MEGARUMA MINING LIMITADA RUBY MINE MONTEPUEZ, CABO …

MEGARUMA MINING LIMITADA RUBY MINE MONTEPUEZ, CABO DELGADO PROVINCE, MOZAMBIQUE

ENVIRONMENTAL MANAGEMENT PLAN

DRAFT

Prepared for:

Megaruma Mining Limitada

Avenida Eduardo Mondlane, No. 178, Edifico Cruz Vermelha Cidade de Pemba, Cabo Delgado

Prepared by:

Coastal & Environmental Services

Avenida da Mozal, Porta 2334 Beluluane Celula D. Quarteirao 02, Matola Cidade, Maputo

Mozambique

August 2017

The original report was written in English and translated to Portuguese

Environmental Management Plan – August 2017

Coastal and Environmental Services

Report Title: Environmental Management Plan, Megaruma Mining Limitada Ruby Mine Report Version: Draft 1

Name Responsibility Date

Tarryn Martin Author 27/07/2017

Marc Hardy Reviewer 06/08/2017

Copyright This document contains intellectual property and propriety information that are protected by

copyright in favour of Coastal & Environmental Services (CES) and the specialist consultants. The document may therefore not be reproduced, used or distributed to any third party without

the prior written consent of CES. The document is prepared exclusively for submission to Megaruma Mining Limitada in Mozambique, and is subject to all confidentiality, copyright and

trade secrets, rules intellectual property law and practices of Mozambique.


Coastal & Environmental Services iii Megaruma Mining Limitada

TABLE OF CONTENTS 1. INTRODUCTION ..................................................................................................................... 1

1.1 Overview ......................................................................................................................... 1 1.2 Project Rationale and Motivation ..................................................................................... 2 1.3 The Environmental Management Plan ............................................................................. 2 1.4 The Project Proponent ..................................................................................................... 2 1.5 The Environmental Consultancy ...................................................................................... 3 1.6 Authors of this EMP ......................................................................................................... 3

2. PROJECT DESCRIPTION ...................................................................................................... 4 2.1 Project Location ............................................................................................................... 4 2.2 Exploration Phase Activities ............................................................................................ 5 2.3 Infrastructure and labour requirements for the exploration phase .................................... 6

2.3.1 Water Supply ............................................................................................................... 7 2.3.2 Power Generation ........................................................................................................ 7 2.3.3 Waste, Sewage and Effluent Management .................................................................. 7 2.3.4 Labour Force ............................................................................................................... 7

2.4 Potential Project Impacts ................................................................................................. 8 ............................................................................................................. 8 ................................................................................................ 9

2.5 Exploration Area .............................................................................................................. 9 3. NATIONAL Legislation and APPLICABLE INTERNATIONAL CONVENTIONS................. 11

3.1 Applicable Mozambican legislation ................................................................................ 11 3.2 Applicable International Conventions and Legislation .................................................... 13

4. ORGANISATIONAL REQUIREMENTS ................................................................................ 14 4.1 Megaruma Mining Limitada Staffing............................................................................... 14

....................................................................................................... 14 .................................................................................................... 14 .................................................... 14 ....................................................... 15 .............................................................................. 15

4.2 Drilling and Exploration Contractor Responsibilities ....................................................... 15 .......................................... 15 ......................................................................................................... 16

4.2.3 ...................................................................................................... 16 5. TRAINING AND AWARENESS REQUIREMENTS ............................................................... 17

5.1 Introduction .................................................................................................................... 17 5.2 Environmental, Health & safety Induction Training ......................................................... 17 5.3 Occupational Health and Safety .................................................................................... 18

..................................................................................... 18 .................................................................................................................... 18 ....................................................................................................... 18

5.4 Emergency Preparedness and Response ..................................................................... 19 5.5 Community Health and Safety ....................................................................................... 20

6. STAKEHOLDER ENGAGEMENT PLAN .............................................................................. 21 6.1 Introduction .................................................................................................................... 21 6.2 Stakeholder Engagement Planning ............................................................................... 21 6.3 Proposed Stakeholder Engagement Plan ...................................................................... 22

............................................................................ 22 .............................................................................................. 23 ........................................................................................................ 23 ............................................................................................... 24

7. IMPLEMENTATION OF THE ENVIRONMENTAL MANAGEMENT PLAN ........................... 25 7.1 Introduction .................................................................................................................... 25 7.2 Exploration Phase Mitigation Measures and Responsibilities ........................................ 25

8. EMP IMPLEMENTATION, PERFORMANCE REVIEW AND REVISION .............................. 28 8.1 Introduction .................................................................................................................... 28


Coastal & Environmental Services iv Megaruma Mining Limitada

8.2 Incident Reporting, Non-compliance and Corrective Action ........................................... 28 ...................................................................................................... 28 ........................................................................................................ 29 ....................................................................................................... 29

8.2.4 .................................................................................................. 29 8.3 Checking and Monitoring ............................................................................................... 29

......................................................................... 30 .............................................................................................. 30 ................................................... 30 ........................................................................................ 30

8.4 Management Review ..................................................................................................... 31 8.5 Financial Budgeting and Adequate Resourcing ............................................................. 31

9. EMP MONITORING PROGRAMME ..................................................................................... 32 9.1 Objectives...................................................................................................................... 32 9.2 Monitoring Categories ................................................................................................... 32 9.3 Monitoring Responsibilities ............................................................................................ 32 9.4 Reporting ....................................................................................................................... 32 9.5 Monitoring Aspects and Areas ....................................................................................... 33

........................................................................................................................... 33 ................................................................................................... 33 .............................................................................. 33 ...................................................................................................................... 34 ........................................................................................................ 34

9.6 Occupational Health and Safety Monitoring ................................................................... 34 9.7 Socio-Economic Monitoring ........................................................................................... 35 9.8 Ongoing Monitoring ....................................................................................................... 35

10. REHABILITATION PLAN ..................................................................................................... 36 10.1 General Surface Rehabilitation ...................................................................................... 36

........................................................................................ 36 ................................................................................................ 36 ........................................................................................ 36

10.2 Re-vegetation Methods.................................................................................................. 36 .......................................................................................................... 36 ........................................................................................... 37 ............................................................................. 37 ..................... 37

10.3 Bulk Sample Pits ........................................................................................................... 37 10.4 Exploration Camp .......................................................................................................... 37 10.5 Rehabilitation Monitoring ............................................................................................... 38

ANNEXURE A: GRIEVANCE MECHANISM ................................................................................ 39 ANNEXURE B: COMPENSATION FRAMEWORK ............................. Error! Bookmark not defined. ANNEXURE C: KEY PERFOMANCE AREAS & INDICATORS .......... Error! Bookmark not defined.


Coastal & Environmental Services v Megaruma Mining Limitada

LIST OF FIGURES Figure 1-1: Locality Map of the MML and MRM License Areas. ....................................................................... 1 Figure 2-1: Position of the project site in relation to the City of Pemba and Montepuez, Cabo Delgado Province

Mozambique .............................................................................................................................................. 4 Figure 2-2: Villages within the Exploration Licence Area. ................................................................................. 5 Figure 2-3: Coordinates of the MML Exploration License Project Site ............................................................ 10 Figure 4-1: Preliminary organisational structure .............................................................................................. 14 Figure 7-1: Simplified Grievance Mechanism .................................................................................................. 24

LIST OF TABLES

Table 2-1: Exploration phase labour requirements (%per category of total requirements) ................................ 7 Table 3-1: List of potentially applicable Mozambican legislation ........................................................................ 11 Table 3-2: International conventions potentially applicable to the project .......................................................... 13 Table 7-1: EMP Specifications .............................................................................................................................. 26

LIST OF ABBREVIATIONS CES Coastal & Environmental Services

CF Compensation Framework

CLO Community Liaison Officer

E&S Environmental & Social

EIA Environmental Impact Assessment

EHS Environmental, Health and Safety

EHS-M Environmental, Health and Safety Manager

EHS-O Environmental, Health and Safety Officer

EL Exploration License

EMP Environmental Management Plan

ERP Emergency Response Plan

GM General Manager

IFC International Finance Corporation

MITADER Ministério da Terra, Ambiente e Desenvolvimento Rural

MML Megaruma Mining Limitada

MRM Montepuez Ruby Mine

OHS Occupational Health and Safety

PAC Project Affected Community

PAP Project Affected Person/People

PPE Personal Protective Equipment

SEP Stakeholder Engagement Plan

TM Technical Manager


Coastal & Environmental Services 1 Megaruma Mining Limitada

1. INTRODUCTION

1.1 Overview

Megaruma Mining Limitada (MML), a listed Mozambican subsidiary company of Gemfields plc (75% equity), and EME Investimentos (25% equity), intend to develop a ruby mine within the License Area 7057C (referred to as the “Project Site”) located approximately 40 km east of Montepuez, within the district of Montepuez in the Cabo Delgado Province, northern Mozambique. Gemfields plc is a listed company based in the United Kingdom. The company is the world’s leading supplier of coloured gemstones, providing around 70% of the world’s ruby supply, as well as producing emeralds and amethysts (Gemfields, 2016). The MML Exploration Licence (EL) area covers 15505 hectares (ha) and shares a boundary with the existing operational Montepuez Ruby Mine (MRM) (Figure 1-1) which has mining licence area of 34 965 ha, operated through a partnership between Gemfields (75% equity) and a local Mozambican entity Mwiriti Limitada (25% equity) (Gemfields, 2016).

Figure 1-1: Locality Map of the MML and MRM License Areas.

The Ministério da Terra, Ambiente e Desenvolvimento Rural (MITADER) through the Central Environmental Impact Assessment Authority has categorised the MML Ruby Mine as a Category B Project (Refer to Appendix A for letter of categorisation). In accordance with article 11, Decree 26/2004, of 20 August (Environmental Regulation for the Mining Activity) and Environmental Management Plan (EMP) must be submitted to them after being preceded by the disclosure of the report to the District Administrator and the project-affected communities. Coastal & Environmental Services Mozambique Lda (CES) have been contracted by Megaruma Mining Limitada (MML) to conduct the environmental authorisation application process, as well as develop the exploration phase EMP, to meet the requirements of Mozambique legislation and various international guidelines, including the African Development Bank (AfDB, 2013), European Investment Bank (EIB, 2009) and the International Finance Corporation’s Performance Standards (IFC PS, 2012).



1.2 Project Rationale and Motivation

The proposed project includes exploration activities to determine whether there are suitable and viable ruby deposits within the EL area. The proponent is therefore applying for environmental authorisation to conduct exploration activities during the estimated five-year period that this will occur. If the deposits are found viable, the proponent will then apply for an environmental license and a mining license to extract the deposits from this area. The purpose of this EMP is to formulate MML’s intentions with regard to ensuring that exploration phase Environmental & Social (E&S) risks and impacts are manged to the best of their ability.

1.3 The Environmental Management Plan

An EMP is a site-specific plan developed to ensure that all necessary measures are identified and implemented in order to protect the environment and comply with environmental legislation. This EMP summarises MML’s commitments to address and mitigate the potential project’s exploration phase E&S risks and impacts, through the avoidance, management and minimisation of these identified risks. It establishes the mitigation principles which the project will adhere to, that in turn also defines the objectives, actions and desired performance outcomes of the exploration activities. More specifically, this EMP provides the implementation framework for the following actions and activities:

Mitigation: This identifies feasible and cost-effective measures that may reduce potentially significant adverse environmental and social impacts to acceptable levels. The programme should include compensatory measures if mitigation measures are not feasible, cost-effective, or sufficient.

Monitoring: monitoring during project implementation provides information about key E&S aspects of the project. The focus is particularly on monitoring the E&S impacts of the exploration activities and the effectiveness of mitigation measures and management interventions adopted by MML.

Capacity Development and Training: To support timely and effective implementation of mitigation measures, the EMP draws attention to the necessary roles and capabilities of MML’s personnel tasked to perform these. This must delegate roles and responsibilities, specifying who is responsible for carrying out the mitigation and monitoring measures, and what training requirements are necessary to achieve this.

Implementation Schedule and Budgets: For all three aspects (mitigation, monitoring, training and capacity development), the EMP provides an implementation framework for measures that must be carried throughout the exploration phase, and highlights the need for adequate budget and human resource provision to support its to its implementation and ongoing development.

As discussed further on in this report, the performance monitoring and ongoing revision requirements are necessary to ensure the above objectives are met throughout the exploration phase lifecycle.

1.4 The Project Proponent

Megaruma Mining Limitada:

Mr. Gopal Kumar, General Manager Montepuez Ruby Mining [email protected] +258 84961 4318 Avenida Eduardo Mondlane, No. 178 Edifico Cruz Vermelha Cidade de Pemba Cabo Delgado Mozambique



1.5 The Environmental Consultancy

This EMP has been prepared by CES, a company registered in Mozambique, with the Ministério da Terra, Ambiente e Desenvolvimento Rural (MITADER), as part of the Category B Project application being undertaken for the issuing of the environmental licence for the proposed exploration activities. CES has the requisite knowledge of the activities under application by MML, as well as the necessary local study area experience to prepare this Environmental Management Plan (EMP). The contact details for CES are:

Mozambique Office:

Mr Marc Hardy Email: [email protected] Avenida da Mozal, Porta 2334 Beluluane Celula D. Quarteirao 02, Matola Cidade, Maputo +27 83 4703696

Cape Town Office:

Ms Tarryn Martin Email: [email protected] The Point, Suite 408 76 Regent Road, Sea Point, 8001 Website: www.cesnet.co.za

1.6 Authors of this EMP

Marc Hardy (Study Leader) Principal Environmental Consultant holds a M. Phil in Environmental Management from Stellenbosch University's School of Public Management and Planning. His professional interests include environmental impact reporting for linear, energy and large infrastructure projects, strategic environmental policy development and reporting, due diligence studies, compliance monitoring and environmental auditing. Marc is currently tasked with managing various large infrastructure, mining and renewable energy projects throughout Africa. Marc manages the CES Maputo office. Ms Tarryn Martin (Project Manager and Ecological Specialist) Tarryn holds a BSc (Botany and Zoology), a BSc (Hons) in African Vertebrate Biodiversity and an MSc with distinction in Botany from Rhodes University. Tarryn’s Master’s thesis examined the impact of fire on the recovery of C3 and C4 Panicoid and non-Panicoid grasses within the context of climate change for which she won the Junior Captain Scott-Medal (Plant Science) for producing the top MSc of 2010 from the South African Academy of Science and Art as well as an Award for Outstanding Academic Achievement in Range and Forage Science from the Grassland Society of Southern Africa. She conducts vegetation assessments including vegetation and sensitivity mapping to guide developments and thereby minimise their impacts on sensitive vegetation. Tarryn has conducted a number of vegetation and impact assessments in Mozambique (to IFC standards) which include the Lurio Forestry Project in Nampula, the Syrah Graphite Mine, Triton Ancuabe Graphite Mine and Nicanda Hills Graphite Mine in Cabo Delgado and the Baobab Iron Ore Mine in Tete, Mozambique.

mailto:[email protected]

mailto:[email protected]



2. PROJECT DESCRIPTION

2.1 Project Location

The Exploration License (EL) area is situated in the district of Montepuez (Figure 2-1). The Project Site encloses 150km2 or 15 000ha of land, and is 16.1km from north to south at its greatest length, and 13.6km from east to west at its greatest breadth. The exact areas to be drilled or bulk sampled will still be finally determined prior to the commencement of the exploration phase activities by MML.

Figure 2-1: Position of the project site in relation to the City of Pemba and Montepuez, Cabo Delgado Province Mozambique

Currently there are ten villages within the EL area; nine in the northern section located along the EN242 tarred road and one in the southern section of the EL area (Figure 2-2). Many of the villages are situated in close proximity to each other. These villages are considered Project Affected Communities (PAC); communities that are affected by the proposed project through either primary (direct) or secondary (indirect) effects. The distinction between direct and indirect PAC is a function of the extent and severity of the anticipated positive or negative impacts to be experienced by particular communities. Direct PAC refers to communities within, or adjacent to, a project (or exploration) area that will be affected by the primary project-related E&S impacts. These communities described below are those most likely to experience possible economic impacts (exploration activity affecting their fields/machambas and crop production for example), and project benefits such as temporary employment. The potentially directly affected PACs include (see Figure 2-2):

Jama Village

Palma Village

Mamomba Village

Naoito Village

Nsajo Village

Saude Village

Namahaka Village

Nsembia Village

Mpupere Village

Ntete Village



Figure 2-2: Villages within the Exploration Licence Area.

An indirect PAC refers to communities in the area surrounding the proposed project site that are not impacted to the same extent or severity as direct PAC and are not proximate to the site. The town of Montepuez, the main economic hub in the area, is considered an indirect PAC in addition to several villages in the area. A large portion of the land in the exploration area appears to be cultivated in some capacity, with some small, villages along the EN242 main road. There is a lush riparian vegetation presence in the south-eastern portion of the project area, and a general presence of vegetation, covering most uncultivated land, over the rest of the project area. Areas that are not under cultivation are used for grazing and as a source of construction materials, for the production of charcoal and to harvest wild foods and medicinal plants. There is no physical resettlement (loss of houses) anticipated, however, there may economic displacement as a result of the machambas, fruit trees and other natural resources and goods (grazing pasture, watering points etc.) located within the EL area and currently utilised by these PAC, being potentially affected by the exploration phase activities described below.

2.2 Exploration Phase Activities

It is estimated that the planned exploration activities will be undertaken over a 5-year period. The initial activities will comprise of the construction of a network of access roads, approximately 3m wide, that will be used to service the drilling areas in identified by MML (and sometime later the identified bulk sampling locations). These routes and locations will be assessed for environmental and social sensitivities by the MML Environmental, Health and Safety (EHS) personnel prior to these locations being confirmed, and site specific mitigation measures for these areas will be implemented as per the specifications detailed further on in this EMP. The resource deposits will be either primary deposits, which is the birth place of the gemstones and typically occurs between 10m to 50m, or secondary deposits, which are less than 10m in



depth (typically between 5 and 6m). The primary and secondary deposits often require different drilling methods; namely Core Sample Drilling and Auger Drilling. Core Drilling: Exploration Core Sample Drilling removes solid or fragmented cores from hard rock to better define the distribution of ruby-bearing rock (amphibolite) below the surface. Core Drilling extends approximately 50-60m deep, at an average rate of 10m per day. Drill bits are coated with synthetic diamond are used to sample the rock at every meter. Drilling sites are positioned approximately every 50-100m in predetermined lines or ‘chains’ by the company or contractor geologists and surveyors. The ruby-bearing rock is found at a depth of approximately 10-30m (Chapin et al. 2015). Auger Drilling: Auger Drilling will be used for secondary (shallower) deposit exploration and is considered efficient for exploration of soft unconsolidated material or weak weathered rocks. Auger Drilling extends approximately 10-12m deep. The auger consists of rotating helical screws drilled into the group. The shape of the screw blade lifts the earth from the boreholes. The workers remove loose gravel from between the blades as the earth is pulled out of the borehole. The drill bits and other equipment will be transported to the drilling sites by truck. The drill will remove one meter of earth with every sample until reaching basement rock, after which 2-3m of rock are removed. The drilling will indicate the depth and thickness of the ruby-bearing layer at each location, after which a contour geology map will be created. The ruby-bearing gravel be transported to the MML processing plant and sorting house to determine the ruby concentration. Bulk Sampling: In 2019, once the gemstone resource locations have been determined, Bulk Sampling and Resource Analysis will take place to provide a clearer understanding of the potential production figures and life of the mine. Bulk sampling will take place six days a week from 06h00 to 18h00 using heavy earthmoving equipment, and will comprise of pits being dug to an estimated to be 50x50m in area (2500m2 or a quarter hectare) and 6-7m in depth. The ruby-bearing gravel coming from these pits will be transported to MML’s existing processing plant where the gemstones will be separated, washed, sorted and graded in order to inform the eventual resource model for the EL area.

2.3 Infrastructure and labour requirements for the exploration phase

The following infrastructure will be required as part of the exploration activities:

Exploration camp comprising of accommodation and ablution facilities, a kitchen, offices, workshop/maintenance areas and core logging assessment yard;

Possible smaller satellite camps as may be necessary during the drilling process;

Drill core pads and laydown areas;

On site electrical generating capacity (diesel generators)

Site access roads providing access to the proposed exploration camp, drill sites and eventual bulk sampling locations;

Boreholes and check-dams for water supply; and

A high-tension line providing electricity from the national grid (if feasible and available at the time of commencement of exploration activity).

The position and exact size of this infrastructure is not currently defined and will depend on the outcomes of the final survey process and environmental screening assessments to be conducted by MML. The locations of the bulk sample pits will largely be based on the initial exploration programme results and findings. During the final survey design process the necessary caution must be used in selecting the exploration and satellite camp locations in that they are located far enough from environmentally and socially sensitive locations, and must demonstrate that all identified potential impacts on these locations have been taken into consideration. Due to the modular nature of the accommodation and ablution units, workshop and storage areas (containers and



tents or temporary structures built with local materials and labour inputs it is not anticpated that any brick and mortar structures will be built at the exploration camp. It may be that vehicle workshop areas will require something more permanent in nature with concrete floors and reinforced steel and sheeting structures as would be necessary for a weather proof maintenance facility. Any vehicle work bay or wash bay areas that may be constructed must be in a manner that ensures the capture and treatment of waste or contaminated water from these areas is in accordance with best practice. 2.3.1 Water Supply

It is estimated that the project will use approximately 5000 litres (l) per day for core drilling and 2000 l per day at the exploration camp. The water will initially be obtained from the existing mine operations from a combination of groundwater extracted from the existing boreholes and rainwater collected in the storage water facility. This water will be transported to the exploration camp and drilling area using a water tanker. Small check dams may be temporarily constructed if this is a technically feasible means for serving the drilling and exploration requirements locally. Any future proposed abstraction of water within the EL area will have to be approved by the relevant authority. 2.3.2 Power Generation

Power will be generated using diesel fuelled generator sets that will be located in bunded and secured areas at the main exploration camp, as well as any satellite drilling camps (as is necessary or required), until such time that a connection to the national grid is feasible or practical. 2.3.3 Waste, Sewage and Effluent Management

Solid non-recyclable waste will be disposed by use of incinerator, with liquid waste disposal will be done in accordance with existing MML practices at the operational mine site. Where possible the exploration camps must utilise any recycling or waste reduction programmes that MML has in place to minimise the amount of waste generated in, and potentially left behind at, all camps and drill pad locations. Workshop areas or those where maintenance of vehicles and equipment will be suitably constructed to ensure all contaminated water runoff is captured and appropriately treated and disposed of. Ablution facilities and sewage management will be accordance with best practice. The exploration and drilling camps will need to ensure that appropriate conservancy tank, or French (self) draining pit latrine facilities are utilised in them. Portable chemical toilets should not be used owing to the high risk of spillage and contamination. If a conservancy tank system is adopted an appropriate service provider will be contracted to maintain these facilities as well as be tasked with sewage removal from camp, in accordance with MML operational mine site practices. 2.3.4 Labour Force

During the exploration phase, there will be approximately 20 people working on the site during Core and Auger Drilling and approximately 200 people during the bulk sampling phase working three shifts a day. Each exploration team is typically composed of a geologist, a technician, and four or five skilled workers. All unskilled labour will be sourced locally from nearby villages. All semi-skilled labour will be Mozambican and it is estimated skilled labour will comprise 90% Mozambicans and 10% expatriates. The majority of the staff will be transported to the near-by villages or to Montepuez by staff busses provided by MML and other staff will be housed in on-site accommodation, in converted containers. Table 2-1: Exploration phase labour requirements (%per category of total requirements)

Type Number

Skilled 10% Expatriates

Semi-Skilled 20% Mozambicans

Unskilled 70% Mozambicans from nearby villages

Total 100%



2.4 Potential Project Impacts

Preliminary social and environmental impacts, both positive and negative, have been identified below. The study that will be undertaken as part of this application will focus on identifying the impacts and associated mitigation measures to responsibly manage and reduce the negative impacts via industry acceptable engineering solutions and/or procedural mitigation measures.

Potential Positive Impacts

Employment Opportunities and Economic Development. Employment generation and the associated economic development, although limited during the exploration phase, are considered potential benefits of the proposed development. Employment opportunities will result in an increase in household income which will, in turn, result in an increase in informal trading stores and shops, as well as emerging businesses and service providers. Even though some skilled workers will be recruited from outside of Mozambique, the majority of the labour force will be recruited from Mozambique and the surrounding communities.

Training opportunities and the expansion of the local skills base. There is opportunity for skills development in the training of local people to improve their skills in various areas that would serve the mining sector.

Social development. The MML Ruby Project may result in the future establishment of social development programmes should it proceed to the mining phase. Even though the exploration phase socio-economic benefits are relatively small (employment and procurement of local goods), there may be development programmes associated with the Corporate Social Responsibility (CSR) initiatives already established at the operational mine (MRM) that can have benefit to the EL area communities. This may include programmes such as small-scale agricultural support, water supply project and support for local health and education programmes.

Potential Negative Impacts

Economic Displacement. The EL area contains ten villages with extensive machambas located therein. Agricultural machambas are therefore likely to be affected by exploration activity and MML needs to ensure that this is minimised as far as possible, and where it is necessary ensure that affected persons are suitably informed, negotiated with, and compensated as necessary, for any impacts or losses they may legitimately incur as a result of this activity. Based on information currently available, no physical displacement of households (or living structures) is expected.

Temporary/permanent in-migration and resulting community tension. There may be an influx of people into the surrounding villages in search of employment. The direct and indirect impacts associated with an influx of job seekers (outsiders) may have impacts on these villages, as it usually results in social, cultural, economic and political changes. This is an indirect impact that is difficult to mitigate, however, the impact can be reduced through a labour recruitment policy that only employs people from nearby villages and not outsiders.

Community health and safety risks. There may be some safety impacts associated with an increase in vehicles on the local roads associated with the transport of machinery and equipment for exploration activities. Health impacts may be associated with reduced air quality (primarily related to dust), elevated noise and possible pollution of water resources as a consequence of water contamination if adequate controls are not planned and implemented. However, these impacts are likely to be low given the scale of the activities during the exploration phase. The bulk sampling pits can also be a significant safety risk if not appropriately rehabilitated on completion of sampling.

Nuisance impact (production of odours, visual impacts and attraction of pests and vermin). The uncontrolled storage of solid waste, in particular food waste, can attract vermin and pests including rodents, birds and flies if adequate controls are not planned and implemented. These vermin / pests may pose a nuisance to the adjacent



communities and may act as vectors for disease if not managed responsibly. The uncontrolled storage of solid waste can also result in the release of unpleasant odours which may be regarded as a nuisance to adjacent land-users, particularly those down-wind of the material.

Disturbance of graves and other cultural sites might take place if exploration related infrastructure, drill pits and bulk sampling pits, are located in or close to these areas. Careful planning and placement of these must be undertaken in conjunction with local communities in areas where graves or cultural heritage features may exist.

Changes to social systems. The falls within a local context, and could result in changes to social structures and associated tensions. These may be related to a variety of factors, such as increased wealth, or a change to a cash income in the area.

Loss of biodiversity. Although mostly fragmented and degraded, the further loss or damage to vegetation cover and subsequent loss of faunal habitats could result in further disruption of ecological systems and functions, this will also result in the loss of biodiversity and potential loss of species of conservation concern in some areas, if the exploration activities are not responsibly planned and managed.

Erosion. Soil erosion may occur as a result of the removal of vegetation cover and crops during the creation of roads and drilling activities. Mitigation measures will need to be considered to reduce the potential impact of soil erosion.

Waste. Inappropriate management of wastes such as leakage of fuel and oil from vehicles, earthmoving and drilling equipment as well as general litter can result in pollution of soil and water, with subsequent negative ecological impacts if not responsibly managed.

Noise and light emissions. Increased noise levels and light emissions at night may result in the disruption of faunal populations.

Air emissions and dust. Dust will be generated as a result of drilling activities and, in particular, where there is exposed ground. The generation of dust may be higher during windy, dry periods. Dust may also be deposited on the surface of the water within the adjacent wetland and riparian areas, potentially resulting in an increased turbidity of water. In certain contexts, this may reduce light penetration and, subsequently have negative impacts on aquatic plants, fish and amphibians. It is therefore important for industry standard dust mitigation measures to be considered during the lifespan of the project.

Fragmentation of habitats. This can lead to the loss of viable populations if not responsibly managed, especially in animals requiring large home ranges, and also impacts on specialist species found in certain habitats. Current land use patterns have however already had a significant impact on the existing fauna due to traditional shifting agriculture which results in habitat fragmentation and excessive hunting by the local communities and it is therefore anticipated that this impact will be minimal.

Depletion and/or contamination of water resources. Inappropriate management and pollution of water resources can result in the depletion and contamination of available water which can have significant impacts downstream on both the biodiversity and human populations reliant on this resource. Sources could be hydrocarbons or other hazardous materials, from poor sewage and waste management practices, or from physical impacts resulting from excavation activities in the bulk sampling phase such as sedimentation of watercourses etc. that can affect water quality and quantity

2.5 Exploration Area

Figure 3.3 below displays the EL area coordinates. MML will produce revised maps the next revision EMP that identifies all exploration target (drilling) areas, camp locations and access routes so as to demonstrate how the E&S screening and mitigation requirements detailed in this document have been met.



Figure 2-3: Coordinates of the MML Exploration License Project Site



3. NATIONAL LEGISLATION AND APPLICABLE INTERNATIONAL CONVENTIONS

3.1 Applicable Mozambican legislation

A summary of the legislation applicable to the exploration activities is provided in Table 3-1 below. It should be noted that the list provided below is not exhaustive, and has been restricted to documents that have direct relevance to either the environment and/or communities. Table 3-1: List of potentially applicable Mozambican legislation

LEGISLATION DATE OF

ENACTMENT APPLICABILITY TO THE PROJECT

INDUSTRIAL LICENSING AND LABOUR LAW

General Investment Act

Law 3/1993 of June 24th

Mining Corporations are required to abide by the commercial laws of Mozambique.

Labour Act Law no. 23/2007 of

August 1st Mining Corporations are required to abide by the labour regulations of Mozambique

ENVIRONMENTAL FRAMEWORK LAW, EIA, INSPECTIONS AND AUDITS

Environment Act

Law 20/1997 of October 1st (As amended by the Decree 42/2008)

The project will have an environmental impact, and as such will fall under the ambit of the Environmental Act

Environmental Impact

Assessment Regulations

Decree 54/2015 of December 31

These regulations govern the processes and rules to be followed when conducting an Environmental Impact Assessment.

Addendum to the EIA Process

Regulations no. 45/2004

Ministerial Diploma 198/2005 of

September 28th The environmental authorization required prior to commencements of this project will be regulated by the EIA legislation

General Directive for EIA

Ministerial Diploma 129/2006 of July

19th

General Directive for the Public Participation

Process in the EIA process

Ministerial Diploma 130/2006 of July

19th

Public participation forms a crucial part of the ESIA process and is mandatory for category A+, A and B projects. At least two public consultation rounds must take place and a final public participation process report, that addresses all questions, concerns and comments raised by I&Aps, must be submitted with the EIR to the relevant authorities.

Regulations for Environmental

Inspections

Ministerial Decree 11/2006 of June

15th

These Regulations apply to both public and private activities influencing, directly or indirectly, environmental components. In particular, the regulation defines the types and contents of environmental audits, the related necessary competences and auditors’ profiles. Moreover, it regulates environmental audit reports and defines sanctions and penalties for non-compliance.

Auditing and monitoring form crucial parts of the ESHIA process, and as such this act directly impacts upon the regulatory requirements to which the proponent must adhere.

Environmental Audit Process

Ministerial Decree 32/2003 of August

12th

WATER

Water Act Law 16/1991 of August 3rd

The statutory legal framework for water and sanitation

Water License and Concessions

Regulations

Decree 43/2007 of October 30th

A water use license or concession will be required for the construction and operation of this project.

Water Policy Decree 46/2007 of

August 21th

WASTE, EFFLUENT AND EMISSION

Regulation on Environmental

Quality and Effluents Emission

Decree No. 67/2010 amending

Decree 18/2004 of June 2nd (As amended by

Decree 67/2010)

This decree defines air quality and emission standards and water classification requirements, according to the uses and related quality control standards and emission requirements, with special regard to potable water. It also provides standards for soil quality and noise emissions.

Waste Ministerial Decree Labour and construction camps, as well as permanent accommodation and



LEGISLATION DATE OF


Management Regulations

13/2006 of June 15th

lodgings installed during the lifetime of this project will be subject to these waste regulations.

Regulations on the management of municipal solid

waste

Decree 94/2014 of December 31st

Labour and construction camps, as well as permanent accommodation and lodgings installed during the lifetime of this project will be subject to these waste regulations.

Regulation on management of

hazardous waste

Decree N.83/2014 of December 31

This decree establishes the general rules for the production, management and disposal of hazardous waste in Mozambique. It applies to all entities involved in the disposal, management, import or distribution of hazardous waste and establishes fees and penalties for non-compliance.

Regulations on the management

and control of plastic bags

Decree 16/2015 of August 5th

Management Regulations and Plastic Bag Control applies to all public and private entities, natural and legal persons involved in the production, import, sale and use of plastic bags in the country.

BIODIVERSITY AND WILDLIFE, LAND

Wildlife and Forestry Act

Law 10/1999 of July 7th

This Regulation applies to protection activities, storage, use, and the exploitation and production of forest and wildlife resources. It covers the marketing, transportation, storage, primary processing, and trade or industrial applications of these resources.

Wildlife and Forestry

Regulations

Decree 10/1999 of July 6th

The law is divided into nine chapters. Of relevance to this ESIA are the following chapters:

Chapter 2 on the Protection of Forest and Wildlife Resources; and

Chapter 3 on Sustainable Forest Resources, Exploitation Regimes and Sustainable

Wildlife Conservation Regimes.

The Regulations on the Law of Wildlife and

Forestry

Decree 12/2002 The Regulations on the Law on Forestry and Wildlife (Decree No.12/2002) provide further guidance to The Wildlife and Forestry Act (1999).

National Strategy and Action Plan of

Biological Diversity

Mozambique (2015-2035)

The 2003 National Biodiversity

Strategy Plan was updated by

MITADER in 2015.

The purpose of this report is to outline a strategy to ensure the conservation of biodiversity through integration, training, financing and the strengthening of partnerships between the different sectors of society.

Regulations on Pesticide

Management

Decree No. 6 of 2009

These Regulations aim to guarantee that the human health and environmental quality standards are upheld, according to environmental legal proceedings approved by Law No. 20/97. It includes the management, composition, classification and inspection of pesticides. The annexes specify offences and penalties to be paid for illegal activity.

Control of Exotic Invasive Species

Act

Law 25/2008 of 01 July

Weed control required throughout the construction and operation phases will be directly regulated by these regulations.

MINING ACTIVITIES

Technical Health and Safety

Regulations of Geological and Mining Activities

Decree No. 61/2006 of 26

December

The purpose of these regulations is to define measures aimed at ensuring the safety and health conditions of employees engaged in mining operations, including the application of technical measures that prevent accidents, lower risks and improve hygiene in the workplace in the mining sector.

Hiring regulations of Foreign

Nationals in the Oil Sector and

Mining

Decree n.º63 / 2011 of 7 December

These regulations establish the legal framework for the employment of foreign nationals under the Petroleum and Mining Law, once these activities have been approved by the competent authority. The regulations also include the mechanisms and procedures involved in this kind of employment. Decree No. 63/2011 defines , that for short-term activities not exceeding 180 days, the hiring of skilled foreign workers can be carried out without a permit from the Minister of Labour, provided that the Ministry of Labour is notified within 15 days of the employee entering the country.

The Mining Law 20/2014 of 18

August

Law No. 20/2014, of 18 August ( "Mining Law"), which was enforced on the same date the Mining Act (Law No. 14/2002 of 26 June) was repealed, intends to set the legal framework for the mining sector. It aims to ensure: greater competitiveness and transparency, the preservation of the environment, the protection of the rights and obligations of the holders of mining rights, the safeguarding of national interests and the communal benefit from these activities.

Mining Law Regulations

Ministerial Decree 20/2014 of 18

August

The purpose of this law is to regulate the use and re-use of mineral resources to ensure that the best and safest mining and socio-environmental practices are adhered to, allow for transparency and ensure the sustainable long term



LEGISLATION DATE OF


development of mineral resources and subsequent raising of revenues in favour of Mozambique.

Environmental Regulations for Mining Activities

Ministerial Decree 26/2004 of August

20th

This law defines the norms for the prevention, control, mitigation and compensation of the adverse effects that mining activities may cause to the environment. It also provides specific environmental protection measures, and defines the required environmental management instruments (e.g. the EIA process) and the use of licenses.

Mining Working Regulations

Decree 13/2015 of 03 July

The new regulation of mining work addresses a major gap in the legislation on professional work in this area; a sector which has generated a substantial amount of work for Mozambican citizens, despite the presence of foreigners within the mining workforce. The Mozambican Government subsequently approved the Mining Work Regulations through Decree 13/2015 of 3 July in response to this legislation gap. The new regulations govern labour relations between mining and oil sector employers, including subcontractor companies, and their employees, whether Mozambican or foreign citizens. It also provides for supervision of employment conditions.

3.2 Applicable International Conventions and Legislation

Mozambique is a signatory to a number of international conventions. Those applicable to this project are summarised in Table 3-2 below. Table 3-2: International conventions potentially applicable to the project

INTERNATIONAL CONVENTIONS

Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal 1989

African Convention on the Conservation of Nature and Natural Resources 1968

(Amended)-Revised African Convention on the Conservation of Nature and Natural Resources (Amended Version)

2003

Constitutive Act of the African Union 2000

Bamako Convention on the Ban of the Import into Africa and the Control of Transboundary Movement and Management of Hazardous Wastes within Africa

1991

Convention on Biological Diversity 1992

Convention on International Trade in Endangered Species of Wild Fauna and Flora (Cites) 1973

UN Convention Concerning the Protection of World Cultural and Natural Heritage 1972

Kyoto Protocol to the UN Framework Convention on Climate Change 1998

Convention on Oil Pollution Preparedness, Response and Cooperation 1990

Convention on Wetlands of International Importance Especially as Waterfowl Habitat (RAMSAR) 1971

Stockholm Convention on Persistent Organic Pollutants 2001

UN Framework Convention on Climate Change (read with Kyoto Protocol) 1992

Vienna Convention for the Protection of the Ozone Layer 1985

International Convention on Civil Liability for Oil Pollution Damage 1992

Montreal Protocol on Substances that Deplete the Ozone Layer 1987

United Nations Convention on the Law of the Sea 1982

International Convention to Combat Desertification in Countries Experiencing Serious Drought and/or Desertification, Particularly in Africa

1994

Treaty Establishing the African Economic Community 1991

SADC Protocol on Mining 1997

African Charter on Human and Peoples’ Rights 1981

MML needs to determine the applicability of all above described laws and conventions to its proposed exploration activities, specifically those that may require reporting or monitoring submissions to the relevant government departments or ministries.



4. ORGANISATIONAL REQUIREMENTS This section outlines the proposed organisational structures and other activities that will be required to implement the EMP throughout the various phases of the project. Although the organisational structure described in this chapter is flexible, MML must ensure that any deviation from this will still ensure that the EMP is adequately implemented.

4.1 Megaruma Mining Limitada Staffing

The key management positions required to manage and implement the various EMP actions are shown in Figure 4-1 and discussed below. The actual titles used for each position may change once the project is implemented, but the responsibilities will largely remain unchanged.

Figure 4-1: Preliminary organisational structure

The role of the General Manager (GM) will be to ensure that all personnel abide with the requirements of the ESMPs, and that all areas of the project are constructed and operated in such a manner that they meet all specified legal and contractual Environmental, Health and Safety (EHS) requirements. All senior managers will report directly to the GM, and all of them will ensure that all aspects of the exploration activities are operated and rehabilitated to meet the specified EMP actions, as well as all relevant contractual and legal requirements.

The role of the MML Technical Manager (TM) will be to ensure that all aspects of the exploration activities are designed, constructed and operated to meet the specified contractual and legal requirements. The TM will report directly to the GM.

Management of the environment, health & safety and community aspects of the project will be the responsibility of the EHS Department headed by an EHS Manager (EHS-M). This department is responsible for ensuring implementation and compliance of all actions specified in this EMP relating to all exploration activities. The EHS-M will report to the GM, and is responsible for ensuring that the project operates in an environmentally and socially responsible manner in all aspects of its operations. Specific roles and responsibilities are expected to be as follows:

Development of the EHS documentation required for all aspects of the project.

Implementation of the EMP.

Continuous review of the suitability and effectiveness of the activities described in all EHS documentation and this EMP document.



Oversee liaison activities with local stakeholders.

On-going liaison with appropriate project personnel.

Maintain and manage the monitoring programme.

On-going reporting to the senior management team.

Oversight function to ensure integration of EHS management and social development activities.

An Environmental, Health & Safety Officer (EHS-O) must be appointed prior to initiation of the exploration phase and support the EHS-M in the duties defined above. In addition, the EHS-O will report to the EHS-M and will be responsible for ensuring that the EMP is implemented and adhered to by MML and their contractors during the exploration phase. Frequent auditing of the compliance of the contractors with the requirements of the EMP will be required.

The CLO will:

Implement the SEP and Grievance Mechanism.

Plan, mobilise and allocate resources for the implementation of the SEP.

Discuss with any beneficiaries of compensation the final entitlement contracts.

Community sensitisation and financial training prior to compensation payments.

Be responsible for the finances and delivery of compensation/entitlement payments.

Liaise with district government on the implementation of the SEP.

Address grievances through the Grievance Mechanism and ensure corrective action as per the mechanism.

Liaise with district government with regard to community issues and refer this back to the EHS-O and EHS-M.

Provide regular feedback in the form of progress report(s) (as needed) to MML management.

Attend regular meetings and continuously engaging with communities as needed.

4.2 Drilling and Exploration Contractor Responsibilities

Before any appointed drilling and other contractors begin, they shall give to the EHS-M written Method Statements setting out the following:

The type of activity.

Localities where the drilling/bulk sampling activity will take place.

Identification of impacts that might result from the activity.

Identification of activities or aspects that may cause an impact.

Methodology and/or specifications for impact prevention for each activity or aspect.

Methodology and/or specifications for impact containment for each activity or aspect.

Emergency/disaster incident and reaction procedures.

Treatment and continued maintenance of impacted environment. The contractor must provide such information at least one week in advance of any or all drilling activities for review and approval. Any changes made to the Method Statements after approval shall be given to the EHS-M for approval. The EHS-M may provide comment on the methodology and procedures proposed by the contractor, but shall not be responsible for the contractor’s chosen measures of impact mitigation and emergency response protocols or procedures.



The EHS Department and the EHS-O will continuously monitor the contractor’s adherence to the approved impact prevention procedures. The EHS-M shall issue to the contractor a notice of non-compliance whenever transgressions are observed. This should be documented to record the nature and magnitude of the non-compliance in a designated register, the action taken to discontinue the non-compliance, the action taken to mitigate its effects and the results of the actions. The non-compliance shall be documented and reported to the General Manager in the monthly report. The drilling or bulk sample pit excavation contractor/s and EHS-M shall ensure that an electronic filing system identifying all documentation related to the EMP is established. A list of reports likely to be generated by the project is provided below, and all applicable documentation must be included in the environmental filing system catalogue or document retrieval index:

EMP

Conditions of Environmental and Exploration Licences

Training Manuals

Training attendance registers

All communications detailing changes of design/scope that may have environmental implications

Daily, weekly and monthly site monitoring reports

Incident and accident reports

Complaints register

Disciplinary actions

Any corrective action requests made by the CLO, EHS-M or EHS-O

4.2.3

MML and the EHS-M shall be responsible for establishing a procedure for electronic document control. The document control procedure should comply with the following requirements:

Documents must be identifiable by organisation, division, function, activity and contact person.

Every document should identify the personnel and their positions, who drafted and compiled the document, who reviewed and recommended approval, and who finally approved the document for distribution.

All documents should be dated, provided with a revision number and reference number, filed systematically, and retained for a two year period.

The contractor shall ensure that documents are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the EMP are performed.

All documents shall be made available to the independent external auditor or government personnel as is appropriate, or necessary.



5. TRAINING AND AWARENESS REQUIREMENTS

5.1 Introduction

MML personnel and its contractors, including third parties, will be conversant with all legislation and best practice standards applicable to their contractual undertakings. They will need to be appropriately trained in environmental management in order to possess the skills necessary to impart on their colleagues and subordinates. All personnel involved in the construction of the project will undergo a training and awareness programme on E&S management requirements prior to commencing any activities. MML will develop EHS training material which will lay out in detail the approach to induction training.

5.2 Environmental, Health & Safety Induction Training

A training-needs-analysis that would cover EHS issues will need to be developed, and should identify the appropriate training areas and target groups prior to commencement of construction activity. The training staff will be appropriately qualified in their respective disciplines and will possess the skills necessary to train, inform and sensitise all personnel involved in the project. Information will be transferred in an appropriate manner and training courses will take language and education levels into consideration. In particular, the training of potentially illiterate staff will require the development of appropriate training material and approach. All personnel involved in the construction and operation of the project will be required to participate in an EHS induction programme. Training programmes will be targeted at three distinct levels of employment, i.e. senior/ technical management, supervisors and labour. These awareness training programmes will contain the following information:

The names, positions and responsibilities of personnel to be trained

The framework for appropriate training plans

The summarised content of each training course

A schedule for the presentation of the training courses The range of topics that need to be covered in the awareness training will, inter alia, include:

Environmental Policy

Occupational Health and Safety (OHS) Policy

Community Health and Safety Policy

E&S Objectives and Targets

Organizational Structure and Responsibilities

Aspects of routine day-to-day operational activities, which can have environmental, social, safety or health impacts

Environmental and safety hazards which could arise from non-routine situations and corrective actions

The importance of environmental and safety incident reporting and completion of appropriate reports

Emergency Preparedness and Response

Channels of communication for discussing and reporting E&S issues

Documentation systems so that appropriate records of E&S matters are maintained

Responsibilities under the applicable E&S legislation and international best practice

Responsibilities related to labour and working conditions that will apply to project and their contractors

Culturally appropriate behaviour

Community engagement procedures and grievance management Additional training on cultural heritage and culturally appropriate behaviour, and OHS and E&S



hazards which could arise from non-routine situations and corrective actions will be provided. Training will highlight the importance of incident reporting and completion of appropriate reports, channels of communication for reporting EHS issues and incidents, documentation systems and responsibilities under national legislation. Printed material must be developed and distributed to all literate personnel at induction training for ongoing reference purposes. MML will ensure that its staff and other employed parties or their contractors, who carry out any aspects of the exploration work, are adequately trained with regard to the implementation of the EMP. Contractors and third parties will be aware of their health, safety, environmental and social requirements and obligations, and these will be legally and contractually binding on them.

5.3 Occupational Health and Safety

It is MML’s policy that each of its employees be provided with a safe and healthy place in which to work. To achieve this policy, the company has set the following objectives:

Ensure compliance with statutory regulations, and maintain constant awareness of new and changing regulations

Aim to eliminate or control safety and health hazards in the working environment to achieve the highest possible standards for occupational health and safety in the mining industry

Ensure each prospective employee’s suitability for appropriate employment through a structured recruitment procedure

Provide relevant occupational health and safety information and training to all personnel

Ensure that appropriate levels of personal protective equipment (PPE) are available to all employees

Develop and constantly review safe working practices and job training

Conduct regular departmental safety meetings and provide an open forum for input from employees

Provide effective emergency arrangements for the protection of employees and the public

Maintain good morale and safety awareness through regular employee assessment and counselling

Ensure contracting companies while engaged in work on site adopt the above policies and objectives and maintain the safety standards of the operation for their employees and subcontractors

Develop public awareness of the safety standards and objectives In conjunction with this policy, a series of guidelines and procedures on specific individual OHS matters will be maintained covering the following areas:

A structured recruitment procedure will be adopted to ensure prospective employees are suitable for appropriate employment and sourced from the ten PAC villages referred to previously.

All new personnel will be integrated into the organisation in a logical and coordinated manner to ensure they are aware of both their own and the operating company’s responsibilities regarding EHS requirements and procedures.

MML recognises the beneficial impact that a well-trained operating crew can have on the safety and economics of a project and as such will establish a structured training programme



which addresses the following aspects for the exploration phase:

Standard Operating Procedures

Safe Work Procedures

Emergency Response Procedures

First Aid Training Training will commence prior to the start of project activities will form part of an ongoing operational programme. Progress through the training programme will be monitored and recognised through performance and salary reviews in recognition of personnel achieving a higher skill level achieved through training.

5.4 Emergency Preparedness and Response

Where the project involves specifically identified physical elements, aspects and facilities that are likely to have significant E&S impacts, MML should establish and maintain an Emergency Response Plan (ERP) that should be included in the existing company Occupational Health and Safety Management Plan, in collaboration with appropriately qualified third parties. The ERP will be developed to respond to accidental and emergency situations associated with the project in a manner that will assist in preventing and mitigating any harm to people and/or the environment. In particular, the ERP will address:

Areas where accidents and emergency situations may occur (high risk areas)

Communities and individuals that may be impacted (high risk receptors)

Response procedures for various events (fire, spills, injuries or mortalities)

Provision of adequate and appropriate equipment and resources

Designation of responsibilities

Communication, including that with potentially affected communities

Periodic training to ensure effective response All staff, including contractors, will adhere to MML’s ERP, including incident and accident reporting requirements, as well as all relevant legal requirements in this regard. The ERP will detail the exact process, resource requirements and responsibilities for ensuring that these emergency procedures are documented, monitored and enforceable will be developed. Ongoing training and awareness interventions will form part the ERP to be developed for the construction and operational phases. Incidents that will be considered during the development of the ERP include but will not be limited to:

Details on emergency organisation (manpower) and responsibilities, accountability and liability

A list of key personnel to be contacted

Details of emergency services e.g. the fire fighting crew, spill clean-up services, etc.

Internal and external communication plans, including prescribed reporting procedures where required by legislation

Actions to be taken in the event of different types of emergencies

Incident recording, progress reporting and remediation measures required to be implemented

Information on hazardous materials, including the potential impact associated with each, and measures to be taken in the event of accidental release

Training plans, testing exercises (including fire drills) and schedules for effectiveness Training and awareness components to be considered will include:

Accidental discharges to water and land

Accidental exposure of employees to hazardous substances

Medical evacuation



Work stoppage incidents requiring medical intervention across all aspects of the operation

Accidental fires and fire drills

Vehicle accidents, including vehicle collisions with pedestrians

The above considerations are also directly applicable to potential risks to host communities’ health and safety.

5.5 Community Health and Safety

Depending on the level of interaction with the host communities, MML staff and contractors may have to undergo community health and safety training. The objectives of the community health and safety training are:

Induction and training to raise awareness about local community norms and values

Specific community-based interventions based on the proactive identification of safety behaviour and trends

Emergency Response Plan

Stakeholder Engagement Plan Many aspects of community engagement related to the project potentially involve partnerships with relevant local government and non-government structures and appropriate consultation with these stakeholders must be ongoing throughout the exploration phase.



6. STAKEHOLDER ENGAGEMENT PLAN

6.1 Introduction

The stakeholder and community engagement process is a crucial component of the process, and for the project’s future phases. It is vital that all Project Affected Persons (PAP) and PAC are not only aware of the project and its possible negative implications, but also understand the project and its potential benefits to their communities and surrounding environment. Failure to do so could cause disputes and disagreements between communities, the developer and government authorities and the disruption of established structures such as community administration. Mozambican law establishes the rights of citizens to have information about, and to participate in, decision-making about activities which may affect the environment. In summary, the directive requires that a stakeholder engagement process is carried out whenever the proposed activity implies the relocation of goods or assets or restrictions on the use of or access to natural resources. A Stakeholder Engagement Plan (SEP) is required to identify the PAC, disseminate information to them, manage a dialogue with the proponent of the activity, assimilate and take into account public comments received and feedback the outcomes of the dialogue and inputs so as to demonstrate how these have been taken into account in the design of the activity. Stakeholder Engagement is an integral part of the project process and will not end with the issuing of the environmental license but will continue during the construction and operational phases of the planned activity.

6.2 Stakeholder Engagement Planning

A SEP is the basis for building strong, constructive and responsive relationships that are essential for the successful management of a project's E&S impacts. This is an on-going process that may involve, in varying degrees, the following elements: Stakeholder engagement planning; disclosure and dissemination of information; consultation and participation; a Grievance Mechanism; and on-going reporting to affected communities. Disclosure of relevant project information helps affected communities and other stakeholders understand the risks, impacts and opportunities of the project. MML will provide affected communities with access to relevant information, and consultation gives affected communities the opportunity to express their views on project risks, impacts and mitigation measures in a non-intimidating setting. In instances where stakeholder engagement is the responsibility of the national authorities, MML will collaborate with the responsible government agency, to the extent permitted by the agency, to achieve outcomes that are consistent with the required objectives. Additional benefits of timely stakeholder engagement include the following:

It assists the developer to address relevant issues, including those raised by the different stakeholder groups.

It harnesses traditional knowledge which conventional approaches often overlook.

It improves information flow between the developers and different stakeholder groups, improving the understanding and ‘ownership’ of a project.

It enables project proponents to better respond to different stakeholders’ needs.

It helps to identify important environmental characteristics or mitigation opportunities that might have been overlooked during the environmental authorisation process.

It helps to ensure that the magnitude and significance of impacts has been properly assessed; and improves the acceptability and quality of mitigation and monitoring processes.

It may avoid escalation of potential conflicts between the company and the stakeholders.

This approach is also fundamental to ensuring that any Corporate Social Responsibility (CSR) programmes established by MML are informed by these communities’ needs and desires.



6.3 Proposed Stakeholder Engagement Plan

Community engagement will be undertaken in accordance with the requirements of the national legislation and regulations. This will be achieved through the development of a SEP by MML (utilising its existing community engagements forums and personnel as it does for its current operations) specifically focussed on the ten PAC villages identified in this EMP prior to any further project-related activities that affect the stakeholders and surrounding villages in any way. The SEP will include an External Communications and Grievance Mechanism procedure to be managed by the EHS-M and EHS-O respectively, with support from the CLO. These requirements are interpreted as follows:

When local communities may be affected by risks or adverse impacts from a project, the project sponsor will undertake consultation with them.

Community engagement will be free of external manipulation, interference or coercion and intimidation; and conducted on the basis of timely, relevant, understandable, inclusive, culturally appropriate and accessible information.

Stakeholder engagement must be initiated early in the exploration phase and continue on an on-going basis throughout.

PAC must be provided with opportunities to express their views on project risks, impacts and mitigation measures and allow the project proponent to consider and respond to them.

Where PAC or affected persons are liable for compensation by MML for disturbances to their agricultural activities, or a demonstrable loss of income as a result, the SEP will provide the means for negotiation and resolving these compensation events.

It is also required that the SEP contain the necessary Compensation Framework (CF) that will detail the manner in which compensation will be calculated and paid over to any persons or communities whose agricultural production is affected in any way. This should be in accordance with the existing framework used for the MRM mine.

As part of this process, MML will develop a list of stakeholders which will be captured in the SEP. The list will be considered dynamic and will need regular updating, as the relationship between stakeholders and MML develops and changes.

Information dissemination involves written and verbal information-sharing to a range of stakeholders. This could relate to anticipated impacts or on-going management and mitigation of social issues. Different information dissemination tools can be used:

Distribution of documents (information leaflets/minutes of meetings etc.);

E-mails and SMS messages;

Meetings (public meetings, focus group meetings etc.);

General community meetings;

Government liaison;

Company website updates and information-sharing;

Annual reporting;

Corporate Social Responsibility (CSR) reporting;

Radio advertisements; and

Posters/billboards. Information dissemination strategies must be tailored to benefit the specific target groups:

Communication will be in the language of the stakeholders;

Documents must include pictorial illustrations where possible;

Written documentation must be accompanied by verbal explanation, especially when dealing with PAP/PAC;

Interpreters must be available during meetings (Portuguese/local language);



Meetings must be arranged to reach the community at large and be widely announced;

Local and traditional authorities must be involved in disseminating information; and

Information sessions must provide opportunities for clarification (allow a Question & Answer session).

Consultation is a two-way sharing of information between the project proponent and stakeholders, and must be sensitive to the needs of the different stakeholder groups. All consultations should be planned at least a week in advance, to allow the interest group(s) to plan accordingly and be able to attend the meeting. Should it be necessary, newspaper or radio advertisements might need to be placed to inform the wider public and community members. Relevant information should be provided to stakeholders in advance of consultation, to allow stakeholders to participate effectively (documents are sent in advance of meetings, stakeholders are informed about the agenda of the meeting). Care must be taken to capture all perspectives in the minutes (in particular, gender differences and livelihood differences at local community level). The outcomes of the consultation processes will be reported back to stakeholders, and could include responses to requests, consideration of suggestions and providing feedback on the minutes of previous meetings.

Detailed minutes must be prepared at least five days after the meeting, and it is advisable to use a recording device and retain a recorded copy of the meeting. Minutes should at least cover the following components:

Original attendance register(s) of all those present attached to the minutes

The date, time and place of the meeting should be indicated;

An indication of how the meeting was arranged and what the objectives were;

The person(s) who chaired the meeting, with a detailed description of key stakeholders present at the meetings (such as proponent, government and community representatives);

An overview of what was discussed in the meeting (this can be in a short format, such as bullet points);

An issues and response trail (or similar); and

Important conclusions and/or commitments. Minutes are useful to refresh attendees’ memories about the previous meeting’s discussions and action points, and to measure what actions have been taken since the last meeting. Relevant government authorities should be queried as to how often they require feedback on the project and meetings, as well as the format they prefer to have minutes sent to them. Minutes should be drafted in Portuguese, but it is also proposed that MML have English versions. All meeting minutes shall become public documents and be distributed to relevant government authorities and those affected at least five days after a particular meeting. General email correspondence needs to be followed-up with telephonic conversations and consequent minute-taking. For those affected members who might not have access to internet facilities, minutes also need to be lodged at a central location (such as the local libraries) at least five days after a meeting or formal interaction, and affected community members should be well-informed as to how these minutes can be accessed and comments made. Minutes need to be amended as soon as any feedback has been received, and the revised minutes need to be disseminated in the same fashion. Of importance is to inform those affected of the availability of minutes and the procedures for reviewing and commenting on these. Some stakeholders and PAC/PAP are potentially affected by exploration activities on a daily basis and may have issues and/or concerns with the project that affect their daily lives. Therefore, a particular mechanism is needed to ensure continuous consultation and



engagement between the company and directly affected parties. A suitable mechanism for direct engagement is to establish a working group, and formalise a system for affected members to solve problems and/or issues related to the project collectively, and to receive feedback on the project, on a regular basis. It should act as a forum for the project’s stakeholders to channel concerns which affect them directly. The central element is a Grievance Mechanism that allows an affected person to voice his/her concerns.

A Grievance Mechanism which allows the PAC/PAP voice issues/concerns/comments to the proponent in a fair manner. The Grievance Mechanism Must continue to function for the entire exploration period and deal with grievances related to environmental, health and safety aspects, cultural and socio-economic issues. The Grievance Mechanism must:

Provide the PAC with an accessible and prompt mechanism through which to lodge a complaint and/or resolve any dispute that may arise in connection with the project;

Facilitate mutually acceptable corrective actions, and address complaints efficiently;

Ensure that complainants are satisfied with the outcomes of any corrective actions undertaken by MML; and

Avoid/minimise the need to resort to judicial proceedings. The Grievance Mechanism will be implemented by the project’s EHS Department through the The CLO and EHS-Manager. The mechanism is illustrated in Figure 7-1 below.

Figure 7-1: Simplified Grievance Mechanism

The proposed Grievance Mechanism process is detailed in Annexure A.



7. IMPLEMENTATION OF THE ENVIRONMENTAL MANAGEMENT PLAN

7.1 Introduction

The purpose of this section of the EMP is to provide detailed recommendations aimed at mitigating negative impacts and enhancing benefits associated with the construction, operational and decommissioning phases of the project. As discussed in Chapter 1 of this report, these requirements have been presented as a framework to allow for a certain degree of flexibility in the development of specific mitigation measures as more detailed technical information is made available to MML and its contractors. The EMP specifications are detailed in Table 7.1 below.

7.2 Exploration Phase Mitigation Measures and Responsibilities

This section provides detailed recommendations and specifications aimed at mitigating negative impacts and enhancing beneficial impacts associated with the exploration phase activities. Specific requirements aimed at mitigating the various E&S impacts identified for this project have been included and must be considered by MML for implementation. The specification checklist details the anticpated impact areas, the source of these potential impacts, the principles and requirements necessary to achieve successful mitigation, as well as the personnel responsible for ensuring these commitments are met. As noted in this EMP the key performance areas and indicators that will be utilised by MML to track the EMP implementation will need to be developed and finalised by MML personnel prior to the commencement of exploration activity. The proposed rehabilitation specifications and considerations are presented in Chapter 10 in more detail.



Table 7-1: EMP Specifications

IMPACT AREA SOURCE OF IMPACTS MITIGATION PRINCIPLES/REQUIREMENTS RESPONSIBILITY

ENVIRONMENTAL, HEALTH &SAFETY MANAGER (EHS-M) - ENVIRONMENTAL, HEALTH &SAFETY OFFICER (EHS-O) - COMMUNITY LIAISON OFFICER (CLO)

1. BIOPHYSICAL IMPACTS

Loss of Plant Biodiversity

The removal of vegetation will cause the loss of vegetation communities and plant species within the study area. These are dynamic ecosystems that provide habitats that support all forms of life. Different types of communities (and habitats) exist in the study area, and these occur in various proportions within the study area and beyond. However, the loss of portions of the different habitats will differ, and the impacts on these need to be considered separately, and must take into account their vulnerability and distribution beyond the study area.

Impacted areas that are no longer required must be rehabilitated and re-vegetated.

Where feasible, existing access roads must be used. Keep the width of the access/haul roads and subsequent clearing during construction to a minimum.

Access roads must avoid wetlands and drainage lines where feasible.

Where feasible, river crossings must be located in already degraded areas and these should be kept to a minimum.

Prevent employees from harvesting plants for personal use, firewood or charcoal within the study area.

Keep the width of the access roads and subsequent clearing to a minimum.

Avoid locating linear infrastructure (such as roads and drilling lines or pads) through areas of high sensitivity.

No bulk sampling pits to be located in areas of high sensitivity - this includes wetland ands areas close to rivers/watercourses.

EHS-M

EHS-O

Fragmentation of Habitats

An ecosystem provides more than simply a ‘home’ for a set of organisms, and is a functional system where biological and biophysical processes such as nutrient cycling, soil formation, reproduction, migration, competition, predation, succession, evolution and migration take place. Destruction or modification of habitats causes disruption of ecosystem function, and threatens the interplay of processes that ensure environmental health and the survival of individual species.

Do not construct access routes through high sensitivity areas and avoid marshy areas as far as possible

Rehabilitate road verges and laydown areas impacted on and no longer required.

Top soil (upper 20cm) containing seeds shall be collected and stored during the exploration process and later used for rehabilitation.

Monitor the study area for any new invasive plant species and eradicate them as they appear.

Loss of Faunal Diversity

Amphibians are motile species, and populations will be displaced due to habitat loss and fragmentation. The immobility of frogs will further make them susceptible to road mortalities related to an increase in the number of project vehicles using roads. Increased noise and motor vibrations may also impact amphibian breeding choruses, but these impacts will be localised and many amphibian species are surprisingly tolerant of vehicle noise. Amphibians are likely to be the most impacted by an increase in dust levels. Dust can increase the turbidity of streams and wetlands which may in turn inhibit amphibian’s ability to feed and breed. Spillages of hydrocarbons and other pollutants may lead to development abnormalities and fatalities of amphibian species. Habitat loss and fragmentation will result in the displacement of reptile species. Increased mortalities from road collisions as well as persecution by people can be expected. Some birds, particularly nocturnal species such as owls and night-jars will be killed on the roads if there is an increase in the number of project vehicles using roads at night. Habitat loss and fragmentation will result in the displacement of mammal species. Most mammals in the EL area are highly mobile, however, high mortalities of species such as moles can be expected, due to earth works associated with bulk sampling activities.

Roads must avoid riparian areas, other than river crossings, and be located a safe distance from these areas.

Speed restrictions for all project vehicles (30km/h is recommended) should be in place to reduce the impact of amphibians, reptiles, mammals and birds being killed on the project roads.

Dust suppression techniques, such as the watering of project roads, must be implemented during the dry season.

A search and rescue plan should be developed for amphibians which fall into sampling pits.

Storage facilities for chemicals should be bunded and situated in high lying areas to avoid spillages and damage from flood events.

As far as possible, protect abiotic habitats, such as rocky outcrops, which provide shelter for many reptile species.

Project employees must be made aware of the risks associated with working in areas containing dangerous animals.

Project employees must be trained on how to react when encountering dangerous species.

Prevent employees from killing fauna through environmental training and ongoing awareness campaigns.

Prohibit and impose penalties on project personnel for purchasing bush meat from local communities/hunters.

EHS-M

EHS-O

Sedimentation and elevated turbidity in rivers

Introducing additional sediment loads into surrounding watercourses/wetlands/streams due to exploration activities is to be avoided. Vegetation cover may be destroyed without implementing measures to limit erosion and off-site transport of sediment during clearing of top-soil or excavation of bulk sampling pits. Together with run-off from roads and construction of river crossings for vehicles, these actions may increase soil erosion and hence sediment-laden run-off into adjacent watercourses.

Ensure that stream and watercourse crossings are appropriately designed and maintained, but minimised as far as possible.

Maintain the integrity of vegetation in the riparian zones of watercourses.

Prevent or limit disturbance to water resources during the planning phase.

Top soil should be removed and stockpiled for rehabilitation.

Maximum vegetation cover should be maintained outside the cleared areas, particularly in riparian areas, to act as silt traps.

Natural drainage lines must not be impeded or otherwise interfered with.

Erosion should be monitored over the entire site and, where initial indications of erosion are detected, appropriate remedial measures must be taken as soon as possible.

EHS-M

EHS-O

Loss of Natural Resources

A number of plant resources are used as a source of food, for medicinal purposes and for the construction of shelters. The loss of vegetation at the drill sites and bulk sampling sites could result in the loss of important species used by the communities. However, these species are relatively widespread and not limited to the study area or the construction footprint.

Limit road, camp and drill pad clearing to the designated areas and keep clearing to the minimum required for drilling and bulk sampling locations. The harvesting or collection of wild foods and other plant material by employees or contractors shall be prohibited.

Appropriate disciplinary procedures shall be taken against offenders by the contractor’s management and notification given to MML management of the actions taken.

EHS-M

EHS-O

Vehicle, earthmover and drill rig movements

Minimisation of compaction of topsoil must be avoided so as to ensure that later rehabilitation efforts are not hampered by unnecessary compacting of the top-sol and vegetation seed banks contained therein. Controlling vehicle and drill rig movements is also essential to avoid disturbance of areas outside of those necessary for drilling or bulk sample pit purposes.

Transport routes to the drill pads and campsites shall be clearly marked. All vehicles used for transportation/ excavation/ drilling purposes shall remain within these demarcated routes and areas.

No movement off these access routes shall be permitted once constructed.

In emergency situations (e.g. flooding, road damage) deviations off-road are permitted, as long as any damage to sensitive environments is rectified as quickly as is practically possible and before the end of the drilling campaign.

The EHS-M and EHS-O shall be notified of these deviations to evaluate the impact and to determine mitigation measures and rehabilitation strategies, where applicable.

CLO

EHS-O

Contamination from pollutants

Hazardous materials and chemical pollutants (e.g. hydrocarbons, paints, drill rig fluid leaks, drill water, etc.) associated with drilling activities, as well as washing detergents and soap, poorly-treated domestic effluents from accommodation camps, or employees using rivers and riparian zones for ablutions, could pollute both groundwater and surface water. These pollutants could be harmful to aquatic biota and impact on drinking water quality for communities and domestic livestock downstream as well as exploration personnel themselves.

No fuel or any other chemical storage shall be below ground.

No hazardous material or bulk fuel storage anywhere outside of the exploration area is permitted without approval from the EHS-O.

MSDS for all chemicals must be readily available on site and the precautions stipulated in these must be adhered to at all times. All staff must be trained on the correct management of bunded facilities, including the discharge of collected liquids.

Spill kits must be readily available at strategic points throughout the site and staff must be trained on the correct use of these kits.

No hazardous wastes should be disposed of into drains as this may impact negatively on the performance of the septic tanks.

Prevention of hydrocarbon spills from machinery and vehicles by the use of drip-trays and permanent bunded areas for overnight parking. This should include any temporary work areas envisaged for the project.

All spills of fuels, oils or other hazardous substances must be immediately cleaned up and measures taken to remediate the spill. Bioremediation measures must be considered before disposal of contaminated soil at a registered facility is considered.

Domestic and sewage effluent from the exploration camp should be managed in accordance with existing MML procedures in this regard for its mining operation. This implies a conservancy tank system will be adopted for removal and treatment at the existing operation, alternatively, a French drain soakaway system must be employed that cannot pose a threat to underground or surface water resources.

All contaminated water run-off from camp sites must be contained and treated prior to discharge.

Used oils and greases shall be separated and recycled wherever possible, or disposed appropriately, in accordance with national legislation.

Chemical toilets should not be used during the construction period unless the contents can be disposed of in a manner that does not pose a threat to the environment. Instead, alternatives such as composting toilets or similar should be considered as preferred alternatives. They must be lined, maintained and sited in a way that minimises the risk of contamination of surface and sub-surface water resources.

EHS-M

EHS-O



IMPACT AREA SOURCE OF IMPACTS MITIGATION PRINCIPLES/REQUIREMENTS RESPONSIBILITY

ENVIRONMENTAL, HEALTH &SAFETY MANAGER (EHS-M) - ENVIRONMENTAL, HEALTH &SAFETY OFFICER (EHS-O) - COMMUNITY LIAISON OFFICER (CLO)

2. SOCIAL IMPACTS

Population influx or in-migration / General Health and Safety risks

There are several direct and indirect impacts associated with an influx of people that will likely result in social, cultural, economic and political changes to the area, examples of which are listed below:

Tension and conflicts between locals and migrants regarding access to: natural resources, land and employment opportunities;

Localised inflation of food and produce prices due to increased demand;

Increased pressure on already limited social and natural resources;

Increased ‘social ills’, such as prostitution, alcohol abuse, and crime;

Increased prevalence of communicable diseases;

Creating ‘poverty gaps’ and income and wealth inequalities between locals and migrants; and

Disruption of local cultural and social dynamics.

It must be noted that while there can be positive impacts resulting from this in-migration such as improved links to the mainstream economy, increased household or community empowerment and improved access to social infrastructure and public goods and services, it is the potentially negative ones that are addressed in more detail here.

A Stakeholder Engagement Plan (SEP), including a Grievance Mechanism must be developed to allow community members the latitude to inform the proponent of any machambas in the area; indicate where access to agricultural land is restricted and to report any other agricultural issues as a result of the project activities. Employ directly affected, employable community members as a first priority for job opportunities and training, prior to employing people from further afield.

No hiring of job seekers on site.

No procurement of local goods at the gate, but at centralised locations or village markets.

Maximising local content in procurement i.e. from local people and towns, whenever possible and whenever project requirements are met.

The entrances to the project area must be controlled by trained security personnel.

All the PACs must be informed about the roles and responsibilities of the security personnel through community briefings.

Reported incidents must be assessed by MML, who will implement appropriate measures as is legally permissible for them and their security personnel. A zero-tolerance for alcohol should be adopted at the site.

Regular monitoring and inspections of the labour force can ensure that such an approach to alcohol is applied. Regular alcohol testing campaigns can be considered.

MML is encouraged to develop an awareness campaign in collaboration with the local clinic for both communicable- and non-communicable diseases and prevention strategies. This campaign should be aimed both at the workforce and also the wider PAC.

A Code of Conduct should be developed for all workers at the mine to conform to basic health standards. This should include standards for not urinating or defecating in any open water sources.

CLO

EHS-O

Economic Displacement and Cultural Heritage

Machambas or other agricultural lands, fruit trees and other natural goods and resources where access may be restricted, temporarily disturbed, or affects a landholder to an extent that compensation for their justifiable losses is necessary. Similarly, project activities could impact of grave sites and cultural heritage resources if inadequate consultation on these aspects is undertaken with affected communities. Cemeteries, gravesites and sacred sites are integral to communities’ cultural and social identity. The disruption or restricted access to these sites would undermine the traditions and culture held by the communities in favour of the proposed project activities.

A Compensation Framework (CF) will be developed by MML in conjunction with local authorities, leadership and PAC to determine what are legitimate grounds for compensation, how this will be calculated, and the manner in which this will be paid over will be finalised by MML prior to the commencement of exploration activities. Any grave sites or sacred sites identified in the project area must be recorded. A buffer area must be established around the grave or sacred site and no activities associated with the proposed project must fall within this buffer.

A Chance Find Procedure and Grievance Mechanism must be developed to allow community members the opportunity to inform MML of any sacred sites or gravesites in the project area; indicate if/where access to these sites are restricted and to report any other disturbance to these sites as a result of project activities.

Should any sacred sites or grave sites be affected, the affected communities will be notified in advance and provided the option to receive compensation and/or assistance with reburial and related expenses, which will be determined through the CF.

CLO

EHS-M

EHS-O

Increased risk of vehicle collisions and personal injuries

The roads which project-related traffic will be using pass through a large number of settlements, and frequently market activity is clustered alongside the road, where existing, non-mine-related traffic volume is highest. In these settlements of concern, vehicles are pulling onto and off the road without using their indicators, pedestrians cross the road at random points, children play alongside the road. The risk of accidents in these environments, especially when drivers are working to a tight schedule, is increased.

Consideration must be given to designing the road to bypass settlements where housing and people are located too close to the road for public safety reasons.

Within the boundaries of the mine site signage should be used to specify speed limits, and adherence to these limits should be monitored and rigorously enforced. On the national roads, the specified speed limit must be strictly adhered to by the mine and contractor workforce.

A road safety awareness campaign should be conducted in each village and schools.

Deliveries of construction material at night should be avoided.

All drivers shall receive training for each type of vehicle including light vehicle training, heavy vehicle truck training and abnormal truck load (including low-bed and trailers) training before they are permitted to drive these.

Deliveries by heavy vehicles must, as far as possible, be scheduled to avoid the formation of convoys. Sufficient distance, as specified in the Road Code, must be maintained between heavy vehicles to allow light vehicles to overtake safely.

An Emergency Response Plan (ERP) must be prepared, and must include provisions to deal with traffic accidents, particularly accidents involving personal injuries, and all drivers must be made aware of the procedures to be followed. The ERP shall comply with the detailed requirements specified in Section 5.4 of this document.

EHS-M

EHS-O

Noise Noise emissions from drilling, excavating and road transport activities throughout the exploration phase.

Noise levels shall be controlled to ensure no detrimental effect to landowners, occupants, employees or the general public.

All vehicles and equipment must be maintained regularly to prevent excessive emissions and noise. Silencers and noise control devices shall be used where required.

The generator supplying power to the drilling rigs and exploration camp needs shall be equipped with acoustic shields to ensure that sound emissions from these sources do not exceed 85 dBA at 5 metre from source.

The drilling sub-contractors shall demonstrate compliance with the internationally accepted noise standards. The noise levels (LAeq) caused by the drilling at the households closest to the drilling activities(if any) shall not exceed: o Daytime: 55 dBA o Night-time: 45 dBA

Minimise individual vehicle engine, transmission and body vibration. This can be achieved by regular maintenance of the vehicles.

When designing roads, avoid need for excessive acceleration and deceleration by minimising slopes.

Maintain road surface to avoid corrugations and potholes.

Minimise the need for trucks to reverse and activate their reverse sirens.

CLO

EHS-O

Dust generation and other air pollutants

Vehicle movements and excavation activities are the major contributors to dust emissions in the exploration phase.

Dust shall be controlled to ensure no detrimental effect to landowners, occupants, employees or the general public.

Dust suppression measures may include dust suppression using water spray and surface binding using ‘environmentally friendly’ products.

The contractors shall ensure that all diesel and other mechanical equipment is in good working order, minimises exhaust fumes and associated air emissions.

EHS-O

Lighting Camp lighting will be visible owing to tits fairly remote location removed from electrified areas and settlements.

No spotlights shall be pointed away from the exploration camp or drill pad sites. All lighting shall be shielded and shall be directed downward onto the site so as to avoid light spillage into surrounding areas.

EHS-O

Prevention of fires and minimisation of fire damage

Fire risks are particularly high during the dry season, particularly in areas were the local population uses fire to prepare new areas or machambas for cultivation.

Specific measures must be taken to prevent the spread of bush fires caused by activities at all sites.

No barbecues or cooking on open fires must be allowed in the drill pad areas. Designated facilities for this must be located in an approved position in the exploration camp.

The construction of firebreaks around the exploration camp.

Instruction of employees about fire hazards and how they are dealt with in the Emergency Response Plan.

Conduct regular fire drills and firefighting training.

Ensure the exploration camp and drill pads have sufficient availability of firefighting equipment.

CLO

EHS-M

EHS-O

3. REHABILITATION

Exploration Camp, Bulk Sample Pit and Drill Pad rehabilitation

All disturbed surface areas will be rehabilitated (and revegetated) as far as possible. The bulk sampling pits will need to be sloped and contoured so as not to pose erosion and general safety risks, and revegetated as far as possible.

At the end of the drilling campaign the EHS-M and Technical Manager shall determine the level of rehabilitation effort required for each drill pad and sampling pit. Refer to Chapter 10 in this regard.

They will also determine which access routes shall be rehabilitated or kept maintained.

A rehabilitation close out register should be established that sign off of each site, any outstanding E&S issues and how they should be closed out. Lessons learnt shall also be recorded in this document for future consideration by MML.

EHS-M

TECHNICAL MANAGER



8. EMP IMPLEMENTATION, PERFORMANCE REVIEW AND REVISION

8.1 Introduction

MML will establish procedures to monitor and measure the effectiveness of the EMP as well as compliance with any related legal and/or contractual obligations and regulatory requirements and applicable standards. Where the authorities or other third party has responsibility for managing specific risks and impacts and associated mitigation measures, MML will collaborate in establishing and monitoring the implementation and effectiveness of such mitigation measures. Where appropriate, MML will consider involving representatives from surrounding communities to participate in monitoring activities. Crucial to ensuring that this EMP remains effective and fit for purpose is the necessary and periodic review thereof by MML. It is recommended that these revisions be undertaken on an annual basis after the MML finalisation of the next version of this EMP prior to the commencement of exploration activities. This next version will provide more detail on the drilling target areas, location of the exploration camp, access roads and other required infrastructure. In addition, the training and capacity building interventions to be undertaken by MML, the EMP budgeting and resourcing considerations, as well the necessary key performance areas and indicators to be utilised in the EMP monitoring processes and reporting outputs by MML personnel going forward will be defined. Also of key importance is the required Compensation Framework (CF) that MML has yet to develop in conjunction with local leadership, authorities and PAC that will address the means and mechanisms for determining compensation amounts and the subsequent payment processes to persons who may be economically displaced by the exploration activities. It is recommended that this framework is aligned with the one in place for the operational mine. These subsequent and ongoing EMP revisions will need to be informed by the observations, findings and outcomes of the performance review and reporting actions that are discussed below.

8.2 Incident Reporting, Non-compliance and Corrective Action

MML and its contractors will develop procedures for managing E&S incidents, subject to approval by its senior management. A report will be completed for all incidents, and appropriate action taken where necessary to minimise any potential impacts. The relevant authorities will be informed of any environmental incident, in accordance with legislative requirements. Notification of an incident or emergency will include the following:

Description of the incident.

The location of the emergency or incident.

The name and telephone number of the designated contact person.

The time of the emergency or incident.

The suspected cause of the emergency or incident;

The environmental harm and/or environmental nuisance caused, or suspected to be caused, by the emergency or incident.

The action taken to prevent future occurrence of the incident and mitigate any harm and/or environmental nuisance caused by the emergency or incident.

The Incident reporting and documentation requirements will be based on best practice principles, and will take the following requirements into account:

Documents associated with the EMP will be regularly reviewed and updated by all environmental management parties.



External environmental audits may be conducted annually by accredited institutions. Internal audits will be conducted regularly for the duration of the exploration phase. The purpose of the audits will be to assess compliance with the conditions of the Environmental Licence, and objectives and targets outlined in the EMP, and its various management tools.

The findings of external, internal and informal environmental reviews will be recorded and items requiring action will be identified from the recommendations made and actions implemented by MML.

An EMP is deemed not to have been complied with when:

There is evidence of contravention of the recommendations in the document, or its environmental specifications.

If exploration activities take place outside the legal boundaries of the concession area;

Environmental damage ensues due to negligence.

Personnel fail to comply with corrective or other instructions that have been issued as corrective measures.

Personnel fail to respond adequately to complaints from the public or authorities.

There are several mechanisms for implementing corrective action and they include verbal instructions, written instructions and contract notices. Verbal instructions are likely to be the most frequently used form of corrective action and are given in response to minor transgressions that are evident during routine site inspections. Verbal instructions are also used to create further awareness amongst contractors, as often the transgressions are a function of a lack of awareness. Written instructions will be given following an internal audit that deems this necessary. The written instructions will indicate the source or sources of the problems, and proposed solutions to those problems. The implementation of these solutions can also be assessed in a follow-up audit and further written instructions issued if required. All written instructions will be centrally logged to ensure that there is an auditable record of such instructions and how they were dealt with and closed out. A contract notice is a more extreme form of written notice because it reflects the transgression as a potential breach of contract. If there is not an adequate response to a contract notice, then the next step can be to have the contractor removed from the site and the contract cancelled. Contracts should be drafted with this in mind.

8.2.4

MML and the contractor/s will ensure that a dedicated complaints register is kept on site at all times. The register will contain the details of the person who made the complaint, the nature of the complaint received, the date on which the complaint was made and the response noted with the date and action taken. The register will be kept in accordance with these requirements by the CLO and EHS-O. This record shall be submitted with the monthly reports and an oral report given at the monthly site meetings.

8.3 Checking and Monitoring

Checking and monitoring will be implemented and is required to ensure that the EMP actions are being implemented and desired outcomes are being achieved. If not, then corrective action will be identified and implemented. This requires on-going inspections and continuous improvement



of general state of the operations; focussing on a particular performance issues and outcomes.

Key performance objectives and targets (measurable indicators for key E&S aspects) against which the performance of the project can be measured and monitored will be developed as part of EMP finalisation process prior to commencement of exploration activities. These objectives and targets will be clearly defined and incorporated, where appropriate, as contractual obligations that have to be fulfilled by third parties. In so doing, MML will be better able to manage its OHS and E&S risks, as well as any legal obligations that are applicable to their activities. Objectives and targets will be reviewed on a regular basis over the exploration period. In cases where objectives and targets are not being met, new or revised specifications and Method Statements indicating the proposed corrective measures, will have to be developed and approved by the designated MML personnel.

MML and its contractors will establish procedures to monitor and measure the effectiveness of the EMP, as well as compliance with any related legal and/or contractual obligations and regulatory requirements (further detailed in Chapter 9 that follows). Results obtained from the monitoring programme will be structured and presented for review on an on-going basis so that if objectives and targets are not met, corrective action can be taken. It is required that all monitoring programmes are to be headed by appropriate personnel in the organisational structure. Where appropriate, MML will consider involving representatives from affected communities to participate in the monitoring activities. Where skills do not exist, or where significant impacts are involved, MML will retain external experts to verify its monitoring information. In instances where a third party has responsibility for managing specific risks and impacts and associated mitigation measures, MML will collaborate with these parties in the establishment and review of such activities.

On-going monitoring, inspection and continuous improvement will form a key component of the EMP, as documents associated with the EMP (audit reports, monitoring programme results, Grievance Mechanism etc.) will be regularly reviewed and updated. Where necessary, research on certain aspects will be undertaken to refine environmental management and to ensure that the levels of environmental protection outlined in this EMP are achieved. The greatest source of information will be obtained through ongoing visual inspection. At the same time some potential impacts are difficult to monitor quantitatively, such as soil erosion and waste management and these aspects - and all other relevant ones identified in this document – must be measured accordingly to track performance over time. An on-going, but practical inspection regime will be developed that allows for potential non-conformances to this EMP to be identified proactively so that adapted mitigation measures can be quickly and effectively implemented.

Audits on the implementation and environmental performance of the EMP may be undertaken on an annual basis by accredited institutions if deemed legally required by MML, or if it is requested by a given authority or government department that is within their rights to do so. The purpose of the audits will be to:

Assess compliance with the conditions of the Environmental and Exploration Licences;

Determine if the objectives and targets outlined in the EMP are being met; and

Provide the necessary supporting documentation and findings setting out the proof for the above compliance findings.

The findings of external, internal and more informal environmental reviews will be recorded and items requiring action will be identified through this ongoing review process. The implementation of these additional, or corrective action requests, will be assessed in a



continuous follow-up manner in order to prevent the recurrence thereof.

8.4 Management Review

The process of management review is in keeping with the principle of continual improvement. As such, MML will develop a Senior Management review procedure to ensure that the company defines and maintains a documented process and agenda for Senior Managers to periodically review the continuing suitability, adequacy and effectiveness of the EMP. The review, which should be conducted annually, will include a review of internal and external audit reports as well as well as the cost estimates for implementation of the EMP. The purpose of the review is to critically examine the effectiveness of the EMP and its implementation and to decide on potential modifications, as and when identified as being necessary.

8.5 Financial Budgeting and Adequate Resourcing

The proponent will be responsible for ensuring that sufficient financial resources are made available for the effective implementation of the requirements of this EMP. Where applicable, and particularly during the construction phase, MML will need to ensure that all contractors are aware of their obligations in terms of this EMP and that they have made appropriate financial provisions to ensure full compliance to the EMP implementation, performance monitoring and ongoing revision obligations.



9. EMP MONITORING PROGRAMME

9.1 Objectives

The objectives of the Monitoring Programme are:

To confirm compliance with commitments to legislative and non-legislative requirements detailed in Chapter 4

To provide early warning of potential impacts, determine the extent of predicted impacts and identify any unforeseen impacts associated with the project activities;

To provide feedback on the adequacy of environmental management practices and allow improved practices to be developed to continuously improve operations;

To detect and measure environmental trends or changes and enable analysis of their cause; and

To provide site management with information and data that can be used as a basis for decision making.

9.2 Monitoring Categories

Three monitoring categories shall be included and these are described below.

1. Ambient Monitoring: This involves the monitoring of background conditions and receiving environments that could be affected by project construction activities. While discharge monitoring should determine if environmentally significant releases have occurred, effects on the ultimate receptors within the receiving environment beyond the boundary of the facility can be determined only by ambient monitoring. Ambient monitoring will be undertaken for surface water, ambient dust and noise.

2. Investigation Monitoring: This will be completed as required to determine the occurrence, nature and extent of possible impacts following an environmental incident, such as oil spillage, or to verify/refute third-party claims of environmental impacts. For example, investigation monitoring may be undertaken to identify a source of contamination.

3. Occupational Health and Safety Monitoring: The working environment will be monitored for occupational hazards relevant to the project. OHS monitoring will be designed and implemented by accredited professionals as part of an occupational health and safety monitoring program with recognition for post-closure long term health concerns. As part of the monitoring programme, occupational accidents, diseases and dangerous occurrences and accidents will be documented for all facilities.

9.3 Monitoring Responsibilities

Implementation of the environmental component of the programme is primarily the responsibility of the EHS-M. However, the Safety Officers will be responsible for monitoring employee health statistics while the EHS-O and CLO will be responsible for monitoring local community employment statistics and reported issues and impacts. MML, through the EHS-M, will ensure that bio-physical monitoring responsibilities are clearly defined within the EHS Department. Where appropriate, MML will consider involving representatives from affected communities to participate in the monitoring activities. Where skills do not exist, or where significant impacts are involved, MML will retain external experts to verify its monitoring information. In instances where a third party has responsibility for managing specific risks and impacts and associated mitigation measures, MML will collaborate in the establishment and monitoring of such activities.

9.4 Reporting

Monitoring results will be compiled by the EHS-M for submission to the General Manager on a monthly basis. Environmental monitoring results shall be incorporated into quarterly, bi-annual and annual reports as applicable.



9.5 Monitoring Aspects and Areas

MML management will implement and maintain a dust monitoring programme during the exploration phase in order to collate continuous dust deposition data and have a repository of records covering its dust suppression activities. Availability of such records will assist management in managing dust impacts, resulting in the reduction of respiratory diseases that are as a result of air pollution, reduced risk of damage to property, improved visibility, fewer disturbances to existing flora and fauna habitats, and a reduction in air pollution in general. As the amount of soil exposed is directly proportional to the amount of dust generated and the amount of dust transported, construction during the windy periods may be limited. If construction has to be done during this period, only a small area will be disturbed at a time. As haul roads are a major source of dust, reducing speed of trucks to 30km/h on access/haul roads will reduce dust significantly. During dust generating periods, wetting of the area until it is moist is recommended. Mulching of recently disturbed areas can reduce the amount of wind erosion significantly. Other methods of reducing dust include using wind breaks which can be natural or constructed. On disturbed areas which are not expected to handle vehicle traffic, vegetative cover can be planted.

The monitoring programme will contain a procedure for ongoing noise monitoring throughout the exploration phase. This will be implemented to determine potential sources of noise, any increases and decreases in noise levels, and determine the level of mitigation required. Noise will be periodically monitored monthly at the villages closest to the exploration activities, as well as at the exploration camp as per the specification contained in Table 8.1.

Various types of waste will be generated during the exploration phase. Major waste streams will be domestic, recyclable and hazardous wastes. Management practices and temporary disposal/storage facilities will require monitoring to ensure compliance with the EMP and existing MML procedures as implemented by them in its current mining operation. The objectives for monitoring waste disposal facilities are:

To minimize the impact of wastes on human and environmental health.

To ensure compliance with the national waste management legislation.

To comply with the company waste management commitments. Parameters will include the physical state of waste storage facilities, volumes of waste generated, waste separation, presence of disease vectors, compliance with environmental conditions and state of housekeeping. Monitoring of waste management facilities will be conducted monthly. Waste management will be monitored across EL as a whole, but particularly in the exploration camps and drill pad locations. The waste management team will undergo basic training in waste management and records of their training will be maintained. Waste disposal log-books will be maintained and monthly averages used to identify areas where waste could not have been collected accordingly. Periodic waste discussions focused on lessons learnt will be held with the waste management team to identify areas of improvement. Periodic inspections and observations will be done to monitor waste management practices and behaviour and all the waste management records will be maintained in record books for inspections. Best management practices will be attained through adherence to permit conditions and regulatory requirements. MML will ensure that non-compliances are attended to and where a waste storage facility cannot conform to the best practices perhaps due to location or other reasons, use of such facilities for waste management will be suspended until corrective measures are put in place.



The site will be monitored for all forms of erosion (rill and sheet erosion, gully erosion, stream bank erosion, on a monthly basis. The position of all erosion sites will be recorded using a GPS and fixed point photographs taken at quarterly intervals to monitor its progression and the effectiveness of the mitigation measures.

Monitoring of fauna and flora is aimed at ensuring that project activities and staff do not have an unnecessary impact on the EL area ecology. Sensitive areas, such as inselbergs, must be monitored to ensure that project activities do not encroach into this area. Any incidents of poaching, trapping or illegal harvesting of plants by the company’s employees must be recorded and the staff involved issued with a warning.

9.6 Occupational Health and Safety Monitoring

The occupational health and safety monitoring program will verify the effectiveness of prevention and control strategies. The OHS monitoring programme will be designed and implemented by accredited professionals and will include plans for mitigating post-closure long term health concerns. Facilities will also maintain a record of occupational accidents and diseases and dangerous occurrences and accidents. As a minimum, the occupational health and safety monitoring programme will include:

Safety Inspection, Testing and Calibration: This will include regular inspection and testing of all safety features and hazard control measures focusing on engineering and personal protective features, work procedures, places of work, installations, equipment, and tools used. The inspection will verify that issued PPE continues to provide adequate protection and is being worn as required. All instruments installed or used for monitoring and recording of working environment parameters will be regularly tested and calibrated, and the respective records maintained.

Surveillance of the Working Environment: Employers will document compliance using an appropriate combination of portable and stationary sampling and monitoring instruments. Monitoring and analyses will be conducted according to internationally recognized methods and standards. Monitoring methodology, locations, frequencies, and parameters will be established individually for each project following a review of the hazards. Generally, monitoring will be performed during commissioning of facilities or equipment and at the end of the defect and liability period, and otherwise repeated according to the monitoring programme.

Surveillance of Workers Health: When extraordinary protective measures are required (for example, against biological agents and/or hazardous compounds), workers will be provided appropriate and relevant health surveillance prior to first exposure, and at regular intervals thereafter. The surveillance will, if deemed necessary, be continued after termination of the employment.

Induction and Ongoing Training: Training activities for employees and visitors will be adequately monitored and documented (material, duration, and participants). Emergency response exercises, including fire drills, will be documented adequately. Service providers and contractors will be contractually required to submit to the employer adequate training and induction documentation before start of their assignment.

The employer will establish procedures and systems for reporting and recording occupational accidents and dangerous occurrences, and incidents. These systems will enable workers to report immediately to their immediate supervisor any situation they believe presents a serious danger to life or health. The systems and the employer will further enable and encourage workers to report to management all of the below:



Occupational injuries and near misses

Suspected cases of occupational disease

Dangerous occurrences and incidents All reported occupational accidents, occupational diseases, dangerous occurrences, and incidents together with near misses will be investigated with the assistance of a person knowledgeable/competent in occupational safety. The investigation will:

Establish what happened

Determine the cause of what happened

Identify measures necessary to prevent a recurrence All OHS and incident reporting will be kept on file and maintained by the EHS-M.

9.7 Socio-Economic Monitoring

MML is responsible for implementing the following social dimension requirements:

The local level engagement programme as per the Stakeholder Engagement Plan (SEP) requirements.

The associated Grievance Mechanism.

The agreed upon Compensation Framework (CF) for any person economically affected or impacted on by the exploration activities.

All feedback arising from PAC, the public at large and other key stakeholders such as government representatives.

Monitoring reports are a valuable tool in identifying problems in the implementation of the SEP. The monitoring team should revisit the monitoring programme after each monitoring exercise to evaluate findings and take necessary steps to rectify issues that have been highlighted by the monitoring reports. Indicators used for the existing mine can be applied to this site. An example of wider social indicators for monitoring can include the following as example

Local hiring as per company policy.

Number of local companies involved in supplying goods and services/value of goods and services provided (MML local procurement and purchasing).

Grievance and resolution outcomes.

Costs of social/welfare provisions/services (schools, clinics and medicines, local transport etc.) provided by MML to the PAC and its employees.

Rate of population Influx/In-migration. As for all key performance areas and indicators to be finalised by MML in the next EMP revision, these can be adapted from those already in use for its operational mine.

9.8 Ongoing Monitoring

As noted in Chapter 10 that deals with the rehabilitation requirements and approaches on completion of exploration activities, it is suggested that ongoing monitoring of the rehabilitated sites continues for 3 years at least after the initial rehabilitation works have been completed. It may also be the case that grievances or corrective actions that remain outstanding at the end of exploration activities will still need to be monitored until such time as they are resolved.



10. REHABILITATION PLAN

10.1 General Surface Rehabilitation

General surface rehabilitation of areas that will be disturbed by exploration activity should ensure the surface topography emulates the surrounding area, is free draining, has a “neat” appearance and is re-vegetated. Special attention must be given to shaping and removal of heaps of excess material, scrap and waste. The entire area is to be ripped, covered with 300 mm of topsoil and vegetated. This section explains the general principles to be adopted during vegetation establishment and application of fertilisers for rehabilitated areas.

The main aim when re-vegetating the drill pads, bulk sampling pits and associated infrastructure footprints is to restore the areas back to the pre-exploration phase environment so that they are self-sustaining with a natural nutrient cycle in place and with ecological succession initiated. Although the rehabilitated land may have variable land capability, including arable land capability for some areas (limited), the main aim of this re-vegetation process is to establish a stable, sustainable vegetative cover. The objectives for the re-vegetation of reshaped and top-soiled land are to:

Prevent erosion;

Re-establish eco-system processes to ensure that a sustainable land use can be established without requiring long-term fertilizer additions; and

Restore the biodiversity of the area as far as possible. It is an assumption here that the dominant and pioneer species found local will be the first to reclaim the stripped earth patches and bulk sampling pits. Reestablishment with plants and seed banks collected from the land clearing activities must be utilised for revegetation purposes, utilising on-site nurseries if deemed necessary.

Planting will be most successful when it is done after the first rains and into freshly prepared fine-tilled seedbeds (provided the soil material is not prone to crusting). Water retention in the seed zone will stimulate germination and can be supported by the application of light vegetation mulches.

Control and management of alien vegetation will contribute to the conservation of the natural vegetation. The alien species should, therefore, be removed from site and control measures must be implemented to ensure spreading of these species does not occur to other parts of the project area or the surrounding lands.

10.2 Re-vegetation Methods

The common methods used to establish vegetation include seeding and hydroseeding. Flat areas should be seeded using tractor implements and slopes too steep for tractors should be hydroseeded. In the event where soils are stripped and returned directly (i.e. no stockpiling) and the areas stripped have good vegetation cover with suitable species present, natural re-colonisation may occur and there will be no need for re-seeding. In this case, it may be best to simply replace the stripped soils, lightly level and rip thoroughly, and leave for one growing season to assess the extent and suitability of the natural re-vegetation. Mulching with locally cut grass will also enhance the seed bank and ecological succession.

Established vegetation requires regular maintenance. If the growth medium consists of low-fertility soils (i.e. topsoil and subsoil mixed) and overburden material, then regular application of



plant food will be required until the natural fertility cycle has been restored. Annual fertiliser application should continue for two to three years.

Deterioration of the fertility regime of soils could be minimised if the surface soils have been stripped separately from the sub-soils and have been replaced at the surface during the replacement process, however, when surface soil has been mixed with sub-soil in the stripping and replacement process, the end product is a soil with low fertility. Surface soil fertility should be reinstated in order to establish and maintain good plant growth.

Immobile fertilisers such as lime (containing calcium and magnesium) and phosphorus should be incorporated deep into the plant rooting zone. This should be done by application prior to the deep ripping, which should be followed by deep ploughing, as this is the only way to get these nutrients deep into the soil. These nutrients may be replaced in a single application.

Potassium and nitrogen are mobile nutrients (as present in most fertilisers) and are subject to loss by leaching. Mobile nutrients will need to be provided for rehabilitation of new areas and because they are mobile repeat applications may be needed. Fertiliser applications are crop and site specific and depend on the soil analysis prior to planting or seeding, and this the fertiliser mixture will need to be determined during rehabilitation and may vary from site to site. It is recommended that soil analysis is conducted to determine the appropriate application of fertilisers. The success of re-establishment of vegetation on rehabilitated areas is not only a function of just adding fertiliser. Other factors play a role, such as appropriate management, climatic conditions and microbes present within the soil. Fertility can be reclaimed by adding inorganic fertilisers, however good soil fertility does not provide a warranty that vegetation will grow and the other factors involved need to be considered during rehabilitation. Normally when fertilisers are applied, good vegetation cover is achieved in the first few years as a result of the high fertility. However, as time passes there is the risk that cover starts to deteriorate because of mismanagement and lack of nutrients. The introduction of legumes into the seed mixture to fix Nitrogen allows for a higher Carbon/Nitrogen ratio, thus maintaining the existing soil fertility which helps build up the biological activity within the soil. However it must be noted that the management of legumes is crucial to their success.

10.3 Exploration Camp

The exploration camp will be dismantled in its entirety will all exposed areas to be similarly revegetated as per the above described process. Owing to its modular and temporary nature it is anticpated that surface rehabilitation activities will be fairly straightforward once all containers, tents and temporary structures are removed and the camp footprint ripped and seeded. Ablution and workshop area facilities will require close inspection for signs of contamination in the soil and surrounding areas. If suspected this soil must be removed and treated as hazardous waste and treated or disposed of accordingly. The same applies for any cement or concrete flooring (workshop areas) that have been exposed to extensive hydrocarbon spills. These must be demolished and disposed of.

10.4 Bulk Sample Pits

The pits are estimated to be 50 x 50m and 6-7m in depth after all excavation activity has stopped.



Pits will be backfilled and revegetation will occur naturally. However, these pits will pose a threat to community health and safety as well as their livestock if not appropriately backfilled and rehabilitated. Free access to these pits will have to be actively discouraged and managed by MML. It is not anticipated that these pits will become waterlogged during the wet season, owing to the fact that the vast majority of excavated material will be deposited into the pit. These pits also risk becoming targets for artisanal and illegal miners if not appropriately secured, and this is an additional reason to control ready access thereto after exploration activities have ended. This possibility will need to be considered and planned for by MML going forward in the following EMP revisions. All soil stockpiles will be utilised as far as possible in the reshaping and contouring of the bulk sample pits. All topsoil stockpiles must be utilised as the topmost revegetation layer on the final surface topography of these pits and pit slopes. The pits will need to be subject to the bulk of the post-rehabilitation monitoring effort as erosion and sow vegetation regrowth is likely to be more of an occurrence here.

10.5 Rehabilitation Monitoring

MML personnel should monitor the success of the rehabilitation efforts for a 3 year period after the commencement thereof of these activities. Observations around the success of the various approaches adopted, notable erosion evidence, or lack of significant regrowth must be investigated and understood - especially and the bulk sample pits - so as to determine whether to apply any additional rehabilitation effort if this is determined to be necessary. The potential for the occurrence of alien invasive fauna and flora species in rehabilitated areas must be monitored and where appropriate removed. Ultimately, this monitoring period will also serve to better inform any future rehabilitation activities MML may embark on for its current and proposed exploration and mining activities.



ANNEXURE A: GRIEVANCE MECHANISM Grievances will be received during community meetings and at the EHS department/office. The process of receiving formal grievances at the offices will be as follows: Step 1: Receipt of grievance: Grievances will be received by the Community Liaison Officer (CLO) either verbally or by written notification and will be entered in a register. Languages used will be English and Portuguese for documentation purposes but the grievance can be provided in the local language/dialect of the project area. The person submitting the grievance will be given a receipt of his submission once entered into the Grievance Register. People will also have the option of making their initial complaint through the Village Chiefs. A receipt will be provided to the person lodging the complaint. Step 2: Assessment: The CLO will assess the grievance in terms of his/her capacity to resolve it locally. If this is not possible, the grievance will be communicated to the EHS Manager and/or General Manager for further action depending on the severity and substance of the grievance. Step 3: Acknowledgement of complaint/grievance: Written information (accompanied with verbal explanation) as to steps that will be undertaken to resolve the grievance and the expected time for its resolution will be provided to the complainant within two weeks. This exchange will be recorded in the register. Step 4: Investigation and resolution of grievance: the company will conduct an internal investigation to determine the underlying cause of the grievance and make any changes required to prevent reoccurrence of a similar grievance. As appropriate, the CLO will also hold meetings with the person/group expressing the grievances to discuss, clarify and solve the issue, and prevent it from reoccurring. Step 5: Closure: Once the investigation has been completed and necessary measures been taken, the results will be communicated to the complainant and entered in the Grievance Register. Step 6: Outcome of the corrective action is verified with the complainant: Following completion of the corrective action, the CLO will verify the outcome with the complainant. The complainant will be asked to sign off on his/her acceptance of the `solution' (or nominate someone to do so on his/her behalf). In the event that the complainant remains dissatisfied with the outcome, additional corrective action may be agreed and carried out by the company. The Grievance Register will be entered in a dedicated database. Situations may arise where complainants will choose to pursue legal recourse and appeal the outcome of the Grievance Mechanism. In such cases, obtaining an independent opinion (e.g. traditional authorities, legal advisors, NGOs etc) on the grievance will be considered as this may aid in the arbitration process. The company will not impede access to this legal recourse. A summary of all grievances received must be included in the periodic internal reporting, as well as external sustainability reporting that the company may choose to release into the public domain at any point in the future.

MEGARUMA MINING LIMITADA RUBY MINE MONTEPUEZ, CABO …

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