stakeholder engagement strategy - mount owen · 2019-12-19 · stakeholder engagement strategy...

Document Number: MGOOC-1779562647-11176

Status: Approved

Version: 5.0

Effective: 19/12/2019

Review: 19/12/2020

Owner: Officer - Environmental

Plan for

Stakeholder Engagement Strategy

Mt Owen Complex Management Plan Stakeholder Engagement Strategy

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MGOOC-1779562647-11176

Officer - Environmental

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Table of Contents

1 Commitment and Policy ................................................................................................... 4

1.1 Purpose .............................................................................................................................................. 4

1.2 Scope ................................................................................................................................................. 4

1.3 Objectives .......................................................................................................................................... 4

1.4 GCAA Requirements .......................................................................................................................... 4

2 Planning ............................................................................................................................ 5

2.1 Stakeholder Engagement Strategy .................................................................................................... 5

2.1.1 Stakeholder Identification and Assessment ............................................................................. 6

2.1.1.1 Identifying our stakeholders .............................................................................................. 6

2.1.2 Mapping – Consultation Manager ............................................................................................. 9 2.1.3 Stakeholder Perception Study ................................................................................................ 10

3 Implementation of Plans ................................................................................................ 11

3.1 Stakeholder Engagement Plan (SEP) .............................................................................................. 11

3.1.1 Models of Engagement and Techniques ................................................................................ 11 3.1.2 Contents of the SEP................................................................................................................ 11

3.2 Community Development Plan (CDP) ............................................................................................. 12

3.2.1 Developing the CDP................................................................................................................ 12 3.2.2 Community Profile – Stakeholder Perception Study .............................................................. 12 3.2.3 Community Investments and Criteria ..................................................................................... 12

3.2.3.1 Tiers of Community Investment ...................................................................................... 13 3.2.3.2 Sustainable Investment ................................................................................................... 13 3.2.3.3 Local investment.............................................................................................................. 13 3.2.3.4 Eligibility ........................................................................................................................... 13 3.2.3.5 Ineligibility ........................................................................................................................ 14

3.2.4 Partnerships over $10,000 ...................................................................................................... 14 3.2.5 Budgeting and Approvals ........................................................................................................ 14

3.2.5.1 Approvals Thresholds ...................................................................................................... 14 3.2.5.2 Online Smarty Grants Management System .................................................................. 14

3.3 Indigenous Engagement .................................................................................................................. 15

3.4 Training and professional development ........................................................................................... 15

3.5 Managing risks and opportunities .................................................................................................... 15

3.6 Coordination ..................................................................................................................................... 15

3.7 Media engagement and Communications ....................................................................................... 15

3.8 Grievances and Complaints ............................................................................................................. 16

4 Review and Improvement .............................................................................................. 17

4.1 Annual review ................................................................................................................................... 17

4.2 Stakeholder Feedback ..................................................................................................................... 17

4.3 Reporting .......................................................................................................................................... 17

5 Accountabilities .............................................................................................................. 18

6 Document Information ................................................................................................... 19


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6.1 Related Documents .......................................................................................................................... 19

6.2 Reference Information...................................................................................................................... 19

6.3 Change Information .......................................................................................................................... 20

Appendix A - Stakeholder Engagement Plan ....................................................................... 21

Appendix B - Community Development Plan ....................................................................... 31

Appendix C - Community Investment ................................................................................... 34


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1 Commitment and Policy

1.1 Purpose The purpose of the Mt Owen Glendell Operations (MGO) Stakeholder Engagement Strategy (SES) is to assist with planning, management and review our community and stakeholder engagement activities. Through the SES, MGO aims to:

Build and maintain effective relationships with our stakeholders;

Engage and gain trust within local communities;

Invest in our local communities;

Meet the requirements of the Glencore HSEC Framework; and

Maintain our social licence to operate.

1.2 Scope Mt Owen Glendell Operations includes Mt Owen, Ravensworth East and Glendell open cut mines. This Stakeholder Engagement Strategy applies to all employees and contractors associated with MGO.

1.3 Objectives This Engagement strategy seeks to provide MGO with a practical management tool for effective stakeholder engagement, build and maintain relationships, develop trust and credibility with the local community.

The objectives of the strategy are:

Identify and record key stakeholders;

Identify strengths, challenges and opportunities;

Determine and rank key areas of risk;

Establish and implement communication and consultation practices that promote long-term relationships with stakeholders;

Provide timely and accurate information to stakeholders;

Actively seek feedback from stakeholders;

Provide feedback to stakeholders on how their input influences operational decisions;

Record and respond to community complaints in a professional and timely manner; and

Implement a Community Investment Program (CIP), which provides a range of environmental, social and educational benefits.

1.4 GCAA Requirements The GCAA Stakeholder Engagement Strategy outlines the strategy, objectives and principles for the implementation of effective stakeholder engagement practices. Engagement with stakeholders is an ongoing process; each stage of the community engagement process should build on the previous allowing for continual improvement with a robust review process.

The intention of the Strategy is to improve how GCAA engages with stakeholders and take into consideration their needs when making decisions.

The desire is to:

1. Improved communications channels;


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2. Improved relationships;

3. Early identification of issues;

4. Changed perceptions e.g. stakeholders better informed of GCAA operations and activities;

5. Agreement on purpose and direction of a project or program;

6. Diffusion of conflict situations before these impede progress;

7. Promotion of local capacity building and education (individual and organisational); and

8. Increased community cohesion and strengthened shared identity.

2 Planning

2.1 Stakeholder Engagement Strategy The MGO Stakeholder Engagement Strategy (SES) outlines how we plan, manage and review stakeholder engagement and investment in our communities.

The strategy is developed based on information gathered through the identification and assessment of issues, opportunities and risks, concerns and interests, community profile and the impacts of our activities within our area of influence.

Stakeholders are identified, assessed, mapped in ArcGIS and Consultation Manager (CM).

The SES has clear objectives for engagement, the plan provides detail on who, how, why and when identified stakeholders are engaged. The Stakeholder Engagement Plan (SEP) Appendix 1 and Community Development Plan (CPD) Appendix 2 work to achieve our SES.

Figure 2-1 Community Engagement Strategy

As outlined in the GCAA HSEC Standard 10 Community & Stakeholder Engagement, all communication activities adhere to the GCAA Principles and Human Rights. In addition and where appropriate, the following guidance should be investigated:

a) Internal Communications: GCAA 10.03 Internal Communications

b) External Communications: If the media will be contacted to promote Community Development or Investment activities, or if it is likely that the media will be involved, notification of the CAA Media and Communications Manager is required in accordance with GCAA 10.04 Media and Public Relations

c) Communications with Aboriginal and Torres Straight Islanders: CAA SD MEM 0001 Guiding Principles for Engagement with Aboriginal People

Stakeholder Engagement Strategy

Desired engagement outcomes

Stakeholder Engagement Plan

Outlines who, how and when stakeholders will be engaged

Community Development Plan (CDP)

Includes community profile and Investment Plan


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2.1.1 Stakeholder Identification and Assessment Identification of Community and external Stakeholders, is based on their proximity, dependency, representation, strategic intent and includes relevant government and development organisations.

The process is to:

a) Identify and assess issues, opportunities and associated risks, including access to resources;

b) Identify community concerns and interests gathered through mechanism including direct consultation;

c) Review, as appropriate, of communities’ socio-economic conditions, perceptions, state of infrastructure & services and capacities;

d) Assess the impact of our activities within our area of influence, including the social dimensions of site closure.

2.1.1.1 Identifying our stakeholders

MGO has developed a comprehensive stakeholder list that is recorded in Consultation Manager. New stakeholders are added to Consultation Manager as they are identified.

New stakeholders are identified through many forms of communication and consultation, including requests for consultation; community meetings, complainants; community sponsorship and feedback forms.

Changes to consultation requirements are gathered through albeit not limited to face-to-face meetings, evaluation and feedback forms, complaints and GCAA Stakeholder Perception Studies.

Stakeholders have been classified into three groups depending on the predicted level of mining impact, perceived level of stakeholder influence on site activities and the perceived level of interest in site activities or the outcome of site decisions.

1. First Tier Stakeholders: High/Frequent level of impact, influence or interest in site activities and decisions. Communication with these stakeholders is included in the SEP Refer Appendix 1

2. Second Tier Stakeholders: Medium/Semi-frequent level of impact, influence or interest in site activities and decisions.

3. Third Tier Stakeholders: Low/infrequent level of impact, influence or interest in site activities and decisions.

The three stakeholder groups were originally adapted from proceedings of a Community Strategy Workshop held in August 2005, which was facilitated by Jim Cavaye of Cavaye Community Development. The groups were then updated following the outcomes of a stakeholder engagement-planning workshop held in August 2017 attended by representatives of MGO and Umwelt (Australia) Pty Limited (Umwelt). This list of Stakeholder groups is further reviewed for relevance as part of the annual SES review. Table 2-1 list key stakeholder groups and key areas of interest.

Table 2-1 Key Stakeholder Groups and Focal Points

Stakeholder Group

Main Focus/Concerns

FIRST TIER STAKEHOLDERS

Highly Interested/ Neighbouring Landholders/ Tenants

Stock management

Weed control

Feral animal control

Bushfire management

Property disturbance

Unauthorised access


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Stakeholder Group

Main Focus/Concerns

Open gates

Damage to fences

Opportunities for stock agistment

Transport and road impacts.

Building Trust

Two-way communication

Affected landholders

(including landholders adjacent to mine owned land, residents within the acquisition and mitigation zones)

Noise and dust emissions

Blasting overpressure & vibration

Impacts on water quality or quantity

Visual impacts

Devaluation of properties

Socio-economic impacts

Odour from spontaneous combustion

Impacts on flora & fauna

Aesthetics

Quality of mine rehabilitation

Impacts on land capability

Lighting emissions

Cumulative Impacts

Work opportunities

Land acquisition process

Fumes from mining equipment

Transport and road impacts

Information on significant modifications to operations

Mt Owen Glendell Operations CCC Compliance with Development Consent Conditions

Compliance with Environmental Protection Licence conditions

Compliance with Mining Lease Conditions

Environmental and operational performance

Support & contributions for the local community


Mt Pleasant Primary School Support for educational activities and other school events

Impact of property acquisition on student numbers

Opportunities for student mine tours

Opportunities to develop school based programs with focus on environmental and biodiversity activities

Aboriginal Cultural Heritage Working Group Disturbance of cultural heritage sites

Management of cultural heritage sites

Employment opportunities

Department of Planning Industry Environment (DPIE) Compliance with Development Consent Conditions

Compliance with Environmental Management Plans

Management of community issues/complaints

Engagement with local community & other key stakeholders

Environment Protection Authority Compliance with Environmental Protection Licence conditions

Management of community issues/complaints

Management of cultural heritage sites

Department Planning Industry and Environment Water (DPIE Water)

Compliance with water licences

Water usage

Department of Planning Industry and Environment Resources Regulator (DPIE RR)

Mine Rehabilitation

Mine Environmental performance

Compliance with Mining Lease Conditions

Compliance with Mining Operations Plan


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Stakeholder Group

Main Focus/Concerns

Singleton Council Compliance with relevant Development Consent conditions & planning instruments

Support for community services

Support for local business

Engagement with local community & key stakeholders

Impact of mine closure

Information on new projects or significant modifications to operations

Cumulative Impacts

Other Glencore mine sites and mining companies:

Rix’s Creek

Integra

Ravensworth Open Cut

Ashton

Liddell

Hunter Valley Operations

General information on the site’s operational, environmental and social performance


Discussions about cumulative environmental issues, including air quality, blast impacts and noise

SECOND TIER STAKEHOLDERS

Local Rural Fire Brigades

Management of Ravensworth State Forest

Bushfire management


Local community members and community groups:

Hebden Hall Committee

Mt Olive Hall Committee

Glennies Creek Hall Committee

Wild Dog Association



Support for local business


Impact of mine closure

Cumulative impacts

Media:

The Singleton Argus

Muswellbrook Chronicle

Newcastle Herald

Hunter Valley News

ABC News

Operational, environmental and social performance

Management of environmental impacts


Downstream water users Impacts on local and regional surface and groundwater

Other Environmental/Interest Groups:

Wybong Action Group

Denman Aberdeen Muswellbrook Scone Healthy Environment Group (DAMS HEG)

Minewatch Community Group

Lock the Gate Alliance

Land and Environment Planning

North East Forest Alliance

The Australia Institute

Nature Conservation Council

Impacts on flora and fauna

Quality of mine rehabilitation

Land management practices (e.g. weed control)


Corporate Employees Continuity of operations and employment




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Stakeholder Group

Main Focus/Concerns

Forestry Corporation NSW Management of Ravensworth State Forest

Bushfire management

Plantation forestry opportunities

Pest management

Department of Industry - Lands & Forestry Road closures

Management of Crown Road permits

THIRD TIER STAKEHOLDERS

Businesses and suppliers Continuity of operations and supply contract


Customers Continuity of operations and product supply


Users of infrastructure (e.g. road and rail) Impacts of traffic movements on local roads and rail

Compliance with relevant Development Consent conditions regarding the local road and rail network

Information on significant modifications to operations affecting infrastructure use

Secondary and primary schools Opportunities for site mine tours

Future employment opportunities (secondary schools)

Tertiary Institutions Work experience opportunities


Australian Rail Track Corporation On-going maintenance and safety of the Mt Owen Rail Spur

Pacific National Continuity of operations and supply contract

NSW Dam Safety Committee On-going maintenance & safety of prescribed water management structures and tailings emplacement facilities on site

Roads and Maritime Services Compliance with relevant Development Consent conditions regarding the local road network

NSW Fisheries Impacts on surface water quality in local streams

NSW Local Land Services

Interaction with Travelling Stock Reserves

Weed management

Stock management

Pest species management

NSW Minerals Council Promoting mining related best practice to foster a dynamic, efficient and sustainable mining industry in NSW. NSWMC is committed to healthy working conditions, strong growth, responsible environmental practices and vital regional communities throughout the state.

2.1.2 Mapping – Consultation Manager Stakeholder details and communications are stored in Consultation Manager. Stakeholder issues, opportunities and risks recorded as the consultation occurs. Complaints recorded in CMO.

As outlined in GCAA HSEC Standard 10 Community & Stakeholder Engagement, engagement activities will be tracked against the SEP in Appendix A using Consultation Manager.


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2.1.3 Stakeholder Perception Study GCAA will coordinate a Stakeholder Perception Study at least once every three years. Information gathered from the research, Mt Owen Continued Operations Project’s EIS and Social Involvement Assessment (SIA) used in the development of our current SES.

The 2018 stakeholder perception study drew a strong positive conclusion in the area of social capital and social relationships. Tree screening highlighted as an area for further improvement. Tree screening planted on Middle Falbrook Road 2019..


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3 Implementation of Plans

3.1 Stakeholder Engagement Plan (SEP) MGO has developed a plan based on the outcomes of the Stakeholder Identification and Assessment process. The plan lists stakeholder groups, outlines the objectives of the engagement, engagement activities, engagement techniques, timing, resources and responsibilities.

3.1.1 Models of Engagement and Techniques Mt Owen Glendell Operations has a long history of proactive engagement with the community. The engagement techniques used are based on the nature of the issue, level of risk, timeframe and resources available.

MGOs models of engagement and technique enhances our commitment to working with the local community and key stakeholders to understand key local issues and opportunities.

We endeavour to include stakeholders in decision-making, by two-way information sharing and techniques to engage and encourage people to share their thoughts and opinions. This is a vital ingredient in creating strong, positive and respectful relationships.

Models of engagement, engagement techniques and how to choose engagement techniques are outlined in GCAA Stakeholder Engagement Strategy. The level of engagement can vary and is explained in Table 2 International Association of Public Participation (IAP2)

Table 2 International Association of Public Participation (IAP2)

3.1.2 Contents of the SEP The plan will consider the following:

a) Stakeholder Group

b) Engagement techniques

c) Engagement objective / goals

d) Timing

e) Responsibilities

f) Resources

g) Engagement tracking / progress.

The MGO Stakeholder Engagement Plan is located in Appendix A.


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3.2 Community Development Plan (CDP) The Community Development Plan (CDP) forms part of MGO’s SES. Community investment activities are described in the CDP, the CDP outlines the requirements of planning, managing and reviewing community development and investment activities at our site. This plan has been developed in accordance with 10.02 Community Development and Investment Protocol.

3.2.1 Developing the CDP A range of information is used to develop the MGO CDP, it has been developed through the following techniques:

a) Communication and feedback from Stakeholders regarding community needs and aspirations;

b) Feedback from existing partnerships; and

c) Findings from the Mt Owen Continued Operations Project’s SIA which aimed to identify the long term aspirations of the community

Careful consideration is given to all potential community investments, weighing community development goals, priorities, strengths, opportunities, risks and impacts of operational activities on our local communities. Maximising the number of people in the community who benefit from the investment is also taken into account.

It is important that our community investment objectives align with Glencore’s investment objectives which are outlined in 10.02 Community Development and Investment Protocol.

Glencore’s community development and investment focus on the following:

d) Capacity building – including but not limited to education / training, enterprise development and economic diversification;

e) Health;

f) Environment;

g) Additional needs identified at a local or regional level that have been identified in the community profile (see section 3.2.2 below) and the stakeholder analysis

Where possible, opportunities to collaborate and involve other partners should be explored.

The CDP will be reviewed annually in accordance with GCAA requirements.

3.2.2 Community Profile – Stakeholder Perception Study Defining community profiles is undertaken by GCAA in the Stakeholder Perception Study every three years. This information allows an accurate definition of the community when developing the CDP. In accordance with GCAA requirements MGO is required to conduct a Social Impact Assessment (SIA) using a 3rd Party every five years, unless otherwise triggered through an approval or mine closure requirement.

3.2.3 Community Investments and Criteria A structured approach to community investment at both the GCAA and Operations level is required. The

following principles and criteria are to be applied to all Community Investment activity. Sponsorship is different to Community Investment and is a commercial arrangement with an expected commercial return on investment. Sponsorships are to be budgeted for separately outside of GCAA or Operations Community Investment budget.


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3.2.3.1 Tiers of Community Investment

Figure 2: Three Tiers of Community Investment

3.2.3.2 Sustainable Investment

Community development investments must have an element of sustainability, particularly concerning larger projects. This should allow ongoing benefit to beneficiaries, avoid dependency on MGO funding, and have a clear exit strategy post MGO funding.

3.2.3.3 Local investment

MGOs CDP focuses on the Singleton LGA, as it is the most impacted by our operations. Outside of Singleton, our investments can extend to Branxton, Muswellbrook and Maitland.

3.2.3.4 Eligibility

The following criteria must apply to MGO’s community investment:

a) be from a not-for-profit, incorporated organisation operating a separate, auditable organisational bank account;

b) demonstrate the organisation’s ability to manage the proposed project/activity in a professional manner;

c) primarily benefit at least one of the communities where we operate;

d) address a substantiated need in the community;

e) demonstrate how the initiative will directly benefit the local community;

f) demonstrate a high level of community involvement i.e. be widely beneficial to the community;

g) demonstrate or progressing towards financial sustainability, i.e. not become reliant on ongoing funding from Glencore;

h) have clearly defined objectives and timeframes; and

i) be received with sufficient notice of the planned project/activity implementation or within the ‘funding round’ timeframe.

Note

Raising funds for other organisations or initiatives should only be supported in a very limited way and be primarily limited to instances where employees are raising funds on behalf of a charity that preferably provides local benefit.


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3.2.3.5 Ineligibility

Applications for support of the following deemed ineligible for MGO’s community investment:

a) political parties or organisations, politicians or candidates for public office;

b) individuals; including those seeking support for activities such as academic studies, competing in a sporting event, or travel;

c) ‘for profit’ organisations;

d) touring sporting or cultural groups or individuals;

e) religious activities;

f) any activities which are exclusive to a single faith community;

g) projects/activities that do not demonstrate financial sustainability;

h) overseas appeals; and

i) projects/ activities that have already been completed (retrospective funding).

3.2.4 Partnerships over $10,000 All individual Community Investment projects that attract an investment of $10,000 or greater should undergo an individual project evaluation using the relevant internal evaluation form 10.02 Community Investment Assessment Approval. As part of projects agreements, an evaluation should also be carried out by the funding recipient and be incorporated into the Community Investment project agreement. These evaluations can be discussed where relevant during the annual planning process. Partnerships of $14,000 (US $10,000 equivalent) or greater must be reviewed in line with GCAA Third Party Due Diligence Protocol for Community Investment, Charitable Contributions and Sponsorships

3.2.5 Budgeting and Approvals MGO prepares the community investment budget as part of the annual planning and budget review process. The community investment budget is submitted to GCAA Community Relations Manager using the form: 10.03 Proforma for Annual Tier 2-3 Community Investment program. All community investment projects must be completed within 12 months of funding unless agreed multiyear project is approved.

3.2.5.1 Approvals Thresholds

Approval thresholds for community investments are shown in Table 3.2. Where approval is required by the Chief Operating Officer (for investments of over $10,000), applications are to be forwarded to GCAA Community Relations Manager for coordination.

Table 3-3 Community Investment Funding Authority Levels

Position Authority / Approval Level

Operations Manager Up to $5,000 per Community Investment and within total approved CAA or Operation Annual Community Investment Budget.

Directors, General Manager Up to $10,000 per community investment and within MGO Annual Community Investment Budget

CAA Chief Operating Officer Greater than $10,000 per community investment or any non-budgeted item in the MGO Annual Community Investment Budget

3.2.5.2 Online Smarty Grants Management System

GCAA has implemented an online grant management system using the Smarty Grants platform. This system will be used by MGO for community investment applications to administer applications and manage budgets. Applicants must complete their application either online through the Smarty Grants platform or by completing 10.01 Community Investment Application Form.


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3.3 Indigenous Engagement Engagement strategies for consultation with Indigenous people should be consistent with the Stakeholder Engagement Principles outlined in this document, MGO Aboriginal Cultural Heritage Management Plan as well as GCAA - Guiding Principles for Engagement with Aboriginal People and GCAA Standard - Human Rights and Our People.

3.4 Training and professional development At MGO, the Environment and Community personnel maintain the primary responsibility for community and stakeholder engagement. All staff responsible for community relations and community development have the appropriate qualifications, experience or on the job training. Roles and accountabilities for community and stakeholder engagement are defined and documented within position descriptions. Training requirements are tracked via the site’s training needs analysis, which is reviewed annually, in accordance with GCAA 11.14 Environment and Community Training.

3.5 Managing risks and opportunities Community risks and opportunities are gathered and assessed using a variety of methods including:

community complaints;

feedback / concerns / opportunities raised through consultation;

Environment and Community Aspects and Impacts Register which is reviewed annually;

Pre-mining risk assessments for Environmental Assessments;

MGO Broad Brush Risk Assessments conducted annually;

Glencore Stakeholder Perception Studies; and

local media.

Throughout the implementation phase, identified risks associated with community and stakeholder engagement are mitigated and monitored. Senior management are to be kept informed in order to adequately manage and monitor risk associated with Community and Stakeholder engagement. Where appropriate, senior management will participate in:

a) Analysis and planning;

b) Dialogue with community and stakeholder representatives; and

c) Grievance resolution.

In accordance with GCAA 11.17 Mine Closure Planning, prior to commencing the mine closure process, a social impact mitigation strategy will be developed to assess the impacts associated with the mine closure.

3.6 Coordination The MGO Environment and Community personnel coordinate the activities within the SES; however, management and other departments are encouraged to participate where appropriate. Further information is outlined in the Rules of Engagement in the GCAA 10.0 Community and Stakeholder Engagement.

3.7 Media engagement and Communications As outlined in 10.0 Community and Stakeholder Engagement, all communications activities are to adhere to the principals outlined in the following:

Internal Communications: GCAA 10.03 Internal Communications


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External Communications: If the media will be contacted to promote Community Development or Investment activities, or if it is likely that the media will be involved, notification of the CAA Media and Communications Manager is required GCAA 10.04 Media and Public Relations

Communications with Aboriginal and Torres Straight Islanders: GCAA MEM 0001 Guiding Principles for Engagement with Aboriginal People and the MGO ACHMP

All branding of communication materials, signage and promotional materials is to be consistent and in accordance with GCAA branding guidelines and global Glencore corporate standards.

All branding of signage and promotional material is to be approved by the GCAA Media and Communications Manager to confirm consistency and accordance with GCAA Branding Guidelines.

3.8 Grievances and Complaints MGO manages community complaints as per the complaints procedure outlined in the MGO Environmental Management Strategy; in accordance with GCAA 10.05 Community Complaints Management and 9.0 Human Rights and Our People

Complaints are recorded in CMO and are reported in the Annual Review and at CCC meetings. A complaints register is also maintained on the public website. Complaints are reviewed as part of our stakeholder feedback during the annual review process.

Effective grievance and complaints mechanisms enable effective detection and remediation of any adverse human rights impacts directly caused or contributed to by our activities.

Grievance mechanisms for employees, contractors and external stakeholders are to meet the following criteria:

a) Seen as an accountable, legitimate and fair process by users.

b) Accessible for all potential users.

c) Clear, understood and predictable procedure and timeframes.

d) Providing reasonable access to information, advise and expertise for potential users to support their use of the mechanism.

e) Transparent to all users.

f) Confirmation that outcomes and remedies respect human rights.

g) Continuously evaluated and updated as part of a continual improvement process.

h) Based on stakeholder engagement and dialogue.

Grievance mechanisms are to be clearly communicated internally and externally, including how to access and make available to individuals.

All grievances and follow-up actions are to be registered, monitored and evaluated to identify trends and enable identification of risk at an early stage.

Where operations identify that they have caused or contributed to an adverse human rights impact, they will provide or participate in effective remediation, giving particular attention to vulnerable and previously disadvantaged groups.

All instances where operations caused or contributed to adverse human rights impacts are to be reported to the applicable Regional Asset General Manager who will review and determine appropriate mitigation or remediation measures. Provision of information to Stakeholders

Consultation with our stakeholders is stored in Consultation Manager.

When any information associated with a MGO approval (such as a structural inspection report) is provided to stakeholders, evidence that it has been provided must be uploaded to both CM and the relevant obligation in CMO.


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4 Review and Improvement

4.1 Annual review Mt Owen Complex conducts an annual review of the environmental aspects and impacts as well as community and SES as part of the annual planning process. The review includes:

a) Stakeholder risks and opportunities identified as part of the E&C Aspects and Impacts Register;

b) Feedback from stakeholders on our engagement or community investment activities, including complaints;

c) Review of the outcomes and deliverables of the SES;

d) Review of the most current Stakeholder Perception Study where relevant, or any other community information or strategic plan; and

e) Changes in community expectations; emerging environmental or community issues or changes to mining operations.

4.2 Stakeholder Feedback Feedback on our environmental performance, engagement techniques and community investment is encouraged and received through the following methods:

a) consultation with stakeholders;

b) 24 hour complaints line;

c) feedback surveys; and

d) CCC and other community meetings.

In the case of negative feedback, we will consider the feedback and where necessary and feasible, implement changes to the operation to address the identified issues. If requested feedback will be provided to the stakeholder on the outcome. This follows the communication principals of providing a two way flow of information and follow-through.

4.3 Reporting Mt Owen Glendell Operations is required to report on our stakeholder engagement activities and community investment documented in the Stakeholder Engagement Strategy. This is achieved through the following methods. Stakeholder engagement and community investment activities are also reported through the Annual Review, community newsletters, presentations at CCC meetings etc.

Table 4-1 – Reporting Mechanisms

Report Type Purpose Frequency Recipients

Environment and Community Status report

Update on engagement and community development activities

Monthly GCAA

Community Development Plan (CSI)

MGO’s budgeted investment Annually GCAA Community Relations

GCP Community investment spend and in-kind

Monthly GCAA

Annual Review Stakeholder engagement, feedback and investment

Annually Government, CCC, online


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5 Accountabilities

Role Accountabilities for this document

Operations Managers Ensuring that there are adequate resources available to fulfil

the requirements of this Strategy.

Environment &

Community Manager

Providing timely and accurate information to stakeholders on

the operational, environmental and social performance of the

MGO;

Maintaining records of communication or consultation with

stakeholders;

Identifying and prioritising community risks and opportunities

and establishing annual objectives;

Reporting on the effectiveness of communication and

consultation strategies and performance against the Plan’s

objectives; and

Undertaking an annual review of this Strategy, in conjunction

with the E&C team; and

Environment &

Community Officers

Recording and responding to community complaints in a

professional and timely manner; and

Preparing, distributing regulatory, and community reports for

the MGO in conjunction with the E&C Manager.

Maintaining an accurate database of stakeholders;

Actively seeking feedback from stakeholders, information

provided by the Company and the communication/consultation

process and where required, incorporating this information into

the decision making process;

Providing feedback to stakeholders on how their input

influenced operations or decisions;

Maintaining records of communication or consultation with

stakeholders;

Co-ordinating and monitoring the implementation of the

Community Development Plan

Coordinating annual reviews of this Plan, or following a

significant change to operations.


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6 Document Information Related documents and reference information in this section provides the linkage and source to develop and maintain site compliance information.

6.1 Related Documents Related documents, listed in Table 6-1 below, are internal documents directly related to or referenced from this document.

Table 6-1 – Related documents

6.2 Reference Information Reference information, listed in Table 6-2 below, is information that is directly related to the development of this document or referenced from within this document.

Table 6-2 – Reference information

Reference Title

MOCO EIS Appendix 5 Mount Owen Continued Operations Project (MOCO) Environmental Impact Statement Volume 1 (Umwelt, January 2015)

Glencore Hunter Valley and Greater Ravensworth Stakeholder Perception Research (Australian Centre for Corporate Social Responsibility, 2016)

Glencore Hunter Valley and Greater Ravensworth Stakeholder Perception Research (Australian Centre for Corporate Social Responsibility, 2018)

Title

Mt Owen Complex Environmental Management Strategy

GCAA Stakeholder Engagement Protocol

GCAA Community and Stakeholder Engagement

GCAA 10.02 Community Development and Investment Protocol

GCAA Community Investment Project Agreement

GCAA 10.02 Community Investment Assessment Approval

GCAA 10.03 Proforma for Annual Tier 2-3 Community Investment Program

GCAA 10.01 Community Investment Application Form

GCAA Guiding Principles for Engagement with Aboriginal People

GCAA Human Rights and Our People

GCAA 11.14 Environment and Community Training

GCAA 11.17 Mine Closure Planning

GCAA 10.05 Community Complaint Management


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6.3 Change Information Full details of the document history are recorded in the document control register, by version. A summary of the current change is provided in Table 6-3 below.

Table 6-3 – Change information

Version Date Review team

(consultation) Change Summary

1.0 November 2015 Mt Owen E&C Officer

MOC E&C Manager

Operations Managers

Update MOC’s Social Involvement Plan to reflect GCAA 10.0 Community and Stakeholder Engagement – Stakeholder Engagement Strategy

2.0 September 2017 Mt Owen E&C Officer

MOC E&C Manager

Changes made following an audit against the GCAA Protocols and to ensure all content is still correct. Updated the SEP, CDP and CIP for 2018.

3.0 November 2018 Mt Owen E&C Officer

MOC E&C Manager

Annual review and update.

4.0 December 2019 MGO E&C Officer

MGO E&C Coordinator

Annual review and update. Changes made to in line with GCAA Protocol Update and Mt Owen MOD 2 DA

5.0 December 2019 MGO E&C Officer

MGO E&C Coordinator

Image issue reformatted on Page 1.

Appendix A - Stakeholder Engagement Plan a) Grouping: Tier 1 – Highly Interested/Impacted Neighbouring Landholders/Tenants

b) Overall Engagement Objective for Group: Through increased community consultation, MGO would like to build further trust with the nearby neighbours through increased community consultation and transparency.

Stakeholder (organisation,

group or individual)

Contact Person Engagement Technique* Engagement

Deliverables

Engagement Timing

Glencore Engagement

Leader

Resources/Planning required

Engagement tracking/ progress

Highly Interested /Impacted Neighbouring Landholders/

Tenants

Goorangoola/

Camberwell Residents:

Badior, K&J; Batch, C&G; Bestic, P; Bodiam, G&G; Bowman, A; Bowman, W; Boyce, M&S; Bridge, M; Brock, H&C; Bynon, D&L; Caldwell, B; Castledine, H; Cheetham, G&K; Crow, G; G; Cullinan, B; De Jong, M&T; Foster, E&D; Gardner, B&A; Hall, R&D; Holmes, G; Johnson, B&A; Keeley, D&M; Marshall, J; McInerney, J&J; Meyn, K; Moran, B&J; Nagle, S&P; Olofsson, D; Porter, M&R; Reid, J&J; Richards, B&R; Koureas, J; Turner, S; Upward, D&J; Upward, S&D; Upward, L&F; Vinson, R&J; Watson, M&D; Williams, W; Woodley & Pollock, D&K; and Yates, G&J

Hebden Residents:

Clydsdale, J&G; Clydsdale, R&B; Clydsdale, R; Clydsdale,

Meeting, either one on one or in a group (such as a Community Gathering)

Meeting offered to each resident in this group to discuss specific issues including land management and environmental impacts

One meeting is the aim, and will be offered each year, however more will be had if required.

MGO E&CM

MGO E&CO

Summary of projects and approvals

Relevant resources from E&C Team

Consultation Manager

Newsletter Mail out

Newsletter to discuss rehabilitation, land management, community involvement etc.

Two Newsletters will be sent out each year.

MGO E&CO

Organise Bink to put the newsletter together

Coordination with Ravensworth and Liddell

Newsletters will go on public website and sent to stakeholders


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Deliverables

Engagement Timing

Glencore Engagement

Leader



J&A; Dawson, L&E; Harper, B&L; Oliver, S; Richards, P; Spiteri, M&C; Smart, T&L; Sproule, B; Wilson & Burg, S&A; Williams, C&S

Tenants:

Orman, M&C; Burzynski, J&T; Smith and Davis; Young, L; Parker, D&A; Burgess, B&G; Badger & LeBrocq; Fiel & Rose; Miller, C&C; Craft & Coleman; Davies & Wittingham; Richards, M; Bagley, G; Smith & Newbigin; Colinta Holdings; Berghan & Oldam; Richards, J&M; Chapman, G&A Butters, J&P; Howard & Cumbley; Donnellan, G.

Upward, D One on one meeting

One on one meeting offered to discuss blasting impacts upon hand fed cattle in feedlot environment in accordance with

One meeting is the aim, and will be offered each year, however more will be had if required.

MTO E&CO

Relevant resources to be utilised as required.



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Deliverables

Engagement Timing

Glencore Engagement

Leader



SSD 5850 commitment

Cherry, B&A Requested no more contact 2019

c) Grouping: Tier 1 - Impacted Landholders (including landholders adjacent to mine owned land, residents within the acquisition and mitigation zones)

d) Overall Engagement Objective for Group: Build and maintain relationships with landholders.


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Deliverables

Engagement Timing

Glencore Engagement

Leader



Impacted Landholders

(including landholders adjacent to mine owned land, residents within the acquisition and mitigation zones)

Mitigation &/ or/ Acquisition Rights:

Moore; Cherry; Watling and Prichard; Cheetum; Stewart; Bridge Boyce; Moran, B&J; Yelverton; Porter; Garland; Johnson; Upward, A&B; Bynon; Holmes; Bodium; Partridge; Gardner, R&W; Woodley & Pollock; Gardner, W&A; Moran, D; Foster; Watson; Scriven; McInerney; Turner; Vollebregt & Clarke; Lopes; De Jong;

One on one communication

Contact made with each resident annually, either by phone or letter, offering a one on one meeting. For those with mitigation rights under SSD 5850, the purpose of the communication will be to monitor the effectiveness of the mitigation strategies in mitigating negative social impacts and / or enhancing positive social impacts over time.

Anytime of the year

MTO E&CO





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e) Grouping: Tier 1 – Community Consultative Committee

f) Overall Engagement Objective for Group: Maintain compliance, update on MOC mine progress and environmental performance.




Deliverables

Engagement Timing

Glencore Engagement

Leader



CCC Marshall, J

Holmes, G

Bestic, P

Olofsson, D

Cheetham, G

Moran, D

Hall, G

Meetings

Open Days

Update on MGO mine progress

Environmental performance

Community update

At least two meetings per year

MGO E&CM


Meeting Room

E&C Team

CCC Minutes to go on public website


g) Grouping: Tier 1 – Mt Pleasant Public School

h) Overall Engagement Objective for Group: Build and maintain relationships, support local school which MGO has impacted upon in the past


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Deliverables

Engagement Timing

Glencore Engagement

Leader



Mt Pleasant Public School

Julie Black (Principle)

Meeting, either one on one or in a group

Meeting requested to discuss opportunities for the development of school based program with focus on environmental and biodiversity

Delivery of school based program with environmental and biodiversity.

One meeting is

the aim, and

will be offered

each year,

however more

will be had if

required.

MTO E&CO Suggestions

Relevant resources regarding history with Mt Pleasant



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i) Grouping: Tier 1 – Aboriginal Cultural Heritage Working Group

j) Overall Engagement Objective for Group: Build and maintain relationships and trust, maintain compliance with Aboriginal Cultural Heritage Management Plan (ACHMP), and encourage feedback.




Deliverables

Engagement Timing

Glencore Engagement

Leader



Aboriginal Cultural Heritage Working Group

Downs, N

Worth, S

Fletcher, A

Perry, L

Skene, T

Waugh, M

Hickey, D

Franks, S

Group meeting Working group meetings held bi-annually

Anytime of the year.

MTO E&C Officer



Meeting Minutes

k) Grouping: Tier 1 – Department of Planning and Environment

l) Overall Engagement Objective for Group: Maintain compliance and provide timely and accurate information.




Deliverables

Engagement Timing

Glencore Engagement

Leader



Department of Planning and Environment

Heidi Watters On site meetings and phone calls

Annual Review

All information required by the Development Consents in a timely manner

Report submission

As required by development consent. Report (Annual Review) submission by 30th March each year

MGO E&CM

E&C team and various other personnel as required


Website Reports


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m) Grouping: Tier 1 – Environment Protection Authority

n) Overall Engagement Objective for Group: Maintain compliance and provide timely and accurate information.




Deliverables

Engagement Timing

Glencore Engagement

Leader



Environment Protection Authority

Natasha

Ryan

On site meetings and phone calls

All information as required by the Environment Protection Licences

As required by the EPLs, each year an Annual Return report is submitted

MGO E&CM


Environmental Data


Annual Return Reports

o) Grouping: Tier 1 – Department of Primary Industries Water

p) Overall Engagement Objective for Group: Maintain compliance and provide timely and accurate information.




Deliverables

Engagement Timing

Glencore Engagement

Leader



Department of Planning Industry and Environment - Water

Ellie Randall Email Provide Annual Review Report

Report (Annual Review) submission by 30th March each year

MGO E&CM


Environmental Data

Annual Return Reports to go on public website

On site meetings and phone calls/emails

Response to any issues or advice sought

No specific timing

GLD E&CC

MGO E&CM

Environmental Data Consultation Manager


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q) Grouping: Tier 1 – Department of Resources and Geoscience

r) Overall Engagement Objective for Group: Maintain compliance and provide timely and accurate information.




Deliverables

Engagement Timing

Glencore Engagement

Leader



Department of Planning Industry and Environment - Resources Regulator

Neil McElhinney

On site meetings and phone calls

All information required by the Development Consents in a timely manner Report submission

As required by development consent, or as requested Report (Annual Review) submission by 30th March each year

MGO E&CM



Website Reports

s) Grouping: Tier 1 – Singleton Council

t) Overall Engagement Objective for Group: Maintain compliance and communicate with Council regarding matters of interest to Council, such as social and amenity, traffic, agriculture, water and offsets, as well as construction workforce scheduling, composition housing requirements, etc.




Deliverables

Engagement Timing

Glencore Engagement

Leader



Singleton Council

Various personnel

On site meetings and phone calls as requested

Communicate with Council regarding matters of interest to Council

As required MGO E&CM

MGO AM




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u) Grouping: Tier 3 – Other Glencore mine sites and mining companies

v) Overall Engagement Objective for Group: Maintain compliance with approvals, which require having discussions about cumulative environmental issues, including air quality, blast impacts and noise




Deliverables

Engagement Timing

Glencore Engagement

Leader



Other Glencore mine sites and mining companies

Rix’s Creek -

Chris Quinn

Integra - Chloe Piggford

Ravensworth Open Cut

Klay Marchant

Ashton-Phil Brown

Liddell-Ben Desomer

HVO – Andrew Speechly

On site meeting or phone call

Discussions about cumulative environmental issues, including air quality, blast impacts and noise

Communication at least annually with each contact person

GLD E&CO Environmental data as required


Appendix B - Community Development Plan

Mt Owen Complex Community Development Plan

Key contact personnel for CDP Melanie Dillon

Commencement date for CDP NB: CDP’s should be updated at least every three years)

January 2019

Community Profile

Geographic boundary for CDP Muswellbrook, Singleton, Maitland

Key community socio economic

demographics

Socio economic statistics are located:

http://www.mtowencomplex.com.au/en/future-mining/Pages/overview.aspx

Community Priorities/Goals/Aspirations

There has been considerable

consultation with the community

regarding their needs and aspirations.

Please see the Social Impacts and

Opportunities Assessment (SIOA) for

further details.

Updates on community initiatives will

be discussed and success evaluated

via community feedback and CCC

meetings.

Priorities/Goals/Aspirations: Supporting the community Providing on-going support for community groups, projects and local businesses through MGO’s community investment program and in particular, support for:

- Local community events (e.g. Charity rugby league game; - Local schools (e.g. Singleton School/Mt Pleasant School); - Neighbourhood centres; and - Health and wellbeing programs.

Promoting community sustainability MGO will consider existing resources and assets to uncover opportunities to build upon these strengths to meet community development goals. For example, support for and use of local community facilities for Mt Owen related events (e.g. use of Mt Olive Hall and Hebden Hall for community meetings) and exploring opportunities for a workforce participation program to enhance participation in voluntary local community activities and strengthen communities. Maintaining relationship with Mt Pleasant Public School Consultation is being undertaken to develop a Community Investment Program (CIP) Partnership with the Mt Pleasant PS. The program aims to support literacy, environmental, sporting programs and an annual apprentice working bee to support school enhancement.

Building community trust in Mt Owen Glendell Operations

Through increased community consultation, MGO would like to build further trust with the nearby neighbours through increased community consultation and transparency. This may be through open days/community functions and frequency will be reviewed based on participation level. This has been addressed in Appendix A - Stakeholder Engagement Plan

http://www.mtowencomplex.com.au/en/future-mining/Pages/overview.aspx


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Addressing community Priorities/Goal/Aspirations

Education Mt Pleasant School Literacy As part of the development of the Community Investment Program (CIP) MGO plan to incorporate an annual donation to the Mt Pleasant Public School MacqLit Program.

Enterprise Development Rural Fire Service Support As part of the CIP, MGO would like to make a donation to local RFS for support for the help they provide to MGO and nearby neighbours throughout the bushfire season. There is no agreement for MGO to support this ongoing. Mt Olive Community Hall MGO would like to support the greater Glennies Creek Community by supporting the annual Mt Olive Community Ball.

Health Singleton Annual Rugby League Charity game for the Westpac Helicopter Service MGO would like to sponsor the MGO team(s) in participating in the charity rugby league game between mining companies, to raise funds for the Westpac Helicopter Service. The goal for MGO in supporting this is to support health initiatives for the local community and also site employees. There is no agreement for MGO to support this ongoing. PCYC Friday Afternoon Fun As part of the CIP MGO would like to support the PCYC in delivering a weekly program that allows kids with disabilities fun activities and interaction with other families.

Environment Mt Pleasant School Based Program with Environmental/Biodiversity Values Mt Owen Development Consent SSD 5850 has a commitment for Mt Owen to explore opportunities for the development of a school based program (with focus on environmental and biodiversity activities). The Stream Health and Water Bugs Program commenced October 2018, 2019 The Value of Trees program was delivered these programs will alternate annually.

Wildlife Aid

MGO will continue to support Wildlife Aid in the rescue, care and management of sick and injured native wildlife.

Local Need Mt Pleasant Annual Sports Focus Day As part of the development of the CIP an annual donation to Mt Pleasant Public School will be included to provide financial support for the Mt Pleasant Sports Focus Day. This will be developed further in consultation with the school as part of the CIP partnership. Samaritans Singleton Christmas Lunch MGO would like to sponsor the Samaritans Singleton Christmas Lunch which provides free Christmas lunch for community members from Muswellbrook to Maitland who are in need. MGO’s goal for this project is to support the underprivileged local community members. There is no agreement for MGO to support this ongoing.


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Monitoring & Evaluation

All Community investment applications must be submitted online via the Smarty Grants platform.

Community investment is reviewed as part of the annual planning process commencing in Q3.

Community aspirations will be discussed and reviewed through the CCC, feedback from stakeholders and feedback at community barbeques

Sponsorships of $10,000 require a project agreement and an annual review.

Appendix C - Community Investment

Name of Project/Activity Recipient Summary of Project/Activity

Date of

activity where

applicable

Community Investment Category

(select from drop down)

Budgeted

Cost Timing

Key Site

Contact

Friday Afternoon Fun - kids with disabilities Singleton PCYC

Free “Friday Afternoon Fun” activity for young people living with a disability

Every Friday 2020 Health $5,000 All

Melanie Dillon

Mt Pleasant School Education Support Program

Mt Pleasant School

Annual donation for education assistance kids with learning difficulties, support teacher and consumables Jan-20 Education $5,000 Q1

Melanie Dillon

Glennies Creek Group 2 RFS RFS

Donation to local RFS for support for the help they provide to Mt Owen Complex and nearby neighbours. This donation is shared between four small RFS stations Mar-20 Enterprise Development $3,000 Q1

Melanie Dillon

Wildlife Aid Inc Wildlife Aid Inc Support to assist in the care of sick and injured Native Wildlife Mar-20 Environment $2,000 Q1

Melanie Dillon

Mt Pleasant School Based Program with environmental/biodiversity values

Mt Pleasant School

2019 Stream Health and Water Bugs Environmental Program. In 2018 this funding was used to develop a school based program. The program had an environmental focus as per the Mt Owen Development Consent SSD 5850 commitment. Jun-20 Environment $3,000 Q2

Melanie Dillon

Mt Olive Community Annual Community Ball

Mt Olive Community Hall

This is a Fundraising event for the Mt Olive Hall Sep-20 Enterprise Development $1,500 Q3

Melanie Dillon

Apprentice Pay Back Program TBA

Apprentice Pay Back Program - Community Event Sep-20 Enterprise Development $5,000 Q3

Melanie Dillon

Samaritans Singleton Christmas Lunch

Samaritan’s Foundation

Lunch/ dinner for community members who are in need Sep-20 Local need $3,000 Q3

Melanie Dillon

Ranch Sorting in the Hunter Valley

Hunter Valley Ranch Sorting

Ranch Sorting in the Hunter Valley Nov-20 Local need $1,000 Q4

Melanie Dillon

Mt Pleasant School Annual Sports Program

Mt Pleasant P&C Association

These funds will be used to develop an annual sports gala day held at Mt Pleasant PS that will bring small schools together in the area - This is replacing the horse sports day. Dec-20 Health $3,000 Q4

Melanie Dillon

Community Investment Categories Total Budget

Education $5,000

Enterprise Development $9,500

Health $8,000

Environment $5,000

Local Need $4,000

Unallocated/Discretionary $12,500

TOTAL BUDGET $44,000