REPORT. Australian Gold Reagents West Africa Supply Chain Ghana, Burkina Faso and Mali, Recertification Audit, Summary Audit Report

Transcription

1 INTERNATIONAL CYANIDE MANAGEMENT CODE West Africa Supply Chain Ghana, Burkina Faso and Mali, Recertification Audit, Summary Audit Report Submitted to: International Cyanide Management Institute (ICMI) Ltd 1400 I Street, NW Suite PO Box 345 Washington, DC KWINANA WA 6167 UNITED STATES OF AMERICA AUSTRALIA REPORT Report Number R-Rev1 Distribution: 1 Copy - ICMI (+1 Electronic) 1 Copy - (Electronic) 1 Copy - Golder Associates Pty Ltd (Electronic)

2 Table of Contents 1.0 INTRODUCTION Operational Information Description of Operation Australia Limited Bolloré Africa Logistics Bolloré Africa Logistics Ghana AL Burkina Faso Burkina Logistics Mining Services Transit Storage Port Facilities Port of Tema Port of Takoradi Tema Bonded Terminal Auditors Findings and Attestation CONSIGNOR SUMMARY Principle 1 Transport Transport Practice Transport Practice Transport Practice Transport Practice Transport Practice Transport Practice Principle 2 Interim Storage Transport Practice Principle 3 Emergency Response Transport Practice Transport Practice Transport Practice Transport Practice Transport Practice Report No R-Rev1 i

3 3.0 DUE DILIGENCE SUMMARY Auditor Review of Due Diligence LIMITATIONS APPENDICES APPENDIX A Limitations Report No R-Rev1 ii

4 1.0 INTRODUCTION 1.1 Operational Information Name of Transportation Facility: West Africa Supply Chain Ghana, Burkina Faso and Mali Name of Facility Owner: Name of Facility Operator: Name of Responsible Manager: Address: State/Province: Country: Not Applicable Ltd Ed Beard, Export Technical Manager Ltd PO Box 345 Kwinana 6167 Western Australia Australia Telephone: Fax: ebeard@a-g-r.com.au 1.2 Description of Operation Australia Limited Australia Limited (AGR) is the management company of the unincorporated joint venture between CSBP Ltd (CSBP) and Coogee Chemicals Pty Ltd (Coogee Chemicals). CSBP, a subsidiary of Wesfarmers Ltd., is the major participant in the venture and acts as both plant operator and sales agent. Coogee Chemicals is a local manufacturer and distributor of industrial chemicals. The AGR cyanide production facility is located within CSBP s fertiliser and chemicals complex at Kwinana, some 40 km south of Perth within the state of Western Australia. AGR produces and transports two different forms of sodium cyanide from the Kwinana production facility, namely solution and solids. Sodium cyanide solution is produced as a 30% liquid and solid sodium cyanide as a >97%, white briquette. AGR in its capacity as the sales agent for is the consignor and is responsible for the overall management of the sodium cyanide transportation activities Bolloré Africa Logistics The Bolloré Group was founded in From its historic beginnings in thin papers, the Group has set about diversifying its product ranges and services. It is now a player in plastic films for capacitors and packaging, electric batteries, thin papers, transportation in Africa (freight forwarding and stevedoring, railways) and international Logistics, fuel distribution and dedicated terminals and systems. The Africa transportation arm of the Group is managed by Bolloré Africa Logistics (Bolloré), which has been established for more than 50 years in 41 countries. The company has established some 200 agencies and is a key player in port activity, terrestrial transport and tailor-made logistics solutions. Bolloré is actively expanding its integrated logistics network in Africa and is now the biggest transport and logistics operator in Africa. West Africa Supply Chain Ghana, Burkina Faso & Mali 13 Report No R-Rev1 1

5 Bolloré Africa Logistics Ghana Bolloré Africa Logistics Ghana (AL Ghana) is a subsidiary of Bolloré and is based in Tema, Ghana. AL Ghana conducts freight forwarding and transportation activities within West Africa. In 2012, a number of subsidiaries of Bolloré s operations in Ghana were grouped under the AL Ghana name. These subsidiaries included AL Ghana Limited and the Antrak Logistics Group (Antrak). AL Ghana was certified as being compliant with the Code on 26 April AL Burkina Faso AL Burkina Faso is a subsidiary of Bolloré and is based in Ouagadougou, Burkina Faso. AL Burkina Faso conducts: Air and sea freight forwarding National and international transport Customs brokerages Container management Lift-handling Warehousing. AL Burkina Faso was first certified against the Code on 6 May A recertification audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process Burkina Logistics Mining Services Burkina Logistics Mining Services (BLMS) is a subsidiary of Bolloré and was formed in July 2008 to service the developing mining industry within Burkina Faso. The company specialises in: Transport and logistics of dangerous reagents Crane hire. BLMS conducts the transport of hazardous goods for AL Burkina Faso and operates out of their office in Burkina Faso. BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Ghana is responsible for transporting cyanide to the Prestea Sankofa Gold Mine in Ghana. BLMS and AL Burkina Faso are responsible for transporting cyanide to the Syama Gold Mine in Mali and the Essakane Gold Mine in Burkina Faso. 1.3 Transit Storage Within the scope of this audit, transit storage is associated with port operations (i.e. Ports of Tema and Takoradi), where containers of cyanide are removed from the vessels, temporarily stored and then placed on road vehicles for the next part of the journey. These transit storages depots are managed by the relevant port authorities and due consideration of relevant protocol requirements has been made through the due diligence process. West Africa Supply Chain Ghana, Burkina Faso & Mali 13 Report No R-Rev1 2

6 1.4 Port Facilities Port of Tema The Port of Tema, near Accra, Ghana, is the main container port servicing Ghana and its landlocked neighbouring countries. AGR ships sodium cyanide to this port from the Port of Fremantle by utilising the Mediterranean Shipping Company. The Port allows unloading of the shipments for the final road transport section to the mining operations in Ghana as well as Burkina Faso and Eastern Mali. The Port is overseen by the Ghana Ports and Harbour Authority (GPHA). The components of the supply chain preceding the receipt of AGR s cyanide at the Port of Tema are covered under audits Port of Takoradi The Port of Takoradi is located in south west Ghana and is suitably located to service the mining industry near the town of Takoradi. AGR ships sodium cyanide to these ports from the Port of Fremantle by utilising the Mediterranean Shipping Company. The Port allows unloading of the shipments for the final road transport section to the mining operations located near the town of Tarkwa in southwest Ghana. The Port is overseen by the Ghana Ports and Harbour Authority (GPHA). The components of the supply chain preceding the receipt of AGR s cyanide at the Port of Takoradi are covered under audits Tema Bonded Terminal In order to reduce congestion within the terminal at the Port of Tema, in November 2012 the GPHA approved the use of bonded terminals located outside of the main terminal. Five Off Dock Terminals provide receipt, storage and delivery services for containers discharged in the Port of Tema. These terminals have enhanced the cargo flow through the Port. All containers of cyanide shipped by AGR are collected by Tema Bonded Terminal transport from the Tema terminal within 48 hours of arrival and transported to the Tema Bonded Terminal, which is located less than 500 metres away. West Africa Supply Chain Ghana, Burkina Faso & Mali 13 Report No R-Rev1 3

7 1.5 Auditors Findings and Attestation AGR s West Africa Supply The International Chain Ghana, Burkina Faso in substantial compliance with Cyanide Management and Mail is: Code Audit Company: Golder Associates Pty Ltd Audit Team Leader: Edward Clerk, CEnvP (112), Exemplar Global (020778) The supply chain is deemed to have been in compliance throughout the recertification period. No significant cyanide incidents or cyanide exposures / releases were noted as occurring during the audit period. Name and Signatures of Other Auditors: Name Position Signature Date Edward Clerk Lead Auditor & Technical Specialist 13 Dates of Audit: This AGR West African Supply Chain Ghana, Burkina Faso and Mali Recertification Audit was assessed based on the following due diligence reports: Due diligence review of Ghana Ports and Harbour Authority, Tema and Takoradi Ports and Tema Bonded Terminal. The due diligence was undertaken by AGR in April 2013 and was reviewed by Golder Associates Pty Ltd (Golder) during May and June I attest that I meet the criteria for knowledge, experience and conflict of interest for Code Verification Audit Team Leader, established by the International Cyanide Management Institute and that all members of the audit team meet the applicable criteria established by the International Cyanide Management Institute for Code Verification Auditors. I attest that this Summary Audit Report accurately describes the findings of the verification audit. I further attest that the verification audit was conducted in a professional manner in accordance with the International Cyanide Management Code Verification Protocol for Cyanide Transportation Operations and using standard and accepted practices for health, safety and environmental audits. Report No R-Rev1 4

8 2.0 CONSIGNOR SUMMARY 2.1 Principle 1 Transport Transport Cyanide in a manner that minimises the potential for accidents and releases Transport Practice 1.1 Select cyanide transport routes to minimise the potential for accidents and releases. The supply chain is in substantial compliance with Transport Practice 1.1 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 1.1 requiring cyanide transport routes to be selected to minimise the potential for accidents and releases. AGR has demonstrated compliance with Transport Practice 1.1 through the engagement of Code certified transporters. Bolloré is contracted to transport sodium cyanide, produced at the AGR production facility in Kwinana, Western Australia, from the Ports of Tema and Takoradi to customer mine sites in Ghana, Burkina Faso and Mali. AL Ghana, AL Burkina Faso and BLMS, all subsidiaries of Bolloré, undertake the physical transportation activities in line with local and corporate policies, procedures and practices. The AGR Export Technical Manager Sodium Cyanide reported that all routes selected for the transportation of AGR s cyanide are assessed by AGR annually, with the exception of the routes to Mali, which have not occurred for approximately 12 months due to security reasons. AGR performs annual audits of its transporters, including Bolloré to assess compliance with the ICMC and other regulations. The AGR annual audits assess compliance against AGR s Transport Management Plan. AGR s contract with Bolloré states the transporter should be compliant with the Code. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Report No R-Rev1 5

9 Ports of Tema AGR takes into consideration the ports available to service the intended target area. AGR only operates in export markets that are serviced by major international shipping companies with the ability to offer scheduled container services and, therefore, this determines the selection of the port used. The Port of Tema is the main container port servicing Ghana and its landlocked neighbouring countries. The Ports allow unloading of the shipments of containers and subsequent road transport to the customer mine sites. The GPHA oversees the operation at the port. Port of Takoradi AGR takes into consideration the ports available to service the intended target area. AGR only operates in export markets that are serviced by major international shipping companies with the ability to offer scheduled container services and, therefore, this determines the selection of the port used. The Port of Takoradi is suitably located to service the mining industry located near the town of Tarkwa in southwest Ghana. The Ports allow unloading of the shipments of containers and subsequent road transport to the customer mine sites. The GPHA oversees the operation at the port Transport Practice 1.2 Ensure that personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to communities and the environment. The supply chain is in substantial compliance with Transport Practice 1.2 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 1.2 requiring personnel operating cyanide handling and transport equipment can perform their jobs with minimum risk to communities and the environment. AGR has demonstrated compliance with Transport Practice 1.2 through the engagement of the Code certified transporter, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Report No R-Rev1 6

10 2.1.3 Transport Practice 1.3 Ensure that transport equipment is suitable for the cyanide shipment. The supply chain is in substantial compliance with Transport Practice 1.3 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 1.3 requiring that transport equipment is suitable for the cyanide shipment. AGR has demonstrated compliance with Transport Practice 1.3 through the engagement of Code certified transporters, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process Transport Practice 1.4 Develop and implement a safety program for transport of cyanide. The supply chain is in substantial compliance with Transport Practice 1.4 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 1.4 requiring the operation develop and implement a safety programme for transport of cyanide. Report No R-Rev1 7

11 AGR has demonstrated compliance with Transport Practice 1.4 through the engagement of Code certified transporter, Bolloré. Additionally, AGR s cyanide is packaged at its cyanide production facility in Kwinana, Western Australia, in accordance with the packaging and labelling requirements required by the political jurisdictions through which the load will pass. The production facility was conditionally recertified against the Code on 24 November A Corrective Action Plan, prepared to close gaps identified during the Recertification Audit, was completed on 6 January These corrective actions were not related to packaging or labelling. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process Transport Practice 1.5 Follow international standards for transportation of cyanide by sea and air. The supply chain is in substantial compliance with Transport Practice 1.5 not applicable Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 1.5 requiring the operation follow international standards for transportation of cyanide by sea and air. AGR does not transport consignments of cyanide by sea within the scope of this audit. AL Ghana AL Ghana is only engaged in land based transport of cyanide within the scope of this audit. BLMS BLMS is only engaged in land based transport of cyanide within the scope of this audit. Report No R-Rev1 8

12 AL Burkina Faso AL Burkina Faso is only engaged in land based transport of cyanide within the scope of this audit. Ports of Tema A due diligence of the Port of Tema was conducted by AGR in April The due diligence indicated that the Port of Tema was in compliance with the Dangerous Goods Code of the International Maritime Organisation. The due diligence specifically referenced provisions of the Dangerous Goods Code that are required to be addressed under this question. Ports of Takoradi A due diligence of the Port of Takoradi was conducted by AGR in April The due diligence indicated that the Port of Takoradi were in compliance with the Dangerous Goods Code of the International Maritime Organisation. The due diligence specifically referenced provisions of the Dangerous Goods Code that are required to be addressed under this question Transport Practice 1.6 Track cyanide shipments to prevent losses during transport. The supply chain is in substantial compliance with Transport Practice 1.6 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 1.6 requiring the operation track cyanide shipments to prevent losses during transport. AGR has demonstrated compliance with Transport Practice 1.6 through the engagement of Code certified transporters, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Report No R-Rev1 9

13 2.2 Principle 2 Interim Storage Design, construct and operate cyanide trans-shipping depots and interim storage sites to prevent release and exposures Transport Practice 2.1 Store cyanide in a manner that minimises the potential for accidental releases. The supply chain is in substantial compliance with Transport Practice 2.1 not applicable Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 2.1 that requires transporters design, construct and operate cyanide trans-shipping depots and interim storage sites to prevent release and exposures. Within the scope of this audit, transit storage is associated with port operations (i.e. Ports of Tema and Takoradi), where containers of cyanide are removed from the vessels, temporarily stored and then placed on road vehicles for the next part of the journey. These transit storages depots are managed by the relevant port authorities and due consideration of relevant protocol requirements has been made through the due diligence process. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Port of Tema A due diligence of the Port of Tema was conducted by AGR in April The due diligence assessed interim storage requirements at the Port and AGR ascertained that the port is operating in a safe and responsible manner and is suitable for the transit of sodium cyanide. Report No R-Rev1 10

14 In order to reduce congestion within the terminal at the Port of Tema, in November 2012 the GPHA approved the use of bonded terminals located outside of the main terminal. Five Off Dock Terminals provide receipt, storage and delivery services for containers discharged in the Port of Tema. These terminals have enhanced the cargo flow through the Port. All containers of cyanide shipped by AGR are collected by Tema Bonded Terminal transport from the Tema terminal within 48 hours of arrival and transported to the Tema Bonded Terminal, which is located less than 500 m away. Port of Takoradi A due diligence of the Port of Takoradi was conducted by AGR in April The due diligence assessed interim storage requirements at the Port and AGR ascertained that the port is operating in a safe and responsible manner and is suitable for the transit of sodium cyanide. Report No R-Rev1 11

15 2.3 Principle 3 Emergency Response Protect communities and the environment through the development of emergency response strategies and capabilities Transport Practice 3.1 Prepare detailed Emergency Response Plans for potential cyanide releases. The supply chain is in substantial compliance with Transport Practice 3.1 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 3.1 requiring the operation prepare detailed Emergency Response Plans for potential cyanide releases. AGR does not physically transport cyanide within the scope of this audit. However, AGR, through its engagement of Bolloré and its Code certified subsidiaries, has ensured that appropriate emergency response plans (ERP) have been prepared for the transport of its cyanide by road within the scope of this audit. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Port of Tema A due diligence of the Port of Tema was conducted by AGR in April The due diligence assessed emergency response at the Port and AGR ascertained that the Port has suitable procedures and resources in place for emergencies. Port of Takoradi A due diligence of the Port of Takoradi was conducted by AGR in April The due diligence assessed emergency response at the Port and AGR ascertained that the Port has suitable procedures and resources in place for emergencies. Report No R-Rev1 12

16 2.3.2 Transport Practice 3.2 Designate appropriate response personnel and commit necessary resources for emergency response. The supply chain is in substantial compliance with Transport Practice 3.2 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 3.2 requiring they designate appropriate response personnel and commit necessary resources for emergency response. AGR has demonstrated compliance with Transport Practice 3.2 through the engagement of Code certified transporters, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process Transport Practice 3.3 Develop procedures for internal and external emergency notification and reporting. The supply chain is in substantial compliance with Transport Practice 3.3 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 3.3 requiring that they develop procedures for internal and external emergency notification and reporting. AGR has demonstrated compliance with Transport Practice 3.3 through the engagement of Code certified transporters, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April Report No R-Rev1 13

17 BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process Transport Practice 3.4 Develop procedures for remediation of releases that recognise the additional hazards of cyanide treatment. The supply chain is in substantial compliance with Transport Practice 3.4 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 3.4 requiring that they develop procedures for remediation of releases that recognise the additional hazards of cyanide treatment. AGR has demonstrated compliance with Transport Practice 3.4 through the engagement of Code certified transporters, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Report No R-Rev1 14

18 2.3.5 Transport Practice 3.5 Periodically evaluate response procedures and capabilities and revise them as needed. The supply chain is in substantial compliance with Transport Practice 3.5 Summarise the basis for this Finding/Deficiencies Identified: AGR is in FULL COMPLIANCE with Transport Practice 3.5 requiring the operation periodically evaluate response procedures and capabilities and revise them as needed. AGR has demonstrated compliance with Transport Practice 3.5 through the engagement of Code certified transporters, Bolloré. AL Ghana AL Ghana was certified against the Code on 26 April BLMS BLMS was first certified against the Code on 6 May 2010 and recertified on 26 September AL Burkina Faso AL Burkina Faso was first certified against the Code on 6 May A Recertification Audit was undertaken between 11 and 12 March The Recertification Audit Reports were submitted to the ICMI noting that AL Burkina Faso was fully compliant with the Code. The Recertification Audit Reports are currently undergoing an ICMI completeness review process. Report No R-Rev1 15

19 3.0 DUE DILIGENCE SUMMARY AGR has conducted due diligence reviews annually of the Ports of Tem and Takoradi since The Ports of Tema and Takoradi are utilised as part of AGR s cyanide supply chain within Ghana, Burkina Faso and Mali. A due diligence of the Ports, dated April 2013 and prepared by AGR was reviewed during May and June 2013 by Golder. Supplementary information was provided to Golder by AGR on 30 May 2013 and considered as part of the due diligence review. The due diligence was conducted by AGR s Export Technical Manager, who meets the ICMI requirements for a Transport Expert. The following items were addressed within the due diligences: Summary of Port operations Safety and security Stevedoring Off dock bonded terminals Observations and information from tours and visits Compliance with ICMC Transport Practice 1.1 Transport Practice 1.5[1] Transport Practice 1.6. Although emergency response was not specifically addressed within a separate section, it was discussed satisfactorily within the Due Diligence under Transport Practices 1.5 and 2.1. The due diligence was compiled through physical visits, interviews and discussions with appropriate personnel and review of applicable documentation. Overall control of the Ports is vested in the GPHA. A stevedoring company manages the on shore (wharf) operations in the Port of Tema. Golder understands that the GPHA manage the stevedoring activities and the Port of Takoradi. The Ports have safety, first aid and emergency response capabilities. In addition, AGR s consultant in Ghana has been working with the respective safety and emergency response departments regarding the cyanide handling and product awareness. This has included the delivery of emergency response training and mock drills. Both Ports have been International Ship and Port Security Code (ISPS) compliant since July 2004 and are operating at Maritime Security level 1. The due diligence notes that all goods are packaged, labelled and placarded as per the International Maritime Dangerous Goods (IMDG) Code requirements for sodium cyanide. This adherence to the IMDG Code commences at AGR s certified production facility and is carried right through the supply chain. Report No R-Rev1 16

20 GPHA receive the vessel manifests, which includes the containers for unloading and handling by the Ports. This information is then captured in the port container terminal software programme. These programmes assist with identifying the locations where each container should be placed from each vessel. In addition, designated areas in the terminals are used for the storage of sodium cyanide. AGR s due diligence provides the following conclusion: The ongoing review as a service provider and this due diligence report has found no issues of concern in regards to the Ghana Ports and Harbour Authority (GPHA), Meridian Port Services Limited and Tema Bonded Terminal s awareness and management of the handling and systems in place for the sodium cyanide product. AGR through its Ghanaian transport service provider and AGR s Consultant in Ghana have ongoing involvement with the Port which is literally on a weekly basis. The report is not a final acceptance of Ghana Ports and Harbour Authority (GPHA) for future work and as with all service providers to AGR, AGR will continue to review and monitor their performance; this will include ongoing and regular contact to maintain awareness and preparedness. 3.1 Auditor Review of Due Diligence The due diligence review was found by the Auditor to sufficiently evaluate the port operations, within the constraints of access and limited influence, and additional management measures by the consigner were not considered necessary. 4.0 LIMITATIONS Your attention is drawn to the document Limitations, which is included as Appendix A to this report. This document is intended to assist you in ensuring that your expectations of this report are realistic, and that you understand the inherent limitations of a report of this nature. If you are uncertain as to whether this report is appropriate for any particular purpose please discuss this issue with us. Report No R-Rev1 17

21 Report Signature Page GOLDER ASSOCIATES PTY LTD Ed Clerk ICMI Lead Auditor and Technical Specialist RB/EWC/se A.B.N Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation. \\pth1-s-file01\jobs\env\2013\ agr-icmc supply chain audits-global\correspondence out\final submissions\west africa - ghana, burkina faso and mali\ rrev1 sar west african supply chain - ghana, burkina faso & mali.docx Report No R-Rev1

22 APPENDIX A Limitations Report No R-Rev1

23 LIMITATIONS This Document has been provided by Golder Associates Pty Ltd ( Golder ) subject to the following limitations: This Document has been prepared for the particular purpose outlined in Golder s proposal and no responsibility is accepted for the use of this Document, in whole or in part, in other contexts or for any other purpose. The scope and the period of Golder s Services are as described in Golder s proposal, and are subject to restrictions and limitations. Golder did not perform a complete assessment of all possible conditions or circumstances that may exist at the site referenced in the Document. If a service is not expressly indicated, do not assume it has been provided. If a matter is not addressed, do not assume that any determination has been made by Golder in regards to it. Conditions may exist which were undetectable given the limited nature of the enquiry Golder was retained to undertake with respect to the site. Variations in conditions may occur between investigatory locations, and there may be special conditions pertaining to the site which have not been revealed by the investigation and which have not therefore been taken into account in the Document. Accordingly, additional studies and actions may be required. In addition, it is recognised that the passage of time affects the information and assessment provided in this Document. Golder s opinions are based upon information that existed at the time of the production of the Document. It is understood that the Services provided allowed Golder to form no more than an opinion of the actual conditions of the site at the time the site was visited and cannot be used to assess the effect of any subsequent changes in the quality of the site, or its surroundings, or any laws or regulations. Any assessments made in this Document are based on the conditions indicated from published sources and the investigation described. No warranty is included, either express or implied, that the actual conditions will conform exactly to the assessments contained in this Document. Where data supplied by the client or other external sources, including previous site investigation data, have been used, it has been assumed that the information is correct unless otherwise stated. No responsibility is accepted by Golder for incomplete or inaccurate data supplied by others. Golder may have retained subconsultants affiliated with Golder to provide Services for the benefit of Golder. To the maximum extent allowed by law, the Client acknowledges and agrees it will not have any direct legal recourse to, and waives any claim, demand, or cause of action against, Golder s affiliated companies, and their employees, officers and directors. This Document is provided for sole use by the Client and is confidential to it and its professional advisers. No responsibility whatsoever for the contents of this Document will be accepted to any person other than the Client. Any use which a third party makes of this Document, or any reliance on or decisions to be made based on it, is the responsibility of such third parties. Golder accepts no responsibility for damages, if any, suffered by any third party as a result of decisions made or actions based on this Document. GOLDER ASSOCIATES PTY LTD GAP Form No. LEG 04 RL 1

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