STAKEHOLDER ENGAGEMENT STRATEGY

Transcription

1 QUANTUM POWER GHANA GAS LIMITED TEMA LIQUEFIED NATURAL GAS PROJECT STAKEHOLDER ENGAGEMENT STRATEGY PREP ARED FOR: Quantum Power Ghana Gas Ltd HNo. 2, 2nd Labone Link North Labone - Accra Ghana PREP ARED BY: Knight Piésold Ghana Limited No. 20, 2nd Close Airport Residential Area P.O. Box CT 4122, Cantonments, Accra p e. accra@knightpiésold.com Web: Rev 1 June 2015 Knight Piésold C O N S U L T I N G

2 Name Project: Client Name: Report Name: Tema Liquefied Natural Gas Project Quantum Power Ghana Gas Limited Stakeholder Engagement Strategy () Our Reference: /02 EPA Reference: CE: 4399/01/13 Name: Responsibility: Signature: Date: Trent Collins Project Director June, 2015 Wisdom Akatu Project Manager June, 2015 Andrew Hickman Author June, 2015 Amelia Briel Technical Reviewer June, 2015 This document has been prepared by Knight Piésold Ghana Limited with all reasonable skill, care and diligence within the terms of the Contract with the client. This report is provided solely for the purposes set out in it and may not, in whole or in part, be used for any other purpose without Knight Piésold Ghana Limited prior written consent.

3 Quantum Power Ghana Gas Limited Tema Liquefied Natural Gas Project Stakeholders Engagement Strategy /02 June 2015 TABLE OF CONTENTS PAGE 1 INTRODUCTION BACKGROUND TO THE TEMA LNG PROJECT PURPOSE OF THIS DOCUMENT ENGAGEMENT STRATEGY AND OBJECTIVES WHY ENGAGE STAKEHOLDERS ENGAGEMENT OBJECTIVES ENGAGEMENT STANDARDS Ghanaian Engagement Requirements International Best Practice Quantum Power s Corporate Policy on Engagement STAKEHOLDER ISSUES AND MAPPING STAKEHOLDER ANALYSIS ISSUES ANALYSIS EXTERNAL ENGAGEMENT PROACTIVE MILESTONE ENGAGEMENT Pre-Construction Construction Operations Decommissioning PROACTIVE AND ONGOING ENGAGEMENT RESPONSIVE ENGAGEMENT Grievance Mechanism INTERNAL CAPACITY AND GOVERNANCE ORGANISATIONAL STRUCTURING Core Engagement Team Alignment with Other Teams RESOURCING Recruitment Considerations SYSTEMS, TOOLS AND TEMPLATES Systems TOOLS AND TEMPLATES MONITORING AND EVALUATION Quantum Power Ghana Gas Limited -1 Knight Piésold Consulting

4 1 INTRODUCTION This Stakeholder Engagement Strategy () serves as a framework document to guide Quantum Power s approach to stakeholder engagement for the life of the Project following completion of the Environmental and Social Impact Assessment (ESIA), i.e. during preconstruction, construction, operations, and decommissioning/closure. It establishes the strategic goals, requirements and principles for completed engagement activities and high level guidance on future engagement requirements at each of the different phases in the Project lifecycle (recognising that the scope and scale of the proposed Project may be subject to changes or expansions in the future). The ensures that a consistent, comprehensive, coordinated and culturally appropriate approach to consultation is followed. Stakeholder engagement refers to a process of sharing information and knowledge, seeking to understand and respond to the concerns of potentially impacted or affected individuals, and building relationships based on trust. As such, stakeholder engagement is essential for the successful implementation of the ESIA and the Project itself. 1.1 Background to the Tema LNG Project The Project will install commission and operate the infrastructure required to import, store, regasify LNG and deliver re-gasified LNG to off-takers in the Tema Metropolis for an initial period of ten (10) years. The project proposes to import LNG via ship, using a Floating Storage and Regasification Unit (FSRU) system approximately 12 km offshore of the coastline, near Tema. This will provide a single contract point for end-users covering storage, re-gasification and transmission of natural gas. The proposed Project will comprise of the following components: 1. Floating Storage And Regasification 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. Supporting infrastructure. The location of the proposed Project and the general arrangement of the proposed layout of the Tema LNG Project site are shown in Figure C1.1 and Figure C1.2 respectively. Quantum Power Ghana Gas Limited -2 Knight Piésold Consulting

5 Figure C-1.1: Location of the Tema LNG Project Quantum Power Ghana Gas Limited -3 Knight Piésold Consulting

6 Figure C-1.2: General Arrangement of Project Infrastructure Quantum Power Ghana Gas Limited -4 Knight Piésold Consulting

7 The lifecycle for the development of the Project can be categorised into the following phases: Feasibility This phase involves planning for the proposed Project, preliminary designs and the ESIA study. Pre-construction - This phase involves planning for construction, putting in place mitigation measures and resettlement (if necessary). Construction - This phase involves construction activities to construct the Project and other required infrastructure. This phase also includes rehabilitation and monitoring activities to make sure what is committed to in the ESIA is implemented. Operation - This phase involves importing and distributing LNG within Ghana. Decommissioning and Closure - This phase involves closing the Project, retrenching workers and decommissioning the project infrastructure. 1.2 Purpose of this Document This is designed to act as an overarching framework for Quantum Power to manage its stakeholder engagement and related activities. It does not serve as a detailed implementation plan but rather a guide. Detailed engagement plans will be generated and implemented at each phase in the Project lifecycle by Quantum Power. Should Quantum Power expand the scope of its activities outside of those described in the ESIA, the will need to be updated. In particular, the updated will need to reflect changes to the stakeholder groups affected and the potential impacts of the activity. Finally, it is important that this aligns to the measures included in the provisional and final Environmental and Social Management Plans (ESMPs) developed. 2 ENGAGEMENT STRATEGY AND OBJECTIVES 2.1 Why Engage Stakeholders Taking cue from the past experience of the oil and gas industry as a whole, various national governments, project finance agencies and corporate entities have realised that the success of a project hinges on the active support of local communities. This is possible only when all stakeholders in the project are engaged in a constructive and transparent manner from the onset and that this engagement continues through the project life cycle. Effective Stakeholder Engagement is thus key to Quantum Power achieving its business targets for the Tema LNG Project. 2.2 Engagement Objectives This is designed to ensure a consistent, comprehensive and coordinated long-term approach that encourages open and transparent dialogue with a broad range of stakeholder groups. This dialogue should be a two-way process where stakeholders are not merely consulted or listened to, but also allowed to input into key decision making processes. This should also be ongoing and not only as part of the ESIA. Quantum Power Ghana Gas Limited -5 Knight Piésold Consulting

8 The objectives of Quantum Power s approach to engagement are: To ensure understanding by facilitating an open, culturally appropriate and inclusive approach to engagement that provides timely and accurate information in an accessible and transparent way to all stakeholders, regardless of their status; To manage expectations and concerns by providing a mechanism which not only provides stakeholders an opportunity to freely provide comment and feedback but also allows Quantum Power to respond to this feedback, thereby addressing concerns; To manage risks through building sustainable relationships. It is a common trend in large infrastructure development projects that communities expect more open and transparent dialogue and long-term social commitments from companies. Engagement will allow Quantum Power to understand stakeholder interests and issues and work with stakeholders to find mutually acceptable ways to achieve or address these; and To create value where engagement allows for partnerships to be developed for the mutual benefit of both Quantum Power and the stakeholders. This includes but is not restricted to corporate social investment activities. This relates also to seeking mutual benefit through design and operations by considering stakeholders and seeking their benefit in all Project activities. 2.3 Engagement Standards This has been designed to ensure compliance with Ghanaian legislative requirements and as far as possible, international best practice. This section presents a summary of the key Ghanaian and international requirements for engagement Ghanaian Engagement Requirements The Constitution of the Ghana stipulated the basic human rights of its people and effective participation in development processes including rights of people to form their own associations free from state interference and to use them to promote and protect their interests in relation to development processes, rights of access to agencies and officials of the State International Best Practice Equator Principles The Equator Principles (EPs) are a set of standards, adopted voluntarily by Equator Principle Financial Institutions (EPFIs) that seek to determine, assess and manage social and environmental risks in project financing. Principles Five, Six and Ten of the EPs contain engagement specific requirements. In particular, Principle Five dictates that an informed consultation and participation process be conducted with stakeholders, facilitating their informed participation in new developments and projects. In addition, Principle Six includes requirements for establishing a grievance mechanism, and all reporting and disclosure requirements are now included within Principle Ten. Quantum Power Ghana Gas Limited -6 Knight Piésold Consulting

9 IFC Performance Standards The IFC Performance Standards (2012) require clients to engage with stakeholders in a manner commensurate with the risks and impacts of a development. In particular, the standards compel developers to engage affected communities through disclosure of relevant and accurate information as well as an Informed Consultation and Participation (ICP) process. ICP requires an in-depth exchange of views and information with affected communities and stakeholders. In addition, it requires that an organised and iterative consultation process be undertaken on, amongst other things, managing and mitigating negative impacts as well as sharing and capitalising on development benefits and opportunities. The main requirements for consultation and disclosure are covered under Performance Standard 1, which aims to ensure that stakeholders are appropriately engaged on issues that could potentially affect them, and to build and maintain constructive relationships with stakeholders in addition to establishing a grievance mechanism. The Performance Standards also outline requirements for engagement with vulnerable people which include identifying vulnerable individuals and groups and tailoring the engagement process to the needs of these groups. This may include applying differentiated measures to allow for the effective participation of vulnerable persons. The IFC also provides further engagement guidance through its handbooks Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets (2007) and Addressing Grievances from Project Affected Communities: Guidance for Projects and Companies on Designing Grievance Mechanisms (2009) Quantum Power s Corporate Policy on Engagement This will serve to set the framework for all future engagement related the Tema LNG Project. It commits Quantum Power to a pro-active and on-going dialogue with all stakeholders interested in or affected by its activities at an appropriate scale. No Quantum Power corporate policies related to stakeholder engagement currently exist and this will therefore serve as the primary guideline for all future engagement activities. 3 STAKEHOLDER ISSUES AND MAPPING 3.1 Stakeholder Analysis Following on from the stakeholder database developed as part of the ESIA (contained in Volume Two Annexure B). Quantum Power will continuously engage stakeholders at the national, regional/district and local level. Table C-1 presents the framework for how stakeholders have been categorised, where each of the identified stakeholder categories and groups is relevant for inclusion in future engagement activities. Quantum Power Ghana Gas Limited -7 Knight Piésold Consulting

10 Table C-1: Stakeholder Categories and Groups Level Stakeholder Group Location National Regional and District Local Environmental Protection Agency (Accra and Tema) Ghana Maritime Authority Ghana Ports and Harbours Authority (GHAPOHA) Volta River Authority (VRA) Ministry of Power Energy Commission (EC) Ministry of Fisheries and Aquaculture Development - Fisheries Commission Independent Power Producers Ghana Highway Authority Electricity Company Ghana Ghana Water Company - Accra Water Resource Commission National Fisheries Association of Ghana (NAFAG) Tema Metropolitan Assembly (TMA) Kpone Katamanso District Assembly Ningo Prampram District Assembly Tema Development Corporation (TDC) The Tema Ashaiman Golf Club Wonsom Fishing Association Ghana Canoe Fisheries Association Ghana Inshore Fishery Association-Tema Ghana Industrial Trawlers Association Dzigbordi Fish Mongers Association Enufa-Enufa Canoe Association Directly Affected Parties The General Public: Communities living in close proximity to the servitude Accra Kpone/ Tema Kpone/ Tema While Quantum Power will adopt an inclusive approach to engagement, it will focus particularly on tailoring engagement to meet the needs of local stakeholders. Local stakeholders include all stakeholders that are located within or undertake livelihood activities directly adjacent to both its terrestrial and marine infrastructure. This includes: Local customary authorities; Local government including political and administrative authorities; Community members and the various fishing associations; Fishing related businesses, including fish mongering and subsidiary services;and Local suppliers and employees. Engagement with local and vulnerable groups will be undertaken through an on-going process whereby a Quantum Power Community Relations Manager and Community Liaison Officer (CLO) will actively engage and ensure the participation of these groups in all phases of the Project lifecycle. Quantum Power Ghana Gas Limited -8 Knight Piésold Consulting

11 Quantum Power will develop a mechanism whereby the views of stakeholders can be fully considered in relevant decision-making. The objective of this mechanism will be to ensure that they are not only heard, but also able to influence the Project s development where appropriate and practicable. This can include the establishment of working groups that represent the interests of vulnerable parties who may not be able to speak out during standard engagement activities. Quantum Power will also work closely with local experts, including the community liaison officers, to ensure that engagement activities are designed in such a way that they do not exacerbate inequalities or vulnerabilities. 3.2 Issues Analysis Quantum Power will maintain an Issues Log/register of material issues, where this is generated by reflecting on and tracking trends from amongst all comments, concerns and grievances raised by stakeholders through engagement throughout the Project lifecycle. Table C-2 below presents a framework for the Issues Log based on the comments, concerns and grievances raised during the initial project development phase. Quantum Power Ghana Gas Limited -9 Knight Piésold Consulting

12 Table C-2: Issue Categories and Groups Issue Category Negative Impacts Current Issue Raised Anticipated Impacts Short term disruption in fishing activities/operations Potential increased restriction to fishing areas Potential reduced income generation during project construction Potential diversification in economic activities/operations (such as diversification from fishing and related activities towards seeking for high income jobs in the oil and gas sector? Temperature and water quality changes during LNG water discharge Noise impacts on fishery resources Potential increased traffic offshore and collision of vessels and canoes Noise and aerial emissions from operation of FSRU Noise and aerial emissions from operation of metering station Marine sediment pollution Increased traffic within project area Vehicle and pedestrian accidents within project area Aerial emissions and from gas flaring and heat generation Potential temporary disruption in social services and increased pressures on social infrastructure. Displacement of subsistence farming activities within RoW Positive Impacts Anticipated Impacts Potential increase in social infrastructure and community development programs Potential acute employment opportunities for local labour force Potential increase in the provision of social services to community 4 EXTERNAL ENGAGEMENT This section outlines the approach to engagement for the pre-construction, construction, operation, decommissioning and closure phases of the proposed Project. A three pronged approach to engagement will be adopted, namely: 1. A proactive approach, engaging stakeholders at key milestones; 2. A proactive, on-going approach to regular engagement and communication activities; and 3. A responsive approach. Quantum Power Ghana Gas Limited -10 Knight Piésold Consulting

13 4.1 Proactive Milestone Engagement Engagement is required at key points in the Project lifecycle both in anticipation of and in response to changes in Project activities and their associated positive and negative impacts. It is therefore important that engagement activities are designed both in anticipation of key milestones and during transition periods between the phases in the Project lifecycle. This section presents the key objectives of engagement at the pre-construction, construction, operations, decommissioning and closure phases of the Project. It also presents the proposed approach to engagement at these phases and engagement considerations. Detailed engagement plans will need to be designed to identify the engagement activities at each phase of the Project Pre-Construction Objectives of Engagement Quantum Power has shifted its attention to a set of pre-construction activities following the completion of the feasibility study and the submission of the scoping report to the EPA for approval. The key objectives during pre-construction are: To inform and engage with stakeholders on the finalisation of the Project design, taking stakeholder concerns into consideration where relevant; To inform stakeholders of Quantum Power s plans and activities to be undertaken during both pre-construction and construction, including anticipated impacts, associated mitigation, contracting of workforce including security providers, procurement of goods and services etc.; To develop and design, in consultation with local stakeholders, a participatory monitoring forum that will allow affected communities, particularly fishermen, to become involved in monitoring impacts alongside Quantum Power; To engage stakeholders on implementation of management plans and mitigation activities identified in the ESIA, and identify and address any issues that arise; To establish clear communication channels, which both allow Quantum Power to make information readily available, particularly for local stakeholders, and allow stakeholders to raise queries, concerns or comments; To establish positive relationships with stakeholders; and To identify and develop opportunities for stakeholders to benefit during the construction phase Approach to Engagement Table C-3 presents a set of engagement activities that will be undertaken during preconstruction. Quantum Power Ghana Gas Limited -11 Knight Piésold Consulting

14 Table C-3: Approach to Engagement Pre-Construction Technical Project Aspect Engagement Objective (s) Engagement Activity Stakeholder Group (s) Finalisation of Project Design To ensure local stakeholders are Update meetings with local District Assembly (Kpone and aware of the finalised design stakeholders. Tema). should it differ from that depicted Provide an update through the Traditional Councils (Kpone and in the ESIA CLO Tema). Any directly affected stakeholders Land Acquisition, Resettlement and Inform and engage with Meetings with traditional councils, District Assembly (Kpone and Compensation stakeholders prior and during VRA and directly impacted Tema). construction activities where there communities. Traditional Councils (Kpone and is anticipated disturbance and Tema). reduced land access or relocation. Any directly affected stakeholders This is to be undertaken within Volta River Authority partnership of the VRA. The Tema Ashaiman Golf Club Procurement of Goods and Services To identify opportunity for local Meetings with local authorities District Assembly (Kpone and business to benefit from and a basic survey to determine Tema). procurement (where appropriate). where local business may benefit Traditional Councils (Kpone and from procurement. Tema). Any directly affected stakeholders Volta River Authority The Tema Ashaiman Golf Club Continued development of Community Identify partners to work with. Meetings with potential partners, District Assembly (Kpone and Development Programme (CDP), this should include local Tema). identifying partners and projects, with government and NGO s. Traditional Councils (Kpone and a focus on meeting Mine contracting Workshop with local leaders to Tema). requirements by using local determine and agree on NGOs resources. community development Local leaders. initiatives. Increased community expectations Identify vulnerable groups in Public forum and meetings with NGOs Quantum Power Ghana Gas Limited -12 Knight Piésold Consulting

15 and uncertainties around displacement project affected communities traditional authorities Local and traditional leaders District assembly Quantum Power Ghana Gas Limited -13 Knight Piésold Consulting

16 Considerations Quantum Power will focus attention on establishing effective communication channels during this phase and forming positive relationships with stakeholders. Together, this should ensure that Quantum Power is able to maintain positive relationships and effective communication and engagement during the construction phase.in addition from the outset Quantum Power will identify and develop specific means to include vulnerable or marginalised groups into all engagement processes Construction Objectives of Engagement Many of the impacts associated with the Project will be experienced or heightened during construction. The objectives for engagement during this phase thus include: To ensure that stakeholders are informed of the construction activities and associated impacts in anticipation of the impacts being experienced. To enable participatory monitoring that will involve stakeholders in monitoring and feeding back to Quantum Power about the impacts experienced during construction as well as the effectiveness of the mitigation measures. To serve as a way of mitigating some of the anticipated impacts. To manage risk and establish and maintain sustainable relationships with stakeholders. To identify and develop opportunities with stakeholders for sustainable mutual benefit Approach to Engagement Table C-4 presents a set of engagement activities that will be undertaken during construction. Quantum Power Ghana Gas Limited -14 Knight Piésold Consulting

17 Table 4: Approach to Engagement Construction Key Technical Project Aspect Engagement Objective (s) Engagement Activity (ies) Stakeholder Group (s) Tema LNG ESIA development Make available and inform the general Request one-on-one meeting with All identified stakeholders across; public up to date information on the stakeholders. national, regional/district and local ESIA process. Update of project website with ESIA levels documents: G/ Make available hard copies of ESIA reports and non-technical summary documents at Quantum Powers office and public libraries Provide platform and opportunity for Organisation of public open forums Any directly affected stakeholder stakeholders to comment on the Set up community participatory Traditional authorities (Tema and project learning groups as key focus for Kpone) Provide information to stakeholders communicating with public Family/clan heads/land owners and PAPs on pipeline construction One on-one meeting with traditional Ghana Grid Company (GridCo) activities leaders and community opinion Volta River Authority Disclose predicted impacts from leaders Ghana Highway Authority Construction of pipeline pipeline construction activities to One-on-one meeting with local Tema Development Corporation (onshore) stakeholders government authorities. Receive comments/grievances from stakeholders and reshape construction design methods if necessary Understand land administration process within the project development area Construction of project access Provide information to stakeholders One on-one meeting with traditional Any directly affected stakeholder roads and PAPs on potential increase in leaders and community opinion Traditional authorities (Tema and Quantum Power Ghana Gas Limited -15 Knight Piésold Consulting

18 traffic and accidents during project leaders Kpone) construction One-on-one meeting with local Valco Discuss and identify the creation of government authorities. Tema Department of Feeder alternative routes for access Roads Provide information to stakeholders Public meetings and open forum Any directly affected stakeholder and fishermen on projects marine discussion with local fishermen. Fishing associations and groups component and development One-on-one meetings with local Government regulators (Fisheries Understand fishing government authorities Commission,) operations/activities and establish One-on-one meetings with fishing Ghana Maritime Authority Construction of marine facilities how project will impact on fishing as sector and maritime regulatory bodies. Ghana Ports and Harbours well as how fishing activities can Authority impact on the project. Identify regulatory compliances of the project to development of offshore components Construction camp and Provide information to stakeholders Public meetings and open forum Any directly affected stakeholder laydown area and project affected person on discussion with project affected The public, Chiefs and Elders in construction area boundaries communities (Bankuman, Local fishing the traditional areas (Bankuman Discuss with stakeholders potential harbour and Kpone). and Kpone) employment opportunities and project Meeting discussions with key opinion benefits. leaders in project affected communities. Natural gas transfer to FSRU Explain LNG transport process to Public meeting with fishermen and Any directly affected stakeholder and FSRU liquefaction process stakeholders fishing associations. Fishermen and Fishing Explain potential impacts from FSRU Presentation of FSRU non-technical Associations operation and gas transfer process to summary notes to stakeholders Local government and traditional stakeholders authority leaders Ghana Ports and Harbours Quantum Power Ghana Gas Limited -16 Knight Piésold Consulting

19 Authority Ghana Maritime Authority Quantum Power Ghana Gas Limited -17 Knight Piésold Consulting

20 Considerations Quantum Power will ensure that contractors and sub-contractors are briefed and committed to adhering to Quantum Power s policies and approaches to engaging with stakeholders. This will include training on a worker code of conduct which includes requirements on interaction with local stakeholders and respecting local tradition and culture. Strict contractor management in general and in relation to stakeholder interfacing activities in particular will be crucial to the effectiveness of Quantum Power s approach to engagement during construction Operations Objectives of Engagement The transition from construction to operations will result in observable changes for stakeholders, in particular local stakeholders. One of the most noticeable changes will be the reduced labour force requirements. The objectives of engagement during the transition to operations include: To inform stakeholders of operational activities and likely changes to occur during the transition to operations. To manage expectations around employment in future phases. To allow stakeholders the opportunity to reflect on changes during construction and the effectiveness of both engagement and the implemented mitigation measures with a view to improving practices for the operations phase. To allow stakeholders to monitor changes during the operation phase. To continue to build relationships with local stakeholders, and identify partners to work with on community development initiatives. To allow stakeholders to comment on proposed community development initiatives and identify opportunities in the context of the local area and changes that are resulting Approach to Engagement Table C-5 outlines the approach to be adapted to engagement during the operational phase. Quantum Power Ghana Gas Limited -18 Knight Piésold Consulting

21 Table C-5: Approach to Engagement Operations Technical Project Aspect Engagement Objective Engagement Activity Stakeholder Group Stakeholder Consultation Continuously engage the public Request one-on-one meeting with All identified stakeholders in the development of the stakeholders. across; national, project while identifying new Update of project website with ESIA regional/district and local levels and potential stakeholders documents: Make available hard copies of ESIA reports and non-technical summary documents at Quantum Powers office and public libraries Monitoring and evaluation of Project Involve stakeholders in Engage with local government and District Assembly (Kpone and impacts monitoring and evaluation of community leaders to present results of Tema). effectiveness of mitigation monitoring. Traditional Councils (Kpone and measures. Tema). Any directly affected stakeholders The Tema Ashaiman Golf Club Grievance feedback and responses Disclose to stakeholders the Public engagement and participation Any affected project stakeholder location of grievance through CLOs District assembly (Kpone and mechanism Update stakeholder issue register and Tema) To work directly with grievance management process People, Chiefs and Elders of stakeholders and the public to Bankuman, Kpone and Fishing address all complaints to the harbour area. project Non-governmental organisations and civil society groups Project Capacity building Identify skills requirements in Partner with local NGO or civil society to Any affected project stakeholder communities engage communities in training and District assembly (Kpone and Quantum Power Ghana Gas Limited -19 Knight Piésold Consulting

22 Empower local/project affected development programs. Tema) communities with project skills Establish external stakeholder forums People, Chiefs and Elders of and knowledge Develop and communicate stakeholder Bankuman, Kpone and Fishing Build trust and enhance engagement protocols for employers harbour area. community relations and staff Non-governmental organisations and civil society groups Corporate Policies (Health, Safety, Disclose to stakeholders Integrate stakeholder engagement Any affected project stakeholder Environment and Corporate Social corporate environmental policy with project environmental health District assembly (Kpone and Responsibilities) policies and safety policy Tema) Develop protocols for employees, People, Chiefs and Elders of consultants and contractors Bankuman, Kpone and Fishing harbour area. Project staff, Contractors and sub contractors Stakeholder engagement Ensure internal alignment to identify and mitigate potential risk proactively Ensure integration and coordination of all communications functions Track external developments and mitigate potential risk Internal workshops Establish teams responsible for stakeholder engagement Develop and implement communication plan Continuous media monitoring and engagement Quantum Power management Community Relations Manager Quantum Power Ghana Gas Limited -20 Knight Piésold Consulting

23 Considerations It should be noted that the transition from construction to operations can affect stakeholder relations that have been developed. In addition, changes to the Project team may further negatively affect stakeholder perceptions and relationships. Efforts will be made to increase engagement activities and information dissemination during this transition period. As far as possible, Quantum Power will maintain or overlap Community Relations Staff between phases. New contractors recruited for operations will be trained and monitored to ensure that they adhere to Quantum Power s policy on stakeholder engagement. Quantum Power s workforce will also receive training on the worker code of conduct which includes requirements on interaction with local stakeholders and respecting local tradition and culture Decommissioning Objectives of Engagement The key change during this phase will be the cessation of Project activities and closure which will result in a downsizing, redeployment or retrenchment of the workforce and associated knock-on effects. In addition, there will be a focus on environmental rehabilitation and postclosure social activities. Specific engagement objectives for this phase will include: To inform stakeholders of decommissioning activities prior to commencement of the decommissioning phase, and involve stakeholders in planning for and monitoring rehabilitation activities; To engage on expectations and measures to address impacts such as retrenchment of the workforce; and To engage and work with local stakeholder groups and elected partners to ensure identified community development initiatives are implemented sustainably and measures are put in place to allow for community ownership Approach to Engagement Table C-6 details the approach to be adopted to engagement during decommissioning and closure. Quantum Power Ghana Gas Limited -21 Knight Piésold Consulting

24 Table C-6: Approach to Engagement Decommissioning Technical Project Aspect Engagement Objective Engagement Activity Stakeholder Group Removal of subsea pipelines Communicate decommissioning plans and schedule programs to stakeholders Communicate predicted decommissioning impacts to stakeholders Record and document all complaints to the decommissioning process Publication of decommissioning plans in the mass media/newspaper Open forum/public disclosure of decommissioning plans to stakeholders Requested one-on-one meeting with local government Workshops All directly affected stakeholders; Fishing associations and fishing businesses Traditional authorities (Tema and Kpone) Fisheries commission District assembly (Tema and Kpone) Ghana Maritime Authority Environmental Protection Agency Removal of terrestrial pipelines Communicate decommissioning plans and schedule programs to stakeholders Record and document all complaints to the decommissioning process Open forum/public disclosure of decommissioning plans to stakeholders Requested one-on-one meeting with local government All directly affected stakeholders Subsistence farmers within RoW Business along RoW Traditional council (Tema and Kpone) Environmental Protection Agency Tema Development Corporation District assembly (Tema and Kpone) On-going monitoring of closure Ensure all decommissioning risk Update grievance mechanism and All directly affected stakeholders activities are identified and communicated Update stakeholders with any delay in schedule for decommissioning issues log/register Business associations along RoW Environmental Protection Agency Tema Development Corporation District assembly (Tema and Kpone) Implement exit strategy for CDP and Disclose procedure for final Publication in the mass media Business associations hand over of infrastructure handover of project infrastructure Request for tender Government of Ghana Quantum Power Ghana Gas Limited -22 Knight Piésold Consulting

25 Considerations Thorough engagement will need to be conducted on impacts associated with redundancy, and cessation of Project activities. Quantum Power must ensure that stakeholder expectations are managed, and the initiatives implemented as part of the CDP are appropriate and result in sustainable benefits beyond the Project. 4.2 Proactive and Ongoing Engagement In addition to engaging at key milestones, Quantum Power will conduct on-going engagement and communications activities with all stakeholder groups through all phases of the Project. The objective of this activity is to provide regular updates and feedback, thereby building sustainable relationships. The approach to regular, on-going engagement and communication should be reviewed and regularly updated, including at the transition of the various phases of the Project and following the evaluations of the described in Section 6. Quantum Power Ghana Gas Limited -23 Knight Piésold Consulting

26 Table C-7: Protocol for On-going Engagement Stakeholder Group Frequency Engagement Activity Responsibility National Annually Written Report on Project Progress and Quantum Power Representative Environmental Protection Authority Environmental and Social performance National Fisheries Association of Ghana (NAFAG) Ministry of Fisheries and Aquaculture Development- Fisheries Commission Ghana Maritime Authority District and Local Quarterly Presentation on Project Progress and Environmental Community Relations Manager Tema Metropolitan and Social performance Assembly (TMA) Meetings as required Kpone Katamanso District Assembly Tema Development Corporation (TDC) The Tema Ashaiman Golf Club Local Monthly Presentation on Project Progress and Environmental Community Relations Manager, Fishing Associations and Social performance Community Liaison Officers and Fish Mongers Associations Meetings as required Grievance Management Officer Directly Affected Parties Quantum Power Ghana Gas Limited -24 Knight Piésold Consulting

27 4.3 Responsive Engagement Quantum Power has an open door policy in so far as it commits to engaging with stakeholders in response to concerns they raise, either formally or informally. The responsive approach provides stakeholders a mechanism through which to raise concerns, questions and issues and dictates a procedure for Quantum Power to follow with regards to how such complaints or grievances will be addressed, described below. Any issues may be raised through this mechanism, including concerns related to project activities, impacts, mitigation measures or the treatment of locals by Quantum Power s staff, contractors or security providers Grievance Mechanism Quantum Power will establish and maintain a mechanism that is: Culturally appropriate; Clear, simple and understandable; Easily accessible, to all stakeholders including vulnerable groups, immobile and illiterate stakeholders, regardless of their language preference; Appropriately scaled to Project impacts and risks; Transparent; and Responsive, ensuring timely and appropriate responses to grievances made. Quantum Power s grievance mechanism (Appendix A) comprises four key steps: Registration of grievances; Review of grievances; Generation of responses; and Feedback and closure. 5 INTERNAL CAPACITY AND GOVERNANCE The aim of this section is to identify the internal capacity and governance requirements that are necessary for robust and relevant engagement to be conducted throughout the Project lifecycle. The section will present on organisational structure, resourcing, planning and systems, tools and templates required tosupport the external engagement activities described in Section Organisational Structuring Core Engagement Team The Quantum Power Project Manager is accountable to the board for the Project as well as the associated environmental and social performance and engagement programme; The Environmental Site Officer (ESO) who is responsible for all environmental monitoring is accountable to the Project Manager for the effective implementation of the Environmental and Social Management Plan implementation and monitoring. Quantum Power Ghana Gas Limited -25 Knight Piésold Consulting

28 A Community Relations Team which will comprise of the Community Relations Manager (CRM), Community Liaison Officers (CLO) and a Grievance Management Officer (GMO). The Community Relations Manager (CLM) is responsible for effective implementation of all stakeholder engagement activities and reports to Project Manager. The Community Liaison Officer (CLO) will work in support of the Community Relations Manager to implement all stakeholder engagement activities The Grievance Management Officer (GMO) will work in the community relations team and be responsible for documenting and managing all grievances and complaints to the project Alignment with Other Teams 5.2 Resourcing For the successful implementation of the external engagement plan and for an effective engagement process in general, Quantum Power recognises that the following resources and facilities need to be put in place: Electronic Resources: A website will be developed to provide the general public, including national and international stakeholders, information about the Project on a regular basis. This may be managed by an external consultant but should be in close co-ordination with the CLO. A local Project Office: A project office should be established in close proximity to the project and local communities. This office will be manned by the CLO 7 days a week to provide stakeholders basic information and materials as well as to receive stakeholder comments or concerns and log these into the formal grievance mechanism Recruitment Considerations The capacity of staff managing engagement related facilities or involved in engagement activities needs to be strengthened so as to ensure that they are able to effectively implement Quantum Power s approach to engagement. This is particularly important from a gender perspective as well as an intercultural perspective. These individuals should encompass the following attributes: Approachable and available, where they will need to be available; Empathetic and representative of local stakeholders but independent with no interests in local villages. The CLO(s) need to facilitate relationships and therefore need to be able to deliver difficult messages to both stakeholders and Quantum Power s management. It is important that local stakeholders feel comfortable to provide the CLO(s) feedback, concerns and grievances; Comprehensive and thorough, where they will be involved in documenting and monitoring all stakeholder activities, including facilitation of participatory monitoring; and Honest and trustworthy, where they will be tasked with creating and maintaining constructive relationships between Quantum Power and the local stakeholders. Quantum Power Ghana Gas Limited -26 Knight Piésold Consulting

29 5.3 Systems, Tools and Templates Systems Quantum Power will develop a system supported by a set of tools and templates which will support the implementation and management of the engagement programme. This system will also serve as an information management system, a monitoring system and an issues management system. 5.4 Tools and Templates Quantum Power will develop and maintain the following tools and templates: An up to date stakeholder database; An Issues Log; A Grievance Log and associated mechanism; and A Commitments and Response Register 6 MONITORING AND EVALUATION It is important to monitor engagement activities to ensure that the guidance contained within the is being implemented effectively. Monitoring allows Quantum Power to adjust the approach as necessary to ensure that the objectives of the are being achieved through the engagement activities being undertaken. Quantum Power will also monitor stakeholder engagement efforts as a way in which to record efforts made in this regard. The outcomes of monitoring will be reported to the Board of Directors in an annual Environmental and Social Performance Report. A template will be set up for this report, which will identify what content is required. This will include a simple set of indicators against which monitoring activities will be undertaken. In addition to monitoring the way in which the is being applied and engagement activities undertaken, there is also a need to evaluate whether the remains appropriate. There is a need to question whether the guidance in the is effective in achieving the intended objectives stipulated in the as well as whether these objectives remain relevant as the project develops. Quantum Power Ghana Gas Limited -27 Knight Piésold Consulting

30 Appendix A Grievance Mechanism Quantum Power Ghana Gas Limited -28 Knight Piésold Consulting