offshore cape three points environmental and … · offshore cape three points environmental and...

Intended for

Vitol Upstream Ghana Limited and the International Finance Corporation

Date

5th May 2017

Project Number

UK14-24203

OFFSHORE CAPE THREE POINTS ENVIRONMENTAL AND SOCIAL MONITORING REPORT

OFFSHORE CAPE THREE POINTS ENVIRONMENTAL AND SOCIAL MONITORING REPORT

Ramboll Environ Box House Box Wiltshire SN13 8AA United Kingdom T +44 122 574 8420 www.ramboll-environ.com

Made by: C Halliwell, R Bisset Checked/Approved by: Chris Halliwell

This report has been prepared by Ramboll Environ with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between Ramboll Environ and the Client. This report is confidential to the Client, and Ramboll Environ accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by Ramboll Environ beforehand. Any such party relies upon the report at their own risk. Ramboll Environ disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services. Version Control Log

Revision Date Made by Checked by Approved by Description

Issue 0 15_3_17 C Halliwell and R Bisset C Halliwell Draft issued to client

Issue 1 20_04_17 C Halliwell and R Bisset C Halliwell Final report following clients’

comments on Issue 0

Issue 2 27_04_17 C Halliwell and R Bisset C Halliwell Revised Final report following

clients’ comments on Issue 1

Issue 3 05_05_17 C Halliwell and R Bisset C Halliwell Redacted version for disclosure

excluding personal details

Project No. UK14 24203 Issue No. 03 Date 5 May 2017 Made by C Halliwell, R Bisset

Checked by C Halliwell Approved by R Andrews

Environmental and Social Monitoring Report Offshore Cape Three Points

UK14_24203_Final Report

CONTENTS

GLOSSARY OF TERMS/ ACRONYMS EXECUTIVE SUMMARY I 1. INTRODUCTION 1 2. SCOPE AND STRUCTURE OF THE REPORT 2 2.1 Scope of the audit 2 2.2 Project Standards 4 2.3 Structure of the Report 4 2.4 Limitations 4 3. PROJECT DESCRIPTION 6 3.1 Socio-economic setting 6 3.2 Project description 7 3.3 Associated Facilities 7 3.4 Status of the Project at time of the audit 7 4. SIGNIFICANCE ASSESSMENT 8 4.1 Review Findings 8 4.2 Assessment of Significance 8 5. LEGISLATIVE FRAMEWORK AND OTHER PROJECT

STANDARDS 10 5.1 Summary of legislative framework 10 5.2 Permitting 10 5.3 Environmental Protection Agency 10 6. PERFORMANCE STANDARD 1: ASSESSMENT AND

MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 12

6.1 Requirements specified in the ESAP 12 6.2 Management Systems 12 6.3 HSE and Sustainability Responsibilities and Resources 12 6.4 Contractor management 14 6.5 Audit and inspection 15 6.6 Environmental and Social Impact Assessment 15 6.7 Cumulative Impacts 16 6.8 Stakeholder engagement 17 6.9 Grievance mechanism 18 6.10 Contingency planning 20 6.11 Management of change 20 6.12 VUGL E&S Assurance 21 7. PERFORMANCE STANDARD 2: LABOR AND WORKING

CONDITIONS 25 7.1 Introduction 25 7.2 VUGL Human Resource Policy 25 7.3 Management of labour and working conditions 25 7.4 Local labour-related issues 27 7.5 Human trafficking 27 7.6 Workers’ grievance mechanism 28 7.7 Occupational Health and Safety 28 7.8 Workers’ accommodation 29 8. PERFORMANCE STANDARD 3: RESOURCE EFFICIENCY

AND POLLUTION PREVENTION 32 8.1 Air quality 32 8.2 Noise 32 8.3 Surface and groundwater 32 8.4 Waste management 33



8.5 Soil management and reinstatement 34 8.6 Greenhouse gas emissions 34 8.7 Environmental Management and Monitoring 34 9. PERFORMANCE STANDARD 4: COMMUNITY HEALTH,

SAFETY, AND SECURITY 38 9.1 Community Health and Safety 38 9.2 Security 38 10. PERFORMANCE STANDARD 5: LAND ACQUISITION AND

INVOLUNTARY RESETTLEMENT 42 10.1 Introduction 42 10.2 Land - focused economic displacement 42 10.3 Fisheries – focused economic displacement 46 10.4 Unplanned in-migration (influx) 46 11. PERFORMANCE STANDARD 6: BIODIVERSITY

CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 50

11.1 Introduction 50 11.2 Invasive Species 50 11.3 Bush Meat 50 11.4 Flora Conservation Plan 50 11.5 Biodiversity Action Plans (BAP) 51 11.6 Biodiversity monitoring 51 11.7 Other requirements for the protection of biodiversity 51 12. PERFORMANCE STANDARD 8: CULTURAL HERITAGE 53 12.1 Introduction 53 12.2 Cultural heritage management planning 53 Appendix 1 Environmental and Social Action Plan with IESC comments Appendix 2 Project Documentation Made Available for Review Appendix 3 Audit Itinerary Appendix 4 List of Participants in the Audit [Redacted] Appendix 5 Photo Log



GLOSSARY OF TERMS/ ACRONYMS

Acronym Abbreviation AoDI Area of Direct Influence AMR Annual Monitoring Report BAP Biodiversity Action Plan CHMP Cultural Heritage Management Plan CLO Community Liaison Officer E&S Environmental and Social ESAP Environmental and Social Action Plan ESDD Environmental and Social Due Diligence EHS Environmental, Health and Safety EIS Environmental Impact Statement EPA Environmental Protection Agency EPIC Engineering Procurement Installation and Commissioning ERP Emergency Response Plan ESHIA Environmental, Social and Health Impact Assessment FLO Fisheries Liaison Officer FPSO Floating Production Storage and Offloading GIIP Good International Industry Practice GNPC Ghana National Petroleum Corporation HSE Health, Safety and Environment HSE and S Health, Safety, Environment and Sustainability IESC Independent Environmental and Social Consultant IFC International Finance Corporation ILO International Labour Organization IMS Integrated Management System IVMS In-Vehicle Monitoring System LR Livelihood Restoration LRP Livelihood Restoration Plan MIGA Multilateral Investment Guarantee Agency MoU Memorandum of Understanding NGO Non-Governmental Organisation NORM Naturally Occurring Radioactive Materials O&G Oil and Gas OBM Oil-Based Mud OCTP Offshore Cape Three Points OSRP Oil Spill Response Plan ORF Onshore Receiving Facility OHS Occupational Health and Safety PAP Project-Affected Person PS Performance Standard SEP Stakeholder Engagement Plan SIMOPS Simultaneous Operations SLC Sustainability & Local Content Vitol Vitol Exploration and Production Limited VUGL Vitol Upstream Ghana Limited WB World Bank WBG World Bank Group WMP Waste Management Plan


UK14_24203_ Final Report

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EXECUTIVE SUMMARY

In February 2017, Ramboll Environ, acting in the role of Independent Environmental and Social Consultant (IESC), monitored the environmental and social performance of the Offshore Cape Three Points (OCTP) project, Ghana (the ‘Project’). The Project is operated by Eni Ghana Exploration and Production Ltd (Eni Ghana). Vitol Upstream Ghana Limited (VUGL), an affiliate of Vitol Exploration and Production Limited (Vitol) and Ghana National Petroleum Corporation are JV non-operating partners.

The February trip was the first of several IESC monitoring visits scheduled to occur 6-monthly during the Project’s construction phase. A two-person team assessed the Project’s management of Environment and Social matters, with a particular emphasis on: the implementation of the Project Environmental and Social Action Plan; the adequacy of the Health, Safety, Environment and Sustainability Management System; and the implementation of a suite of environmental and social management plans intended to address applicable Project standards, notably the World Bank Group Performance Standards1.

At the time of the monitoring visit the IESC team was unable to visit the main onshore facilities because of risks posed by the socio-political context surrounding the current Chieftaincy dispute2. The team was therefore limited to a visit to the logistics base in Takoradi, desk-top review of documentation and interviews with Eni Ghana and Contractors’ Health, Safety and Environment, and Sustainability and Local Content staff (for social performance matters).

Throughout the monitoring process, VUGL and Eni Ghana cooperated fully and responded to all Ramboll Environ’s requests in relation to the audit effort. The audit covered a broad range of topics areas and Health, Safety and Environment and Social matters were found to be well managed for the most part. The project is generally compliant with the requirements of the Environmental and Social Action Plan, however, a total of 29 findings were identified during the monitoring visit. Of these 3 are considered High; 12 are Moderate and the remainder considered to be of Minor significance. The High findings relate to the timing/urgency of actions as follows:

The anticipated appointment of specialist environmental quality and biodiversity monitoring contractors several months after the start of construction works has resulted in missed opportunities for monitoring and a real data gap which in some cases is a risk for the Project. Consequently there is an urgent need to appoint monitoring contractors, refine the Environmental Monitoring Plan and start comprehensive monitoring set forth in the plan at the earliest opportunity;

There have been some delays in establishing the complete Livelihood Restoration Plan delivery team (management in Accra and implementing organizations in the concession area) and in implementing key components of the Livelihood Restoration Programme (due in part to the chieftaincy dispute). Eni Ghana must devote sufficient resources to contracting its on-site delivery partner as soon as possible and provide an enabling environment that will allow for the implementation of the Support Services component of the Livelihood Restoration Programme to begin speedily thereafter; and

Considerable work remains to be done to finalize/approve the Fisheries Management Plan so that its implementation can coincide with the construction schedule of the nearshore and onshore sections of the gas pipeline in May 2017. There is a risk that the Fisheries Management Plan will not be finalised and implemented in time. Eni Ghana must devote all

1 WBG Performance Standards refer to IFC (January 2012), WB (July 2012) and MIGA (October 2013) Performance Standards 2 The Paramount Chief of the area, within which the onshore component of the Project is located, communicated with Eni Ghana and recommended that the IESC team should not visit the main onshore facilities because the funeral of the former chief was planned to occur at the same time as the IESC visit.



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necessary technical and financial resources, to ensure that the Fisheries Management Plan is finalized/approved prior to commencement of the onshore pipeline works.

The findings presented in this report should be incorporated within Eni Ghana’s audit findings and closure procedure, with evidence of corrective actions provided via the lenders’ quarterly reporting process. Ramboll Environ will undertake desk-top review of quarterly reports and also undertake a further monitoring visit in approximately six months (from the date of the initial audit) during which the issues identified in this report will be revisited and the closure of issues identified confirmed.



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1. INTRODUCTION

Ramboll Environ UK Limited (Ramboll Environ) was commissioned in January 2017 by Vitol Upstream Ghana Limited (VUGL) to undertake environmental and social monitoring of the proposed Offshore Cape Three Points (OCTP) project (the ‘Project’), Republic of Ghana. The Project is operated by Eni Ghana Exploration and Production Ltd (Eni Ghana). VUGL, an affiliate of Vitol Exploration and Production Limited (Vitol) and Ghana National Petroleum Corporation are JV non-operating partners.

In fulfilling the role of Lenders’ Independent Environmental and Social Consultant (IESC), Ramboll Environ had a duty of care to a consortium of lenders (the ‘Lenders’) to the Project, including the International Finance Corporation3 (IFC), World Bank4 (International Development Association) and the Multilateral Investment Guarantee Agency5 (MIGA) which is also a member of the World Bank Group (WBG).

This report provides our findings following a monitoring visit (also referred to interchangeably as an audit) of the Project that has included an assessment against applicable Project Standards, specifically, WBG Performance Standards and applicable WBG Environmental, Health and Safety (EHS) guidelines, thereby identifying any environmental and social risks associated with the Project’s realisation.

The ‘Project Operator’ is Eni Ghana. Face-to-face interviews were held primarily with Eni Ghana:

Senior Management;

Health, Safety and Environment (HSE) Team;

Sustainability & Local Content (SLC) Team;

Procurement Manager; and

Human Resources and Security functions.

The Vitol Environmental and Social Assurance Manager was also present during interviews and available to answer any questions raised by Ramboll Environ.

Interviews were also conducted with the contractor responsible for early works at the Onshore Receiving Facility (ORF) site. Ramboll Environ also had the opportunity to meet with representatives of the Ghana Environmental Protection Agency in which the Project was discussed, and a number of NGOs (four) which have links to the Project.

3 Lender to Vitol Ghana debt financing package 4 Guarantor to support the gas development 5 Insurer for the lenders to Vitol Ghana, including Equator Principles Banks and Export Credit Agencies.



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2. SCOPE AND STRUCTURE OF THE REPORT

2.1 Scope of the audit

As a condition of the Project Environmental and Social Action Plan (ESAP) (Appendix 1), Eni Ghana and VUGL are required to appoint an IESC to monitor (audit) and report on the implementation of the ESAP and compliance with WBG Performance Standards and Project Environmental and Social (E&S) commitments. For the purposes of this report we refer to monitoring and auditing interchangeably.

This Environmental and Social Monitoring Report details the Project’s compliance with the applicable Project Standards listed in Section 2.2, and in doing so, presents the environmental and social risks associated with the Project. It has been prepared for the attention of VUGL, the IFC and other entities defined as relying parties6. It addresses the various components of the Project (as defined in Section 3, Project Description).

The report presents the findings of the audit based on information gained following:

A review of ESAP implementation;

A review of Health, Safety, Environment and Sustainability (HSE and S) Management System documentation;

Interviews held with key HSE and SLC staff within Eni Ghana and VUGL;

Interviews with other Eni functions including Procurement, Security, Human Resources and facility managers (logistics base);

Interviews held with onshore Contractor’s HSE representatives; and

Visual observations made during walkover inspection of Project facilities.

A full list of Project documentation reviewed during preparation of this Environmental and Social Monitoring Report is provided in Appendix 2 (each item has a Reference number and, in the text of this report, specific named documents are provided with their Reference numbers).

The site visit was undertaken on 20-24 February 2017. The tasks performed during this period are summarised below and detailed in the audit itinerary (Appendix 3):

A one day visit to the logistics base in Takoradi took place on day 2 of the monitoring visit;

The meetings/ interviews held with key personnel and organisations during the site visit are summarised below:

- Meeting with Eni Ghana senior management team;

- Meetings with the HSE team;

- Meeting with the SLC team;

- Interview with the Technical Support and Interface Manager/Deputy Development Project Manager;

- Interview with the Personnel Manager;

- Interview with Procurement Manager;

- Interview with the Eni Ghana Security Manager;

6 Relying parties include World Bank, MIGA, Eni Ghana and other lenders.



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- Meeting with HSE/security representatives from De Simone Limited, Eni Ghana Local Content and Community Liaison Coordinator and a NGO representative7;

- Meeting with representatives of three NGOs that are bidders for the contract to implement the Livelihood Restoration Programme component (mainly the ‘Support Services’) of the Livelihood Restoration Plan (LRP);

- Meeting with Ghana EPA; and

- Meetings with IFC, WB and MIGA representatives;

Meetings and interviews primarily concerned the management and monitoring of the following Project HSE and S aspects:

- Emergency response plan;

- Waste management;

- Biodiversity;

- Audit and inspection programme;

- Management of change;

- Livelihood restoration planning and fisheries management;

- Environmental monitoring;

- Cumulative impacts;

- Influx management;

- Stakeholder engagement/grievance mechanism;

- Occupational Health and Safety (OHS) plans and procedures;

- Cultural heritage; and

- Security management

ESAP discussions.

It should be noted that a visit to the main construction activities underway for the ORF at Sanzule could not be conducted due to community tensions at the time of the visit (see Section 3.1 for further details).

The main organisations involved in the audit are listed below and in Appendix 4:

VUGL;

Eni Ghana (the Operator and a client to the WB which is providing a partial risk guarantee);

De Simone Limited (Early Works Contractor);

Ghana Environmental Protection Agency;

IFC (present as an observer);

MIGA (present as an observer);

World Bank (present as an observer); and

NGOs (linked to the Project).

7 This representative is also a member of the Livelihood Restoration Plan Steering Committee



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2.2 Project Standards

In accordance with Ramboll Environ’s Terms of Reference, the Project was assessed against the following standards and guidelines:

Applicable laws and regulations of Ghana;

WBG Performance Standards (2012) including:

PS1: Assessment & Management of Environmental & Social Risks & Impacts;

PS2: Labour and Working Conditions;

PS3: Resource Efficiency and Pollution Prevention;

PS4: Community Health, Safety, and Security;

PS5: Land Acquisition and Involuntary Resettlement; and

PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources;

WBG Environmental Health & Safety (EHS) Guidelines applicable to the Project including:

- EHS Guidelines for Offshore Oil and Gas Development (2015);and

- EHS Guidelines for Onshore Oil and Gas Development (2007).

PS7 (Indigenous Peoples) was excluded from the scope of the audit on the basis that the Environmental and Social Due Diligence8 performed prior to financial close concluded no Indigenous Peoples are affected by the Project.

PS8 (Cultural Heritage) was excluded from the Ramboll Environ’s scope, however some text is included in so far as it relates to specific issues such as shrines and chance finds (Section 12). Ramboll Environ also notes that Eni Ghana has developed a Cultural Heritage Management Plan [Ref 12].

2.3 Structure of the Report

Section 3 below provides a description of the Project facilities, activities and timelines. Section 4 describes how different levels of significance are attributed to issues highlighted in the report, and Section 5 outlines the Ghanaian legislative framework and other applicable Project Standards. The report is then structured around the seven IFC Performance Standards applicable to the Project (includes cultural heritage as there is a discussion of this issue) as listed above. The key issues identified during the audit are summarised in ‘significance tables’ for each Performance Standard.

Within the report we have endeavoured to provide a balanced opinion, providing examples of good practice. However, due to the nature of a compliance report, and the broad range of aspects covered, it does focus on the non-compliances.

2.4 Limitations

At the time of the visit, drilling activities were complete and the Floating Production Storage and Offloading (FPSO) vessel had not left Singapore. In accordance with advice from the WBG, Eni Ghana and VUGL, and in the absence of the FPSO, the Ramboll Environ team did not go offshore.

The IESC was unable to visit the ORF because of unrest in neighbour communities triggered by a chieftaincy dispute (see Section 3.1, Socio-economic setting). Consequently, the monitoring visit prioritised familiarisation with the Project and desk based audit of management plan

8 An environmental and social due diligence (ESDD) exercise was performed by KBC Process Technology Ltd on behalf of potential

lenders [Ref 37 - Environmental and Social Review OCTP Project, Ghana September 2016]. The ESDD Report identified a number of issues and made recommendations that were transposed into an Environmental and Social Action Plan (ESAP). The ESAP provided in the ESDD report formed the basis of the final agreed ESAP included in Appendix 1 of this report.



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implementation. A one-day visit to the logistics base in Takoradi took place on the second day of the monitoring visit.

The IESC only considered activities relevant at the time of audit based on ongoing Project activities. Future activities will be the subject of forthcoming monitoring visits.



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3. PROJECT DESCRIPTION

This section is intended to provide a brief description of the Project activities and current status. It provides the socio-economic setting, activities to date and a high-level summary of the Project based on the description in the Project’s Final ESHIA Report and associated documentation, with emphasis on those elements of the Project that could give rise to environmental, social and health impacts.

3.1 Socio-economic setting

On 1 July 2011, the World Bank reclassified Ghana from a low-income to a lower middle income status country, in response to the discovery and production of oil. In recent years Ghana has been one of the fastest growing economies in Sub-Saharan Africa with GDP growth of 8.8% and 7.1% in 2012 and 2013. The Western Region, where the Project will be located, is the highest ‘regional’ contributor to the country’s GDP (55%) based on only 10% of the country’s land area, but containing a wide variety of mineral deposits and generating significant agricultural production. The discovery of hydrocarbon reserves off the coast of the Western Region has played a key role in the growth of the Western Region and, hence, the national economy. Unsurprisingly, there is a significant amount of internal migration to, and within the Western Region, with people migrating to areas with employment opportunities such as Ahanta West and Takoradi.

In 2012 -2013, investment in mining, and oil and gas, was high and it is expected that investments in the oil and gas sector and related industries will increase. At present the main centres of investment and hence development are further to the east, of the proposed port site, toward Takoradi. However, the coastal area around Sanzule is experiencing development pressures. There is an existing pipeline landfall and the GNGC gas processing plant (which is now operational) near Atuabo town and the proposed construction of a port to service the oil and gas sector also next to Atuabo. In addition, there are signs of increased provision of tourist accommodation facilities near the proposed OCTP onshore facilities’ site and there is a programme of local road upgrading. Finally, Ellembelle District Council is considering the allocation of land for an industrial ‘park’ to the north-west of the port. The existing gas processing plant, the proposed Atuabo port coupled with the impending construction and then operation of the OCTP Project will act to focus development in Ellembelle District, particularly the coastal strip, helping to create an industrial node.

Consultations with traditional authorities and local government entities were undertaken by Eni Ghana and cumulative impacts resulting from other oil and gas and industrial projects in the area arose as a concern, particularly: adverse impacts arising from uncoordinated project siting and operations (with attendant need for local government planning authorities to be kept aware of such key issues as land requirements and infrastructure needs); pressures on physical and social infrastructure; influx of people and attendant negative social impacts; land take and compensation procedures and the need for consultations with both traditional authorities and local community members to be undertaken consistently and systematically.

At present, undertaking consultations with Sanzule-based stakeholders (Sanzule being the largest and nearest community to the OCTP onshore facilities and ‘owner’ of the land used for the ORF), especially the traditional political authority, is a complex activity due to a chieftaincy dispute. Eni Ghana is being very sensitive in its consultations with the traditional authority given the uncertainty created by this dispute.



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3.2 Project description

The Project involves the development of the Sankofa East oil field and non-associated gas in the Sankofa and Gye Nyame Gas Fields, which are located 55 to 60 km offshore in the Western Region of the Republic of Ghana. It is proposed to be developed as an integrated oil and gas development Project utilising newly converted double-hulled Floating Production, Storage and Offloading (FPSO) unit. Other components of the Project include:

Fourteen wells for oil exploitation; oil will be transferred to shuttle tankers before export.

Five wells for non-associated gas exploitation;

A 63 km subsea gas pipeline from the FPSO to shore;

A 1.5 km onshore gas pipeline from the shore to an ORF;

An ORF including a gas compressor station, accommodation camp, firefighting station, helipad and medical facility; and a tie-in to the existing Ghana National Gas Company (GNGC) 20-inch gas pipeline; and

Logistics bases in Takoradi and a quay within the port of Takoradi.

The Project is split into two phases:

Phase 1: Oil Development Project. This phase will consist of the 14 subsea wells (8 oil producers, 3 water injectors and 3 associated gas injectors), subsea facilities, and a FPSO unit that would be located approximately 60 km offshore south of Sanzule; and

Phase 2: Gas Development Project. This phase will consist of 5 subsea wells, subsea facilities, gas treating facilities on the FPSO unit, a 63 km subsea gas pipeline, an ORF, and tie-in with the GNGC sales gas pipeline.

3.3 Associated Facilities

The ESDD Report (Appendix 2 – E&S review, 2016) concludes there a no Associated Facilities, as defined by WBG PS1. Associated Facilities are not considered further in this report.

3.4 Status of the Project at time of the audit

Eighteen wells have been drilled and the drill ship is remaining on site for well completions. Early works (site preparation) at the ORF are being finalised with the early works contractor (De Simone Limited) soon to hand over to Technip (the Engineering Procurement Installation and Commissioning (EPIC) Contractor). The FPSO is due to sail from Singapore in the coming weeks arriving on site in April 2017, with first oil then expected to commence in August 2017 and first gas in June 2018.

At the time of the site visit, overall progress was 68.3% compared with the overall planned project schedule which was 66.6% i.e. slightly ahead of schedule. At the end of February, 2017, the total number employees at the Sanzule site was 437 (direct and indirect). This represents almost 55% of the expected peak labour force of 800.



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4. SIGNIFICANCE ASSESSMENT

4.1 Review Findings

A summary of the review findings is presented in a significance table at the end of each section. For each item, we present:

The topic/aspect;

A description of the issue, for example deficiencies or omissions;

The phase(s) to which an issue relates;

Identification of the standard(s) against which the deficiency has been identified;

Ramboll Environ’s recommendation, where applicable, to resolve/manage the deficiency; and

The significance on a three-point scale (see below for criteria).

4.2 Assessment of Significance

A ranking system has been used to indicate the relative significance of an issue identified during the monitoring visit. As well as highlighting the most important areas requiring attention, it can also be used to aid the tracking and rectification of specific items requiring improvement.

Identified issues have been placed into one of the following three categories:

Minor: Minor non-compliance, risk or minor technical breach of Applicable Standards and commitments with no material, actual or likely potential: environmental or social consequences; or significant human injury or harm.

Moderate: Moderate non-compliance or risk with actual or likely potential: localised and short-term environmental or social consequences; minor human injury or harm; or material short-term breach of Applicable Standards and commitments.

High: Major non-compliance or risk with actual or likely potential: spatially extensive and/or long-term environmental or social consequences; serious human injury/death or harm; or material and extensive breach of Applicable Standards and commitments.

Not Item is noteworthy, but it is not an issue of non-compliance. Applicable

Where time critical recommendations for specific actions are made a timeframe linked to Construction/Operational phase milestones is indicated in the IESC recommendation column. Time critical issues can lead to a higher classification of significance.

Table 1: Example of the summary table format

ID Aspect Issue Description

Phase9 Standard IESC Recommendations

Significance

00 Storm water run- off – monitoring

The ESAP requires Company X monitors the quality of surface water run-off from facilities.

Ops WBG EHS Guidelines ESAP

Company X shall Expedite procurement of monitoring equipment with the support of senior management.

Moderate

9 Phases can include: construction; operations; decommissioning or; any combination of these phases.



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ID Aspect Issue Description

Phase9 Standard IESC Recommendations

Significance

To date the Company has been unable to procure monitoring equipment – no monitoring has been undertaken.



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5. LEGISLATIVE FRAMEWORK AND OTHER PROJECT STANDARDS

5.1 Summary of legislative framework

The undertaking of projects such as oil and gas developments requires registration and authorisation by the Ghana Environmental Protection Agency (EPA). The Ghana EPA was established under the Environmental Protection Agency Act (Act No. 490 of 1994) as the leading public body responsible for the protection and improvement of the environment in Ghana. The EPA has the authority to require an EIA, is responsible for issuing and enforcing requirements specified in environmental permits.

5.2 Permitting

At the time of the monitoring visit, Eni Ghana had all relevant permits in place for ongoing activities. A further three key environmental permits will need to be in place prior to first oil and first gas and it is understood work to secure these permits is underway.

5.3 Environmental Protection Agency

The IESC met with representatives of the EPA, including the Acting Deputy Director and his team. The IESC discussed permitting requirements and the EPA’s relationship with Eni Ghana.

EPA indicated a two phase approach to its environmental permitting procedure 1) installation (construction phase) and 2) operations phase permits. Permits are typically issued a day or so prior to start of activities. In this way, the commencement date of activities can be controlled, although it does potentially run the risk of halting Project activities in the event of unexpected permitting delays. The EPA indicated that there is a lot of communication between the Project and the EPA, and as such, Eni Ghana is made aware of any problems with a permit well in advance of its issue date.

EPA further confirmed frequent interaction with the Project HSE and SLC teams and indicated the frequency of interaction had increased following changes in the HSE team in 2016.

5.3.1 Inspection and Reporting

The EPA requires Eni Ghana to send a technical report for each well drilled and report annually for each calendar year, submitting the annual report by the 31st March. To date (February 2017) the EPA has received the 2015 annual report. All well reports (Terminal Reports) have been submitted to the EPA.

The EPA undertakes periodic inspections, including offshore rig inspections, with the support of the Norwegian Oil for Development Programme.

5.3.2 EPA concerns

The EPA expressed concerned over encroachment of fishermen in the offshore exclusion zones. The EPA is a currently working to set up a standing committee, including the Petroleum Commission, the Navy and the Fisheries Commission, to address the issue.

5.3.3 Fish catches

The EPA is aware of claims from communities that the offshore oil and gas activity is reducing marine fish catches. In response to the claims the EPA commissioned a fish catch study to see if there is a linkage between fish catches and the activities of the various oil and gas operators. The study does not provide evidence of any linkages to the oil and gas activities and confirms there have been long terms fluctuations in catch levels with low catches also being noticed away



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from the O&G fields. Nevertheless the EPA is working, alongside other regulators, to achieve sustainable fishing techniques. Of note, the Fisheries Commission has banned the use of certain large trawlers in the region.



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6. PERFORMANCE STANDARD 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS

6.1 Requirements specified in the ESAP

Line 1 of the ESAP requires ‘Eni Ghana with support from Vitol will develop a construction/ development phase Environmental, Social, Health Management Plan (ESHMP) and the relevant management plans and programs in advance of development drilling and construction, ……. The ESHMP will be updated as required, such as in the event of any significant changes to the project and its environmental and social risks and impacts occur, following a Management of Change process. The ESHMP will include social management plans and procedures to meet the objectives of the Performance Standards, and those plans and procedures will be incorporated into an integrated Environmental and Social (E&S) Management System for the OCTP project.’

A number of timeframes that are linked to the Project’s status are specified including ‘c) Development drilling and construction phase: all management plans (others than the plans specified in the action items below [in the ESAP]) approved by end of December 2016.’

During the site visit a list of plans, applicable as relevant to ESAP Line 1, where identified to be completed (submitted to WBG) by the end of December 2016. One management plan (actually named a ‘strategy’), identified in the ESAP under separate line items, was submitted after the deadline:

The Fisheries Management and Participatory Monitoring Programme Framework Strategy (dated 30 January 2017). The timeframe in the ESAP is specified in Line 11 of the ESAP as 31st December 2016.

The potential implications of the late submission of this strategy are discussed in further detail in Section 10.3, Fisheries–focused economic displacement.

6.2 Management Systems

Eni Ghana operates an Integrated Management System (IMS) that includes HSE and S components. The IMS is a mature system, albeit continuously evolving, based on Eni Ghana corporate standards for IMS. Eni Ghana has ISO1400110 (environmental) and OHSAS1800111 (health and safety) certification. Also, Eni Ghana commissioned an assessment of the IMS against ISO 26000 (social responsibility).

The IESC notes the integration, within the IMS, of management plans, identified within the Final ESHIA Report, for OCTP Phase 2, as necessary for the management of environmental, social and health impacts. A list of HSE-IMS documents as of February 2017 includes; 2 HSE guidelines; 2 protocols; an HSE manual; 25 plans; 4 standards; 32 procedures, 15 operating instructions, 4 programs and three registers.

It is the IESC’s opinion that there is a strong HSE and S culture and firm commitment to good HSE and S management within Eni Ghana and that this culture is impressed upon Project contractors. Further commentary on contractor management is provided in Section 6.4.

6.3 HSE and Sustainability Responsibilities and Resources

Eni Ghana has established the HSE and the SLC teams shown in Figures 1 and 2 respectively. The teams have strong leadership, team members demonstrate a good level of competency and staffing levels appear to be appropriate, noting some less critical positions have yet to be filled.

10 Certificate no. EMS-3201/S, renewed 15th December 2016 11 Certificate no. OHS-535, renewed 15th December 2016



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In addition, it should be noted that neither organogram shows the post of ‘Compliance Officer’. The person appointed will be responsible for cross-cutting co-ordination between HSE and SLC functions and is expected to be appointed by the end of Q2, 2017.

Figure 1 Safety, Environment and Quality organogram

The HSE and SLC teams receive good support from senior management. When questioned, both the Safety, Environment and Quality Manager and SLC Manager indicated they were satisfied with the level of resourcing made available i.e. they were not constrained by resourcing levels.

Social issues are managed by the Sustainability & Local Content and department under the leadership the SLC Manager. All staff are nationals except for one expatriate acting as Livelihood Restoration Advisor. There are two important posts which are not yet filled- Project Delivery Coordinator and Stakeholder Engagement Officer. It is expected that these two posts will be filled by the end of Q2, 2017. Two other posts are filled by young Ghanaians who are undertaking ‘national service’. The department is supported by the Eni HQ Sustainability function. It is noteworthy that all staff whose day-to-day tasks are ‘community-facing’ are based in Sanzule. Senior staff with managerial responsibilities are based in Accra. It is noted that the post of Labour Relations Officer (considered necessary to meet local content and hiring needs) is not included (see Section 6.7); perhaps because this post will be allocated to a different department.

At the senior level there is an Advisor with ‘livelihood’ responsibilities (the incumbent is an Eni HQ staff member). The Advisor is supported by two permanent Eni Ghana staff members with ‘livelihood’ responsibilities with a senior-level appointment (Project Delivery Coordinator) still to be made. Once this Coordinator is in post the staff complement, with a full-time focus on livelihoods, will consist of a team of four employees. Currently, this complement appears adequate to manage the successful delivery of the LRP ‘Support Services’ component which is about to begin and to be followed, at some point, by the cessation of the Transitional Support Food Aid. However, the permanency of the Advisor is an uncertain factor that poses a risk to the successful delivery and completion of the LRP.



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Figure 2: Sustainability & Local Content Department Organogram

6.4 Contractor management

Consistent with Lenders requirements, Eni Ghana requires that its contractors and their sub-contractors apply Eni Ghana’s HSE and SLC standards to their own activities whilst working on the Project. A number of mechanisms are used to ensure good E&S performance including contractual agreements and periodic inspection/audit of contractors’ performance.

Based on the IESC’s interview with the Procurement Manager, it is understood that all contracts include a set of minimum requirements, which include among others, minimum requirements for the management of E&S, H&S and SLC matters. The IESC has reviewed the contract for early works which included the following:

Appendix E, HSE-R Requirements, including requirements pertaining to management of sub-contractors, audit and inspections, HSE reporting, emergency planning, environmental management, transportation, camp management etc. The Appendix is comprehensive, although it pre-dates many of the environmental management plans which are consequently excluded. The IESC was informed that more recent contracts will include specific environmental and social management plans;

Appendix F, Quality Requirements, including the need for inspections and audits.

Appendix Q, Security Requirements, with reference to applicable law, human rights, international good practice and requirements for trained unarmed guards, although there is no specific reference of requirement to align with the voluntary principles (see Section 9.2, Security);

Appendix W, Local Content Development Plan (provided by the bidding entity); and

Appendix Z, Eni guidelines for the Protection and Promotion of Human Rights, with reference to applicable ILO conventions.

Recently, Eni Ghana has introduced Appendix Y - Sustainability & Local Content Requirements for Contractors –which "provides minimum requirements for ITT stage and standard requirements



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for Sustainability & Local Content that Contractors shall comply with and implement during execution of works. These are the components that the Contractors shall take into account for the preparation of a Sustainability & Local Content Management Program, which sets out mechanism for Stakeholders economic and employment opportunities, engagement, communication, grievance handling and agreements / compensations, and any potential social development initiatives for execution & related to contract implementation as operations specifically require."

The SLC Manager confirmed that this Appendix will be incorporated into all contracts going forward including the contract for the EPIC contractor: Technip.

The Procurement Manager confirmed, during the interview, that the HSE and SLC teams are involved in the tender evaluation process12 and that requirements placed on contractors must flow down to sub-contractors. Examples were given where plans have been rejected, and in the case of a security provider, disqualification from the tender process.

Overall the procurement process is robust and has been used to ensure good HSE and social performance of contractors. It is understood that more recent and future contracts will include further requirements driven by the lenders via inclusion of E&S management plans developed during the course of 2016/2017 (management plans were physically handed to Technip). The contract appendices should also include specific lender standards and guidance, and stipulate alignment with the Voluntary Principles on Security and Human Rights and the Workers’ Accommodation: Processes and Standards guidance note co-authored by the IFC (see also Section 7.7, Workers’ Accommodation).

6.5 Audit and inspection

The IESC was provided with the annual audit programmes for 2016 and 2017. The 2016 programme includes a mixture of HSE audits (waste, safety, transport etc.) of the Project’s main onshore and offshore contractors. Eni Ghana has provided the IESC with a sample of audit reports inclusive of audit plans, audit reports and corrective action/close out plans.

The Company’s audit programme is considered robust and the findings presented in those audit reports reviewed suggest auditors are experienced and stringent in their approach (senior managers are required to participate in audits to add weight to the process).

Eight audits are scheduled for 2017, including external audits of the Company (including Lenders’ monitoring visit), internal audits of contractors and internal audits of Eni Ghana.

6.6 Environmental and Social Impact Assessment

Two documents, each reporting the results of an environmental, social and health impacts Assessment (ESHIA), have been prepared; one for each of the two phases of the Project (referred to hereinafter as ESHIA Reports). A phase 1 ESHIA Report, for the development of the Sankofa East Oil Field (Phase-1), was issued for submission to authorities and dated January 2015, followed by the ESHIA Report for the development of the Sankofa Gas Field (Phase-2), dated July 2015. The ESHIA Reports have been prepared to satisfy the requirements of national and international legislation and Good International Industry Practice (GIIP), including the Lenders’ standards as described in Chapter 4.

Commitments made in the ESHIA Reports have been incorporated into a suite of Project E&S management plans and subsequently captured and elaborated within E&S Commitment Registers. The IESC has not undertaken a detailed review of the register to confirm all commitments made in the ESHIA documentation have been captured in the Commitment Registers.

12 The tender evaluation process verifies the statement made by the Procurement Manager



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6.7 Cumulative impacts

ESAP line 5 states ‘Eni Ghana will report on their best efforts to engage other developers, local institutions and government, and other stakeholders in designing coherent management strategies to mitigate cumulative impacts.’

b) Evidences of implementation provided to WBG as part of the Annual Monitoring Report (31/12/16)

The Project Annual Monitoring Report provided to Ramboll Environ ahead of the site visit [Ref 16] did not include any reference or evidence of implementation/efforts to engage with other parties in designing management strategies. The IESC also notes that there is limited progress in the implementation of mitigation measures detailed in the Cumulative Impact Mitigation Strategy [Ref 13], notably:

Engagement with the EPA with regards to the possibility for a new Strategic Environmental and Social Assessment (by November 2016);

Development of a coordinated action plan; designation of timings, responsible parties and costs; and

Implementation of the action plan.

Discussions during the course of the monitoring visit revealed that Eni Ghana has made some efforts to manage cumulative impacts, and that the non-compliance relates to the failure to clearly report efforts rather than a failure to make the efforts.

Since the initial finding was made, Ramboll Environ has been made aware that:

Eni Ghana participated in a meeting arranged by EPA in July 2016 in which Eni Ghana raised the aspect of sharing ‘Emergency Response and Oil Spill Response Management’ leading to joint training with Tullow Oil involving community individuals in ‘Oil Spill Response Emergency Management’;

A second meeting was planned on 24th November 2016 in which Eni Ghana planned to raise ‘Cumulative impact mitigation’ in a coherent and shared way, however this meeting was cancelled because of the general election; and

A meeting was arranged by the Petroleum Commission in December 2016, in which all Chiefs of Western Region were invited, and Eni Ghana raised the need to have a coherent management of cumulative impacts given the presence of other project proponents in the area.

Ramboll Environ has also been made aware that Eni Ghana is finding it difficult, as a single commercial operator, to coordinate efforts to manage cumulative impacts. Furthermore, Eni Ghana believes that, to a large extent, this is not the role of a single operator. Consequently, Eni Ghana and VUGL have requested, in their respective Annual Monitoring Reports, that WBG takes a leading role in establishing a multi-stakeholder group for the management of cumulative impacts.

The issue of cumulative impacts was also discussed with the EPA during an IESC/WBG only meeting at the EPA offices. During this meeting the EPA referred to an onshore Strategic Environmental Assessment (SEA) for the Voltaian Basin, including the Western Region, which is currently underway. The EPA accepts it has a significant role to play in respect to the coordination and management of cumulative impacts. Given the information provided, the IESC accepts some efforts have been made by Eni Ghana to progress the management of cumulative impacts.

The IESC has also since been made aware that there are two Annual Monitoring Reports (AMR) to be submitted. One AMR (the Operator’s AMR) is to be submitted by Eni Ghana to WBG. A second



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AMR (the non-Operator AMR), with the Operator’s AMR appended, is to be submitted by VUGL to lenders, including IFC, and MIGA (and copied to WB). Whereas the Operator’s AMR has been submitted to the WB, the submission timeframe for the non-Operator’s AMR is not until the end March 2017 (90 days from the end of the reporting year), allowing the recent efforts made with respect to cumulative impacts to be included in the VUGL (non-Operator) AMR13. The Cumulative Impact Mitigation Strategy will require revision given the actions listed have either been superseded or have lapsed.

See also Section 10.4 where cumulative impacts associated with influx is addressed.

6.8 Stakeholder engagement

During work to prepare the final ESHIA Report (July, 2015), for the Phase 2 Project, extensive stakeholder engagement activities were undertaken as per the ‘ESHIA’ Stakeholder Engagement Plan (SEP) (attached as Annex A to the ESHIA Report). This SEP was prepared by ERM, SRC Consulting and ESL Consulting – the ESHIA Report authors. Subsequently, Eni Ghana issued a SEP (dated 04 October 2016) which builds on the earlier ’ESHIA’ SEP and focuses on the early works and construction phase of the Project. This SEP is comprehensive in its coverage and includes:

SEP objectives;

Identification of community and non-community stakeholders (including vulnerable groups);

Description of overall engagement approach (with emphasis on engagement activities relating specifically to communities and impacts);

Description of specific engagement actions (disclosure and consultations relating to the early works and site works phases);

Roles and responsibilities (including management of contractors); and

Monitoring of SEP implementation/performance.

The SLC department has devoted/is devoting considerable resources to stakeholder engagement. There are five Community Liaison Officers (CLOs) and five Fisheries Liaison Officers (FLOs) all based locally. At present, the CLOs operate from an office at the Onshore Receiving Facility (ORF) site, but it is intended that a community liaison office will open in each of the five communities (Eikwe, Bakanta, Sanzule, Krisan and the migrant fishing settlement of Anwolakrom which ‘belongs’ to Sanzule) considered to be in the Area of Direct Influence (AoDI). Sanzule (including Anwolakrom), due to its relative importance, will be served by two CLOs. There is one female CLO and two female FLOs so there is potential for local women to discuss gender-related or gender-sensitive issues with a female CLO and/or FLO.

Apart from the strategic issue relating to the chieftaincy, presented above in section 3.1, stakeholder engagement faces significant challenges in the near future:

The entry of Technip and the exit of De Simone Ltd as the main onshore contractor. Due to the scale and significance of their presence/activities, these contractors respectively have been/will be the main, local ‘face’ of the Project and, therefore, Eni Ghana. Thus, the legacy of De Simone and the early impressions made by Technip will be important for setting the tone of future stakeholder engagement;

Respecting the ‘boundaries’ between the Project and the traditional political authorities (primarily the community-level chiefs). If the traditional authorities perceive that their roles

13 Eni Ghana also highlighted that the AMR template did not allow for the inclusion of text relating to efforts made in relation to the management of cumulative impacts. WBG acknowledged the AMR template did not allow for the narrative on cumulative impacts and agreed to amend the template accordingly.



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and responsibilities are being undermined, or that they are being by-passed, then they could use their authority and influence to hinder the Project;

The ‘handover‘ between De Simone and Technip, especially in terms of the transfer of workers from one contractor to another, needs to be managed sensitively so that any differences in terms and conditions of employment (e. g. date of salary payment) can be carefully explained to the workers and the wider community (see section 7.4); and

Demonstrating that the local recruitment procedure has been improved so that local people consider that they are benefiting from the successful achievement of local content targets, for local labour recruitment, which have been set by Eni Ghana for each community.

The SEP is supported by a Stakeholder Management Plan which consists of a spreadsheet which consolidates the many SEP commitments into a single structured framework for disclosure and consultation activities. This will be a key document to assist Eni Ghana in implementing, effectively, its intention to move away from the current mix of planned and ad hoc stakeholder engagement activities/events toward a more planned and structured set of activities/events to reflect the Project’s progress from construction to operations (production) phase.

The SLC Department’s organogram (Figure 2) shows that there is an institutional ‘split’ between community-level liaison/relations and wider stakeholder engagement. This is understandable given the locality of the Project. It will be important, however, to ensure effective co-ordination at senior manager level, in the department, to ensure that the two dimensions of local community-level liaison/relations and wider stakeholder engagement activities are integrated successfully. It is noted that the Stakeholder Engagement Officer is not yet in post.

6.9 Grievance mechanism

The ‘ESHIA’ SEP contains a Grievance Mechanism, to be developed, disseminated and implemented, at the time of writing of the ‘ESHIA’ SEP. The subsequent (current) SEP refers, in section 8 (entitled Grievance Procedure and Mechanism), to a Grievance Procedure, but does not include it. It is stated that the Grievance Procedure has been operational since, “… the inception of site works,” and that the Grievance Management Committee was established, formally, on 19 April, 2016. The Grievance Procedure was disseminated to all affected local communities in March 2016; before De Simone’s mobilization and the beginning of construction phase early works.

A ‘standalone’ Grievance Mechanism (a revision of the earlier 2015 ‘ESHIA’ SEP Grievance Procedure) has been provided (SUST-PRO-007-01 “Grievance Mechanism”), with an effective date of May 2016, and this Grievance Mechanism is considered by VUGL and Eni Ghana to be ‘Annex A’ to the SEP. This Grievance Mechanism is a hybrid document- it consists of guidance on preparing a Grievance Mechanism and then it presents a Grievance Mechanism. The Grievance Mechanism provides for concerns, grievances and ‘whistle-blowing’ complaints to be considered at the early stages of the procedure and then for concerns and ‘whistle-blowing’ complaints to be separated from grievances prior to entering separate procedures.

Eni Ghana has issued its first Annual Report (for year 2016)14 on the operation of the Grievance Mechanism. The Report states that twenty three (23) grievances were recorded and closed out in 2016. These grievances were mainly related to misinterpretation of messages during the Transitional Support Food Aid ‘pilot’ testing. All grievances were successfully resolved and closed out through clarification of activities related to the food aid programme. Further, it is stated that all the grievances were closed out at CLO and or management level. No grievance was escalated to the Grievance Management Committee. In addition to these grievances, issues/concerns were also received. These were all managed and closed out in 2016. The Annual Report does not

14 The Annual Report is dated 17/02/2017 with the document reference: SUST–REP-0600-00



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clarify whether the grievances include grievances submitted to De Simone and Eni Ghana or only Eni Ghana.

The Annual Report confirms that grievance sign boards and suggestion boxes were placed in Project communities to grant community members the opportunity to submit their concerns/grievances locally (see Figure 3 for English-language notice). The suggestion boxes are accessed twice weekly by the CLOs. Concerns/grievances can be submitted directly to CLOs/FLOs, by calling/texting via the telephone or by sending emails to the ‘grievance’ email address (telephone numbers and the email address are on the sign board).

Figure 3: Notice Presenting the ‘Community’ Grievance Mechanism

The Annual Report noted three challenges faced in 2016:

Complainants were not patient in terms of waiting for resolution;

Complainants were not willing to accept any explanation not in their favour; and

Complainants were resistant to sign a ‘resolution and close out form’ when the resolution did not meet their expectations.

The SLC Risk Register (Updated: 10 February 2017) lists a number of risks relating to the operation of the Grievance Mechanism. The only grievance-related risk to be rated as ‘High’ relates to the fact that De Simone’s management of grievances was not monitored adequately by Eni Ghana due to the lack of an Eni Ghana Labour Relations Officer working at the local



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community level (it is understood that the appointment of this Officer is a high priority and will occur in Q2, 2017).

6.10 Contingency planning

Eni Ghana has developed an Emergency Response Plan (rev 10) dated January 2017 outlining the Company’s approach to emergency planning, including oil spill contingency planning. Eni Ghana has also prepared an Oil Spill Contingency Plan, updated in February 2017, with input from Oil Spill Response Limited (OSRL) based in the UK. The IESC has been provided with this plan but has not been able to undertake a full review in the timeframes permitted. Nevertheless, based on preliminary screening, it appears to be comprehensive in terms of its scope, organisational responsibilities, tiered approach, response strategies, sensitivity mapping, equipment stockpiles, training and exercises. Contractors are also required to align their own OSR plans with Eni Ghana’s.

The IESC notes several examples of good practice relating to Eni Ghana’s response equipment including: a proposed Memorandum of Understanding (MoU) with Tullow Oil; detailed sensitivity mapping along coastline (to inform response strategies); the Simultaneous Operations (SIMOPS) vessel tracking system; secondment of a specialist from OSRL; availability of a dedicated control room in the event of an emergency; mechanisms for handling media enquiries; and the afore- mentioned drills and exercises, including actual deployment of response equipment.

The IESC notes the use of volunteers to assist in oil spill clean-up operations and highlights potential liabilities associated with the use of inexperienced volunteers during the monitoring visit. Consistent with this concern, it is noted that in addition to the need for training, provision of PPE and supervision of volunteers in the event of a clean-up operation, the OSRP contains the following text ‘It is advisable for the incident owner to ask volunteers to sign a legal release of liability form. This may or may not prevent legal claims, but can assist in clarifying expectations of clean-up volunteers.’ Emphasis added by IESC. Identification and pre-training of volunteers will help control liability issues in the event of a spill, but nevertheless it is recommended that Eni Ghana makes itself fully aware of risk associated with potential liabilities/personal injury claims in advance of a spill.

The IESC would also advise Eni Ghana procures in-house oil spill trajectory modelling capabilities. It is understood a budget has been agreed and an oil spill model (OSCAR) will be available in the Eni Ghana headquarters in the near future.

During the meeting with the EPA, it was confirmed that chemical dispersants have been pre-approved for use in an oil spill in line with the National Oil Spill Contingency Plan. However, Eni Ghana would have to liaise with the EPA in an emergency situation before actual use of dispersants. The IESC recommends future oil spill exercises should include the need to use dispersants in order to test the EPA approval process. It is also recommended that incident scenarios are designed without Eni Ghana’s advanced knowledge to ensure realistic response conditions.

6.11 Management of change

The Project operates a management of change process [Ref 107]. The process is designed to take account of high risk E&S implications associated with any change requiring, in summary:

A request for a change (to be assessed by HSE and SLC departments);

Risk evaluation and risk categorisation; and

Preparation of a change plan and amendment of E&S management plans if required.

The process requires notification of the WBG in the event of a medium high/ high potential risk change at least 15 days prior to commencement of the change event.



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The IESC was provided with an example of the change management documentation generated following the decision to rotate the location of the ORF facilities by 90 degrees, including an engineering change form and a risk evaluation report.

The risk evaluation concludes there are no medium high/high risks associated with the change, primarily because the area of swamp affected by construction will be reduced, and therefore there was no requirement to notify the WBG.

The IESC confirms the existence of a Management of Change Procedure and has seen evidence of the procedure working in practice. However, it is noted that the risk evaluation did not consider rare flora and the need to revise the Flora Conservation Plan or to expand the botanical survey performed for the original site ORF positioning (see Section 11.4, Flora Conservation Plan)

6.12 VUGL E&S Assurance

In line with WBG PS1 and ESAP action 16, Vitol has assigned an E&S Assurance Manager to the OCTP project to oversee environmental, health, safety and social aspects, ensuring compliance with the Performance Standards and Project E&S commitments.

The Vitol E&S Assurance Manager was present throughout the audit. During audit interviews it was apparent that the Vitol E&S Assurance Manager had close interaction with the Eni Ghana HSE and SLC teams, including review and technical input into the Project’s E&S management plans.



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Table 2: Summary of Findings, PS1

ID Aspect Issue Description Phase Standard IESC Recommendations Significance

001 Management plans

Late submission of the Fisheries Management and Participatory Monitoring Programme Framework Strategy.

Construction PS1 See Finding 024

Minor

002 Contractor management

Appendices for the Early Works contract do not include requirements specified in those E&S management plans developed post contract award over the course of 2016. In particular there is no reference to Lender guidelines relating to security providers and workers’ accommodation standards.

Construction and operations

PS2 Contract appendices should include requirements of management plans developed over the course of 2016/17 and stipulate alignment with the Voluntary Principles on Security and Human Rights and the Workers’ Accommodation: Processes and Standards guidance note co-authored by the IFC.

Moderate

003 Management of Cumulative Impacts

Eni Ghana has not reported its efforts to manage cumulative impacts in the Operator’s AMR submitted to the World Bank. The IESC acknowledges emails were sent from for attention of WBG via VUGL, but communications failed.

The actions specified in the Cumulative Impact Mitigation Strategy have not been actioned.


ESAP Eni Ghana should include details of its efforts to manage cumulative impacts in the non-Operator AMR due for submission to IFC and MIGA at the end of March 2017. WBG should amend its AMR template to facilitate inclusion of commentary relating to cumulative impacts.

Update the Cumulative Impact Mitigation Strategy to reflect revised timeframes and strategy, for example, revisions associated with the potential letter to the WBG seeking support in the management of cumulative impacts.

Minor (recognising efforts made

by Eni Ghana)



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004 Staffing The SLC department has not yet achieved its full complement of staff members in post (two positions remain to be filled)

Construction and Operations

PS 1 Increase efforts to recruit new staff members to fill the remaining posts.

Try to recruit a woman to fill the vacant CLO post (to increase the number of women in the CLO team and thereby enhance Project links with local women)

Minor

005 Contractor Management and Monitoring

Weaknesses in contractor management and monitoring (with respect to the Early Works contractor) have emerged regarding local recruitment, transfer of workers from one contractor to another and in terms of grievance management


PS 1 Ensure that the Labour Relations Officer is in place by the end of Q2, 2017

Moderate

006 Grievances Annual reporting on Grievances, as implemented in the 2016 Annual Report on the Grievance Mechanism (the only such Annual Report to date) does not distinguish between grievances linked to/managed by contractor/s and Eni Ghana


PS 1 Ensure that there is a clear distinction made between grievances managed by Eni Ghana and those that are managed by a contractor with the annual analyses of performance, in managing grievances, clearly covering both types/situations

Minor

007 Oil spill response

The use of volunteers could expose Eni Ghana to potential liabilities/personal injury claims

Eni will require approval from the EPA to use dispersants


PS1 It is recommended that Eni Ghana makes itself fully aware of risk associated with potential liabilities/personal injury claims in advance of a spill.

Future exercises should include use of dispersants and test the interaction/approval for use of dispersants from the EPA (especially

NA



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outside of EPA normal working hours) To maximise the benefit of the exercises, Eni Ghana should be kept unaware of the planned scenarios



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7. PERFORMANCE STANDARD 2: LABOR AND WORKING CONDITIONS

7.1 Introduction

No ESAP items, applicable to Eni Ghana, refer to labour and working conditions. The only related ESAP item is item 17 which states that ‘Vitol Ghana’15 will develop and adopt a Human Resource Policy.

7.2 VUGL Human Resource Policy

Vitol has issued a Human Resources Policy (signed by the General Manager on 20 April 2016). This Policy covers all the key issues relating to labour and working conditions (as presented in PS 2), and includes a statement that Vitol will comply with all applicable national regulatory requirements and be guided by the UN Global Compact on Human Rights and international best practice including IFC’s Performance Standards and the International Labour Organization’s accepted labour standards. This Policy also states that Vitol will, “….ensure that in all of the countries where we operate we will develop Human Resources Procedures which implement the commitment of this Policy.” This Policy is accompanied by the Human Resources Corporate Standard (dated December 2015) which gives effect, at the corporate level, to the Policy. The aim of the Human Resources Corporate Standard is, “To promote a sound management - worker relationship, protecting the fundamental rights of workers and providing a safe and healthy working environment.” Finally, Vitol has issued an Ethics Policy (signed by the General Manager on 20 April 2016) and covering such topics as bribery and corruption and whistle-blowing.

VUGL, an affiliate of Vitol, has not issued a Human Resources Policy specific to its Ghana operations. It has prepared, however, a Human Resources Plan (Version 2 dated July 2016) which is aligned with the Vitol Human Resources Policy and which reiterates the commitments made in that Policy, “As a Company we are guided by the UN Global Compact principles on Human Rights and are committed to providing a safe and healthy place of work, based on the principle of equal opportunity and fair treatment and freedom from discrimination, to provide an environment where our employees and contractors can work in full enjoyment of their legitimate rights. This commitment is stated in the Vitol Upstream Ghana Human Resources (HR) Policy [IESC emphasis added] and implemented through this Corporate HR Procedure and the country level HR Procedures.”

The Human Resources Plan is referred to as a ‘Corporate HR Procedure’ so it may be considered to fulfil the Vitol commitment of ensuring that,”….. in all of the countries where we operate we will develop Human Resources Procedures which implement the commitment of this Policy.” However, the current status of the Human Resources Plan is not clear as the ‘Document Details and Issue Record’ for the Plan refers to it as ‘Rev 2’ and ‘Revision’ (not ‘Final’) and there is no signature.

7.3 Management of labour and working conditions

Eni Ghana has prepared two key plans that relate in different ways to labour and working conditions:

Workers Management Plan16;

Recruitment, Employment and Training Plan17

15 The ESAP refers to ‘Vitol Ghana’. ESAP references to ‘Vitol Ghana’ are to be understood as referring to VUGL. 16 Document reference: SUST-PLAN-003. 17 Document reference: SUST-PLAN-001.



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Both of these plans became effective in May 2016 and apply not only to Eni Ghana, but also to contractors and, also, they are a guide to ‘main suppliers’ which are hiring workers, “Eni Ghana will use commercially reasonable efforts to require contractors, or other intermediaries procuring labour, to apply comparable standards.” Further, both plans state that, “Eni Ghana remains the ultimate responsible party for compliance with ESHIA commitments, and will establish means for monitoring/supervision of contractor’s performance.” The ‘effective’ dates for these plans is at least two (2) months after De Simone started its work in the concession area.

These Plans refer to other plans and attendant procedures inter alia:

External Recruitment Plan;

Human Resources Recruitment and Selection Procedure;

Local recruitment procedure (in final stages of internal review and not provided to the IESC) which relates directly to the Recruitment, Employment and Training Plan and focuses solely on mechanisms for hiring workers from within the DAoI so that community-focused recruitment targets are met;

Company Handbook for National Staff (classed as a ‘Procedure’); and

Code of Ethics: information on operation of the Code is contained in the Eni corporate document entitled ‘Model 231’ (a copy of the Code of Ethics was not provided to the IESC).

Essentially, the Recruitment, Employment and Training Plan deals with managing risks in relation to:

Selection, hiring and induction training of workers; and

Maximizing community benefits related to employment and skill enhancement.

A key aim of this plan is to maximize hiring of local people residing in the DAoI (this aim also links to efforts to manage influx). Targets, in the form of %s for recruitment from each of the communities, are stated in the Plan. In this context, three (3) key objectives of this plan are to:

Promote fair and equitable labour practices, non-discrimination and equal opportunity for all workers;

Establish, manage and promote a healthy management-worker relationship; and

Protect workers’ rights including migrant and third-party workers.

Both plans refer to PS 2 and the Recruitment, Employment and Training Plan mentions forced labour as a PS 2 issue, but the measures to be implemented do not include a prohibition on hiring forced labour while a prohibition on hiring of child labour is included. However, the Workers Management Plan contains a clear commitment to avoid the use of forced labour. Again, ‘migrant workers’ are mentioned in the Recruitment, Employment and Training Plan18, but no measures apply to hiring of migrant workers (a similar finding applies to the Workers Management Plan in terms of employees who are migrant workers). There is a clear commitment to apply the principles of non-discrimination and equal opportunities (including pay).

All workers are issued with a written contract that will be explained verbally to recruits, when necessary. Induction of workers will cover the following:

Terms and conditions of employment;

Workers’ associations and collective bargaining;

Company policy on non-discrimination; and

Use of the workers’ grievance mechanism.

18 The Workers Management Plan refers to the UN Convention on the Protection of the Rights of all Migrant Workers and Members of their Families, but not the Recruitment, Employment and Training Plan.



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During induction all recruits will be informed of the Code of Ethics (and will be provided with a copy – according to the Company Handbook for National Staff) which requires:

Respect for different cultures and their differences (for example, with respect to diet, and religious ceremonies);

Application of non-discrimination and equal opportunity in the workplace;

No harassment of colleagues; and

Adherence to a set of community “do’s and don’ts”.

Neither the Company Handbook for National Staff nor the ‘model’ Employment Contract mention the issue of workers’ associations and collective bargaining. However, the Workers Management Plan includes compliance monitoring for freedom of association.

The available documentation plus the statements made in interviews, particularly with the Personnel Manager, indicate compliance with PS 2 requirements. However, the following issues have been identified:

Consistency is needed in the key plans and procedures to ensure that avoidance of employing forced labour is clearly expressed;

Despite a realization, as expressed in both the Workers Management Plan and the Recruitment, Employment and Training Plan, that migrant workers are a special category of workers, there are no measures specifically mentioned to ensure that they are engaged on substantially equivalent terms and conditions to non-migrant workers carrying out similar work;

Although workers will be informed about workers’ associations and collective bargaining during induction; the key documents provided to workers do not mention this topic (it is noted that the Company Handbook for National Staff is being revised and that this topic will be introduced into the revised version of the Handbook); and

Eni Ghana does not yet have a Human Resources Policy that is tailored to its operations in Ghana.

7.4 Local labour-related issues

During interviews with senior Eni Ghana personnel certain labour-related issues were mentioned as occurring in the concession area. First, despite information on labour recruitment procedures and terms and conditions of employment being provided to local people via community-level meetings, employment contracts and explanations provided during induction, some problems have arisen when workers have ceased working for one contractor and start working for another. For example, problems have resulted from differences between contractors in terms of dates for payment of salaries. Secondly, local people, have complained that the local recruitment procedure has not been entirely successful in terms of meeting local recruitment targets. It appears that non-locals have been employed (it is noted that a revised Local Recruitment Procedure is in the process of internal Eni Ghana review).

Also, there was a reported ‘blockage’ of De Simone’s office, at the ORF site, in August 2016 due to worker dissatisfaction about the early ‘laying off’ of workers on a 7-month contract. This incident points to the importance of effective contractor management in maintaining good labour relations; good relations with local communities and Eni Ghana’s reputation.

7.5 Human trafficking

The Community Health Management Plan contains a measure relating to human trafficking – this measure involves the issue being raised in stakeholder engagement activities.



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7.6 Workers’ grievance mechanism

The Workers Management Plan refers to a Workers Grievance Mechanism and one of the impact management provisions relates to the need for monitoring that the, “Grievance mechanism is accessible for contracted workers” (see table 6.1 of the Workers Management Plan). The Company Handbook for National Staff does not mention a Workers Grievance Mechanism; however, there is an intranet- based online grievance mechanism for all Project workers (see Figure 4). The Workers’ Grievance Mechanism is referred to in the ‘model’ Employment Contract which is provided to each recruit. Also, there is provision for ‘whistle-blowing’ complaints/grievances, via the Code of Ethics.

Figure 4: Screenshot of page for workers to submit suggestions and/or grievances

7.7 Occupational Health and Safety

Eni Ghana operates under an integrated Health, Safety and Environment Management System. The operational framework for HSE management is provided for in the plan entitled ‘Ghana OCTP Block Environmental, Social, Health Management Plan (EHSMP) – Construction and Development Drilling Phase, dated May 2106.

The HSE-IMS system is OHSAS 18001 certified, being re-certified in December 2016 by Rina Services S.p.A (‘Rina’). The Rina audit report (Ref 16GE171MS) [Ref 16 – embedded] did not identify any major or minor non-conformances, only recommendations. The IESC was subsequently provided with a summary of corrective actions undertaken to address the recommendations indicating 9 of 11 recommendations had been addressed with the remainder ongoing.

The purpose of the IESC monitoring visit was wide ranging and therefore not intended to cover all H&S aspects in detail. The IESC did however verify implementation of certain H&S plans and procedures, including verification of Eni Ghana and Contractor’s H&S performance at the Takoradi logistics base, as discussed below.

Permit to Work (PTW) procedure – Eni Ghana operates a PTW which was reviewed for lifting operations at the Takoradi Logistics base. Eni Ghana provided evidence of the procedure including risk assessment, tool box talks (prior to start of activity), maintenance records for



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cranes, certificates for lifting straps and an example lifting plan. The process was thorough and well documented – no concerns were raised with the PTW procedure. See Appendix 5, Photos 8 and 9 for examples of good practice.

Training records – training records and certificates for staff at the logistics base (rigging and slinging banksmen, mobile crane operators (x5) and forklift truck drivers were examined and again no issues were identified.

Traffic management – Eni Ghana has developed a Traffic Management Plan, dated August 2016. The plan is intended to manage Project traffic in a manner that minimises disruption to other users and maintains safety of pedestrians and other road users. The plan includes numerous management action placed on road hauliers to control routes, speeds and drivers’ behaviour. Key to the implementation is the EHS commitment that an In Vehicle Monitoring System (IVMS) is used.

The IESC reviewed a loading and transportation plan and a route survey assessment associated with the transportation of Christmas trees from the GE yard to the port by Baj Freight. Of note, Baj Freight was audited as part of the 2016 audit programme.

Other HSE management plan/procedures, including incident investigation and reporting19 are also required by Eni Ghana, and evidenced by the IESC during the trip. It is clear that Eni Ghana aims to enforce high HSE standards through its procurement procedure and HSE-IMS (specifically the audit programme). However, during the visit to the Takoradi Logistics base a number of issues were identified.

1. The mini-bus used to transport the lender group did not have seat belts for fold down seats. Seats without belts were used;

2. As an additional safeguard to the PTW system (which requires valid certificates for all lifting equipment) untested/expired lifting straps should be stored separately from other straps and labelled ‘not for use’. Unique identifiers should be clearly visible – use of indelible markers is not appropriate because it can be readily removed due to abrasion (Photos 3 and 4, Appendix 5); and

3. Although not an H&S issue, staining was observed outside the entrance to the generator. The wall surrounding the generator does not function as a bund therefore allowing loss of containment should the sump adjacent to the generator fail (Photos 5 and 6, Appendix 5).

The IESC found a strong health and safety culture within Eni Ghana and the project in general. The implementation of a robust H&S management system is reflected in a good safety record: Eni Ghana reports zero fatalities, recordable injuries and lost workdays in the AMR for 2016.

7.8 Workers’ accommodation

The Workers’ Management Plan focuses on workers once in employment and includes requirements regarding provision of accommodation to workers. This plan contains clear commitments to apply the IFC/EBRD (2009) Guidelines on Worker Accommodation when siting, designing, constructing and managing accommodation, to be provided for workers, is undertaken. However, there is no accommodation policy that provides a set of high-level commitments in terms of provision of accommodation to workers.

19 IESC was shown incident report following a road traffic accident. The driver fell asleep due to tiredness; corrective action included change of shift patterns to prevent back to back shift working and ensure opportunities to rest.



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008 Human Resources Policy

Eni Ghana does not have a Human Resources Policy that is tailored to its operations in Ghana No clear and consistent statements across all key Plans that child and forced labour and trafficked persons will not be hired


PS 2 Prepare, approve, disseminate and implement a tailored Human Resources Policy This policy to include explicit statements that child and forced labour and trafficked persons will not be hired

Minor

009 Workers’ Associations and Collective Bargaining

Key documents (for example, Company Handbook for National Staff) provided to workers upon recruitment and during induction do not mention workers’ rights/potential opportunities in relation to workers’ associations and collective bargaining


PS 2 Amend the Company Handbook for National Staff and perhaps, the ‘model’ Contract of Employment, when appropriate, to include either a) existing worker’s rights in terms of joining workers’ associations, if agreements have been reached between Eni Ghana and a workers’ association/s; or b) potential opportunities available to workers in relation to benefitting from workers’ associations and collective bargaining

Minor

010 Accommodation Provision

No Eni Ghana accommodation policy exists


PS 2 Prepare, approve, disseminate and implement an Accommodation Policy or incorporate it into a (combined) Human Resources and Workers’ Accommodation Policy

Minor

011 Migrant Workers No specific measures to ensure that the interests of migrant workers are recognized and protected are included in Recruitment, Employment and Training Plan and the Worker Management Plan


PS 2 Amend the Recruitment, Employment and Training Plan and the Worker Management Plan, when appropriate, to include a commitment to engage migrant workers, on substantially equivalent terms and conditions to non-migrant workers carrying out similar work

Minor

012 Discontinuity in Terms and Conditions in

Lack of understanding among some local people that terms and conditions can vary


PS 2 Work with contractors that will hire local workers, already employed by another contractor, to ensure that there are no major differences that may lead to local labour

Moderate



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Employment Contracts

disquiet (such as changes in the date of salary payments) and to ensure the workers understand the new terms and conditions during recruitment and later during induction Complete the hire of the Labour Relations Officer as soon as possible

013 Human trafficking

No mention of human trafficking in Plans and other documents relating to labour and working conditions


PS2 Add measures to manage the risks posed by human trafficking to the Security Management Plan, and any operating procedures issued under this Plan, particularly with respect to onshore/offshore activities and to risks to the integrity of the Eni Ghana local labour recruitment process and, therefore, to Eni Ghana’s reputation

Minor

014 Occupational Health and Safety – seat belts

A mini-bus unexpectedly used to transport the lender group did not have seat belts for the fold down seats.


PS2 Use of seats without seat belts should be prohibited. Ideally seats should be removed or provided with seat belts. Moderate

015 OHS – lifting straps

Poor labelling of lifting straps Construction PS2 Untested/expired lifting straps should be stored separately from other straps and labelled ‘not for use’. Unique identifiers should be clearly visible – labelling with indelible marker pens is not appropriate

Minor



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8. PERFORMANCE STANDARD 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION

This chapter considers the management and monitoring of key environmental impacts associated with the Project and the Project’s commitments to the prevention of pollution and resource efficiency. Key aspects relevant to the Project include:

air quality;

noise;

surface water and sediments;

groundwater;

waste management;

soils;

traffic;

greenhouse gas emissions; and

environmental monitoring

These are discussed in turn below.

8.1 Air quality

Ambient air quality measurements have not been taken since the start of construction activities because a monitoring contract had not been awarded at the time of the site visit. See Section 8.11, Environmental Management and Monitoring.

Eni Ghana has developed an Environmental Monitoring Plan. The sections of the plan addressing air quality monitoring need to be amended to include appropriate sampling techniques because certain parameters listed cannot be measured using the techniques specified, for example, passive sampling.

The IESC would also question the value of offshore air quality monitoring in the absence of permanent offshore receptors.

8.2 Noise

Contrary to Table 8.7 in the Environmental Monitoring Programme [Ref 18] noise measurements have not been taken by the Early Works contractor at the ORF since the start of construction activities because a monitoring contract had not been awarded at the time of the site visit. See Section 8.11, Environmental Management and Monitoring.

Underwater noise measurements are not required because of the low risk to marine mammals and others species assessed in the ESHIA.

8.3 Surface and groundwater

Eni Ghana has developed a Water Management Plan. The basic premise of the plan is to avoid water sources used by local communities i.e. source Project water from deep aquifers and avoid any changes to the hydrological regime, and in particular wetland areas, through engineering design.

The IESC was unable to visit the ORF at the time of the monitoring visit. The IESC is however aware that water volumes required for Project purposes, sourced from 4 deep aquifer wells located at the ORF site, will be relatively small. Aerial evidence of measures to ensure hydrologic continuity (use of culverts) was observed on drone footage of the ORF site. The IESC also learnt that the footprint the ORF facilities was reoriented 90 degrees to avoid swampy areas.



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Water management, and in particular the results of surface and groundwater monitoring, will be subject to further review during the second monitoring visit.

8.4 Waste management

The Project manages waste in accordance with the Waste Management Plan Rev 08 dated January 2017, which replaces Rev07 dated Jan 2016 and preceding WMPs dating back to 2009. The plan covers all locations and waste generating activities of the Project and includes requirements placed on Contractors. It adopts a waste management hierarchy and generally includes elements expected from a good waste management plan, including procedures for segregation and tracking of wastes (waste consignment notes) through to the final treatment/disposal option. Eni Ghana has commissioned ZOIL Services Limited, a specialist waste management contractor with the capability to handle hazardous and non-hazardous wastes.

The IESC sought evidence of waste management practices during a visit to the Takoradi Logistics base and noted good waste management practices including:

Facilities for segregation of waste (Appendix 5, photo 1);

Use of waste transfer notes (evidence provided to IESC);

Provision of disposal certificate by waste contractor (electronic evidence provided); and

A formal audit of ZOIL.

Eni Ghana informed that periodic inspections are carried out in line with a ‘cradle to grave’ philosophy. For example, Eni Ghana witnessed the destruction of its used lifting straps intended for disposal to ensure these could not be reused.

Evidence provided during the site visit demonstrated good waste management practices, however a number of observations are made with respect to the Waste Management Plan that should be addressed.

The waste management plan refers to the use of on-site incinerators for the treatment of sewage sludge. Based on discussions held during the audit it is understood there are no plans for Eni Ghana to operate on-site incinerators and ZOIL’s incinerator in Takoradi will be used.

The table in chapter 6 needs to be reviewed and updated accordingly to reflect current/proposed practices. For example, the table currently indicates ballast water will be treated by a waste management contractor; this is not correct. Similar the table indicates treatment of drill cuttings is by the waste management contractor, whereas actual practice was for drill cuttings to be monitored for oil content and discharged to sea in accordance with a permitted 2% maximum oil content.

The WMP includes text relating to treatment and disposal of Normally Occurring Radioactive Materials (NORM). Following discussions with the EPA, the IESC understands there are currently no waste treatment options for radioactive material in Ghana. It is understood that Eni Ghana will enter into discussions with the Ghanaian Atomic Energy Commission to agree a solution. Whereas the Project does not have any NORM at present, it is likely to occur during production in accumulated sludge and scale20, and a survey is planned in the future.

The WMP needs to be revised to address the issues highlighted above and provide greater clarity over the management of NORM and other hazardous waste streams.

20 IESC was informed by the EPA that Tullow Oil is generating NORM.



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8.5 Soil management and reinstatement

The Project has developed two plans that relate to top soil management and reinstatement: the Topsoil Management working instruction Rev 01 dated August 2016 and Reinstatement and Revegetation Standard Rev01, dated August 2016.

The Topsoil Management Plan outlines a number of good practice stripping and stockpiling measures, including measures stipulated within environmental permit conditions. Based on discussion with the Early Works Contractor, still photographs, moving aerial imagery and review of top soil inspection and monitoring checklists the IESC considers good practice is being used at the site.

Of note, the Project is also using spare top soil to reinstate an area to the north of the ORF boundary that was disturbed by a third party. The area will be then handed back to the land owner for agricultural purposes.

Reinstatement will be assessed in the next Lenders’ monitoring trip when the IESC will have an opportunity to visit the ORF site.

8.6 Greenhouse gas emissions

Line 8 of the ESAP requires Eni Ghana to maintain a quantification programme for GHG emissions. Linked to this requirement, Eni Ghana has committed to implement a Zero-Permanent Flaring policy, and will implement measures for minimization of venting and flaring (consistent with the Global Gas Flaring and Venting Reduction Voluntary Standard) and minimization of fugitive emissions. The first milestone in the ESAP is ‘Quantification and minimization program for GHG emissions submitted to WBG, by 30th June 2017.

The Project’s management of GHG emissions is described in the EMP in which GHG quantification methodologies are outlined. Industry good practice is also detailed in Table 9.5 of the EMP, including avoidance of flaring of produced hydrocarbons during well testing. The EMP refers to estimation of CO2 emissions during flaring and Eni Ghana has confirmed that well testing is being conducted using the rig which has no on-board production or storage facilities, thus making it not possible avoid flaring of test fluids. The Project will not flare once the FPSO is operational and Eni Ghana has full production facilities.

The quantification programme21 of GHG emissions is likely to be the subject for discussion during the IESC second monitoring visit during the second half of 2017.

8.7 Environmental Management and Monitoring

Eni Ghana produced a broad ranging Environmental Monitoring Plan (EMP) dated 5th October 2016 which was subsequently updated on 26th January 2017. The EMP builds on the commitments made in the Phase 1 ESHIA and covers onshore and offshore construction activities. It also cross references to a number of supporting plans including the Sea Turtles Biodiversity Action Plan, the Avian Biodiversity Action Plan, Marine Mammals & Sea Turtle Protection Policy Plan, the Bushmeat Action Plan and the Flora Conservation Plan among others. The stand-alone plans referenced also specify additional monitoring requirements that are not necessarily captured within the EMP.

The Plans apply to all contractors, although Eni Ghana retains ultimate responsibility for the content of the plan and its implementation. The findings below are based on review of the EMP, various complementary plans, and discussion with HSE staff during the monitoring visit.

It is unclear from the ESAP whether specific timeframes were envisaged for this Environmental Monitoring Plan. However, the EMP was finalised in January 2017 (October 2016 for Rev 00)

21 ESL Consulting will support Eni Ghana in the qualification of GHG emissions



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whereas works construction activities started several months earlier at the ORF and similarly for the offshore drilling works. Consequently, this plan and the associated plans listed above were not provided to Contractors prior to start of their activities. The IESC was made aware that the plans were provided to contactors as they became available, and the IESC confirms that measures identified in the various plans have been applied retrospectively where possible, Nevertheless, certain monitoring actions that, in accordance with good practice, would be expected to occur during earlier construction, did not occur. These include, inter alia:

Limited/no records of the early trainings and communications provided to the Contractors’ employees;

No monitoring of surface water and/or sediment quality in 2016 during offshore drilling activities;

No monitoring of water levels and water quality in wells used by nearby communities;

Delays in the onshore monitoring for invasive species; and

For the Early Works at the ORF, delays in the monitoring of hunting, harvesting, collection or trading in bush meat, vulture parts or turtle eggs by employees, contractors or their families.

In addition to the monitoring requirements highlighted above, the various stand-alone plans place important requirements in relation to future planned construction work, including the beach pipe-lay. Some of these items have reasonably long-lead start dates prior to commencement. For example the Sea Turtle Action Plan requires a pre-work inspection of the work area to be performed daily by a suitability trained ecologist(s) (at night and dawn) for 60 days prior to the commencement of clearing and trenching on the beach. The Bird Action Plan includes pre-commencement survey requirements in relation to shorebirds for 30 days prior to pipeline trenching or excavation of nesting habitat, as well as for vulture roosting and feeding areas. With beach work due to commence in May 2017, pre-construction turtle surveys must commence in the near future.

The Marine Mammal and Sea Turtle Monitoring Programme specifies monitoring to be completed throughout the construction and development drilling phase, to include both dedicated watches by an experienced observer and incidental sightings by any personnel. This requirement is in part to fill a gap in baseline data on marine mammals22. Other marine mammal monitoring requirements are included to measure KPIs in relation to mitigation measures designed to avoid impacts to marine mammals. Notwithstanding the ‘Minor’ impact significance categorisation in the ESHIA, without this ongoing monitoring to date, baseline data gaps will remain and it will not be possible to assess the efficacy of mitigation/verify the impact significance categorisation in the ESHIA Report.

The Biodiversity Action Plans for birds and turtles also include monitoring requirements that are not directly related to the construction schedule or activities. The Turtle Action Plan specifies that Eni Ghana will establish and commence sea turtle monitoring programme that incorporates local NGO beach surveillance and monitoring as well as sea turtle specialists for the first year to ground truth data collected by the local NGO. It is not clear to Ramboll Environ whether this has commenced prior to the appointment of Ghana Wildlife Society (GWS).

The Biodiversity action plans also include a number of non-monitoring actions that were due to commence recently, or are due to commence shortly. For example, the Bird Action Plan specifies

that a community education, awareness and conservation initiative in relation to vultures was due to start in late 2016; and

22 The IESC acknowledges that the ESHIA assessed impacts to marine mammals and turtles caused by drilling activities to be minor.



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Implement Additional Conservation Actions in a phased manner to support and secure Amansuri DMU due to start December 2016;

and the Turtle Action Plan specifies:

The ongoing requirement to engage and contribute to existing community based turtle conservation programme; and

Directly support GWS to communicate and/or erect suitable signs in the ORF and in the communities warning about illegal activities including harvest of sea turtles and eggs due to start in December 2016.

Other observations made following review of the EMP requiring attention include:

Limited reference to WBG environmental guideline values23 thus making it unclear which standard will be applied where differences are apparent between Ghanaian, MARPOL and WBG limits e.g. water quality. Confirmation is required within the EMP that the most stringent applies or justification provided for any derogation;

Concerns over sampling methodologies and analytical techniques. For example, inappropriate use of passive samplers for certain parameters e.g. particulate matter and carbon monoxide; and

The plan has a number of erroneous cross references, making it difficult to use as an operational plan, and also questioning it review and approval process.

To date HSE Operations Coordinator has been responsible for coordination of the EMP. In the future implementation of the EMP and associated plans will largely be undertaken by ESL Consulting24. The Monitoring Contractor has identified accredited laboratories (Tecnoambiente) outside of Ghana (in Spain). Furthermore, the IESC understands the EMP will be refined with the appointment of ESL.

Eni Ghana also intends to commission the service of Ghana Wildlife Society for the implementation of the Turtle Biodiversity Action Plan, other offshore marine fauna monitoring and the Bird BAP. At the time of the audit Eni Ghana informed the IESC that contractual agreement with GWS was imminent.

The appointment of the environmental monitoring contractors several months after the start of construction works has resulted in missed opportunities for monitoring and a real data gap which in some cases is a risk for the Project. Consequently there is an urgent need to prioritise finalisation of contract(s), refine the EMP and start comprehensive monitoring at the earliest opportunity.

23 For ambient air quality local standards can apply. For other parameters the Project should adopt the most stringent of either

national or IFC standards. 24 IESC was informed that contract negotiations were almost finalised at the time of the monitoring visit and ESL start date was imminent.



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Table 6: Summary of Findings (PS3)


016 Air quality monitoring

Inappropriate use of passive Monitoring techniques for certain parameters


PS3 Revision of the EMP to ensure appropriate analytical techniques are specified for each pollutant targeted for analysis

Minor

017 Waste Management

The Waste Management Plan lacks specificity and has a number of inaccuracies relative to actual Project practices Options for the anticipated disposal of NORM should be identified before NORM is generated


PS3 Amend the current WMP so it reflects actual Project practices Clarify disposal options for anticipated generation of NORM

Moderate

018 Environmental monitoring

The Environmental Monitoring Plan lacks specificity has a number of inaccuracies

Construction PS3 Revise the EMP taking account of the issues highlighted in this report, including: - appropriate sampling techniques - erroneous cross referencing - definition of numerical standards

Minor

019 Environmental monitoring

The appointment of the environmental monitoring contractors several months after the start of construction works has resulted in missed opportunities for monitoring and a real data gap which in some cases is a risk for the Project. Consequently there is an urgent need to prioritise finalisation of contract(s), refine the EMP and start comprehensive monitoring at the earliest opportunity

Construction PS3 Appoint specialist companies to implement monitoring plan as a matter of priority Focus attention of upcoming construction activities, for example, monitoring required for the onshore pipe lay

High



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9. PERFORMANCE STANDARD 4: COMMUNITY HEALTH, SAFETY, AND SECURITY

PS 4 indicates that there is a range of considerations to be taken into account in identifying and considering risks/impacts on community health and safety; these are:

Infrastructure and Equipment Design and Safety;

Hazardous Materials Management and Safety;

Ecosystem Services;

Community Exposure to Disease; and

Emergency Preparedness and Response.

A Community Health Management Plan25 has been prepared (31 May 2016) and it indicates which of the Project E&S management documents (such as study reports and plans) apply to each of the five (5) topics listed above. It refers to a Security Management Plan; however this Plan does not yet exist (see Section 9.3 below).

Below the analysis focuses on community health and safety and security under separate headings:

Community health and safety; and

Security.

9.1 Community Health and Safety

A Community Health Management Plan has been in place since 31 May 2016. This Plan post-dates the initiation of early works by De Simone Ltd by approximately 2 months. This Plan focuses on community health and safety. Community safety issues related to traffic, induced by the Project are managed, also, via the Traffic Management Plan (effective date 15 August, 2016). The Traffic Management Plan post-dates the initiation of early works by De Simone Ltd by approximately 4.5 months.

Viewing the ‘drone’ video footage of the Project site it is clear that early works have created some areas of standing water; such as the build-up of water at the sides of the access road in the swampy area. Eni Ghana is taking action to reduce this build-up of standing water through de-watering. This prompt remedial action is an example of the continuing vigilance that is, and will be, required by Eni Ghana to manage the risks posed to community health by any increase in standing waterbodies.

Offshore the main community health and safety issue relates to the risks to fishermen posed by the offshore facilities and vessel movements to/from the shore to service them. Eni Ghana has ‘declared’ exclusion zones of differing scales (and, also, duration) around facilities and certain vessels undertaking specified offshore activities. It has also deployed chase vessels and stationed FLOs offshore to warn fishermen of the dangers and persuade them to keep outside of the zones. Despite this concerted effort, the threat to fishermen remains significant as does the threat to offshore operations. The security implications are considered below in section 9.2.

9.2 Security

PS 4 requires consideration of issues relating to the provision of security personnel (whether provided by a company, its contractors or the state or a combination of one or more of these options). In particular, it requires a series of measures to be undertaken to ensure that

25 Document reference: SUST-PLAN-007



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interactions between security provision and local communities are managed to avoid or minimise adverse effects on communities.

The Community Health and Security Plan considers security issues and provides a ‘high-level’ list of issues and commitments for managing the interactions between security providers and local community members. The Plan cross-refers to the envisaged Security Management Plan.

The Eni Ghana Security Manager is employed in the HR department and security management practices comply with Eni corporate requirements. There is no Eni Ghana Security Management Plan aligned with Eni corporate policy and the Voluntary Principles on Security and Human Rights.

At present, the Security Manager is responsible for legacy security providers (security providers that were in place when Eni Ghana rented/occupied buildings to be used for offices and accommodation). This legacy issue applies, mainly, to assets in Accra. The Security Manager has limited control over these security providers and, in Q3, 2017 will initiate actions to increase the level of direct control over them. Currently, there are periodic inspections of security providers’ performance which is supported by specific training initiatives aimed at improving performance and aligning practices not only across all the providers, but also with Eni Ghana requirements/procedures.

For some assets, including the Takoradi logistics base and the ORF, Eni Ghana has outsourced security provision. There are no directly-hired guards except for locally-recruited guards at the ORF (these guards are more like ‘watchmen’ than security guards, but they have received training). For other assets, especially in the concession area, the contractors will be responsible for managing security issues. At the ORF site, De Simone Ltd contracted G4S to provide security and De Simone Ltd appointed a security focal point to liaise with the Security Manager. Technip, the construction contractor, which will be starting soon will appoint its own security provider. At present, the Security Manager does not know the identity of the provider or the Technip focal point. Currently, the Security Manager has limited involvement in the procurement process for contractors (for example, in setting minimum requirements for security provision).

Apart from the directly-hired guards at the ORF, all security providers are contractors. All security guards are unarmed, that is they do not carry firearms; however, some carry weapons, such as batons, that may only be used defensively.

Based on discussions with the Procurement Manager, Invitations to Tender for security providers currently set minimum requirements that must be met by tenderers - including implementation of a training plan for guards. To date, one potential provider was disqualified for not meeting the requirements.

Currently, the main security challenge is offshore due to continuing breaches of the exclusion zones by local craft, particularly those used by fishermen. Eni Ghana deploys chase boats to warn those entering into the exclusion zones and to convince them not to enter or to leave as soon as possible. An FLO is deployed on these vessels to assist attempts to persuade fishermen (and others) to respect the exclusion zones. The exclusion zones have been approved by the Ghana Maritime Authority and therefore can be enforced. To reinforce Eni Ghana’s ability to enforce the exclusion zones around all offshore assets, Eni Ghana is in the process of negotiating a MoU with the Ghanaian Navy. The MoU will include provision for navy personnel and/or boats and provision for training of navy personnel in the application the Voluntary Principles on Security and Human Rights.

A key offshore asset, the FPSO, will be operated/managed by Yinson. The Security Manager has provided Yinson with a ‘skeleton’ security plan. Yinson is expected to prepare a ‘full’ plan which will be sent for Eni Ghana approval.



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9.2.1 Security-related grievances

The Security Manager referred to a complaint made by a female member of staff following a sexist comment from a security guard; the complaint was promptly handled by the Security Manager.

The IESC notes that the 2016 AMR reports there were no grievances raised against security forces and no workers’ grievances recorded in 2016. It is unclear whether the incident occurred in 2016 or 2017, but if it was 2016 then the information provided in the AMR is inaccurate. Regardless of the timeframe, it is important that all staff are encouraged to use the workers’ grievance procedure, including for security incidents, and managers notified of such incidents maintain good records for subsequent inclusion in quarterly and annual monitoring reports.



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020 Security Management Plan

There is no Project Security Management Plan, consistent with ESHIA commitments, in place

Construction and Operation

PS 4 Prepare a Security Management Plan which is aligned with good international industry practice (including the Voluntary Principles on Security and Human Rights and other international requirements and guidance)

Moderate

021 Contractor Management - security

The extent of the involvement of the Security Manager in the procurement of contractors is limited

Construction and Operation

PS 4 Ensure that the Security Management Plan will contain minimum requirements to be met by contractors and that these requirements will be factored into procurement processes (and subsequent contractor management) with regards to security provision

Moderate



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10. PERFORMANCE STANDARD 5: LAND ACQUISITION AND INVOLUNTARY RESETTLEMENT

10.1 Introduction

The Project will occupy land, parts of the shore and inshore and offshore marine areas. Some of the land was used for agriculture/aquaculture and the shore, inshore and offshore areas are used for fishing. The land to be taken also includes some natural resources that support livelihoods. The Project, also, will restrict access to marine fishery resources for varying periods of times and at different locations. No physical displacement has/is expected to occur following a Project site selection process which prioritised the avoidance of physical displacement as one of its key site selection criteria (e.g. in 2015, Eni Ghana reduced the Project footprint in order to avoid physical displacement of the fishing village of Anwolakrom to the south east of the Project site and the design layout of the pipeline from the shore was modified, also, to avoid physical displacement). Therefore, only economic displacement has occurred/is expected to occur.

The Project is managing land- and fishery-related economic displacement in separate, but parallel procedures. Thus, this section presents findings for both land- and fisheries–focused economic displacement separately. These two sections are followed by a consideration of issues pertaining to a) sharecroppers and (landless) labourers; b) the temporary closure of an access route between Anwolakrom and Sanzule; and c) an ESAP item referring to the type of document required to manage potential future land acquisition.

10.2 Land - focused economic displacement

This section focuses on the concession area only and does not include the Takoradi logistics base. It is understood that PS 5 does not apply to the land, acquired for the logistics base, as it is subject to a 3-year renewable lease negotiated on a ‘willing buyer/willing seller’ basis in a context whereby Eni Ghana had no legal recourse to compulsory purchase. It is understood that any land which may be required for future expansion of the logistics base is likely to be acquired on a similar basis (probably from the same land owner).

Regarding the concession area; a Livelihoods Restoration Plan (LRP)26 for Phase 2 has been prepared (dated 26 January 2016: issued for Disclosure) and is being implemented over the period 2016-2020. It contains a Livelihoods Restoration (LR) Programme; to be put in place after cash compensation has been paid to the project-affected persons (PAPs)27. It is stated in the LRP, that,

“The first priority of the LR Programme is to provide early support that will commence as soon as access to land is lost or earlier if possible. The early support components will be provided to all 200 households28, incorporating: 1) transitional support in the form of food baskets and other provisions to ensure households are supported during the time it takes them to recover their livelihood and standard of living; and 2) financial management training for all households receiving cash compensation to ensure households have the tools and skills to manage the cash they have received sustainably.

Once priority early support is in place, livelihood restoration will focus on two additional elements: 1) land-based primary production activities including crop production, livestock keeping and aquaculture; and 2) non-land based value adding activities including training and processing.”

26 Document Reference: SUST-PLAN-001-00. 27 PAPs are defined as those person affected by land acquisition. 28 Upon request of the Sanzule chief, after transitional support for the 200 households began, all households received the ‘transitional support’; however, the period over which the affected households will receive this support is limited.



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The LRP presents an indicative implementation schedule summarizing the implementation of LRP actions, focusing on the LR Programme. An Annual Report on the implementation of the LRP, in 2016, has been prepared (dated 19 February 2017) which provides useful information on LRP implementation progress (Box 1 provides key dates).

Box 1: LRP Key dates: from LRP Implementation Schedule and LRP 2016 Annual Report (dated February 2107)

The indicative LRP implementation schedule includes the following key actions/dates:

Implement Transitional Support (01/03/16 to 31/12/17);

Implement financial management training (first session) (01/03 to 15/03/16) with subsequent session following in sequence;

Procure services of primary production, value adding and training implementation agencies (01/06 to 29/07/16);

Implement primary production livelihood options (25/10/16 t0 31/12/20); and

Implement value-adding and training livelihood options (01/11/16 t0 31/12/20).

To date, the sequence of key LRP milestones is:

The cut-off date for compensation valuation was March 2015;

The acquisition of land was completed on 2 April 2015 (Note: this is almost 8 months before the LRP was finalized [January 2016] and almost 5 months before the Rev00 version of the LRP);

The payment of compensation for lost assets (crops, structures, fish and animal farms) was completed in October 2015 (Note: this is almost 3 months before the date that the LRP was finalized);

Land take ‘cut off’ after which land could not be used by community members was 1 April 2016

The final list of livelihood restoration options (essentially the components of the Livelihood Restoration Programme) were presented in Sanzule community in November 2015;

LRP implementation started in February 2016, with the establishment of the Livelihood Restoration Steering Committee (LRSC). A Livelihood Restoration Working Group (LRWG) was also established and was inaugurated on 26 June 2016. The LRSC has a strategic focus; whereas the LWRG focuses on operational issues;

The first Transitional Support Food Aid distribution took place as a ‘testing’ in April 2016 and deliveries over the subsequent 2- 3 months were also considered to be ‘tests’ (2016 LRP Annual Report);

Full Transitional Support Food Aid started on 22 September, 201629 and is expected to cease for non-affected households in January 2017 (this latter date is mentioned in the WBG Environmental and Social Performance Annual Monitoring Report (AMR) for 2016 (dated 2017)); and

The contract for Financial Management Training (to be implemented in parallel with the Transitional Support Food Aid component) was awarded in December 2016.

The IESC was informed, verbally, that land occupiers/uses were able to continue farming/harvest crops in the period between receipt of compensation (October 2015) until shortly before early works stared in the concession area (March 2016). This meant that local people were able to sustain their livelihoods for the intervening period.

29 ‘Full’ Transitional Support Food Aid refers to 417 households and not to the original 200 households (the 200 are included in the 417 total)



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It is clear from the key LRP dates (see Box 1) that the LRP was not in place when land acquisition and compensation was undertaken and completed (the valuation process, consultations on compensation rates and payment of compensation, for built structures and most crops and trees using replacement cost, were all implemented in accordance with PS 5). However, precursors to the LRP had been prepared, at different times, and were applied as appropriate. The LRP presents an account of previous work whereby these documents were amended and/or updated to ensure that they complied, increasingly, with PS 5 over time leading up to the compliant LRP of 26 January 2016.

It is noted also, that land acquisition matters were managed by Eni Ghana HSE department until the SLC department was established on 21 July 2015. LRP preparation commenced in August 2015 - soon after the establishment of SLC department under the supervision of Eni HQ Sustainability Function and with the support of external consultants. In addition, Eni Ghana appointed a LRP Advisor from Eni HQ to the Accra office to assist finalizing the LRP and its subsequent implementation.

Ideally, livelihood restoration activities should begin as near as possible to completion of all cash compensation payment. Transitional Support Food Aid (plus supplementary related ‘benefits’) has been applied as the key measure to bridge the gap between receipt of cash compensation and full implementation of the ‘Support Services’ component30 of the LR Programme. There have been some delays, when compared to the LRP indicative schedule, in initiating the ‘Support Services’. Fortunately, the Transitional Support Food Aid is a flexible measure that can be extended to cover any delays. However, again, ideally, it is good practice to minimize any period of transitional support. With the imminent appointment of the LRP delivery partner to manage ‘on the ground’ LRP implementation; it may be expected that implementation will begin very soon. The delays are unfortunate, but evidence available indicates that there has been no significant issues raised by affected households regarding this aspect (however, as mentioned above in section 6.9 there have been a number of grievances raised concerning implementation of the Transitional Support Food Aid).

In parallel and, in part, a contributory factor to the delays, have been the difficulties in forming the planned LRP delivery team (both in Accra and in Project area) and the chieftaincy dispute. As mentioned in the 2016 LRP Annual Report, building the ‘Accra’ team faced recruitment difficulties while appointment of the LRP delivery partner, to implement the LRP, faced procurement challenges. While acknowledging the delays, the 2016 LRP Annual Report states that these difficulties have been overcome, to a great extent, and that mobilizing staff and external support is expected to be easier in the future. However, the existing difficulties posed by the chieftaincy dispute continue and may hinder future LRP implementation.

Care will be needed to manage the secondary ‘transition’ from Transitional Support Food Aid to reliance on the ‘Support Services’. A ‘hard’ transition with all Transitional Support Food Aid ceasing on a specific date to be followed immediately by initiation of the Support Services’ is likely to result in hardship because of the potential time lag between a sudden loss of livelihood support and the gradual build-up of livelihood contributions from the ‘Support Services’. An alternative ‘soft’ transition might involve a gradual phasing out of the Transitional Support Food Aid which attempts to reach a balance, over time, with the increase in livelihood contributions from the ‘Support Services’. It is understood the Eni Ghana is considering, with the appointed LRP delivery partner, a scheme for a phased transition. Whichever option for managing this ‘secondary’ transition is adopted; care will be needed to manage it successfully.

30 Essentially, ‘Support Services’ are the main elements of the LR Programme as follows: (1) land-based primary production activities

including crop production, livestock keeping and aquaculture; and 2) non-land based value-adding activities including training to be implemented upon completion of the transitional support (‘food aid basket’ plus financial management training).



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10.2.1 Sharecroppers and (landless) labourers

Although identified as potentially vulnerable groups in the ESHIA Report for Phase 2; sharecroppers and (landless) labourers31 are not identified, explicitly, in the LRP as being eligible for entitlements such as cash compensation for assets or loss of income. However, the LRP refers to shared tenancy farmers working under the “abusa” system (such farmers are sharecroppers) and these farmers are included in the ‘individual land users’ category and received compensation, as applicable. In contrast, (landless) labourers are mentioned as being potentially vulnerable and as being consulted during LRP preparation, but there is no further reference to them (they are not referred to as ‘landless labourers’; only as ‘labourers’). Since the Transitional Support Food Aid was extended to all households then these (landless) labourers are in receipt of an entitlement that will help maintain their livelihoods. Once Transitional Support Food Aid ceases then sharecroppers will be able to access the ‘Support Services’ according to the level of impact of the land acquisition on their livelihoods. However, the situation regarding the (landless) labourers and entitlements it is not clear. Additional work may need to be done to revisit the most recent census data to identify (landless) labourers that, perhaps, should be classed as PAPs with access to the appropriate entitlements.

10.2.2 Access Route

Work on the onshore pipeline will result in an access route between Anwolakrom and Sanzule being temporarily blocked. This might have livelihood implications, particularly for the inhabitants of Anwolakrom (being the smaller village and thus being dependent on the services that can be found in the bigger village of Sanzule). Eni Ghana is aware of the issue and is examining options to provide an alternative route.

10.2.3 ESAP item

ESAP item 10 includes the following statement, “….Eni Ghana will develop a Land Acquisition and Compensation Framework for any potential additional land acquisitions that may be required for the project or future expansions.” The LRP states that, in the event that additional land is required in the concession area, then an LRP Addendum will be prepared for each occasion when land needs to be acquired. There is no mention, in the LRP, of preparing a Land Acquisition and Compensation Framework and the IESC understands one doesn’t exist. However, it is understood that a document entitled ‘Land Acquisition’ (SUST-PRO-006), in the drafting phase) provides principles and guidance to ensure that land acquisition is undertaken in accordance with local law and international standards (specifically, PS 5). A judgement as to whether the ‘Land Acquisition’ (SUST-PRO-006) document may be considered to be the equivalent of Land Acquisition and Compensation Framework will be made once ‘Land Acquisition’ (SUST-PRO-006) is available for IESC review.

10.2.4 Observations

In reviewing the LRP and related documents, and following discussions with key Eni Ghana personnel, two observations are made:

Verbally, the IESC was informed that the land ‘owning’ families and individuals with differing rights to land have received compensation for the land (which is subject to a 30-year lease). Written confirmation of receipt of payment, by the land ‘owners’ and land users, for loss of land, should be included in the 2017 LRP Annual Report; and

There is no mention in the LRP of the land use restrictions that will apply to the onshore pipeline/s right-of-way (e. g. restrictions on erection of structures and types of trees that may be planted) and whether the restrictions will/will not affect land occupiers/users.

31 Verbally, the IESC was informed that there is no evidence to indicate the extent to which the labourers are/are not landless.



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10.3 Fisheries – focused economic displacement

Fisheries-focused economic displacement will occur for both nearshore (beach seine fishery) and offshore fishing from canoes and powered fishing boats. Eni Ghana has made a commitment not to increase the size of the offshore exclusion zones and to shorten some construction schedules to minimize periods of temporary economic displacement.

The fishery-focused economic displacement will be managed via a Fisheries Management Plan with a dedicated team of 5 FLOs. The FLOs are in place and working; however the Fisheries Management Plan is still in preparation. This Plan was preceded by the “Fisheries Management and Participatory Monitoring Programme Framework Strategy,”32 which was due to be submitted to WBG on 31 December 2016, but was one month late33. Construction work on the onshore pipeline, which is the Project activity that will affect the beach seine fishery, is due to begin in May, 2017 with the fencing of the beach (this will prevent access to the fenced area of beach).

The “Fisheries Management and Participatory Monitoring Programme Framework Strategy” states that the following work/actions need to be undertaken/completed to help prepare the Fisheries Management Plan:

Additional fish catch survey (to supplement the data acquired in an earlier fish catch survey);

Additional social baseline data collection/analysis (to supplement existing social baseline data); and

Fisheries compensation framework to be devised and agreed. This will involve:

o Engagement with fishers; and

o A decision on the need for a livelihood restoration ‘package’ to supplement any cash compensation mechanism that may be applied.

To complete the above work/actions and have a Fisheries Management Plan in place by the beginning of May is very challenging. Eni Ghana will need to mobilize and devote sufficient resources to ensure that the Fisheries Management Plan is in place by the end of April/early May.

10.4 Unplanned in-migration (influx)

An Influx Management Plan34 has been prepared with an effective date of 31 May 2016 (it is currently being revised). This Plan contains an extensive and ambitious set of local and macro-level mitigation actions. The range of mitigation actions is based on a realization that influx to the coastal area of the Western Region is already occurring and that Eni Ghana alone will have only a limited effect in trying to minimize it; but if it were to act in cooperation with other companies and local governments the chances of success will be considerably increased. Thus, as mentioned above (see section 6.7), Eni Ghana has initiated efforts, such as requesting WB to take a leading role in stablishing a multi-stakeholder group, to promote collaboration to implement the macro-level actions.

At present, there is a ‘two-speed’ Plan implementation:

Almost no movement at macro-level due to delays in establishing a collaborative multi-stakeholder forum with an agenda of co-ordinated macro-level actions; and

Focus mostly on local-level actions.

Eni Ghana needs to maintain the impetus behind its efforts to establish a collaborative multi-stakeholder forum while at the same time reviewing the outcomes of the local-level measures

32 Document reference: SUST-STRA-002-04 rev 04. 33 It is dated 30 January, 2107. 34 Document reference: SUST-PLAN-004



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that it has been applying and considering whether there are any changes that might be needed to enhance their effectiveness (for example, with respect to local labour recruitment).

See also Section 6.7, Cumulative Impacts.



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Table 8: Summary of Compliance Findings, PS5


022 Implementation of Support Services

There have been some delays in establishing the complete LRP delivery team (in Accra and in the concession area) and in implementing the LR Programme

Construction PS 5 Devote sufficient resources to contracting its on-site delivery partner as soon as possible and provide an enabling environment that will allow for the implementation of the Support Services component of the LR Programme to begin speedily thereafter

High

023 (Landless) Labourers

The LRP does not include (landless) labourers (recognized as potentially vulnerable in the Phase 2 ESHIA Report) in its categories of those people eligible for compensation/livelihood support activities (IESC recognizes that most, if not all, of them are receiving Transitional Support Food Aid, but this will cease soon for those people that are not included in the categories of eligible people)


PS 5 Consider undertaking additional work to revisit the most recent census data to identify any (landless) labourers that should be classed as PAPs. Appropriate measures should be taken in line with PS 5 should this ‘review’ identify (landless) labourers that are classed as PAPs

Moderate

024 Timing of finalization and approval of Fisheries Management Plan

Considerable work remains to be done to finalize/approve the Fisheries Management Plan so that its implementation can coincide with respect to the construction schedule of the onshore pipeline (May 2017). There is a risk that the Fisheries Management Plan will not be finalised and implemented in time

Construction PS 5 Devote all necessary technical and financial resources, to ensure that Fisheries Management Plan is finalized/approved prior to commencement of the onshore pipeline works

High

025 Access Route Temporary Closure

Access route between Anwolakrom and Sanzule will be temporarily closed and this might have livelihood implications

Construction PS 5 Evaluate implications of the alternative options and select the preferred option. The preferred option to be in place before the existing route is closed. Local community

Moderate



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views should be factored into the evaluation of the options

026 Land Acquisition and Compensation Framework

ESAP item 10 requires preparation of a Land Acquisition and Compensation Framework


PS 5 Prepare a Land Acquisition and Compensation Framework. This can be done in near future or when a decision is made, in principle, that additional land is required for the Project. The Land Acquisition and Compensation Framework must be in place before a Resettlement Action Plan (physical displacement only or physical displacement and economic displacement) or a Livelihood Restoration Plan is prepared for a particular act of land acquisition

Minor

027 Influx Management

The potential effectiveness of the Influx Management Plan is threatened by the lack of progress in establishing a collaborative multi-stakeholder forum for managing influx (this is not the fault of Eni Ghana; rather the results of the practical institutional and political challenges of setting up such a forum from a range of disparate private sector and local government parties)


N/A Maintain its support to WB efforts to establish a collaborative multi-stakeholder forum while at the same time reviewing the outcomes of the local-level measures that it has been applying and considering whether there are any changes that might be needed to enhance their effectiveness (for example, local labour recruitment)

Moderate



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11. PERFORMANCE STANDARD 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES

11.1 Introduction

This section highlights the plans and procedure developed to manage impacts to biodiversity and provides evidence of implementation.

The Project has developed a Biodiversity Management Plan (BMP) dated September 2016 which are supported by a number of complementary plans relating to:

Protection of birds (an Avian Biodiversity Action Plan)

Sea Turtles (a Sea Turtle Biodiversity Action Plan)

Flora Conservation

Invasive Species

Bush Meat

Top Soil management

The Project also commissioned a Critical Habitat Assessment which concluded there is there are critical habitat triggers for Sanderling (Calidris alba) and the Royal Tern (Thalasseus maximus) which inhabit the beach. There is also critical habitat to the north of the Project area in the form of Black Water Swamp Forest.

11.2 Invasive Species

The control of invasive species is outlined in the work instruction entitled ‘Prevention and Control of Invasive Species’ dated 15th August 2016 and applies to onshore activities. Many of the measures required to prevent presence of invasive species must be undertaken by the Early Works Contractor, De Simone Ltd. During a meeting with De Simone Ltd the IESC was provided with evidence of completed checklists/vehicle cleaning. We do however note that the work instruction was prepared several months after the start of early works site clearance/movement of vehicles. Environmental monitoring due to commence in the near future should provide confirmation that invasive species are not present in disturbed areas.

11.3 Bush Meat

The Project prepared a Bushmeat Action Plan in August 2016 intended to inform and manage worker behaviour. The IESC was provided evidence of completed bush meat checklists from De Simone Ltd post issuance of the Bushmeat Plan.

11.4 Flora Conservation Plan

A key objective of this plan was to identify species of particular interest, typically those classified as rare at either the Ghanaian or international level, and establish procedures for conservation of such species. A pre-construction survey was undertaken by local botanists with support from international experts; species of interest were mapped.

The survey identified numerous protected plants within the boundary of the main ORF pad and the ORF temporary construction facility pad. According to Annex B of the plan (figure B-01), some of the plants identified required physical translocation. During subsequent discussion about the translocation process it became apparent that design changes, including the 90 degree rotation of the ORF pad had removed to need to translocate plants.



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Whereas the IESC recognises the benefits to biodiversity associated with the reorientation of the ORF pad and movement of the ORF TCF pad, it is unclear whether the original area surveyed included the area to the north of the original ORF pad location that is now affected by the reorientation i.e. whether the original survey covered the new ORF locations/whether further survey effort was required.

It is recommended that the Flora Conservation Plan is reviewed/amended on the basis of the design change, including consideration of any changes made to the pipeline routes. Translocation requirements for plants identified in close proximity to the pipeline right of way should also be confirmed given clearance if the pipeline route was planned to occur shortly after the IESC’s monitoring visit.

11.5 Biodiversity Action Plans (BAP)

The Avian and Turtle BAP will be implemented by specialist contractors. See comments relating to time critical actions specified in the BAPs in Section 8.11 of this report.

11.6 Biodiversity monitoring

See Section 8.11, Environmental Management and Monitoring

11.7 Other requirements for the protection of biodiversity

11.7.1 Helicopters flights

Line 13 of the ESAP specifies that Eni Ghana will ensure that support helicopters will routinely avoid flying over the sensitive areas of Amansuri wetland and that, if avoidance is not feasible due to weather conditions, a minimum altitude will be specified, according to international good practice, when flying over this area to minimize disturbance to wildlife.

During the monitoring visit Eni Ghana confirmed that no helicopters would routinely fly over the Amansuri wetland because they are routinely flying from Takoradi. It was further explained that the helicopter landing pad at the ORF was for use only in a medical emergency35 36.

35 Letter dated 14th July 2015 to the Civil Aviation Authority confirmed intended use for medical emergencies 36 Email to IFC dated 10th May 2015 showing flight paths avoiding the Amansuri wetlands.



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028 Implementation of plans

The Contractor is required to abide by the requirements specified in various plans developed to protect biodiversity, for example, the Bushmeat and Invasive Species plans. Whereas the Early Works contractor is now implementing the measures specified in these plans, this would not have been the case prior to finalisation and dissemination of the plans.

Construction PS6 None (noting future environmental monitoring includes survey for invasive species in Project disturbed areas)

Potentially Minor

(on the basis monitoring will be undertaken)

029 Flora Conservation Plan

The plan includes survey results performed for the original ORF orientation. Consequently there is a risk that rotation of the ORF affects rare plants not identified by the plant survey. It is unclear whether there was a need for additional survey work – the possible need for additional survey effort was not considered during the Management of Change process.

Construction PS6 The Flora Conservation Plan (and other relevant plans as necessary) should be updated to reflect the reorientation of the ORF facilities. Eni Ghana should confirm that the geographical coverage of the original survey was sufficient for the new ORF orientation/confirm additional survey effort was undertaken as appropriate.

Moderate

NA Biodiversity Monitoring

See row 019 See row 019 High


UK14_24203_ Final report

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12. PERFORMANCE STANDARD 8: CULTURAL HERITAGE

12.1 Introduction

The Environmental and Social Review Summary (ESRS), 15 September 2015 states that PS 8 is not applicable because, “The project is not expected to affect any known cultural heritage features….” Mention is made of a change in concession area boundaries to avoid a cemetery, used by royal families, located in the vicinity of the onshore pipeline right-of-way. Nevertheless, it is stated, in the ESRS, that a Cultural Heritage Management Plan (CHMP), containing a Chance Finds Procedure, will be prepared to ensure that the cemetery is not affected and to address the issue of managing any cultural heritage finds that may occur during construction and operations.

12.2 Cultural heritage management planning

A CHMP has been prepared with an effective date of 04 July 201637, and contains a Chance Finds Procedure. As reported in the WBG 2016 AMR, the CHMP was cascaded to the early works contractor with emphasis on the Chance Finds Procedure. The AMR reports that no chance find/archaeological object was reported as being found during the early works construction phase (that is, up to the end of 2016). No chance find/archaeological object was reported to the IESC during the February 2016 site visit. The CHMP will be updated by end June 2017.

The CHMP mentions the existence of a number of shrines (location of deities), in/near the local communities. The locations of these shrines are known, following pre-construction surveys, and measures to protect them or to allow for the relocation of deities are known and, in the case of relocation, agreed with the traditional political and religious authorities. The locations of all shrine are listed as an Annex to the CHMP; however but the CHMP was not disclosed. It is confirmed that, based upon current knowledge, there are no items of cultural heritage that are threatened by the Project.

Early works (De Simone Ltd) began in late Q1 (March) and the CHMP’s effective date was 4 July 2016. This means that there was no CHMP in place during the early months of De Simone’s activities. Although the CHMP was not in place; cultural heritage issues were presented to the construction teams, as part of wider ‘sustainability’ awareness-raising event held in Sanzule on 14 May 2016. Also, in March 2016, all pacification rituals were conducted, in accordance with the requirements later to be specified in approved CHMP, to ensure that the deities moved to new location with no risk to the local communities.

As there are no findings to report, there is no ‘summary of findings’ table inserted here.

37 Document reference: SUST-PLAN-005



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SUMMARY The Project has robust management system for HSE and S matters that is implemented by a well-resourced, integrated and competent HSE and Sustainability teams. The IESC finds the Project is generally compliant with the ESAP with the exception of three minor observations discussed in the report and highlighted in Annex 1 below. In addition, a total of 29 issues have been identified that represent opportunities for improvement, including:

High significance issues

The appointment of the environmental monitoring contractors several months after the start of construction works has resulted in missed opportunities for monitoring and a real data gap which in some cases is a risk for the Project. Consequently there is an urgent need to appoint specialist monitoring contractors, refine the Environmental Monitoring Plan and start the comprehensive monitoring set forth in the plan at the earliest opportunity;

There have been some delays in establishing the completed Livelihood Restoration Plan delivery team (in Accra and in the concession area) and in implementing the Livelihood Restoration Programme. Eni Ghana must devote sufficient resources to contracting its on-site delivery partner as soon as possible and provide an enabling environment that will allow for the implementation of the Support Services component of the Livelihood Restoration Programme to begin speedily thereafter; and

Considerable work remains to be done to finalize/approve the Fisheries Management Plan so that its implementation can coincide with the construction schedule of the beach crossing/nearshore section of the gas pipeline (May 2017). There is a risk that the Fisheries Management Plan will not be finalised and implemented in time. Eni Ghana must devote all necessary technical and financial resources, to ensure that Fisheries Management Plan is finalized/approved prior to commencement of the beach crossing/nearshore pipeline works;

Moderate significance issues

Contract appendices (for Contractors) should include the requirements of management plans developed over the course of 2016 and stipulate alignment with: the Voluntary Principles on Security and Human Rights; and the Workers’ Accommodation: Processes and Standards guidance note co-authored by the IFC;

Weaknesses in contractor management and monitoring (with respect to the Early Works Contractor) have emerged regarding local recruitment, transfer of workers from one contractor to another and in terms of grievance management;

Discontinuity in Terms and Conditions in Contractors’ Employment Contracts and a lack of understanding among some local people that terms and conditions can vary emphasises the need to hire a Labour Relations Officer;

A mini bus used to transport the lender group did not have seat belts for the fold down seats.

The Waste Management Plan lacks specificity and has a number of inaccuracies relative to actual Project practices. Options for the anticipated disposal of NORM should be identified before NORM is generated;

There is not an adequate Project Security Management Plan in place;

The extent of the involvement of the Security Manager in the procurement of contractors is insufficient;

The LRP does not include sharecroppers and landless labourers as eligible for compensation/livelihood support activities. It is recognized that sharecroppers were eligible for compensation (which they received) as they were included in the category of ‘individual land users’.



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Access route between Anwolakrom and Sanzule will be temporarily closed and this might have livelihood implications – the implications of this closure need to be considered and managed.

The potential effectiveness of the Influx Management Plan is threatened by the lack of progress in establishing a collaborative multi-stakeholder forum for managing influx.

The Flora Conservation Plan should be updated to reflect the revised positioning of the ORF. It is unclear whether there was a need for additional survey work – the potential need for additional survey work was not considered during the Management of Change process.

Suggested corrective actions are provided within the report, but these are not prescriptive: instead the Project should define appropriate corrective actions and report on the implementation of such actions via periodic monitoring reports submitted to the WBG.



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APPENDIX 1. PROJECT ESAP WITH IESC COMMENTS

ESAP status 13 December 2016

Task Indicator of Completion Timeframe 1 Eni Ghana with support from Vitol will develop a construction/ development

phase Environmental, Social, Health Management Plan (ESHMP) and the relevant management plans and programs in advance of development drilling and construction, followed by a production/operations ESHMP which will be developed before first oil, with gas-related elements integrated as needed before first gas. The ESHMP will be updated as required, such as in the event of any significant changes to the project and its environmental and social risks and impacts occur, following a Management of Change process. The ESHMP will include social management plans and procedures to meet the objectives of the Performance Standards, and those plans and procedures will be incorporated into an integrated Environmental and Social (E&S) Management System for the OCTP project.

Plans and procedures submitted to WBG: a) Development drilling and construction phase: ESHMP, Procurement Plan, Grievance Mechanism, Waste Management Plan, Security Management (Offshore) Strategy by November 15, 2015 b) Recruitment, Employment and Training Plan, Local Content Development Plan, Workers Development Plan, Marine Traffic Management Strategy, Commitment Register by end of November 2015 c) Development drilling and construction phase: all management plans (others than the plans specified in the action items below) approved by end of December 2016 d) Phase-1 commissioning and production operations: by end of August 2017 or one month prior to commissioning / production operations whichever comes first e) Phase-2 commissioning and production operations: by end of July 2018 or one month prior to commissioning / production operations whichever comes first.

a) 11/15/2015 – Complete (with understanding that current procurement plan is linked to the ESHMP as per ESHIA commitment) b) 11/30/2015 - Complete c) 12/31/2016 d) 08/31/2017 or one month prior to commissioning / production operations whichever comes first e) 07/31/2018 or one month prior to commissioning / production operations whichever comes first

2 Eni Ghana will require that contractors adopt measures and bridging documents to ensure that their management systems are compatible with HSE Policy, guidelines and procedures and the project ESHMP.

Evidences (i.e., approved bridging documents) collected and submitted to WBG.

12/31/2015 – Complete and ongoing

3 Eni Ghana will implement well integrity and control strategies and develop specific Well Control Emergency Response Plans for each well drilled. All drilling programs will be approved by Eni headquarters (that will act as independent, expert third party in charge of verification/review).

a) WCEMP applicable to the first three wells drilled approved by Eni headquarters and submitted to WBG by September 2015, and evidences of implementation of the third party verification/review of the drilling programs by October 15, 2015 b) Auditable evidences of implementation provided to WBG in the Annual Monitoring Report.

a) 10/15/2015 - Complete b) 12/31/2017

4 Eni Ghana will develop the specific E&S monitoring plans. A number of pre-construction surveys will be implemented, including: (i) preconstruction fish catch surveys at Sanzule and in the project area of influence, with specific focus

a) Terms of reference of the time sensitive surveys (birds and sea turtles) submitted to WBG by end of October 2015

a) 10/31/2015 - Complete



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Task Indicator of Completion Timeframe on beach seine fishing activities; (ii) phyto- and zooplankton surveys (near the same time as the catch surveys and focusing on fishing grounds); (iii) ambient air quality and noise monitoring in the area of influence of the ORF; (iv) preconstruction survey of sensitive avian species that may be present, particularly during the boreal winter.

b) Pre-construction surveys and monitoring plans submitted to WBG. b) 06/30/2016 - Complete

5 Eni Ghana will report on their best efforts to engage other developers, local institutions and government, and other stakeholders in designing coherent management strategies to mitigate cumulative impacts.

a) Cumulative impact mitigation strategy submitted to WBG b) Evidences of implementation provided to WBG as part of the Annual Monitoring Report (emphasis added by IESC)

a) 11/30/2015 - Complete b) 12/31/2016

IESC Comment: Evidences were not provided in the 2016 AMR reviewed by the IESC during the Feb 2017 monitoring visit. Refer to Section 6.7 of this report

6 Eni Ghana will update and refine the air emission dispersion and noise propagation modeling during production facility final design to inform the identification and development of a package of air emission reduction measures.

Modeling updated and submitted to WBG during production facility final design and by anticipated completion date.

06/30/2017

7 Eni Ghana will develop and enforce a policy and relevant procedures to ensure that operations of drillship, support vessels and helicopters minimize disturbance to marine mammals and turtles.

Policy and procedures submitted to WBG. 12/31/2015 - Complete

8 Eni Ghana will maintain a quantification program for GHG emissions, according to an internationally recognized emissions estimation methodology, and will establish annual review programs to identify areas of improvement and GHG emission reduction. Eni Ghana has committed to implement a Zero-Permanent Flaring policy, and will implement measures for minimization of venting and flaring (consistent with the Global Gas Flaring and Venting Reduction Voluntary Standard) and minimization of fugitive emissions.

a) Quantification and minimization program for GHG emissions submitted to WBG b) First annual report by anticipated completion date.

a) 06/30/2017 b) 12/31/2017

9 Eni Ghana will include an environmental lead as part of the oil spill response team and will develop a clear mechanism of escalation of response effort based on coastal and biodiversity sensitivity. Mutual aid agreements with other operators in Ghana will be established.

Evidences of implementation (i.e., approved revised OSCP) submitted to WBG.

12/31/2015 - Complete

10 Eni Ghana with the support of Vitol will develop and implement a Livelihood Restoration Plan (LRP) for affected people in the community of Sanzule. Once all mitigation measures have been substantially completed and displaced persons are deemed to have been provided adequate opportunity and assistance to sustainably restore their livelihoods, Eni Ghana will undertake a completion audit comparing outcomes against objectives of the plan and current living conditions against living conditions prior to the start of the project. Eni Ghana will develop a Land Acquisition and Compensation Framework for any potential additional land acquisitions that may be required for the project or future expansions. (emphasis added by IESC)

a) LRP workshop held b) Draft final LRP submitted to WBG c) Final LRP submitted to WBG d) Evidences of implementation included in the periodic E&S progress reports and Annual Monitoring Report e) Interim Implementation Audit

a) 10/31/2015 - Complete b) 11/30/2015 - Complete c) 12/31/2015 or six weeks prior to construction early works whichever comes first - Complete d) Based on LRP e) 01/31/2018



58

Task Indicator of Completion Timeframe f) Completion Implementation audit

f) 01/31/2020

IESC Comment: The LRP acknowledges the potential for future land take but does not refer to the development of a Land Acquisition and Compensation Framework. Refer to Section 10.2.3 of this report 11 Eni Ghana with the support of Vitol will develop a Fisheries Management Plan

(FMP) to ensure fishermen are compensated appropriately and assistance for improving or at least restoring their living conditions is provided. The FMP will be monitored throughout its implementation to its completion. A participatory monitoring program will be developed with the involvement of local fishermen. The plan will also include a compensation framework in line with PS 5 in case fishers are adversely impacted by an oil spill.

a) FMP strategy submitted to WBG. (emphasis added by IESC) b) FMP submitted to WBG. c) Evidences of implementation of the FMP and participatory monitoring program included in the Annual Monitoring Report.

a) 12/31/2016 b) 04/30/2017 or 2 months prior to construction sea pipeline whichever comes first c) 12/31/2017

IESC Comment: The FMP Strategy was provided to Lenders in February 2107. Refer to Section 10.3 of this report 12 Eni Ghana with the support of Vitol will develop a Biodiversity Management

Plan (BMP and relevant Biodiversity Action Plans) and will implement it, in collaboration with recognized species specialists. Seasonal constraints, associated with peak turtle nesting season between October and February and with dwelling season of the IBA triggering species, will be incorporated in the construction and operation management plans.

a) BMP submitted to WBG, including identification of opportunities to enhance conservation of priority bird species (including specific focus on the hood vulture) and/or habitat in the project area b) BAPs for sea turtles and for birds submitted to WBG c) Evidences of implementation of the BMP / BAPs included in the Annual Monitoring Report.

a) 07/31/2016 - Complete b) 11/30/2016 - Complete c) 12/31/2017

13 Eni Ghana will ensure that support helicopters will routinely avoid flying over the sensitive areas of Amansuri wetland and that, if avoidance is not feasible due to weather conditions, a minimum altitude will be specified, according to international good practice, when flying over this area to minimize disturbance to wildlife.

Evidences of avoidance (i.e., helicopter flight plans and relevant language on flights associated with emergency/oil spill response drills in the revised BMP - see Action Item 12) provided to WBG.

05/31/2016 - Complete

14 Eni Ghana and Vitol Ghana, as partner of the OCTP project, will develop and implement a community investment strategy for the area of influence of the project by identifying areas of potential social investment based on community assets and needs. The community investment strategy will be developed in consultation with local and regional stakeholders.

a) Community investment strategy submitted to WBG b) Final Community Investment Strategy submitted to WBG b) Updates and evidences of implementation of the strategy included in the Monthly E&S Reports and Annual Monitoring Report.

a) 12/31/2015 - Complete b) 04/30/2017 c) 05/31/2017

15 Eni Ghana and Vitol Ghana, as partner of the OCTP project, will hire an independent E&S consultant (IESC) to monitor and report on implementation of this E&S Action Plan and compliance with Performance Standards and E&S commitments. The monitoring visits will be carried out biannually (every six months) during development drilling and annually during production operations. The reports of the IESC will be published.

a) IESC's Terms of Reference submitted and approved by the WBG, and IESC hired b) First monitoring visit and report submitted.

a) 12/31/2016 b) 03/31/2017

16 Vitol Ghana will assign an E&S assurance manager to the OCTP project to oversee environmental, health, safety and social aspects, ensuring compliance

E&S assurance manager appointed.

10/31/2015 - Complete



59

Task Indicator of Completion Timeframe with Performance Standards and project E&S commitments.

17 Vitol Ghana will develop and adopt a Human Resource Policy. Human Resource Policy submitted to WBG.

12/31/2015 - Complete

18 Vitol Ghana will update its security policy to be aligned with the Voluntary Principles on Security and Human Rights.

Policy submitted to WBG. 12/31/2015 - Complete



60

APPENDIX 2. PROJECT DOCUMENTATION PROVIDED FOR REVIEW

Ref no. Document Title Organisation

1 Biodiversity Management Plan, September 2016, rev.00, plan ms hse 019 Eni Ghana

Eni Ghana

2 Biodiversity Management Plan: Avian Biodiversity Action Plan – Appendix A, September 2016, rev.00, pln ms hse 019 Eni Ghana

Eni Ghana

3 Biodiversity Management Plan: Critical Habitats Screening and Assessment – Appendix D, August 2016, rev.00, pln ms hse 019 Eni Ghana

Eni Ghana

4 Biodiversity Management Plan: Desktop Analysis of Wetlands Habitats – Appendix G, August 2016, rev.00, plan ms hse 019 Eni Ghana

Eni Ghana

5 Biodiversity Management Plan: Flora Conservation Plan – Appendix E, August 2016, rev.00, plan ms hse 019 Eni Ghana

Eni Ghana

6 Biodiversity Management Plan: No Net Loss Strategy for Natural Wetlands – Appendix F, September 2016, rev.00, plan ms hse 019 Eni Ghana

Eni Ghana

7 Biodiversity Management Plan: Sea Turtles Biodiversity Action Plan – Appendix B, August 2016, rev.00, plan ms hse 019 Eni Ghana

Eni Ghana

8 Blowout Emergency Response Plan for the OCTP – Sankofa Field, September, 2015, FR/OPE/2015/09/1172

Eni Ghana

9 Bushmeat Action Plan, August 2016, rev.01, plan ms hse 015 Eni ghana

Eni Ghana

10 Code of Conduct: Health, Safety, Environmental And Social (HSES) Management System, December 2015

VUGL

11 Community Health Management Plan, May 2016, rev.00, SUST-PLAN-007

Eni Ghana

12 Cultural Heritage Management Plan, July 2016, rev.01, SUST-PLAN-005

Eni Ghana

13 Cumulative Impacts Mitigation Strategy, August 2016, rev.00, plan ms hse 006 Eni Ghana

Eni Ghana

14 Drilling Oil Spill Contingency Plan – OCTP block, March 2013, rev.02, HSE-PLAN-003

Eni Ghana

15 Emergency Response Plan, January 2017, rev.10, pln ms hse 002 Eni ghana

Eni Ghana

16 Environmental and Social Performance Annual Monitoring Report (AMR), January 2017

WBG

17 Environmental and Social Performance Quarterly Monitoring Report (QMR), January 2017

WBG

18 Environmental Monitoring Program, January 2017, rev.01, pln ms hse 018 Eni Ghana

Eni Ghana

19 Environmental, Social and Health Management Plan - Construction and

Eni Ghana



61


Development Drilling Phase, May 2016, rev.00, plan ms hse 009 Eni Ghana

20 Environmental and Social (E&S) Review Summary, December 2016

IFC

21 ESAP Status, December 2016 WBG/VUGL and Eni Ghana

22 Final Environmental and Social Impact Assessment, OCTP Block, Phase 1, June 2015, 000415_DV_CD.HSE.0208.000_00 and Final Environmental Impact Statement, Ghana Offshore Cape Three Points Oil Block Development, Phase 2, July 2015, 000415_DV_CD.HSE.0304.000_01

ESL Consulting ERM, ESL Consulting, and SRC Consulting

23 Fisheries Management and Participatory Monitoring Programme Framework Strategy, January 2017, rev.04, SUST-STRA-002-04 Eni Ghana

Eni Ghana

24 Fisheries Management and Participatory Monitoring Programme Framework Strategy, January 2017, rev.04, SUST-STRA-002-04 Eni Ghana

Eni Ghana

25 Grievance Mechanism, May 2016, rev.01, SUST-PRO-007-01 Eni Ghana

26 HSE Bridging Document (HSE-BD) between Maersk RigWorld Ghana Limited and Eni Ghana Expolration and Production for the Maersk Voyager MODU, June 2015, rev.00

Eni Ghana

27 Human Resources Corporate Standard: Health, Safety, Environmental And Social (HSES) Management System, December 2015

Vitol

28 Human Resources Plan: Health, Safety, Environmental And Social (HSES) Management System, July 2016

Vitol

29 Hydrotest Water Disposal Management Plan, January 2017, rev.00, plan ms hse 012 Eni Ghana

Eni Ghana

30 Impl.Schedule_Comm Registers SMPs_Community Health Plan, rev.00

ERM

31 Impl.Schedule_Comm Registers SMPs_Cultural Heritage Plan, rev.01

ERM

32 Impl.Schedule_Comm Registers SMPs_HSE,rev.00 ERM

33 Impl.Schedule_Comm Registers SMPs_Influx Management Plan, rev.00

ERM

34 Impl.Schedule_Comm Registers SMPs_Local Content Plan, rev.00

ERM

35 Impl.Schedule_Comm Registers SMPs_Workers Management Plan, rev.00

ERM

36 Incident Notification, Investigation and Reporting Accidental Event Investigation Form – Appendix E, February 2017, rev.03, pro ms hse 005 Eni ghana

Eni Ghana



62


37 Independent Lenders’ Report: Environmental and Social Review, September 2016, rev.D, 201999

KBC Process Technology Ltd

38 Influx Management Plan, May 2016, rev.00, SUST-PLAN-004 Eni Ghana

39 Quarterly Monitoring Report, 4Q 2016_Final Eni Ghana

40 Intentionally blank

41 Livelihoods Restoration Plan for the Ghana OCTP Block Phase 2, January 2016, rev.06, SUST-Plan-001.00

ERM

42 Local Content Development Plan – Annex A, May 2016, rev.00, SUST-PLAN-002

Eni Ghana

43 Local Content Development Plan, May 2016, rev.00, SUST-PLAN-002

Eni Ghana

44 Maersk Voyager MedEvac Flowchart, SNKE-C – Annex J Maersk

45 Marine Mammals & Sea Turtles Protection Policy Plan – Appendix A, May 2016, rev.00, plan ms hse 014 Eni Ghana

Eni Ghana

46 Marine Mammals and Sea Turtles protection Policy and Plan, May 2016, rev.00, plan ms hse 014 Eni Ghana

Eni Ghana

47 Marine Traffic Management Plan, May 2016, rev.00, plan ms hse 013 Eni Ghana

Eni Ghana

48 Medical Emergency Response Plan, November 2016, rev.00, HR-PLN-001.00 (cancels and replaces pln ms hse 008 Eni Ghana r02)

Eni Ghana

49 Medical Emergency Response Plan: Company Emergency Telephone Numbers – Annex C

Eni Ghana

50 Medical Emergency Response Plan: Event Log Sheet – Annex H Eni Ghana

51 Medical Emergency Response Plan: External Emergency Contact Details – Annex D

Eni Ghana

52 Medical Emergency Response Plan: Health and MEDEVAC Providers – Annex A, HR-PLN-001.00

Eni Ghana

53 Medical Emergency Response Plan: Medical Emergency Communication Flowchart – Annex B, HR-PLN-001.00

Eni Ghana

54 Medical Emergency Response Plan: MERP for EGH Personnel Working in the Engineering and Constructing Yards Overseas – Annex K

Eni Ghana

55 Medical Emergency Response Plan: MERP for EGH Personnel Working in Sanzule – Annex L

Eni Ghana

56 Medical Emergency Response Plan: MERP for EGH Personnel Working OFFSHORE and relative Flowcharts – Annex J

Eni Ghana

57 Medical Emergency Response Plan: Patient Condition Evaluation Form – Annex F

Eni Ghana

58 Medical Emergency Response Plan: Patient Information & MedEvac Form – Annex E

Eni Ghana

59 Medical Emergency Response Plan: Radio Communication Alphabets and Pro-words – Annex G

Eni Ghana



63


60 Medical Emergency Response Plan: Revised Trauma Score - Annex F

Eni Ghana

61 Medical Evacuation Response Plan (MERP) – Annex J, June 2016, rev.1.5

Maersk Drilling A/S/ International SOS

62 Medical Evacuation Response Summary, DOF Subsea AS / Skandi Skansen – Annex J, June 2016, rev1.5

International SOS/ DOF Subsea

63 Medical Evacuation Response Summary, DOF Subsea AS / Skandi Skansen – Annex J, November 2016, rev1.5

International SOS/ DOF Subsea

64 Non-Technical Summary (NTS) Offshore Cape Three Points (OCTP) Phase 1 Development, June 2015, 0272709

ERM

65 Offshore Hazardous Material Management Plan, May 216, rev.00, plan ms hse 011 Eni Ghana

Eni Ghana

66 Onshore Pollution Prevention and Control Management Plan, May 2016, rev.00, pln ms hse 010 Eni Ghana

Eni Ghana

67 Organisational Chart: Safety, Environmental and Quality, January 2017

Eni Ghana

68 Organisational Chart: Sustainability & Local Content, November 2016

Eni Ghana

69 Permit: 1.2.11.3 OCTP_Drilling Permit-3GI+6OP+1GP+3WIs, 8 June 2015 - 15 December 2016

EPA

70 Permit: Additional Soil, 19 January 2016 – 18 July 2017 EPA

71 Permit: Additional Soil, 27 November 2015 – 31 December 2016

Minerals Commission

72 Permit: Approval Notice for OCTP onshore receiving facilities and Sanzule, June 2015

Ellembelle District Assembly

73 Permit: Construction Permit of an onshore receiving facility at Sanuzule, 11 February 2016 – 10 August 2018

Petroleum Commission

74 Permit: GE Oil and Gas, 4 January 2017 Petroleum Commission

75 Permit: Geological Survey Consent, 26 January 2015 Geological Survey Department

76 Permit: helipad Construction, 19 October 2015 Ghana Civil Aviation Authority

77 Permit: Land Commission Consent, 3 June 2014 Western Regional Lands Commission

78 Permit: OCTP Phase 1 Development, 9 July 2015 – 31 January 2017

EPA



64


79 Permit: OCTP_Comp+Interconnect Construction Permit _EC_24 AUG 2015 - 23 AUG 2017

Energy Commission

80 Permit: OCTP_Drilling Permit-1GI+2OP+2GPs, 27 May 2016 - 15 April 2017

EPA

81 Permit: OCTP_Ph2 Onshore Construction Permit, 24 July 2015 - 28 February 2017

EPA

82 Permit: offshore Pipe Laying Permit, 15 November 2016 Ghana Maritime Authority

83 Permit: PC Permit Letter, 24 January 2017 Petroleum Commission

84 Permit: Siting and Clearance Permit, 13 May 2015 – 17 November 2017

Energy Commission

85 Permit: Siting Permit, 22 May 2015 Petroleum Commission

86 Permit: Water Use Permit, 1 November 2015 – 31 October 2018 Water Resources Commission

87 Permit: Wells Permit, 16 November 2016 Ghana Maritime Authority

88 Prevention and Control of Alien Invasive Species, August 2016, rev.01, opi ms hse 025 Eni ghana

Eni Ghana

89 Recruitment Employment and Training Plan, May 2016, rev.00, SUST-PLAN-001

Eni Ghana

90 Reinstatement and Revegetation Standard, August 2016, rev.01, std ms hse 004 Eni Ghana

Eni Ghana

91 Topsoil Management, August 2016, rev.01, opi ms hse 026 Eni ghana r01

Eni Ghana

92 Traffic Management Plan, August 2016, rev.00, plan ms hse 016 Eni Ghana

Eni Ghana

93 Vessel Emergency Preparedness Chart Outside safety Zone – Annex J, October 2016, 1000099-HS-CL-1070-010-0002

Skansken/ DOF Subsea

94 Vitol Exploration and Production Ethics Policy, April 2016 Vitol

95 Vitol Exploration and Production Limited Human Resources Policy, April 2016

Vitol

96 Water Management Plan, January 2017, rev.08, pln ms hse 005, (cancels and replaces plan ms hse 017 Eni Ghana)

Eni Ghana

97 Well 01 GI-1 P&A Program_Headquarter Approval: OCTP Licence for the Temporary Abandonment Program Checklist (MSG Certification), August 2015

Eni Ghana

98 Well 02 Sankofa-D Drl Program_Headquarter Approval: Well Sankofa-D Drilling Program Checklist (MSG Certification), August 2015

Eni Ghana



65


99 Well 03 Ghana_Well OP-CAMP-1_Headquarter Approval: Well OP-CAMP-1 Drilling Program Checklist (MSG Certification), September 2015

Eni Ghana

100 Well GI-2 Drilling Program Checklist (MSG Certification), October 2015

Eni Ghana

101 Well OP-5 Drilling Program Checklist (MSG Certification), November 2015

Eni Ghana

102 Well OP-7 Drilling Program Checklist (MSG Certification), January 2016

Eni Ghana

103 Well OP-CAMP-1 Drilling Program Checklist (MSG Certification), September 2015

Eni Ghana

104 Workers Management Plan, May 2016, rev.00, SUST-PLAN-003 Eni Ghana

105 Yinson Production Emergency Notification Chart – Annex J Yinson

106 Zoning Report, April 2015 Town and Country Planning Department

107 HSE Management of Change Procedure (HSE-PRO-017.00) Eni Ghana



66

APPENDIX 3. AUDIT ITINERARY

Objectives:

1. Gain detailed appreciation of the project2. Assess HSE and Social performance and compliance with the ESAP.

E&S Participants

Ramboll Environ (IESC)

IFC E&S specialists

WB E&S specialists

MIGA E&S specialist

Vitol E&S Assurance Manager

Eni Ghana HSE and SLC team and other functions

Day Location / Time Activity Auditee Lead Auditor

Sun 19th Travel to Accra ‐

Accra ‐

0830 ‐ 0900 Arrival of WBG Audit Team in Eni Office ‐

0900 ‐ 0930 HSE Induction for the WBG Auditors

1000 ‐ 1200

Opening Meeting with Eni Senior Management Team: ∙

• Introductions

• Purpose of Visit (IESC)

• Project status update (Eni HSE/Sustainability Teams)

1230 ‐ 1400

1400 – 1500

• ESMS/ESAP

• Meetings with HSE team*

(development and implementation of ESAP/management

plans/bridging documents)

HSEQ ManagerCH

1500 – 1600

ESMS/ESAP

• Meeting with Sustainability/Local content team (development

and implementation of ESAP/management plans/bridging

documents/permitting) ‐ overview

Topics

• Livelihood restoration and fisheries

Sustainability & Local

Content Manager RB

1600 – 1700

Interview with Human Resources Manager

Topics

• Human Resources Management

• Employees working conditions

HR Manager RB

End of Day‐1

0615 Hrs Travel from Accra to Takoradi on Starbow 0615 Hrs flight

0700 Hrs Arrival at Takoradi Airport

Takoradi

A.M:

Induction

Visit logistics base

PM: meetings in office (eni and DSL)

‐ with HSE staff

‐ HSE/security representatives from DSL

‐ CLO

‐ NGO

Accompanied by HSE and

Sustainability Teams

All

CH

CH

RB

RBEnd of Day ‐2

0900 ‐ 10.30 Emergency response CH

10.30 ‐ 12.00 Waste management CH

0900 ‐ 1100 LRP [IESC team to split] RB

11.00 ‐ 1200 NGOs (11am) ‐ topics to be confirmed RB

1400 ‐ 1530 Biodiversity CH & RB

Mon 20th

All

All

1700 – 1800

Interview with Procurement Manager

Topics

• Contractor Management

Procurement Manager CH

Breakfast

Lunch Break

Tues 21st

Lunch (sandwiches)Wed 22nd

OCTP Project, Ghana Vitol – Site Visit Itinerary

20th to 24th February 2017Issue 4 (20_2_17) ‐ agreed with Eni Ghana and Vitol

All

By HSE Department

15.30 ‐ 17.30Monitoring and evaluation for social projects/initiatives.

Social Investment Strategy.RB

1530‐1700 Audit and inspection programme CH

1700 ‐ 17.30 Management of change CH

End of Day ‐3

Thur 23rd 0900 ‐ 0930 Fisheries management (30 mins) All

0930‐1130 Env monitoring CH

1130 ‐ 1200 ESAP discussions All

1200‐1230 Cumulative Impacts RB/CH

1400‐1445 Influx management RB

1445‐ 1530 Community Investment/Stakeholder engagement/grievance mechanism RB

1445‐ 1530 OHS plan and procedures (including journey management) CH

1530 ‐ 1600? Cultural heritage RB

End of Day ‐4

0900 ‐ 1000 free

1000 ‐ 11.15Meeting with Ghana EPA (permitting status, relationship with

Company)

11.45 ‐ 1300 Security Management Security ManagerCH/RB

1300 ‐ 1500 IESC meeting with lenders and lunch.

1500 ‐ 1545 pre close out meeting All CH/RB

1600 ‐ 1730 Close out Meeting with Eni Management Team (with video link) All CH/RB

Depart on late evening flight

WBG and AuditorsFri 24th

WBG and Auditors

Lunch (sandwiches)



67

APPENDIX 4. LIST OF PARTICIPANTS INVOLVED IN THE AUDIT

[REDACTED FOR PUBLIC DISCLOSURE]



68

APPENDIX 5. PHOTO LOG

Photo 1. Multiple bins for segregation of waste at source at Takoradi Logistics base

Photo 2. Good housekeeping in Takoradi Logistics base warehouse. Clear separation of pedestrians (yellow lines) and vehicles (red lines)



69

Photo 3. Storage of lifting straps

Photo 4. Unique identifier using indelible marker pen



70

Photo 5. Quarantined lifting wires awaiting inspection before further use

Photo 6. Generator and bunded diesel storage tank. Dropped bund wall providing access to generator



71

Photo 7. Evidence of staining outside generator - possibly diesel

Photo 8. HSE performance – 4 years since last LTI at the logistics base



72

Photo 9. Lifting operations – use of physical barrier (marker tape) to prevent non authorised personal entering work area

Photo 10. Containerised oil spill response equipment stored at the base

offshore cape three points environmental and … · offshore cape three points environmental and...

Documents