can bring their comments, concerns and grievances to the Tema LNG Project community management or external relations team. This document describes the objectives, scope and mechanisms of the Grievance Mechanism which will be available to any person (such as community members or others who consider themselves affected by Project activities). This will enable them to readily and efficiently communicate their concerns and complaints to Quantum Power (the term complaint will also refer to grievances and concerns ). The effective management of the procedure will ensure good relations between Quantum Power and the surrounding communities and PAPs. 2.1 GENERAL OBJECTIVE The objective of the Grievance Mechanism is to provide a mechanism/process to receive and respond timely to any complaints made about the Project (including those from members of the communities, local businesses and other stakeholders) and to be the basis for developing appropriate mitigation strategies. 2.2 SPECIFIC OBJECTIVES Establish a mechanism for responding to complaints in an understanding, transparent and culturally appropriate way Develop an accessible, transparent and an efficient complaint procedure for people involved in and/or impacted by the Tema LNG Project Facilitate effective dialogue and open lines of communication with the public Manage expectations and/or negative perceptions towards Quantum Power Establish a system of investigation, response and prompt complaint resolution Minimize grievances regarding the Tema LNG Project and Quantum Power Improve the Project social performance by evaluating complaints as a basis for taking remedial or preventive actions or developing responsive initiatives. 3 KEY ELEMENTS OF THE GRIEVANCE MECHANISM The key elements of a robust Grievance Management Procedure are the following: Quantum Power Ghana Gas Limited 2 Knight Piésold Consulting

3 An agreed and disclosed grievance submission and response procedure. It is critical that Quantum Power is committed to and adopts the Grievance Management Procedure, and that affected parties have sufficient access to knowledge and information to make use of the procedure. Transparency and knowledge transfer are thus extremely important. Clear rules, performance criteria and lines of accountability: The Grievance Management Procedure must be underpinned by clear operating rules, and accountability must be unambiguous. Performance criteria must be set, monitored and reported on. These might include measures like response time, feedback evaluation and resolution success rate. A hierarchy of response and resolution: The procedure should encourage the resolution of issues at the most appropriate level. It is mutually beneficial that grievances be settled quickly between the mandated staff and the affected parties. Where suitable resolution is not possible, a hierarchy of response should be in place. In unresolved cases, grievances may be referred to a neutral mediator, with recourse to courts as a final (but ideally unused) option. Fair, objective and consistent application of the Grievance Management Procedure: The procedure must be applied predictably and without favour. If complainants do not trust the procedure and resort to other ways of seeking redress, the mechanism is ineffective and a waste of time and resources. The mechanism ensures that women, vulnerable groups or minorities are considered and privacy is ensured: The procedure will include mechanisms that allow women, vulnerable people (elderly or sick) and minority groups to have an equal and fair access to voice grievances. Where grievances are reported, the privacy of all people will be ensured to the strictest of standards. 3.1 KEY PERFORMANCE INDICATORS The following performance indicators have been developed for the Grievance Mechanism. Participation Percentage of grievances to the Project channelled through the Project Grievance Mechanism the target is to have all grievances addressed through the Project Grievance Mechanism before complaints cause undue stress, reach the media or the courts. Effectiveness Percentage of complaints receiving effective and timely response (target is 100%) Resolution Percentage of complaints resolved in the first and second reviews the target is to resolve at least 80% of complaints. Recurrence Reduction in number of complaints by categories: environmental issues, employment opportunities, traffic congestion, misinformation or lack of information and behaviour of employees of Quantum Power or its contractors the target is to gradually reduce the number of complaints in each category by 50% year-on-year. The intention is to learn from grievances and respond to them in a manner that, over time, reduces their rate of occurrence. Influence Quantum Power Ghana Gas Limited 3 Knight Piésold Consulting

4 This indicator identifies policy or performance/conduct changes in Quantum Power influenced by an evaluation of Grievance Mechanism indicators and analysis of grievances. 3.2 COMPLAINTS TYPES The Project may receive complaints such as those about local employment, environmental concerns (e.g. air quality, noise, and traffic congestion), unfulfilled expectations regarding employment and procurement/sale of goods, opportunities, and infrastructure damage. Complaints will be classified by different criteria: by the type of process (involving complaints to the government, NGOs, contractors), involving contractors; according to geographic area; or by the nature of the complaint. There may also be complaints about the public consultation process or construction impacts. Also, complaints may arise out of Quantum Power s social and environmental performance, economic conditions, cultural issues, behaviour of Quantum Power or contractors personnel, information or lack of information about the Project. 4 RESPONSIBILITIES AND SCOPE The Grievance Mechanism will be available for those living or working in the areas of influence communities around the Project including: Bankuman, Local fishing harbour and Kpone Katamanso. This will be managed by a Grievance Management Officer who will be part of team of Community Liaison Officers and supported by Community Relations Manager. Any person with the right to participate in the Grievance Mechanism will have easy access to it and will be encouraged to use this confidential complaint system. The Procedure does not replace the public mechanisms of complaint and conflict resolution in the Ghanaian Legal system but attempts to minimize use of them. 5 PROPOSED GRIEVANCE MANAGEMENT PROCEDURE 5.1 ORGANIZATION Mechanism to Identify and/or Receive Grievances: It is suggested that the Grievance Management Officer adopts a monthly turn-over rate for complaints in which receipt of the complaint/suggestion will be acknowledged within 15 days and issues will be resolved within 30 days. It is understood that, a Grievance Management Office will be established on site or within one project affected community and that the Community Relation Officers at a minimum be required to visit traditional authorities and communities to discuss project details. This is agreed to be done every fortnight during project construction and at the end of every month during operation. The Grievance Management Officer will be available to visit the site within short notice to address grievances that are more urgent and/or pressing in nature. Attention to Grievances by Area of Influence: Upon the initiation of on-site activities (including offshore surveying, if involving site disturbance) and then during construction, an on-site office and resources will need to be established, under the oversight of the Community Relations Manager. In terms of the procedure; grievances, comments and suggestions can be submitted in writing, telephonically or presented verbally to the Grievance Management Officer. Collection points for the submission of written grievances and a grievance hotline will need to be established by Quantum Power and agreed to with community representatives. The grievance hotline will also be communicated to community Quantum Power Ghana Gas Limited 4 Knight Piésold Consulting

5 members as well. Current suggestions are to make use of the traditional authority officers as additional collection point for grievances and this will be tested throughout the process. Reception of Grievances: Verbal submissions may be made to the traditional authorities first, but the grievance must then be directed to the Grievance Management Officer, whom will record the grievance on a Grievance Report Form (Appendix A1). The Grievance Report Form includes the following information: - Case number; - Date the complaint was reported; - Complainant s name and contact details 1 ; - Nature of the complaint; - Department designated to investigate and resolve complaint; - Follow-up action / corrective action; - The final outcome; and - Any information on the case closure, including the date. Receipt of Grievance and Registry: A register of grievances is to be maintained by the Grievance Management Officer who will discuss and present to the Community Relations Manager. The Community Relations Manager will disclose all documented grievances to management of Quantum Power for decision making. Receipt of grievances will be acknowledged within a 15 day period by letter or verbal/telephone means in a culturally acceptable language. Where additional investigations are required to resolve the complaint/suggestion, the complainant will be notified in a 30 day period thereof and the timeframe required for resolution. Where possible, grievances will be addressed directly by Grievance Management Officer in consultation with the Community Relations Manager. If wider consultation is necessary, grievances will be forwarded to a third party. This third party should be neutral, wellrespected, and agreed upon by both Quantum Power and the affected parties. These may include public defenders, legal advisors, and legal Non-Governmental Organisations (NGOs), or university personnel. In cases where further arbitration is necessary, appropriate government involvement at the district or metropolitan level will be requested. Further to the above, where the grievance is directly related to resettlement or compensation matters, the Quantum Power will establish a Grievance Resolution Committee. The committee will be composed of persons as determined by Quantum Power and key opinion leaders within the project area. As a last resort, aggrieved parties have a right to take legal action. 5.2 PROCEDURE Grievances are received in writing or verbally by the Grievance Management Officer directly from the complainant or via the traditional authorities, Quantum Power employees, consultants or contractors. The Grievance Management Officer ensures that: The grievance is entered into the Grievance Register and assigned a case number. 1 Name and contact details are necessary for interaction around the resolution of the grievance. Anonymous submissions will be permitted, but the party submitting should understand that direct response will not be possible. Quantum Power Ghana Gas Limited 5 Knight Piésold Consulting

6 The complainant is informed of the receipt of the grievance, as soon as possible (but within a 15 day period as a maximum timeframe), by an appropriate means (written or verbal) and language. Appropriate action is taken or that the grievance is referred to the appropriate member of the management team within 24 hours of the grievance being registered. The complaint is tracked, investigated and addressed. Feedback is given to the complainant about how the complaint has been addressed to allow dialogue. Feedback is given to the complainant by appropriate means (written or verbal) and language within 30 days of being received. If not resolved during this time, as further investigation is required, the complainant is notified within the 30 day timeframe of this and the time period required for the further investigations. Unresolved grievances and disputes are referred to a credible and independent person or body for arbitration. Quantum Power HR Manager Quantum HSE Manager Power Aggrieved/Affected party Community Liaison Officer/Grievance Management Officer Community Relations Manager Quantum Power Senior Management Contractors and Sub-contractors HSE Managers Figure 1: Grievance Communication Structure 5.3 RECORDS The record of grievances will be held electronically and in hard copy in the Community Relations Manager s offices. This will be available for scrutiny by interested and affected parties. The record will reflect the following: Date and nature of grievance (or comment). Source of the grievance (name and contact details). Date and nature of acknowledgement of receipt. Department designated to investigate and resolve complaint. Details of actions taken to resolve the grievance, or to incorporate the comment. Status box to indicate whether the grievance has been resolved or not. unresolved grievance records will be filed appropriately. Resolved and Quantum Power Ghana Gas Limited 6 Knight Piésold Consulting

7 Minutes of all follow-up meetings with affected parties. 5.4 MONITORING AND REPORTING Quantum Power s management will monitor grievances routinely as part of the broader management of the project. This means that there must be good record keeping of complaints raised throughout the life of the project. On receipt of grievances, electronic notification to management must be distributed. Grievance records must be made available to management at all times. The grievance reports must include: The number and the status of complaints. Quantum Power s responses to the concerns raised by the various stakeholders. The measures taken to incorporate these responses into project design and implementation. These reports and other records will be made available for external review if required. Monthly internal reports will be compiled by the Grievance Management Officer and distributed to the management team. These reports will be available to the public upon request. 5.5 REVIEWS AND RESOLUTION OF GRIEVANCE AND APPEALS The Grievance Mechanism is designed to resolve complaints as quickly and efficiently as possible. If a complaint can be resolved with an explanation, clarification, or delivery of information, these cases will be readily closed and documented. However, some complaints will require special treatment due to their complexity, political sensitivity or due to the nature of the complaint. During the initial review of a complaint, action is implemented in accordance with the Grievance Mechanism, and proposed corrective action is identified, depending on the type of complaint: Complaints Regarding Health, Safety and Environmental Issues Complaints and grievances regarding health, safety and environmental matters will be brought to the attention of the Community Relations Manager to be reviewed with the HSE Manager and, where appropriate, may warrant collaboration with all HSE managers of contractors and subcontractors, specialized consultant, the claimant, community authorities or a government oversight agency. Technical reports will be prepared under the direction of the HSE Manager for these cases. Complaints Regarding Accidental Impacts Events likely to occur during the Project development will be identified and different procedures required in each case defined. These events may include: Traffic and/or Construction Vibration Damage to Houses and Other Structures; Accidental Injury of People; Accidental Death of People and Temporary Disruption of Local Traffic. Complaints Stemming from a Lack of Information or from Misinformation When these cases occur in local communities, a Community Liaison Officers and Grievance Officers will provide an explanation or organize informative workshops about the topics as required by the community of complainant. The information provided will be as clear as Quantum Power Ghana Gas Limited 7 Knight Piésold Consulting

8 possible and will be given in a way appropriate to the recipient (in writing or if literacy is a question, orally) to ensure that any topic related to the Project or that of the contractors is clear. Complaints about the Behaviour of Personnel of Quantum Power or its Contractors If a complaint is made, the Grievance Management Officer will investigate the complaint. A Grievance Management Officer will provide the person who lodged the complaint a written response/report of the result of the investigation and the measures taken. The Grievance Management Officer will also explain verbally the content of the report. If the claimant expresses acceptance of the implemented solution, the Grievance Management Officer will document the acceptance. The case will be considered closed and registered as closed. If the claimant does not accept the proposed solution after the first review, the Community Relations Manager will proceed with a second review of the complaint. 6 DISCLOSURE AND IMPLEMENTATION The following implementation steps are required for the Tema LNG Project on the basis of the above proposed Grievance Management Procedure. Quantum Power will ensure through the Grievance Management Officer and Community Liaison Officers that the project impacted people know about the Grievance Mechanism, how complaints are made, that they feel free to file a grievance and know how to do so. Appointment of a Grievances Management Officer and provision of contact details to the project team for public notification. The Grievance Management Officer and Community Liaison Officers will be in constant contact with the communities, frequently visiting project affected people. Quantum Power must ensure that CLOs have members who live in the Project affected areas. This will provide opportunities to express grievances, either in writing or verbally. If a verbal complaint is made, a member of the CLO will help them express it in writing and will process the grievance in accordance with the Procedure. To ensure that people know where and how to file a grievance, the Grievance Management Officer will publicise the Grievance Mechanism (including contact details of the Community Liaison Officers telephone numbers and office locations) at community meetings, in one-on-one meetings throughout the communities, from their offices in the Community Development Centres and in periodic publications about the Project which will be distributed in the communities. Establishment of a grievance hotline by the Quantum Power. Preparation of material for public notification of the procedure. These materials need to be in a format and language that is culturally acceptable, readily understandable to the local population and/or communicated orally in areas where literacy levels are low. Communicate the procedure and especially the means of access to all affected parties. Implement regular follow-ups to ensure that the mechanism is well understood. Ensure that Quantum Power has the continued capacity to manage and sustain the procedure. This includes a responsible manager, the necessary communication capacity and infrastructure; the necessary data capture capacity and infrastructure, and management arrangements to process and respond to grievances. Quantum Power Ghana Gas Limited 8 Knight Piésold Consulting

9 Third party mediation options should be identified, in case the services are needed. 7 CONCLUSION It is currently proposed in regard of appropriate public notification that the Grievance Management Framework be introduced during the ESIA disclosure. For this, it is required that Quantum Power will review the proposed mechanism, comment thereon and appoint a Grievance Management Officer who will be supported by a Community Relations Manager. Further discussions may be required with the traditional authorities with regard to suitable collection points and a grievance hotline needs to be established. Quantum Power Ghana Gas Limited 9 Knight Piésold Consulting

10 APPENDIX A1: QUANTUM POWER GHANA GAS GRIEVANCE FORM QUANTUM POWER GHANA GAS PUBLIC GRIEVANCE FORM TEMA LIQUEFIED NATURAL GAS PROJECT CASE NUMBER: CONTACT INFORMATION NAME: GENDER: MALE FEMALE ADDRESS: TEL: AREA: BANKUMAN ; LOCAL FISHING HABOUR/TEMA NEW TOWN ; KPONE TEMA AFFILIATION: COMMUNITY RESIDENT ; NGO ; LOCAL BUSINESS, LOCAL GOVERNMENT NATIONAL GOVERNMENT ; COMMUNITY BASED ORGANIZATION If with an Organization, Organization s Name: Position in Organization: DESCRIPTION OF GRIEVANCE Where relevant provide specific names, dates and locations of incidences What is your suggested resolution for the grievance? SIGN: DATE: Quantum Power Ghana Gas Limited 10 Knight Piésold Consulting

11 APPENDIX A2: QUANTUM POWER GHANA GAS GRIEVANCE REPORT FORM QUANTUM POWER GHANA GAS GRIEVANCE REPORT FORM TEMA LIQUEFIED NATURAL GAS PROJECT Case number Received by Complaint status Date Method of complaint Grievance officer Complainant Contact details (including location) Nature of complaint Designated Department Follow up action Date by which follow up action to be implemented Communication with regard to receipt of complaint and follow up action/response and date thereof Result of follow up action Communication regarding complaint resolution and satisfaction in handling of complaint Case closure date Quantum Power Ghana Gas Limited 11 Knight Piésold Consulting

12 APPENDIX A3: POSSIBLE EVENTS OCCURRING DURING THE PROJECT AND DIFFERENT PROCEDURES REQUIRED IN EACH CASE Construction Damage to Property If a complaint is received which relates to damage to property, the Community Relations Manager will arrange (together with the relevant contractor s Community Relations/General Manager) to inspect the reported loss or damage. If verification is received, the Quantum Power s Community Relations Manager will progress remedial action/repairs to be performed by a mutually acceptable contractor. If the claimant expresses acceptance of the implemented solution, the case is closed and registered accordingly. If the claimant does not accept the proposed solution, the second stage process involving a third party mediator (either local government authority or traditional authority) is instituted. Accidental Injury to People If in the course of construction or operations an accident occurs (most likely involving vehicle collisions or pedestrian incidents), the Quantum Power or contractor/sub-contractor staff involved must ensure that emergency services and the police are immediately notified and that a copy of the police report is obtained for insurance and legal liability purposes. The Community Liaison Officer and Grievance Management Officer must also be contacted immediately who will endeavour to go the scene. The Tema LNG project will develop an accident and incident reporting procedures which will be applied to all contractors and subcontractors. In cases where the Community Relations Manager determines appropriate and following consultation with Senior Management of Quantum Power, Quantum Power will offer to pay all medical bills, in good faith as well as to pay for lost time. Temporary Disruption of Local Traffic on Roads Traffic assessment on roads within the project area has been determined and a schedule of increase and or unusual traffic flows has been established. The Community Relations Manager of Quantum Power will, sufficiently in advance (i.e. prior consultation), submit the schedule of increase and/or unusual traffic flow to the project s site engineer. The Community Relations Manager with the support of the CLOs will communicate in good time any aspects of this schedule which may impact on project affected people s lives and livelihoods. By its nature, during the construction phase (and to a less extent during operations), there will be movements of numerous trucks and equipment which will unavoidably increase the traffic congestion. If complaints are raised, the Grievance Management Officer and Community Liaison Officers will endeavour to work with all contractors and subcontractors to minimize the disruption and also provide information to the community about the duration and schedules. Quantum Power Ghana Gas Limited 12 Knight Piésold Consulting