Environmental and Social Compliance Assurance Plan

Transcription

1 Environmental and Social Compliance Assurance Plan

2 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 2 of 57 TABLE OF CONTENTS Glossary of Terms... 5 List of Acronyms and Abbreviations Introduction Objectives Scope Reference Documents and Links with other Plans....4 Responsibilities TAP responsibilities Contractor responsibilities Project Compliance Assurance Processes Tier - Self-Verification Tier 2 - Oversight Tier 3 Assurance Contractor Assurance Programme (Self-Verification) Contractor ESMS Manual and ESIPs CONTRACTOR s Pre-Construction Survey Contractor Inspections and Audits Contractor Action Tracking System Contractor Non-Conformance and Incident Reporting Contractor Interface Contractor Monitoring and Reporting TAP Oversight and Assurance Daily Oversight Monitoring Oversight Inspections... 20

3 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 3 of TAP Oversight Action Tracking System Route Environmental and Social Impact Registers Environmental Engineering Compliance Register TAP Oversight Interface TAP Oversight Reporting Regular oversight reporting Monthly Performance Report Quality Assurance Programme Quarterly Management Reviews ESCH Assurance Audits Non-conformances Reporting and Corrective Actions Non-conformance categorization Non-conformance Reporting ESCH Incident Reporting Management of Change Key Performance Indicators... 29

4 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 4 of 57 APPENDIX - Daily Report Template... 3 APPENDIX 2 - Regular Oversight Report Template APPENDIX 3 Social Focused Inspection Checklist APPENDIX 4 Environmental Focused Inspection Checklist APPENDIX 5 E&S Issues Tracking Register APPENDIX 6 - Monitoring Requirements List of Tables Table Document references... Table 2 Non-Conformance Categories and Associated Corrective Actions Table 3 Key Performance Indicators... 29

5 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 5 of 57 Glossary of Terms Assurance (Tier 3) Audit Contractor(s) Environmental impact ESCH Change ESMS Project Standards Documents ESMP Inspection Non-conformance Oversight (Tier 2) Assurance refers to the highest level of checking (Tier 3) to measure compliance of project activities by personnel not directly involved in the activities being checked. Assurance is primarily conducted through targeted audits but is also undertaken as formal reviews. Assurance activities are typically detailed and focussed upon defined risk areas or guided by feedback from the results of the self-verification and oversight activities. Assurance activities are intended to provide an additional layer of assurance above and beyond self-verification and oversight activities. Specific, discrete investigation to check compliance (with environmental, socioeconomic and cultural heritage requirements) that can be undertaken by various parties (e.g. internal, external, authority, lenders) Engineering, Procurement and Construction (EPC) contractors (incorporating activities of their sub-contractors) A change to the environment (in this context the environment refers to any aspect of the natural or semi-natural physical environment (air, water, soil etc.)) which may occur as a result of Project activities. Impacts may be considered to be positive or negative. is a deviation from the project scope or activity approved by Project ESIAs that has a potential to cause environmental, social or cultural heritage impact Documents detailing the Project Standards as applicable in each of the three TAP host countries Environmental and Social Management Plan (overarching framework document that describes accountabilities as well as how project environmental, social and cultural heritage requirements are identified, managed and reported upon) Periodic, targeted examination or formal evaluation exercise of specific activities to check whether they are meeting the relevant requirements of the ESMS unapproved (by TAP) deviations from TAP ESCH Specifications or Standards and TAP or Contractor Management Plans Oversight activities represent the next tier of checking above self-verification. Oversight is typically performed by the TAP (TAP) site E&S teams and the ESCH Experts. Oversight activities ensure that the self-verification conducted by CONTRACTORs has been carried out sufficiently. Oversight activities include review of E&S reports/documentation/monitoring data/procedures & plans, undertaking formal inspections (checklists), undertaking quarterly reviews, internal TAP reporting on E&S performance and attendance of meetings with CONTRACTORs to drive performance.

6 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 6 of 57 Project Route Environmental and Social Impact Registers Socio-economic impact Self-Verification (Tier ) Stakeholder Trans Adriatic Pipeline including related facilities such as access roads, compressor stations, etc. Dynamic planning and verification tool indicating applicable Project E&S constraints by KP and informing the E&S Assurance processes. A change, or potential change, to the existing socio-economic environment which occurs because of Project activities. Social factors may include aspects such as demographics, community structure and relationships, health and wellbeing etc. and may refer to individuals, groups or wider communities of people. Economic factors may include, for example, employment, government or household finances, livelihoods etc. An impact may be positive or negative. Self-verification refers to the checking by the implementing party on itself, to demonstrate compliance with commitments or requirements, and provides evidence to self-verify that it is meeting its obligations. Examples include Contractor E&S assessments, monthly E&S reports, KPI reporting, monitoring data, development and implementation of management plans etc. Any person, group or organization who may be affected by the Project, and may in turn affect Project design, development or operation.

7 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 7 of 57 List of Acronyms and Abbreviations ALARP ATS CCP CH CHA CHM CLC CLO EBRD EBRD PR EFM EIB EPC ESCH E&S E&S CAP ESIA ESIP ESCHMD ESMP ESMS EU HGA H&S IFC IPMT ISO KP KPI MPR LEA NCR OECD PIMS REIR RFA RSIP RSIR SEI As Low As Reasonably Practicable Action Tracking Register EPC Contractor Control Plan Cultural Heritage Cultural Heritage Advisor Cultural Heritage Monitor Community Liaison Coordinator Community Liaison Officer European Bank for Reconstruction and Development European Bank for Reconstruction and Development Performance Requirement Environmental Field Monitor European Investment Bank Engineering, Procurement and Construction Environment, Social and Cultural Heritage Environmental and Social Environmental and Social Compliance Assurance Plan Environmental and Social Impact Assessment Environmental and Social Implementation Plan Environmental, Social and Cultural Heritage Management Document Environmental and Social Management Plan Environmental and Social Management System European Union Host Government Agreement Health and Safety International Finance Corporation Integrated Project Management Team International Organization for Standardisation Pipeline Kilometre Point Key Performance Indicator Monthly Performance Report Land Easement and Acquisition Non-conformity report Organization for Economic Cooperation and Development Project Information Management System Route Environmental Impact Register Rapid Field Assessments Route Social Impact Plan Route Social Impact Register Social and Environmental Investment

8 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 8 of 57 SFM SIMP TAP Social Field Monitor Social Impact Management Plan Trans Adriatic Pipeline

9 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 9 of 57. Introduction This Environmental and Social Compliance Assurance Plan (E&S CAP) describes the framework and approach that will be applied by TAP and its Contractors to manage verification of compliance with the requirements of the ESIA, the ESCH management system, the ESMP and relevant contract documents including CCPs and specifications. This plan is supported by the Compliance Monitoring CCP and is subordinate to, and should be read in conjunction with the Environmental and Social Management Plan (CAL00-PMT-60-Y-TTM- 0006). The ESMP is the overarching framework document for the TAP ESCH Management System, and provides an overview of all Company environmental, socio-economic and cultural heritage aspects and how impacts will be identified, avoided, mitigated or managed in accordance with Project requirements. The Project is committed to meeting the requirements of: National environmental and social laws and regulations applicable to the Project in host countries Applicable EU legislation Applicable international conventions. The Project has also adopted the following standards: EBRD Performance Requirements (PRs through 6 and 8 through 0) as per EBRD's Environmental and Social Policy (204) EIB Environmental and Social Practices and Standards (203) IFC Performance Standards (PS through 6 and 8) 2 (January 202) IFC EHS General Guidelines (2007) IFC Industry-specific Guidelines the IFC EHS Guidelines for Onshore Oil and Gas Development (2007) the IFC EHS Guidelines for Offshore Oil and Gas Development (205) The Equator Principles III (203) OECD Common Approaches (202). The ESMP is the central document of TAP s ESCH management system and is supported by: TAP ESCH Standards and Specifications specific design, procurement, construction and operational controls and general requirements for Contractors and TAP teams defined within EBRD PR 7 is a performance requirement in relation to Indigenous Peoples and is not applicable to TAP Project. 2 IFC PS 7 is a performance standard in relation to Indigenous Peoples and is not applicable to TAP Project.

10 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 0 of 57 the Contractor Control Plans, Consolidated ESMS Project Standards Document and design and construction specifications (see Section 2.5 and Table 2 in Section 5.2 of ESMP). TAP ESCH Management Documents translate TAP ESCH standards and specifications into documented procedures on how TAP ESCH standards and specifications are implemented and managed on the Project. The ESCH Management Documents detail TAP processes for managing Contractor performance, including TAP oversight, compliance and assurance activities, and processes for guiding implementation of TAP initiatives. TAP ESCH Management Documents form part of the ESMP (see Section 2.5 and Table 3 in Section 5.2 of ESMP) Contractor ESCH management plans and Contractor Environmental and Social Implementation Plans (ESIPs).. Objectives The primary objectives of this E&S CAP are to: ensure that Project ESCH standards and specification are identified and monitored during the construction and commissioning stages of the Project ensure adequate systems, tools and processes are in place to appropriately monitor construction and commissioning activities against Project ESCH standards and specifications clarify roles and responsibilities for the three tiers of compliance verification processes (selfverification, oversight and assurance) ensure performance reporting systems are developed and implemented to communicate compliance to the IPMT, TAP Corporate and other accountable personnel and stakeholders as required to facilitate continual improvement and compliance assurance. The E&S CAP details a range of tools that TAP and Contractors will adopt to ensure that both TAP and Contractors are implementing the environmental, socio-economic and cultural heritage requirements of the Project..2 Scope The E&S CAP is applicable to all onshore and offshore activities during the construction and commissioning phases of the Project. A revised version of this plan will be issued to support start up and operation stages of the Project 6 months prior to introduction of hydrocarbons into the TAP facilities. The E&S CAP is applicable to activities under TAP s direct control (i.e. activities performed solely by the TAP) and its indirect control (i.e. activities performed by Contractor). This E&S CAP does not apply to supplier manufacturing sites (e.g. pipe, fibre optic cable, cement manufacturing sites) as these are covered by TAP and Contractor procurement processes. The plan covers various elements of TAP ESCH management controls such as:

11 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: of 57 inspections audits reviews non-conformance reporting incident notification and reporting action tracking qualitative monitoring quantitative monitoring reporting management of change.3 Reference Documents and Links with other Plans The E&S CAP is part of TAP s over-arching ESCH Management System and as such interfaces with other ESCH management documents listed in Table. It is subordinate to, and should be read in conjunction with the TAP ESMP (CAL00-RSK-60-Y-TTA-0002), Contractor Control Plans (CCPs) and Contractors ESMS including Environmental and Social Implementation Plans (ESIPs) that have been developed for this Project. Table Document references Document Number CAL00-RSK-60-Y-TTA-0002 CAL00-PMT-60-Y-TTM-000 CAL00-RSK-60-Y-TTM-000 TAP-HSE-PR-00 CAL00-PMT-000-V-TPQ-000 TAP-PRC-PR-00 CAL00-PMT-000-V-TVL-0002 CAL00-PMT-60-Y-TAT-000 AAL00-PMT-60-Y-TLX-000 TAP-PRO-OPLA TAP-PRO-ITT-OFI A AAL00-C Y-TAT-0003 AAL00-C Y-TTM-006 Document Name Environmental and Social Management Plan Consolidated ESMS Project Standards Document Contractor`s ESMS Framework Document H&S and ESCH Data, Incident Reporting & Investigation Non-conformity Management Procedure Management of Change Procedure Quality Assurance program Environmental Engineering Compliance Register ESIA Commitments Register (Albania) Onshore Compliance Monitoring CCP Albania Offshore Compliance Monitoring CCP Albania ESIP Compliance Monitoring Plan (Albania) Spie-capag Entrepose - ONPL ESIP Compliance Monitoring Albania Renco Terna Joint Venture - CS

12 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 2 of 57 Document Number GAL00-PMT-60-Y-TLX-000 GAL00-ENT-60-Y-TTM-0008 GAL00-SPIGR-000-Y-TAT-0003 GPL00-C Y-TAT-003 GCS00-C Y-TTM-0006 IAL00-PMT-60-Y-TLX-000 TAP-PRO-ITT-OPLI Rev B TAP-PRO-ITT-OFI Rev A IAL00-C Y-TTM-0005 IPL00-C Y-TAG-0008 Document Name ESIA Commitments Register (Greece) Onshore Compliance Monitoring CCP ESIP Compliance Monitoring Plan (Greece) Spie-capag Entrepose ONPL ESIP Compliance Monitoring Bonatti - ONPL ESIP Compliance Monitoring Greece Renco Terna Joint Venture CS ESIA Commitments Register (Italy) Onshore Compliance Monitoring CCP Offshore Compliance Monitoring CCP Onshore Compliance Monitoring ESIP Italy Onshore Compliance Monitoring ESIP Italy.4 Responsibilities.4. TAP responsibilities TAP is ultimately responsible for ensuring that all activities and site operations comply with the Project ESCH requirements listed in Section.0. TAP responsibilities for compliance assurance include: ongoing monitoring and review of Contractor s daily activities planning assurance and oversight activities based upon Contractor s scheduling and work activities undertaking formal oversight monitoring and communicating the result to Contractor for risk management and continual performance improvement communicating the contents of this E&S CAP to its own and Contractor staff and ensuring that they understand their responsibilities with respect to compliance assurance and incident reporting and response undertaking targeted audits and inspections ensuring formal, regular meetings that record and document actions as appropriate reporting on assurance and compliance ensuring that adequate resources are mobilised for compliance assurance including input from any specialist resources necessary to ensure effective planning and timely implementation of appropriate measures ensuring that systems are in place to assess compliance monitoring with Project ESCH standards and specifications, Contractor Control Plans and Contactor ESIPs.

13 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 3 of 57 liaising and coordinating with Contractor staff with regards to environmental, social and cultural heritage compliance assurance and monitoring. ensuring that all environmental, socio-economic and cultural heritage incidents are reported and dealt with effectively and that any lessons are learned and considered as part of the continual improvement process. maintaining a Management of Change process encouraging a lessons learned culture implementing a non-compliance process maintaining systems to identify and track actions as appropriate. Specific responsibilities of key TAP staff are summarized within ESMP (CAL00-RSK-60-Y-TTA- 0002)..4.2 Contractor responsibilities Contractor is responsible to ensure that environmental, social and cultural heritage compliance is achieved according to the requirements and processes defined in this E&S CAP, the applicable Onshore and Offshore Compliance Monitoring CCPs, Contractor ESMS Manual and associated Compliance Monitoring ESIP (referenced in Table ). Each Contractor is responsible for: self-verification of its own compliance by maintaining a system to manage ESCH aspects and impacts in line with TAP and Contractor requirements ensuring that all environmental, socio-economic and cultural heritage incidents are reported and dealt with effectively and that lessons are learned in accordance with the procedures outlined in the Contractor ESMS Framework Document (CAL00-RSK-60-Y-TTM-000) ensuring its organisation has adequate resources and expertise for compliance monitoring and control to meet the TAP CCPs, Contractor ESIP requirements and Contractor ESMS. keeping the TAP fully informed of any site environmental, socio-economic and/or cultural heritage issues recording and reporting monitoring observations, required actions and raising non-conformance reports, where appropriate instructing own staff in their responsibilities with respect to compliance assurance and incident reporting and response cooperating with the TAP in relation to compliance assurance activities participating in joint inspections, performance reviews and audits as required by the TAP providing the TAP with access to monitoring records (including all relevant documentation and databases) as required ensuring adequate planning and availability of expertise and resources for appropriate identification of ESCH risks sufficiently in advance of commencement of construction works

14 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 4 of 57 identifying ESCH risks as part of its pre-construction surveys, planning appropriate mitigation measures and communicating these to its workforce ensuring adequate planning of required pre-construction surveys of project areas and identified additional land, executing these and communicating associated reports to the TAP reporting monthly to TAP on ESCH performance, including KPIs participating in regular interface meetings to discuss and action E&S issues requiring attention

15 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 5 of Project Compliance Assurance Processes Throughout the construction and commissioning phases of the Project, verification of compliance is executed broadly across three distinct levels or tiers, which combine both Contractor and TAP compliance assurance activities. The three tiers have been designed to operate in parallel to optimise compliance assurance monitoring and to provide an appropriate and robust system for ensuring Project ESCH requirements are monitored and implemented. 2. Tier - Self-Verification Self-verification refers to the examination by the Contractor of its own compliance, to demonstrate conformance with Project ESCH standards and specifications. It provides evidence that the Contractor is meeting its obligations. Examples include: inspections against checklists or E&S assessments monthly E&S reports KPI reporting monitoring data non-conformances incident reports development of management plans and procedures action tracking and closure. 2.2 Tier 2 - Oversight Oversight activities represent the next tier of confirming Contractor compliance and is performed by TAP country ESCH teams. Oversight activities ensure that the self-verification conducted by Contractor has been carried out sufficiently and provide TAP with an additional layer of compliance assurance. Oversight activities include: review of Contractor ESCH reports, monitoring data, procedures and plans undertaking formal planned inspections against checklists undertaking quarterly reviews of Contractor performance internal TAP reporting on ESCH performance verification of Contractors action closure readiness reviews prior to start of major construction activities participation in Contractor interface meetings to raise issues and drive performance improvements.

16 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 6 of Tier 3 Assurance Assurance refers to the highest level of verification of compliance of project activities by personnel not directly involved in the activities being examined. Assurance is conducted through: targeted audits against pre-developed protocols formal reviews. Assurance activities are typically detailed and focussed upon defined risk areas or are guided by feedback from the results of the self-verification and oversight activities. Assurance activities are intended to provide an additional layer of verification above and beyond Tiers and 2 activities.

17 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 7 of Contractor Assurance Programme (Self-Verification) TAP compliance assurance requirements of the Contractor are defined in the Onshore and Offshore Compliance Monitoring CCPs (Table ). Further, as part of its construction planning Contractor is required to develop their own ESMS aligned with the principles of ISO400, which requires selfverification of compliance as a phase of the Plan-Do-Check-Review cycle. Contractor ESMS shall include specific subordinate ESIPs setting out how they meet and comply with Project ESCH requirements. These requirements include: development of an overarching ESMS Manual preparation of a range of subordinate ESIPs that address respective CCPs undertaking pre-construction surveys and ESCH assessments to identify and manage ESCH risks implementation of Contractor s inspection and audit programme identification, reporting and closure of non-conformances incident notification and reporting ESCH monitoring programme Action Tracking System 3. Contractor ESMS Manual and ESIPs Contractor is required to implement its own environmental, social and cultural heritage compliance monitoring and assurance processes as outlined within Onshore and Offshore Compliance Monitoring CCPs, associated Compliance Monitoring ESIPs (referenced in Table ) and Contractor s own ESMS manual. The Contractor ESMS Manual and subordinate ESIPs form the overarching system for identification of ESCH requirements, against which compliance is measured. 3.2 CONTRACTOR s Pre-Construction Survey Prior to initiating construction works at a specific Project location, Contractor is required to undertake pre-construction surveys to identify associated ESCH risks and to support mitigation planning and implementation. CONTRACTOR is responsible for ensuring that planning and execution of pre-construction surveys are performed with sufficient time in advance of construction commencement. The scope of pre-construction surveys is agreed with TAP; however, the scope may be defined on a case by case basis with consideration of: site specific monitoring requirements as specified in the Compliance Monitoring CCPs applicable ESCH constraints identified within Route Environmental and Route Social Impact Registers applicable ESCH constraints identified within other sources of information.

18 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 8 of 57 The Pre-construction surveys shall include assessment of ESCH risks and identify measures or actions necessary to avoid or appropriately mitigate potential ESCH impacts. Contractor ESCH team plays the main role in communicating the findings of pre-construction surveys to other members of the construction team. 3.3 Contractor Inspections and Audits To provide assurance that the provisions of the TAP CCPs and Contractor ESIPs and sub-plans are implemented effectively, Contractor is required to implement a programme of documented inspections and audits in line with its Compliance Monitoring ESIP. The programme shall encompass: walk-around inspections during construction activities at sites and impacted areas (including third party sites such as quarries or batching plants) to visually monitor that mitigation measures specified within pre-construction surveys or each of the environmental, social and cultural heritage ESIP (or other applicable ESMS document) have been implemented joint inspections with TAP using checklists due diligence assessment of third-party quarry and batch plant sites prior to use, including an appropriate level of documented ESCH assessment submitted to TAP. The ESCH assessments will demonstrate that use of the sites is undertaken in alignment with the relevant TAP CCP, ESIA requirements and local regulations engagement with project affected parties, stakeholders and regulators. Contractor internal ESCH audits are to be performed in line with Contractor s Compliance Monitoring ESIP, Contractor s management system procedures and internal audit programme approved by TAP. These audits are to be performed by an interdisciplinary team of appropriately qualified environmental, social, cultural heritage auditors. TAP ESCH staff may join the audit team and participate in the Contractor internal audits. 3.4 Contractor Action Tracking System Contractor shall operate an Action Tracking System (ATS) that will record corrective actions proposed in response to all ESCH issues, observations, non-conformances and incidents. In addition to the corrective actions, Contractor ATS shall record the responsible party and timescale for completing each action. TAP ESCH teams shall review Contractor ATS on a regular basis to follow-up on progress and to confirm actions closure. 3.5 Contractor Non-Conformance and Incident Reporting Contractor shall notify TAP of all ESCH incidents and near misses in accordance with provisions and timeframes detailed in Section 5.3 and Table 5. of the H&S and ESCH Data, Incident Reporting & Investigation Document (TAP-HSE-PR-00). Contractor shall align categorisation and reporting of formal non-conformances with the severity definitions and reporting timeframes of ESCH Incidents as detailed within H&S and ESCH Data, Incident Reporting & Investigation Document (TAP-HSE-PR-00). Depending on the nature and severity of

19 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 9 of 57 the non-conformance, Contractor shall record a formal non-conformance in its own non-conformance system and submit a formal non-conformance report within TAP NCR system. TAP In-Country E&S Manager shall review and qualify non-conformance reports submitted by Contractor within TAP NCR system. Further details on NCR reporting is provided in Section 5 of this document. Non-conformances identified as result of inspections, monitoring and audits performed are to be recorded by Contractor and along with corrective actions shall also be raised at the regular interface / coordination meetings. 3.6 Contractor Interface Contractor shall maintain a series of regular meetings with TAP to review the Action Tracking System and update it with new issues, actions or record closure as appropriate. Contractor shall participate in the formal meetings between ESCH and Construction Team representatives to discuss issues that require elevation and resolution with the support of TAP Senior Site Representatives and Contractor Construction Management. Minutes of these meetings shall be kept and shall be entered into the Contractor Action Tracking System. 3.7 Contractor Monitoring and Reporting The scope of Contractor ESCH monitoring programme is defined within Contractor ESMS Manual and Contractor Compliance Monitoring ESIPs (Appendix 6) and includes monitoring effectiveness of implemented mitigation measures and data acquisition for Route Environmental and Social Registers (see Section 4.4 for further details). The monitoring frequencies, parameters, methodology and duration are determined for construction activities on a case by case basis, dependent on construction activity type and location. Monitoring results are to be reported to TAP as a part of Contractor Monthly ESCH Report or more frequently when requested by TAP.

20 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 20 of TAP Oversight and Assurance 4. Daily Oversight Monitoring Daily oversight monitoring of construction activities is a key element of TAP ESCH compliance assurance in assessing effectiveness of the mitigation measures implemented by the Contractor (i.e. avoiding and minimising environmental, social or cultural heritage impacts as intended) and in identifying whether construction site practices require improvement. Daily oversight monitoring is undertaken by TAP ESCH Field Monitors whilst they visit construction sites or project affected areas as part of their daily work. Observations are discussed with senior TAP In-Country ESCH staff and TAP Senior Site representatives to determine whether further actions are necessary. TAP ESCH field monitors shall record results of the daily oversight monitoring using the Daily Oversight Report which shall be referred to by the ESCH Field Monitors when undertaking planned monthly inspections. The format of the daily oversight report shall be determined by the TAP In- Country E&S Manager, a minimum the report shall indicate: project location / area inspected construction activities performed / inspected weather conditions observation notes providing description of good practices and identified issues commitment reference number and controlling document reference (CCP and ESIP) where applicable photographic evidence of the observations actions and recommendations The completed daily reports shall be submitted to the TAP Senior Site Representatives and TAP In- Country E&S Manager or his/her delegate and shall be used by the ESCH Field Monitors in populating TAP E&S Issues Tracking Register and assist in directing the focus of the planned monthly inspections. Remedial actions identified as necessary by daily oversight monitoring are to be discussed with the TAP In-Country E&S Manager or his/her delegate and further communicated to and agreed with the relevant Contractor. 4.2 Oversight Inspections The oversight inspections based on focused checklists are performed by the ESCH Field Monitors, and on a case by case basis with guidance from senior ESCH staff. The frequency and scope of oversight inspections is ultimately decided by the TAP In-Country E&S Manager. The focus, visited site and scope of the inspection are based on the status of the ongoing construction works, relevant ESCH risk priorities and potential associated issues.

21 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 2 of 57 ESCH inspections of construction sites and Project affected areas are planned and performed based upon: observations from daily monitoring review of Project schedule and forecasts reference to Route Environmental and Social Impact Registers (see Section 4.4) review of project documentation, including method statements, Contractor ESCH assessments and Contractor inspection reporting the status of the construction activities in progress the assessed risks presented by proposed activities (including use of third party sites). The inspections shall take place as a site walk-around or a drive-through (with Contractor where possible) to observe conditions and identify any non-conformances for defined project areas (e.g. a KP range along the ROW, at a specific camp, pipe yard, third party site, etc.) The conformance oversight inspections are intended to highlight key Contractor conformance aspects with the use of focused inspection checklists (examples are provided in Appendix 3 and 4). The checklists used include key Project standards and specifications against which CONTRACTOR performance is assessed. The checklists are organised into specific CCP/ESIP topics and are designed to cumulatively address key ESCH aspects associated with specific activities being inspected. They include review of relevant requirements and capture actions, which can be assessed monthly for progress and closure, or elevation to TAP and Contractor management attention, where required. The focused checklists completed by the ESCH Field Monitors are reviewed by the In-Country E&S Manager or his/her delegate to provide support on determining appropriate corrective actions for issues identified and to plan the focus of the next monthly inspection. This allows for compliance assurance intelligence and evidence to accumulate from month to month to facilitate ongoing TAP oversight. 4.3 TAP Oversight Action Tracking System As described within Section 3.4 of this document Contractor shall operate its own ATS that records actions arising from issues, observations, non-conformances and incidents. Contractor s ATS is intended to capture most of such actions since most compliance assurance activities throughout the construction and commissioning phases relate to Contractor scope of activities. In parallel to Contractor ATS, the TAP In-Country E&S Manager or his/her delegate shall operate TAP ATS in the form of E&S Issues Tracking Register (Appendix 5). The intent of TAP tracking register is to record TAP-specific actions so that TAP compliance oversight and assurance activities can be managed, organised and implemented. 4.4 Route Environmental and Social Impact Registers Prior to initiation of construction works, TAP develops Route Social Impact Registers (RSIR) and Route Environmental Impact Registers (REIR) to manage georeferenced data on environmental and

22 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 22 of 57 social constraints, sensitivities and the associated management actions. TAP and its Contractors use the RSIR and REIR as a living and dynamic planning and management tool to: Ensure all teams recognise the specific constraints and sensitivities and reference the most recent environmental and social data Provide oversight, compliance and assurance to support delegation, implementation and monitoring of mitigation and monitoring activities associated with the specific constraints and sensitivities. The RSIR and REIR and associated impact assessment and mitigation tools ensure that all relevant information on sensitive sites and recommended mitigations are centralised in a single location that is available to TAP and its Contractors. The risk-based Register format is applied across all countries and Contractors to ensure consistency in the environmental and social management approach. The RSIR and REIR assist TAP ESCH Field team in identifying known upcoming ESCH risks that will require focussed oversight monitoring. The registers are risk-based and can be used to track status of deliverables throughout the execution phase, providing TAP oversight of environmental and social performance. TAP and Contractor hold an initial review meeting to agree section boundaries, schedules and other information contained within the RSIRs and REIRs. At this point the Registers become live and are used by Contractor for preconstruction activities planning and for executing deliverables in line with the schedule indicated within the RSIR and REIR. TAP and Contractor hold coordination meetings as required to review the REIRs and RSIRs to facilitate early identification and resolution of actions for seasonal constraint conflicts, to ensure appropriate mitigation has been implemented for known constraints and to record any key sensitivities identified by pre-construction surveys. The Registers are also used to assist in determining scope for pre-construction surveys. Further details on development, maintenance and implementation of RSIRs and REIRs is provided in Section 5.3 of the TAP ESMP (CAL00-PMT-60-Y-TTM-0006). 4.5 Environmental Engineering Compliance Register Within the TAP ESCH standards and specifications, there are commitments to eliminate, minimise and manage environmental and social impacts associated with the operation of the permanent TAP facilities. To ensure that TAP complies with these ESCH standards and specifications an Environmental Engineering Compliance Register (CAL00-PMT-60-Y-TAT-000) has been developed by the Project. The Environmental Engineering Compliance Register lists the ESCH standards and specifications that relate to design and procurement phases, along with the specific implication that each requirement has on design and procurement activities. The Environmental Engineering Compliance Register logs engineering evidence for design activities, and vendor evidence for procurement activities, to demonstrate compliance and track changes or associated additional work. The Environmental Engineering Compliance Register is a live document that is updated on a regular basis. The actions recorded in the Register are also logged in the Project Information Management

23 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 23 of 57 System (PIMS). To support Contractor oversight, studies and reviews will be completed to confirm appropriate controls have been included in the facilities design and that vendors can achieve the required standards and specifications (e.g. review of Contractor noise assessments). Further details on development, maintenance and implementation of Environmental Engineering Compliance Register are provided in Section 5. of the TAP ESMP (CAL00-PMT-60-Y-TTM-0006). 4.6 TAP Oversight Interface TAP and Contractor maintain a regular Project IPMT meeting to review issues and ongoing actions requiring closure. Higher level ESCH issues are discussed and recorded in these meetings, which typically include members from the IPMT of both Contractor and TAP, including the TAP In-Country E&S Manager or his/her delegate. Minutes of meetings are kept and form part of the TAP Action Tracking system. 4.7 TAP Oversight Reporting 4.7. Regular oversight reporting TAP ESCH Site Leads /ESCH Experts shall provide a regular brief report to the TAP In-Country E&S Manager that summarises key highlights and challenges for the reporting period, based upon the results of daily monitoring, review of Action Tracking, the outcome of regular meetings, the results of Oversight inspections and the status of construction activities. Regular Reporting is intended to keep the TAP In-Country E&S Managers abreast of ESCH issues, so that direction and feedback can be provided to field teams. The format for Regular E&S Oversight Reporting is attached at Appendix 2. The regular report will also be used by the TAP In-Country E&S Manager to prepare the Monthly Performance Report Monthly Performance Report Contractor is required to report to TAP on monthly basis the monitoring results, inspection information and performance data as part of the Contractor Monthly ESCH Report (Section 3.7 of this document). TAP has an oversight role in reviewing Contractor Monthly ESCH Report to examine or query reported performance. Review of Contractor Monthly ESCH Report, performance statistics and monitoring data is to be undertaken primarily by TAP In-Country E&S Manager or his/her delegate with support as required from the field team with the results of the review communicated to the TAP In- Country E&S Manager for use at: the regular Project Management Leadership Team meetings the regular meeting with the In-Country E&S and IPMT Construction Managers These reviews inform TAP performance reporting as well as Quarterly Assurance Reviews (see further Section 4.8 of this document). TAP country ESCH team shall provide a monthly performance report (MPR) to TAP E&S Manager on overall Project ESCH performance. The MPR shall cover: key ESCH events, activities and issues for the month

24 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 24 of 57 series of metrics used to measure performance, including Contractor KPI non-conformance reports ESCH incidents Contractor ESIP approval status training indicators audits grievance management CH chance finds and inspections. The MPR compares all Contractors against the same parameters and allows assessment of performance and continual improvement across the Project sites. A monthly review of project ESCH risks and supporting mitigations is undertaken at the country and project level to inform the TAP risk tool and maintain the appropriate classification of the risk and mitigating actions are relevant and closed in a timely manner and verified by management. 4.8 Quality Assurance Programme TAP ESCH Assurance activities are summarised within TAP Quality Assurance Program (CAL00- PMT-000-V-TVL-0002) and include ESCH Quarterly Management Reviews and ESCH Assurance Audits Quarterly Management Reviews ESCH Quarterly Management Reviews, held at two levels within the TAP organisation. At the TAP corporate level, the E&S Manager leads an ESCH Quarterly Management Review with his direct team in TAP headquarters and with the TAP In-Country E&S Managers focusing on assurance of TAP ESCH standards and specifications, consistent oversight of the Contractors, implementation of mitigations identified in the REIRs and RSIRs, as well as planning of tactical support to pre-empt project risks. A quarterly review focused on country ESCH issues will be led by the TAP In-country E&S managers. These reviews adopt a risk based approach, aiming to highlight key issues requiring attention or more strategic action and management support. The scope of these reviews applies to Contractor activities as well as TAP activities, including review of ESMDs. The results of quarterly reviews are reported to TAP Senior Management to assist in highlighting high level issues, achieving resolution of compliance assurance issues and facilitating continual improvement as part of the review cycle. Where appropriate, system changes are identified and implemented as actions, to be reviewed at the next ESCH Quarterly Management Review ESCH Assurance Audits ESCH Assurance audits are conducted primarily by TAP Corporate teams to provide assurance Tier (Contractor self-verification) and Tier 2 (TAP oversight) activities.

25 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 25 of 57 Joint H&S and ESCH audits of each Contractor and/or in-country ESCH Team are performed on an annual basis or after specific Project delivery milestones are attained by the Contractor (e.g. 0 25%, 25 75%, 75-00% works execution). Grievance Management audits are performed separately. The scope of the ESCH audit is defined by the TAP E&S Manager or his/her delegate and may include but not be limited to: Contractor ESCH organisation ESCH documentation implementation of ESIPs, associated sub-plans, method statements, specific ESCH procedures ESCH inductions Key Performance Indicators (KPIs) Non-conformance and incidents reporting, tracking and closure In-Country ESCH Team organisation, documentation and oversight activities, as appropriate Implementation of TAP ESMDs Contractor and the TAP In-Country E&S Manager are formally notified of the upcoming joint H&S and ESCH audit in advance. Audit protocols are developed based on the defined scope and communicated to the Contractor and the TAP In-Country E&S Manager in advance of the audit. The audit protocol is to be used by the audit team for guidance during the audit and for recording audit observations including good practice and non-conformances. The results of the audits are summarised in audit reports and formally communicated to the Contractor and the TAP In-Country E&S Manager. Audit findings are discussed with the Contractor and the TAP In-Country E&S Manager and agreed corrective actions recorded in the relevant Action Tracking System.

26 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 26 of Non-conformances Reporting and Corrective Actions TAP has established a non-conformance management system, as documented in the Non- Conformity Management Procedure CAL00-PMT-000-V-TPQ-000. Non-conformances are unapproved (by TAP) deviations from TAP ESCH Specifications or Standards and TAP or Contractor Management Plans. These are typically identified by ESCH personnel through the oversight and assurance activities. Further details on management of ESCH non-conformances and corrective actions are provided in Section 5.4. of the TAP ESMP (CAL00-PMT-60-Y-TTM-0006). Contractor is responsible for monitoring the effectiveness of the mitigation measures implemented in line with their own quality system to ensure appropriate rigor and control. The implementation of the corrective mitigation measures is subject to TAP ESCH oversight and assurance. 5.. Non-conformance categorization Non-conformances are classified by the In-Country E&S Manager using a 5-level severity scale (Table 2), aligned with severity definitions and reporting timeframes of ESCH incidents detailed within H&S and ESCH Data, Incident Reporting & Investigation Procedure (TAP-HSE-PR-00). Table 2 Non-Conformance Categories and Associated Corrective Actions Non-conformance Levels Category 5 Category 4 Category 3 Category 2 Category Action Triggered Immediate corrective action required to rectify or stop the on-going non-conformance and to implement mitigation Immediate corrective action or site-specific attention required to rectify or stop the on-going nonconformance and to implement mitigation Corrective action or site-specific attention to rectify or stop the on-going non-conformance and/or to prevent the occurrence of environmental and social impacts Corrective or preventive action or site-specific attention to ensure compliance with Project Standards, TAP and Contractor Management Plans Corrective or preventive action or site-specific attention to ensure compliance with Project Standards, TAP and Contractor Management Plans Non-conformance Reporting Category 3 non-conformances are addressed through TAP E&S Issues Tracking Register as described in Section 4.3 of this document. Category 4 and 5 non-conformances are entered into the TAP or Contractor NCR System and are subject to the formal NCR process below: Initiate The originating person (Contractor or TAP authorised user) submits the Non- Conformance Report by providing concise non-conformance description, indication of deviated requirement / procedure and identification of location/ area where the nonconformance occurred.

27 CAL00-PMT-60-Y-TTM-0005 Doc. Title: Environmental and Social Compliance Assurance Plan Page: 27 of 57 Response The Contractor Lead in conjunction with TAP (and TAP Discipline Lead for TAP non-conformances) defines the Root Cause, proposed corrective actions and actions to prevent re-occurrence. Review Assigned Contractor / TAP reviewers confirm or comment on the proposed corrective actions. In the case of E&S Non-conformances, reviewers are the TAP E&S Manager and the In-Country Project Manager. Implement The Contractor Lead (TAP Discipline Lead for TAP non-conformances) finalises the non-conformance action plan and initiates implementation according to set due dates. As actions are implemented, the Contractor Lead (TAP Discipline Lead for TAP nonconformances) enters in the system relevant supporting documentation confirming implementation. Close Out - TAP reviewers confirm, validate and close out non-conformance. The TAP NCR System defined in the Nonconformity Management Procedure (CAL00-PMT-000-V- TPQ-000) is based on a system tool part of the TAP Project Information Management System (PIMS). It is and operated by authorised users from both TAP and Contractor. All ESCH non-conformances are tracked through to closure by the TAP ESCH team, presented and discussed in weekly TAP-Contractor ESCH and TAP cross functions construction meetings ESCH Incident Reporting Incident management and associated reporting are addressed by Section of the TAP ESMP (CAL00-PMT-60-Y-TTM-0006). Incidents are classified according to the 5-level severity scale provided in Table 2. All ESCH incidents and near misses are notified to the TAP ESCH functions in accordance with H&S and ESCH Data, Incident Reporting & Investigation Document (TAP-HSE-PR- 00).