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SAINSHAND WIND PARK PROJECT

STAKEHOLDER ENGAGEMENT PLAN

Ulaanbaatar

2017

Sainshand Wind Park Project Stakeholder Engagement Plan - Final Report

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Brief information:

The project name: Sainshand Wind Park

Customer Sainshand Salkhin Park LLC

Location: Dornogovi aimag, Sainshand

Document: Stakeholder Engagement Plan

Classification: Confidential

Prepared by: Tecol LLC

Prepared date: 12 June 2016

Authorized by: Social expert N.Oyunchimeg

Checked by: Project manager D.Nandinbayar

Senior project manager Federica Pelzer

Tecol LLC has prepared this document to ensure compliance with the IFC performance standards, EIB

environmental and social standards and Mongolian national legislation, taking into account the more

detailed development of the project.

About this report

This report has been prepared by Tecol LLC for the exclusive use of Sainshand Salkhin Park LLC (“the

Customer”) in connection with the proposed Sainshand wind park in Mongolia. It should be read subject

to and in accordance with the disclaimer below.

This document is available for all employees via the project network and is approved for use. This

document is regularly updated, and the latest version is available electronically. It may be distributed to

all stakeholders based on written approval of the Customer.

The project environmental coordinator is responsible for updating and maintaining this plan. The

original hard copy of the document should be signed to indicate approval and filed in the project filing

system. If you have any enquiry relating to this plan, please contact the project environmental

coordinator in the first instance.

Confidentiality

The information in the report is proprietary and confidential.


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Table of Contents 1. INTRODUCTION ...............................................................................................................................4

1.1. Background ....................................................................................................................................4

1.2. Objectives and Scope ....................................................................................................................4

2. PROJECT DESCRIPTION ................................................................................................................5

2.1. Overview........................................................................................................................................5

2.2. Project Location .............................................................................................................................5

2.3. Environmental and Social Impact Assessment Process ................................................................6

3. REGULATORY REQUIREMENTS.................................................................................................6

3.1. National Requirements .................................................................................................................6

3.2. International Requirements ..........................................................................................................7

3.2.1. IFC Requirements ..................................................................................................................7

3.2.2. EPs Requirements ..................................................................................................................7

3.2.3. EIB Requirements ..................................................................................................................8

4. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES .......................8

5. STAKEHOLDER IDENTIFICATION AND ANALYSIS ............................................................11

6. STAKEHOLDER ENGAGEMENT ACTIVITIES .......................................................................15

6.1. The phases of the Stakeholder engagement activities .............................................................. 15

6.1.1. Construction phase............................................................................................................. 15

6.1.2. Operation phase .................................................................................................................. 15

6.1.3. Project Closure ................................................................................................................... 15

6.2. The Future Public Consultation and Disclosure Programme ...................................................... 16

6.3. Resources and Responsibilities .................................................................................................. 20

7. MONITORING AND REPORTING ...............................................................................................20

8. GRIEVANCE MECHANISM.............................................................................................................21

8.1. Overview..................................................................................................................................... 21

8.2. SSP grievance resolution mechanism ......................................................................................... 23

8.3. Responsibilities ........................................................................................................................... 23

8.4. On receiving a grievance ............................................................................................................ 24

8.5. Assessing the grievance .............................................................................................................. 24

8.6. Formulating a response .............................................................................................................. 24

8.7. Track and monitor grievances .................................................................................................... 25

APPENDIX A. .............................................................................................................................................27


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Glossary and list of abbreviations and acronyms

Aimag Province (Mongolian administrative unit)

Soum Mongolian administrative unit (sub-district of aimag)

km kilometer

kV kilovolt

m meter

MW Megawatt

CLO Community liaison officer

CMEC China machinery engineering corporation

EIA Environmental impact assessment

EIB European investment bank

EKF Eksport kredit fonden

EMP Environmental management plan

EPs Equator Principles

EPFIs Equator Principles Financial Institutions

ES Environment-social

ESAP Environmental and social action plan

ESIA Environmental and social impact assessment

EU European Union

DEIA Detailed environmental impact assessment

GEIA General environmental impact assessment

IFU Investment fund for developing countries

IFC International Finance Corporation

MET Ministry of Environment and Tourism

NGO Non-Government Organization

NTS Non-technical summary

SEP Stakeholder Engagement Plan

SWP Sainshand Wind Park

SSP Sainshand Salkhin Park

PS Performance Standards


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1. INTRODUCTION

1.1. Background

SSP considers stakeholder engagement as an essential part of good business practice and corporate

citizenship, and a way of improving the quality of the Project. Effective community engagement is central

to the successful management of risks and impacts on communities affected by the Project, as well as

central to achieving enhanced community benefits.

This Stakeholder Engagement Plan (SEP) has been developed by the Mongolian environmental

consultancy Tecol LLC on behalf of Sainshand Salkhin Park (SSP) to help the Project communicate its

key environmental and social impacts, identify risks and develop innovative solutions to build trust

between the Project and its stakeholders and develop and maintain a constructive relationship with its

stakeholders throughout the duration of the Project. This SEP is intended to provide a framework to

further align business practices with societal needs and expectations, helping to drive long-

term sustainability and shareholder value.

The SEP is supported by a number of sub-plans such as the Resettlement Action Plan (RAP) and the

Corporate Social Responsibility Plan (CSRP), which have already been developed or are currently under

preparation.

The SEP will be reviewed and updated on a regular basis. If activities change or new activities relating to

stakeholder engagement commence, the SEP will be brought up to date. The SEP will also be reviewed

periodically during project implementation and updated as necessary.

This Plan is in accordance with the national requirements for Environmental Impact Assessments (EIA)

as well as with the international standards required by the International Finance Corporation (IFC), and

other financial institutions such as European Investment Bank (EIB), European Bank for Reconstruction

and Development (EBRD) as well as the Equator Principles Financial Institutions (EPFIs).

1.2. Objectives and Scope

The overall objective of the SEP is to define a stakeholder engagement, public information disclosure and

consultation process. This SEP highlights the methods that will be used by SSP to communicate with

people and stakeholders groups who may be affected by or interested in the Project operations and

activities. The end goal of the SEP is to build a trusting relationship with the host community and other

interested stakeholders based on a transparent and timely supply of information and open dialog. A

grievance mechanism for stakeholders and public, included to the SEP, will provide feedback and

comments about the company’s operations and how those complaints/comments will be handled.

A level of stakeholder engagement has already taken place as part of the requirements of the

Environmental and Social Impact Assessment (ESIA) of the Project.

Communication will continue as further planning and design activities are progressed and through the

project implementation.

Key stakeholders have been identified in this document. If any stakeholders have not been identified, they

should contact SSP and ask to be included in the future information and communication.

https://en.wikipedia.org/wiki/Sustainability

https://en.wikipedia.org/wiki/Shareholder_value


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2. PROJECT DESCRIPTION

2.1. Overview

The Sainshand Wind Farm Project (Project) has been classified as a project of Category B under the IFC

and Equator Principles. It means that the project has potential limited adverse environmental and social

risks and/or impacts that are few in number, generally site-specific, largely reversible and readily

addressed through mitigation measures.

The Project is expected to comprise the following components:

25 WTGs (Vestas V100-2.2MW)

On-site substation

On-site access roads as well as 2 km road connection to the public highway

An underground electrical collection system which interconnects the WTGs with the site

substation

4 km long 110kV overhead transmission line (OHL) from the site substation to the existing

Sainshand substation

Temporary workers accommodation located in Sainshand city

2.2. Project Location

SSP has leased an area of 486.6 hectare in the Dornogobi aimag, at the convergence of the territories of

three different soums: Sainshand, Urgun and Altanshiree for a period of 30 years.

The Project site is located at a place called “Ulaan tolgoin khundii” elevated at the altitude of 915-1005

m; approximately 7 km southeast of Sainshand city, in the Gobi region of Mongolia, 460 km southeast

south of the capital Ulaanbaatar. The Project’s location is illustrated below in Figure 1.

Figure 1. Location of the Project site


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The wind turbines will be installed in line from west to the east over the elevated flattish terrace (plateau)

on the south of the Ulaan tolgoin khundii and on the north of the Khetsuutsav predominated with the low

knolls and hillocks and dry swashes.

The closest settlement is Sainshand city located approximately 7 km to the northwest (Figure 1).

Sainshand city is a major city, with a registered population of 34,000, of whom about 24,000 are believed

to reside in the city1.

2.3. Environmental and Social Impact Assessment Process

A General - EIA (GEIA) and Detailed - EIA (DEIA) were first undertaken in 2009 by the local

Mongolian environmental consultant Baigali-Ecology LLC. The GEIA was updated in 2014, and

MEGDT confirmed that a DEIA was required for the Project. The DEIA was completed in 2015 in

accordance with the above requirements and accepted formally by the Ministry of Environment, Green

Development and Tourism (MEGDT) in 2015.

The Project has been classified as Category “B”2 project by the IFC. The GEIA and the DEIA (as

previously discribed) assessed the impacts and benefits of the Project and identified measures by which

these impacts and benefits can be managed.

3. REGULATORY REQUIREMENTS

3.1. National Requirements

No specific Mongolian legislation is designed to ensure wide public consultations during implementation

of Renewable Energy Projects, although the Minister of Environment issued the Decree No A-03,

“Procedures for public participation in environmental impact assessment” on Jan. 6th, 2014 which requires

generally a public consultation. The Law on Environmental Impact Assessment (1998, amended 2012,

2014 and 2015), the Regional Development Management Law (2003, amended in 2006) and the Law on

Environmental Protection (2012), however, define the right of citizens to be informed about ongoing

projects and to be involved in environmental protection activities.

The Law on Environmental Impact Assessment stipulates that public involvement in the DEIA process is

required. Article 18.4 of the Law requires the opinion of local residents of the area to be addressed in

undertaking and preparing a DEIA. However, there is no specific requirement under the Law to

demonstrate how the opinions of local residents should be reflected in design or operational aspects.

The Mongolian Law on Regional Development Management (2003) primarily aims to regulate regional

development and to balance social and economic objectives. Respect for the powers of local self-

governing bodies in the regional development process is underwritten in the Law. According to the Law

local self-governing bodies are responsible for engaging citizens in the regional development process, by

responding to appropriate queries and by encouraging and directing engagement by ‘citizens, enterprises

and organizations’.

1 Personal communication, Ms Narangarel – Head of 3

rd Bag Sainshand soum, October 4

th, 2016

2 Projects for which potential adverse future environmental and/or social impacts are typically site-specific, and/or

readily identified and addressed through mitigation measures are classified as B category project. (The International

Finance Corporation Procedure for Environmental and Social Review of Project) An addition, the Salkhit Wind Park

(the only wind park in Mongolia) was classified as the B category project.


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3.2. International Requirements

Public consultations for the SWP Project will be undertaken to meet the Lenders requirements, which

include:

• International Finance Corporation (IFC) Performance Standards (PSs) on Environmental and

Social Sustainability (IFC PSs 2012);

• IFC Environmental and Social Review Procedure (April, 2006);

• IFC Guidance Note F: Guidance for Preparation of a Public Consultation and Disclosure Plan;

• Equator Principles (EPs) III 2013;

• World Bank Group Environmental, Health and Safety Guidelines (EHS Guidelines) 2007;

• EIB Standards on Assessment and Management of Environmental and Social Standards and Risks

(Standard 1);

• Good Practice Manual Doing Better Business through Effective Public Consultation; and

Disclosure (1998);

• EBRD Performance Requirement (PR) 10 on Information Disclosure and Stakeholder

Engagement

3.2.1. IFC Requirements

Performance standard #1 aims to promote identification and assessment of positive/negative social and

environmental impacts in the project/activity area, prevention of negative impacts of affected

communities and environment, at least minimization or recovery of such impacts if prevention is not

possible, disclosure to the communities of issues which shall affect them, and improvement of social and

environmental performance of the companies with efficient management system.

Performance standard #1 aims to build, maintain and develop the relationships between the employees

and the management, to promote practices guaranteeing compliance with the national laws such as equal

opportunity, non-discrimination and equal treatment towards everyone, prevention of child and forced

labor, protection of work force, promotion of safe and healthy occupational conditions and protection of

workers’ health.

Performance standard #4 requires prevention or minimization of risk and impacts on health and safety

of the society and working of security personnel within legal boundaries in a way to prevent or minimize

the risk to be created, for safety of the society.

Performance standard #5 requires the restoration of livelihoods affected by a project as a result of

acquisition of land and other immovable assets.

3.2.2. EPs Requirements

Equator Principle #5 (Consultation and Disclosure), requires continuous consultation with a cultural

sensitivity that is in harmony with communities affected by the Company’s activities and in a structured

manner. This principle also contains the requirement that consultation status must be independent,

preferential and equipped with information, and that ascertainment of the needs of groups which have

been or might be affected by this project must be guaranteed.


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Equator Principle #6 (Grievance Mechanism), requires formation of a grievance mechanism which

ensures regular and systematic receiving and recording of the complaint of communities affected by the

activities of companies, and which also guarantees action to be taken within a specified period.

3.2.3. EIB Requirements

EIB published the Environmental and Social Handbook with the aim to provide an operational translation

of the policies, principles and standards on Environmental and Social requirements.

Standard #1 aims to outline the promoter’s responsibilities in the process of assessing, managing and

monitoring environmental and social impacts and risks associated with the operations. For operations

outside the EU, candidate and potential Candidate countries must meet the best international practice with

regards to the assessment and management of environmental and social impacts and risks, promote good

environmental and social governance and align with relevant EU principles and standards.

Standard #6: Involuntary Resettlement. EIB projects sometimes necessitate land acquisition,

expropriation and/or restrictions on land use, resulting in the temporary or permanent resettlement of

people from their original places of residence or their economic activities or subsistence practices.

Standard 6 is rooted in the respect and protection of the rights to property and to adequate housing, and of

the standard of living of all affected people and communities. It seeks to mitigate any adverse impacts

arising from their loss of assets or restrictions on land use. It also aims to assist all affected persons to

improve or at least restore their former livelihoods and living standards and adequately compensate for

incurred losses.

Standard #8: Labor Standards. Good labor practices and the use of appropriate codes of conduct are

important to ensure the fair treatment, non-discrimination and equality of opportunity of workers. This

standard aims at ensuring that promoters of EIB projects comply with the core labor standards of the

International Labor Organization and with national labor and employment laws. The standard also

requires the establishment, maintenance and improvement of worker-management relationships.

Standard #10: Stakeholder Engagements. As a public institution, the EIB actively promotes the right to

access to information, as well as public consultation and participation. Standard 10 requires promoters to

uphold an open, transparent and accountable dialogue with all project-affected communities and relevant

stakeholders in an effective and appropriate manner. The value of public participation in the decision-

making process is stressed throughout the preparation, implementation and monitoring phases of a project.

The right to access to remedy, including through grievance resolution, is actively required.

3.2.4. EBRD Requirements

EBRD performance requirements are generally aligned with the standards of IFC and EIB described

above. EBRD PR10 requires the development of a Stakeholder Engagement Plan for projects that are

likely to have adverse environmental or social impacts and issues, tailored to take into account the main

characteristics and interests of the affected parties and other interested parties.

4. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES

To date, three scoping meetings have been held with local communities (see Table 1). The primary goals

of these meetings were to:

• Describe the Project and the ESIA process;


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• Discuss and identify potential Project impacts and benefits associated with the construction and

operation of the Project, including the transmission line, roads and other on-site facilities;

• Understand local land use, activities and populations living and working within or near the

Project site;

• Identify the most effective ways of information dissemination in the future; and

• Develop a list of stakeholder groups and local people most likely to be affected by the Project;


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Table 1. Previous Stakeholder Engagement Activities

Date Attendees Participants Location Key Discussions Key comments and concern

of the community

Community benefits of the

Project

2009 SSP LLC

Representatives of

the County officials

and communities

Local herders

Total 70

Male 36

Female 34

Sainshand soum An introduction and information on the construction

of the Project was provided. Detailed discussion

regarding advantages of the wind farm, the fact that

it is environmentally friendly technology, improving

the road and infrastructure and to provide electricity

to the local communities including local mining

companies. Detail was provided on how wind

energy is used to produce electricity using WTGs

and how this Project will be Mongolia’s second

wind farm.

How to maintain the safety of

local herders and animals,

whether the project impacts

pasture land

Creation of local workplaces,

benefits for local business

entities especially during

construction phase, increase

of local energy quality

(leading to less voltage

fluctuation), sustainable clean

energy production.

2014 Baigal-ecology LLC

Representatives of

County officials and

communities

Local herders

Total 45 Sainshand soum,

Altanshiree soum,

Urgun soum

Baigali-Ecology introduced the DEIA role. Detail

was provided on the environmental assessment

workload and on the work performances.

Environmental issues and restoration measures were

also discussed.

Whether the wind turbines

support desertification,

whether the project impacts

on pasture land and water

resource, whether the project

impacts wild life

2015 SSP LLC

Baigal-ecology LLC

Representatives of


communities

Local herders

Total 161 Sainshand soum,

Altanshiree soum,

Urgun soum

SSP introduced the Project and Baigali-Ecology.

Baigali-Ecology introduced the DEIA role,

highlighted areas where there may be concern e.g.

noise, visual, economic, and queries whether there

were any concerns from the local community.

Baigali-Ecology advised that the wind farm would

be designed to minimize impacts.

SSP provided details of potential community

benefits associated with the Project. Detail was

provided on how wind energy is used to produce

electricity using WTGs and how this Project will be

Mongolia’s second wind farm.

Whether the project impacts

annually horse race, whether

the project impacts water

resource, whether the turbine

rotation has impact on

weather conditions,

2016 SSP LLC

TeCol LLC


communities

Local herders

Total 18 Sainshand soum Tecol provided information on Project’s concern for

maintaining affected herders’ normal life, and

introduced about a plan for livelihood restoration to

herders and local officials.

If the Project provide water

resources for affected

herders.

If there is any possibility for

local citizens to involve in

construction of the wind park

as a worker.


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5. STAKEHOLDER IDENTIFICATION AND ANALYSIS

In order to define effective communication process with the various stakeholder groups SSP has

identified several stakeholder groups that may be interested and/or directly or indirectly affected by the

Project’s implementation.

The stakeholders identified include internal stakeholders, such as employees and construction contractors’

workers, as well as external stakeholders, such as governmental authorities, non-governmental

organizations and local residents.

Figure 2. Stakeholder Analysis Tool3

All the stakeholders identified are presented in Table 2 below.

3 https://www.stakeholdermap.com/stakeholder-analysis.html


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Table 2. Stakeholder Groups Stakeholder

Groups

Stakeholders Summary of Specific Interests Proposed means of

engagement

Stakeholder

ranking

Internal stakeholders

SSP workforce Directly-employed staff Training, health and safety

Meetings, phone calls,

emails, training

Meet their needs

Ferrostaal

Industrial

Projects GmbH

Equity investor Develop project up to Financial Close and

facilitate equity to the project


emails, reporting

Key player

ENGIE

Equity investor

Develop project up to Financial Close, facilitate

equity and provide operation & maintenance

service to the project


emails, reporting

IFU Equity investor Facilitate equity to the project


emails, reporting

EIB Lender Facilitate debt financing to the project


emails, reporting

FinnFund Lender Facilitate debt financing to the project


emails, reporting

EKF Lender Facilitate debt financing to the project


emails, reporting

EBRD Lender Facilitate debt financing to the project


emails, reporting

CMEC BoP Contractor

Procure civil works, electrical equipment and site

management


emails, reporting

Vestas

Turbine supplier

Supply wind energy turbines, supervise

installation and commissioning, provide

maintenance


emails, reporting

External

stakeholders

Government

(National) Ministry of Energy

National energy production policy and issue of

permissions Group meetings

Reporting

Broadcasting media Key player

Energy Regulatory Commission

National energy production policy and issue of

permissions

Ministry of Environment and Tourism Land rehabilitation

Ministry of Health Protection of employee and public safety

Ministry of Construction and Urban Development Land-related issues


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(Administration of Land Affairs, Geodesy and

Cartography)

Minister for Road and Transportation (including State

Railway Authority; Department of Road

Transportation)

Transport related issues

Government

(Provincial)

Governor’s offices of:

Dornogobi aimag

Sainshand soum

Urgun soum

Altanshiree soum

Bags

Negotiating land use and land

possession contracts (Aimag and Soum)

Implementation of EIA-related

management actions are supervised by

the Aimag.

Group meetings

Public notifications

Local print media and

newsletter

Key player

NGOs /

Association Dornogobi Aimag Chamber of commerces

4 (not yet

engaged with) Business development opportunities Group consultation

Public notifications

Local print media and

newsletter

Meet their needs

Mongolian Wind Energy Association

Khuggliin tuv NGO5 (not yet engaged with)

Tsagaan lish cooperative6 (not yet engaged with)

Show consideration

Industry and

Business

National and local specialist consulting and

contracting companies Business opportunities, price, payment terms

Public notification

Information leaflet

Local media

Ulaanbaatar Railway JSC Railway use and safety management

Mongolian National Power Transmission Grid

Company Electricity supply and safety management

National Dispatching Center Electricity supply and safety management

Village well provision and maintenance company:

Chandman Ilch LLC

Office headquarter: Sainshand

Ongoing provision of clean water

Small and medium companies (from Sainshand)

Business opportunities

Potential Impacts on their operations

Specific

communities Local Residents

Local herders located near to Project area

Environmental quality, land acquisition

and compensation, construction traffic

Jobs and other economic benefits

Social/community investment

opportunities/initiatives

Group meetings

Individual meetings

Public notification

Local press end

broadcasting media

Least important

Meet their needs

4 Promoting and aiding businesses and investors by engaging in a mega projects

5 Business development opportunities

6 Economic benefits by investing diary food supply


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Press & Media Print media, circulated widely in Urgun soum:

‘Daily News’ & ‘Zuunii Medee’ (Century

News)

Local news items of interest to readers and

listeners/viewers

Group meetings

Public notification

Local media

Leaflets

Meet their needs

Broadcasting media:

TVs: Mongolian National Broadcaster & TV9

channel, MN 25, TV5

Radio station: FM 101.5 station “My home

place” & Mongolian National Radio Station

Local news items of interest to listeners and

viewers

The SEP will be reviewed on an annual basis and updated by CLO, if necessary.


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6. STAKEHOLDER ENGAGEMENT ACTIVITIES

6.1. The phases of the Stakeholder engagement activities

6.1.1. Construction phase

Stakeholder engagement during the construction phase will relate to all activities leading up to and during

the physical construction of facilities, roads, infrastructure, and buildings related to the project, including

the management of contractors and construction contracts (IFC, 2012).

Early stakeholder engagement during the project design and the EIA process informed the Project

planning and design teams about stakeholder issues thus enabling these teams to investigate and manage

adverse impacts as part of the EMP and construction contract.

Once construction starts, it is important to involve affected stakeholders and keep them informed of

anticipated and unanticipated impacts throughout the period. Engagement during construction is

essentially about involving stakeholders in assessing whether the impact mitigation measures as stipulated

in the EMP are effective. This entails addressing stakeholder concerns and grievances, and monitoring

and managing project impacts. Stakeholder engagement during the construction phase of the project will

set the tone for continued stakeholder engagement during the life of the operation. It should therefore aim

to improve relationships with stakeholders for the remainder of the project’s operational life.

6.1.2. Operation phase

The transition from construction to operations typically means fewer grievances and potentially less

project impacts, which usually translates to less engagement with stakeholders. During this phase

however there is an overall reduction in the number of employees and contractor workforce, which can

potentially affect ongoing stakeholder relationships. The resulting shifts in the composition of the

workforce and associated retrenchments need to be carefully managed.

As such, engagement with stakeholders should be considered an integral component of operations

management, whether this be day-to-day operational activities, or periodic meetings with stakeholder

forums. Stakeholder engagement will therefore be integrated into existing monitoring systems and

management plans, including health and safety, environmental management, social development,

procurement and contractor management, logistics management, audits, and project risk management.

In order to maintain constructive long-term relationships with stakeholders during project operation,

stakeholder engagement needs to go beyond impact mitigation. A more dynamic process is required in

which the SEP is adapted to suit new stakeholder groups and changing stakeholder concerns for dialogue

throughout the life of the Project. Management must be aware of these and the SEP must remain flexible

to make the changing social and business environment a part of stakeholder engagement that will

strengthen effective management of impacts during operations.

6.1.3. Project Closure

The stakeholders potentially affected by project closure will likely be different from those at earlier stages

of the project. Impacts such as the loss of local employment, a general decline in regional economic

activity, the cutting-back of community services previously provided by the company, and the

disbandment of local community involvement in monitoring environmental and social impacts, can

potentially introduce long-term financial and reputational liabilities for the company (IFC, 2012).

Engaging with stakeholders needs to take place well before project closure. This can lower potential costs,

reduce liabilities and strengthen the overall reputation of the company. For example, engagement will


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help guide the rehabilitation of the natural environment damaged by the Project, integrate operational

infrastructure into existing public services, develop worker retrenchment programme, and establish funds

and management structures for the long-term monitoring of assets.

6.2. The Future Public Consultation and Disclosure Programme

It is recognized that stakeholder engagement is an important element of the strategic planning and

management of the Project as well as its day to day running. SSP will invest the appropriate resources in

this process over the life of the Project, from planning and construction, to decommissioning and closure.

SSP will ensure that stakeholders are well informed about the Project throughout its lifecycle. At

community and public meetings, participants will be given the opportunity to raise their concerns and

identify potential Project impacts.

These public meetings will be in line with applicable legal requirements and conducted in Mongolian

with interpreters for English being made available, as required. Records of these meetings will be kept

and continuously updated. Engagements with other entities will be held in the forum as is suitable for the

parties.

As of today, the local project manager is responsible for the communication activities of the project. As

soon as construction of the project commences, a CLO will be nominated, who is committed to manage

the ongoing programme of planned stakeholder engagement, including community relations.

Engagement phase’s specific to the Project can be classified as follows:

Consultation completed by SSP during the development stage, include:

DEIA consultation with local stakeholders and permitting authorities, prior to obtaining an

environmental permit for the Project; and

Consultation and engagement as part of the ESIA process.

The following section and Table 3 outlines the planned engagement modules to be carried out by SSP and

their Engineering Procurement and Construction (EPC) contractor respectively the operating company

over the Project life cycle.


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Table 3. Stakeholder Engagement Programme

Activity Information to be disclosed/issue to be discussed Locations and dates of meetings / forms of

communication

Stakeholder groups to

be consulted

Pre-construction

phase

Disclosure of

Supplementary

Information Report

Non-Technical Summary (NTS) and Environmental

and Social impact supplementary information.

Expected construction, operational and

decommissioning/ abandonment impacts and

mitigation measures to avoid/reduce adverse impacts

and actions to enhance potential benefits.

Initial Announcement of the availability of the

Supplementary information and the overall intentions for

public consultation, through local print media and radio and

website.

Advertisement of the information must be made in the

following:

o ‘Daily News’ & ‘Zuunii Medee’

o Radio station: FM 101.5 station “My home place”

Government

NGOs

Local community7

Public Groups

Potential Clients

General public8

Public consultation meeting, followed by an open house

‘drop in’ event within Sainshand soum, with a ‘comments’

book available.

This will be undertaken approximately 30 days from the date

of disclosure, at a time when the community will be

specifically available in the area (e.g. near to a festival period

to be identified dependent on disclosure timescales).

o Notices on public notice boards, in shops, local

offices etc.

o Information delivered to local businesses /

residents through an information leaflet giving key

details date, time and coverage of the meeting and

following up ‘drop in’ sessions, along with details

of transport provision.

o Official notice on public notice boards in Urgun,

Altanshiree and Sainshand.

A full record of the sessions will be maintained, with

reporting back of responses to questions and comments

made.

Local community

Public Groups

Government Authorities

Herder representation

General pre-

construction

planning and site

preparation prior to

Overall schedule of site preparation and construction,

including sub activities, key stages and potential stages

of stakeholder interest, including road development

and construction /operational work camp development.

Notices on public notice boards, in shops, local offices

etc.

Information delivered to local businesses / residents

through leaflets and open house meetings, as well as

Local community

Public Groups

General public

NGOs

7 Local community: A group of individuals that interact within their immediate surroundings. In this case it refers to the residents of Sainshand city.

8 General public: All people of an area. In this case it refers to citizens of all three soums of Dornogobi aimag (Sainshand, Altanshiree and Urgun).


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construction public notice boards.

Press announcement, local media television and radio.

Environmental and social officers, monthly meetings.

One month prior to:

o Start of construction

o Other major work phases

Grievance mechanism

disclosure A separate workers' grievance procedure will be

established for the Company’s employees and its

contractors. Workers will be given the possibility

to lodge grievances both through workers

representatives and independently, personally,

regardless of the matter of the complaint.

At the project site and project office

Specific consultation

with herders:

Disclosure of the

Resettlement Action

Plan.

NTS and Environmental and Social impact

supplementary information.

Information on compensation and negotiation on

compensation.

Public grievance mechanism

Focus group meetings can be undertaken individually and in

group of herders.

Time:

o Winter Camp cut-off date – 15 November 2016

o Impacts to communal summer pasture areas will also be

compensated. Details of this compensation eligibility and

process will be made prior to commencement of summer

grazing.

Local community

specifically targeted at

herders.

Construction phase

Construction Phase

general information

provision

Schedule of construction works.

Construction activities.

Progress of construction.

Construction impacts and mitigation measures

(with opportunities for feedback from affected

communities).

Notices on public notice boards, in shops, local offices etc.

Information delivered to local businesses / residents through

leaflets and open house meetings, as well as public notice

boards

and safety signs.

Newspaper; Daily News’ & ‘Zuunii Medee’ Broadcasting

media:

Radio station: FM 101.5 station ‘My homeplace’

Community relationship team, as part of the monthly

meetings.

NGOs

Local community

Public Groups

General public

Consultation and

communication on

employment.

Description of plant and operations.

Operational hours.

Construction phase employment opportunities,

application

Processes

Employment terms and conditions

Human resources and Environment, Health and

Safety (EHS) policies and procedures

Notices on public notice boards, in shops, local offices

etc.

Information delivered to local businesses / residents

through leaflets and open house meetings, as well as

public notice boards and safety signs.

Newspapers;

Broadcasting media: Radio stations, monthly meetings.

Included in contracts.

Local community

Public Groups

Potential Suppliers

General public


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Grievance mechanism

disclosure A separate workers' grievance procedure will be

established for the Company’s employees and its

contractors. Workers will be given the possibility

to lodge grievances both through workers

representatives and independently, personally,

regardless of the matter of the complaint.

At the project site and project office

Operational phase

Company

Performance

in Operational Phase

Grievance mechanism disclosure

Workers’ grievance mechanism

In Project site

Bulletin board in break room, tool box talks when new

groups of workers commence work on the Project

Project workers

Company

Performance

in Operational Phase

Annual update and reporting on the ESAP Company Reports.

Summary under ‘Social

Responsibility’

Internal

Stakeholders

• Local community

• Suppliers


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6.3. Resources and Responsibilities

It is recognized that stakeholder engagement is an important element of the strategic planning and

management of the Project as well as its day to day running. SSP will invest the appropriate resources in

this process over the life of the Project, from planning and construction, to decommissioning and closure.

Key roles and responsibilities for stakeholder engagement have not currently been assigned but there will

be appointed a Community Liaison Officer (CLO) and Health and Safety Officer/ Advisor (EHS Officer)

prior to financial close.

During construction and operation the Project Company will employ a designated EHS Officer, who will

be based on site, and a CLO, who will be based primarily on site.

The EHS Officer will supervise and promote the execution of EHS related work by workers on site and

assist and support managers, supervisors and workers in implementing the EHS and achieving EHS

compliance.

He will report to the construction director and later on directly to the site operational and maintenance

manager.

As it may be required, the CLO will carry out day to day liaison with all stakeholders, communities and

interested groups. The CLO will be responsible for collecting up to date information about local

communities and other stakeholders, as well as anticipating and reporting any issues. As part of SSP’s

ongoing stakeholder engagement process, the CLO will also carry out regular community visits, including

meetings with the nomadic herders at their camps.

During construction and operation the CLO will report directly to SSP Chief Execution Officer. The CLO

will also be responsible for periodical monitoring and reporting on SEP implementation and grievances to

SSP management and also externally.

The SEP will be updated with additional contact information when additional roles and responsibilities

are finalized.

7. MONITORING AND REPORTING

The purpose of the Stakeholder Engagement monitoring is to verify that:

Actions and commitments described in this SEP are implemented fully and on time;

Complaints and grievances lodged by project affected people are followed up and that where

necessary, appropriate corrective actions are implemented; and

If necessary, changes in SEP procedure are made to improve stakeholder engagement.

Through communication channels such as media and newsletter notifications, one-to-one meetings and

periodic public meetings, SSP LLC will monitor and provide feedback as appropriate.

To promote transparency and satisfy stakeholder concerns, internal monitoring and implementation of

mitigation measures, and other environmental and social programs are key components of the stakeholder

engagement. This will be achieved through periodic feedback as part of the two way communication

through project implementation and reporting through the meetings to community.

Future important public consultation meetings or public exhibitions will be arranged at venues to enable

stakeholders to participate. An open book (with pens provided) will be positioned in a suitable location

such as community bulletin boards, etc. for recording comments anonymously. This book will be

presented in an obvious area of the exhibition but in an area that will not be directly monitored by host


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staff (e.g. by the exit). The information will be recorded by SSP LLC so that a response and feedback can

be made to stakeholders.

The monitoring on the implementation of SEP and grievance mechanism will be conducted monthly, and

the community engagement monitoring must be an ongoing process.

On an annual basis, SSP LLC will produce a public report on their social and environmental performance,

including a non-technical summary of the Environmental and Social Action Plan (ESAP) and progress

made with the implementation of the ESAP, against agreed indicators and targets.

The results of external audits which will be conducted by certified environmental audit entities on behalf

of the Ministry of Environment, Green Development and Tourism against SEP will be submitted to the

SSP LLC.

8. GRIEVANCE MECHANISM

8.1. Overview

SSP is always accessible for all its stakeholders and responds to complaints and grievances as soon as

possible. A grievance mechanism was designed by taking conditions and needs of PAPs into

consideration so as to ensure that all complaints are dealt with appropriately and corrective actions are

taken. SSP have developed a grievance mechanism for the project in accordance with IFC’s Performance

Standards and Guidance Notes. These include:

• Establishing a procedure for receiving, recording or documenting and addressing complains that

is easily accessible, culturally appropriate, and understandable to affected communities.

• Informing the affected communities about the mechanism during the company/community

engagement process.

• Considering when and how to seek solutions to complaints in a collaborative manner with the

involvement of the affected community,

• Addressing concerns promptly, using an understandable and transparent process that is readily

accessible to all segments of the affected communities—and at no cost and without retribution.

• Ensuring full participation of both genders and vulnerable groups.

• Taking into consideration customary and traditional methods of dispute resolution when

designing the system.

• Assigning consistent, experienced, and qualified personnel within the client organization with

responsibility for receiving and responding to grievances.

• Establishing a redress mechanism so those who feel their grievances have not been adequately

addressed have recourse to an external body for reconsideration of their case.

• Documenting grievances received and responses provided and report back to the community

periodically.

• Providing periodic reports on issues that the grievance mechanism has identified as of concern to

those communities.

The Performance Standards and Guidance Notes emphasize that a grievance mechanism should help SSP

understand the community’s perception of project risks and impacts so as to adjust its measures and

actions to address the community concerns.

The objective of SSP’s SWP grievance procedure is to ensure that all comments and complaints from


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people directly affected by the project, including local communities, herder families and railway workers

are processed and considered in an appropriate way. Furthermore, the grievance mechanism should

contain a process for determining what corrective actions need to be implemented in relation to

complaints received and guarantees that complainant are informed of the outcome. The means by which

stakeholders may make comments and complaints must be appropriate to their culture. The flowchart

below shows a general mechanism of processing the complaints.

Resolved?

Not resolved? Revise choice or execution of approach

Communicate

decision

Implement

approach

Process feedback

and learn

Track and document

Receive and register grievance

Reject complaint

Act to resolve locally?

Screen and assess

Refer as appropriate Define approach

Verification of the complaint

received

Figure 3. Flowchart for Processing Grievances

No Yes


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Workers’ Grievances

A separate workers' grievance procedure will be established for the Company’s employees and its

contractors. Workers will be given the possibility to lodge grievances both through workers

representatives and independently, personally, regardless of the matter of the complaint.

8.2. SSP grievance resolution mechanism Local people need a trusted way to voice and resolve concerns linked to a project’s operations. A locally

based grievance resolution mechanism provides a promising avenue by offering a reliable structure and

set of approaches where local people and the company can find effective solutions together. SSP will

develop and implement a grievance mechanism which:

Increases the likelihood that small disputes can be brought to a conclusion relatively quickly

before they become deep-seated grievances

Keeps ownership of the dispute in the hands of local people

Offers an early, efficient, and less costly way to address concerns

Promotes a more stable business climate for companies that reduces risk and enhances

accountability to the host community.

A successful grievance mechanism can help achieve the following goals:

Open channels for effective communication

Demonstrate that a company is concerned about community members and their well-being

Mitigate or prevent adverse impacts on communities caused by company operations

Improve trust and respect

Provide structures for raising, addressing, and resolving issues that reduce imbalances in power

Promote productive relationships

Build community acceptance of a company’s “social license” to operate.

8.3. Responsibilities

Table 4. Contact Details

Ferrostaal Industrial Projects GmbH

Pelzer Federica

Senior Project Manager

Ferrostaal Industrial Projects GmbH

Email: [email protected]

Tel: +49 (0)201 818 1637

Cell Phone: +49 (0)171 5666882

Sainshand Salkhin Park

Nandinbayar

Manager

Sainshand Salkhin Park LLC

9F, DHE Building

Street ,

Ulaanbaatar

MONGOLIA

Email: [email protected]

Tel: +976-99990416

These contact details will be updated as soon as a local CLO is appointed. In addition to the above contact

details a mailbox will be provided at the site entrance to allow local people to raise grievances in a more

informal way.

mailto:[email protected]

mailto:[email protected]


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8.4. On receiving a grievance

The comments and complaints will be summarized and listed in a Complaints/Comments Log Book,

containing the name/group of commenter/complainant, date the comment was received, brief description

of issues, information on proposed corrective actions to be implemented (if appropriate) and the date of

response sent to the commenter/complainant. Receipt of a grievance must be acknowledged within 5 days

and responded to within 30 work days unless the investigation takes longer, in which case the

complainant will be informed of the extended timeframe.

8.5. Assessing the grievance

During the assessment, the team gathers information about the case and key issues and concerns and helps

determine whether and how the complaint might be resolved. SSP will:

• Determine who will conduct the assessment. Typically, the complaints coordinator performs this

task or directs it to an appropriate staff or department for assessment (production, procurement,

environment, community relations, and human resources).

• Select a company member to engage directly with the complainants to gain a first-hand

understanding of the nature of the complaint.

• Clarify the parties, issues, views, and options involved

- Identify the parties involved;

- Clarify issues and concerns raised by the complaint;

- Gather views of other stakeholders, including those in the company;

- Determine initial options that parties have considered and explore various approaches for

settlement;

• Classify the complaint in terms of its seriousness (high, medium, or low). Seriousness includes

the potential to impact both the company and the community.

Issues to consider include the gravity of the allegation, the potential impact on an individual’s or

a group’s welfare and safety, or the public profile of the issue. A complaint’s seriousness is

linked to who in the company needs to know about it and whether senior management is advised.

• Rather than resorting to a purely unilateral “investigate, decide, and announce” strategy, engage

more directly with the complainant in the assessment process, and involve the complainant in

influencing the resolution process to be selected, and settlement options.

8.6. Formulating a response The system for responding to the complainant should specify who communicates and how.

In some cases, it may be appropriate that feedback be provided by the staff member responsible for

assessment accompanied by the coordinator of the complaints procedure.

The site manager may participate in feedback, depending upon the seriousness of the complaint.

When formulating a response SSP will ensure that:

• The complaint coordinator or relevant department may prepare the response. The response should

consider the complainants’ views about the process for settlement as well as provide a specific

remedy. The response may suggest an approach on how to settle the issues, or it may offer a


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preliminary settlement.

• To present and discuss the response to the complainant, consider holding a meeting with the

complaint coordinator, relevant company manager, and the complainant. If a direct meeting is not

possible, consider meeting with a neutral third party serving as facilitator. The group would also

discuss appropriate next steps during this meeting. If the proposal is a settlement offer and it is

accepted, the complaint is resolved successfully and there is no need to proceed to the next step

of selecting a resolution approach. If the complainant is not happy with the response about a

resolution process or substance, the group should try to reach an agreement that would be

mutually acceptable.

• If the case is complex and a resolution time frame cannot be met, provide an interim response—

an oral or written communication—that informs the person of the delay, explains the reasons, and

offers a revised date for next steps.

All comments and complaints will be responded either verbally or in writing, in accordance with

preferred method of communication specified by the complainant in the Comments and complaints form.

Comments will not be considered as complaints and may not, therefore, be responded to unless the

commenter requests a response.

SSP will respond to the complaint within 30 work days after undertaking complete grievance

investigation. It is possible that some responses may take longer than one week to implement, but even in

those instances SSP will inform the complainant what actions will be taken and when.

8.7. Track and monitor grievances Grievances need to be tracked and monitored as they proceed through the system. Effective tracking and

documentation accomplishes several goals:

• Document the severity of a complaint (high, medium, low) according to specific criteria. The

level of severity guides requirements for alerting senior management and determines the seniority

of management oversight needed.

• Provide assurance that a specific person is responsible for overseeing each grievance—from

receipt and registration to implementation.

• Promote timely resolution.

• Inform all concerned (the complainant and appropriate company personnel) about the status of

the case and progress being made toward resolution.

• Document the company’s response and outcome(s) to promote fairness and consistency.

• Record stakeholders’ response(s) and whether additional research or consultation is needed.

• Provide a record of settlements and helps develop standards and criteria for use in the resolution

of comparable issues in the future.

• Monitor the implementation of any settlement to ensure that it is timely and comprehensive.

• Provide data needed for quality control measures, to assess the effectiveness of the process and

action(s) to resolve complaints.

• Identify learning from specific cases to be used later to assess the effectiveness of the mechanism

or address systemic issues that may require changes in company policies or performance.

In order to ensure that grievances are tracked and documented SSP will provide the following:

• Tracking forms and procedures for gathering information from company personnel and

complainant(s).


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• Dedicated staff to routinely update the database of grievances.

• Periodically review information so as to recognize grievance patterns, identify any systemic

causes of grievances, promote transparency, publicize how complaints are being handled by the

company, and periodically evaluate the overall functioning of the mechanism.

• Processes for informing stakeholders about the status of a case (such as written status reports).

• Procedures for provision of regular reporting of grievances and resolutions


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APPENDIX A. Public Grievance Form

Public Grievance Form

I, (full name)

Resident at:

Tel: Fax:

Wish to raise the following complaint or concern (include location and duration of problem):

Suggestions to solve problem:

Preferred method of communication (verbal: face to face, telephone; written: e-mail, online):

Signed: Date:

……………………………………………….. ……………………………………………….

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