SAINSHAND WIND PARK PROJECT STAKEHOLDER ENGAGEMENT PLAN

Transcription

1 SAINSHAND WIND PARK PROJECT STAKEHOLDER ENGAGEMENT PLAN Ulaanbaatar 2017

2 Brief information: The project name: Customer Location: Document: Classification: Prepared by: Sainshand Wind Park Sainshand Salkhin Park LLC Dornogovi aimag, Sainshand Stakeholder Engagement Plan Confidential Tecol LLC Prepared date: 12 June 2016 Authorized by: Checked by: Social expert N.Oyunchimeg Project manager D.Nandinbayar Senior project manager Federica Pelzer Tecol LLC has prepared this document to ensure compliance with the IFC performance standards, EIB environmental and social standards and Mongolian national legislation, taking into account the more detailed development of the project. About this report This report has been prepared by Tecol LLC for the exclusive use of Sainshand Salkhin Park LLC ( the Customer ) in connection with the proposed Sainshand wind park in Mongolia. It should be read subject to and in accordance with the disclaimer below. This document is available for all employees via the project network and is approved for use. This document is regularly updated, and the latest version is available electronically. It may be distributed to all stakeholders based on written approval of the Customer. The project environmental coordinator is responsible for updating and maintaining this plan. The original hard copy of the document should be signed to indicate approval and filed in the project filing system. If you have any enquiry relating to this plan, please contact the project environmental coordinator in the first instance. Confidentiality The information in the report is proprietary and confidential. 1/27

3 Table of Contents 1. INTRODUCTION Background Objectives and Scope PROJECT DESCRIPTION Overview Project Location Environmental and Social Impact Assessment Process REGULATORY REQUIREMENTS National Requirements International Requirements IFC Requirements EPs Requirements EIB Requirements SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES STAKEHOLDER IDENTIFICATION AND ANALYSIS STAKEHOLDER ENGAGEMENT ACTIVITIES The phases of the Stakeholder engagement activities Construction phase Operation phase Project Closure The Future Public Consultation and Disclosure Programme Resources and Responsibilities MONITORING AND REPORTING GRIEVANCE MECHANISM Overview SSP grievance resolution mechanism Responsibilities On receiving a grievance Assessing the grievance Formulating a response Track and monitor grievances APPENDIX A /27

4 Glossary and list of abbreviations and acronyms Aimag Soum km kv m MW CLO CMEC EIA EIB EKF EMP EPs EPFIs ES ESAP ESIA EU DEIA GEIA IFU IFC MET NGO NTS SEP SWP SSP PS Province (Mongolian administrative unit) Mongolian administrative unit (sub-district of aimag) kilometer kilovolt meter Megawatt Community liaison officer China machinery engineering corporation Environmental impact assessment European investment bank Eksport kredit fonden Environmental management plan Equator Principles Equator Principles Financial Institutions Environment-social Environmental and social action plan Environmental and social impact assessment European Union Detailed environmental impact assessment General environmental impact assessment Investment fund for developing countries International Finance Corporation Ministry of Environment and Tourism Non-Government Organization Non-technical summary Stakeholder Engagement Plan Sainshand Wind Park Sainshand Salkhin Park Performance Standards 3/27

5 1. INTRODUCTION 1.1. Background SSP considers stakeholder engagement as an essential part of good business practice and corporate citizenship, and a way of improving the quality of the Project. Effective community engagement is central to the successful management of risks and impacts on communities affected by the Project, as well as central to achieving enhanced community benefits. This Stakeholder Engagement Plan (SEP) has been developed by the Mongolian environmental consultancy Tecol LLC on behalf of Sainshand Salkhin Park (SSP) to help the Project communicate its key environmental and social impacts, identify risks and develop innovative solutions to build trust between the Project and its stakeholders and develop and maintain a constructive relationship with its stakeholders throughout the duration of the Project. This SEP is intended to provide a framework to further align business practices with societal needs and expectations, helping to drive longterm sustainability and shareholder value. The SEP is supported by a number of sub-plans such as the Resettlement Action Plan (RAP) and the Corporate Social Responsibility Plan (CSRP), which have already been developed or are currently under preparation. The SEP will be reviewed and updated on a regular basis. If activities change or new activities relating to stakeholder engagement commence, the SEP will be brought up to date. The SEP will also be reviewed periodically during project implementation and updated as necessary. This Plan is in accordance with the national requirements for Environmental Impact Assessments (EIA) as well as with the international standards required by the International Finance Corporation (IFC), and other financial institutions such as European Investment Bank (EIB), European Bank for Reconstruction and Development (EBRD) as well as the Equator Principles Financial Institutions (EPFIs) Objectives and Scope The overall objective of the SEP is to define a stakeholder engagement, public information disclosure and consultation process. This SEP highlights the methods that will be used by SSP to communicate with people and stakeholders groups who may be affected by or interested in the Project operations and activities. The end goal of the SEP is to build a trusting relationship with the host community and other interested stakeholders based on a transparent and timely supply of information and open dialog. A grievance mechanism for stakeholders and public, included to the SEP, will provide feedback and comments about the company s operations and how those complaints/comments will be handled. A level of stakeholder engagement has already taken place as part of the requirements of the Environmental and Social Impact Assessment (ESIA) of the Project. Communication will continue as further planning and design activities are progressed and through the project implementation. Key stakeholders have been identified in this document. If any stakeholders have not been identified, they should contact SSP and ask to be included in the future information and communication. 4/27

6 2. PROJECT DESCRIPTION 2.1. Overview The Sainshand Wind Farm Project (Project) has been classified as a project of Category B under the IFC and Equator Principles. It means that the project has potential limited adverse environmental and social risks and/or impacts that are few in number, generally site-specific, largely reversible and readily addressed through mitigation measures. The Project is expected to comprise the following components: 25 WTGs (Vestas V MW) On-site substation On-site access roads as well as 2 km road connection to the public highway An underground electrical collection system which interconnects the WTGs with the site substation 4 km long 110kV overhead transmission line (OHL) from the site substation to the existing Sainshand substation Temporary workers accommodation located in Sainshand city 2.2. Project Location SSP has leased an area of hectare in the Dornogobi aimag, at the convergence of the territories of three different soums: Sainshand, Urgun and Altanshiree for a period of 30 years. The Project site is located at a place called Ulaan tolgoin khundii elevated at the altitude of m; approximately 7 km southeast of Sainshand city, in the Gobi region of Mongolia, 460 km southeast south of the capital Ulaanbaatar. The Project s location is illustrated below in Figure 1. Figure 1. Location of the Project site 5/27

7 The wind turbines will be installed in line from west to the east over the elevated flattish terrace (plateau) on the south of the Ulaan tolgoin khundii and on the north of the Khetsuutsav predominated with the low knolls and hillocks and dry swashes. The closest settlement is Sainshand city located approximately 7 km to the northwest (Figure 1). Sainshand city is a major city, with a registered population of 34,000, of whom about 24,000 are believed to reside in the city Environmental and Social Impact Assessment Process A General - EIA (GEIA) and Detailed - EIA (DEIA) were first undertaken in 2009 by the local Mongolian environmental consultant Baigali-Ecology LLC. The GEIA was updated in 2014, and MEGDT confirmed that a DEIA was required for the Project. The DEIA was completed in 2015 in accordance with the above requirements and accepted formally by the Ministry of Environment, Green Development and Tourism (MEGDT) in The Project has been classified as Category B 2 project by the IFC. The GEIA and the DEIA (as previously discribed) assessed the impacts and benefits of the Project and identified measures by which these impacts and benefits can be managed. 3. REGULATORY REQUIREMENTS 3.1. National Requirements No specific Mongolian legislation is designed to ensure wide public consultations during implementation of Renewable Energy Projects, although the Minister of Environment issued the Decree No A-03, Procedures for public participation in environmental impact assessment on Jan. 6 th, 2014 which requires generally a public consultation. The Law on Environmental Impact Assessment (1998, amended 2012, 2014 and 2015), the Regional Development Management Law (2003, amended in 2006) and the Law on Environmental Protection (2012), however, define the right of citizens to be informed about ongoing projects and to be involved in environmental protection activities. The Law on Environmental Impact Assessment stipulates that public involvement in the DEIA process is required. Article 18.4 of the Law requires the opinion of local residents of the area to be addressed in undertaking and preparing a DEIA. However, there is no specific requirement under the Law to demonstrate how the opinions of local residents should be reflected in design or operational aspects. The Mongolian Law on Regional Development Management (2003) primarily aims to regulate regional development and to balance social and economic objectives. Respect for the powers of local selfgoverning bodies in the regional development process is underwritten in the Law. According to the Law local self-governing bodies are responsible for engaging citizens in the regional development process, by responding to appropriate queries and by encouraging and directing engagement by citizens, enterprises and organizations. 1 Personal communication, Ms Narangarel Head of 3 rd Bag Sainshand soum, October 4 th, Projects for which potential adverse future environmental and/or social impacts are typically site-specific, and/or readily identified and addressed through mitigation measures are classified as B category project. (The International Finance Corporation Procedure for Environmental and Social Review of Project) An addition, the Salkhit Wind Park (the only wind park in Mongolia) was classified as the B category project. 6/27

8 3.2. International Requirements Public consultations for the SWP Project will be undertaken to meet the Lenders requirements, which include: International Finance Corporation (IFC) Performance Standards (PSs) on Environmental and Social Sustainability (IFC PSs 2012); IFC Environmental and Social Review Procedure (April, 2006); IFC Guidance Note F: Guidance for Preparation of a Public Consultation and Disclosure Plan; Equator Principles (EPs) III 2013; World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines) 2007; EIB Standards on Assessment and Management of Environmental and Social Standards and Risks (Standard 1); Good Practice Manual Doing Better Business through Effective Public Consultation; and Disclosure (1998); EBRD Performance Requirement (PR) 10 on Information Disclosure and Stakeholder Engagement IFC Requirements Performance standard #1 aims to promote identification and assessment of positive/negative social and environmental impacts in the project/activity area, prevention of negative impacts of affected communities and environment, at least minimization or recovery of such impacts if prevention is not possible, disclosure to the communities of issues which shall affect them, and improvement of social and environmental performance of the companies with efficient management system. Performance standard #1 aims to build, maintain and develop the relationships between the employees and the management, to promote practices guaranteeing compliance with the national laws such as equal opportunity, non-discrimination and equal treatment towards everyone, prevention of child and forced labor, protection of work force, promotion of safe and healthy occupational conditions and protection of workers health. Performance standard #4 requires prevention or minimization of risk and impacts on health and safety of the society and working of security personnel within legal boundaries in a way to prevent or minimize the risk to be created, for safety of the society. Performance standard #5 requires the restoration of livelihoods affected by a project as a result of acquisition of land and other immovable assets EPs Requirements Equator Principle #5 (Consultation and Disclosure), requires continuous consultation with a cultural sensitivity that is in harmony with communities affected by the Company s activities and in a structured manner. This principle also contains the requirement that consultation status must be independent, preferential and equipped with information, and that ascertainment of the needs of groups which have been or might be affected by this project must be guaranteed. 7/27

9 Equator Principle #6 (Grievance Mechanism), requires formation of a grievance mechanism which ensures regular and systematic receiving and recording of the complaint of communities affected by the activities of companies, and which also guarantees action to be taken within a specified period EIB Requirements EIB published the Environmental and Social Handbook with the aim to provide an operational translation of the policies, principles and standards on Environmental and Social requirements. Standard #1 aims to outline the promoter s responsibilities in the process of assessing, managing and monitoring environmental and social impacts and risks associated with the operations. For operations outside the EU, candidate and potential Candidate countries must meet the best international practice with regards to the assessment and management of environmental and social impacts and risks, promote good environmental and social governance and align with relevant EU principles and standards. Standard #6: Involuntary Resettlement. EIB projects sometimes necessitate land acquisition, expropriation and/or restrictions on land use, resulting in the temporary or permanent resettlement of people from their original places of residence or their economic activities or subsistence practices. Standard 6 is rooted in the respect and protection of the rights to property and to adequate housing, and of the standard of living of all affected people and communities. It seeks to mitigate any adverse impacts arising from their loss of assets or restrictions on land use. It also aims to assist all affected persons to improve or at least restore their former livelihoods and living standards and adequately compensate for incurred losses. Standard #8: Labor Standards. Good labor practices and the use of appropriate codes of conduct are important to ensure the fair treatment, non-discrimination and equality of opportunity of workers. This standard aims at ensuring that promoters of EIB projects comply with the core labor standards of the International Labor Organization and with national labor and employment laws. The standard also requires the establishment, maintenance and improvement of worker-management relationships. Standard #10: Stakeholder Engagements. As a public institution, the EIB actively promotes the right to access to information, as well as public consultation and participation. Standard 10 requires promoters to uphold an open, transparent and accountable dialogue with all project-affected communities and relevant stakeholders in an effective and appropriate manner. The value of public participation in the decisionmaking process is stressed throughout the preparation, implementation and monitoring phases of a project. The right to access to remedy, including through grievance resolution, is actively required EBRD Requirements EBRD performance requirements are generally aligned with the standards of IFC and EIB described above. EBRD PR10 requires the development of a Stakeholder Engagement Plan for projects that are likely to have adverse environmental or social impacts and issues, tailored to take into account the main characteristics and interests of the affected parties and other interested parties. 4. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES To date, three scoping meetings have been held with local communities (see Table 1). The primary goals of these meetings were to: Describe the Project and the ESIA process; 8/27

10 Discuss and identify potential Project impacts and benefits associated with the construction and operation of the Project, including the transmission line, roads and other on-site facilities; Understand local land use, activities and populations living and working within or near the Project site; Identify the most effective ways of information dissemination in the future; and Develop a list of stakeholder groups and local people most likely to be affected by the Project; 9/27

11 Table 1. Previous Stakeholder Engagement Activities Date Attendees Participants Location Key Discussions 2009 SSP LLC Representatives of the County officials and communities Local herders 2014 Baigal-ecology LLC Representatives of County officials and communities Local herders 2015 SSP LLC Baigal-ecology LLC Representatives of County officials and communities Local herders 2016 SSP LLC TeCol LLC County officials and communities Local herders Total 70 Male 36 Female 34 Total 45 Total 161 Sainshand soum Sainshand soum, Altanshiree soum, Urgun soum Sainshand soum, Altanshiree soum, Urgun soum An introduction and information on the construction of the Project was provided. Detailed discussion regarding advantages of the wind farm, the fact that it is environmentally friendly technology, improving the road and infrastructure and to provide electricity to the local communities including local mining companies. Detail was provided on how wind energy is used to produce electricity using WTGs and how this Project will be Mongolia s second wind farm. Baigali-Ecology introduced the DEIA role. Detail was provided on the environmental assessment workload and on the work performances. Environmental issues and restoration measures were also discussed. SSP introduced the Project and Baigali-Ecology. Baigali-Ecology introduced the DEIA role, highlighted areas where there may be concern e.g. noise, visual, economic, and queries whether there were any concerns from the local community. Baigali-Ecology advised that the wind farm would be designed to minimize impacts. SSP provided details of potential community benefits associated with the Project. Detail was provided on how wind energy is used to produce electricity using WTGs and how this Project will be Mongolia s second wind farm. Total 18 Sainshand soum Tecol provided information on Project s concern for maintaining affected herders normal life, and introduced about a plan for livelihood restoration to herders and local officials. Key comments and concern of the community How to maintain the safety of local herders and animals, whether the project impacts pasture land Whether the wind turbines support desertification, whether the project impacts on pasture land and water resource, whether the project impacts wild life Whether the project impacts annually horse race, whether the project impacts water resource, whether the turbine rotation has impact on weather conditions, If the Project provide water resources for affected herders. If there is any possibility for local citizens to involve in construction of the wind park as a worker. Community benefits of the Project Creation of local workplaces, benefits for local business entities especially during construction phase, increase of local energy quality (leading to less voltage fluctuation), sustainable clean energy production. 10/27

12 5. STAKEHOLDER IDENTIFICATION AND ANALYSIS In order to define effective communication process with the various stakeholder groups SSP has identified several stakeholder groups that may be interested and/or directly or indirectly affected by the Project s implementation. The stakeholders identified include internal stakeholders, such as employees and construction contractors workers, as well as external stakeholders, such as governmental authorities, non-governmental organizations and local residents. Figure 2. Stakeholder Analysis Tool 3 All the stakeholders identified are presented in Table 2 below /27

13 Table 2. Stakeholder Groups Stakeholder Groups Stakeholders Summary of Specific Interests Proposed means of engagement Internal stakeholders SSP workforce Meetings, phone calls, Directly-employed staff Training, health and safety s, training Ferrostaal Meetings, phone calls, Develop project up to Financial Close and Industrial Equity investor s, reporting facilitate equity to the project Projects GmbH ENGIE IFU EIB FinnFund EKF EBRD CMEC Vestas External stakeholders Government (National) Equity investor Equity investor Lender Lender Lender Lender BoP Contractor Turbine supplier Ministry of Energy Energy Regulatory Commission Ministry of Environment and Tourism Ministry of Health Ministry of Construction and Urban Development Develop project up to Financial Close, facilitate equity and provide operation & maintenance service to the project Facilitate equity to the project Facilitate debt financing to the project Facilitate debt financing to the project Facilitate debt financing to the project Facilitate debt financing to the project Procure civil works, electrical equipment and site management Supply wind energy turbines, supervise installation and commissioning, provide maintenance National energy production policy and issue of permissions National energy production policy and issue of permissions Land rehabilitation Protection of employee and public safety Land-related issues Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Meetings, phone calls, s, reporting Group meetings Reporting Broadcasting media Stakeholder ranking Meet their needs Key player Key player 12/27

14 Government (Provincial) NGOs / Association Industry and Business Specific communities (Administration of Land Affairs, Geodesy and Cartography) Minister for Road and Transportation (including State Railway Authority; Department of Road Transportation) Governor s offices of: Dornogobi aimag Sainshand soum Urgun soum Altanshiree soum Bags Dornogobi Aimag Chamber of commerces 4 (not yet Transport related issues Negotiating land use and land possession contracts (Aimag and Soum) Implementation of EIA-related management actions are supervised by the Aimag. Group meetings Public notifications Local print media and newsletter engaged with) Business development opportunities Group consultation Mongolian Wind Energy Association Public notifications Local print media and Khuggliin tuv NGO 5 (not yet engaged with) newsletter Tsagaan lish cooperative 6 (not yet engaged with) National and local specialist consulting and contracting companies Ulaanbaatar Railway JSC Mongolian National Power Transmission Grid Company National Dispatching Center Village well provision and maintenance company: Chandman Ilch LLC Office headquarter: Sainshand Small and medium companies (from Sainshand) Local Residents Local herders located near to Project area Business opportunities, price, payment terms Railway use and safety management Electricity supply and safety management Electricity supply and safety management Ongoing provision of clean water Business opportunities Potential Impacts on their operations Environmental quality, land acquisition and compensation, construction traffic Jobs and other economic benefits Social/community investment opportunities/initiatives Public notification Information leaflet Local media Group meetings Individual meetings Public notification Local press end broadcasting media Key player Meet their needs Show consideration Least important Meet their needs 4 Promoting and aiding businesses and investors by engaging in a mega projects 5 Business development opportunities 6 Economic benefits by investing diary food supply 13/27

15 Press & Media Print media, circulated widely in Urgun soum: Daily News & Zuunii Medee (Century News) Broadcasting media: TVs: Mongolian National Broadcaster & TV9 channel, MN 25, TV5 Radio station: FM station My home place & Mongolian National Radio Station Local news items of interest to readers and listeners/viewers Local news items of interest to listeners and viewers Group meetings Public notification Local media Leaflets Meet their needs The SEP will be reviewed on an annual basis and updated by CLO, if necessary. 14/27

16 6. STAKEHOLDER ENGAGEMENT ACTIVITIES 6.1. The phases of the Stakeholder engagement activities Construction phase Stakeholder engagement during the construction phase will relate to all activities leading up to and during the physical construction of facilities, roads, infrastructure, and buildings related to the project, including the management of contractors and construction contracts (IFC, 2012). Early stakeholder engagement during the project design and the EIA process informed the Project planning and design teams about stakeholder issues thus enabling these teams to investigate and manage adverse impacts as part of the EMP and construction contract. Once construction starts, it is important to involve affected stakeholders and keep them informed of anticipated and unanticipated impacts throughout the period. Engagement during construction is essentially about involving stakeholders in assessing whether the impact mitigation measures as stipulated in the EMP are effective. This entails addressing stakeholder concerns and grievances, and monitoring and managing project impacts. Stakeholder engagement during the construction phase of the project will set the tone for continued stakeholder engagement during the life of the operation. It should therefore aim to improve relationships with stakeholders for the remainder of the project s operational life Operation phase The transition from construction to operations typically means fewer grievances and potentially less project impacts, which usually translates to less engagement with stakeholders. During this phase however there is an overall reduction in the number of employees and contractor workforce, which can potentially affect ongoing stakeholder relationships. The resulting shifts in the composition of the workforce and associated retrenchments need to be carefully managed. As such, engagement with stakeholders should be considered an integral component of operations management, whether this be day-to-day operational activities, or periodic meetings with stakeholder forums. Stakeholder engagement will therefore be integrated into existing monitoring systems and management plans, including health and safety, environmental management, social development, procurement and contractor management, logistics management, audits, and project risk management. In order to maintain constructive long-term relationships with stakeholders during project operation, stakeholder engagement needs to go beyond impact mitigation. A more dynamic process is required in which the SEP is adapted to suit new stakeholder groups and changing stakeholder concerns for dialogue throughout the life of the Project. Management must be aware of these and the SEP must remain flexible to make the changing social and business environment a part of stakeholder engagement that will strengthen effective management of impacts during operations Project Closure The stakeholders potentially affected by project closure will likely be different from those at earlier stages of the project. Impacts such as the loss of local employment, a general decline in regional economic activity, the cutting-back of community services previously provided by the company, and the disbandment of local community involvement in monitoring environmental and social impacts, can potentially introduce long-term financial and reputational liabilities for the company (IFC, 2012). Engaging with stakeholders needs to take place well before project closure. This can lower potential costs, reduce liabilities and strengthen the overall reputation of the company. For example, engagement will 15/27

17 help guide the rehabilitation of the natural environment damaged by the Project, integrate operational infrastructure into existing public services, develop worker retrenchment programme, and establish funds and management structures for the long-term monitoring of assets The Future Public Consultation and Disclosure Programme It is recognized that stakeholder engagement is an important element of the strategic planning and management of the Project as well as its day to day running. SSP will invest the appropriate resources in this process over the life of the Project, from planning and construction, to decommissioning and closure. SSP will ensure that stakeholders are well informed about the Project throughout its lifecycle. At community and public meetings, participants will be given the opportunity to raise their concerns and identify potential Project impacts. These public meetings will be in line with applicable legal requirements and conducted in Mongolian with interpreters for English being made available, as required. Records of these meetings will be kept and continuously updated. Engagements with other entities will be held in the forum as is suitable for the parties. As of today, the local project manager is responsible for the communication activities of the project. As soon as construction of the project commences, a CLO will be nominated, who is committed to manage the ongoing programme of planned stakeholder engagement, including community relations. Engagement phase s specific to the Project can be classified as follows: Consultation completed by SSP during the development stage, include: DEIA consultation with local stakeholders and permitting authorities, prior to obtaining an environmental permit for the Project; and Consultation and engagement as part of the ESIA process. The following section and Table 3 outlines the planned engagement modules to be carried out by SSP and their Engineering Procurement and Construction (EPC) contractor respectively the operating company over the Project life cycle. 16/27

18 Table 3. Stakeholder Engagement Programme Activity Information to be disclosed/issue to be discussed Locations and dates of meetings / forms of communication Pre-construction phase Disclosure of Non-Technical Summary (NTS) and Environmental Supplementary and Social impact supplementary information. Information Report General preconstruction planning and site preparation prior to Expected construction, operational and decommissioning/ abandonment impacts and mitigation measures to avoid/reduce adverse impacts and actions to enhance potential benefits. Overall schedule of site preparation and construction, including sub activities, key stages and potential stages of stakeholder interest, including road development and construction /operational work camp development. Initial Announcement of the availability of the Supplementary information and the overall intentions for public consultation, through local print media and radio and website. Advertisement of the information must be made in the following: o Daily News & Zuunii Medee o Radio station: FM station My home place Public consultation meeting, followed by an open house drop in event within Sainshand soum, with a comments book available. This will be undertaken approximately 30 days from the date of disclosure, at a time when the community will be specifically available in the area (e.g. near to a festival period to be identified dependent on disclosure timescales). o Notices on public notice boards, in shops, local offices etc. o Information delivered to local businesses / residents through an information leaflet giving key details date, time and coverage of the meeting and following up drop in sessions, along with details of transport provision. o Official notice on public notice boards in Urgun, Altanshiree and Sainshand. A full record of the sessions will be maintained, with reporting back of responses to questions and comments made. Notices on public notice boards, in shops, local offices etc. Information delivered to local businesses / residents through leaflets and open house meetings, as well as Stakeholder groups to be consulted Government NGOs Local community 7 Public Groups Potential Clients General public 8 Local community Public Groups Government Authorities Herder representation Local community Public Groups General public NGOs 7 Local community: A group of individuals that interact within their immediate surroundings. In this case it refers to the residents of Sainshand city. 8 General public: All people of an area. In this case it refers to citizens of all three soums of Dornogobi aimag (Sainshand, Altanshiree and Urgun). 17/27

19 construction public notice boards. Press announcement, local media television and radio. Environmental and social officers, monthly meetings. One month prior to: o Start of construction o Other major work phases Grievance mechanism disclosure Specific consultation with herders: Disclosure of the Resettlement Action Plan. Construction phase Construction Phase general information provision Consultation and communication on employment. A separate workers' grievance procedure will be established for the Company s employees and its contractors. Workers will be given the possibility to lodge grievances both through workers representatives and independently, personally, regardless of the matter of the complaint. NTS and Environmental and Social impact supplementary information. Information on compensation and negotiation on compensation. Public grievance mechanism Schedule of construction works. Construction activities. Progress of construction. Construction impacts and mitigation measures (with opportunities for feedback from affected communities). Description of plant and operations. Operational hours. Construction phase employment opportunities, application Processes Employment terms and conditions Human resources and Environment, Health and Safety (EHS) policies and procedures At the project site and project office Focus group meetings can be undertaken individually and in group of herders. Time: o Winter Camp cut-off date 15 November 2016 o Impacts to communal summer pasture areas will also be compensated. Details of this compensation eligibility and process will be made prior to commencement of summer grazing. Notices on public notice boards, in shops, local offices etc. Information delivered to local businesses / residents through leaflets and open house meetings, as well as public notice boards and safety signs. Newspaper; Daily News & Zuunii Medee Broadcasting media: Radio station: FM station My homeplace Community relationship team, as part of the monthly meetings. Notices on public notice boards, in shops, local offices etc. Information delivered to local businesses / residents through leaflets and open house meetings, as well as public notice boards and safety signs. Newspapers; Broadcasting media: Radio stations, monthly meetings. Included in contracts. Local community specifically targeted at herders. NGOs Local community Public Groups General public Local community Public Groups Potential Suppliers General public 18/27

20 Grievance mechanism disclosure Operational phase Company Performance in Operational Phase Company Performance in Operational Phase A separate workers' grievance procedure will be established for the Company s employees and its contractors. Workers will be given the possibility to lodge grievances both through workers representatives and independently, personally, regardless of the matter of the complaint. Grievance mechanism disclosure Workers grievance mechanism At the project site and project office In Project site Bulletin board in break room, tool box talks when new groups of workers commence work on the Project Annual update and reporting on the ESAP Company Reports. Summary under Social Responsibility Project workers Internal Stakeholders Local community Suppliers 19/27

21 6.3. Resources and Responsibilities It is recognized that stakeholder engagement is an important element of the strategic planning and management of the Project as well as its day to day running. SSP will invest the appropriate resources in this process over the life of the Project, from planning and construction, to decommissioning and closure. Key roles and responsibilities for stakeholder engagement have not currently been assigned but there will be appointed a Community Liaison Officer (CLO) and Health and Safety Officer/ Advisor (EHS Officer) prior to financial close. During construction and operation the Project Company will employ a designated EHS Officer, who will be based on site, and a CLO, who will be based primarily on site. The EHS Officer will supervise and promote the execution of EHS related work by workers on site and assist and support managers, supervisors and workers in implementing the EHS and achieving EHS compliance. He will report to the construction director and later on directly to the site operational and maintenance manager. As it may be required, the CLO will carry out day to day liaison with all stakeholders, communities and interested groups. The CLO will be responsible for collecting up to date information about local communities and other stakeholders, as well as anticipating and reporting any issues. As part of SSP s ongoing stakeholder engagement process, the CLO will also carry out regular community visits, including meetings with the nomadic herders at their camps. During construction and operation the CLO will report directly to SSP Chief Execution Officer. The CLO will also be responsible for periodical monitoring and reporting on SEP implementation and grievances to SSP management and also externally. The SEP will be updated with additional contact information when additional roles and responsibilities are finalized. 7. MONITORING AND REPORTING The purpose of the Stakeholder Engagement monitoring is to verify that: Actions and commitments described in this SEP are implemented fully and on time; Complaints and grievances lodged by project affected people are followed up and that where necessary, appropriate corrective actions are implemented; and If necessary, changes in SEP procedure are made to improve stakeholder engagement. Through communication channels such as media and newsletter notifications, one-to-one meetings and periodic public meetings, SSP LLC will monitor and provide feedback as appropriate. To promote transparency and satisfy stakeholder concerns, internal monitoring and implementation of mitigation measures, and other environmental and social programs are key components of the stakeholder engagement. This will be achieved through periodic feedback as part of the two way communication through project implementation and reporting through the meetings to community. Future important public consultation meetings or public exhibitions will be arranged at venues to enable stakeholders to participate. An open book (with pens provided) will be positioned in a suitable location such as community bulletin boards, etc. for recording comments anonymously. This book will be presented in an obvious area of the exhibition but in an area that will not be directly monitored by host 20/27

22 staff (e.g. by the exit). The information will be recorded by SSP LLC so that a response and feedback can be made to stakeholders. The monitoring on the implementation of SEP and grievance mechanism will be conducted monthly, and the community engagement monitoring must be an ongoing process. On an annual basis, SSP LLC will produce a public report on their social and environmental performance, including a non-technical summary of the Environmental and Social Action Plan (ESAP) and progress made with the implementation of the ESAP, against agreed indicators and targets. The results of external audits which will be conducted by certified environmental audit entities on behalf of the Ministry of Environment, Green Development and Tourism against SEP will be submitted to the SSP LLC. 8. GRIEVANCE MECHANISM 8.1. Overview SSP is always accessible for all its stakeholders and responds to complaints and grievances as soon as possible. A grievance mechanism was designed by taking conditions and needs of PAPs into consideration so as to ensure that all complaints are dealt with appropriately and corrective actions are taken. SSP have developed a grievance mechanism for the project in accordance with IFC s Performance Standards and Guidance Notes. These include: Establishing a procedure for receiving, recording or documenting and addressing complains that is easily accessible, culturally appropriate, and understandable to affected communities. Informing the affected communities about the mechanism during the company/community engagement process. Considering when and how to seek solutions to complaints in a collaborative manner with the involvement of the affected community, Addressing concerns promptly, using an understandable and transparent process that is readily accessible to all segments of the affected communities and at no cost and without retribution. Ensuring full participation of both genders and vulnerable groups. Taking into consideration customary and traditional methods of dispute resolution when designing the system. Assigning consistent, experienced, and qualified personnel within the client organization with responsibility for receiving and responding to grievances. Establishing a redress mechanism so those who feel their grievances have not been adequately addressed have recourse to an external body for reconsideration of their case. Documenting grievances received and responses provided and report back to the community periodically. Providing periodic reports on issues that the grievance mechanism has identified as of concern to those communities. The Performance Standards and Guidance Notes emphasize that a grievance mechanism should help SSP understand the community s perception of project risks and impacts so as to adjust its measures and actions to address the community concerns. The objective of SSP s SWP grievance procedure is to ensure that all comments and complaints from 21/27

23 people directly affected by the project, including local communities, herder families and railway workers are processed and considered in an appropriate way. Furthermore, the grievance mechanism should contain a process for determining what corrective actions need to be implemented in relation to complaints received and guarantees that complainant are informed of the outcome. The means by which stakeholders may make comments and complaints must be appropriate to their culture. The flowchart below shows a general mechanism of processing the complaints. Figure 3. Flowchart for Processing Grievances Receive and register grievance Verification of the complaint received Screen and assess Act to resolve locally? No Yes Reject complaint Refer as appropriate Define approach Communicate decision Implement approach Track and document Resolved? Process feedback and learn Not resolved? Revise choice or execution of approach 22/27

24 Workers Grievances A separate workers' grievance procedure will be established for the Company s employees and its contractors. Workers will be given the possibility to lodge grievances both through workers representatives and independently, personally, regardless of the matter of the complaint SSP grievance resolution mechanism Local people need a trusted way to voice and resolve concerns linked to a project s operations. A locally based grievance resolution mechanism provides a promising avenue by offering a reliable structure and set of approaches where local people and the company can find effective solutions together. SSP will develop and implement a grievance mechanism which: Increases the likelihood that small disputes can be brought to a conclusion relatively quickly before they become deep-seated grievances Keeps ownership of the dispute in the hands of local people Offers an early, efficient, and less costly way to address concerns Promotes a more stable business climate for companies that reduces risk and enhances accountability to the host community. A successful grievance mechanism can help achieve the following goals: Open channels for effective communication Demonstrate that a company is concerned about community members and their well-being Mitigate or prevent adverse impacts on communities caused by company operations Improve trust and respect Provide structures for raising, addressing, and resolving issues that reduce imbalances in power Promote productive relationships Build community acceptance of a company s social license to operate Responsibilities Table 4. Contact Details Ferrostaal Industrial Projects GmbH Pelzer Federica Senior Project Manager Ferrostaal Industrial Projects GmbH Federica.Pelzer@ferrostaal.com Tel: +49 (0) Cell Phone: +49 (0) Sainshand Salkhin Park Nandinbayar Manager Sainshand Salkhin Park LLC 9F, DHE Building Street, Ulaanbaatar MONGOLIA nandinbayar@euro-khan.com Tel: These contact details will be updated as soon as a local CLO is appointed. In addition to the above contact details a mailbox will be provided at the site entrance to allow local people to raise grievances in a more informal way. 23/27

25 8.4. On receiving a grievance The comments and complaints will be summarized and listed in a Complaints/Comments Log Book, containing the name/group of commenter/complainant, date the comment was received, brief description of issues, information on proposed corrective actions to be implemented (if appropriate) and the date of response sent to the commenter/complainant. Receipt of a grievance must be acknowledged within 5 days and responded to within 30 work days unless the investigation takes longer, in which case the complainant will be informed of the extended timeframe Assessing the grievance During the assessment, the team gathers information about the case and key issues and concerns and helps determine whether and how the complaint might be resolved. SSP will: Determine who will conduct the assessment. Typically, the complaints coordinator performs this task or directs it to an appropriate staff or department for assessment (production, procurement, environment, community relations, and human resources). Select a company member to engage directly with the complainants to gain a first-hand understanding of the nature of the complaint. Clarify the parties, issues, views, and options involved - Identify the parties involved; - Clarify issues and concerns raised by the complaint; - Gather views of other stakeholders, including those in the company; - Determine initial options that parties have considered and explore various approaches for settlement; Classify the complaint in terms of its seriousness (high, medium, or low). Seriousness includes the potential to impact both the company and the community. Issues to consider include the gravity of the allegation, the potential impact on an individual s or a group s welfare and safety, or the public profile of the issue. A complaint s seriousness is linked to who in the company needs to know about it and whether senior management is advised. Rather than resorting to a purely unilateral investigate, decide, and announce strategy, engage more directly with the complainant in the assessment process, and involve the complainant in influencing the resolution process to be selected, and settlement options Formulating a response The system for responding to the complainant should specify who communicates and how. In some cases, it may be appropriate that feedback be provided by the staff member responsible for assessment accompanied by the coordinator of the complaints procedure. The site manager may participate in feedback, depending upon the seriousness of the complaint. When formulating a response SSP will ensure that: The complaint coordinator or relevant department may prepare the response. The response should consider the complainants views about the process for settlement as well as provide a specific remedy. The response may suggest an approach on how to settle the issues, or it may offer a 24/27