Bisha Mine, Eritrea: Social Management Plans (SMPs)

Transcription

1 Bisha Mining Share Cmpany Bisha Mine, Eritrea: Scial Management Plans (SMPs) Fr: BMSC 17 th February 2010 Citrus Partners LLP Registered Office: 30 Gay Street Bath BA1 2PA United Kingdm Scial Management Plans [18/02/2010] Page 1 f 111

2 Bisha Mining Share Cmpany Table f Cntents 1 CULTURAL HERITAGE MANAGEMENT PLAN INTRODUCTION OBJECTIVES SCOPE REGULATORY REQUIREMENTS POTENTIAL IMPACTS ROLES & RESPONSIBILITIES APPROACH TO CULTURAL HERITAGE MANAGEMENT IDENTIFIED ARCHAEOLOGICAL SITES CULTURAL HERITAGE ACTIVITIES CONDUCTED (AND PLANNED) CULTURAL HERITAGE MANAGEMENT PROCEDURES CULTURAL HERITAGE DATA AND DOCUMENTATION MONITORING & REPORTING STAKEHOLDER ENGAGEMENT PLAN INTRODUCTION STAKEHOLDER ENGAGEMENT PRINCIPLES SPECIFIC OBJECTIVES SPATIAL SCOPE REGULATORY REQUIREMENTS BUDGET APPROACH TO STAKEHOLDER ENGAGEMENT PROJECT STAKEHOLDERS METHODS AND TOOLS FOR ENGAGEMENT STAKEHOLDER ENGAGEMENT PROCEDURES COMPLAINTS MANAGEMENT ROLES & RESPONSIBILITIES TRAINING MONITORING & REPORTING...33 ANNEX A...34 ANNEX B HUMAN RESOURCES & EMPLOYMENT MANAGEMENT PLAN INTRODUCTION OBJECTIVES SCOPE REGULATORY REQUIREMENTS POTENTIAL IMPACTS APPROACH TO RECRUITMENT, EMPLOYMENT AND TRAINING RECRUITMENT AND EMPLOYMENT PROCEDURES EMPLOYMENT CONDITIONS LABOUR RELATİONS EMPLOYEE-RELATED GRİEVANCES TRAİNİNG EMPLOYMENT DATA AND DOCUMENTATION FORMS ROLES & RESPONSIBILITIES MONITORING & REPORTING...62 ANNEX A...64 ANNEX B...65 ANNEX C...67 ANNEX D...69 Scial Management Plans [18/02/2010] Page 2 f 111

3 Bisha Mining Share Cmpany 4 COMMUNITY ASSISTANCE PLAN (CAP) INTRODUCTION OBJECTIVES SCOPE CORPORATE POLICY APPROACH TO COMMUNITY ASSISTANCE THE NEED FOR COMMUNITY DEVELOPMENT MANAGEMENT OF THE CAP TARGET STAKEHOLDERS SPECIFIC ACTIONS CURRENT INITIATIVES PROJECT APPROVAL PROCESS COMMUNITY ASSISTANCE DATA AND DOCUMENTATION ROLES & RESPONSIBILITIES MONITORING & REPORTING...83 ANNEX A LAND USE MANAGEMENT PLAN INTRODUCTION OBJECTIVES SCOPE REGULATORY REQUIREMENTS APPROACH TO LAND USE MANAGEMENT WORK UNDERTAKEN TO DATE GENERAL MITIGATION MEASURES AGRİCULTURE IMPROVEMENT PROGRAMME LAND USE MANAGEMENT PROCEDURES LAND USE DATA AND DOCUMENTATION LAND USE-RELATED COMPLAİNTS TRAINING ROLES & RESPONSIBILITIES MONITORING & REPORTING...97 ANNEX ANNEX PROJECT IMPACTS COMMUNITY HEALTH, SAFETY & SECURITY PLAN INTRODUCTION OBJECTIVES SCOPE REGULATORY REQUIREMENTS POTENTIAL IMPACTS COMMUNITY HEALTH & SAFETY PROCEDURES TRAINING ROLES & RESPONSIBILITIES MONITORING & REPORTING Scial Management Plans [18/02/2010] Page 3 f 111

4 Bisha Mining Share Cmpany 1 Cultural Heritage Management Plan 1.1 Intrductin The Cultural Heritage Management Plan is designed t ensure that the Bisha Prject has minimal impact n the cultural resurces f the prject area, thrugh the implementatin f effective mitigatin and mnitring measures thrugh cnstructin, peratin and clsure. The plan cntains the methds t map, dcument and excavate knwn cultural resurces including the prcedures fr dealing with Chance Finds. Cultural heritage encmpasses a wide range f resurces, including archaelgical depsits and remains, histrical mnuments, sites and buildings, histrical and culturally-significant landscapes, places f wrship, cemeteries and graveyards, places assciated with lcal flklre, mythlgy and traditins and the lcatin f histrical and cultural festivals, events and rituals. A large number f archaelgical sites were identified during the three field surveys cnducted fr the Bisha Prject, and can be summarised as fllws: Evidence was cllected in the prject area and surrunds pertaining t a number f burial sites; ral traditins indicate that burial sites change frequently and that the Bisha cmmunities were still burying their dead near the ld Bisha village (up t 2006); Sme f the tmbs/burial sites recrded during the mst recent survey may date as early as the Italian, Turkish r even the pre-clnial perids; Ethngraphic inquiries indicated that the area seems t have been ccupied befre the Turkish clnial perid, which began in 1557 and ral traditins alluded t a lng and unstudied histry that included scial, cultural, and ecnmic transfrmatins; Ceramics were identified in all field surveys cnducted, and they displayed varius features indicating bth recent and ancient frmatin (the art f pttery making was reprtedly still cntinuing, but due t widespread use f plastic and metal utensils, the use f clay-made prducts has diminished); and Lithic materials identified included grinding stnes, scrapers, blades, perfrated stnes, hammerstnes, pestles, stne axes, mrtars, plished stnes, cres, flakes and debitages. The Natinal Museum f Eritrea cncluded that the different cultural features bserved in the Bisha regin have chrnlgical variability. Sme f them appear t be ancient, while thers are identified as being recent. Obsidian, quartz and flaked tls and the varius ceramics decrated with unique decratin types that were bserved n sme f the sites, may pint twards the ancient settlement f the regin. Sme circular tmbs are als reprted t be ancient. 1.2 Objectives The bjectives f this Management Plan are t: Establish effective plans and prcedures fr managing archaelgical sites and cultural assets in the Bisha area, including ptential Chance Finds during cnstructin and peratins activities; Define BMSC requirements and prcedures t guide the Prject Management Team and ther Prject cntractrs; Define rles and respnsibilities; and Define mnitring and reprting prcedures. 1.3 Scpe This plan describes the management f cultural resurces assciated with all phases f the Bisha Prject, with a fcus n cnstructin when the mst disturbances are likely t ccur. The plan cnsiders ptentially adverse impacts related t: Scial Management Plans [18/02/2010] Page 4 f 111

5 Site preparatin and infrastructure; The cnstructin f water retentin features and diversin channels; Waste rck strage and waste management; Tpsil strage and replacement; Increased human presence; Mining and quarrying; and Site rehabilitatin and reclamatin. Bisha Mining Share Cmpany The plan is a flexible dcument that shall be reviewed n a regular basis. This plan applies t BMSC as well as t EPCM Cntractr persnnel. The EPCM Cntractr, SENET, shall make sure that this plan is available t their wn staff and subcntractrs and that all prcedures/actins included within the plan are recgnised, adpted and applied by them prir t cmmencing cnstructin wrks. 1.4 Regulatry Requirements Crprate Plicy BMSC has established a plicy regarding Scial Respnsibility that includes the Cmpany s cmmitment t prtecting cultural resurces, and sets ut the gals that frm the basis fr all cultural heritage prtectin activities cnducted by the Cmpany Eritrean Requirements The primary Eritrean legislatin fr dealing with archaelgical sites is the Material Cultural Heritage Prtectin and Cnservatin Prclamatin (2007), Article 24 Creatin f Prtected Sites is mst relevant t the Prject. Other legal tls fr dealing with cultural heritage prtectin in Eritrea are the Prclamatin t Prmte the Develpment f Mineral Resurces N. 68 (1995) and Legal Ntice N. 19/1995 Regulatins n Mining Operatins (the Regulatins) Internatinal Finance Crpratin Guidelines Internatinal Finance Crpratin (IFC) Perfrmance Standards fr Scial and Envirnmental Sustainability set ut a range f recmmendatins with regard t cultural heritage (Perfrmance Standard #8) 1. BMSC will cmply with Eritrean legal requirements in the first place in additin t the requirements f IFC Perfrmance Standard 8 that are relevant t the Bisha prject Other Relevant Guidelines Other relevant guidelines include thse f the Internatinal Cmmissin n Mnuments and Sites (ICOMOS), and the United Natins Educatinal, Scientific, and Cultural Organizatin (UNESCO). Eritrea ratified "The Cnventin Cncerning the Prtectin f the Wrld Cultural and Natural Heritage" (The Wrld Heritage Cnventin) n Octber 24, The signatries t this Cnventin have agreed "t ensure that effective and active measures are taken fr the prtectin, cnservatin and presentatin f the cultural and natural heritage" n their territries. 1.5 Ptential Impacts Cultural heritage impacts will ccur predminantly in the cnstructin phase, because land clearance and ther intrusive activities are required t prepare the site and build prject facilities. Althugh cnstructin will be phased, it is understd that the maximum extent f the facility ftprint wuld be determined in the first year. As a result, the prject ftprint was cleared f archaelgical/cultural sites prir t intrusive cnstructin wrks (in August 2008) (see Sectin 1.9). This wrk invlved further field investigatin f knwn sites, and excavatin and retrieval activities t relcate and prtect artefacts frm destructin as a result f Prject activities. Since 2008, further surveys have been cnducted f the Tailings Management Facility (TMF) ftprint, the suthern tpsil strage area and the prpsed suthern waste dump. 1 Internatinal Finance Crpratin. Perfrmance Standards fr Scial and Envirnmental Sustainability; Perfrmance Standard #2. 30 April pp Scial Management Plans [18/02/2010] Page 5 f 111

6 Bisha Mining Share Cmpany Each phase f Prject implementatin presents different ptential risks t cultural heritage/archaelgical sites, and these are summarised fr the cnstructin, peratins and clsure/pst clsure phases Cnstructin Phase Extensive excavatin will arise during the Prject as a result f pen pit mining, in the Main Bisha Pit and Waste Rck Facility (WRF) areas. The pit and WRF areas have already been cleared as part f the pre-cnstructin archaelgical field wrk cnducted in June 2008 and Spring As such, further disturbance/destructin f knwn archaelgical sites is nt expected. Issues arising during cnstructin shuld be limited t the discvery f Chance Finds/new sites as the majrity f the prject area has nw been subject t survey Operatins Phase The cncept f pst cnstructin excavatin shuld nt arise during rutine peratins utside the pit area. If sites are threatened by the peratins, either directly r indirectly, they will be surveyed prir t disturbance, if impacts cannt be avided by ther mitigatin measures. If the sites are nt threatened, then the principle f preservatin in situ wherever pssible, which is upheld in all relevant legislatin, n bth a natinal and internatinal level, wuld indicate that n further excavatin shuld take place Clsure Phase The clsure phase is nt expected t invlve additinal impacts t archaelgical/cultural sites as disturbance f new areas shuld nt be required. Hwever, there will be reclamatin activities that may require cnsideratin f the ptential fr chance finds/new discveries f archaelgical/cultural sites. 1.6 Rles & Respnsibilities Overall respnsibility fr the implementatin f this Management Plan shall rest with the Bisha Envirnment Manager. Others with respnsibility fr the implementatin f this Management Plan shall include: SENET, as EPCM Cntractr, shall be respnsible fr the integratin f these prcedures and requirements int their perating prcedures and plans; The Envirnment Manager and his/her team shall be respnsible fr mnitring activities at lcatins deemed t require special attentin in terms f cultural heritage/archaelgical management; and Bisha Mine Manager shall be respnsible fr ensuring that these prcedures and requirements are implemented fr all mine peratin. 1.7 Apprach t Cultural Heritage Management The main bjective f the verall apprach t archaelgical/cultural heritage is t ensure that cultural heritage issues are managed cnsistently acrss all activities related t the Bisha prject. The Cultural Heritage Management Plan therefre includes prvisin fr the fllwing general activities: Site specific prtectin/retrieval plans will be develped fr each knwn site ptentially impacted by prject activities. Subsurface evaluative testing will be cnducted at ptentially threatened sites prir t cnstructin activities t determine if buried cultural depsits are present; All testing and cllectin will be dne under an apprved plan and cnducted by experienced archaelgists/wrk teams recgnised by the Natinal Museum f Eritrea; Scientific and cultural analysis and interpretatin f the archaelgical data cllected during mitigatin is an integral part f the prcess and will be undertaken in a timely fashin; BMSC will wrk with bth archaelgists familiar with the area and lcal cmmunities n issues related t site interpretatin f cultural resurces; Scial Management Plans [18/02/2010] Page 6 f 111

7 Bisha Mining Share Cmpany The Envirnment Manager will be emplyed t mnitr activities at lcatins deemed t require special attentin in terms f cultural heritage/archaelgical management; The Envirnment Manager mnitr will versee any rutine mine peratins that require additinal subsurface activities that may uncver new artefacts; and Clse cnsultatin with the Natinal Museum will be maintained regarding specific assessment fr each archaelgical site t ensure it is prtected adequately. 1.8 Identified Archaelgical Sites A number f sites were identified during the 2006 effects assessment that required further archaelgical field evaluatin and then subsequent excavatin and/r prtectin prir t cnstructin activities. Figure 1 shws the lcatin f the archaelgical sites within the prject area as well as the wider area f influence. Cmprehensive details f each f the archaelgical sites that were identified in the Prject area are available in the Scial and Envirnmental Impact Assessment, Bisha Prject, December 2006 and the SEIA Update Reprt Figure 1 Lcatin f Archaelgical Sites within the Bisha Prject Area 1.9 Cultural Heritage Activities Cnducted (and Planned) Clearance Wrk Cnducted t Date In early 2008 further field investigatins and analysis f knwn archaelgical sites were cnducted by the Natinal Museum and a number f burial sites and sme ceramic and lithic materials were cnfirmed t be at risk in the ftprint area. As a result, BMSC tgether with the Natinal Museum, lcal administratrs and lcal cmmunities, devised a plan fr the excavatin and relcatin f remains and artefacts, prir t the start f scheduled cnstructin activities in mid The clearance activities cnducted included: Scial Management Plans [18/02/2010] Page 7 f 111

8 Bisha Mining Share Cmpany Archaelgical field wrk was undertaken by a team f Natinal Museum archaelgists fllwing cnsultatin between BMSC, the Museum, lcal Administratin and representatives f affected cmmunities: The Natinal Museum cnducted the prfessinal wrk required t clear the site and prtect artefacts, which included the excavatin, retrieval, dcumentatin and strage f artefacts and cultural assets; Six lcal high schl field assistants were hired and trained n sme basic aspects f excavatin, retrieval, dcumentatin and strage f artefacts and cultural assets t supprt Museum staff (fr apprximately 10 weeks); Stne, pttery and lithic materials/artefacts were relcated frm the prject area during this field wrk, in rder t avid damage t them frm earthwrks and ther cnstructin activities; and The Natinal Museum prepared dcumentatin fr the archaelgical field wrk that was undertaken at the site. A lcal cmmittee was established t crdinate the relcatin f graves ut f the tailings ftprint and included members f the cmmunity f Mgraib: Extensive cnsultatin was cnducted with Mgraib residents t design and plan fr the grave mve wrks t ensure that it was fully supprted by affected residents and carried ut in the mst culturally sensitive manner; The grave mve relcatin began n June 10, 2008 and lasted 5 days and a ttal f 122 peple frm the cmmunities f Mgraib participated in the excavatin and relcatin f graves; A further 15 BMSC emplyees helped with the wrk t relcate graves; A ttal f 608 graves were relcated t 42 newly created grave hles established nearby t the village f Mgraib (a site identified in cnsultatin with cmmunity members and administratrs); BMSC prvided all technical supprt and equipment required t cmplete the field wrk, including transprtatin fr village members, and the prvisin f trucks, bxes, digging equipment, water and fd; and A Grave Mve Reprt was prepared by BMSC (in Tigringa) and the findings are incrprated int this plan. All materials ther than skeletal remains that were re-buried, were excavated, examined and recrded; Artefacts classified as f natinal significance were taken t Asmara t the Natinal Museum fr presentatin and thse classified as f lcal/reginal significance were stred in a secure lcatin at the Bisha camp; and Lcal peple expressed a desire t establish a lcal museum t huse the lcally significant artefacts, and BMSC has cmmitted t fund the lcal museum in Mgraib t huse the existing artefacts and any future discveries in the nearby area. Terms f Reference and an implementatin plan fr the Mgraib Museum will be drawn up by BMSC under the Cmmunity Assistance Plan (CAP). In additin t establishing a lcal museum, BMSC and the Mgraib village agreed that the Cmpany wuld pay the 122 peple wh participated in the grave mve fr each f the 5 days they wrked. Disbursement fr archaelgical assistance has nw been made in full by BMSC Wrk Planned Recent wrk art Bisha has included in the archaelgical investigatin f the TMF ftprint and suthern tpsil strage areas. Further wrks are planned t survey the ftprint f the water diversin area. Scial Management Plans [18/02/2010] Page 8 f 111

9 Bisha Mining Share Cmpany 1.10 Cultural Heritage Management Prcedures The Bisha Prject has develped a range f cultural heritage management prcedures t ensure that unanticipated discveries f archaelgical sites are mapped, dcumented and prtected as much as pssible during cnstructin, peratins and clsure activities Preparing Archaelgical Wrk Specificatins Future archaelgical wrk t be undertaken fr the Bisha Prject shall be preceded by the preparatin f a wrk specificatin that utlines what wrk will be undertaken. The fllwing prcedures shall be fllwed: An Archaelgical Wrk Specificatin Frm (see Frms belw) shall be used by each archaelgist/wrk team; Each individual specificatin shall be submitted fr apprval by the Bisha Envirnment Manager prir t the cmmencement f each archaelgical mitigatin measure; The specificatin will be presented sufficiently in advance f archaelgical mitigatin cmmencing t allw time fr amendments t be made if required; Archaelgical wrk specificatins shall be develped in cperatin with cnstructin teams that may be impacted by their implementatin; and BMSC will keep SENET infrmed f cultural heritage wrk that will be cnducted fr the Prject Chance Finds Prcedure Mineral wrkings have the ptential t impact archaelgical resurces directly thrugh land clearance and the disturbance f abve r belw-grund sites and indirectly, thrugh grund vibratin, the depsitin f airbrne dust, traffic mvements and waste dispsal. This prcedure prvides guidance t BMSC emplyees and cntractrs n hw t deal with chance finds arising thrugh the fllwing: Land clearance and tpsil stripping activities; Excavatin activities; Cnstructin f bridges and stream crssings; Well cnstructin; Basement, fundatin and cncrete husing/hdpe liner cnstructin; and Preparatin and cnstructin f prject access rads. Fr land clearance activities, the fllwing prcedures shuld be adpted: All persnnel invlved in land clearance and excavatin shuld take respnsibility fr managing archaelgical prtectin, and shuld be trained in these aspects; Shuld any archaelgical artefacts (relics, bricks, bnes, ceramics, graves etc) be encuntered, activities shuld halt immediately and the site shuld be islated and clearly marked; BMSC emplyees shuld respect the cultural and scial significance f any such finds during the life f mine and shuld be strictly prhibited frm interfering with r disturbing any such depsits; The Bisha Envirnment Manager shuld be infrmed immediately; The Bisha Envirnment Manager shuld liaise with the relevant ministry t determine the need fr further investigatin/apprpriate actin; and Any subsequent investigatin r excavatin wrks shuld be cnducted by a suitably-qualified archaelgist. Scial Management Plans [18/02/2010] Page 9 f 111

10 Bisha Mining Share Cmpany Shuld archaelgical depsits be identified r suspected, further detailed excavatin wrks shuld be undertaken (under the guidance f the relevant natinal and reginal authrities) as fllws: All necessary permits and licenses fr archaelgical investigatin shuld be btained; Any archaelgical finds shuld be discussed with the lcal cmmunity t establish lcal significance (even in the absence f legal prtectin status); Tpgraphic mapping shuld be carried ut, t identify the likely spatial extent f depsits; The exact area fr excavatin shuld then be selected accrding t the density and physical distributin f archaelgical material; Trial pits shuld be dug by hand excavatin at the cnventinal 5cm levels t register archaelgical elements tgether with the physical characteristics f the strata; The excavatin prcess and the different archaelgical material (ceramics, stnes, charcal, seeds, bnes, etc.) shuld be registered in detail using phtgraphs and field diaries; Any material fund in the pits shuld be treated (washed and tagged) and later classified in accrdance with accepted criteria; Samples f material shuld be sent t specialised labratries fr carbn-dating (e.g. using the C14 methd), tgether with samples f rganic remains and sil, which shuld be analysed fr the identificatin f pllen; An analysis f the spatial distributin f the material recvered at each f the levels surveyed shuld be carried ut Archaelgical Excavatin/Retrieval If archaelgical excavatin r retrieval prcesses are required fr chance finds/new discveries f cultural sites within the prject area the fllwing additinal prcedures shuld be fllwed: An archaelgical wrk specificatin (see Frms belw) fr the item t be retrieved and relcated must be cmpleted; All staff must be suitably qualified and experienced fr their rles within the wrk specificatin; Excavatin/retrieval and relcatin wrks shuld be mnitred by representatives f the lcal cmmunites/traditinal wners f the area and at least ne archaelgist (e.g. the archaelgy/cultural resurces mnitr); Cnsideratin shuld be given t supplementing excavatin wrk with nn-destructive means f investigatin, e.g. gephysical survey, remte sensing, gechemical survey, field scanning; Immediately after the retrieval and relcatin wrks have been cmpleted the relcated items will be recrded as new sites within the Cultural Heritage Data Base; Full and prper recrds (written, graphic, electrnic and phtgraphic as apprpriate) will be made fr all wrk, using pr frma recrds and sheets apprpriate t the wrk; The recrding system used will be ne that is apprpriate t the requirements f the prject, and will be agreed with relevant parties including the bdy that is t receive the archive; The recrding system and data standards will be cmpatible with thse f all ther fieldwrk related t archaelgical mitigatin fr the Bisha prject; and Fllwing cmpletin f the n-site excavatin a pst-excavatin assessment reprt shuld be prduced. Unless ther arrangements are made with lcal cmmunities and authrities, BMSC expects t stre any additinal artefacts r materials retreived frm the prject area, at a dedicated lcal Museum t be established in Mgraib. Scial Management Plans [18/02/2010] Page 10 f 111

11 Recrding Sites which Cannt be Relcated Bisha Mining Share Cmpany Sme items (e.g. ethngraphic stne pits) cannt be salvaged and relcated. Prcedures fr recrding sites which cannt be relcated will invlve the fllwing: Upn cnsultatin and mutual agreement with all relevant parties (e.g. lcal cmmunities, authrities and the Natinal Museum), these items will be destryed in situ; Prir t destructin the items will be recrded t dcument the physical extent f the item and the physical envirnment in which the item is lcated; and Phtgraphs shall als be taken, including a cntext phtgraph Cultural Heritage Data and Dcumentatin Cultural Heritage Recrds System The Envirnment Department is respnsible fr maintaining a recrd f archaelgical sites and related activities. Recrds will cntain infrmatin n cultural heritage/archaelgical sites, materials and items within the prject area, activities cnducted t manage knwn sites, as well as Chance Finds. Such data will likely include: Archaelgical sites and the status f their prtectin/retrieval/relcatin; Details f watching briefs /mnitring cnducted; Results f field evaluatins, excavatins and relcatins cnducted; Identificatin and evaluatin f unexpected/chance finds; Cnsultatin with lcal cmmunities and the Natinal Museum; Cmplaints and actins taken; and Cnditin and peratin f demarcatin and prtectin measures. The Natinal Museum is respnsible fr maintaining detailed archaelgical recrds fr specific artefacts discvered and activities undertaken by museum archaelgists/staff Frms The Envirnment Department will maintain an inventry f all archaelgical mnitring activities and cultural heritage management dcumentatin arising n site. SENET will be required t ensure a similar prcess is fllwed fr cnstructin activities. A selectin f example frms is prvided belw. Scial Management Plans [18/02/2010] Page 11 f 111

12 Bisha Mining Share Cmpany Fr all archaelgical wrks t be undertaken as part f the Bisha Prject, an Archaelgical Wrk Specificatin Frm shuld be cmpleted. An example f an Archaelgical Wrk Specificatin Frm is as fllws: Example Wrk Specificatin Frm ARCHAEOLOGICAL WORK SPECIFICATION FORM SITE NAME: Permit Number (if applicable) Sectr Number/Lcatin Identificatin Item/Site Number Item/Site Crdinates General and Specific Aims f the Fieldwrk Site Type Gegraphical and Tpgraphical Backgrund Archaelgical and Histrical Backgrund Detailed Site/Item Descriptin Metres Belw Grund Level Summary f Relevant Legislatin Recmmended Salvage Prcess/Field Methdlgy Salvage/Retrieval Ranking Cllectin and Dispsal Strategy fr Artefacts/Ecfacts Access Cnditin Occupatinal Health & Safety Risk and Requirements Degree f Difficulty Cntingency Prcedures Staffing Timetable (extent & duratin f the archaelgical wrk) Site Plan/Map Attached Reprting/Publicatin/Archive Arrangements COMMENTS AND REQUIRED ACTIONS Scial Management Plans [18/02/2010] Page 12 f 111

13 Bisha Mining Share Cmpany 1.12 Mnitring & Reprting Cultural heritage mnitring prcedures shall be as fllws: SENET shall reprt n a mnthly basis t the Bisha Envirnment Manager n the implementatin f this Management Plan during the cnstructin phase, including: Watching briefs they participate in at specific areas/cnstructin sites; The erectin and maintenance f demarcatin fencing arund sites; The prtectin f sites by careful siting f access rutes r facilities; Inductin training including cultural heritage awareness given t staff and planned; Cultural heritage-related cmplaints and actins taken; and Cases f damage t, r disruptin f, cultural heritage prperties and actins taken. Bisha Envirnment Manager will cnduct rutine inspectins f site activities in cnsultatin with the Cnstructin Manager and Mine Manager t assess the ptential fr chance finds at wrk sites and any ther cultural heritage issues that may arise. Bisha Envirnment Manager will cnduct an inspectin f any cultural heritage field activities and dcumentatin that are implemented as a result f a chance find r ther event that results in archaelgical field wrk. The inspectin shall include: Details f all wrk specificatins prepared and implemented; Mnitring/ watching briefs cnducted at specific cnstructin and ther sites; Cnsultatin with lcal cmmunities related t cultural resurces; Cmmunicatin and cperatin with SENET and the Natinal Museum; Hw the Cultural Heritage Database is being maintained; Infrmatin disseminatin regarding cultural heritage; Perfrmance f SENET in managing cultural resurces at specific cnstructin sites; Cultural heritage-related cmplaints and actins taken; and Cases f damage t, r disruptin f, cultural heritage prperties and actins taken. The Bisha Envirnment Manager shall be respnsible fr recrd-keeping. Regular reprting shall be undertaken via the mnthly SEMS Reprt that shall be prepared and submitted t the Bisha General Manager. Reprting shall include: A summary f activities undertaken during the reprting perid; Any material deviatins r nn-cmpliances t this Management Plan; Planned activities during the next reprting perid; Any ther issues f cncern. Further infrmatin n scial mnitring and reprting requirements and prcedures is set ut in the Mnitring Plan and in the Scial & Envirnmental Management System. Scial Management Plans [18/02/2010] Page 13 f 111

14 Bisha Mining Share Cmpany 2 Stakehlder Engagement Plan 2.1 Intrductin The Stakehlder Engagement Plan (SEP) is designed t ensure effective engagement with lcal cmmunities, gvernment and key relevant stakehlders during the cnstructin and peratin f the Bisha mining Prject. The plan cntains the methds and recmmendatins fr nging engagement with lcal cmmunities, gvernment authrities and particularly thse respnsible fr permitting the Prject, as well as ther stakehlders that may be affected by r interested in the Prject. BMSC is cmmitted t a technically and culturally apprpriate apprach t cnsultatin and disclsure. Since the beginning f Prject activities in 2004, the gal has been t ensure that adequate infrmatin is prvided t Prject-affected peple in a timely manner whilst aiming nt t unduly raise lcal expectatins. The engagement prcess adpted fr the Prject cmprises three cnsecutive phases: First Phase: Planning and Scping the SEIA Prcess; Secnd Phase: Prject Assessment Stage (including the SEIA reprt preparatin); and Third Phase: Engagement during Cnstructin and int Operatins. Between 2004 and late 2006, cnsultatin and disclsure activities were cnducted arund the varius feasibility studies being undertaken and als the submissin f the draft SEIA dcumentatin t the relevant authrities (Phases 1 and 2). Nw the Prject is mving int cnstructin activities, engagement is fcused n Phase 3, including keeping authrities and cmmunities infrmed abut prgress during cnstructin wrks and helping lcal peple and ther Eritreans t access emplyment, business and cmmunity assistance pprtunities that will arise frm the Prject. 2.2 Stakehlder Engagement Principles Maintaining the gd relatinships that the BMSC has established with stakehlders, particularly the cmmunities f Mgraib, Ad Ibrihim, Tekreret, Jimel, and Adarat, is the verall gal f the SEP. During cnstructin and peratins, the Prject plans t build n the experience gained thrugh early public cnsultatin. T this end, BMSC will: Ensure that stakehlder engagement fcuses n the envirnmental and scial issues that are likely t affect lcal cmmunities; Prvide regular infrmatin abut cnstructin and peratins activities in a pr-active and timely manner; Ensure the nging disclsure f Prject infrmatin in a culturally apprpriate way that is cmmensurate with the level f educatin/literacy f the target audience; Develp key messages n lcal emplyment and training, lcal business develpment, agriculture supprt prgrammes, influx related issues, envirnmental mnitring and cmmunity health and safety awareness; Achieve successful negtiatins and participatin related t land changes and ther ecnmic displacement issues; Identify new issues, cncerns r needs f affected cmmunities including reslutin f cmmunity cmplaints in an expedited manner; Cntinue t build lng-term relatinships within the key stakehlders near the mine site as well as thse relevant stakehlders alng the transprt rute and at the prt; Assess the effectiveness f envirnmental and scial mitigatin measures by using mnitring in cmmunities and direct feedback, e.g. related t nise and dust; and Maximise Prject benefits such as emplyment and prcurement pprtunities thrugh effective engagement with lcal cmmunities and the wider Zba Gash Barka. Scial Management Plans [18/02/2010] Page 14 f 111

15 2.3 Specific Objectives Bisha Mining Share Cmpany The specific bjectives f this Management Plan are t: Establish effective plans and prcedures fr engagement with lcal/natinal stakehlders fr Prject cnstructin, peratin and clsure; Define BMSC requirements and prcedures t guide the Prject Management Team and ther Prject cntractrs; Define rles and respnsibilities; and Define mnitring and reprting prcedures. 2.4 Spatial Scpe Study Area and Scial Zne f Influence The Prject zne f scial influence includes the area f direct influence (i.e. mine site and surrunds) as well as the indirect scial zne f influence resulting frm implementatin f all phases f the Prject. The indirect area includes the transprt rute frm Bisha and the prt facilities at Massawa. It is expected that the Prject s indirect zne f scial influence will als extend beynd this, particularly in terms f taxes paid at the natinal level, direct and indirect labur, and because f anticipated inmigratin t the Gash Barka regin as a whle Bisha Mine Area The Bisha mine area is lcated in the western lwlands f Eritrea and can be described as fllws: The Prject is lcated in Zba Gash Barka, and the depsit itself is in Dighe sub-zba; Barentu (est. pp. 18,568) is the centre f Zba Gash Barka (apprx. 110 km frm Bisha), while Agrdat (est. pp. 14,770) is the sub-zba centre and the nearest twn t Bisha (apprx. 50 km); Mst lcal residents belng t the Tigre natinality and Tigre is the mst cmmn language; The lcal ppulatin has little t n mineral explratin r mining knwledge r experience; The majrity f lcal residents are Muslim (reprted t be ver 95%) althugh there are reprted t be a small number f Christians within the Bisha regin; and During the mid-1990 s smaller cmmunities within Gash Barka were cnslidated int larger resettlement centres and tw f these resettlements were frm the nw Bisha area (the Bisha cmmunity were mved t Ad Ibrihim, and the Harenay cmmunity t Adarat). Of the six villages in the study area, all except Takawda 2 have been classified as Prject affected villages fr the Bisha develpment. The direct scial zne f influence can therefre be described as: The five nearby villages that are all within 4 t 35 km frm the site (sme f which are n the direct transprt rute t and frm the mine): Mgraib; Jimel; Ad Ibrihim; Adarat; and Tekreret. The village f Mgraib is the ptentially mst affected village in the area since it is nly 4 km frm the mine; and Mgraib is als expected t be the village where sme infrastructure and services can be established r expanded ver the life f the Prject t directly supprt mine activities. 2 Takawda is nt n the transprt rute t and frm the Bisha site and is ver 50 kilmetres away frm the area. Scial Management Plans [18/02/2010] Page 15 f 111

16 Bisha Mining Share Cmpany Figure 1 shws the five ptentially affected villages. The ratinale fr identifying and selecting the five nearby villages as the Prject affected ppulatin is as fllws: Tekreret is 28 km frm the Bisha Prject and is the first village alng the main rad (heading west) after Agrdat. This village will experience higher traffic levels and be a ptential surce f labur; Ad Ibrihim is 16 km frm the Bisha Prject and is n the same majr rad as Tekreret. The cmmunity includes the village f Bisha, whse members were resettled frm the Bisha Prject area as part f Eritrea s resettlement initiative in the mid s. Bisha residents still use the Prject area fr farming and grazing their herds; Mgraib (frmally the administrative village f Mgraib) is 4 km away frm the current explratin camp and 6 km frm the Prject site. It may be the main surce f labur as well as a centre fr key services. It is als n the main rad but is lcated past the Prject site turn ff; Adarat is 20 km frm the current Bisha camp. The cmmunity includes the village f Harenay, whse residents have traditinally used the suthern part f BMSC s cncessin. Based n their histric lcatin, BMSC recgnises that land use by the cmmunity extends int the Bisha Prject area. It is nt lcated n the main rad and access t the cmmunity is pr, hwever, it culd als be a surce f labur; and Jimel is lcated 27 km away frm the Bisha camp, n the main rad and well past the Bisha Prject turn-ff. This cmmunity is included in the affected villages because there are plans t mve the cmmunity clser t Mgraib (in the west). Agrdat is the nearest twn in the regin and is currently n the transprt rute and thus cnsidered in the indirect zne f influence. The reginal centre f Barentu is als cnsidered t be in the indirect zne f influence since it is the capital city f Gash Barka and is likely t be a surce f labur and supplies fr the Prject Massawa Prt Site A cement plant, wned by the Eritrean gvernment and lcated near the prt f Massawa is the mst likely lcatin fr transprtatin f cncentrate. The prpsed prt site can be described as fllws: Massawa is in Zba Semenawi Keih Bahri in Eastern Eritrea n the Red Sea; The city and prt f Massawa are lcated apprximately 115 km sutheast f Asmara, and apprximately 347 km frm the Bisha mine site; Massawa is a city with a ppulatin f 15,441 that is fcused n cmmercial trade at the prt as well as turism, since it is the launching place fr the Dahlak Islands; and Massawa and its envirns have been designated a Free Trade Zne by the Eritrean Gvernment Transprt Rute The preferred transprt rute between Bisha and Asmara and Asmara and Massawa has been chsen due t better rad surface cnditins. Nevertheless, sme villages and twns alng the rute are likely t be affected indirectly by Prject-related traffic. This is expected t be assciated predminantly with the cpper prductin phase when cncentrate will be transprted daily t prt. Rad haulage will reach a peak during years 5 t 10 f the Prject. Further investigatins will be required t identify ptential stakehlders assciated with the transprt rute nce arrangements are cnfirmed. There are likely t be a number f villages and twns alng the transprt rute that will need t be engaged prir t prductin. Scial Management Plans [18/02/2010] Page 16 f 111

17 Bisha Mining Share Cmpany Figure 1 Prject Affected Villages 2.5 Regulatry Requirements Crprate Plicy BMSC has established a plicy regarding Scial Respnsibility that includes the Cmpany s cmmitment t cnsult with gvernment and lcal cmmunities n issues that affect them, and sets ut the gals that frm the basis fr all engagement activities cnducted by the Cmpany Eritrean Requirements The Natinal Envirnmental Assessment Prcedures & Guidelines (NEAPG) intrduced in 1999, state that a public cnsultatin prcess shuld be included fr any develpment where lcal cmmunities r ther stakehlders are interested r affected by the prject. Scial Management Plans [18/02/2010] Page 17 f 111

18 2.5.3 Internatinal Finance Crpratin Guidelines Bisha Mining Share Cmpany Internatinal Finance Crpratin (IFC) Perfrmance Standards fr Scial and Envirnmental Sustainability set ut a range f recmmendatins with regard t stakehlder engagement BMSC will cmply with requirements f IFC Perfrmance Standard 1 (30 April pp 7-10.). The guidance dcument that is mst relevant t engagement related t the Bisha Prject is Stakehlder Engagement: A Gd Practice Handbk fr Cmpanies ding Business in Emerging Markets (2007). 2.6 Budget The SEP can nly be effectively implemented if adequate resurces are in place fr the Prject. T this end, BMSC will: Develp a budget fr stakehlder engagement activities fr the cnstructin phase and estimate an annual budget until peratins; Review the indicative budget fr stakehlder engagement after a reasnable perid int cnstructin activities (e.g. by end 2009) t ensure it remains valid; and Ensure that budgets prpsed fr stakehlder engagement are adequate t implement the SEP and that they are apprved and in place fr early enugh t cnduct each year s activities. 2.7 Apprach t Stakehlder Engagement Previus Cnsultatin Dcuments The SEP has been prepared with cnsideratin f fur dcuments related t cnsultatin and disclsure that were prduced and released fr the Bisha Prject, namely: A Public Cnsultatin and Disclsure Plan (February 2006); An Addendum t Public Cnsultatin Tls and Schedule (March 2006); An Interim Public Cnsultatin Reprt (July 2006); and Chapter 5 Stakehlder Engagement Prgramme, SEIA dcument (December 2006) Overall Apprach The range f ptential levels f engagement fr a prject can be categrised by the degree f active invlvement f the cmmunity (r ther stakehlders). This range is shwn in Figure 2. These successive phases f engagement and infrmatin disclsure are designed t prvide fr increasing invlvement f stakehlders in the develpment f the prject. Figure 2 Stakehlder Engagement Ladder Level f Relatinship Engagement with the 10% uncnditinal advcates r the 10% Hardcre adversaries will tend t be in these steps f the ladder. Engagement with the 80% middle grund stakehlders will tend t be in these parts f the ladder. Participatin Cnsensus Empwerment Cnsultatin Adhc slutins Infrm N Cntact Time and Resurces Scial Management Plans [18/02/2010] Page 18 f 111

19 Bisha Mining Share Cmpany During the early stages f the Bisha Prject the level f engagement with the lcal cmmunities was at the Infrm level (Phase 1). Cmmunity leadership was infrmed f the Prject activities and there were several meetings t start discussins regarding the cmmencement f baseline studies necessary fr input t the SEIA prcess. Frm February t December 2006, the level f engagement increased cnsiderably and mved int a cnsultatin apprach with sme participatin in decisin-making by cmmunities themselves, e.g. n issues such as training and emplyment pprtunities (Phase 2). As the Prject advances with cnstructin the aim f further engagement (Phase 3) is t rapidly increase t a participatin and cnsensus apprach. The aim f this level f engagement is t ensure that cmmunities feel that their cncerns are being taken int accunt and implemented n the grund. It shuld als help build capacity and bring lcal cmmunities t a level f higher participatin and empwerment, s that they can make decisins arund issues that affect them, and in particular, mre readily access benefits frm the Prject. Table 1 Summary f Cnsultatin Activities Descriptin Key Engagement Activities Key Dates 1. PLANNING AND SCOPING THE SEIA Cnceptual design and scping cnsultatins, stakehlder identificatin and limited infrmatin disclsure abut explratin. Stakehlder identificatin Cmmunity and husehld surveys Fcus grup discussins Cnsultatin with gvernment agencies Rund tables with gvernment fficials COMPLETED Pre PROJECT ASSESSMENT STAGE Preparing the Feasibility Study including the SEIA submissin t Eritrean authrities. Engagement during land clearing exercises and planning fr full cnstructin activities. Cnsultatin and negtiatins during land acquisitin activities SEIA preparatin and cnsultatin with Eritrean authrities Disclsure and disseminatin f the SEIA dcuments Submissin f SEIA dcuments and review with Eritrean authrities Infrmatin n Prject design and prgress Maintaining Cmmunity Liaisn Officers and Stre Frnt Infrmatin Centres COMPLETED Jan 05 Dec 06 COMPLETED Jan 07 Dec CONSTRUCTION, OPERATIONS AND CLOSURE Cnstructin Regular cnstructin updates fr lcal villages Building cmmunity awareness f cnstructin impacts and preparing lcal cmmunities fr peratins. Onging engagement and cmmunity relatins, thrughut peratins and int clsure. Cmmunity-driven engagement, e.g. cmmunity newsletter Disclsure f printed materials (varius tpics) Awareness raising fr cmmunities t help them deal with mine impacts Addressing cmmunity cmplaints Operatins and Clsure Maintaining prven methds f engagement Early engagement n rehabilitatin/reclamatin Sustainable lcal develpment planning fr ONGOING FUTURE 2011 Scial Management Plans [18/02/2010] Page 19 f 111

20 Bisha Mining Share Cmpany Descriptin Key Engagement Activities Key Dates beynd mining. Scial Management Plans [18/02/2010] Page 20 f 111

21 Bisha Mining Share Cmpany 2.8 Prject Stakehlders Stakehlders are individuals and rganisatins wh need t be infrmed and cnsulted abut the Bisha Prject and wh have an interest in the utcme f the Prject. Stakehlders are thse wh may be directly affected by the Prject r have a significant influence ver the success f the Prject. Fr the Bisha mine they include: Peple wh live, use r have cultural ties t lands and resurces within the ftprint r zne f influence f the Prject; Peple r villages wh will be ptential emplyees r will seek emplyment frm the Prject, within Zba Gash Barka and ther parts f Eritrea; Lcal disadvantaged grups such as wmen, children r the pr; and Authrising gvernment and regulatry bdies in Eritrea as well as gvernment agencies that have jurisdictin ver resurces ptentially affected by the Prject. There are n permanent settlements within the Prject mine ftprint. Hwever, the Prject des affect seasnal dwellings, limited agricultural land, and herder activities in the Bisha area. Grazing land in the ftprint was used by members f nearby cmmunities prir t mine develpment Gvernment Authrities Natinal gvernment stakehlders include thse Ministries respnsible fr permitting, apprvals and mnitring related t the Bisha Prject. Table 2 prvides the list f natinal/ministry level authrities. Table 2 Stakehlders frm the Natinal Authrities/Ministries Authrity Ministry f Energy & Mines * particularly the Department f Mines Ministry f Land, Water & Envirnment * particularly the Department f Envirnment Ministry f Agriculture Ministry f Fisheries Ministry f Health Ministry f Labur & Human Welfare Ministry f Natinal Develpment Ministry f Transprt & Cmmunicatins Ministry f Trade & Industry Ministry f Justice Ministry f Infrmatin Ministry f Public Wrks Ministry f Finance Impact Review Cmmittee Table 3 prvides the list f reginal/lcal level authrities fr the Prject. Reginal and lcal authrities include thse frm the Zba Gash Barka and the Dighe and Ggne sub-zbas, as well as lcal administratrs (village) frm the five villages nearest t the Bisha site. Authrities frm Semenawi Keih Bahri Zba, where the prt f Massawa is lcated, as well as thse alng the transprt rute will als be imprtant stakehlders. Scial Management Plans [18/02/2010] Page 21 f 111

22 Bisha Mining Share Cmpany Table 3 Stakehlders frm Reginal/Lcal Authrities Administrative Divisins Name Specific Grup/Persns Zba-level Authrities Gash Barka Zba Administratr Reginal Assembly (Bait) Reginal Administratr Branch ffices in Barentu f the Ministries f Land, Water, Envirnment, Energy & Mines, Educatin, Health and Agriculture Semenawi Keih Bahri Zba Administratr Reginal Assembly (Bait) Massawa Prt Authrity Sub-Zba Administratin Village Administratin Dighe Ggne Mgraib Tekreret Adi Ibrihim Jimel Adarat Sub-Zba and Deputy Administratrs Village and Deputy Administratrs versee lcal village activities Anebaberti-Adi, Magistrates, Village Cmmittees and Elders are ther key figures in village administratin Surce: Bisha Mining SC, Envirnmental Impact Assessment, AMEC, December Affected Ppulatin The affected ppulatin r Prject-affected persns is the segment f the ppulatin that will be directly affected by envirnmental r scial cnsequences f the Prject during its cnstructin r peratin. Fr the Bisha Prject the affected ppulatin cmprises members f the five villages lcated near the Prject site, which are shwn in Table 4, alng with key demgraphic data. Table 4 Prject Affected Villages Village Sub-Zba r Number f Est. Main Ethnic Distance frm Administrative Husehlds Pp. Grup Bisha site Regin Tekreret 1,200 5,000 Tigre, Hidarib 27 km (east) Dighe Adi Ibrihim 539 3,780 Tigre, Hidarib 17 km (east) Dighe Mgraib 870 4,016 Tigre 4 km (nrth) Dighe Jimel 400 2,000 Tigre, Hidarib 27 km (west)* Dighe Adarat 342 1,667 Tigre, Nara 16 km (suth) Ggne * Jimel is expected t be relcated 9 kilmetres clser t Mgraib site by gvernment (date unknwn). Surce: Bisha Mining SC, Envirnmental Impact Assessment, AMEC, December Affected Ppulatin fr Transprt Rute and Prt Facility BMSC will assess transprt rute and prt facility stakehlders during the SEIA t be cnducted fr Phases 2 and 3 f the Prject. At this time a further SEP will be develped Differentially Affected, Vulnerable and Marginalized Peples Based n studies cnducted fr the Bisha Prject and available research and literature, BMSC has identified the fllwing ptentially vulnerable r disadvantaged grups: Scial Management Plans [18/02/2010] Page 22 f 111

23 Bisha Mining Share Cmpany Wmen and female headed husehlds; Rural drught-affected residents and cmmunities; Elderly and infirm; and War-affected residents and refugees, including thse wh lst assets during the war. The Barentu and Dighe areas had the highest Glbal Acute Malnutritin rates within Gash Barka during the 2004 drught. The Prject area and wider regin als have a higher than average prprtin f refugees due t the effects f cnflict and prximity t internatinal brders (i.e. with Sudan). Elderly and infirm residents may als be cnsidered vulnerable grups because f their limited ability t access benefits frm the Prject, including participatin in sme emplyment and cmmunity assistance prjects. During cnstructin and peratins, BMSC intends t increase its effrts t engage wmen and ensure their full participatin. BMSC will als assess the ptential fr ther vulnerable grups and determine where special cnsideratin n certain tpics r issues may be required Civil Sciety and Other Organizatins There are few internatinal NGOs remaining in the cuntry as a result f shifts in the Gvernment f Eritrea apprach t internatinal aid. Only ne NGO, the Internatinal Fund fr Agricultural Develpment (IFAD), which is a specialised branch f the United Natins, has been active in the Bisha area in recent years. Due t Natinal leadership sensitivity abut NGOs, n frmal cnsultatin sessins have been held with IFAD, hwever, the sub-regin IFAD representative, an Eritrean Natinal, has supprted the Bisha cnsultatin prcess by acting as a facilitatr fr many f the wrkshps held with the villages. Natinal unins/quasi gvernmental rganisatins such as the Natinal Unin f Eritrean Wmen (NUEW) and the Natinal Unin f Eritrean Yuth and Students (NUEYS) are active in Zba Gash Barka and the Prject area. Members f the NUEW and NUEYS have been represented at natinal and lcal meetings and wrkshps related t the Prject since 2006 and their cntributin cntinues by the inclusin f a representative in regular cmmunity meetings held with Bisha. BMSC has als engaged with the Natinal Cnfederatin f Eritrean Wrkers, Federatin f Eritrean Emplyers, the Eritrean Chamber f Cmmerce (ECC) and the Lutheran Wrld Federatin and engagement is expected t cntinue during the Prject. Other secndary stakehlders that might be interested in r affected by the Prject include ptential investrs and relevant internatinal finance institutins (IFIs), ther mining cmpanies in Eritrea, and the interested internatinal public. 2.9 Methds and Tls fr Engagement The Bisha Prject will cntinue t use prven methds f engagement that have already been established by BMSC, such as the village-based Cmmunity Liaisn Officers (CLO) and the Stre Frnt Infrmatin Centres. A selectin f existing and prpsed methds that are likely t be emplyed by the Prject are described in the fllwing sectins Update and Briefing Sessins with Eritrean Gvernment Representatives BMSC will cntinue t hld update and briefing sessins with gvernment during cnstructin and peratin f the Prject. T this end, BMSC will: At least annually, hld update and briefing sessins with interested gvernment representatives in Asmara; Invite relevant Ministries and departments, including the Department f Mines and ther permitting agencies t these update sessins, e.g. the Department f Envirnment; Scial Management Plans [18/02/2010] Page 23 f 111

24 Bisha Mining Share Cmpany Invite the administratrs f the Zba Gash Barka and the sub-zbas f Dighe and Ggne (and as apprpriate thers alng the transprt rute and thse respnsible fr the Prt facility) t annual public update events; Use the update sessins t prvide infrmatin t gvernment n prgress and perfrmance f the Prject with respect t plans and mitigatin strategies, and the Prject schedule; and Use a range f materials and methds such as pwer pint presentatins, r site turs, as apprpriate, during the briefing sessins Infrmatin Update Cmmittee (IUC) BMSC intends t cnduct regular meetings with lcal cmmunities during cnstructin activities (and int peratins) and t this end, will cntinue t meet with the Infrmatin Update Cmmittee that has been established with lcal authrities and cmmunities. The key features f the grup are as fllws: The cmmittee cnsists f representatives frm the five key cmmunities f Mgraib, Ad Ibrihim, Tekreret, Jimel, and Adarat, the village-based Cmmunity Liaisn Officers, the Bisha Cmmunity Relatins Manager, and ther BMSC representatives as required; The cmmittee cmprises representatives frm each village, including the fllwing: (i) the village administratr r smene chsen by the administratr t represent them; (ii) a lcal wman representative f the Natinal Unin f Eritrean Wmen; and (iii) tw members elected by the cmmunity; The cmmittee is scheduled t meet each mnth and mre ften if circumstances require it during cnstructin activities (in peratins, quarterly meetings will likely be adequate); BMSC prvides transprtatin, per diem expenses (e.g. 100 Nakfa per half day) and refreshments fr all cmmittee meetings; The cmmittee will be targeted fr pprtunities t participate in educatin thrugh the Cmmunity Assistance Plan because ne f the ptential barriers t effective engagement is the high level f illiteracy and the generally lw level f educatin in the lcal cmmunities; and BMSC will mnitr prgress and perfrmance f the cmmittee Cmmunity Liaisn Officers BMSC has maintained a grup f Cmmunity Liaisn Officers (CLO) t supprt the Prject since During cnstructin and peratins, BMSC will cntinue t emply CLOs fr the Prject, at least frm the areas f: Barentu; Agrdat; Mgraib; Ad-Ibrihim; Tekreret; Jimel; and Adarat. Cmmunity Liaisn Officers are BMSC emplyees wh represent the Prject in their respective cmmunities and cnduct a range f supprt activities/duties fr BMSC, including manning the relevant Stre Frnt Infrmatin Centres. Specific issues arising, which may frm the fcus f the CLO wrk, are likely t include: Land use, land changes and cmpensatin; Scial Management Plans [18/02/2010] Page 24 f 111

25 Bisha Mining Share Cmpany Recruitment and emplyment; Water use, availability, quality and prtectin; Rad maintenance; Student/yuth issues; Induced and infrmal in-migratin; HIV/AIDS and ther cmmunicable diseases; and Wmen and vulnerable grups Public Educatin-Outreach Building n the success and effectiveness f the Rad Shws and displays in lcal cmmunities and at natinal festivals, BMSC will plan and enable cmmunity utreach and educatin events during the cnstructin and peratin f the Prject, at bth lcal and natinal levels Lcal Events BMSC, in cnsultatin with lcal cmmunities, shall hld regular lcal events during cnstructin and peratins activities, and will: Plan and implement at least bi-annual public educatin events in each f the five key cmmunities and, as needed at a particular time perid, in ther cmmunities such as Agrdat and Barentu (e.g., in cnjunctin with infrmatin n emplyment pprtunities); Invite lcal, reginal and natinal gvernment representatives t lcal utreach events; Prvide infrmatin at lcal events in an easy t understand and entertaining way in rder t update cmmunities and the wider public abut the activities and plans f the Prject; Pst relevant dcuments/printed materials at these events and prvide a venue fr feedback; Use these events where apprpriate, t cnduct cmmunity awareness raising and educatin activities, such as n imprtant tpics like health & safety assciated with the mine; Seek input int planning public events frm lcal peple and ask cmmunities abut what they wuld like t discuss with the Prject and in what frmat; Target a range f different audiences, including schl and yuth grups, and ther sectins f lcal cmmunities; and Use innvative and interactive cmmunicatin tls, e.g. quizzes, rle plays, vides and phts (i.e. means mre easily absrbed by thse with lw literacy levels) Natinal Events BMSC will build n the success f their displays at the Festival f Eritrea Exp in Asmara and the Natinal Eritrean Yuth Festival in Sawa in 2006, 2007 & 2008 t cntinue their wider public awareness and educatin thrughut the life f the mine. T this end, BMSC will: Cntinue t participate in regular natinal events t prmte infrmatin sharing abut the Prject at a natinal level; Seek pprtunities t maintain public interest in the mine and enable the general ppulatin t understand the different activities related t the Prject, particularly during cnstructin and then int the peratins phase; and Use natinal events t prmte natinal emplyment and business develpment pprtunities. Scial Management Plans [18/02/2010] Page 25 f 111

26 2.9.5 Website Bisha Mining Share Cmpany BMSC will establish a Prject specific website (r expand the infrmatin n the Nevsun website) by early peratins. Annual reprts including infrmatin abut stakehlder engagement activities will be psted n the website. Other relevant dcuments, such as press releases abut cnstructin activities and ther Prject infrmatin will als be disclsed thrugh the website Open Huses BMSC will use pen huses and site turs at the Bisha mine, as required, t: Shw representatives f the natinal, reginal and lcal gvernment and ther interested peple invited by BMSC the prgress f the Prject; Hst ther grups invited by BMSC such as yuth r schl grups, wh fr example, ver the life f the mine, will be maturing and ptentially becming eligible fr emplyment r participatin in the stakehlder engagement prcess; and Update lcal cmmunities n what the current state f cnstructin r develpment at the mine actually lks like and t further enable them t cntribute meaningfully t the stakehlder engagement prcess. Visitrs will nt be permitted t enter parts f the Prject site where cnditins pse a danger r where hazardus wrk is in prgress Disclsure f Printed Materials Disclsure f infrmatin materials will cntinue t be an imprtant part f the engagement prcess in the cnstructin and peratins phases f the Prject. BMSC shall disclse regular infrmatin t stakehlders invlving the fllwing: Prepare and disseminate relevant printed infrmatin abut the Prject and in particular, cnstructin and peratins activities, e.g. a brchure t explain hw t use the cmplaints prcedure, r a pamphlet utlining recruitment prcedures; All infrmatin materials shall be prvided in relevant languages, e.g. Tigre/Tigringa/Arabic, and designed t prvide details in a frmat readily understandable by lcal peple; Materials shall als be prepared in English if necessary and relevant t the details being disclsed r fr BMSC management apprval; Particular attentin will be given t ensuring that peple with lw literacy levels and ther vulnerable grups receive printed infrmatin in frmats that are apprpriate fr them; During cnstructin, materials shall be prepared and disclsed n at least the fllwing tpics: Cnstructin activities at site/in each area; Hiring practices and emplyment pprtunities; Supplier pprtunities; Transprt/traffic in the cmmunity; Cmmunity health and safety briefings and awareness prgrams; Onging cmpensatin and resettlement activities; Waste and envirnmental issues; Rad access restrictins/diversins; Land access and assciated issues; Influx/infrmal in-migratin issues; Lcal wrker training; Wrker camp management and the Cde f Cnduct; and Scial Management Plans [18/02/2010] Page 26 f 111

27 Bisha Mining Share Cmpany Cmplaints prcess. The Cmmunity Relatins Manager shuld maintain cllectin f disclsure materials prepared; BMSC will ensure that messages disclsed in varius materials are cnsistent and that relevant apprvals by management are in place fr any sensitive infrmatin; and Public ntice bards, cmmunity newsletters, Stre Frnt Infrmatin Centres, and a range f ther vehicles will likely be used t make infrmatin accessible t lcal cmmunities Cmmunity Newsletter In rder t actively engage cmmunities during the cnstructin and peratins phases f the Prject, BMSC will establish sme frm f cmmunity newsletter. T this end, BMSC will: Establish a Cmmunity Newsletter (r similar) that fcuses n tpics f mst interest and relevance t lcal cmmunities; The newsletter shuld be managed by BMSC but include input frm residents themselves t ensure that the infrmatin prvided meets the expectatins and needs f the cmmunities; Cnsider pprtunities fr the newsletter t be delivered in bth written and ral frmat, t enable thse that are nt literate t als access the infrmatin; and The Cmmunity Newsletter shuld be prduced at least quarterly during cnstructin and distributed thrughut the lcal cmmunities and reginal areas as apprpriate Stre Frnt Infrmatin Centres A number f Stre Frnt Infrmatin Centres have been perated by BMSC since As at the end f 2008, centres were pen in Barentu, and Agrdat. BMSC will cntinue t use Stre Frnts and ther similar venues t prvide lcal stakehlders with access t Prject infrmatin. T this end, BMSC will: Maintain Stre Frnt Infrmatin Centres in at least Barentu, Agrdat and Mgraib t act as an interface between BMSC and the public; Recrd visitrs and cmments received, including mnthly statistics n the number f visitrs, the nature f queries made, where visitrs cme frm and ther relevant indicatrs; Establish mbile infrmatin shps ( Inf Shps ) r similar, t help disseminate regular infrmatin in ther affected villages/twns and reginal centres as required; These mbile r temprary Inf Shps shall be established in rder t ensure that affected peple have easy access t Prject infrmatin, as nt all peple will be able t attend the central Stre Frnt Infrmatin Centres; Inf Shps are generally nt manned ffices but spaces where Prject infrmatin can be presented, such as brchures, cpies f cmplaints frms and ther materials; and Materials in Stre Frnt Infrmatin Centres and Inf Shps shuld be regularly updated t ensure that infrmatin is current and relevant t Prject activities. BMSC recgnises that the lcal ppulatin has lw literacy levels. As such, the cmmunity relatins team will investigate creative methds f prviding infrmatin t lcal peple at the Stre Frnt Infrmatin Centres that includes delivering infrmatin in written frmat but als in ral frmat Special Methds fr Engaging Wmen BMSC will develp relevant measures t help t fully integrate wmen s perspectives int its engagement activities, including: Scial Management Plans [18/02/2010] Page 27 f 111

28 Bisha Mining Share Cmpany Obtain the full picture, as experience shws that wmen ften have different perspectives and pririties than men and may be differentially impacted by the Prject (i.e. seek ut the views f wmen n all relevant tpics); Disaggregate data t allw fr a better understanding f gender differences related t the Prject; Ensure that there is a representative sample by gender when undertaking surveys and interviews; and Tailr the cmmunity relatins team and engagement activities t get mre wmen in the rm and make them mre likely t participate, including hlding separate meetings fr wmen, using active facilitatin, and having wmen staff and facilitatrs s wmen will be mre cmfrtable talking t ther wmen Stakehlder Engagement Prcedures General BMSC recgnises the need t actively engage with lcal cmmunities and ther key stakehlders during the cnstructin and peratins phases f the Prject n key issues that may affect them. The fllwing subsectins describe the key elements f the SEP Actin Plan fr Engagement T supprt the engagement prcess, BMSC has develped an utline Actin Plan fr Engagement (included as Annex A). This plan identifies the different engagement activities which will be required during the cnstructin phase and ging frwards. BMSC will review the Actin Plan at least quarterly during cnstructin, t ensure that it remains valid and meets the needs f BMSC, lcal cmmunities and ther key stakehlders Stakehlder Analysis and Tracking BMSC will cntinue t cmplete a Meeting Recrd (see Frms belw) fr all stakehlder engagement activities. Recrds f stakehlder interactins shall be held centrally by BMSC. Prcedures fr nging stakehlder identificatin, analysis and tracking as the Prject advances with cnstructin, shall invlve: BMSC will establish a stakehlder tracking system (see Frms belw) t lg all meetings with, and relevant infrmatin abut, key stakehlders at natinal, reginal and lcal levels; The stakehlder tracking system shall keep track f engagement activities, imprtant cmments, issues r utcmes and Prject respnses; BMSC shall circulate key stakehlder infrmatin t Prject teams, including the EPCM Cntractr, SENET; BMSC will incrprate stakehlders fr the prt site at Massawa and the transprt rute int this tracking system in due curse; The stakehlder tracking system may be a spreadsheet, database r similar; BMSC will designate the Cmmunity Relatins Manager (r ther apprpriate candidate) t be respnsible fr develping and implementing the stakehlder tracking system. The Envirnment Department is respnsible fr maintaining a recrd f all stakehlder engagement activities. The recrd will cntain infrmatin n key stakehlders and their engagement histry with the Prject, and will be updated t track changes as they ccur. Such data will include: Meeting/activity recrds; Budget expenditure dcuments; Cmplaints frms, lg and recrds detailing hw cmplaints were reslved; Scial Management Plans [18/02/2010] Page 28 f 111

29 Bisha Mining Share Cmpany Public cmments bks/ther dcuments shwing issues raised by stakehlders; Cmmitments register fr lcal cmmunities; Cmmunity relatins staff reprts; Crrespndence received by gvernment r ther stakehlders; and Disclsure materials disseminated; Statistics n visitrs t Stre Frnt Infrmatin Centres; Respnses prvided t stakehlders by the Prject; Cmmunity attitudes and perceptin surveys; and Training recrds. An example Stakehlder Engagement Tracking Matrix is as fllws: Example Stakehlder Engagement Tracking Matrix Categry Stakehlder / rganisatin Rle / psitin Relatinship Issue / interest / cncern Ranking Engagement histry Cmmitments made Prject Respnses Methds fr engagement Frequency / timing Respnsibility Resurces Additinal infrmatin Descriptin The name f the individual, main cntact, with full cntact details Describe wh this grup / individual is and their relevance (e.g., gvernment regulatr, influential envirnmental NGO representative) Describe in detail what their relatinship is with the Cmpany Describe main issues (e.g., want emplyment, cncerned abut scial r envirnmental impacts) Describe the level f imprtance e.g. frm 1-5, 1 nt very imprtant, 5 imprtant Describe previus cntacts and dialgue held, and their utcmes Describe what was cmmitted t during engagements Hw issues/interests/cncerns are infrm management plans r ther respnses Describe hw this individual/grup shuld be engaged in the future including the level f engagement (e.g., partner, participant, bserver) Plan fr frequency f engagement Wh in BMSC is respnsible t implement the engagement activity Estimate the cst and ther resurces that are required t manage this relatinship Any additinal cmments r bservatins The Envirnment Department shall ensure that minutes/recrds f each engagement event r activity are cmpleted and filed. The Bisha Meeting Recrd Frm is as fllws: Scial Management Plans [18/02/2010] Page 29 f 111

30 Bisha Mining Share Cmpany Surce: Addendum t Public Cnsultatin Tls and Schedule, Nevsun Resurces Ltd., March 16, 2006 Scial Management Plans [18/02/2010] Page 30 f 111

31 Bisha Mining Share Cmpany Crdinatin between Different Teams As activities increase n site, it will be imprtant fr the cmmunity relatins team t interact regularly with ther Prject teams and departments. The Prject shall implement the fllwing prcedures fr internal crdinatin related t stakehlder engagement: Establish a schedule f regular meetings with relevant Departments t discuss stakehlder engagement activities and issues; Meet regularly with the human resurces, engineering/design, envirnmental, health & safety, and cnstructin teams t discuss lcal cmmunities and cmmn issues; BMSC teams and Departments dealing with lcal cmmunities and stakehlders shall keep the cmmunity relatins team infrmed f their activities; and The cmmunity relatins team shall crdinate all meetings, disclsure materials and ther engagement events that take place with primary stakehlders, particularly lcal cmmunities Crdinatin with Gvernment BMSC recgnises the imprtance f crdinating its stakehlder engagement activities with lcal/reginal and natinal gvernment, and as such, has already develped a gd relatinship with lcal administratrs, the Department f Mines and ther relevant line ministries. Cperatin with gvernment related t stakehlder engagement fr the Prject shall include: BMSC will keep the Department f Mines and relevant lcal authrities infrmed f its engagement activities, at least n a quarterly basis; BMSC will wrk clsely with varius gvernment agencies and ministries t c-rdinate any activities that the Prject may want t undertake with lcal cmmunities (e.g. agriculture extensin prgram); BMSC will maintain recrds f all engagement activities and make these available t relevant gvernment fficials upn request; and Reprt t lcal/reginal authrities and the Department f Mines abut cmmunity cmplaints received by the Prject and actins being taken t reslve issues Cnsultatin and Disclsure f New r Updated SEIA-related Dcuments BMSC has been thrugh an extensive cnsultatin and disclsure prcess regarding the riginal SEIA dcumentatin that has been prepared fr the Prject. Since sme f the dcumentatin is being updated it will be apprpriate fr sme dcuments t g thrugh a specific, althugh mre limited, disclsure prcess. The updated r new Management Plans will be cmpleted and published in early 2009, and an SEIA Update Reprt will als be made available in relevant frmats fr different stakehlder grups: Lcally: summary materials n relevant Management Plans, particularly prpsed mitigatin measures which affect lcal peple will be disclsed lcally (e.g. at Stre Frnt Infrmatin Centres, ther relevant lcatins and in specific face-t-face meetings with lcal cmmunities); Reginally/Natinally: relevant Management Plans and a cpy f the SEIA Update Reprt will be available at the BMSC ffice in Asmara as well as disclsed t relevant authrities including the Department f Mines; and Internatinally: the SEIA Update Reprt will be available n the Nevsun website. BMSC will advise peple hw they can access a cpy f the new r updated Management Plans, the SEIA Update Reprt and ther relevant dcumentatin, as well as the timetable and prcess fr making cmments where apprpriate. Scial Management Plans [18/02/2010] Page 31 f 111

32 2.11 Cmplaints Management Bisha Mining Share Cmpany BMSC will implement the fllwing prvisins ensure that a frmal cmplaints management prcess is in place fr the Prject fr cnstructin and peratins: Establish and implement a cmplaints prcedure (see Annex B) which will allw BMSC t register and respnd in a timely manner t cmplaints f peple directly affected by the Prject; The cmplaints prcedure will incrprate the fllwing principles: It will be transparent and simple t understand by Prject affected peple; It will be activated and cmpleted in a timely manner; It will be put in writing; It shall define the respnsibilities f each party invlved; and It will be free. BMSC will designate a persn wh is respnsible fr crdinating the receipt f and respnse t all cmplaints (e.g. the Cmmunity Relatins Manager); Relevant managers are respnsible fr helping t reslve cmplaints that relate t their technical areas, e.g. envirnment, engineering, cnstructin etc; The cmplaints prcedure shall apply t all Prject cmpnents and activities ver which BMSC has direct cntrl; The cmplaints prcedure will be tested and refined as the cnstructin phase prgresses t ensure it is easy t use and adequate fr capturing the cmplaints f lcal peple; and All emplyees shall be trained t direct peple with cmplaints t the designated persn r, in their absence, t anther member f the cmmunity relatins team Rles & Respnsibilities BMSC shall remain in cntrl f stakehlder engagement activities thrughut the Prject, thugh SENET will be required t identify/allcate apprpriate staff t supprt engagement activities with the Bisha cmmunity relatins team in the cnstructin phase. Overall respnsibility fr the implementatin f this Management Plan shall rest with the Bisha Cmmunity Relatins Manager wh shall reprt n prgress t the Bisha Envirnment Manager. Others with respnsibility fr the implementatin f this Management Plan shall include: SENET, as EPCM Cntractr, shall be respnsible fr the integratin f these prcedures and requirements int their perating prcedures and plans; Bisha Cmmunity Relatins Manager shall be respnsible fr designing and implementing engagement activities with lcal cmmunities and lcal/reginal gvernment; Bisha Cmmunity Liaisn Officers shall supprt Cmmunity Relatins Manager with stakehlder engagement activities and act as the interface between lcal villages and the Prject; Bisha Mine/Mill Superintendents shall be respnsible fr ensuring that these prcedures and requirements are implemented fr all peratins Training All emplyees f BMSC and Cntractrs t BMSC shall be prvided with basic training n apprpriate interactin with lcal cmmunities, including requirements f the Cde f Cnduct. Additinal specialist training shall be prvided t cmmunity relatins staff invlved in engagement activities. BMSC will prvide specific training t at least t the Cmmunity Relatins Manager and village-based Cmmunity Liaisn Officers n relevant stakehlder engagement activities. Scial Management Plans [18/02/2010] Page 32 f 111

33 2.14 Mnitring & Reprting Bisha Mining Share Cmpany It is imprtant t mnitr stakehlder engagement t ensure that cnsultatin and disclsure effrts are effective, and in particular that primary stakehlders such as lcal cmmunities, are meaningfully incrprated int the prcess. Stakehlder engagement mnitring prcedures shall be as fllws: The Bisha Cmmunity Relatins Manager shall reprt n a mnthly basis t the Bisha Cmmunity Relatins Manager, including n: Engagement activities; Visitrs t the Stre Frnt Infrmatin Centres; Level f participatin by different stakehlder grups (e.g. wmen); Cmments frm, and feedback prvided t, stakehlders; Cmmitments made t lcal cmmunities by the Prject; Disclsure materials disseminated: types, frequency, and lcatin; Cmmunity attitudes and perceptins; Cmmunity cmplaints and their reslutin; Cmmunity relatins staff, their duties/activities and staff changes; Cmmittees, grups and partnership activities related t engagement; and Prject website. Bisha Cmmunity Relatins Manager shall regularly participate in engagement activities and shall inspect BMSC dcumentatin n a mnthly basis. The inspectin shall include: Stakehlder engagement recrds; Budget expenditure recrds; Cmplaints frms, lg and recrds detailing hw cmplaints were reslved; Public cmments bks/ ther dcuments shwing issues raised by stakehlders; The schedule/actin plan fr implementing the engagement prgram; Cmmitments register fr lcal cmmunities; Cmmunity relatins staff reprts; Crrespndence received by gvernment r ther stakehlders; and Disclsure materials disseminated. The Bisha Cmmunity Relatins Manager shall be respnsible fr recrd-keeping. Regular reprting shall be undertaken via the mnthly SEMS Reprt that shall be prepared and submitted t the Bisha General Manager. Reprting shall include: A summary f activities undertaken during the reprting perid; Any material deviatins r nn-cmpliances t this Management Plan; Planned activities during the next reprting perid; Any ther issues f cncern. Further infrmatin n scial mnitring and reprting requirements and prcedures is set ut in the Mnitring Plan and in the Scial & Envirnmental Management System. Scial Management Plans [18/02/2010] Page 33 f 111

34 Annex A Prpsed Actin Plan fr Engagement in the Cnstructin Phase BISHA PROJECT ACTION PLAN FOR CONSTRUCTION-RELATED ENGAGEMENT Bisha Mining Share Cmpany Revisin: 2 Date: 26 March 2009 WHEN WHAT/ METHOD DESCRIPTION RESPONSIBILITIES/SPECIFIC TASKS N. Stakehlders Lcal 1 Lcal administratrs/village elders As required Small grup meetings BMSC will engage with lcal administratrs thrugh the Infrmatin Update Cmmittee and all ther activities implemented with the Prject affected villages (see belw). a. T be develped b. T be develped 2 Prject-affected villages/residents By 1st quarter 2009 Stre Frnt Infrmatin Centres Stre Frnt Offices will be maintained in Barentu, Mgraib and Agrdet during cnstructin. These Offices will be staffed by BMSC persnnel and will be regularly updated with Prject infrmatin. a. T be develped b. T be develped By June 2009 Inf Shps r similar Inf Shps r similar will be established in relevant lcatins within affected villages/twns that d nt have Stre Frnt Offices s that key Prject infrmatin is accessible t all lcal residents. a. T be develped b. T be develped Onging Public Cmments Bks, "mailbxes" r similar BMSC will cntinue t make Public Cmments Bks, mailbxes and/r similar available in public places, such as the Stre Frnt Offices, t allw lcal ppulatin t make suggestins and requests t the Prject. a. T be develped b. T be develped 3 Lcal wmen As required but at least every 3 t 4 mnths Regular Cnstructin Updates Regular updates n cnstructin activities, hiring and emplyment pprtunities, lcal wrker training, cmmunity assistance and any ther relevant issues will be displayed n ntice bards r similar in villages. By May 2009 Frequently Asked Questin system BMSC will establish a Frequently Asked Questin system r similar in rder t respnd t cmmn questins and cncerns f lcal cmmunities in an efficient and cnsistent manner. This may need t be implemented bth in printed and ral frmats t ensure the respnses can be readily understd by lcal peple. At least twice a year Lcal events/public meetings The Prject will arrange lcal events with the five key cmmunities t prvide prgress reprts abut the Prject, cnduct cmmunity awareness raising/educatin abut Prject impacts and hear any cncerns frm lcal villages. As required Open huses Open huses will be rganised at the mine site t update participants n the status f cnstructin activities and enable them t see what the Prject actually lks like n the grund. As agreed (apprx. every quarter) Annually Distributin f a regular Cmmunity Newsletter Disclsure f printed materials n relevant tpics e.g. thrugh fact sheets, brchures, pamphlets etc BMSC will establish a regular newsletter during cnstructin (and likely int peratins) fr lcal villages abut the Prject, which will be prepared with input frm residents themselves. Disclsure materials will be prepared t supprt engagement activities. BMSC will ensure that all imprtant Prject infrmatin is prvided in written (as well as ral) frmat; s that lcal peple can have a recrd f the infrmatin prvided. e.g. brchure n hw t use the cmplaints prcedure, recruitment prcesses, etc. Annually Perceptin and attitude surveys The Prject will cnduct a perceptin and attitude survey with a sample f the affected ppulatins t gauge their level f supprt fr the Prject, and their interests and cncerns abut current activities. As available Disclsure f new r updated SEIA-related dcuments BMSC will disclse Prject related dcuments which are f interest t lcal stakehlders related t bth current and future activities f the Prject. This may include dcuments such as a summary f the Human Resurces and Emplyment Plan and the Cmmunity Health & Safety Plan. At least mnthly Cmmunity Liaisn Officers The CLO team will meet the Public Cnsultatin Officer regularly and will als attend meetings f the Infrmatin Update Cmmittee and thers events as directed by BMSC. At least every 2 mnths Infrmatin Update Cmmittee BMSC will facilitate at least tw mnthly meetings with the Infrmatin Update Cmmittee (made up f lcal village authrities and ther representatives). As required Mediatin Cmmittee The Mediatin Cmmittee will meet t address cmplaints that cannt be readily reslved between BMSC and cmplainants. T be determined Other wrking grup/cmmittees Bisha staff will facilitate regular meetings with any cmmittees/wrking grups established t supprt manage specific cmmunity-related issues abut the Prject (e.g. recruitment/emplyment, water management etc) At least twice a year Small wmen nly grup meetings BMSC will facilitate wmen's participatin thrugh separate wmen nly meetings and ther discussins. This will be arranged fr all relevant tpics t ensure that impacts t wmen are prperly understd and their pinins are adequately cnsidered in planning activities in the cmmunities. As required Wmen fcused surveys and interviews In additin t separate meetings and ther frums, BMSC will implement specific surveys and assciated interviews with wmen when gathering data t infrm n prgrams within the cmmunity. This is t ensure that gender differences related t scial and envirnmental issues are incrprated int Prject planning. a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped Scial Management Plans [18/02/2010] Page 34 f 111

35 Bisha Mining Share Cmpany BISHA PROJECT ACTION PLAN FOR CONSTRUCTION-RELATED ENGAGEMENT Revisin: 2 Date: 26 March 2009 N. Stakehlders Reginal 3 Reginal authrities 4 Reginal public At least annually, but therwise as required 5 Natinal Ministries & ther gvernment agencies 6 Natinal public (and interested internatinal parties) WHEN WHAT/ METHOD DESCRIPTION RESPONSIBILITIES/SPECIFIC TASKS As required Small grup meetings BMSC will invite Gash Barka, Dighe and Ggne authrities t lcal cmmunity meetings and ther events frm time t time, and when the issues being discussed require it. Once r twice a year Site turs In additin t pen huses with natinal gvernment, BMSC will invite reginal authrities t tur the site and discuss issues with BMSC at least nce r twice a year. Natinal events BMSC will participate in relevant reginal events t help prmte understanding abut the Prject in the regin. Stre Frnt Infrmatin Centres will als be used t cmmunicate with the reginal public in Barentu and Agrdet. Printed materials will als be disclsed reginally where apprpriate. At least annually Update and briefing sessins BMSC will hld frmal update and briefing sessins with interested authrities including relevant Ministries a(nd Gash Barka, Dighe and Ggne Authrities). As required Infrmal discussins and meetings with key authrities/line ministries BMSC already has regular cntact with the Department f Mines n all aspects f Prject implementatin. This will cntinue during cnstructin and the Cmpany will ensure t infrm/invite ther relevant natinal authrities t discuss tpics that affect their gvernmental remit (e.g. agricultural, land, water issues). a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped a. T be develped b. T be develped As required BMSC public website Regular updates abut the Prject n the public website. a. T be develped As required Meetings/turs/ther natinal events BMSC will hst natinal and internatinal parties at the site and hld meetings and ther events as required b T be develped a. T be develped during Prject cnstructin. This is expected t include turs by ptential investrs, Eritrean mining nd ther cmpanies, as well as ther Dignitiries and interested parties. BMSC will cntinue t participate in relevant natinal events such as the Festival f Eritrea Exp and the Natinal Eritrean Yuth Festival. b. T be develped As required Media (advertisements and ther channels) Relevant media channels will be used t keep the natinal public infrmed abut the Prject. a. T be develped Annually Annual reprts The Prject will prduce an Annual HSEC Reprt that details the Prject s perfrmance n HSEC issues, b T be develped a. T be develped including stakehlder engagement. This reprt wuld be disclsed t the general public. b. T be develped Scial Management Plans [18/02/2010] Page 35 f 111

36 Bisha Mining Share Cmpany Annex B Cmplaints Prcedure B.1 General The Cmplaints Prcedure is summarised in Figure B.1 which utlines the key steps t be taken in the cmplaints management prcess. Each f these steps is described in further detail belw. B.2 Recrding and Lgging the Cmplaint Recrding and lgging cmplaints will include the fllwing prcedures: A Cmplaint Actin Frm (see Figure B.2) will be prepared; Recrd infrmatin abut the cmplaint, e.g. when it was raised and by whm (cmplainant); BMSC will either help peple cmplete a cmplaint frm directly r fill it in n their behalf; and A Cmplaints Lg will be established s cmplaints can be tracked by BMSC (see Bx B.1). Bx B.1 Cntent fr Cmplaints Lg The Cmplaints Lg ensures that each cmplaint has an individual number and that the tracking and recrding f fllw-up actins is undertaken. The Lg will include the fllwing infrmatin: cmplaint registratin number. date cmplaint received. brief summary f cmplaint. cmplainant details (name, address, ther cntact infrmatin). cmpany s respnse / crrective actin. date f respnse sent t cmplainant. fllw up actins required. final reslutin. B.3 Respnding t Cmplainants Prcedures fr respnding t cmplaints include: A site visit and/r interview with the cmplainant in rder t understand the issue raised; Infrmatin may need t be verified r further investigated thrugh anther surce and BMSC will endeavur t cllect this additinal infrmatin at n cst t the cmplainant; All cmplaints received shall be acknwledged in writing within a specified time perid (n greater than tw weeks) and where apprpriate, verbal respnses may als be given, and will be dcumented in the Cmplaint Lg (e.g. cmplainant may initial the Cmplaint Lg entry); As nt all cmplaints can be readily reslved, the initial respnse may be a summary f what is planned and when it is likely t ccur; Fr issues and/r crrective actins that take lnger t address, r where the cmplainant(s) are nt satisfied and additinal activities are required, the Prject will keep cmplainant(s) infrmed f prgress; and Scial Management Plans [18/02/2010] Page 36 f 111

37 Bisha Mining Share Cmpany Once a cmplaint has been addressed, the Cmpany will cmmunicate the reslutin f the issue t the cmplainant, and will crdinate any further cmmunicatins that may be necessary. B.4 Assessing and Reslving Cmplaints Prcedures fr assessing and reslving cmplaints are: BMSC will aim t reslve cmplaints quickly and in an effective and apprpriate manner; BMSC tgether with the cmplainant, will explre thrugh discussin r negtiatin, pssible remedies that will reslve the issue; BMSC will utilize relevant managers t help reslve cmplaints (e.g. if cmplaint is related t an envirnmental issue, the Envirnmental Manager may lead reslutin activities, r if it has t d with safe driving in cmmunities, the Safety Manager wuld likely lead reslutin effrts; Where cmplaints d nt require crrective actin (e.g. where cmplaint is nt directly relevant t Prject r where cmplaint is already the subject f anther prcess) the initial acknwledgement f the cmplaint will incrprate the respnse/reslutin t the cmplainant; and When the Prject cannt reslve a cmplaint, BMSC will nt inhibit the cmplainant taking actin in a curt f law. B.5 Reprting and Mnitring Cmplaints Mnitring f cmplaints will include review f the number and status f cmplaints and any utstanding issues t be addressed. Reprts n cmplaints mnitring will be prduced and sent t the General Manager n less than nce each mnth. The reprts shall include, as a minimum, infrmatin n: Subject/classificatin f the cmplaints received; Discussin f each cmplaints validity; The imprtance f the issues raised; Measures taken, and any required fllw-up; Invlvement f the mediatin cmmittee, if any; Analysis f types f cmplaints and cmplaint levels; Actins taken t reduce cmplaints; and Time taken t slve the cmplaint. The effectiveness f the cmplaints prcess shuld be evaluated by independent evaluatrs, e.g. every 1 t 2 years during peratins; BMSC will include Prject affected peple in the assessment f the cmplaints mechanism, e.g. by using participatry mnitring methds; and The utcmes f the cmplaints prcess will be reprted in the mnthly SEMS reprt. The vlume f cmplaints may be such that the current paper system will nt be able t cpe with it. As such BMSC will investigate the use f an electrnic registratin system fr managing cmplaints. This culd include a mechanism t ensure that Bisha staff knws when cmplaints are nt clsed ut which is an essential aspect f the cmplaints management prcess. B.6 Disclsure f Cmplaints Prcedures In rder t ensure that the cmplaints management prcess can be accessed and used by lcal stakehlders, BMSC will disclse the cmplaint prcedure t lcal stakehlders in a relevant frmat and in apprpriate languages. This may include prviding a cpy f the prcedure and explaining its purpse and use t lcal, sub-zba and Zba authrities as well as lcal cmmunities. Scial Management Plans [18/02/2010] Page 37 f 111

38 Bisha Mining Share Cmpany Figure B.1 Prpsed Cmplaints Prcedure Flwchart Cmplaint Received (verbally r writing) Cmpleted Cmplaint Actin Frm submitted Recrd date n the Cmplaints Lg Enter registratin number n Cmplaint Actin Frm Cmplete Immediate Crrective Actin Sectin (if apprpriate) and assign respnsibility Yes Crrective actin cnsidered adequate? N Initiate next level f reslutin Establish & agree next reslutin steps Recrd date n the Cmplaints Lg Infrm cmplainant (if apprpriate) f the prpsed reslutin prcess Implement prcedure and agree crrective actin utcme Carry ut fllw up f the crrective actin Infrm cmplainant f crrective actin Recrd date n the Cmplaints Lg Yes Crrective actin satisfies the cmplaint N Clse ut the Cmplaint Actin Frm Recrd date n the Cmplaints Lg Scial Management Plans [18/02/2010] Page 38 f 111

39 Bisha Mining Share Cmpany Figure B.2 Example Cmplaint Actin Frm All cmmunity cmplaints received shall be recrded using a Cmplaint Actin Frm. A cpy shuld be frwarded t the Cmplaints Officer. COMPLAINT ACTION FORM PART 1 CONTACT AND REGISTRATION DETAILS COMPLAINT REGISTRATION NUMBER: (Number t be taken frm the Cmplaint Lg) DATE RECEIVED: TO BE COMPLETED BY COMPANY LOCATION: (Cmmunity/general area) Cmplainant: (Name, Surname) Telephne Number: Address: TO BE COMPLETED BY COMPLAINANT PART 2 COMPLAINT DESCRIPTION TO BE COMPLETED BY COMPLAINANT Scial Management Plans [18/02/2010] Page 39 f 111

40 Bisha Mining Share Cmpany COMPLAINT ACTION FORM PART 3 Immediate Actin: PROPOSED RESPONSE/CORRECTIVE ACTION Date fr Cmpletin: Respnsible Persn: Signature: Date: Lng Term Actin: Date fr Cmpletin: Respnsible Persn: Signature: Date: TO BE COMPLETED BY COMPANY Other Reslutin Details PART 4 Fllw-up Details: VERIFICATION OF CORRECTIVE ACTION Clsed Out: Signature: (Date) TO BE COMPLETED BY COMPANY Scial Management Plans [18/02/2010] Page 40 f 111

41 Bisha Mining Share Cmpany 3 Human Resurces & Emplyment Management Plan 3.1 Intrductin The Human Resurces and Emplyment Management Plan is designed t ensure that lcal emplyment, ne f the main benefits f the Bisha Prject, is maximised and enhanced thrugh effective prcedures fr recruitment, emplyment and training f persnnel during the cnstructin, peratins and clsure phases f the Prject. The plan cntains the methds that shall be used t maximise lcal/natinal emplyment tgether with prcedures t ensure that recruitment, emplyment and training is cnducted in a fair and transparent manner. Lcal emplyment is the main sci-ecnmic benefit that the Prject can directly bring t peple living in the villages nearest t the Bisha Mine. The relevant sub-zba, Zba and wider Eritrean ppulatins are als likely t be able t access emplyment pprtunities. During the Prject assessment prcess, the fllwing emplyment estimates were made: Apprximately 358 wrkers will be required fr the cnstructin f the Bisha Mine and ancillary facilities. The majrity f the cnstructin wrkfrce is expected t be skilled Eritreans frm Asmara and the highlands; althugh the Prject intends t hire suitable lcals fr psitins t the extent they are available. It is estimated that 90% f cnstructin wrkers will be Eritrean natinals. At the peak f the Prject peratins, jbs will be created fr apprximately 700 peple. By midway thrugh the peratins phase, the direct wrkfrce is als expected t cmprise 10% expatriates and 90% Eritrean natinals. There is a high expectatin f lcal emplyment in the lcal villages as well as within the wider Zba Gash Barka and the cuntry as a whle. Implementatin f this plan is central t managing emplyment expectatins as it sets ut specific actins fr the Prject t ensure that pprtunities fr lcal emplyment are maximised, and that there is a fair distributin f jbs. This is vital t maintaining a gd relatinship between the Prject, nearby villages and ther stakehlders. 3.2 Objectives The bjectives f this Management Plan are t: Establish effective plans and prcedures fr lcal/natinal recruitment, emplyment and training; Define BMSC requirements and prcedures t guide the Prject Management Team and ther Prject cntractrs; Define rles and respnsibilities; and Define mnitring and reprting prcedures. 3.3 Scpe The plan describes the management f human resurces, emplyment and training prcesses assciated with all phases f the Prject. The plan deals with hiring and training f lcal/natinal Eritrean persnnel t supprt develpment f the Bisha mine and ancillary facilities and describes requirements frm the assessment f new recruits thrugh t the certificatin that relevant training has been cmpleted. The plan cnsiders ptentially adverse as well as psitive impacts related t: Direct emplyment; Wide distributin f emplyment pprtunities; Recruitment prcess; Emplyment expectatins; Wrking cnditins; Enhanced lcal skills; and Scial Management Plans [18/02/2010] Page 41 f 111

42 Indirect emplyment pprtunities (e.g. lcal prcurement and supply). Bisha Mining Share Cmpany This plan is a flexible dcument that shall be reviewed n a peridic basis and amended where necessary changes are identified. The plan applies t BMSC as well as EPCM Cntractr persnnel. The EPCM Cntractr, SENET, shall make sure that this plan is available t their wn staff and that all prcedures/actins included within the plan are recgnized, adpted and applied by them prir t cmmencing cnstructin. Civil wrks activities fr cnstructin at the mine are being sub-cntracted by SENET t Eritrean cntractrs. One f the main sub-cntractrs fr the Prject is Segen, a natinal cmpany ding civil wrks thrughut the cuntry. Segen is a gvernment run rganisatin and accrdingly they have their wn recruitment and emplyment prcedures that are in accrdance with the Eritrean Labur Law. BMSC shall als prmte apprpriate n-site prcedures and practices fr sub-cntractrs as far as are practicable (e.g. emplyee cnduct, health, safety and envirnmental practices). 3.4 Regulatry Requirements Crprate Plicy BMSC has develped an Emplyee Plicy t cver emplyees and cntractrs invlved in the Prject. BMSC shall ensure that the plicy is cmmunicated and distributed t all relevant staff Cde f Cnduct BMSC has develped a Cde f Cnduct t ensure that the lcal custms, traditins and the cmmunity way f life are respected. The Cde f Cnduct is intended t assist with preventing and mitigating impacts t the cmmunity and maintaining gd relatins between lcal residents and natinal and internatinal emplyees. The Cde shall apply t all emplyees f BMSC and cntractrs undertaking wrk n r arund the Bisha Prject mine site (and ther facilities as they are integrated int the Prject, e.g. the prt site at Massawa). Deviatin frm this Cde shall be treated seriusly. The Cmmunity Relatins Manager (r their delegate) shall induct all emplyees and cntractrs n the requirements f the Cde f Cnduct Eritrean Requirements The primary Eritrean legislatin relating t emplyment is the Labur Law (118/2001). Applicable prvisins in the Labur Law include: Written cntracts fr a perid f ne year r lnger, r fr a team f emplyees (Article 3 (3)); Prvisins fr terminatin including requirements fr ntice r valid reasn fr terminatin (Articles 22, 23, 24, and 30); Ntice f cmpensatin (Article 29); Severance pay (Article 32); Maximum wrking week (Article 48); Minimum wage (Article 41); Overtime wrk (Articles are 52, 53); Annual leave (Article 56); Minimum age (Article 68, 69); Prvisins related t the prhibitin f discriminatin based n gender, disability and criminal histry (Articles 63, 65, 68); Reasnable measures t prtect the health and safety f emplyees and prvisin f a secure wrkplace (Article 20(4), 70); and Emplyees carrying ut the same jb and having equivalent qualificatins must be treated equally (wages, salaries and agreements regarding terminatin f cntracts are excluded). Scial Management Plans [18/02/2010] Page 42 f 111

43 Bisha Mining Share Cmpany In additin, wrkers rights are als prtected by the Cnstitutin and cllective agreement, which als gverns the scial benefits t which all wrkers, are entitled Internatinal Best Practice Internatinal Finance Crpratin (IFC) Perfrmance Standards fr Scial and Envirnmental Sustainability set ut a range f recmmendatins with regard t labur and wrking cnditins (Perfrmance Standard #2) 3. BMSC will cmply with requirements f IFC Perfrmance Standard 2 which include: Adpt a human resurces plicy apprpriate t its size and wrkfrce that sets ut the apprach t managing emplyees; Prvide emplyees with infrmatin regarding their rights under natinal labur and emplyment law, including their rights related t wages and benefits; Plicy will be clear and understandable t emplyees and will be explained r made accessible t each emplyee upn taking emplyment. Dcument and cmmunicate t all emplyees/wrkers directly cntracted abut their wrking cnditins and terms f emplyment, including their entitlement t wages and any benefits; Cmply with natinal law in cuntries where natinal law recgnizes wrkers rights t frm and t jin wrkers rganizatins f their chsing; The prject will nt discurage wrkers frm frming r jining wrkers rganizatins f their chsing r frm bargaining cllectively, and will nt discriminate r retaliate against wrkers wh participate, r seek t participate, in such rganizatins and bargain cllectively; The prject will nt make emplyment decisins n the basis f persnal characteristics unrelated t inherent jb requirements; Base the emplyment relatinship n the principle f equal pprtunity and fair treatment, and d nt discriminate with respect t aspects f the emplyment relatinship, including recruitment and hiring, cmpensatin, wrking cnditins and terms f emplyment, access t training, prmtin, terminatin f emplyment r retirement, and discipline; In cuntries where natinal law prvides fr nn-discriminatin in emplyment, the client will cmply with natinal law; Special measures f prtectin r assistance t remedy past discriminatin r selectin fr a particular jb based n the inherent requirements f the jb will nt be deemed discriminatin; Develp a plan t mitigate the adverse impacts f retrenchment n emplyees, if it anticipates the eliminatin f a significant number f jbs r a layff f a significant number f emplyees; Prvide a grievance mechanism fr wrkers (and their rganizatins, where they exist) t raise reasnable wrkplace cncerns and infrm the wrkers f the grievance mechanism at the time f hire, and make it easily accessible t them; The prject will nt emply children in a manner that is ecnmically explitative, r is likely t be hazardus r t interfere with the child s educatin, r t be harmful t the child s health r physical, mental, spiritual, mral, r scial develpment; Children belw the age f 18 years will nt be emplyed in dangerus wrk); and The prject will nt emply frced labur, which cnsists f any wrk r service nt vluntarily perfrmed that is exacted frm an individual under threat f frce r penalty United Natins and Internatinal Labur Organisatin Cnventins The internatinal cnventins negtiated thrugh the Internatinal Labur Organisatin (ILO) are relevant t the Bisha Prject and encmpassed in the Declaratin n Fundamental Principles and Rights at Wrk. The Declaratin cvers fur fundamental principles and rights at wrk: 3 Internatinal Finance Crpratin. Perfrmance Standards fr Scial and Envirnmental Sustainability; Perfrmance Standard #2. 30 April pp Scial Management Plans [18/02/2010] Page 43 f 111

44 Eliminatin f all frms f frced r cmpulsry labur: Cnventin 29 n Frced Labur; and Cnventin 105 n the Ablitin f Frced Labur. Effective ablitin f child labur: Cnventin 138 n Minimum Age (f Emplyment); and Cnventin 182 n the Wrst Frms f Child Labur; Eliminatin f discriminatin in respect f emplyment and ccupatin: Cnventin 100 n Equal Remuneratin; and Cnventin 111 n Discriminatin (Emplyment and Occupatin). Bisha Mining Share Cmpany Freedm f assciatin and the effective recgnitin f the right t cllective bargaining: Cnventin 87 n Freedm f Assciatin and Prtectin f the Right t Organize; and Cnventin 98 n the Right t Organize and Cllective Bargaining. Eritrea has signed the cre cnventins listed. BMSC will cmply with the cre cnventins and ther relevant cnventins signed by Eritrea. IFC Perfrmance Standard 2 als references these cnventins in its requirements. 3.5 Ptential Impacts Opprtunities fr emplyment (bth direct and indirect) will ccur in all phases f the Bisha Prject. Benefits are expected t be greatest during peratins, when psitins will be lnger term and will be predminantly filled by Eritrean natinals. Emplyment and assciated skills training and develpment is likely t be ne f the mst significant benefits f the Bisha Prject. The ptential psitive effect is increased wage emplyment fr skilled and semi-skilled Eritrean natinals. There will als be a limited number f emplyment pprtunities fr unskilled (and predminantly lcal) peple. Develpment f a cmpetent and skilled Eritrean wrkfrce fr the Bisha Prject will be a challenge fr BMSC and its cntractrs. Eritrea currently has n mdern mining sectr and a largely unknwn, and limited, pl f available, apprpriately skilled labur frm which BMSC can draw. At the same time, Zba Gash Barka has a high rate f illiteracy, high drput rates and substantial cultural bstacles t educatinal advancement by females. In general, the quality f educatinal facilities is limited and there are very few technical training prgrammes Cnstructin Phase The cnstructin wrkfrce is expected t peak at apprximate 358 peple but will fluctuate depending n the activities being cnducted n site. Emplyment during cnstructin will be a predminantly shrtterm assignments fr the majrity f staff, with nly a limited number f emplyees retained fr the entire cnstructin perid. The cnstructin phase will last apprximately 2-3 years Operatins Phase Direct and indirect emplyment assciated with Bisha is expected t amunt t a maximum f 700 jbs when in full peratin. During peratins, the wrkfrce is expected t include apprximately 10% expatriates and 90% Eritreans, mst f them nn-lcals Clsure Phase There will be sme emplyment required during the clsure phase and this is expected t cnsist f a limited number f Eritrean natinals. Scial Management Plans [18/02/2010] Page 44 f 111

45 3.6 Apprach t Recruitment, Emplyment and Training Overview Bisha Mining Share Cmpany The BMSC apprach t recruitment, emplyment and training invlves ensuring that the Prject is cmpliance with the Eritrean Labur Law. Eritrea places a statutry requirement n mining cmpanies t use Eritrean emplyees when it is reasnable t d s. At the same time, BMSC recgnises the need t have experienced mining staff. The Human Resurces and Emplyment Plan addresses the need fr sme expatriates and the steps t be taken t maximise emplyment f Eritreans. The main elements f the BMSC apprach are: Utilisatin f skilled and experienced mining industry expatriates as required; expatriates will nly be brught in t fill psitins fr: (a) skilled and experienced peratrs fr specific mining and prcessing plant and machinery, nt available in-cuntry; (b) skilled and experienced mine trained supervisrs in mining, prcessing and engineering; and (c) high level mining industry prfessinals; Hiring f experienced Eritrean natinals with transferable skills, fr example frm the cnstructin industry Eritreans identified will be trained t enable them t perfrm their jb t the standards required fr an internatinal mining prject; Training f Eritrean emplyees will cmmence during the cnstructin phase and intensify during and fllwing prductin start-up; Training shall be prvided t ensure that all recruits have the necessary skill and knwledge levels defined fr each psitin; Replacement during the peratins perid f many expatriates fllwing building f training and experience levels amng Eritrean emplyees; Recruitment prcedures will be transparent, public and pen t all and shall be publicised in advance, including distributin f infrmatin t affected cmmunities and reginal stakehlders; The Prject shall manage sme frm f recruitment ffice (e.g. the existing Stre Frnt Infrmatin Centres) in each f the regins (r lcal centres) as apprpriate thrugh cnstructin and peratins; The Prject team will ensure that frced labur is nt used by BMSC r its cntractrs, specifically the use f Eritrean Natinal Service persnnel n extended service; Lists f Preferred Individuals will nt be accepted (e.g. lists prvided by nn-bmsc persnnel t seek favur fr certain individuals utside f the frmal recruitment prcess); Unwarranted influxes f individuals int the Prject area will be minimised thrugh practive plicies and prcedures t reduce in-migratin in search f emplyment; and Emplyment cnditins will meet natinal laws and internatinal standards and there shall be n discriminatin n the grunds f religin, ethnicity, gender r ther factrs Categries f Emplyment The fllwing definitins fr emplyee categries apply t this plan: Skilled wrker: Skilled wrkers will include experienced staff in categries such as prfessinals (e.g. gelgists engineers), artisans (e.g electricians, instrument fitters, technicians, welders, riggers), supervisrs, and peratrs (e.g. crane, truck); Semi-skilled wrker: Semi-skilled wrkers will include experienced drivers, steel man, electrical helper, security guards, cks etc; and Unskilled wrker: Unskilled wrkers may include cncreters, cleaners, waiters, laders, sand fillers etc. Scial Management Plans [18/02/2010] Page 45 f 111

46 3.6.3 Preferential Lcal/Reginal Emplyment Bisha Mining Share Cmpany Recruitment fr unskilled wrkers is t be held at the Lcal level. Pririty is t be given t residents f directly affected villages where these are defined as fllws. First preference is given t Mgraib. Secnd preference is given t: Jimel; Ad Ibrihim; Adarat; and Tekreret. Thse resident in directly affected settlements are again t have pririty fr semi-skilled emplyment, fllwed by thse living in Agrdat and Barentu, and the Dighe and Ggne sub-zbas, and then the Zba Gash Barka. Skilled wrkers are t be recruited n a natinwide basis in line with natinal emplyment targets fr the Bisha Prject. The exact nature f the arrangements at the Prt facility have nt been determined, nr has the transprt rute fr Phase 2 and 3 been cnfirmed. BMSC will apply relevant preferential recruitment plicies fr these Prject cmpnents at an apprpriate time during the implementatin prcess. 3.7 Recruitment and Emplyment Prcedures BMSC has develped a number f plicies in relatin t recruitment and emplyee wrking cnditins. These will be summarised in a Human Resurces (HR) Manual. Key recruitment and ther HR prcedures are described belw Identifying Labur Needs Frecasting labur needs in a systematic and cnsistent fashin will be imprtant t ensuring that sufficient time is allwed t find suitable lcal/reginal candidates, particularly fr unskilled psitins, which shuld be readily able t be filled by lcal residents. The general prcedure fr identifying labur needs shall include: Relevant BMSC/SENET Departments will create Emplyment Frecasts fr the relevant psitins required fr their teams (Annex A); Departments shall draw up detailed jb descriptins (identifying whether they are categrised as skilled, semi-skilled r unskilled), emplyment numbers and duratins f emplyment; and BMSC/SENET shall cnduct an audit f current skills available in the lcal area and cmpare it with skills requirements Recruitment Offices Recruitment ffices are an imprtant part f ensuring that recruitment and emplyment prcedures and prcesses are accessible fr lcal/natinal peple, particuarly thse lcated in the five villages nearby t the mine site. Designated recruitment places are als a key mitigatin measure fr managing inmigratin issues related t jb seekers. A recruitment ffice will be established within the fllwing lcatins (as a minimum) during cnstructin: Asmara (at the Head Office); Agrdat (in the Stre Frnt Infrmatin Centre) Barentu (in the Stre Frnt Infrmatin Centre); and Mgraib (mst likely a temprary ffice used n an as needs basis). Scial Management Plans [18/02/2010] Page 46 f 111

47 Bisha Mining Share Cmpany The requirement fr recruitment ffices will be reviewed prir t the peratins phase t determine which centres need t remain r be relcated. The prcedure fr establishing and perating a recruitment ffice shall include: The ffice shuld be established at a suitable lcatin within reasnable prximity frm the persns being targeted fr recruitment, e.g. twn centre r n main bus rute; There shall be suitable infrastructure and equipment such that the ffice can prcess emplyment applicatins; Each ffice is t be adequately staffed (e.g. by an Emplyment Officer) fr the perid between the jb advertisement and the clsing date fr all psitins; Relevant details are t be prvided t allw jb seekers t cmmunicate with the relevant cmpany during emplyment perids, e.g. a htline number, pster(s) with details f the Emplyment Officer and s n; and Recruitment ffices will frm the central pint fr lcal/reginal recruitment activities, and shall be the nly lcatins where recruitment activities may take place Identificatin f Candidates and Applicatin Prcess Applicatin fr Emplyment fr Unskilled Wrkers The Prject expects that lcal/reginal candidates frm the five identified nearest cmmunities, as well as the Dighe and Ggne sub-zbas and then wider Zba Gash Barka, can fill the majrity f unskilled psitins Stage 1: Identificatin f Candidates Prcedures fr identifying ptential candidates fr unskilled psitins will include: Departments will cmplete a Jb Requisitin Frm (see Frms belw) which is t be submitted t the BMSC Human Resurces Manager; All recruitment requests will be reviewed by BMSC prir t advertisements being develped and psted in relevant lcatins; and Advertisements will be prepared by the relevant Department and reviewed by BMSC and the lcal labur ffice/lcal administratr wh will prvide apprpriate apprval fr the advert t be psted (Annex B shws an example advertisement); Advertisements are t be first placed in the lcal villages (e.g. labur ffice in Mgraib) and then expanded t ther villages and als Agrdat and Barentu as required (and then the Zba Gash Barka and natinwide); Screen applicatins and prepare a Shrt-List Frm (see Frms belw) f interested persns accrding t relevant criteria, including: residential lcatin based n preferential hiring plicies, ability t meet ther jb requirements, and wrking experience; Recrd candidates in the emplyment database (shrt-listed and nn-selected candidates t be filed separeatey fr ptential future emplyment); Cntact shrt-listed candidates and arrange interviews and ther testing/screeing that is required; Cmplete a Ptential Candidate Interview Frm (see Frms belw) fr each interviewee and infrm candidates f the relevant emplyment cnditins; Relevant Line Managers (and as apprpriate an Emplyment Officers r ther persnnel management representative) shuld cnduct interviews and make the final selectin; The final selectin must be dcumented n the interview frm and all recrds frwarded t the Human Resurces Department; Scial Management Plans [18/02/2010] Page 47 f 111

48 Bisha Mining Share Cmpany Residents f directly affected villages and then the Dighe and Ggne sub-zbas, fllwed by the Zba Gash Barka will receive pririty fr semi-skilled and skilled emplyment; If there is a shrtage f semi-skilled r skilled wrkers within the pririty areas, the Prject shall select persnnel frm ther the natinal ppulatin; and An explanatin and evidence t be prvided t the BMSC Human Resurces Department where emplyment targets can nt be met (e.g. where an expatriate is required) Stage 2: Applicatin fr Emplyment Prcedures fr managing applicatins fr unskilled psitins will include: Fr unskilled emplyment, lcal residents are t submit an applicatin frm t the Emplyment Officer directly r thrugh the relevant recruitment ffice, r village representative (e.g. Lcal Administratr if apprpriate); Where applicants require assistance with applicatin frms this will be prvided by Emplyment Officers r the village representative; The applicatin frms are t be frwarded t BMSC/SENET Human Resurces Department, fllwing assessment f applicatin frms by the relevant Emplyment Officer; Fr each village, the Emplyment Officer will identify the mst suitable village representative (e.g. Lcal Administratr) fr a crdinating rle this selectin is t be based n BMSC perceptins/experience f wh is mst trusted and respected in the settlement as well as wh is mst willing and able t carry ut this respnsibility; Each applicant is t receive a registered receipt f their applicatin. This receipt is t indicate that the registratin is free f charge and can be used t audit the Emplyment Officer r relevant village representative; If required, applicants may be asked t present an apprpriately authrised dcument shwing lcatin f residence; After the applicatin deadline, the list f applicants is t be prepared by the Emplyment Officer and psted in public places fr a minimum f three days; The list shall als be reviewed by the Human Resurces Department and a relevant village representative; and An applicant may ntify the Emplyment Officer within these three days if he/she is nt n the psted list. Receipt t be prvided as evidence. N late applicatins will be accepted. This mechanism shall be designed t create a fair and transparent system that will ensure that each applicant has been registered Stage 3: Selectin f Candidates Prcedures fr selecting candidates fr unskilled psitins will include: Screen applicatins and prepare a Shrt-List Frm (see Frms belw) f interested persns accrding t relevant criteria, including: residential lcatin based n preferential hiring plicies, ability t meet ther jb requirements, and wrking experience; Prepare a main list and a standby list fr each psitin r grup f psitins frm the screened candidates; Recrd candidates in the emplyment database (shrt-listed and nn-selected candidates t be filed separately fr ptential future emplyment); Pst lists at the recruitment ffices and ther relevant lcatins in the villages and lcal/sub-zba administratin ffices; Scial Management Plans [18/02/2010] Page 48 f 111

49 Bisha Mining Share Cmpany Interviewing f applicants will be cnducted by BMSC/SENET in the Stre Frnt Infrmatin Centres, designated recruitment ffice r ther apprpriate venue such as at site; N applicant (frm a directly affected settlement) will be required t travel fr mre than ne hur n public transprt; If a settlement des nt have access t public transprt r if there are cases where the jurney by public transprt will exceed ne hur, then the Prject will prvide transprtatin fr the applicants cncerned; Fllwing the selectin f applicants, the BMSC/SENET line manager is t ntify the selected persnnel and frward their names/details t the Human Resurces Department; and An explanatin and evidence t be prvided t the BMSC Human Resurces Department where emplyment targets can nt be met (e.g. where a nn-lcal persn is emplyed in an unskilled psitin) Randm Selectin The selectin prcess fr unskilled psitins may require randm selectin. General cnditins and prcedures wuld include: Where the number f screened candidates greatly exceeds the required number f vacancies randm selectin may be required t get a shrt-list; The randm selectin prcess shall be carefully executed in crdinatin with relevant lcal/reginal authrities and respected village respresentatives Disadvantaged Candidates As part f the applicatin prcess, the Prject will cnsider a prcess fr identifying disadvantaged candidates. This wuld likely include prcedures such as: Applicants wuld be required t fill ut an evaluatin frm that assesses the extent t which an applicant is disadvantaged; Emplyment Officers wuld actively take part in this prcess t ensure cnsistency and t verify that the mst disadvantaged sectins f the ppulatin are identified; Any prcess fr evaluating vulnerable/disadvantaged persns must be cmpleted in crdinatin with relevant lcal authrities and village representatives; and The Prject wuld then be required t select emplyees frm the identified disadvantaged grup with apprval frm relevant lcal authrities and village representatives. The purpse f this prcess wuld be t ensure that the mst vulnerable members f the lcal cmmunities have supprt in accessing emplyment pprtunities with the Prject. It wuld als aim t ensure that they are nt further marginalised by prcesses that wuld nrmally be difficult fr them t participate in Age Verificatin In Eritrea the minimum wrking age is 16 years. BMSC als intends t cmply with internatinal standards which require a minimum age f 18 years fr any high risk wrk. Prcedures fr verifying the age f relevant candidates will be implemented by BMSC and will include sme r all f the fllwing: Relevant applicants will be asked t present an apprpriately authrised dcument shwing prf f their age; Where relevant dcumentatin is nt available BMSC will wrk with relevant lcal authrities and cmmunity leaders/families t try t verify an applicant s age; BMSC will infrm applicants where age verificatin is required and keep them infrmed f prgress f such activities; and Scial Management Plans [18/02/2010] Page 49 f 111

50 Bisha Mining Share Cmpany Where minimum age cannt be satisfactrily verified, BMSC will nt prceed with the applicatin prcess Infrmatin Prvisin/Advertisements In Eritrea advertisments are legal papers which shuld be cntrlled by the emplyer and the relevant lcal/reginal authrities. All advertisements must have an apprpriate seal frm the relevant authrities and be psted in designated areas. The advertisement prcess will require at least the fllwing: BMSC will make sure that advertisements are prepared at least ne mnth prir t the psitins needing t be filled; Ensure that there is effective cverage f advertisements in lcal and natinal media, as well as in ther accessible lcatins (e.g. Asmara ffice, public places etc); In additin t advertisements, BMSC will distribute recruitment leaflets and psters in directly affected villages, and sub-zba and Zba centres, e.g. at public places such as bus stps, markets and cffee huses; Other nn-written avenues fr advertising recruitment may als be adpted, e.g. Request Imam t annunce during Friday prayers r Minister during Church services; All infrmatin disclsure regarding emplyment pprtunities and prcesses t be prvided in relevant languages, with particular attentin t lcal dialects fr villages near the mıne site; and Ensure that infrmatin/adverts regarding emplyment d nt raise unrealistic expectatins, the extent and duratin f emplyment t be accurately cmmunicated such that the limitatins t emplyment pprtunities are knwn. An example Advertisement/Vacancy Annuncement is included in Annex B. BMSC shall keep the Department f Mines infrmed abut all upcming vacancy annuncements related t the Prject Prhibitin f Hiring at Wrk Site The Bisha Prject has adpted the plicy nt t hire at wrk sites r cnstructin camps during cnstructin. BMSC/SENET will recruit nly frm designated recruitment ffices and nt via infrmal requests r appraches frm cmmunity members, either at camps r at wrk sites. The prcedure t ensure that adequate infrmatin is prvided abut prhibitin f hiring at wrk sites is as fllws: Apprpriate signs will be installed at all wrk sites, camps, entrance gates, and where practical, at lcatins within lcal/reginal centres themselves (e.g. n jb adverts); Infrmatin disclsed will make it clear that individuals appearing at the jb site that have nt been previusly screened by BMSC/SENET elsewhere WILL NOT BE HIRED; Only nce an individual has been frmally hired, will administratin and ther cmplementary activities such as persnnel badging, and training f emplyees hired lcally, be implemented. This prcedure will be reviewed prir t peratins at which time it may be apprpriate t cnduct n-site recruitment. Hwever, this review will take int cnsideratin past lessns learnt and any current issues related t in-migratin f jb seekers Selected Candidates Once candidates are selected by the relevant BMSC r SENET Department, they are t be prvided with written cntracts that state: Jb descriptin; Scial Management Plans [18/02/2010] Page 50 f 111

51 Hurs; Wrking cnditins; Wage level (nrmal and vertime); Bisha Mining Share Cmpany Rules including Cde f Cnduct and Alchl and Substance Abuse plicy; and Disciplinary prcedures. The cntents f this wrk cntract will be clearly explained t each wrker. An example Emplyment Cntract is shwn in Annex C. Fr temprary emplyees this is a mdified and simpler versin but this shall still cntain the requirements mandated under the Eritrean Labur Law. All permanent and temprary emplyees (e.g. daily laburers) are required t sign the emplyment cntract relevant t the wrk being undertaken Exclusin f Wrkers n Natinal Service The Prclamatin n Natinal Service (N. 82, 1995) states that Natinal Service is bligatry fr any Eritrean citizen and the mandatry length f active service is 18 mnths, fllwed by membership in the Reserve Army until the age f Extensin f active Natinal Service beynd the bligatry 18 mnths is invluntary and use f Natinal Service persnnel fr cmmercial prject wrk cnstitutes frced labur under bth the Mining Agreement between the GE and BMSC and the principal Internatinal Labur Organisatin definitins f and cnventins n frced labur. BMSC and SENET shall ensure that Natinal Service persnnel n extended service are nt used by BMSC r its cntractrs, and dembilisatin certificates shall be required t be kept n file fr all Eritrean wrkers. Cnditins t this effect shall be included in cntracts with all cntractrs. 3.8 Emplyment Cnditins The Human Resurces Department is respnsible fr ensuring that all specific emplyee terms and cnditins are adequately identified, dcumented and made clear t all emplyees (eg. details n prbatin perids, hlidays, vertime, sick leave, absences, visitrs, visas, travel etc). In additin t thse cnditins set ut in the emplyment cntract, BMSC has a Staff Handbk that it prvides t all emplyees befre they cmmence emplyment with the Prject. The handbk prvides further detail and guidance abut wrking cnditins Wages All wages paid fr the Prject shall be in accrdance with Eritrean legislatin. The fllwing prcedures will be emplyed t ensure wage related issues are prperly managed: The calculatin and payment f wages fr all BMSC/SENET and their staff/cntractrs shall be cnsistent with the Eritrean Labur Law; BMSC/SENET and their staff/cntractrs will pay at least the minimum wage fr natinal wrkers in accrdance with the Eritrean Labur Law; BMSC/SENET shall establish apppriate salary scales fr all psitins required during the Prject fr cnstructin and peratins; Wages will be calculated using time sheets that will be filled by timekeepers at sites and then apprved by the relevant manager (e.g. Cnstructin Manager); 4 Terminatin age f bligatry Reserve Army service is given in the Prclamatin as 50 years in sme clauses and 40 r 42 in ther clauses. Scial Management Plans [18/02/2010] Page 51 f 111

52 Bisha Mining Share Cmpany Payment will be n a regular basis (e.g. mnthly basis). Where practical, a lcal bank will be engaged t handle emplyee salary payments thrugh their lcal branches in the nearby villages s as t avid large amunts f cash being handled at cnstructin r ther sites; BMSC/SENET shall investigate pprtunities t supprt emplyees (e.g. particularly Daily Laburers wh are generally paid in cash) t effectively managing their wages; In the event f terminatin f emplyment, emplyees will be paid in accrdance with the Bisha Prject terminatin payment plicy which will be in accrdance with the Eritrean Labur Law; BMSC/SENET will present an infrmatin sessin in each area when initial wage payments are made in rder t explain clearly wrker pay statements (i.e., grss pay, deductins, net pay), answer any questins, and recrd any grievances; Payrll assessments shall be undertaken n BMSC cntractrs t ensure that wrkers are being paid wages cnsistent with prject pay structures and agreed levels and that cntractrs are nt unreasnably withhlding pay frm wrkers (t avid perceptins f wage inequity); and A lg f wage-related grievances shall be maintained, and all grievances will be addressed in accrdance with the BMSC emplyee grievance prcess Wrking Hurs Wrking hurs will be in cmpliance with the Eritrean Labur Law; Wrk hurs fr the Bisha Prject are 10 hurs per day (with a 2 hur break) fr 6 days per week. The standard wrk hurs fr emplyees at the Bisha Prject will therefre be 48 hur per week; Overtime and related cnditins are t fllw Eritrean Labur Law, including strict prvisin fr the maximum number f hurs that can be wrked in any ne perid; and BMSC and cntractrs will cnsult with emplyees where alternative wrking schedules are required t cmplete cnstructin r ther activities in a timely manner Terminatin All wrker terminatins will be perfrmed strictly accrding t Eritrean Labur Law and shall include the fllwing prcedures: At the time f hiring, the likely perid f emplyment and the cnditins fr hiring and layff will be clearly explained t the new recruits and recrded in the emplyment cntract; During regular meetings held with wrker representatives, persnnel management will share infrmatin n the Prject s schedule and ptential frthcming layffs (particularly fr temprary cnstructin jbs); It is the intent f Bisha Prject nt t lay ff large numbers f wrkers n the same day and SENET will be required t apply this plicy; The Prject is respnsible fr returning wrkers t the place where they were recruited r t their dmicile (the place f hire will be specified and transprt service r cst will be cvered) Husing and Feeding Prject Wrkers The Bisha Prject will clearly explain its husing and meal prvisin plicies t all wrkers at the time f recruitment. In particular, each wrker will be clearly tld at the time f his/her hiring what (if any) husing and/r meals will be prvided by their emplyer (e.g. BMSC, SENET r sub-cntractr as relevant) Husing and Feeding f Nn-Lcal Permanent Emplyees During Prject cnstructin activities, the Cntractr s expatriate and nn-lcal Natinal wrkers will be hused in temprary cnstructin camps. Scial Management Plans [18/02/2010] Page 52 f 111

53 Bisha Mining Share Cmpany Natinal and expatriate wrkers residing in Cntractr s camps will be prvided with all meals in camp. The Cntractr will ensure that there is a sufficient supply f fd and ptable water fr all residents f the camps. During Prject peratins, the majrity f BMSC expatriate and nn-lcal Natinal wrkers will als be hused in camps at the site. Other accmmdatin/husing facilities may be develped with lcal authrities (e.g. in Mgraib) at a later stage, hwever the details fr such arrangements have nt yet been cnfirmed Husing and Feeding f Nn-Lcal Temprary Emplyees During bth cnstructin and peratins, nn-lcal temprary emplyees, such as thse persns wh take up a shrt-term cntract with the Prject, will be prvided with meals at the camp. In terms f husing, they will be given an allwance fr accmmdatin that is suitable t find rental husing in a nearby village r twn (e.g. Agrdat) Husing and Feeding f Lcal Prject Wrkers/Daily Laburers All Lcal Natinal wrkers will return t their wn hmes each night and will nt be hused in wrker camps. In additin, Bisha Mining SC/SENET shall supply such wrkers with ptable water at the wrk sites Transprtatin BMSC/SENET will prvide daily bus transprtatin f Lcal wrkers frm their hme villages t preestablished wrk lcatins and back t their hme-villages (including fr nn-lcal temprary wrkers residing in nearby villages). Emplyees may be paid fr travel time at the discretin f the Cmpany where the travel time is deemed t be excessive Clthing fr Wrkers Clthing fr Full-Time Prject Wrkers All full-time wrkers (i.e., thse wh will have an emplyment perid that exceeds 14 days) will be issued a basic unifrm and apprpriate Persnal Prtective Equipment (PPE). Specific craft/field wrkers will be issued additinal apprpriate clthing and PPE as required. Replacements f wrn items may be btained upn return f the riginal item; lst items will be replaced but the cst (less any adjustments fr nrmal wear and tear) will be deducted frm the wrker s salary. Wrker s wuld be ntified in advance f any intended deductin. Emplyees will be allwed t keep the basic utfit f wrk clthes (safety shes, scks, veralls) at the end f their emplyment with the Prject Clthing fr Temprary Prject Wrkers Temprary wrkers will be prvided with the same basic set f wrk clthes as prvided t full-time wrkers fr use n the wrk sites, and apprpriate PPE t perfrm their jb. Such wrkers must return these wrk clthes at the end f their perid f emplyment. Otherwise they will be charged fr the cst f the item adjusted fr nrmal wear and tear. The emplyee will be ntified befre the sum will be deducted frm their salary Laundry BMSC/SENET will prvide laundry services in its camp fr all clthing it distributes t its wrkers. Private clths will be laundered free r charge fr the residents f the camp (within reasnable limits). Wrkers living in camps will fllw arrangements set by camp management. Wrkers living in Lcal husing can wear ne unifrm and hand in a dirty unifrm in exchange fr a clean ne fr the next day s wrk. Scial Management Plans [18/02/2010] Page 53 f 111

54 3.9 Labur Relatins Bisha Mining Share Cmpany The Bisha Prject shall seek t wrk in gd faith with trade unins and ther bdies that emplyees cllectively chse t represent them, within the apprpriate lcal legal framewrk. The Bisha Prject shall nt seek t prevent by any means whatsever the frmatin f trade unins r any ther legally established wrker grup. T maintain strng psitive relatinships with trade unins, the Bisha Prject will act as fllws: BMSC/SENET and ther respnsible parties t cnsult n relevant labur-related regulatins and inspectins required by gvernmental authrities; This may include rates f pay, premium payments, electin f wrker representatives, signing f wrk cntracts, wrking hurs, labur laws, vertime etc; Prvide facilities t labur unin representatives t cnduct their labur relatins activities at all sites, in accrdance with the requirements f current labur cnventins and regulatins; Cmply with the Eritrean Labur Law and any ther regulatins cncerning relatins with authrized labur rganisatins; Line management t cmmunicate with trade unins thrugh meetings, as required, and deal with all prblems r issues regarding emplyment. Line management and the trade unin representative in accrdance with site-specific issues will identify frequency f thse meetings; Recrd and discuss the sessins with BMSC senir management; and All issues t be dealt with and respnded t in a verbal r written manner, with apprpriate recrds maintained Plans T Handle Wrk Stppages/Strikes/Demnstratins Althugh it is unlikely t ccur in Eritrea, it is legal t strike/cnduct stp wrk demnstratins. In case f a stppage f wrk r strike BMSC will: Ensure relevant managers, Cntractrs and ther parties are infrmed (as per Article 115/2); Arrange meeting with designated labur representatives in rder t determine the cause f wrk stppage (as per Article 122); Discuss ptential slutin and if pssible, reach and dcument reslutin (as per Article 123); Discuss agreed slutin with BMSC (and Cntractr where relevant) management and, if necessary with labur fficials frm Gvernment (as per Article 122); Any agreement t return t wrk t be signed by the parties invlved in the dispute, and, as apprpriate, Ministry fficials (as per Article 124); In the event f a cntinuing dispute/wrk stppage, the relevant requirements f the Labur Law are t be exercised, using interventin and arbitratin by lawyers; and Prhibit immediate layffs after a wrk stppage r strike and fllw apprpriate requirements f the Labur Law Emplyee-Related Grievances The Bisha Prject shall establish a grievance prcess fr emplyees. The Human Resurces Department will be respnsible fr this prcess. SENET (and ther relevant cntractrs) shall develp their wn equivalent prcedure r adpt that f BMSC. Grievances related t emplyment and training shall be managed thrugh the fllwing general mechanism: The relevant Line Manager will infrm Human Resurces Department abut emplyment related grievances raised frm his/her emplyees; Scial Management Plans [18/02/2010] Page 54 f 111

55 Bisha Mining Share Cmpany Upn receiving a cmplaint, this Department shall ensure that a Cmplaint Actin Frm is cmpleted. Afterwards Cmplaints Lg shuld be frwarded t relevant Department managers and shuld be apprpriately dealt with and respnded t; The timelines fr pssible actins will be determined upn the nature f the grievance; Line Managers remain respnsible fr tracking the cmplaint and ensuring that it is dealt with. The cmplaints investigatin reprts will be generated and submitted t the Human Resurces Department; and The Human Resurces Department is respnsible fr all grievances related t emplyment/wrking cnditins/training. In additin t the emplyee grievance prcess, BMSC has a Suggestin Bx at the site fr emplyees t register their suggestins and ideas fr emplyee arrangements n site Training Training Prcess Eritrean wrkers will be emplyed and trained during the cnstructin phase, with a view t preparing sme f them fr peratins. The training f Prject wrkers, bth Eritrean natinals and semi-skilled r unskilled lcals, will largely invlve health & safety and ther wrksite inductins and a mix f n the-jb and separate frmalised training. Table 2 shws the general training prcess t be emplyed by the Prject. Table 2: Bisha Prject Training Prcess Training Categry Training Cntent Cmpulsry fr all wrkers Wrk Ethic Training & HSEC Inductin Skills/Craft Training Cnducted by SENET in cnstructin and BMSC in peratins in relevant languages (team wrk, wrk rules, respect, etc.) Safety awareness explaining BMSC/SENET s site safety prcess. Theretical input required fr relevant discipline. OR Practical skills in each discipline imparted in the training institute s varius wrkshps. Training institute/facility instructrs will On the Jb Training crdinate this phase with relevant BMSC/SENET Department. Trainee shall maintain the Lg Bk detailing the wrk carried ut during the n the Jb Training signed ff by their supervisr n a daily basis. The fllwing general mechanisms will be emplyed t ensure that training is prperly delivered: The training prgramme will seek t enhance the skill levels f natinal emplyees t maximise pprtunities t gain emplyment in skilled and semi-skilled rles; Specific training requirements fr wrkers will be determined during the final selectin prcess and recrded n the Jb Interview Frm (see Frms belw); Training will be delivered in relevant languages, e.g. Tigre/Tigrinya/Arabic; Scial Management Plans [18/02/2010] Page 55 f 111

56 Bisha Mining Share Cmpany All training is the respnsibility f the relevant Department and is t be implemented in accrdance with ther relevant systems and prcedures (as lng as they d nt cntradict the details cntained herein); Cmpetency assessment shall be in place fr all relevant training mdules t nt nly assess initial training needs but t als assess the effectiveness f the training itself; N emplyees are t start wrk until minimum training requirements have been satisfied fr their psitin; It is the respnsibility f the relevant Department/line manager t identify additinal training requirements and ntify the the Human Resurces Department; and SENET shall keep BMSC up t date regarding training arrangements and shall seek apprval fr the training prgrammes the cmpany plans t implement Training Facilities The Bisha Prject will establish a training centre (r centres) in Eritrea. The general measures will be emplyed t establish apprpriate training facilities: Training facilities will be prvided with relevant audi-visual aids bks, graphics and multi-lingual supprt t enable training t be given effectively t all levels f persnnel; The Prject will cnsider pprtunities t utilise existing facilities wherever feasible t help maximise use f Eritrean resurces; The use r establishment f any training facilities will be crdinated with relevant lcal, reginal and natinal authrities, as well as ther ptential partners such as training institutes and private cmpanies; and Qualified and experienced training persnnel will be sught t manage training prgrammes and facilities and where this invlves expatriate trainers, skills transfer will be priritised Health, Safety, Envirnmental and Cmmunity (HSEC) Training All emplyees will receive general health, safety, envirnmental, and scial awareness training that emphasizes each emplyee s respnsibility fr cmplying with relevant laws, regulatins, and cmmitments as well as BMSC/SENET plicies and standards. In additin, emplyees will receive safety training in hazard recgnitin, first aid, and cardipulmnary resuscitatin (CPR), emergency respnse prcedures, jb-specific health hazards and safe perating prcedures etc. Inductin training will be prvided fr all new emplyees. Experienced persnnel will prvide peridic specialized training in specific jb tasks as needed n a case-by-case basis. In sme instances, it may be necessary t retain specialty cnsultants t prvide certain specialized training. Cntractrs and cnsultants wh wrk at the Prject will be required t adhere t all f the health, safety, envirnment, and cmmunity plicies and prcedures that BMSC/SENET has cmmitted t thrughut their tenure with the Prject. All persnnel will carry ID and certificatin n site, i.e. a Safety Passprt (with phtgraph), r equivalent, scheme will be perated. Only persns wh are in pssessin f certificatin will be permitted n site. As a minimum, an envirnmental awareness briefing will be prvided as part f the HSEC inductin given t all persnnel emplyed n the prject. In additin, a series f tlbx talks n envirnmental awareness will be delivered as part f the fllw-n prgramme frm the initial inductin briefing. Training fr expatriates and nn-lcal Eritreans will include awareness f natinal sensitivities. Training fr nn-lcal staff and third cuntry natinals will include awareness f lcal cultural sensitivities. Updates n specific lcal issues, such as imprtant religius r cultural dates and tabs will be prvided regularly t emplyees at the site. Scial Management Plans [18/02/2010] Page 56 f 111

57 Bisha Mining Share Cmpany 3.12 Emplyment Data and Dcumentatin Persnnel Database & Recrds System The Human Resurces Department is respnsible fr maintaining a recrd f all persnnel emplyed. SENET are expected t maintain a similar system and share it with BMSC (r make it available fr inspectin). An example Human Resurces Checklist fr each emplyee is shwn in Annex E. The database will cntain infrmatin n the emplyee, cvering his/her terms f emplyment, and will be updated t track changes as they ccur. Such data will include: 3.13 Frms Prject Wrker Status (Lcal/Natinal/Expatriate); Pre-Emplyment Screening Data (Jb Applicatin, Health-Related Data, Skills Testing, Interview Recrds, Infrmatin Verificatin, etc.); Emplyment Date; Jb Classificatin and Wage Histry; Certificatins; Natinal Service dembilisatin certificates; Hurs Wrked; Jb Perfrmance Evaluatins and Skill Advancement/Prmtin Histry; Terminatin Data; and Training Recrds. The Human Resurces Department maintains an inventry f all recruitment prcesses and emplyment dcumentatin arising n site. SENET is als required t ensure a similar prcess is fllwed fr cnstructin activities. A selectin f example frms is prvided belw. The relevant Department requiring emplyees will prepare recruitment request dcumentatin arising frm psitins required n site. SENET will be required t ensure a similar prcess is fllwed fr cnstructin activities. The Bisha Jb Requisitin Frm is as fllws: Scial Management Plans [18/02/2010] Page 57 f 111

58 Bisha Mining Share Cmpany BISHA MINING SHARE COMPANY Jb Requisitin (JR) Frm This frm must be cmpleted and authrized befre any jb is advertised r any jb ffer made. The Cmpany will nt recgnise any ffer made t a candidate unless first apprved by the Human Resurces Manager and the General Manager. Prcess fr cmpleting the frm: 1. Frm t be cmpleted by relevant Manager r Department head. 2. Apprved Jb Descriptin t be attached. 3. Frm t be sent t Human Resurces. 4. Frm t be sent t General Manager fr apprval. Jb Title: Jb Grade: (Human Resurces t cmplete) Jb Lcatin: Duratin f Cntract: Indefinite Perid Definite Perid Intermittent Peridical Wrk Jb Descriptin Attached? Prbatin Perid: Frm Wrk Days/Shift: Other cmments: YES / NO YES / NO YES / NO YES / NO Department: Salary per mnth: (Human Resurces t cmplete) Cmmencement Date: T: Wrking Hurs: RECOMMENDATION: DEPARTMENT MANAGER SIGNATURE: APPROVALS: HUMAN RESOURCES MANAGER: SIGNATURE: GENERAL MANAGER: SIGNATURE DATE: DATE: DATE: Scial Management Plans [18/02/2010] Page 58 f 111

59 Bisha Mining Share Cmpany The relevant Department will prepare a shrt-list arising frm applicatins fr a psitin r psitins. SENET will be required t ensure a similar prcess is fllwed fr cnstructin activities. The Bisha Shrt-List Frm is as fllws: Psitin Applied: Name Age Educatin Natinal Service Related Experience Other Experience Remark Cntact/Telephne Scial Management Plans [18/02/2010] Page 59 f 111

60 Bisha Mining Share Cmpany Fr all psitins a Candidate Applicatin Frm shuld be cmpleted (with assistance frm Emplyment Officer if apprpriate). An example f a Candidate Applicatin Frm is as fllws: Example Candidate Applicatin Frm CANDIDATE APPLICATION FORM Clsing date fr applicatin: Persnal Details LAST NAME (FOR ALL POSITIONS) FIRST NAME AGE Gender Cntact Details City / Village Telephne number (if available) Address Ethnic Origin (This is requested fr infrmatin nly and is nt a requirement. Selectin fr emplyment will in n way depend n ethnic rigin. If yu d nt give this infrmatin, it will nt affect yur applicatin.) Educatin and Wrk Experience Qualificatins Tigre Tigrinya Hidareb Nara Other (please indicate) Educatin Wrk Experience POSITION (S) APPLYING FOR: Manual Labrer Huse keeper Ck Guard Office / clerical Other Scial Management Plans [18/02/2010] Page 60 f 111

61 Bisha Mining Share Cmpany Fr semi-skilled and skilled psitins an interview will be cnducted with each shrt listed candidate individually using a Candidate Evaluatin Frm t assess and recrd relevant persnal/prfessinal attributes. The interviewing Department is required t cmplete the frm and submit t the Human Resurces Department. An example f a Candidate Evaluatin Frm is as fllws: Example Candidate Evaluatin Frm POTENTIAL CANDIDATE INTERVIEW FORM Candidate Name Interviewer Name Open psitin Interview Date N.B: Please keep specific requirements f Psitin in prcess and rate nly thse items that relate t that Psitin Requirement. Interview Questins: 1. Intrduce the Candidate with the Interviewers. By Chair persn 2. Request the Candidate t briefly explain abut himself 3. Invite the Candidate t describe the Basic Functins f the POSITION 4. Request the Candidate t explain the main dcuments r Materials that have t be used in executing the Jb in the POSITION 5. Ask Candidate s Natinal service status 6. Ask Candidate Salary Expectatin PERFORMANCE INDICATORS (Scales: ) Educatinal backgrund Wrk Experience Substance in the Subject matter Cmmunicatin Skill and Reliability Cmputer Skill TOTAL ============ Interviewer Final Cmment Interviewer Signature Date Scial Management Plans [18/02/2010] Page 61 f 111

62 Bisha Mining Share Cmpany 3.14 Rles & Respnsibilities Overall respnsibility fr the implementatin f this Management Plan shall rest with the Bisha Human Resurces Manager wh shall reprt n prgress t the Bisha General Manager. Others with respnsibility fr the implementatin f this Management Plan shall include: SENET, as EPCM Cntractr, shall be respnsible fr the integratin f these prcedures and requirements int their perating prcedures and plans; Bisha Cmmunity Relatins Manager shall be respnsible fr aspects related t interactin with lcal/reginal cmmunities related t emplyment and fr relevant envirnmental and scial training and ther functins; Bisha Emplyment Officers shall be respnsible fr crdinating emplyment related activities at the lcal level and act as the fcal pint fr lcal/natinal peple seeking emplyment with the Prject; and Bisha Mill/Mine Superintendents shall be respnsible fr ensuring that these prcedures and requirements are implemented fr all peratins. BMSC requires that SENET allcate its wn Human Resurces Manager as well as a relevant number f Emplyment Officers t supprt implementatin f the requirements in this plan during the cnstructin phase Mnitring & Reprting It is imprtant t mnitr emplyment and training t ensure that emplyment targets are met and that effrts t enhance lcal and natinal skills and emplyment pprtunities are maximised. Human resurces, emplyment and training mnitring prcedures shall be as fllws: The Bisha Human Resurces Manager shall maintain recrds n the fllwing: Recruitment cnducted; Recruitment and emplyment targets; Hw the Emplyment Database is being maintained; Training cnducted/given t staff and planned; Interviews and randm selectin prcesses; Jb descriptins and selectin criteria; Infrmatin disseminatin regarding emplyment, including vacancy annuncements; Operatin f recruitment ffices; Equities and inequities in recruitment prcess (e.g. gender, ethnicity, age); Emplyee grievances and actins taken; Cases f crruptin and disciplinary actins taken; and Wrking cnditins and related issue. Bisha Human Resurces Manager shall inspect recruitment ffices and BMSC/SENET dcumentatin n mnthly basis and shall maintain apprpriate recrds. The inspectin shall include: Recrds f recruitment prcesses; Recrds f emplyees hired; Recrds f hurs wrked; Recrds f wages paid (and against prject pay structures as a crss reference); Recrds f Natinal Service dembilisatin certificates; Recrds f grievances and f disciplinary actins taken; Cnditin f wrkers n site and wrker camp areas; Recrds f training given t staff; Cnditin and peratin f recruitment ffices; Scial Management Plans [18/02/2010] Page 62 f 111

63 Bisha Mining Share Cmpany Other spt checks f relevant practices and dcumentatin; Cmpliance with applicable regulatry and crprate requirements. SENET will reprt n a mnthly basis t the Bisha Human Resurces Manager n the implementatin f this Management Plan during the cnstructin phase. The Bisha Human Resurces Manager shall be respnsible fr recrd-keeping. Scial Management Plans [18/02/2010] Page 63 f 111

64 Annex A Example Emplyment Frecast Schedule Bisha Mining Share Cmpany ERITREAN RECRUITMENT FORECAST SCHEDULE BISHA PROJECT (EXAMPLE ONLY) Key Dates Dec- 08 Jan- 09 Feb- 09 Mar- 09 Apr- 09 May- 09 Jun- 09 Jul- 09 Aug- 09 Sep- 09 Oct- 09 Nv- 09 Jan- 10 ACTIVITY/SITE TRADES Tracked Excavatr Opp Crane Operatr Grader Operatr Welder Structural Steel Plater Electrician Heavy Duty Drivers Aut Mechanic Aut Electrical Plumber Masn Carpenter Ttal SEMI SKILLED Unlading & Transprt Banksman U/Grund service crew Hand Excavatins Fencing Frnt End Pwer Brush Grinder Pre-heat 4 4 Ttal UNSKILLED Laburers Reinstatement Ttal TOTALS Scial Management Plans [18/02/2010] Page 64 f 111

65 Annex B Example Recruitment Annuncement Bisha Mining Share Cmpany BISHA MINING SHARE COMPANY BISHA MINING SHARE COMPANY INVITES ELIGIBLE APPLICANTS TO APPLY FOR THE FOLLOWING VACANT POSITIONS Infrmatin and Requirements fr all Psitins Place f Wrk: Type f Cntract: Salary: Additinal Reference Date f clsing Bisha (unless indicated therwise) Definite perid As per Cmpany salary scale 1) Prvide evidence f cmpletin r exemptin f natinal service 2) Applicants currently emplyed must hld release paper frm frmer emplyer Applicants must write three references with current address. : 7 days frm the day put in the Cmpany Ntice Bard Address 1: Human Resurces, Bisha Mining Share Cmpany P.O.Bx 4276 Asmara, Eritrea Or 2: Bisha Prject Site, Mgraib Applicatin: Attach all testimnial dcuments (phtcpy nly). Applicatin papers and dcuments will nt be returned back t sender Scial Management Plans [18/02/2010] Page 65 f 111

66 1. Psitin Title CARPENTER Majr Duties and Respnsibilities Bisha Mining Share Cmpany Studies blueprints, specificatin sheet, and drawings t determine style and type f windw r wall panel required. Examines wd surfaces fr defects. Measures and marks lcatin using tape measures, template, and marker. Cuts sidings and muldings, sectin f weatherbard using hand tls and pwer tls. Trims verlapping edges f wd, weatherbard, using prtable pwer saw and hand tls. Installs prefabricated windws and drs, insulatin, wall ceiling and flr panels r sidings, using adhesives, hists hand tls and pwer tls. Aligns and fastens materials tgether using hand tls and pwer tls t frm building. Repairs and replaces defective lcks, hinges, cranks, and pieces f wd using glue, hand tls and pwer tls. Required Qualificatins Lng experience in cnstructin carpentry. Knwledge t use pwer tls, hand tls and tape measures. Gd physical fitness t keep bdy balance and stay uprights in high grund. Ability t read blueprints. Experience in prefabricated huses fittings. English is the wrking language. Psitin Title: LABORERS Majr duties and respnsibilities Apply prtective cverings such as masking tape t articles r areas that culd be damaged r stained by wrk prcesses. Clean wrk areas and equipments and fill cracks r breaks in surfaces f plaster articles r areas with putty r epxy cmpund Erect scafflding and d supprt duties t masns carpenters painters etc. mix plasters Supply r hld tls and materials,smth surfaces t be painted, using sanding and buffing tls and equipments Remve articles such as cabinets, metal furniture, and paint cntainers frm stripping tanks after prescribed perids f time. Required qualificatins Strng and physically fit. Ability t listen and fllw instructins. Experience as a helper in ne r all the cnstructin trades. December 5, 2008 Scial Management Plans [18/02/2010] Page 66 f 111

67 Emplyment Cntract Annex C Example Emplyment Cntract Bisha Mining Share Cmpany This Cntract is made between BISHA MINING SHARE COMPANY, Asmara, hereafter called the Emplyer and Mr. / Mrs., ER. ID Address hereafter called the Emplyee. The Emplyee and the Emplyer hereby agree t enter int a Cntract f Emplyment based n the fllwing Terms and Cnditins: 1. JOB TITLE: The psitin f the Emplyee will be 2. DUTY STATION: the lcatin f wrk place f the Emplyee will be in thugh the emplyee may be required t travel t ther Cmpany lcatins frm time t time. Travel r Transfer will be dne with accrdance f cmpany plicy and the Labur Law f Eritrea. 3. DATE OF HIRE 4. CONTRACT TYPE 5. PROBATION PERIOD 6. SALARY: 7. BENEFITS: 1. The mnthly Grss salary will be 2. Salary is paid at the end f each mnth 3. Salary will be paid in lcal currency i.e. Nakfa 4. The amunt f mnthly salary is determined in accrdance with the internal Cmpany salary scale in frce. 5. Salary reviews will nrmally take place n first f January f each year, but can be delayed at the discretin f the Cmpany. Husing allwance Accmmdatin Transprt Fd allwance Medical allwance If yu suffer a nn-wrkplace related illness the Cmpany will reimburse 100% f the cst f medical treatment up t maximum f Nakfa 7,500 per year. 8. WORKING DAYS: Six days per week r 48 hrs per week 9. ANNUAL LEAVE: a. Yu are entitled fr 14 wrking days fr the first year f service and an additinal ne day per every year f service thereafter up t a maximum f 35 days b. The Cmpany requires annual leave t be taken nt later than tw years. Hwever by mutual agreement c. Annual leave may be taken later than tw years r settled by payment. d. If yu fail t take annual leave within tw years f entitlement yu will frfeit yur entitlement. 10. ADDITIONAL CONDITIONS: a. Any matter nt specifically mentined in this Emplyment Cntract and/r in the Staff Regulatins Plicy and Prcedures shall be cvered by the prvisins f the relevant Labur Laws f Eritrea. b. Yu agree in accepting this psitin perfrm such duties as the Cmpany may designate frm time t time, and devte yur full time and best effrts t the business f the Cmpany. c. Yu agree t hld all the Cmpany infrmatin in cnfidence and yu will nt disclse, use, cpy, publish, distribute r summarize any cnfidential infrmatin, except, (a) as necessary t carry ut Scial Management Plans [18/02/2010] Page 67 f 111

68 Emplyment Cntract Bisha Mining Share Cmpany yur assigned respnsibilities as the a Cmpany Emplyee, r (b) as specifically authrized in writing by the Cmpany. d. Yu shall have an n-ging respnsibility t treat as cnfidential all cnfidential infrmatin prvided t yu by Cmpany and all infrmatin develped by yu n behalf f the Cmpany even after terminatin. e. Yu cnfirm that yu have been released frm Natinal Service and that yu hld a dembilisatin certificate that will be prvided t the Cmpany befre yur emplyment is cnfirmed. f. This Cntract cancels and replaces all previus verbal r written agreements cncluded befre the belw date. Apprved and signed n behalf f the Cmpany by : Afewerki Kebreab Manager, Human Resurces Date Stan Rgers General Manager. Date EMPLOYEE ACCEPTANCE, I have fully understd the Terms and Cnditins f this Cntract and affix my signature belw in agreement with and cnfirmatin f this Cntract f emplyment: Signature Date TWO WITNESSES: 1. Name and Signature 2. Name and Signature Scial Management Plans [18/02/2010] Page 68 f 111

69 Bisha Mining Share Cmpany Emplyee Name Annex D Example Human Resurces Checklist HUMAN RESOURCES CHECKLIST Guide t Internatinal & Lcal Emplyees DOH Applicatin Letter Educatinal Certificate Experience ID Phtcpy Passprt Cpy Natinal Service Medical Certificate Plice Certificate Jb Requisitin Jb Descriptin Interviewers Opinin Emplyment Cntract Payrll Ntificatin Cmpany ID Staff Regulatin Other (If any) Scial Management Plans [18/02/2010] Page 69 f 111

70 Bisha Mining Share Cmpany 4 Cmmunity Assistance Plan (CAP) 4.1 Intrductin The Cmmunity Assistance Plan (CAP) is designed t ensure that the Bisha Prject cntributes beynd direct mining activities, t the scial and ecnmic well-being f the hst cmmunities in which it perates. The aim f the CAP is t ensure that lcal/hst cmmunities will be better ff fr BMSC being there than nt being there. The verall gal f the CAP is t imprve ecnmic cnditins f Eritrea and its citizens thrugh diversifying incme pprtunities, enhancing peple s ability t take advantage f diversified pprtunities, and building lcal gvernment capacity t carry ut its develpment respnsibilities. In shrt, the strategy aims at helping cmmunities enjy greater cntrl ver their livelihds and quality f life, thus facilitating their direct participatin in the larger ecnmic and scial develpment prcess. 4.2 Objectives The specific bjectives f this Plan are t: Establish prcedures fr identifying cmmunity needs, wrking with the cmmunity and ther partners, planning and implementing cmmunity prjects and managing financial arrangements; Define rles and respnsibilities; and Define mnitring and reprting prcedures. 4.3 Scpe The CAP cnsiders the ptential fr prviding cntributins t cmmunity develpment, which are: In additin t actins taken t mitigate direct Prject impacts; Fcused n the Prject affected cmmunities near t the Bisha mine site; Integrated with reginal develpment plans already in place fr cmmunities; Aimed at imprving the health and well-being f the lcal ppulatin; Able t deliver enhanced lcal skills; and Aimed at prviding additinal incme generatin pprtunities fr lcal peple. The plan is a flexible dcument that shall be reviewed n a peridic basis and amended where necessary changes are identified. This plan applies t BMSC, althugh the EPCM Cntractr, SENET, will be expected t supprt the Prject (mstly in-kind) t cntribute t cmmunity assistance during cnstructin. 4.4 Crprate Plicy BMSC has established a plicy regarding Scial Respnsibility that includes the Cmpany s cmmitment t sustainable cmmunity develpment and sets ut the gals that frm the basis fr all develpment activities spnsred by the Cmpany. 4.5 Apprach t Cmmunity Assistance The BMSC apprach t cmmunity develpment includes the fllwing guiding principles: Crdinatin with the Eritrean gvernment is critical fr successful implementatin, hence: BMSC will wrk clsely with varius gvernment agencies and ministries t c-rdinate lcal develpment pririties with reginal/natinal prgrammes in rder t create a cherent develpment prcess; Prpsals fr specific cmmunity develpment initiatives will be intrduced t natinal and Zba level gvernments first, prir t final apprval; Scial Management Plans [18/02/2010] Page 70 f 111

71 Bisha Mining Share Cmpany It is expected that line ministries within Gash Barka as well as lcal authrities will take the lead n cmmunity assistance initiatives in cllabratin with BMSC (e.g. Department f Agriculture in Barentu wuld lead agriculture extensin service prjects t be implemented); Any external implementing partners that may be required will be intrduced t the gvernment and the cmmunity prir t any visits t the area; and BMSC shall cnsult with gvernment n the best apprach t allcate cmmunity assistance funds including hw this infrmatin shuld be disclsed t the Prject area ppulatin and ther interested parties. Cmmunity develpment initiatives shuld benefit the cmmunity as a whle r a large prtin f the cmmunity (rather than individual husehlds); It is the eths f BMSC that nly independent prjects that have wnership within the cmmunity will deliver sustainable and develpment beynd the life f the mine; Initiatives that cntribe t r prmte the health and well-being f cmmunities are a pririty fr funding, and vulnerable and disadvantaged grups will als be targeted; Eritrean rganisatins and gvernment agencies will prvide expertise in the design, planning and achievement f develpment gals; Partnerships will be used t allw the Cmpany t tie its cmmunity assistance prjects int lnger term prgrammes and plans fr the Dighe and Ggne sub-zbas, Zba Gash Barka and the cuntry as a whle (Annex A prvides details f several ptential partners in the CAP); All prjects that are prpsed fr implementatin under the plan will be carefully reviewed t ensure that the gals and bjectives are in line with thse f BMSC; and Prject prpsals must demnstrate hw the prject benefits will be sustainable in the lng-term and funds shuld nt be used fr supprting the perating csts f prjects. Funding under the CAP will nt be available fr the fllwing types f activities: Plitical actins r supprt fr gvernment unrelated t cmmunity develpment; Scial bligatins (such as weddings r funerals) r activities that are directed at individual gain; Prgrammes which are nt fcused n the cmmunities and residents affected by the mine, althugh district and reginal prgrammes will be cnsidered; Prgrammes which d nt demnstrate a sustainable benefit t the cmmunity r are nt supprted by the cmmunity; and Prgrammes that discriminate accrding t religin, ethnic grup, age r gender (prgrams targeted at a particular segment f the ppulatin must clearly shw why the prpsed beneficiaries require special assistance). 4.6 The Need fr Cmmunity Develpment The Bisha Prject area is characterised by a rural setting, with a narrw ecnmic base, that is heavily dependent n subsistence agriculture, particularly pastralism (which is the predminant livelihd activity fr mst cmmunities). The Prject is in a regin where there are acute unmet develpment needs. Much f the public and scial infrastructure, such as schls and health clinics, cnsist f basic buildings and equipment. Clean water supply and sanitatin facilities are lacking in many areas. Studies cnducted fr the purpse f the Bisha Prject scial and envirnmental assessment highlight a range f sci-ecnmic cnditins that further demnstrate the current needs f lcal area cmmunities. The Prject has cnducted an initial assessment f cmmunity develpment needs during cnstructin activities. The needs assessment shall be reviewed (and re-dne if necessary) at least annually, e.g. at the beginning f each year, t ensure the pririties identified remain relevant. Scial Management Plans [18/02/2010] Page 71 f 111

72 Bisha Mining Share Cmpany 4.7 Management f the CAP The CAP will evlve thrugh varius stages f prpsal, planning, selectin, implementatin and evaluatin, and a variety f parties will be invlved at each stage. In rder t effectively manage cmmunity assistance prjects, BMSC will implement the fllwing management prcesses and practices Cmmunity Assistance Steering Cmmittee BMSC will cntinue t facilitate discussins with its Bard, relevant gvernment agencies and Zba and sub-zba administratrs t establish a multi-stakehlder frum fr develping and implementing cmmunity assistance prjects. A Steering Cmmittee (r similar) will be established and is likely t include the fllwing: The Cmmunity Relatins Manager will be respnsible fr the setup f the Steering Cmmittee, including terms f reference fr its peratin and the lgistics and fund management; The Steering Cmmittee will have primary respnsibility fr the selectin, mnitring, evaluatin and reprting f prjects and activities implemented thrugh the CAP; Initially the Steering Cmmittee shall be part f the management structure f BMSC, directed by the General Manager and funded by BMSC n an annual basis; The Steering Cmmittee will initially be frmed f representatives f BMSC, the lcal cmmunity, as well as Zba/sub-Zba and lcal gvernment; The Steering Cmmittee shall be respnsible fr the apprval f recmmended prjects and will cnduct a mnitring prcess t evaluate the success f the varius initiatives; and The Steering Cmmittee may eventually be adapted t becme a Fundatin that can act as an autnmus rganisatin with its wn scial develpment agenda based n resurces. The fllwing specific steps will be required t establish the Steering Cmmittee, and shall be implemented by BMSC, preferably by early in the peratins phase: Preparatin f a definitive terms f reference fr the Steering Cmmittee; Selectin f criteria fr membership n the Steering Cmmittee; Establishment f the Steering Cmmittee; Develpment f perating prcedures fr the selectin, apprval and executin f prgrams; Preparatin f administrative and accunting prcedures; Selectin and cntracting with an audit firm; and Establishment f mnitring, evaluatin and reprting prcedures, including thse fr regular reprting t BMSC management and lcal cmmunities. It is envisaged that the Steering Cmmittee wuld include the fllwing initial membership (which shuld generally be nt mre than 15 members): Bisha General Manager; Bisha Cmmunity Relatins Manager; Bisha Finance Manager; Gvernment Representatives: e.g. relevant natinal level authrities, 01 each frm sub-zba Dighe and Ggne, 01 frm Zba Gash Barka; and A Nn-Gvernmental r Quasi-gvernment representative, e.g. frm a reputable NGO, r a relevant representative frm the Natinal Unin f Eritrean Wmen. Scial Management Plans [18/02/2010] Page 72 f 111

73 4.7.2 Cmmunity Actin Grup Bisha Mining Share Cmpany In rder t achieve effective cmmunity mbilisatin, the Steering Cmmittee will be supprted in the day t day management and implementatin f the cmmunity assistance prgram by a Cmmunity Actin Grup. The Cmmunity Actin Grup will generally include the fllwing: The Cmmunity Actin Grup shall cmprise a selectin f lcal peple wh are elected t act n behalf f their cmmunities t wrk with gvernment, BMSC and ther relevant partners; The Grup shall cmprise an equal number f representatives frm each f the five Prject affected villages as well as relevant reginal representatives (e.g. frm Agrdat and/r Barentu) t facilitate planning fr initiatives that need t be implemented n a wider basis; The Cmmunity Actin Grup will crdinate cmmunity input int identifying, planning, implementing and mnitring cmmunity develpment prjects fr the Bisha Prject; and The Cmmunity Actin Grup shall rganise wrking teams at each cmmunity, as needed, fr each apprved prject t be implemented Financial Arrangements BMSC will establish an annual budget fr cmmunity assistance. Prir t prductin, BMSC has defined an initial budget fr cmmunity assistance which has been apprved by the Bard fr the year This initial budget shall be reviewed at the end f 2009 and additinal funds allcated fr the remainder f the cnstructin phase. The funds available prir t peratins will be fcused n establishing pilt prjects (r shrt term investments ) that can be develped ver time t create sustainable cmmunity initiatives. By the peratins phase, BMSC will implement the fllwing financial arrangements: Prir t prductin at the mine, an annual budget shall be estimated fr at least Years 1 t 3 f peratins; Early in the peratins phase, the annual budget shall be cnfirmed and will be based n the actual prductin level frm the preceding financial year (r a similar cncept); A minimum amunt fr cmmunity assistance shuld als be set regardless f prductin levels; BMSC will seek financial independence fr its CAP in the lng-term with respect t fundraising and financial activities, t achieve sustainability fllwing the cessatin f mining activities and financial supprt by BMSC; and Wherever feasible, the allcated budget will be leveraged fr maximum return value thrugh partnerships and fund matching with varius rganisatins in bth the private and public sectrs. BMSC cntributins t cmmunity assistance will be used t directly imprve cnditins in the lcal cmmunities and as such, it is imprtant t use as much f the cntributin in the early years as is pssible t ffset the impacts f cnstructin. BMSC will investigate the establishment f an escrw accunt at the cmmencement f peratins t put aside a small stipend (perhaps 1 t 3 %) int escrw each year. During later years f mine peratins, the feasibility and benefits f apprtining a greater percentage f BMSC cntributins int escrw will be examined. Earnings frm the escrw accunt wuld then be available t prvide fr develpment initiatives fllwing clsure f the mine and withdrawal f active BMSC supprt. 4.8 Target Stakehlders Cmmunity assistance initiatives are intended t benefit the wider Eritrean cmmunity, with particular emphasis at least in the near term n Prject area cmmunities and lcal Gvernment. The five cmmunities nearest the Prject area are the intended beneficiaries f the prgramme. As such, these prgrams are nt directly part f the cmpensatin and ther entitlements intended fr peple wh are affected by land acquisitin r ther scial impacts related t the Prject. Peple wh are directly affected by land acquisitin, hwever, are entitled t participate in cmmunity assistance prgrams. The cmmunity assistance initiatives that will be implemented thrugh this plan are in Scial Management Plans [18/02/2010] Page 73 f 111

74 Bisha Mining Share Cmpany additin t the mitigatin measures that will be implemented t minimise/ffset impacts. Cmmunity assistance initiatives will be fcused n enhancement f ptential benefits Target Cmmunities There are n permanent settlements within the Prject mine ftprint. Hwever, the Prject des affect seasnal dwellings, limited agricultural land, and herder activities in the Bisha area. Grazing land in the ftprint was used by members f nearby cmmunities prir t mine develpment. Fr the Bisha Prject the direct scial zne f influence has been identified t include the five villages lcated nearest t the mine area (Figure 1), which are: Mgraib; Adarat; Ad Ibrihim; Tekreret; and Jimel. Figure 1 Prject Lcatin and Target Cmmunities Scial Management Plans [18/02/2010] Page 74 f 111

75 Bisha Mining Share Cmpany These will be the target cmmunities fr the CAP and further details are prvided in the SEIA Update Reprt Vulnerable and Disadvantaged Grups Based n studies cnducted fr the Bisha Prject and available research and literature, BMSC has identified the fllwing ptentially vulnerable r disadvantaged grups: Wmen and female-headed husehlds; Rural drught-affected residents and cmmunities; Elderly and infirm; and War-affected residents and refugees, including thse wh lst assets during the war. 4.9 Specific Actins CAP cmpnents respnd t the current dependence n subsistence activities, the need fr fd security, and the need fr mre prfitable and diverse incme pprtunities and develpment activities. Table 1 shws the indicative categries and bjectives fr the next 3-5 years. TABLE 1 SUMMARY OF THE COMMUNITY ASSISTANCE PROGRAM Categry Objectives Prvide lcal cmmunities with a safety net. Cmmercialise land based prducts. Increase crp prductivity thrugh prgrams such as mre intensive Land based prductivity land use, imprved seeds, different crps, and the use f inputs. Increase animal prductivity thrugh prgrams such as imprved animal husbandry practices, new breeds, quality cntrl, veterinary prgrams, range land imprvements, and develpment f watering hles. Maximise the number f Eritreans wh can be emplyed by the Prject Training and skills develpment thrugh special cnstructin and mine training prgrams. Enhance lcal skills thrugh land-based and nn-farm training initiatives fr lcal peple. Small and medium enterprise Maximize the ecnmic benefits that flw frm the Prject t the (SME) develpment regin and the cuntry. Help diversify lcal peple s incme streams. Increase lcal peple s incme and imprve their standard f living. Increase lcal peple s access t credit. Micr-credit lans Enhance mney management thrugh educatin and awareness. Enhance lcal transprtatin rutes t facilitate transitin t a mre cash-based ecnmy and allw residents t participate in the ecnmic activity generated by the Prject and ther pprtunities. Imprve sanitatin facilities and practices in the Prject s area f Infrastructure and services influence. Imprve the supply f safe drinking water. Expand prvisin f electricity utside the immediate prject ftprint where feasible, e.g. using a pay-as-yu-use, self-sustaining mdel. Imprve husing stck t meet requirements f a grwing ppulatin. Increase lcal access t staffed and equipped health facilities. Health and sanitatin Imprve the quality f the health care prvided in lcal facilities. Imprve the management f majr health care facilities. Educatin Expand access t staffed schls in the Prject s area f influence. Imprve the quality f the educatin at lcal schls. Scial Management Plans [18/02/2010] Page 75 f 111

76 4.10 Current Initiatives Bisha Mining Share Cmpany In respnse t acute develpment needs, and t the cmmencement f cnstructin wrks, BMSC has already began the planning and implementatin f urgent prjects under the CAP Infrastructure Prjects Detailed planning has been cmpleted fr several initial infrastructure rehabilitatin prjects and funds have been cmmitted by BMSC twards these prjects. Additinal investigatin and planning wrk by the Steering Cmmittee and Cmmunity Actin Grup will als be required t develp these prjects and initiatives t the pint where they can be implemented Cultural Heritage Prjects BMSC has been wrking clsely with lcal residents f Mgraib, lcal authrities and the Natinal Museum t prtect cultural heritage f the area and recver artefacts and ther materials where needed. A range f artefacts have been cllected as part f clearance activities and lcal peple have expressed a desire t establish a lcal museum t huse the lcally significant artefacts. BMSC has cmmitted t fund the lcal museum in Mgraib t huse the existing artefacts and any future discveries in the nearby area. BMSC will als cmpensate in-kind, the village f Mgraib, fr the disruptin caused t burial sites and cultural heritage f the area. A cmmunity assistance prject will be identified with Mgraib residents and the lcal authrities, and funded by BMSC (preliminarily agreed at 250,000 Nakfa r apprximately USD $16,000). These measures are scheduled fr implementatin by mid Agricultural Extensin An Agriculture Imprvement Prgram (including bth crps and animal husbandry) will initially be fcused n prviding a safety net fr cmmunities, while mving tward develping mre cmmercial agriculture ( agbiz ) pprtunities thrugh utput intensificatin, cmplimented by business develpment training and ther kinds f supprt. Accelerated grwth must invlve a transitin t mre intensive farming and imprved husbandry/livestck prtectin, applying increased inputs t farms, prmting livestck/crp integratin, increasing crp diversificatin, and imprving access t technical expertise, inputs, agricultural technlgy and credit. Prgramme design will be based n further technical and market based assessment. Prject implementatin will be dne in clse cllabratin the Ministry f Agriculture and their relevant ffices in Agrdat and Barentu. Land based prductivity prgrams will initially be implemented in accrdance with the Land Use Management Plan and fcused n cmmunities affected by land acquisitin. Hwever these initiatives will eventually be integrated with the cmmunity assistance prgram and as such, are expected t be extended t ther cmmunities in the Prject area Infrastructure Rehabilitatin Prjects BMSC has been wrking clsely with stakehlders in the area t develp a funded cmmunity prject which addresses the mst immediate scial-service prblems f the target cmmunities (Tekreret, Ad Ibrihim, Mgraib, Jimel and Adarat) and which, fr the investment level t be apprved, will have maximum psitive impact n the livelihd f their residents. BMSC believes that it can best benefit the area by adding t and reinfrcing existing infrastructure and facilities, rather than building new, islated facilities. Taking lcal inputs int accunt (thrugh an initial cmmunity needs assessment), BMSC has put tgether the elements f a cmprehensive, but scpelimited interventin which can be described as fllws: Rehabilitatin f dilapidated classrm buildings, teachers drmitries and administratin buildings replacing rfs blwn away by windstrms, cmpleting walls, installing new drs and Scial Management Plans [18/02/2010] Page 76 f 111

77 Bisha Mining Share Cmpany windws, fitting windws with glass panes and screens, prviding additinal classrm desks t ffset shrtages and repairing brken nes, install decent blackbards etc; Imprvement f facilities in existing health clinics - e.g. repair f slar pwer installatins, install new (r fix nn-functinal) indr plumbing, prvide extra rms fr use as shrt-term accmmdatin fr referral bund in-patients; and Rehabilitatin and expansin f cmmunity water supply systems: Prvide and install slar pump systems, reservirs and public funtains; carry ut pipeline extensins t effect huse r yard cnnectins (at schls, teachers drmitries, clinics and their staff residence), put a dysfunctinal cmmunity livestck-watering facility back int peratin. Table 2 prvides a summary f the actual wrks t be cmpleted fr each f the three prjects that are in the detailed planning phase. BMSC has cmpleted the detailed planning fr these initiatives and expects t start implementatin by mid The prpsed prjects will be implemented under the directin and supervisin f a civil engineer wh will be assigned t the prject by BMSC. T the extent pssible, residents f each f the beneficiary villages will be hired t perfrm all skilled, semi-skilled and unskilled (i.e. manual labur) rehabilitatin tasks that will be implemented in their respective cmmunities; and will be cmpensated at current market rates fr the area. TABLE 2 PROJECTS PROPOSED FOR COMMUNITY ASSISTANCE PROGRAM IN 2009 Summary Resurces/Budget Mgraib Partial replacement f rfing fr a classrm building; prvisin f drs, windws and screens as replacement; supply blackbards, additinal desks and repair brken nes; Install yard cnnectin t teachers drmitry and huse cnnectin t clinic and staff residence; repair f clinics dysfunctinal indr plumbing; extensin f water supply pipeline t abve lcatins; cmplete and renvate partially cmpleted shelters fr use as additinal classrms. Ad Ibrihim Cnstruct a new teachers drmitry t replace ne that had cllapsed; rehabilitate a dysfunctinal cmmunity livestck watering facility; install a slar pump n an existing brehle alng with cnstructin f a reservir and public funtains. Tekreret Cmplete walls and install rfing n abandned Village Administratin Building; Ditt fr abandned classrm building unit and teachers residence building; install replacement drs, windws and screens fr the abve; Cnstruct a 6-bed prefabricated rm as additin t existing clinic; implement extensin f water supply pipeline t prvide a yard cnnectin t the clinic. Budget estimate = USD 62,579 (apprx.) BMSC t prvide additinal resurces including transprtatin, supplementary building materials, key technical staff, Bisha camp facilities (e.g. mechanical wrkshp Budget estimate = USD 46,663 (apprx.). BMSC t prvide additinal resurces including transprtatin, supplementary building materials, key technical staff, Bisha camp facilities (e.g. mechanical wrkshp Budget estimate = USD 27,410 (apprx.). BMSC t prvide additinal resurces including transprtatin, supplementary building materials, key technical staff, Bisha camp facilities (e.g. mechanical wrkshp The ttal prject cst indicated in the Bill f Quantities (see Table 3) that has been develped is likely t exceed the initial budget that BMSC has allcated fr BMSC will therefre review prject tasks and adpt a phased implementatin apprach fcusing n thse cnsidered f high pririty. The implementatin f the remaining tasks will be deferred until such time as additinal funds becme available (r fund matching is achieved) Lcal Wrker Training Prgramme BMSC is cmmitted t hiring lcal/natinal residents and will examine ways f increasing the skills base f emplyees, fr example thrugh apprenticeship prgrammes and prviding basic literacy and skills training fr a prtin f the lcal ppulatin. Prjects t prmte adult technical training and skills develpment may include, but nt be limited t: Scial Management Plans [18/02/2010] Page 77 f 111

78 Bisha Mining Share Cmpany Skills training fr lcal residents within relevant areas related t mine activities (e.g. driving, catering, cking, husekeeping etc); Establishment f skills develpment centres; Educatinal supprt in the frm f grants and schlarships; Supply f teaching and learning materials; Supprt f the few private training clleges in the regin which ffer training and skills develpment; and Supprt fr mine supply cntracts t lcal SMEs and t help them develp new and imprved skills and expertise in their business. T identify relevant training and skills develpment pprtunities fr lcal residents, BMSC will cnsider the fllwing general activities: Examine adult educatin and training needs and ways in which they can be achieved in affected cmmunities; Supprt the literacy prgramme being run by the Ministry f Educatin in Zba Gash Barka, with a particular fcus n Prject affected cmmunities; Build linkages with the Ministry f Labur and Human Welfare ffice in Agrdat t supprt their existing effrts in training lcal peple (e.g. in carpentry, metalwrk, bricklaying, mechanical, electrical and ther skills); Build linkages with the Ministry f Agricutlure and Ministry f Health in Barentu which ffer specalised training curses in land-based and health areas; Investigate the pprtunity t supprt the re-pening f the vcatinal schl (r similar) in Agrdat with the Ministry f Educatin; and Establish partnership prgrammes with technical/vcatinal training clleges r ther schls in Asmara r ther relevant regins t help with training the mining wrkfrce that will be required Health and Sanitatin Awareness BMSC has identified that there is a need t increase awareness f cmmunicable diseases and sanitatin, and t imprve the capacity f lcal health clinics. This part f the CAP will cnsider the fllwing activities: Health examinatins fr cmmunities and residents, and supprt fr specific medical prgrammes, e.g. fr lder residents t have cataract surgeries; Capacity building and supprt fr the reginal health centre and its netwrk at village level, e.g. thrugh training t health clinic staff, training f traditinal midwives; Supprt fr maternal and child health care, including thrugh training kindergarten staff n nutritin and fd safety, prviding mthers with knwledge and skills n child care and rganising rehabilitatin fr malnurished children; Educatin and preventin related t sexually transmitted diseases (including HIV/AIDS) such as health educatin, prvisin f cndms at the mine site and health clinics, treatment prgrammes and vluntary and cnfidential testing; and Supprt existing r planned lcal health service initiatives thrugh in-kind supprt r direct funding initiatives. T identify relevant health and sanitatin awareness raising pprtunities within lcal cmmunities, BMSC will cnsider the fllwing general activities: Scial Management Plans [18/02/2010] Page 78 f 111

79 Bisha Mining Share Cmpany Meet with lcal/reginal health fficials and btain their feedback abut pririty areas f health and sanitatin awareness; Cnduct a health needs assessment fr all villages, fcusing n health incidences, health facilities and health educatin in schls; and Prepare initial training and educatin materials and distribute thrugh apprpriate channels, particularly related t health and well-being issues that may be affected by mine activities, e.g. cmmunicable diseases Small and Medium Enterprise Develpment A rbust and diverse small and medium-sized enterprise (SME) system will be established thrugh capacity building, access t credit, and market linkages. BMSC will act as an initial market and will supprt prgrammes that build lcal business capacity t meet sme Prject needs, bth during cnstructin and peratins. This supprt may include: Prviding existing and ptential small business peratrs with business management and ther relevant training; Supprting peratrs in buying prducts and equipment t perate their businesses; Supprt in establishing lcal enterprises t supprt sme f the services and needs that will arise frm the Prject and ut f ppulatin influx int the area due t the Prject; Supprt in establishing service teams (e.g. staffed by vulnerable grups) t becme subcntractrs fr the Cmpany; and Supprt t establish r expand lcal/reginal market areas, prviding pprtunities fr additinal small businesses t be perated at these markets. T identify relevant SME develpment pprtunities and help establish businesses that can supply t the mine and beynd, BMSC will cnsider the fllwing general activities: Dcument lcal supply and prcurement capacity in the area, including an inventry f what is available, and circulate t Prject teams t prmte lcal prcurement; Dcument the required gds and services the mine will need during the different phases f the Prject, including cnstructin and peratins, and disclse this t lcal/reginal cmmunities; Build prcurement linkages with lcal businesses as well as identify new markets fr thse businesses. BMSC shall require SENET t prvide a detailed descriptin f the gds and services required during cnstructin, as well as the requirements that need t be met t supply such gds and services, e.g. perfrmance criteria Micr-Credit Lans Small micr credit lans can prvide essential supprt fr develpment f lcal industry and businesses. Prmtin and supprt f alternative surces f incme will help t reduce lcal dependence n the mine as an incme surce, mitigate the cntinuing effects f ppulatin grwth and pressure n available agricultural land and help ensure sustainability f the area fllwing mine clsure. Prjects which will generally be cnsidered fr micr credit lans will be thse that relate t the types f develpment initiatives in this plan such as, agricultural imprvement activities and SME develpment r expansin. Mney management educatin and awareness will als be priritised by BMSC, either in cllabratin with r separate t specific micr credit schemes. BMSC will cnsider where micr-credit schemes might be apprpriate and shall investigate partnerships with relevant credit prviders r ther agencies that can facilitate micr-lans n behalf f the Cmpany. Scial Management Plans [18/02/2010] Page 79 f 111

80 Individuals Champining Prmising Prjects Bisha Mining Share Cmpany On the thery that success breeds success, BMSC will priritise prjects that shw significant prmise fr success and that have individuals r rganisatins that are willing t champin their develpment and implementatin. As lng as a prpnent, r prpnent grup, is champining a prject that is cnsistent with BMSC s cmmunity assistance prgram, if the prject has a gd chance f being successful, BMSC will encurage the Steering Cmmittee t cnsider these prjects n a pririty basis Prject Apprval Prcess Prject Prpsal The selectin prcess fr prjects requires the Cmmunity Actin Grup, under the directin f the Public Cnsultatin Officer, t submit prject prpsals t the Steering Cmmittee. The prject prpsals t be submitted will include, at a minimum: A needs assessment, including hw the prject cntributes t the BMSC cmmunity assistance prgramme bjectives; A detailed descriptin f the prject including its target grup and lcatin; Intended utcmes and targets; Indicative budgets; Implementatin prcess, including respnsibilities and timelines; and Mnitring and evaluatin prcess. A CAP Prject Prpsal Frm (see Frms belw) shall be prepared t capture the relevant infrmatin fr each prpsed prject prpsal, and this can then be submitted t the Steering Cmmittee fr apprval Review f Prject Prpsals It is the intent f BMSC t use a structured apprach t prject planning. On receipt f the Prject Prpsal frm the Cmmunity Actin Grup, the Steering Cmmittee will appraise each prject n the basis f a range f criteria, including the fllwing: Cmmunity needs basis: prjects must be designed in cnsultatin with cmmunities and ther relevant stakehlders; Impact: prjects must deliver material and measurable scial and/r ecnmic benefits t cmmunities directly r indirectly affected by the mine; Sustainability: prjects must be designed t deliver lasting benefits, by securing matching funding and/r building increased self-reliance amng affected cmmunities (e.g. ecnmic efficiency, lng term human capacity building etc); Plicy cntributin: prjects shuld illustrate hw they cmply with BMSC s crprate plicies and lcal bligatins with regards t scial investment; Transparency: prgrammes and prjects must be transparent and pen t internal and external scrutiny t allw ptential beneficiaries and lcal authrities t understand the apprach; Preventin f duplicatin: in selecting prjects, all effrts must be taken t avid duplicating the effrts f ther cmpanies, natinal and lcal agencies r gvernment departments; Scial Management Plans [18/02/2010] Page 80 f 111

81 Bisha Mining Share Cmpany Enhancing linkages: in selecting prjects, due cnsideratin must be given t the verall prtfli f activities and initiatives being undertaken by BMSC, its cntractrs and lcal and reginal develpment plans, t ensure prjects are cmplimentary and build n existing successes and relatinships; Measurement: clear targets and measurements f success fr the prject must be identified; Budget and price: in selecting prjects, cnsideratin fr the budget and price must be made in the verall cntext f the funds available versus the target audience and intended utcmes; and Best practice: BMSC must select prjects that are best practice in scial investment in Eritrea. Each prject shall be identified and recmmended using this selectin and assessment prcess. The prject develpment, apprval and implementatin prcess is summarised belw: Step 1. Step 2. Step 3. Step 4. Step 5. Step 6. Step 7. Step 8. Step 9. Identificatin f a ptential prject by the Cmmunity Actin Grup; Develpment f the prject prpsal by BMSC staff tgether with the Cmmunity Actin Grup; Discussin f the prject by the Steering Cmmittee including budget prpsal; Discussin f the prject with the relevant village, sub-zba and/r Zba authrities and key members f the lcal cmmunities; Negtiatin f final cnditins and arrangements with the partner rganisatin/s; Final discussin and apprval f the prject by the Steering Cmmittee; If prject apprved, allcatin f prject funding by the Steering Cmmittee; If prject apprved, cmpletin f prject dcumentatin and any apprpriate implementatin prcedures; If prject apprved, intrductin f apprpriate mnitring and evaluatin prcesses Infrmatin Prvisin related t Cmmunity Assistance Activities BMSC shall distribute infrmatin n the CAP that will be available t lcal peple during cnstructin and peratins. The infrmatin disclsure prcedure shall include at least the fllwing: Prvisin f the BMSC apprach t cmmunity assistance e.g. in a leaflet describing relevant plicies and prcedures t Zba, sub-zba and lcal authrities; Distributin f cmmunity assistance infrmatin in directly affected villages, e.g. at Stre Frnts and ther relevant public places; Other nn-written avenues fr prmting cmmunity assistance pprtunities shall als be adpted, e.g. Request Imam t annunce during Friday prayers, r Priest during Sunday church services; All infrmatin disclsure regarding cmmunity assisstance pprtunities t be prvided in relevant languages, with particular attentin t lcal dialects fr Prject affected villages; Publicatin f a summary f the cmmunity assistance prjects being planned and implemented in Prject-affected cmmunities s that residents can readily see when pprtunities/initiatives will be cming up in their area (and t highlight the equal distributin f develpment initiatives by the Cmpany); and Ensure that infrmatin n cmmunity assistance initiatives des nt raise unrealistic expectatins, the extent and duratin f cmmunity assistance prjects shuld be accurately cmmunicated. Scial Management Plans [18/02/2010] Page 81 f 111

82 Bisha Mining Share Cmpany Infrmatin related t the CAP shall be apprved by relevant authrities wherever necessary prir t its disclsure. BMSC will keep the Department f Mines, as well as relevant implementing partners and agencies regularly infrmed abut upcming cmmunity assistance activities related t the Prject Cmmunity Assistance Data and Dcumentatin Cmmunity Assistance Database & Recrds System A recrds system/database will be established by BMSC t capture infrmatin abut the cmmunity assistance planning prcess. Infrmatin shall be recrded fr each prject regardless f the value f the cntributin r where it was implemented, and will be updated t track changes as they ccur. Such data will include: Prject descriptin and status (Lcal/Reginal/Natinal); Prject planning and implementatin details; Implementing partners, including a partnership assessment; Fund disbursement histry; Cmmencement (and cmpletin) dates; Steering Cmmittee inputs and apprvals; and Perfrmance mnitring and evaluatin. The HSEC Department is respnsible t ensure that all the abve mentined infrmatin is cmpleted and btained fr each cmmunity assistance initiative and related activities Frms The HSEC Department will maintain an inventry f all cmmunity assistance dcumentatin related t the Prject. A selectin f example frms is prvided belw. Fr all prject prpsals a Cmmunity Prject Prpsal Frm shuld be cmpleted (by the Cmmunity Actin Grup with supprt frm the Public Cnsultatin Officer). An example f a Cmmunity Prject Prpsal Frm is as fllws: Example Cmmunity Prject Prpsal Frm COMMUNITY PROJECT PROPOSAL FORM Prblem/Issue: E.g. Lw crp prductin Descriptin: Lcatin: Village 1 Opprtunity: Imprved farming Actins Resurces Needed Wh Will Prvide 1. E.g. Use f Manure Date t Start Wh Will Fllw UP 2. Terracing Agriculture 3. Extensin Service Advice Other ntes: Cmpleted by: Details apprved by: Scial Management Plans [18/02/2010] Page 82 f 111

83 Bisha Mining Share Cmpany 4.13 Rles & Respnsibilities Overall respnsibility fr the implementatin f this Management Plan shall rest with the Bisha Cmmunity Relatins Manager wh shall reprt n prgress t the Bisha HSEC Manager. Others with respnsibility fr the implementatin f this Management Plan shall include: SENET, as EPCM Cntractr, shall be respnsible fr the integratin f these prcedures and requirements int their perating prcedures and plans; Bisha Public Cnsultatin Officer shall be respnsible fr identifying lcal/reginal cmmunity needs, and fr managing activities f implementing partners and related functins; Bisha Finance Manager shall be respnsible fr ensuring that financial arrangements and requirements in this plan are implemented in accrdance with financial plicies and legislatin gverning BMSC; and Bisha Mill/Mine Superintendents shall be respnsible fr ensuring that these prcedures and requirements are implemented fr all peratins Mnitring & Reprting It is imprtant t mnitr cmmunity develpment activities t ensure that cmmitments are met and that effrts t make imprve health and well-being f lcal cmmunities are maximised. Cmmunity assistance mnitring prcedures shall be as fllws: The Bisha Public Cnsultatin Officer shall mnitr the implementatin f the cmmunity assistance prgram and reprt t the Bisha Cmmunity Relatins Manager n at least a quarterly basis, including: The number and value f prjects supprted fr cmmunity assistance; Villages benefiting frm imprved water, sanitatin r ther similar systems; New r imprved infrastructure develpments funded; Training, skills develpment and capacity building prvided including the number f sessins held and number f peple trained; The number f awareness raising materials distributed t target stakehlders; Public attitudes t cmmunity develpment initiatives; and Perfrmance f the Cmmunity Actin Grup and implementing partners. The Bisha Cmmunity Relatins Manager shall inspect cmmunity assistance prjects and dcumentatin n a quarterly basis and shall maintain apprpriate recrds. The inspectin shall include: Recrds f cmmunity assistance activities/meetings/events; Recrds f funds disbursed; Feedback frm lcal cmmunities related t prjects implemented; Recrds f training given t cmmunities; Cnditin and peratin f specific prjects (e.g. fr infrastructure prjects); Status f prjects already implemented; Review f prjects being planned; Spt checks n the activities f the Cmmunity Actin Grup; and Review f prgress and perfrmance f implementing partners r peratrs. The Bisha Cmmunity Relatins Manager shall reqprt findings frm regular inspectins t the cmmunity assistance Steering Cmmittee; Scial Management Plans [18/02/2010] Page 83 f 111

84 Bisha Mining Share Cmpany Each prject r initiative t be funded by BMSC as part f the cmmunity assistance prgram shall have its wn specific mnitring and evaluatin prcedures; and The Cmmunity Actin Grup shall participate in mnitring Prject prgress f cmmunity assistance prjects and related activities. The Bisha Public Cnsultatin Officer shall be respnsible fr recrd-keeping. Regular reprting shall be undertaken via the mnthly SEMS Reprt that shall be prepared and submitted t the Bisha General Manager. Reprting shall include: A summary f activities undertaken during the reprting perid; Any material deviatins r nn-cmpliances t this Management Plan; Planned activities during the next reprting perid; Any ther issues f cncern. Further infrmatin n scial mnitring and reprting requirements and prcedures is set ut in the Mnitring Plan and in the Scial & Envirnmental Management System. Scial Management Plans [18/02/2010] Page 84 f 111

85 Bisha Mining Share Cmpany Annex A Ptential Partners fr the Cmmunity Assistance Plan (CAP) Gvernment Agencies and Departments The Gvernment f Eritrea and in particular the Zba and sub-zba line ministries and lcal authrities will be central t all activities related t the Bisha cmmunity assistance prgram. Natinal, reginal and lcal gvernments have spnsred and implemented varius prgrams aimed at pverty reductin and verall rehabilitatin in Eritrea. As such, there is experience in sme f the ministries and assciated institutins, which will be valuable in planning and implementing prjects in the Bisha area. Such ministries and agencies include but are nt limited t, the fllwing: Ministry f Land, Water & Envirnment; Ministry f Agriculture; Ministry f Fisheries; Ministry f Health; Ministry f Labur & Human Welfare; Ministry f Natinal Develpment; Ministry f Transprt & Cmmunicatins; Ministry f Trade & Industry; and The Natinal Museum f Eritrea Educatin Facilities and Training Prviders Building lcal capacity and prviding lng-term skills imprvement pprtunities t lcal peple, is central t all f BMSC s scial prgrams, including cmmunity assistance initiatives that will be implemented thrugh this plan. Hwever, there is a severe shrtage f training supprt centres, universities, vcatinal training enterprises and private sectr training prviders bth cuntry-wide, as well as in the lcal and reginal areas. Hwever, there is a shrtage f training supprt centres, universities, vcatinal training enterprises and private sectr training prviders bth cuntry-wide, as well as in the lcal and reginal areas. BMSC has been in discussins with the Ministry f Educatin t research training prviders in Eritrea. There are tw types f training prviders that have either recently been perating r are perating currently: 1) Technical and Vcatinal Training; and 2) Skill Develpment Centers. Technical and Vcatinal Training The Ministry f Educatin is perating a natinwide Technical and Vcatinal Training Prgram implementing curses fr secndary schl students. Originally this prgram was a three year prgram where Grade 9 students entered the curse fr three years training in a technical Diplma. Hwever, as f 2008 the prgram changed t fcus n entry fr Grade 12 students t receive a ne year training curse. The training centres that are in peratin are: Wina Tech Schl Nakfa (Zba Semenawi Keih Bahri) Asmara Tech Schl Asmara (Zba Maekel) Maihabar Tech Schl Maihabar (Zba Debub) Dmbsk Tech Schl Dekamare (Zba Debub) Hagaz Tech & Agricultural Schl Hagaz (Zba Anseba) Sawa Tech Schl Sawa (Zba Gash Barka) Archive & Library Science Asmara (Zba Maekel) Skill Develpment Centres A range f training prgrams used t be in place t admit students wh cmpleted at least 5th t 6th grade f schling. They were funded by NGOs but nw the prgram has cmpletely stpped. The Skill Develpment Centres were: Scial Management Plans [18/02/2010] Page 85 f 111

86 Bisha Mining Share Cmpany Mai-Atal (Zba Semenawi Keih Bahri) Agrdat (Zba Gash Barka) Mendefera (Zba Debub) Adi Keih (Zba Debub) Haicta (Zba Gash Barka) The training equipment frm all the centres is nt available tday except thse f Mendefera and Adi Keih, accrding t the Ministry f Educatin. Hwever, special arrangements culd reprtedly be made if there is a need fr training grups at these centres in cnsultatin with the Ministry. BMSC will seek t supprt the imprvement and expansin f educatin facilities and training prviders thrugh the cmmunity assistance prgram, t build capacity in the regin, and thus imprve the ptins fr partnering with lcal educatin/training prviders n future initiatives Private Sectr Organisatins An imprtant categry f ptential partners fr the cmmunity assistance prgram is the private sectr. Private sectr rganisatins may be able t ffer direct jb pprtunities and related skills training, particularly in nn-farm based incme generatin activities. The scarcity f agricultural land and cnversin f existing lands t mining peratins by the Bisha Prject will result in nn-agricultural industries and rganisatins playing an increasingly imprtant rle in the nging ecnmic develpment f the lcal area. BMSC intends t prmte the intrductin and expansin f ther industries in the area as part f its apprach t cmmunity assistance. Industrial diversificatin and expansin will be particularly imprtant fr lcal cmmunities after mine clsure. In the Zba Gash Barka and the lcal area there are a number f cmmercial plantatins in peratin, and there are als lime prcessing plants which currently prvides sme lcal residents with seasnal wage labur. BMSC will seek t partner with existing rganisatins where there is an bvius synergy between the assistance being delivered and a cmpany s cmmercial activities Cmmunity Based Organisatins There are very few typical cmmunity-based grups r rganisatins active in the Prject area. Hwever, prmtin f cmmunity interests and lcal rganisatinal develpment is facilitated thrugh unins that are part f Eritrean civil sciety. Unins are ne f the mst imprtant channels f cmmunicatin frm the gvernment t lcal peple, and play a rle in implementing plicy. The Natinal Unin f Eritrean Wmen (NUEW) fr example, has had gd success in prpagating gvernment prgrammes in basic health and sanitatin. Other majr grups include the Ppular Frnt fr Demcracy and Justice (PFDJ) and the Natinal Unin f Eritrean Yuth (NUEY). BMSC has engaged with a range f unins at varius levels thrugh its activities t date, and will seek t build n its existing relatinships as part f the cmmunity assistance prgram. Lcal develpment cmmittees at the village-level als play a great rle in making linkages between the cmmunity and the gvernment, thugh this is usually in larger villages/twns. BMSC anticipate wrking mst clsely with these village-level cmmittees as they will be critical t defining and implementing assistance prjects t ensure that they are wned by the cmmunity. Scial Management Plans [18/02/2010] Page 86 f 111

87 Bisha Mining Share Cmpany 5 Land Use Management Plan 5.1 Intrductin The Land Use Management Plan is designed t ensure that the BMSC mitigates and/r cmpensates fr impacts t land and land use that will ccur as a result f the Bisha Prject. The 2006 baseline studies and resulting Scial and Envirnmental Impact Assessment (SEIA) reprt characterised the land use situatin in the Bisha regin and a preliminary list f Prject affected peple and cmmunities was prepared. At the same time, a range f ptential mitigatin strategies fr landbased impacts were prpsed by BMSC and the Eritrean gvernment apprved this dcumentatin in 2008 when it granted the Mining License. N permanent residential was land identified in the Prject area, althugh sme seasnal dwellings had been cnstructed by herders fr use thrughut the year. A limited amunt f pprtunistic crp cultivatin was als identified, but the majrity f land in the Prject area was classified as rangelands, used by herders frm a number f nearby cmmunities fr dmestic livestck. Cnstructin wrks have nw cmmenced in the Prject area, therefre mst land access issues and related impacts have already ccurred. Sme negtiatins and actins have been implemented t mitigate land use impacts since 2006, and further data and infrmatin has been gathered abut the peple and cmmunities affected by land take fr the Prject. Specifically, actins were taken by gvernment t allcate replacement land fr agricultural plts within the Prject area, and BMSC has prvided sme in-kind supprt services including prviding equipment fr the preparatin f replacement land fr cultivatin. Hwever, further wrk is required, particularly in relatin t impacts t farmers and herders that were previusly perating within the area. Additinal measures need t be identified t mitigate land-based effects and t ensure that affected peple/villages are nt wrse ff as a result f the Prject. 5.2 Objectives The bjectives f this Management Plan are t: Establish effective plans and prcedures t mitigate the effects f land take fr the mine and ancillary facilities t ensure that affected peple are nt wrse ff as a result f the Prject; Define BMSC requirements and prcedures t guide the Prject Management Team and ther Prject cntractrs; Define rles and respnsibilities; and Define mnitring and reprting prcedures. 5.3 Scpe The plan cnsiders ptentially adverse impacts related t: Land take fr the Prject; Lss f prductive agricultural land; Lss f access t grazing land; Lss f seasnal dwellings; Lss f access t ther assets such as water pints; and Affects t livestck migratin and related practices. The plan is a flexible dcument that shall be reviewed n a peridic basis. This plan applies t BMSC, althugh the EPCM Cntractr, SENET, will be expected t supprt the Prject (mstly in-kind) t cntribute t land use management activities during cnstructin. Assciated plans which als incrprate activities related t lcal cmmunities include the Cmmunity Assistance Plan which deals with prviding sustainable cmmunity assistance t thse affected and the Cultural Heritage Management Plan that seeks t ensure the prtectin and safeguard f lcal cultural heritage/resurces. Scial Management Plans [18/02/2010] Page 87 f 111

88 5.4 Regulatry Requirements Crprate Plicy Bisha Mining Share Cmpany BMSC has established a plicy regarding Scial Respnsibility that includes the Cmpany s cmmitment t respecting land use rights and addressing scial issues thrugh active cnsultatin with lcal cmmunities Eritrean Requirements The Eritrean Land Prclamatin (Prclamatin N. 58/1994) declares that all land is the prperty f the State. This indicates that the village cmmunity has n cllective wnership ver land, but the Gvernment allws villages t have cntinuus use and cntrl ver farmlands, rangelands and water resurces. The law states the fllwing, which are mst relevant t the Prject: Every Eritrean citizen is entitled t land usufruct with regard t agriculture and residential land ( Tiesa ) regardless f rigin, sex and religin; Accrding t the Prclamatin land alltted shall be registered and granted in the name f the recipient usufructuary; the usufructuary shall use the land fr his/her lifetime; An usufructuary may, in exchange fr a fixed quantity f agricultural prducts, grant the right t use part f all f his/her land t any persn, wh wuld cntribute labur r xen, r bth r ther farming implements; An usufructuary may lease his/her right ver land in whle r in part and duratin f cntracts shall be determined by an agreement t be made between the parties; The gvernment r apprpriate gvernment bdy shall have the right and pwer t exprpriate land that peple have been settling n r land that has been used by thers, fr varius develpment and capital investment aimed at natinal cnstructin; and A gvernment bdy that exprpriates land in accrdance t this prvisin shall pay cmpensatin fr given assets that may be built n the land but nt fr land itself Internatinal Finance Crpratin Guidelines Internatinal Finance Crpratin (IFC) Perfrmance Standards fr Scial and Envirnmental Sustainability set ut a range f recmmendatins with regard t land acquisitin and invluntary resettlement (Perfrmance Standard #5) 5. BMSC will cmply with requirements f IFC Perfrmance Standard 5 that are relevant t the Bisha Prject. Key requirements include: The cncepts f physical displacement (lss f shelter) and f ecnmic displaced (lss f means f livelihd); bth Physically Displaced and Ecnmically Displaced Peple are t be cnsidered in resettlement planning; The Prject shall mitigate adverse scial and ecnmic impacts frm land acquisitin r restrictins n affected persns use f land by: (i) prviding cmpensatin fr lss f assets at replacement cst; and (ii) ensuring that resettlement activities are implemented with apprpriate disclsure f infrmatin, cnsultatin, and the infrmed participatin f thse affected; The Prject shall imprve r at least restre the livelihds and standards f living f displaced persns; The Prject is expected t ffer displaced persns and cmmunities cmpensatin fr lss f assets at full replacement cst and ther assistance t help them imprve r at least restre their standards f living r livelihds ; Where livelihds f displaced persns are land-based, r where land is cllectively wned, the client will ffer land-based cmpensatin, where feasible ; 5 Internatinal Finance Crpratin. Perfrmance Standards fr Scial and Envirnmental Sustainability; Perfrmance Standard #2. 30 April pp Scial Management Plans [18/02/2010] Page 88 f 111

89 Bisha Mining Share Cmpany The Prject is t cnsult with and facilitate the infrmed participatin f affected persns and cmmunities, including hst cmmunities, in decisin-making prcesses related t resettlement. Cnsultatin will cntinue during the implementatin, mnitring, and evaluatin ; The Prject is expected t establish a grievance mechanism cnsistent with Perfrmance Standard 1 t receive and address specific cncerns abut cmpensatin and relcatin that are raised by displaced persns r members f hst cmmunities, including a recurse mechanism designed t reslve disputes in an impartial manner ; The Prject is expected t carry ut a census with apprpriate sci-ecnmic baseline data t identify the persns wh will be displaced by the prject, t determine wh will be eligible fr cmpensatin and assistance, and t discurage inflw f peple wh are ineligible fr these benefits. In the absence f hst gvernment prcedures, the client will establish a cut-ff date fr eligibility. Infrmatin regarding the cut-ff date will be well dcumented and disseminated thrughut the prject area ; If land acquisitin fr the prject causes lss f incme r livelihd, regardless f whether r nt the affected peple are physically displaced, the client will cmpensate ecnmically displaced persns fr lss f assets r access t assets at full replacement cst and meet a range f ther supprt related requirements. A summary f the measures that the Prject is taking (and intends t take) relating t cmpliance with IFC requirements is prvided in Annex Practical Implicatins f the Legal Cntext fr the Bisha Prject The pre-prject land tenure situatin in the Bisha area was relatively cmplex but can be summarised by the fllwing: Residential land is allcated t all husehlds in designated villages, hwever, wnership rights ver seasnal/permanent dwellilngs are nt frmally allcated thrugh either land use title r ccupatin license granted by the relevant authrities; Agricultural land is allcated t husehlds, with each family generally having between 1 t 4 hectares f land f varying quality, althugh pprtunistic crp cultivatin is als practiced by families frm time t time (there are certain families that claim the agricultural plts in the Prject area); Grazing land is cmmunal prperty; hence every member f the cmmunity has equal access t use the grazing land and, in the Bisha area, villagers have develped their wn mechanism f managing and cntrlling their grazing land; The rangelands f the Bisha area are used by livestck riginating frm lcal cmmunities such as Mgraib, Ad-Ibrihim, and Adarat fr mst f the year, hwever during the dry seasn, and in particular the latter part f the seasn, sme f the lcal herds migrate t ther areas t access available frage and water; and A security zne has been established arund the Prject area (which limits access by lcal cmmunities t the Prject site as well as ther land utside the site as defined by the gvernment) Eritrean Law and IFC s Requirements The main difference between natinal legislatin and internatinal land acquisitin instruments is that Eritrean law cncentrates n cmpensatin fr lst assets. The requirements f internatinal gd practice are livelihd-riented instead: displaced peple must be restred in their livelihd, and must be n wrse-ff after displacement. Emphasis must be put nt nly n cmpensating lst assets but als n assisting peple t restre incmes, ways f life and livelihds. This includes access t incme-earning pprtunities such as agricultural prductin r t natural resurces deemed critical fr subsistence. Eritrean legislatin des nt prvide fr cmpensatin fr lss f land (as all land is state-wned). Perfrmance Standard 5 n the ther hand, stipulates that where physical replacement f the land is nt pssible, cmpensatin at full replacement cst shuld be prvided. Scial Management Plans [18/02/2010] Page 89 f 111

90 Bisha Mining Share Cmpany If land is nt available r if natinal plicy des nt prvide fr cmpensatin, nn-land based ptins, including emplyment pprtunities, assistance t establish businesses r dedicated supprt services shuld be prvided. It is als imprtant t nte, that in Eritrea the majrity f steps f the land acquisitin and cmpensatin prcess must be implemented by the Eritrean gvernment. A summary f ptential landuse impacts is prvided in Annex 2 t this plan. 5.5 Apprach t Land Use Management The BMSC apprach t land use management is driven by the fllwing bjectives: Mitigatin measures, including any cmpensatin fr Prject-affected persns, will be carried ut in cmpliance with Eritrean legislatin and nly with the apprval f relevant gvernment representatives; BMSC shall als seek t cmply with the IFC s requirements; Impacts frm permanent r temprary land acquisitin n assets and livelihds will be mitigated, and bth physical and ecnmic displacement will be taken int cnsideratin; Affected livelihds will be restred as a minimum, r preferably imprved, and living cnditins f affected husehlds will be imprved; Cash cmpensatin is nt a preferable methd f cmpensatin fr land use effects as a result f the Bisha Prject (gvernment d nt agree there is a need t cmpensate fr use f state wned land r assets n such land), hwever cmpensatin will be prvided in-kind; Families affected by the lss f cultivated land and/r seasnal dwellings will be prvided with inkind supprt fr land-based activities r nn-land based ptins including emplyment, in additin t the measures allcated by gvernment; All mitigatin measures related t grazing land and assciated assets will be delivered at the cmmunity-level since the predminant impacts relate t lss f access t land used by varius herders frm a number f nearby villages; The implementatin and utcmes f this plan will be mnitred and evaluated as part f a transparent prcess invlving independent parties; The cmplaints management prcess established fr the Prject will als be used t handle land use-related cmplaints (and shall be audited at regular intervals); and Affected families and cmmunities will be engaged, infrmed and cnsulted during the curse f plan develpment, implementatin and evaluatin. 5.6 Wrk Undertaken t Date BMSC has cmpleted r been invlved with, the fllwing activities related t land use management since 2006: Cnducted baseline studies, including three field surveys and preliminary census f affected land and assets in the lcal study area, including current and histrical land use and wnership claims (2006); Cnsultatin with a number f ptentially affected families and cmmunities during preparatin f the impact assessment fr infrmatin/discussin including land use and cmpensatin issues; Cnducted studies n ptential lsses t grazing/rangeland in the Bisha area (these lsses are nt easy t assess in view f the changes in land tenure in Eritrea in the 1990 s where all wnership was transferred t the state); Prepared land use maps and reprts describing the different agricultural and ther land units in the lcal study area (2006); Cnducted studies int the habits and habitats f dmestic livestck in the Bisha regin, including mapping lcal and reginal migratin rutes and assessing frage/feeding patterns (2006); Scial Management Plans [18/02/2010] Page 90 f 111

91 Bisha Mining Share Cmpany Supprted gvernment activities t prvide replacement land fr 19 families affected by lss f agricultural land in the Prject area (2008); and Rented a tractr fr farmers (displaced frm farming near the Bisha mine) t plugh their new agricultural land that was allcated by the lcal/reginal authrities in the Mgraib diversin channel area (2008). 5.7 General Mitigatin Measures Backgrund A range f mitigatin strategies were prpsed in the riginal SEIA reprt t address land use impacts. Cmmitments were made t prvide apprpriate cmpensatin and ther cntributins t families/cmmunities affected by land take fr the Prject. These strategies have been reviewed and develped int general mitigatin measures that mre clsely reflect the actual impacts f the Prject. The fllwing sectins briefly describe the apprach t mitigatin prpsed fr each impact categry. Table 2 prvides further detail f the general mitigatin measures/entitlements prpsed fr each impact categry as well as sme f the measures that have been implemented t date Dwellings Impacts t dwellings (seasnal/permanent) will need t be mitigated/cmpensated at the individual/husehld level. It is prpsed t prvide replacement wd fr huts and ther negtiated in-kind supprt (rather than cash) r give preference fr emplyment with the Prject (thrugh apprpriate training) Recently Cultivated Land Impacts t agricultural land will need t be mitigated/cmpensated at the individual/husehld level. Mitigatin/cmpensatin fr the lss f cultivated land has been partly addressed since the 19 affected families were allcated 2 ha each f replalement land by the lcal authrities. At this time, BMSC prvided in-kind supprt by renting a tractr fr plughing befre the first rainy seasn. Hwever, further inputs are needed t ensure that adequate mitigatin is achieved. It is prpsed t firstly rehabilitate the diversin channel nearby t the replacement land t imprve access t water. In additin, it is recmmended t prvide ther farm inputs and services t affected families thrugh an Agriculture Imprvement Prgramme r t give preference fr emplyment with the Prject (thrugh apprpriate training) (see Sectin 1.9 belw) Grazing/Fallw Lands and Assciated Assets All impacts t lands defined as rangelands, grazing land and fallw land within the Prject area will be mitigated/cmpensated at the cmmunity level nly. This land is cmmunal prperty and every member f the cmmunity has equal access t these areas. It is recmmended t prvide grazing, herding and animal husbandry supprt, as well as replacement water pints t affected cmmunities thrugh an Agriculture Imprvement Prgramme. Table 2 belw prvides a summary f land-use impacts and mitigatin measures assciated with the Bisha mining prject. Scial Management Plans [18/02/2010] Page 91 f 111

92 Bisha Mining Share Cmpany Table 2 Mitigatin Measures Prpsed fr Land Use Impacts frm Bisha Prject Affected Land/Peple/Asset Affected Right / Eligibility Descriptin/Actin Taken t Date Seasnal/Permanent Dwellings 2 permanent residents in fur huts (in mine area) 8 seasnal dwellings (in mine area) And Greater than 10 dwellings frm ld Bisha village Agricultural Land Apprx. 40 hectares f recently cultivated land 2 residents f Ad Faid clan (ne hut each fr living, and ne each fr gats) 5 dwellings near Bisha Main belnging t Ad Humed Sheik clan plus 3 dwellings near Fereketetet River belnging t Ad Faid clan) And Greater than 10 dwellings f ld Bisha 19 families f Debuk and Ad Humed Sheik clan in Mgraib Rangelands/Grazing Land (including Fallw Land) Estimated 875 hectares f fallw land / range land (including lcal migratin crridr and access t water pints) Cmmunities f Adarat, Ad- Ibrihim and Mgraib Permanent dwellings within mine ftprint can n lnger be used by ccupants. Dwellings dismantled reprtedly by military fr security zne purpses (nt by BMSC). Tw residents are elderly and s it is nt feasible t ffer emplyment as ptin fr livelihd cntinuatin. Seasnal dwellings within mine ftprint can n lnger be used by ccupants. Dwellings dismantled reprtedly by military fr security zne purpses (nt by BMSC). Census f affected families cnducted. 19 families identified as affected by lss f recently cultivated land. Replacement plts f 2 hectares per family allcated thrugh the traditinal cmmunity land mechanism. BMSC prvided in-kind supprt t farmers by renting tractr fr plughing befre rainy seasn. N specific actin t date. Cmmunity supprt t be delivered exclusively in kind and directed at cmmunity level; nt individual herders. Specific Mitigatin/Actin Prpsed Replacement hut (r negtiated in-kind supprt fr resident); but must ensure individuals have ther secure shelter. In-kind supprt fr any ther assets assciated with the dwelling such a well r ther structures. Membership in Agriculture Imprvement Prgramme (see Annex C) including supprt relevant t age grup, e.g. animal husbandry. Replacement wd fr huts (and relevant supprt t re-establish hut in anther lcatin) OR ther in-kind supprt preferred by family (e.g. 3-5 gats r access t water/well). Since residence is nt permanent, n requirement t find replacement plt f residential land. OR Preference fr emplyment with the Prject shuld be given t thse affected by lss f seasnal dwellings t mitigate livelihd effects (but training critical). Rehabilitate the diversin channel in the Mgraib area t imprve access t water. Membership in Agriculture Imprvement Prgramme (see Annex C) t prvide farm inputs and services. OR Preference fr emplyment with the Prject shuld be given t families affected by lss f prductive land t mitigate livelihd effects (but training critical). Replacement f water pints affected in Mgraib River area fr Mgraib and Adarat herders. Membership in Agriculture Imprvement Prgramme (see Annex C) t prvide farm inputs and services, mdern grazing facilities. Scial Management Plans [18/02/2010] Page 92 f 111

93 Bisha Mining Share Cmpany 5.8 Agriculture Imprvement Prgramme Gals and Objectives The main gal f the Agriculture Imprvement Prgramme is t maintain r exceed pre-prject levels f agr-pastralism activities and/r crp prductivity; t supprt livelihd cntinuatin f peple in affected cmmunities. The specific bjectives f the Agriculture Imprvement Prgramme (including bth crps and animal husbandry) will need t be fcused n mitigating the actual effects frm land and asset lsses and shall therefre be determined by BMSC in due curse Beneficiaries The three villages f Mgraib, Adarat and Ad Ibrihim that are affected by land take in the mine area are the intended beneficiaries f the Prgramme. Hwever, the Prgramme culd be extended t ther villages later n such as Tekreret and Jimel as part f wider cmmunity assistance activities Phases f the Prgramme The Agriculture Imprvement Prgramme will be implemented in tw phases: Phase 1: Cmmunities directly impacted by land acquisitin (shrt-term prjects t specifically address land take impacts frm the Prject); and Phase 2: Land-based initiatives fr brader cmmunity assistance (medium-term investments fr land based prductivity prgrammes that will be integrated with the cmmunity assistance prgramme). Phase 1 land-based initiatives will respnd t addressing impacts fr thse cmmunities that have been directly affected by land acquisitin. These measures will be implemented as a matter f pririty fr the Prject and will have a finite timeframe. The verificatin f land and asset lsses and seasnal and cultivatin elements will dictate the length f the Prgramme. BMSC will integrate Phase 2 land-based initiatives int the cmmunity assistance prgramme and target all Prject affected cmmunities. These initiatives will be further develped during the peratins phase thrugh the Cmmunity Assistance Plan Phase 1: Land Based Assistance BMSC prpses t ffer a limited range f land based prductivity measures based n the prvisin f standard field inputs and extensin services. Therefre, the prgramme wuld be expected t include initiatives such as: Field inputs and supprt: Land clearing and weeding; Fertilisers and pesticides; and Crp strage assistance, seeds and s n. Agricultural extensin services: Agricultural training; Animal husbandry supprt; and Educatin and training fr herders/agr-pastralists. Access t water/irrigatin: Drilling f wells and generatrs t pump; Building and rehabilitating diversin channels; and Assistance t prtect rain-fed crps. Establishing mdern grazing facilities and frage imprvements. Business planning and training (e.g. mney/financial management, marketing and grup management). Scial Management Plans [18/02/2010] Page 93 f 111

94 Bisha Mining Share Cmpany BMSC will cllabrate with lcal cmmunities, gvernment and in particular the relevant branch ffices f the Ministry f Agriculture, t cnduct relevant technical and market assessments and cmplete detailed planning Vulnerable Grups Vulnerable peple are peple wh by virtue f gender, ethnicity, age, physical r mental disability, ecnmic disadvantage, r scial status, may be mre adversely affected by land acquisitin than thers and wh may be limited in their ability t claim r take advantage f land-based assistance and related develpment benefits. BMSC will wrk with lcal authrities t identify vulnerable peple that have been affected by land take as a result f the Prject, and may require specific assistance and mnitring. Assistance may take varius frms, depending upn the requests and needs f each vulnerable persn and the cntext f the effects frm land take fr the Prject: Assistance t access the prgramme; Assistance t btain training and access emplyment pprtunities either directly r indirectly with the Prject; Help t make sure their pprtunities fr assistance are well understd and in accrdance with what they need fr imprving their livelihds; and Cunselling in matters such as family, health, mney management, and livelihd cntinuatin Budget Rather than calculating an amunt based n the surface area f rangeland each cmmunity has user rights/claims t, r the number f livestck using the rangeland in the Prject area (which wuld be very cmplex r impssible), it is prpsed t allcate each affected village the same verall budget. A budget shall be develped by BMSC fr Phase 1. This is initially expected t be in the rder f USD $25,000 plus, fr each village althugh this is t be cnfirmed by BMSC Timing It is expected that Phase 1 can begin by the end f 2009, depending n detailed planning and cnsultatin. Further assessment wrk and detailed planning is expected t take apprximately 3 4 mnths. Hwever, sme prjects and initiatives may need t be implemented t parallel with the rainy seasn, and therefre a number f activities might need t be pstpned until Overall the implementatin f the plan is anticipated t be cmpleted early in the prductin phase (e.g. apprximately end 2011). At the same time, there are a number f smaller initiatives prpsed that culd likely be implemented readily befre this time, upn agreement frm all parties (e.g. rehabilitatin f diversin channel near Mgraib River). These are quick hit (and lw cst) activities that include existing cmmitments made t cmmunities. If apprpriate, these measures shuld nt be delayed due t ther planning prcesses. 5.9 Land Use Management Prcedures Assess Land and Asset Lsses An assessment f the specific impact lsses t individual husehlds and cmmunities frm land take is required t determine if the mitigatin measures prpsed meet relevant standards and the needs f affected cmmunities. T this end, BMSC will: Cnduct an assessment f impacts frm land take fr the Prject and cnfirm specific husehlds/individuals and cmmunities affected; Cnduct cnsultatin with gvernment and affected cmmunities t adequately characterise the affects frm land and asset lsses; Target the assessment t enable the BMSC t distinguish the impact f the Prject frm the impact f the security zne; Scial Management Plans [18/02/2010] Page 94 f 111

95 Bisha Mining Share Cmpany Ensure the assessment includes analysis f the pst-cnflict situatin f the area and that relevant recmmendatins are incrprated int the specific initiatives identified; Ensure that the assessment includes preparatin f relevant maps t clearly delineate land lss as a result f the Prject; versus land lss as a result f the security zne; and Obtain input frm a sci-ecnmic specialist (r similar) t design and cnduct the assessment Detailed Planning Prcess In rder t cmplete detailed planning, BMSC will use the fllwing general prcedures: Review the results f the updated impact assessment; Develp a specific implementatin plan fr Phase I f the me clearly stating which actins are t be taken, when and by whm; Allcate respnsibilities, csts and a schedule fr each actin r prcedure required s that they will be implemented in the timeframe defined; Establish a Cmmittee (r similar) t take respnsibility fr delivery f the land use management prgramme and this will likely be crdinated with a grup t manage brader scial prgrammes (e.g. the Steering Cmmittee fr the cmmunity assistance me); Wrk with the Ministry f Agriculture in Barentu and lcal authrities t cmplete detailed planning fr Phase 1; Seek pprtunities t invlve lcal peple as much as pssible in the planning wrks fr each f the land-based prjects t be implemented; Identify specific partners fr Phase 1 activities and cmplete relevant assessments f each individual r grup; Cmplete cntractual arrangements with partners (e.g. Memrandums f Understanding (MOU) fr wrk t be cmpleted); and Establish a mnitring and evaluatin me Cperatin with Gvernment Cperatin with the Eritrean gvernment related t land use management will be critical and shall include: BMSC will wrk clsely with varius gvernment agencies and ministries t cntinue discussins abut land use impacts in rder t create a cherent and agreed apprach t the prcess; BMSC will nt independently engage directly with cmmunities n land use issues and related mitigatin measures, but will wrk with the Department f Mines and relevant lcal authrities; Prpsals fr specific mitigatin measures will be intrduced t natinal and Zba level gvernments first, prir t final apprval; It is expected that line ministries within Gash Barka as well as lcal authrities will take the lead n implementing measures t be put int practice, with BMSC taking a supprting/funding rle; Any external implementing partners that may be required will be intrduced t the gvernment and the cmmunity prir t any visits t the area; and BMSC shall cnsult with gvernment n the apprach t funding the implementatin f this Land Use Management Plan and the mitigatin measures prpsed, including hw this infrmatin shuld be disclsed t the affected ppulatin and ther interested parties Land Use Data and Dcumentatin The HSEC Department is respnsible fr maintaining a recrd f all land take impacts and assciated mitigatin measures and ther activities related t land use management. Scial Management Plans [18/02/2010] Page 95 f 111

96 Bisha Mining Share Cmpany The database will cntain infrmatin n the land based impacts and related mitigatin measures. Infrmatin shall be recrded fr each impact and mitigatin measure, and will be updated t track changes as they ccur. Such data will include: Each land use impact/categry and the affected individual/grup; Specific mitigatin measures/prgrammes identified and agreed; Planning and implementatin details fr measures t be implemented; Implementing partners, including gvernment; Cnsultatin activities with gvernment and lcal cmmunities; Fund disbursement histry; Cmmencement (and cmpletin) dates; and Perfrmance mnitring and evaluatin Land Use-related Cmplaints BMSC will perate a cmplaints prcess fr lcal cmmunities thrugh its stakehlder engagement me. The Stakehlder Engagement Plan describes the cmplaints management prcedure. Cmplaints related t land use r the agriculture imprvement me and related activities shall be managed thrugh the same cmplaints management prcess Training All emplyees f BMSC and Cntractrs t BMSC shall be prvided with basic training n the requirements f the Cde f Cnduct, which includes requirements t prtect natural resurces in the lcal area. Additinal specialist training shall be prvided t cmmunity relatins and envirnmental staff and key persnnel invlved in land use management activities Rles & Respnsibilities Overall respnsibility fr the implementatin f this Management Plan shall rest with the Bisha Cmmunity Relatins Manager. Others with respnsibility fr the implementatin f this Management Plan shall include: Bisha Envirnment Manager shall supprt the Cmmunity Relatins Manager t design and implement land-based mitigatin measures and fster the link between land use management prcesses and envirnmental management within the lcal/reginal area; Bisha Public Cnsultatin Officer shall be respnsible fr engaging directly with affected cmmunities n land use management issues and supprting the Cmmunity Relatins Manager t implement relevant land-based mitigatin measures; and Bisha Mine Superintendent shall be respnsible fr ensuring that these prcedures and requirements are implemented fr all mine peratins. Scial Management Plans [18/02/2010] Page 96 f 111

97 Bisha Mining Share Cmpany 5.14 Mnitring & Reprting Land use management mnitring prcedures shall be as fllws: The Bisha Cmmunity Relatins Manager shall mnitr the implementatin f the prgramme and reprt t the Bisha General Manager n at least a quarterly basis, including: Specific mitigatin measures develped and implemented; Engagement cnducted with gvernment and affected cmmunities; In-kind supprt prvided t families/husehlds; Funds disbursement histry; Activities cnducted by gvernment versus BMSC related t mitigatin measures; Affected peple invlved with the Agriculture Imprvement Prgramme; Supprt fr vulnerable peple; Perfrmance f implementing partners; Perceptins/attitudes f affected peple twards the prgramme; and Cmplaints prcess. Each measure r initiative t be funded by BMSC as part f this plan shall have its wn specific mnitring and evaluatin prcedures; and Affected peple shall participate in mnitring prgress f each f the mitigatin measures implemented thrugh this plan. The Bisha Cmmunity Relatins Manager shall be respnsible fr recrd-keeping. Regular reprting shall be undertaken via the mnthly SEMS Reprt that shall be prepared and submitted t the Bisha General Manager. Reprting shall include: A summary f activities undertaken during the reprting perid; Any material deviatins r nn-cmpliances t this Management Plan; Planned activities during the next reprting perid; and Any ther issues f cncern. Further infrmatin n scial mnitring and reprting requirements and prcedures is set ut in the Mnitring Plan and in the Scial & Envirnmental Management System. Scial Management Plans [18/02/2010] Page 97 f 111

98 Bisha Mining Share Cmpany Annex 1 Prject Measures relating t Cmpliance with IFC Requirements Specific measures that will need t be adpted by the Bisha Prject t meet the requirements f the IFC Perfrmance Standards. IFC Perfrmance Standard Requirement Cmpliance Apprach Prepare a Resettlement Actin Plan Avid r at least minimize resettlement Cmpensate at full replacement cst Prvide displaced peple with prmpt payment Imprve r at least restre livelihds f affected ppulatin Imprve living cnditins amng displaced persns Security f tenure will be ffered fr ffered fr physically displaced persns t avid future frced evictin Absence f legal title nt a bar t cmpensatin Include special measures t allw disadvantaged grups t participate meaningfully in the resettlement planning prcess, t access resettlement assistance and t benefit frm Prject develpment pprtunities. Ensure affected cmmunities are apprpriately engaged in the design and implementatin f resettlement activities t facilitate their infrmed participatin Prject has prepared this Land Use Management Plan in accrdance with IFC s Perfrmance Standards fr Scial and Envirnmental Sustainability, specifically Perfrmance Standard 5, Land Acquisitin and Invluntary Resettlement. Since the scpe f physical displacement is minimal, it was determined that a Land Use Management Plan wuld be sufficient t address ecnmic displacement issues. Prject is nt in an area where residential land is lcated and resettlement has therefre predminantly been avided. The Prject has minimised the extent f ecnmic displacement by minimising the size f Prject cmpnents and the distances between them. The Prject ftprint is in a sparsely ppulated, rural area. Prject will cmpensate fr all affected immvable assets at full replacement cst, althugh this is likely t be replacing assets r in-kind cmpensatin rather than cash. The Prject will mitigate/cmpensate fr ecnmic displacement that has ccurred, but this requires further cnsultatin with gvernment due t the sensitive nature f the situatin in the Bisha area and the fact that these requirements are unprecedented in the cuntry. In-kind supprt is likely rather than cash payment (and will include land-based and nn-agricultural supprt services). Prject has elabrated several strategies fr livelihd cntinuatin, particularly access t emplyment with the Prject and cntributins t an agriculture imprvement prgramme. There are nly tw peple displaced and these persns have already secured ther shelter with the help f gvernment. The Prject will prvide additinal in-kind supprt, which may include preferential emplyment pprtunities r land-based supprt services. N applicable. Because land is state wned peple d nt have legal titles t land. Hwever, the Prject will prvide supprt t all thse affected by lss f seasnal/permanent dwellings and agricultural land. Fr grazing land lst, supprt will be prvided at the cmmunity level t thse cmmunities affected. Prject will identify grups and individuals wh may be mre diversely affected by Prject land acquisitin. Assistance measures t vulnerable persns will be elabrated in the Land Use Management Plan. Prject has engaged practively with Prject-Affected Persns using a variety f culturally apprpriate engagement techniques. Mre than 50 frmal engagement activities invlving all Prject stakehlder grups have been cncluded. Scial Management Plans [18/02/2010] Page 98 f 111

99 Bisha Mining Share Cmpany IFC Perfrmance Standard Requirement Where land acquisitin and resettlement are the respnsibility f the hst gvernment, cllabratin will be made with the respnsible gvernment agency t achieve utcmes cnsistent with Perfrmance Standard 5. Establish a grievance mechanism t receive and address specific cncerns abut cmpensatin and resettlement, including a recurse mechanism designed t reslve disputes in an impartial manner. Cultural heritage will nt be remved unless the fllwing cnditins are met: There are n technically r financially feasible alternatives The verall benefits f the prject utweigh the lss f cultural heritage Any remval f cultural heritage is cnducted with the best available techniques Cmpliance Apprach Prject-Affected Peple were cnsulted initially abut prpsed mitigatin strategies fr land-based impacts and will be invlved in develping cmpensatin packages and related prcesses. The Prject has cllabrated extensively with the gvernment thrugh a variety f frums. The Prject will seek apprval fr all its activities in the cmmunity and fllw the directin f the gvernment t ensure cmpliance with lcal laws. Hst gvernment is respnsible fr prviding replacement land. Prject will prvide in-kind supprt measures in circumstances where lsses caused by the Prject are nt cvered by lcal laws. Prject is in the prcess f establishing a detailed prcess fr cmmunity cmplaints, and this will incrprate the reslutin prcess fr land-based impacts. Remval r relcatin f tmbs/burial sites and cultural resurces fund within the Prject ftprint has been cnducted in cperatin with the Natinal Museum and with the assistance and apprval f lcal authrities and cmmunities. The Prject area is being cleared and cultural assets remved r relcated in advance f cnstructin activities. A Cultural Heritage Management Plan has als been develped by the Prject includes prcedures fr dealing with chance finds during cnstructin and peratins. Scial Management Plans [18/02/2010] Page 99 f 111

100 Bisha Mining Share Cmpany 5.15 Prject Impacts Prject Land Requirements Annex 2 The Bisha Prject will make use f 1,650 hectares (ha) f land permanently fr the mine and ancillary facilities. This is the Mining License area that was granted in 2008 which includes the Prject facilities and a buffer zne (see Figure 1) Prject Ftprint Table 1 summarises the different impacts t land, peple and structures as they were estimated at December 2008 fr the Bisha Prject. This infrmatin takes int accunt the 2006 baseline data as well as updated infrmatin that has been gathered by BMSC thrugh its pre-cnstructin activities and nging cmmunity engagement effrts. Impacts t each f the affected land units/assets are further described in the fllwing sectins. Table 1 Summary f Land Acquisitin Impacts fr the Bisha Prject Affected Land/Assets Land Take/Impact Seasnal/Permanent Dwellings 5 seasnal dwellings near Bisha Main belnging t Ad Humed Sheik clan 4 dwellings near Fereketetet River belnging t Ad Faid clan (there is ne permanent resident in an Ad Faid hut; the rest are used seasnally) Greater than 10 dwellings f ld Bisha village Agricultural Land Apprximately 40 hectares f recently cultivated agricultural land (crpped in 2006) Rangelands fr Dmestic Livestck Estimated 393 hectares (plus rads) f rangeland Estimated 482 hectares f histric agricultural land (fallw land nt actively crpped fr 20 years) Lcal migratin crridr (nrthern rute) Access t rangeland and water pints Reductin in rangeland and frage quality Cmpetitin fr range resurces Further wrk is required t adequately characterise the impacts t land and assets and ptential effects t the livelihds f agr-pastralists, s that apprpriate mitigatin measures can be identified and cnfirmed. The villages f Mgraib, Adarat and Ad Ibrihim are the affected cmmunities in terms f land take impacts, since a number f their residents were pprtunistically farming land in the Prject area and many husehlds were using the area fr livestck grazing prir t Prject develpment. Whilst the villages f Tekreret and Jimel are within the zne f scial influence f the Prject, their residents did nt reprtedly use land within the Prject area prir t develpment f the Bisha mine Seasnal/Permanent Dwellings There are very limited effects t residential structures as a result f the Bisha Prject. A summary f the impacts t seasnal/permanent dwellings are as fllws: Five seasnal dwellings have been affected by the Prject in the area knwn as the Bisha Main Depsit; Fur permanent dwellings have been affected in the Prject area in a lcatin alng the Fereketatet River; and There are greater than 10 dwellings that were in the ld Bisha village that have been affected by the Prject, hwever these were ld structures left frm when resettlement ccurred in the 1990 s, but were being used seasnally by the Ad Faid clan t heard cattle/gat (the Ad Faid clan are nw part f Ad Ibrihim). Scial Management Plans [18/02/2010] Page 100 f 111

101 Agricultural Land Recently cultivated land Bisha Mining Share Cmpany Currently cultivated land was identified during baseline study activities in the rainy seasn f July 2006 and then further assessed during cnsultatin with lcal cmmunities and gvernment in 2007 and A summary f the impacts t cultivated land are therefre as fllws: The Prject land take has affected apprximately 40 hectares f recently farmed land by the clans f Debuk and Ad Humed Sheik; Nineteen families were identified t have been pprtunistically cultivating this land since 2006 (and this was crrbrated by gvernment and BMSC itself); These pprtunistic farm plts may r may nt be cultivated in any given year and are als likely t change in their lcatin; The farmed area was nrth f the Bisha Main Depsit, alng the rad between the Explratin Camp and the Main Depsit; Families farming this land have farm plts nearer their settlement areas but chse t farm this land because f histric land wnership/user rights and perceived benefits f the agricultural value/ptential f this land; Effects have ccurred primarily thrugh land cnversin and restricted access because f cnstructin and peratins activities; and After mine clsure, it may be pssible t farm reclaimed land in areas ther than the mine pit, waste dump and tailings impundment. There are n ther knwn areas that have been cultivated in recent years in the Prject ftprint accrding t cnsultatin with lcal farmers and cmmunities Rangelands/Grazing Land (and dmestic livestck) Mine develpment will require an area f land which was previusly used as rangelands (including fallw land) fr dmestic livestck that riginate frm cmmunities in the Prject area. A summary f the estimated impacts t rangelands/grazing land are as fllws: An estimated 875 hectares f rangelands/grazing lands are n lnger able t be accessed by lcal cmmunities in the Prject area: Livestck riginating frm cmmunities in the lcal area utilise rangelands f the Bisha area during mst times f the year; Specifically the cmmunities f Adi Ibrihim, Mgraib, and Adarat willl be affected by the lss f rangelands/grazing land in the Prject area; A decrease in available habitat fr existing ppulatins f wildlife and livestck is likely t result in sme increased pressure and cmpetitin fr remaining rangeland resurces; Water pints within the Prject area are n lnger be available alng the Mgraib River fr Mgraib and Adarat herders; and These rangelands include land that was histrically cultivated land but has been fallw fr the past 20 years. The Prject land take has als affected a nrthern migratin rute in the lcal area, which has been interrupted and is unvailable fr utilisatin by dmestic livestck herds. Additinal inputs f dust and air emissins frm Prject activities are likely t have lw t medium level effects n rangeland and frage quality in the Prject area, primarily thrugh aerial depsitin. Scial Management Plans [18/02/2010] Page 101 f 111

102 Cmmunity Infrastructure and Businesses Bisha Mining Share Cmpany N cmmunity r public infrastructure f any significance is lcated within the Prject area (schls, health centres, streets, water supply, etc ) and n businesses will be affected by the Prject land requirements Other Related Issues The land and assciated assets in the Prject area described abve, have nt been used by cmmunities since the security zne was established by the Eritrean military in 2007 fr mnitring reginal security. Figure 1 Prject Land Requirements Scial Management Plans [18/02/2010] Page 102 f 111