suni resources s.a. graphite project, balama, cabo …

SUNI RESOURCES S.A. GRAPHITE PROJECT, BALAMA, CABO DELGADO PROVINCE, MOZAMBIQUE

ENVIRONMENTAL AND SOCIAL MANAGEMENT PROGRAMME AND MONITORING PROGRAMME

Prepared for:

Prepared by:

SUNI RESOURCES S.A.

Edifício Solar das Acácias,

Avenida Julius Nyerere 4000, Loja 05,

Cidade de Maputo Mozambique

COASTAL & ENVIRONMENTAL SERVICES MOZAMBIQUE LDA

Av. Amilcar Cabral 1423 R/C Amilcar Cabral & Mao Tse Tung

Maputo Moçambique

NOVEMBER 2018

ESMPr and Monitoring Programme – November 2018

Coastal & Environmental Services ii Suni Resources S.A. Graphite Project

CES Report Revision and Tracking Schedule

Document Title:

Suni Resources S.A. Graphite Project, Balama, Cabo Delgado Province, Mozambique: Environmental and Social Management Programme and Monitoring Programme

Client Name & Address:

Suni Resources S.A. Edifício Solar das Acácias, Avenida Julius Nyerere 4000, Loja 05, Cidade de Maputo, Mozambique

Document Reference:

Status:

Draft (Revision 0.1)

Issue Date:

October 2018

Lead Author:

Dr Chantel Bezuidenhout 07/11/2018

Reviewer:

Marc Hardy 13/11/2018

Study Leader/ Registered Environmental Assessment Practitioner – Approval:

Dr Ted Avis

Report Distribution Circulated to No. of hard copies

No. electronic copies

This document has been prepared in accordance with the scope of Coastal & Environmental Services (CES)’s appointment and contains intellectual property and proprietary information that is protected by copyright in favour of CES. The document may therefore not be reproduced, used or distributed to any third party without the prior written consent of Coastal & Environmental Services. This document is prepared exclusively for use by CES’s client. CES accepts no liability for any use of this document other than by its client and only for the purposes for which it was prepared. No person other than the client may copy (in whole or in part) use or rely on the contents of this document, without the prior written permission of CES. The document is subject to all confidentiality, copyright and trade secrets rules, intellectual property law and practices of South Africa.

Coastal& Environmental Services

[email protected] www.cesnet.co.za

http://www.cesnet.co.za/


Coastal & Environmental Services iii Suni Resources S.A. Graphite Project

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

1.1 PROJECT BACKGROUND .............................................................................................................. 1 1.2 OBJECTIVES OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PROGRAMME ......... 2 1.3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT PROCESS TO DATE........................ 2

2. PROJECT DESCRIPTION ........................................................................................................................ 4 MINING METHOD ............................................................................................................................ 4

2.2 PROCESSING ................................................................................................................................. 4 TAILINGS DISPOSAL ...................................................................................................................... 4

2.4 PRODUCT EXPORT ........................................................................................................................ 4 2.5 AUXILIARY INFRASTRUCTURE .................................................................................................... 4

3. THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PROGRAMME (ESMPR) .............................. 6 3.1 INTRODUCTION .............................................................................................................................. 6 3.2 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS (ESMP) .............................................. 7

3.2.1 ............................................................................................. 7 .......................................................................................................... 7 ............................................................................................................ 7 .................................................................................................. 8

4. APPLICABLE POLICIES, LEGISLATION AND STANDARDS ............................................................... 9

4.1 LEGISLATIVE FRAMEWORK ......................................................................................................... 9 ...................................................................................................................... 9 .......................................................................................................... 12

5. ORGANISATIONAL REQUIREMENTS FOR IMPLEMENTATION ....................................................... 14

6. SPECIFIC RECOMMENDATIONS FOR PROJECT RELATED IMPACTS ........................................... 23 6.1 INTRODUCTION ............................................................................................................................ 23

7. MONITORING PROGRAMME ................................................................................................................ 39 7.1 INTRODUCTION ............................................................................................................................ 39

.................................................................................................................................. 39 ............................................................................................... 39 ................................................................................................................ 39 ........................................................................................................ 40 ........................................................................................... 40 ............................................................ 40 .................................................................................................................................... 41

7.2 REGULATORY FRAMEWORK AND POLICY GUIDELINES ........................................................ 41

7.3 MONITORING PHYSICAL ASPECTS ........................................................................................... 41 7.4 BIODIVERSITY AND ECOLOGICAL MONITORING ................................................................ 5352 7.5 SOCIAL MONITORING .............................................................................................................. 5352

8. MANAGEMENT IMPLEMENTATION AND REVIEW ......................................................................... 5756 8.1 INTRODUCTION ........................................................................................................................ 5756 8.2 TRAINING AND AWARENESS PROGRAMMES ...................................................................... 5756 8.3 EMERGENCY PREPAREDNESS AND RESPONSE ................................................................ 5857 8.4 CHECKING AND MONITORING ............................................................................................... 5958

8.5 PERFORMANCE OBJECTIVES AND TARGETS ..................................................................... 5958 8.6 ON-GOING INSPECTIONS AND CONTINUOUS IMPROVEMENT ......................................... 6059 8.7 INTERNAL AUDITS ................................................................................................................... 6059

8.8 INCIDENTS REPORTING, NON-COMPLIANCE AND CORRECTIVE ACTION ...................... 6059 8.9 MANAGEMENT REVIEW .......................................................................................................... 6160 8.10 FINANCIAL RESOURCES ......................................................................................................... 6261 8.11 EXTERNAL ENVIRONMENTAL AUDITING AND VERIFICATION ........................................... 6261

9. STAKEHOLDER ENGAGEMENT ...................................................................................................... 6362 9.1 INTRODUCTION ........................................................................................................................ 6362


Coastal & Environmental Services iv Suni Resources S.A. Graphite Project

9.2 NATIONAL LEGISLATION ON STAKEHOLDER ENGAGEMENT............................................ 6362

9.3 STAKEHOLDER ENGAGEMENT PLANNING .......................................................................... 6362

9.4 PROPOSED STAKEHOLDER ENGAGEMENT PLAN .............................................................. 6463 9.5 EXTERNAL COMMUNICATIONS AND GRIEVANCE MECHANISM........................................ 6564

10. MINE CLOSURE AND DECOMISSIONING .................................................................................. 6665 10.1 WHY A Preliminary Mine Closure Plan is required .................................................................... 6665 10.2 TARGET Closure Outcomes AND Objectives ........................................................................... 6665

10.3 SITE SPECIFIC Closure Outcomes, Objectives and Targets.................................................... 6867 10.4 APPLICABLE MOZAMBICAN STANDARDS............................................................................. 6867 10.5 DECOMMISSIONING, REHABILITATION AND CLOSURE OF SPECIFIC COMPONENTS ... 6867 10.6 SOCIAL COMPONENTS OF CLOSURE ................................................................................... 7271 10.7 POST CLOSURE MINE SITE INSPECTION, ENVIRONMENTAL MONITORING AND

REPORTING ........................................................................................................................................... 7372

10.8 CALCULATION OF FUTURE FINANCIAL CLOSURE LIABILITY............................................. 7574


Coastal & Environmental Services v Suni Resources S.A. Graphite Project

LIST OF TABLES Table 1.1: Reports produced for the updated ESIA process ............................................................ 2 Table 4.1: List of Applicable Legislation .......................................................................................... 9 Table 4.2: International conventions applicable to the project ....................................................... 12 Table 6.1: Mitigation measures for project related impacts ............................................................ 24 Table 6.2: Mitigation measures for project related impacts ............................................................ 36 Table 7.1: Proposed surface and groundwater monitoring points .............................................. 4342 Table 7.2: Proposed Guidelines for Ground and Surface Water Monitoring .............................. 4443 Table 7.3: Proposed Parameters for Surface Water Monitoring .................................................... 44 Table 7.4: Proposed Parameters for Mine Effluent Standards ....................................................... 44 Table 7.5: Potable Water Quality Guidelines ................................................................................. 45 Table 7.6: Process Effluent Discharge Guidelines ..................................................................... 4746 Table 7.7: Sanitary Effluent Discharge Guidelines applicable to the project .................................. 47 Table 7.8: Water Monitoring Frequency .................................................................................... 4847 Table 7.9: Acceptable dust fall rates as measured at and beyond the boundary of premises where dust originates .............................................................................................................................. 49 Table 7.10: Ambient air quality guidelines for applicable pollutants and various international organisations as accepted by the World Bank (IFC, 2007). ........................................................... 49 Table 7.11: Monitoring Compliance for waste management ...................................................... 5251 Table 10.1: Sensitivity Ranking ................................................................................................. 7574 Table 10.2: Master rates for rehabilitation ................................................................................. 7877 Table 10.3: Weighting Factors .................................................................................................. 7877 Table 10.4: Specialist study requirements ................................................................................. 7978 Table 10.5: Projected project closure liability costs ................................................................... 7978

LIST OF FIGURES

Figure 1.1: Location of the proposed Balama Central Graphite Mine, Cabo Delgado Province, Mozambique ................................................................................................................................... 1 Figure 5.1: Senior Management Organogram ............................................................................... 14 Figure 5.2: Mining Department Organogram ................................................................................. 14 Figure 5.3: HSEC Department Organogram .................................................................................. 15 Figure 5.4: Processing Department Organogram .......................................................................... 16 Figure 5.5: HR Department Organogram ...................................................................................... 17 Figure 7.1: Location of surface and groundwater monitoring points .............................................. 42 Figure 7.2: Proposed noise monitoring stations ........................................................................ 5251 Figure 10.1: The integrated mine closure planning approach as recommended by the ICMM (2008) ................................................................................................................................................. 6766 Figure 10.2: Cross section of the Balama Central Graphite Project waste dump design showing the angles of the slopes rehabilitated progressively with mining operations. ................................... 6968


Coastal & Environmental Services vi Suni Resources S.A. Graphite Project

LIST OF ABBREVIATIONS

ACRONYM MEANING

AMD Acid Mine Drainage

ANZECC Australian and New Zealand Environment and Conservation Council

ARA Administração Regional de Águas

ASTM American Society for Testing and Materials

BFD Bird flight diverters

BMWP British Biological Monitoring Working Party

CCME Canadian Council of Ministers of the Environment;

CES Coastal & Environmental Services

CESMP Construction Phase Environmental and Social Management Plan

CLO Community Liaison Officer

D/PESMP Design and Planning Phase Environmental and Social Management Plan

DESMP Decommissioning Phase Environmental and Social Management Plan

Del S

Sulphur speciation results indicate that a considerable proportion of the total sulphur consists of neither sulphide sulphur nor sulphate sulphur. This sulphur is termed “del S” and probably consists of thiosulphates that are intermediate products of sulphide oxidation and are associated with acid potential.

DHS Daily Health and Safety Dialogues

DWAF Department of Water Affairs and Forestry;

E&S Environmental & Social

ECO Environmental and Compliance Officer

ES Environmental Superintendent

EHS Environmental, Health and Safety

EHSC Environmental, Health, Safety and Community

EHS-M EHS Manager

EPCM Engineering, Procurement, Contractor Management

EPCM Engineering, Procurement, Construction Management

EPR Emergency Preparedness and Response

ESAP E&S Action Plans

ESIA Environmental and Social Impact Assessment

ESHIA Environmental, Social and Health Impact Assessment

ESMP Environmental and Social Management Plan

ESMPr Environmental and Social Management Programme

ESMS Environmental and Social Management System

FAO (Food and Agriculture Organisation

GHG Greenhouse Gas

GM General Manager

H&S Health & Safety Section Head

HAZOP Hazard and Operability Study

HMC Heavy Minerals Concentrate

HSEC Health, Safety, Environment and Community

I&AP interested and affected parties

ICRC International Committee of Red Cross

IEC International Electrotechnical Commission


Coastal & Environmental Services vii Suni Resources S.A. Graphite Project

ACRONYM MEANING

IFC International Finance Corporations

KPI Key Performance Indicator

LIMS Low-intensity magnetic separation

LTV Long-term trigger value

MITADER Ministry of Lands, Forestry and Rural Development (Ministério da Terras, Ambiente e Desenvolvimento Rural)

MM Mine Manager

MSDS Material Safety Data Sheets

MSP Mineral Separation Plant

Mt Mega tonne

Mtpa Mega tonne per annum

OECD Organization for Economic Co-operation and Development

OESMP Operational Phase Environmental and Social Management Plan

OHS Occupational Health & Safety

OP Operating Procedure

PAG Potentially Acid Generating

PPE Personnel Protective Equipment

PPP Public Participation Process

PS Performance Standards

QA/QC Quality Assurance / Quality Control

RAP Resettlement Action Plan

RM Resident Manager

RSA Resettlement and Social Affairs Manager

RZMP Riparian Zone Management Plan

SASS5 South African Scoring System Version 5

SO Safety Officer

SCC Species of Conservation Concern

SEP Stakeholder Engagement Plan

SH Section Head

SLM Sound Level Meter

SOP Standard Operating Procedures

STV Short-term Trigger Value

TM Technical Managers

TSF Tailings storage facility

TSS Total Suspended Solids

UK DWI United Kingdom Drinking Water Inspectorate;

WCP Wet Concentrator Plant

WHO World Health Organization

WRD Waste Rock Dump

ZOI Zone of Influence


Coastal & Environmental Services 1 Suni Resources S.A. Graphite Project

1. INTRODUCTION 1.1 PROJECT BACKGROUND

Battery Minerals are currently working on two graphite projects in the Cabo Delgado Province, Mozambique (Figure 1.1). These are the Balama Central Graphite Project next to the Syrah Resources Graphite Mine, and the Montepuez Graphite Project north of Montepuez City. This report, deals with the Balama Central Graphite Project which comprises of two deposits; Lennox and Byron.

Figure 1.1: Location of the proposed Balama Central Graphite Mine, Cabo Delgado Province, Mozambique

The final surface footprint of the Byron pit is designed to be approximately 22 ha and the final surface footprint of the Lennox pit is designed to be approximately 30 ha. It is estimated that the pits will be approximately 140 m below ground level. A mining schedule for the two deposits has been developed. Mining will commence at the Lennox pit for the first twenty three years. Conventional open pit mining methods will be used. A nine month pre-strip period is scheduled to provide enough waste for the construction of the Run-of-Mine (ROM) pad. The Byron pit will be mined from Year 2 to Year 4 and will then cease until Year 22. Mining at the Byron pit will then recommence at Year 22 and will be mined until Year 34. Following the depletion and closure of the Lennox and Byron pits at the end of the 34 years of mine life, long-term stockpiles built over the mine life will be exclusively processed by the plant for an additional 42 years. Once these stockpiles deplete the mine will close. The mineralised waste pile,



which generally contains graphite bearing material between with grades between 3.5-5%, will be processed at the end of the mine life if economically viable at that time. A description of the project and associated infrastructure is provided in Chapter 2 of this document. This report is structured as follows:

Chapter 1 provides an overview of the Balama Central Graphite Project and details of the team members that drafted this report.

Chapter 2 provides a summary of the project description.

Chapter 3 provides a background to the ESMPr and details of relevant management plans required in each phase of the operation to ensure compliance with relevant standards.

Chapter 4 provides the applicable legislation and relevant local and international policies and standards.

Chapter 5 contains the organisational capacity and human resources requirement to implement the ESMPr.

Chapter 6 identifies the specific recommendations for project related impacts that would be required to manage the range of identified environmental and social impacts.

Chapter 7 describes the monitoring and review procedure implemented by the management team.

Chapter 8 provides information on the management, implementation and review of this ESMPr.

Chapter 9 contains community engagement and on-going consultation and communication requirements.

Chapter 10 provides a preliminary closure plan for the proposed development. 1.2 OBJECTIVES OF THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PROGRAMME This document represents the company’s commitment to addressing and managing the potential negative and positive impacts associated with the construction, operation and closure phases of the Balama Central Graphite Project in a systematic, efficient and effective manner. The objectives of the document are to: 1. Ensure the project is compliant with applicable national environmental and social legal

requirements. 2. Identify the required mitigation measures that are needed in order to reduce negative

Environmental and Social (E&S) impacts and enhance positive ones. 3. Ensure that all mitigation measures and recommendations identified during the Environmental,

and Social Impact Assessment (ESIA) are incorporated into documents that are referenced and expanded if necessary during the various phases of the project.

4. Outlines management structures so that the individuals responsible for the implementation of the ESMP has the relevant skills to do so and are aware of their responsibilities.

5. Identify relevant documents and procedures to be developed that will facilitate the implementation of the ESMPr.

1.3 ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT PROCESS TO DATE

Suni Resources contracted Coastal & Environmental Services (CES) to conduct an Environmental and Social Impact Assessment (ESIA), to local Mozambican standards. Table 1.1 presents the volumes that were produced during the ESIA process. Table 1.1: Reports produced for the updated ESIA process

REPORT PRODUCED DATE AUTHORS

Scoping

EPDA and Terms of Reference June 2018 Ms Tarryn Martin & Dr Ted Avis (CES)

Specialist Studies

Noise Impact Assessment October 2018 AirShed Planning Professionals (Pty) Ltd



REPORT PRODUCED DATE AUTHORS

Aquatic Assessment March 2018 Mr Justin Green (CES)

Botanical Assessment March 2018 Ms Tarryn Martin (CES)

Hydrogeology Assessment October 2018 Mr George van Dyk (Exigo)

Geochemistry Assessment October 2018 Mr Terry Harck (Solution H+)

Soil, Land and Natural Resource Use Assessment

June 2018 Ms Rosalie Evans & Mr Roy de Kock (CES)

Social Impact Assessment June 2018 Mr Marc Hardy (CES)

Terrestrial Fauna Baseline Assessment June 2018 Ms Amber Jackson & Ms Hayley Katz (CES)

Waste Assessment July 2018 R. Almanza & Dr K. Whittington-Jones (CES)

Traffic Impact Assessment June 2018 Mr Gregory Shaw (CES)

Environmental, Social and Health Impact Assessment

Environmental, Social and Health Impact Assessment

October 2018 Ms Tarryn Martin & Dr Ted Avis (CES)

Environmental and Social Management Programme and Monitoring Programme

Environmental and Social Management Programme and Monitoring Programme (this report)

October 2018 Dr Chantel Bezuidenhout & Dr Ted Avis (CES)

The above studies have informed the development of this ESMPr.



2. PROJECT DESCRIPTION

MINING METHOD Conventional open pit mining methods will be employed using 90t excavators and 40t articulated dump trucks. The upper saprolite layer (thoroughly decomposed and porous rock that is produced in tropical and humid conditions) is expected to be freely dug down to an estimated 5-20 m depth for the pits. The fresh rock residing below the saprolite layer will then require blasting and further excavation using the 90t excavators. Ore will be loaded onto 40t articulated dump trucks and transported to either the Waste Rock Dump (WRD), Long-Term Stockpiles (LTSP) or the ROM pad located north of the two pits. 2.2 PROCESSING Front end loaders will feed the plant via a ROM bin. The ore is then crushed in the primary crusher and transported via conveyor into the crushed ore bin where it is reclaimed and fed by conveyor into the primary mill. After primary milling the ore (now in a slurry with water), it is passed over classification screens with any oversize particles recycled back to the primary mill for re-feed. The undersize material reports to the flotation circuit, where it is fed into the rougher conditioning tank and then passes through a series of flotation stages (rougher and cleaner stages including regrind). The concentrate is then de-slimed by cyclones to produce a graphite concentrate in solution which reports to the concentrate storage tank. The by-product (or tails) from the flotation circuit is pumped to the tailings thickener. The concentrate stored in the concentrate storage tank is filtered and moved to a concentrate stockpile by front end loader. The filtered concentrate is then dried and screened to produce a number of graphite size products. Each dry graphite product will be stored in dedicated storage bins before being packaged into 1 tonne bulk bags ready for dispatch by road to port for shipment.

TAILINGS DISPOSAL The tailings produced by the rougher and cleaner flotation cells are fed to the tailings thickener where flocculent is added to accelerate the settling and separation of solids from water. The thickened tailings are then pumped via a pipeline and ring main1 to the Tailings Storage Facility (TSF) for disposal. Thickener overflow water gravitates to the process water pond and is recycled within the processing plant. The TSF is designed to store 15-20 million tonnes of tails. The TSF incorporates an underdrainage system to reduce the pressure head acting on the compacted soil liner to reduce seepage, increase water recovery, increase tailings densities and improve the geotechnical stability of the embankments. Tailings will be discharged by sub-aerial deposition methods using spigots located at regularly spaced intervals on the embankment crest. Supernatant water will be removed via submersible pumps and pumped back for re-use in the plant process circuit. 2.4 PRODUCT EXPORT The dried concentrate will be transported to Pemba in 1 tonne bulk bags loaded onto flat-bed trucks. A load of 30 tonnes per flat-bed truck has been assumed. The product will be delivered to a storage area at the port of Pemba, prior to shipping. 2.5 AUXILIARY INFRASTRUCTURE In addition to primary infrastructure, the project will also require infrastructure related to auxiliary services including the following:

Two weirs, one located north-west of the pits on the Lapua stream and the other south-east of the pits on the Namituca River;

1 An arrangement of pipes forming a closed loop into which the thickened tailings will be fed and whose points of draw-off are supplied by flow from two directions.



A pipeline or channel to divert excess water from Lapua stream to the Namituca River in order to avoid water flooding the pits;

A raw water storage tank situated at the processing plant;

Mine accommodation village to provide construction and operational phase accommodation to employees;

A water treatment plant situated at the mine accommodation village to provide employees with potable water;

A wastewater treatment plant, situated at the mine accommodation village;

High speed generators for the provision of power;

A haul road used to transport product from the pits to the Long-Term Stockpile (LTSP) and then on to the processing plant;

Major and minor access roads to provide access to the mine accommodation village, TSF, weirs, powerline, etc.;

Sand quarry for the provision of construction material;

Landfill site for the disposal of non-recyclable materials; and

Additional mine buildings and supporting infrastructure as listed below: o Ablution building o Administration office o Bulk lubricant and hydrocarbon storage facility o Change house (toilets and clothes washing facilities) o Control Room and communications building o Core logging facility o Emergency Response area o Explosive storage o Gatehouse and security o Heavy and light vehicle refuelling facility o Heavy vehicle wash down facility o Heavy vehicle workshop o Laboratory o Light mobile equipment workshop o Lunch room o Mine contractors medical facilities o Mine office o Oil water separation facility o Plant office o Reagent store o Sample preparation o Site medical facility o Training Room o Tyre change facility o Vehicle wash down facilities o Warehouse o Water truck filling o Workshop including mechanical workshop, boiler maker workshop, electrical workshop,

instrument room, tool store, hydraulic store, dirty equipment area and repair equipment area. The above activities and operations are covered by this report.



3. THE ENVIRONMENTAL AND SOCIAL MANAGEMENT PROGRAMME (ESMPr)

3.1 INTRODUCTION The ESIA is normally conducted prior to preparation of the final design and operational details of the development. While it is possible to identify and assess potential E&S impacts at this early stage, in many cases, the outcome of the assessment process results in modification of the original conceptual plans. Thus, while it is possible to identify a number of specific mitigation measures applicable to the construction and operational phases at the time of completing the ESIA, it is necessary to allow for modification of these mitigation measures as the plans for the development mature. This document (ESMPr) summarises Suni Resources’ commitments to address and mitigate risks and impacts identified as part of the ESIA process, through avoidance, minimisation, and compensation/offset. It establishes mitigation measures which defines desired outcomes and actions to address the issues raised during the ESIA. These measures also inform monitoring requirements and responsibilities for implementation. More specifically, the ESMPr should include the following components:

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

Monitoring: Environmental monitoring during project implementation provides information about key environmental aspects of the project, particularly the environmental impacts of the project and the effectiveness of mitigation measures.

Capacity Development and Training: To support timely and effective implementation of mitigation measures, the ESMPr must draw attention to the existence, role, and capability of environmental departments at various Government levels. The ESMPr must provide a specific description of institutional arrangements, specifying who is responsible for carrying out the mitigation and monitoring measures.

Implementation Schedule and Cost Estimates: For all three aspects (mitigation, monitoring, and capacity development), the ESMPr provides an implementation schedule for measures that must be carried out as part of the project, and in addition, the capital and recurrent cost estimates and sources of funds for implementing the ESMPr may also be included.

An ESMPr does not present technical details and specifications for managing construction or operational phase impacts since many of these have not been finalised at this stage. Rather, it maps out broad management initiatives and principles, and establishes a framework within which environmental issues are managed at various stages of the project. Although much of this responsibility is passed on to various third parties, such as contractors for construction related impacts or sub-contractors for various operational activities, the ultimate responsibility for ensuring compliance with the objectives of the ESMPr rest with Suni Resources and its project managers. In large and complex projects it is usually necessary to expand and add to the environmental framework, management initiatives and principles developed in the ESMPr for the construction, operation and decommissioning phases of a project as the project evolves. This is required in order to update the ESMPr using specific project details regarding the various actions that will take place once the project is implemented. These specific details are used to develop the necessary phase and action specific Environmental and Social Management Plans (ESMP) discussed in Section 3.2. The ESMPr therefore ensures that: 1. During project planning and design all mitigation measures identified during the ESIA that could

be incorporated into the layout or design of the project are considered. 2. During construction all constraints, restrictions and actions required to minimize construction

related impacts are implemented. 3. During commissioning and operation, detailed operating procedures are developed so that all



constraints, restrictions and actions required to minimize impacts caused by commissioning and operation are developed, implemented and monitored for all aspects of the project.

4. During the life of the project continue to enhance positive impacts and ensure mitigation for negative impacts. An important component of this is monitoring, evaluation and communication of findings, and adherence to the principle of continued improvement.

5. During decommissioning, detailed procedures are developed to ensure that the project area is rehabilitated to an acceptable and previously agreed-to level.

3.2 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLANS (ESMP) The key objectives of the ESMPs discussed below is to ensure that the proposed project and its associated infrastructure, through the entire life of the project from design through to post-closure:

Adheres to Mozambican law.

Adheres to applicable International best Practice where relevant (specifically where local standards are absent); and

Takes due cognisance of the biophysical, social and economic environment in which the project will operate.

Further detail on the ESMPs for each phase of the project is provided below. 3.2.1 The Design and Planning Phase ESMP (D/P-ESMP) is an integral component of the project life cycle and requires interaction between the design engineers and environmental consultants to ensure that the engineers are aware of the environmental constraints that they must consider and incorporate into the final design. For the Balama Central Graphite Project, the selected contractor will finalise the detailed design for many of the components. To ensure that the E&S constraints are accommodated in the final detailed design, the selected contractors will be briefed through the production of a D/P-ESMP. The format of the D/P-ESMP is that of a checklist, to ensure that all environmental and social specifications are considered and included in the design of the development. The design phase requires ongoing and in-depth discussions between the contractor’s final design team and the company’s Environmental Manager and specialist E&S consultants.

A Construction Phase ESMP (C-ESMP) will be developed prior to the commencement of the construction phase. This document will list activities during the construction phase that are likely to have environmentally and socially significant impacts, and describe appropriate mitigation measures. Suni Resources will implement the C-ESMP for all activities that will occur during the construction phase based on local standards. This will be done to protect human health and the environment from the potential impacts of its activities, and to assist in maintaining and improving the quality of the environment.

The Operational Phase ESMP (O-ESMP) lists activities during the operational phase that are likely to have environmentally and socially (E&S) significant impacts and describes the required mitigation measures to avoid or reduce the significance of the negative impacts or enhance positive impacts. Suni Resources will implement the O-ESMP for all operational activities as required by local and international standards and guidelines. This will be done to protect human health and the environment from the potential impacts of its activities, and to assist in maintaining and improving the quality of the environment. In some cases Standard Operating Procedures (SOPs) or Method Statements will be adequate to manage certain aspects of the operation. These should focus on the measures and actions necessary to comply with specific regulations, applicable standards and recommendations contained within the O-ESMP and will also provide detail on responsibilities for implementation. For example, an SOP can be developed to manage risks associated with the handling and use of chemicals and pesticides. In addition, E&S



Action Plans (ESAP) may be developed to fill in the gaps in existing management programmes or SOPs to ensure consistency or to provide immediate remedy and timely closure of specific items.

The decommissioning phase ESMP (D-ESMP) is typically encountered within extractive industries such as the Balama Central Graphite Project. As the final phase in the project cycle, decommissioning may present positive environmental opportunities associated with the return of the land for alternative use and the cessation of impacts associated with operational activities. However, depending on the nature of the operational activity, the need to manage risks and potential residual impacts may remain well after operations have ceased. Examples of potential residual impacts and risks include contamination of soil and groundwater and old (unserviceable) structures. As such a Closure and Rehabilitation Plan forms an integral part of the D-ESMP. The development of a Closure Plan is also a requirement of Mozambican legislation (Environmental Framework Act (Law No. 20/97, 1 October 1997)). In line with international best practice, a Conceptual Mine Closure Plan has been developed as part of this report and is included in Chapter 10 below. A Conceptual Closure Plan is intended to communicate the expected outcomes and goals of the closure activities and is then subject to refinement to create a detailed Closure Plan that includes timeframes and milestones, detailed methodologies for achieving goals, more detailed budgets, rehabilitation and site amelioration specifications, and monitoring and validation processes. This additional detail can only be added, after the ESIA process has been completed, once the engineering designs of all components of the project and the mine plan have been finalised. A Conceptual Closure Plan is developed at this early stage for use during pre-feasibility, feasibility and design phases of the project, and to inform the EIA process. Its effective period may be a few years, but if well-defined and based on effective community and stakeholder engagement, it may not change much during the first five years of construction and mining. However, the Closure Plan must be reviewed every five years over the life of the mine, in order to accommodate any changes in the mining area, approaches to mining and other technical refinements that are likely to take place during the start and ramp-up phases of the project. These changes would also trigger a revision of the Closure Plan budget to ensure that sufficient funds are available to cover any additional costs associated with closure activities. A key element of successful development and implementation of a Mine Closure Plan is regular engagement with local authorities and community leaders throughout the life of the mine. This will ensure that their expectations regarding the post-mining land use of the area as well as any mine infrastructure are shared and considered during closure planning.



4. APPLICABLE POLICIES, LEGISLATION AND STANDARDS

4.1 LEGISLATIVE FRAMEWORK

A list of legislation applicable to the Balama Central Graphite Project is provided in Table 4.1 below. It should be noted that the list provided is not exhaustive and has been restricted to documents that have direct relevance to either the environment and/or communities. Table 4.1: List of Applicable Legislation

LEGISLATION DATE OF

ENACTMENT APPLICABILITY TO THE PROJECT

NATIONAL LEGISLATION

Constitution of the Republic of Mozambique

2004 Dictates the right to environment for each citizen in section 7.1: “All citizens shall have the right to live in a balanced environment and shall have the duty to defend it”.

INDUSTRIAL LICENSING AND LABOUR LAW

General Investment Act Law 3/1993 of June

24th Mining Corporations are required to abide by the commercial laws of Mozambique.

Labour Act Law no. 23/2007 of

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

ENVIRONMENTAL FRAMEWORK LAW, EIA, INSPECTIONS AND AUDITS

Environment Act

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

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

Environmental Impact Assessment Regulations

Decree 54/2015 of December 31st

The process and rules to be followed when conducting an Environmental Impact Assessment.

Addendum to the EIA Process Regulations no.

45/2004

Ministerial Diploma 198/2005 of

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

General Directive for EIA Ministerial Diploma 129/2006 of July

19th

General Directive for the Public Participation Process in the EIA

process

Ministerial Diploma 130/2006 of July

19th

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

Regulations for Environmental Inspections

Ministerial Decree 11/2006 of June

15th

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

Auditing and monitoring form crucial parts of the ESIA process and,

as such, this act directly impacts upon the regulatory requirements to which the proponent must adhere.

Environmental Audit Process

Ministerial Decree 32/2003 of August

12th

Extracts from the Penal Code

16 September 1886

These regulations define the consequences of environmental non-compliance and infringement on the proponent.

Norms of application of fines and other sanctions

prescribed in the Environmental legislation

Ministerial Diploma 1/2006 of January

4th



LEGISLATION DATE OF


Law on Crimes against the Environment

Ministerial Diploma of 2006/7

SOCIAL

Protection of the Mozambican Cultural

Heritage

(Law No. 10/88 of December 22)

The purpose of this law is to protect the tangible and intangible assets of the Mozambican cultural heritage – e.g. monuments, buildings of historical, artistic and scientific sites and natural elements of scientific interest and particular aesthetic. This law extends to any cultural assets that may be discovered on Mozambican territory, in particular, in the soil, subsoil, beds of inland bodies of water or the continental shelf.

Heritage Resources may be disturbed and impacted by the mining activities, and as such fall under the ambit of these regulations.

Archaeological Heritage Decree 27/1994 of

July 20th Heritage Resources may be disturbed and impacted by the mining activities and, as such, fall under the ambit of these regulations. Regulation on the

Protection of the Archaeological Heritage,

Decree 27/97 of July 20th

Regulation of Resettlement Process

Resulting from Economic Activities

Decree 31/2012 of August 8th

These regulations formulate the procedures for any resettlement in Mozambique, and especially articulate the assistance required from Government during a resettlement process. They are used during the ESIA process to inform all project affected communities of their rights with regard to economic displacement. The articles in this regulation is used to structure most of the RAP procedures at community level if and when required.

Land Act Law19/97 of October 1stv

The Land Act provides the legal framework for land ownership, as well as the control of land and natural resources in Mozambique. The process of determining land rights is also explained by this law. As Kenmare Resources will require land use rights (DUAT) in order to establish the proposed mining operation, this law is relevant.

Land Act Regulations Decree 66/1998 December 8th (Amended by

Decree 1/2003 of February 18th)

Land appropriation and ownership rights are pivotal to the project implementation. Key aspects of the regulations include cconsultations between the applicants for land and the local community are mandatory before a decision to grant title use is made by the provincial governor or higher authority.

Land Planning Act Law 19/2007 of July

18th

The Land Planning Act (Law 19/2007 of July 18) creates a legal framework for land planning. The Act defines the mechanisms for preparation, approval, implementation, monitoring and supervision of land-use plans, as well as the responsibilities associated.

Regulation of the Land Planning Act

Decree no. 23/2008

This Act sets out measures and regulatory procedures to ensure the occupation and rationale and sustainable use of natural resources, appreciation of the diverse potential of each region, the infrastructure, urban systems and promoting national cohesion and population safety.

WATER RESOURCES

Water Act Law 16/1991 of August 3rd

The statutory legal framework for water and sanitation.

Water License and Concessions Regulations

Decree 43/2007 of October 30th A water use license or concession will be required for the construction

and operation of this project. Water Policy

Decree 46/2007 of August 21st

WASTE, EFFLUENT AND EMISSION

Regulation on Environmental Quality and

Effluents Emission

Decree No. 67/2010 amending

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

Decree 67/2010)

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



LEGISLATION DATE OF


Waste Management Regulations

Ministerial Decree 13/2006 of June

15th

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

Regulations on the management of municipal

solid waste

Decree 94/2014 of December 31st

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

Regulation on management of

hazardous waste

Decree N.83/2014 of December 31st

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

Regulations on the management and control

of plastic bags

Decree 16/2015 of August 5th

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

BIODIVERSITY

Wildlife and Forestry Act Law 10/1999 of July 7th

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

Wildlife and Forestry Regulations

Decree 10/1999 of July 6th

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

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

Chapter 3 on Sustainable Forest Resources, Exploitation Regimes and Sustainable Wildlife Conservation Regimes.

The Regulations on the Law of Wildlife and

Forestry

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

National Strategy and Action Plan for the

Conservation of Biological Diversity for Mozambique

Formulated by MICOA (now

MITADER) and passed by the

Council of Ministers in August 2003

Biodiversity and wildlife management will form part of the mitigation measures for the project

Regulations on Pesticide Management

Decree No. 6 of 2009

The Regulation aims at guaranteeing the human health and the environmental quality standards are upheld, according to environmental legal proceedings approved by Law No. 20/97. It includes the management, composition, classification and inspections to be carried out on pesticides. The annexes specify offences and penalties to be paid for illegal activity.

Control of Exotic Invasive Species Act

Law 25/2008 of 01 July

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

MINING ACTIVITIES

Technical Health and Safety Regulations of Geological and Mining

Activities

Decree No. 61/2006 of 26

December

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

Hiring regulations of Foreign Nationals in the Oil Sector and Mining

Decree n.º63 / 2011 of 7 December

Establishes the legal framework including the mechanisms and procedures for employing foreign nationals under the Petroleum and Mining Law, as long as those activities have been approved by the competent authority. Decree No. 63/2011 defines, that for short-term activities not exceeding 180 days, hiring of skilled foreign workers can be carried out without a permit from the Minister of Labour, provided the Ministry of Labour is notified within 15 days of the employee entering in the country.

The Mining Law 20/2014 of 18

August Law No. 20/2014, of 18 August ( "Mining Law"), which entered into force on the same date the Mining Act (Law No. 14/2002 of 26 June)



LEGISLATION DATE OF


was repealed, intends to set the legal framework for the mining sector. It aims to ensure greater competitiveness and transparency, preserve the environment, ensure the protection of the rights and obligations of the holders of mining rights, safeguard national interests and benefit the communities.

Mining Law Regulations Ministerial Decree 31/2015 of 31

December

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

Environmental Regulations for Mining

Activities

Ministerial Decree 26/2004 of August

20th

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

Mining Working Regulations

Decree 13/2015 of 03 July

The new regulation of mining work addresses a major gap in the legislation on professional work in this area that has generated employment for Mozambican citizens, although there are also a significant number of foreign workers in the sector. To fill the gap in the legislation, the Mozambican Government has approved the Mining Work Regulation through Decree 13/2015 of 3 July. The new regulation governs labour relations between mining and oil sector employers, including subcontractor companies, and their employees, whether Mozambican or foreign. It also provides for supervision of employment conditions.

Mozambique is a signatory to a number of international conventions. Those potentially applicable to this project are summarised in Table 4.2 below.

Table 4.2: International conventions applicable to the project

CONVENTIONS RATIFIED

BIODIVERSITY

Convention on International Trade and Endangered Species of Wild Fauna and Flora (CITES)

1973

Convention on Biological Diversity (CBD) 1992

Convention on Wetlands of International Importance especially as Waterfowl Habitat (Ramsar Convention)

1971

African Convention on the Conservation of Nature and Natural Resources 1968

Cartagena Protocol on Bio-safety to the Convention on Biological Diversity 2003

African Convention on the Conservation of Nature and Natural Resources 2003

Convention on the Conservation of Migratory Species of Wild Animals 2009

MARINE

United Nations Convention of the Law of the Sea (UNCLOS) 1982

Convention for the Protection, Management and Development of the Marine and Coastal Environment of the Eastern African Region

1999

The Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Dumping Convention)

1972

International Convention for the Prevention of Pollution from Ships (MARPOL) 1973

IMO Guidelines for the Control and Management of Ships’ Ballast Water to Minimise the Transfer of Harmful Aquatic Organisms and Pathogens

1997

International Convention for Control and Management of Ships’ Ballast Water and Sediments

2004

WASTE

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

1989



CONVENTIONS RATIFIED

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

1991

CLIMATE CHANGE

Kyoto Protocol to the UN Framework Convention on Climate Change 1998

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

Vienna Convention for the Protection of the Ozone Layer 1985

Montreal Protocol on Substances that Deplete the Ozone Layer 1987

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

1994

CULTURAL HERITAGE

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

OTHER

Constitutive Act of the African Union 2000

Stockholm Convention on Persistent Organic Pollutants 2001

International Convention on Civil Liability for Oil Pollution Damage 1992

Treaty Establishing the African Economic Community 1991

SADC Protocol on Mining 1997

African Charter on Human and Peoples’ Rights 1981

Convention on Safety of Life at Sea (SOLAS) 1974

It is advisable that Suni Resources develop a legal register that specifies what legislation and/or conventions will be applicable to the project and its associated activities. Any formal reporting, auditing and documentary submission activities that are required by law will need to be identified prior to the commencement of construction activity



5. ORGANISATIONAL REQUIREMENTS FOR IMPLEMENTATION This section outlines the proposed organisational structures and other activities that will be required to implement the ESMPr. This organisational structure is subject to change and is meant to ensure that the ESMPr is adequately implemented. The key management roles and functions required to manage and implement the various management instruments are discussed below. The actual titles used for each position may change once the project is implemented, but the responsibilities will largely remain unchanged. 5.1 SUNI RESOURCES ORGANISATIONAL STRUCTURE

Figure 5.1 shows the proposed structure of the Suni Resources Senior Management team. The Resident Manager (RM) will be in charge of the overall operations at the project site and will report directly to the company executive.

Figure 5.1: Senior Management Organogram

The company’s senior management is ultimately responsible for the implementation of the ESMPr and ensuring that adequate performance monitoring evaluation and corrective action requirements are fulfilled.

The organisation of the mining department is shown in Figure 5.2.

Figure 5.2: Mining Department Organogram

The Mine Manager (MM) will have responsibility for day to day administration of the mining contractor and all operational aspects of the mine, mine design and planning, as well as all geological functions carried out in the mine.



The mine establishment and ongoing mining operations will be performed by a mining contractor who will establish a workshop, warehouse and support services required for operation and maintenance of the mining fleet. The mining contractor will also be responsible for supply and management of explosives and for all drill and blast activities. The MM will have a small team of professional personnel to help manage and direct the mining contractor in respect of mine production, grade control, survey, geology, mine planning and processing. The mining contractor will be self-sufficient with a complete team on site to manage the mining contractors operations, conduct short term mine planning, implement survey control, drill and blast, operation of mining equipment and support vehicles, maintenance of equipment, supply of spares, lubricants, tyres, consumables, etc. A separate earthmoving team will also report through to the mining department. This team will undertake miscellaneous civil earthworks construction and maintenance activities from project commencement through to mine closure. This team will be established to operate and maintain a medium sized owner-operator earthmoving fleet. The fleet will be used by Suni Resources to perform the following activities:

Pioneering earthworks for construction establishment and early works.

Construction of haul road and major and minor access roads.

Construction of staged TSF wall lifts over the life of mine.

Construction of exploration drilling access tracks and pads.

Maintenance of access roads, drains and clearing of vegetation around the plant and infrastructure areas.

Mining development and support activities as required from time to time. The earthmoving team will report directly to the MM, and will be bound to the implementation requirements of the ESMPr as for any other contractor.

A Health, Safety, Environment and Community (HSEC) Department will be required to support the mining and processing operations. The proposed organisation of this Department is provided in Figure 5.3 below.

Figure 5.3: HSEC Department Organogram

The HSEC Department will be responsible for the management of all HSEC aspects, as well as external relationships with key stakeholders such as communities and government. In addition:

The HSEC team will be responsible to ensure that the mining, processing and services operations are carried out in accordance with statutory obligations and relevant legislation, permits, and licenses.

The HSEC team will monitor safety on the mine site and ensure that safe work practises are being carried out by both company personnel and contractors and that they are documented in accordance with the site specific procedures and safety management plans.

The HSEC department will be also responsible for monitoring environmental management plans



and compliance with statutory and licence obligations and ensuring that any non-compliance is reported and promptly rectified.

Furthermore the HSEC department will liaise with stakeholders in the local community to ensure good levels of communication are maintained at all times so that any concerns can be communicated to the Resident Manager (RM).

The HSEC department will manage external relations with relevant government bodies and stakeholders in relation to health, safety, environment and community relations

Figure 5.4 shows the proposed organisation of the Processing Department.

Figure 5.4: Processing Department Organogram

The Process Manager will have responsibility for all operational aspects of the process plant and tailings facilities, as well as the production, drying, bagging and loading of final concentrates at the mine site. The process team will all be company personnel broken down into functional groups as follows:

Process Management and Technical: This team comprise metallurgists and process technicians, production planning and production supervisors. They are responsible for the plant operating and producing in accordance with the production plan and budget to produce the required amount of graphite concentrate at the designated quality and material criteria.

Laboratory: This team provide round the clock coverage and perform the sample preparation and laboratory services, continuously analysing feed material to the plant, plant operations (stage by stage operational data/graphite recoveries etc.) and product analysis (product size/grade) to track process plant performance and product quality.

Process Operations: The process operations team operate the process plant from the ore feed into the process plant through all process plant unit operations until final tailings deposition and



concentrate loadout. The process operators are also responsible for overseeing and operating water recovery systems from the raw water dam and the tailings dam decant recovery systems.

Process Maintenance: The engineering and maintenance group carry out regular preventative maintenance as well as emergency maintenance and repairs. This team is responsible for maintenance planning and scheduling to set planned shutdown dates for major maintenance activities such as pump wet end replacements, ball mill relines, screen deck changes, crusher relines, etc.

A Human Resources (HR) Department will be required to support the mining and processing operations. The proposed organisation of this Department is provided in Figure 5.5 below.

Figure 5.5: HR Department Organogram

The HR Department will be responsible for the management of personnel and industrial relations practises, employee recruitment, employment contracts, performance and pay reviews, training and development. This HR team will be responsible to ensure the HR functions are carried out in accordance with all statutory obligations and relevant legislation. The HR Manager will report directly to the RM. The HR department will manage external relations with relevant government bodies and unions and will interact with recruitment agencies as required. 5.2 ESMPr IMPLEMENTATION ROLES & RESPONSIBILITIES

The responsibility of the RM will be to ensure that all personnel abide with the requirements of the ESMPr, and that all areas of the project are constructed and operated in such a manner that they meet all specified legal and contractual HSEC requirements. All senior technical managers will report directly to the RM, and all will ensure that all areas of the operations are designed, constructed, operated and decommissioned to meet the specified E&S parameters, contractual and legal requirements.

The role of the Technical Managers (TM) will be to ensure that all areas of the project are designed, constructed and operated to meet the specified contractual and legal requirements. The TM will report directly to the RM and are comprised of the following designations:

Mine Manager

Process Manager

HR Manager

Finance Manager

Supply Manager



HSEC Manager

Administration Manager Please note that the appointed construction contractor TM will also assume these responsibilities for the duration of the construction and commissioning activities.

Management of the project HSEC issues will be the responsibility of the HSEC Department headed by an HSEC Manager (HSEC/M). The HSEC Department is responsible for ensuring implementation and compliance of all HSEC actions specified in this ESMPr relating to all project operations. The HSEC/M will report directly to the GM, and is responsible for ensuring that the project operates in a socially responsible manner in all aspects of its operations. Specific roles and responsibilities of the HSEC/M are expected to be as follows:

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

Implementation of the project’s HSEC plans and relevant EMP aspects.

Continuous review of the suitability and effectiveness of the activities described in all HSEC documentation.

Oversee liaison activities with local stakeholders.

Ongoing liaison with appropriate project personnel.

Maintain and manage the HSEC monitoring programme.

Ongoing reporting to the senior management team.

Oversight function to ensure integration of health, safety and security with environmental management and social development activities.

The HSEC/M will report directly to the RM and will be responsible for the management of all aspects related to resettlement, social management, community and skills development, implementation of the company Social Development Plan (SDP) - this plan is to be initially developed in the construction period - as well as all stakeholder engagement processes going forward. The HSEC/M will ensure successful on-site implementation and supervision of stakeholder engagement and coordinate community and skills development initiatives. The HSEC/M will have the following roles and responsibilities:

Ensuring that all the environmental authorisations and permits required in terms of the applicable legislation have been obtained prior to activities commencing on the ground.

Reviewing and approving method statements with input from the TM in order to ensure that the environmental specifications in the ESMPr is adhered to.

Conducting environmental awareness training.

Ensuring implementation and compliance with the ESMPr and various internal SOPs.

Keeping accurate and detailed records of all activities on site.

Monitoring and verifying that environmental impacts are kept to a minimum.

Monitoring and regulating compliance by all personnel and contractors.

Continued and ongoing liaison with Senior/Technical Managers and contractors through the HSEC Department regarding environmental compliance.

Recommending actions to the TM and RM in the event of non-compliance.

Recommending the removal of, or issuing spot and penalty fines to contractors for person/s and/or equipment not complying with the specifications of the ESMPr.

Execution of the environmental components of the E&S Monitoring Programme.

Ensuring implementation of the Emergency Response Plan.

Ensuring that all sites disturbed during all phases of the operation are effectively rehabilitated as soon as possible.

Ongoing liaison with national and local government agencies and regulatory authorities.

Implementing the Community Health and Safety Management. Plan

Continuous review of the suitability and effectiveness of the activities described in all HSEC documentation.

Plan, mobilise and allocate resources for the implementation of the ESMPr and its necessary



Monitoring Programme, Resettlement Action Plan (RAP) and SEP.

Be responsible for the financial management and delivery of entitlement payments through the approved process for compensation.

Play a role in the allocation of alternative farmland if necessary.

Liaise with local government on the implementation of the RAP and SDP.

Address grievances through the established Grievance Mechanism.

Provide regular feedback to the District and Provincial Government on the progress of the RAP and SDP.

Provide ongoing reporting to the senior management team and the board. In addition, the HSEC/M will be responsible for rehabilitation activities across the mine site, as well as managing the environmental aspects of the water, tailings and rock dump facilities. The HSEC/M will may be assisted by an Environmental Superintendent (ES), an Environmental and Compliance Officer (ECO), Safety Officers (SO) and a Community Liaison Officer (CLO).

The ES and ECO will report directly to the HSEC/M and will be responsible for the management of all aspects related to OHS issues, and coordinate health and safety related aspects of the mining operation and associated facilities. The HSEC/M will be further supported by Safety Officers (SO) and a Community Liaison Officer (CLO). The HSEC Department will work together with senior management to ensure that health and safety standards are met at all times, that emergency equipment is available at all times and ensure that appropriate management interventions are implemented during all phases of the project. Responsibilities for the above personnel include:

Ensuring all project activities are assessed using a systematic risk assessment approach.

Ensuring a safe working culture is adopted and embraced by all project employees.

Ensuring that health and safety of employees is a project priority.

Ensuring implementation and compliance with all safety aspects of the ESMPr.

Ongoing liaison with Senior Managers and contractors through the GM regarding safety compliance.

Providing appropriate training on Occupational Health & Safety (OHS) aspects for Suni Resources employees and contractors.

Ongoing liaison with national and provincial Government agencies and regulatory authorities.

Ensuring that all incidents are reported to the HSEC/M and RM within 24 hours. Significant incidents (loss of life, serious injury, etc.) will be reported immediately to the RM.

The designated ES and ECO will report to the HSEC/M directly in the manner and frequency determined by the HSEC/M. The ECO will be responsible for the monitoring, reviewing and verifying of compliance with the ESMPr by the contractor and company personnel. The ECO duties in this regard will include the following:

Verifying that all permits required in terms of the applicable legislation have been obtained prior to construction commencing.

Monitoring and verifying that the ESMPr and legislative requirements are adhered to at all times and taking action if there are transgressions.

Monitoring and verifying that environmental impacts are kept to a minimum as far as possible.

Reviewing and approving construction method statements with input from the HSEC/M and ES, where necessary, in order to ensure that the environmental specifications contained within the ESMPr is adhered to.

Inspecting the site and surrounding areas on a regular basis, but not less than weekly, throughout the construction phase.

Monitoring the undertaking by the contractor of environmental awareness training for all new



personnel on site.

Reporting all incidences of non-compliance to the HSEC/M, TM and RM as appropriate.

Ordering corrections, in conjunction with the MM, of any transgressions, or issuing spot fines for person/s and/or equipment not complying with the specifications of the CESMP and OESMP.

Confirming that the required actions are/were undertaken to mitigate the impacts resulting from non-compliance.

Maintain the register of complaints kept on site that will be maintained by the ECO and contractor ensuring that the correct actions are/were taken in response to these complaints.

Conducting environmental performance audits in respect of the construction activities undertaken. Such reports shall be reviewed by the HSEC/M and TM on a periodic basis.

Keeping a photographic record of progress on site from an environmental perspective. This can be conducted in conjunction with the contractor’s representative that will be onsite at all times and can therefore take photographic records weekly. The ECO would need to check and ensure that the contractors understand the task at hand.

Recommending additional environmental protection measures, should this be necessary.

Providing report back on any environmental issues at site meetings. The ES and ECO must have:

A good working knowledge of all relevant environmental policies, legislation, guidelines and standards.

Thorough understanding of the CESMP and ESMPr.

The ability to conduct inspections and audits and to produce thorough, readable and informative reports.

The ability to manage public communication and complaints.

The ability to think holistically about the structure, functioning and performance of environmental systems.

The CLO will:

Implement the Stakeholder Engagement Plan (SEP), SDP and RAP.

Plan, mobilise and allocate resources for the implementation of the RAP (i.e. manage the RAP finances).

Present, discuss and obtain approval for any land-use plans developed in collaboration with external service providers and the district government.

Discuss with the beneficiaries the final affected household entitlement contracts.

Community sensitisation and financial training prior to payments2.

Be responsible for the finances and deliver of entitlement payments, in conjunction with approved management guidelines/processes.

Play a central role in assisting the government to allocate alternative farmland3.

Oversee government compliance with the implementation of the RAP.

Minute-taking and keeping records of all compensation, any potential DUAT transfers, agricultural extension services offered, and alternative land allocation.

Liaise with district government on the implementation of the RAP.

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

Liaise with district government with regard to community issues and refer this back to the HSEC/M.

Provide regular feedback in the form of progress report(s) (as needed) to the district and provincial

2 The intent of the financial training is to sensitise the community, through engagement such as meetings and focus groups, to the pit falls of receiving large sums of money and to provide guidance on how these large sums could be more appropriately invested to support the household, i.e. livelihood strategy / income earning potential.

3 In terms of the regulated RAP process, the government is responsible, however this has to be in conjunction with the appointed RAP consultant and suitable representation of the company as well as the technical working group constituted by affected communities.



government (through the resettlement commissions) on the progress of the RAP.

Attend regular meetings and continuously engage with communities as needed. 5.3 CONTRACTOR RESPONSIBILITIES

Before the appointed contractor begins each construction activity, the contractor shall give to the ECO and Project Manager a written Method Statement/SOP setting out the following:

The type of construction activity.

Locality where the activity will take place.

Identification of impacts that might result from the activity.

Identification of activities or aspects that may cause an impact.

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

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

Emergency/disaster incident and reaction procedures.

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

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

ESMPr and CESMP

Conditions of Environmental Authorisation

Final design documents and diagrams issued to and by the Contractor

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

Daily, weekly and monthly site monitoring reports

Complaints register

Training Manuals/Environmental Handbook

Training attendance registers

Incident and accident reports

Electronic copies of all relevant environmental legislation and permits

Permits and legal documents, including letters authorising specific personnel of their duties as part of emergency response teams e.g. fire teams, etc.

Disciplinary procedures

Monthly site meeting minutes during construction



5.3.3

The contractor shall be responsible for establishing a procedure for electronic document control. The document control procedure should comply with the following requirements:

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

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

All documents should be dated, provided with a revision number and reference number, filed systematically, and retained for a period of time. The exact number of years will be established by the Company..

The contractor shall ensure that documents are periodically reviewed and revised, where necessary, and that current versions are available at all locations where operations essential to the functioning of the CESMP and OESMP are performed. All documents shall be made available to the independent external auditor as necessary.



6. SPECIFIC RECOMMENDATIONS FOR PROJECT RELATED IMPACTS

6.1 INTRODUCTION The generally accepted world best practice sequence for implementation of environmental management processes associated with large projects is:

1. Pre-feasibility Environmental Assessments: These are undertaken to identify critical environmental issues that could be regarded as fatal flaws.

2. Environmental and Social Impact Assessment (ESIA) and Environmental and Social

Management Programme (ESMPr): These are traditionally carried out at project level and are used to identify and assess potential impacts and mitigation measures (of which this document form part).

3. Environmental and Social Management Plans (ESMPs): These are traditionally used to

identify, implement, maintain and monitor detailed mitigation measures aimed at reducing/managing the potential impacts during all phases of a project.

4. Environmental and Social Management System (ESMS): This is aimed at ensuring

that the E&S aspects associated with the operational phase of a project are effectively managed and monitored.

5. Closure and Rehabilitation Plans (CRPs): These outline the procedures required to close

and rehabilitate an operation once activities have ceased. This ESMPr builds on the findings of the ESIA undertaken for the project and describes the mitigation measures that are needed in order to reduce negative impacts and enhance positive ones. It ensures that all mitigation measures and recommendations identified during the ESIA are incorporated into a single document so that they can be considered and implemented during relevant phases of the project. Implementation of these mitigation measures are the responsibility of Suni Resources and, as such, this report is designed to ensure that the company and their contractors are aware of their E&S responsibilities and that the environmental authorities, MITADER, have a clear record of the requirements against which they can be held accountable. Suni Resources will ensure that their employees and contractors adhere to the requirements of this document. Specific mitigation measures and recommendations are outlined in Table 6.1 included below.



Table 6.1: Mitigation measures for project related impacts

MITIGATION MEASURES RELEVANCE PER PHASE

Construction Operation Decommissioning

BIOPHYSICAL ENVIRONMENT

HYDROGEOLOGY

Service facilities/bays for mine vehicles must be fitted with hydrocarbon spillage sumps. √ √ √

A detailed surface water assessment and Surface and Storm Water Management Plan is to be finalised that considers

the following:.

The drainages that will be intersected with the Lennox pit, the Lennox WRD and the TSF need to be properly diverted and accompanied by a detailed design report.

The surface water and storm water assessment needs to cater for the operational phase as well as the detailed storm water and surface runoff assessment in the construction phase.

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Drilling monitoring boreholes around the open pit areas to detect the Zone of Influence (ZOI) as mining develops and pit depth progresses.

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The monitoring positions boreholes that will be drilled will can serve for water quality assessment and monitoring purposes as well.

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Monitoring the weir water levels and inflows with recording of TSF outflows. The surface water assessment and water balance should indicate losses from water use and evaporation which should indicate if any water is seeping into the underground system and towards the pits.

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Storm water and diversion channels to restrict flow towards the open pits during flooding events. √ √ √

Seepage trenches and capturing berms can be implemented down gradient from the waste facilities to capture on surface as well as near surface seepage.

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A post mining monitoring program to evaluate the water levels from boreholes close to the open pit areas to verify the simulated ZOI from the groundwater model is required.

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Constant maintenance of all facilities required for mitigation. √ √ √

GEOCHEMISTRY

Selective handling of ore material and placing it (for long-term stockpiling) so that acid generating material is encapsulated within acid neutralising material. This would require a detailed geochemical testing programme to identify the distribution of acid potential and neutralisation potential in and around the mineral resource. Specific questions to be addressed would include:

How much calcite is present and where does it occur in the mineral resource? This preliminary geochemical assessment has indicated the presence of calcite in the composite ore sample S1, although its contribution to neutralisation potential appears to be limited. However, if present in significant amounts, it may be a resource to mitigate acid drainage.

Why does the calcite in Composite S1 contribute so little to neutralisation potential?

How much does the del S component of sulphur contribute to the acid potential of the material? The acid drainage categories (Potentially Acid Generating (PAG, non-PAG, uncertain) in this report are based on the assumption that del S has the same potential as sulphide minerals. This assumption may be conservative and further testing is required to assess whether there is a significant difference.

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Reducing the volume of seepage from the stockpiles. This might be achieved by one or a combination of the following:

Placing the stockpiles on a surface that has been engineered to have a low permeability, for example, a compacted soil layer.

Including a drainage network beneath stockpiles to intercept seepage and divert it to a holding facility.

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Covering the stockpiles to prevent rain from infiltrating into the material.

SURFACE WATER (AQUATIC ENVIRONMENT)

Ensure that riparian buffer zone areas are included in the Surface and Storm Water Management Plan. Riparian area

buffer zones serve to protect these rivers and streams and maintain the associated faunal and floral habitats. √ √

The required Surface and Storm Water Management Plan will need to incorporate both water quality and quantity

measures. √ √ √

Land clearing should only take place in the dry season or at the end of the wet season. If this is not possible, suitable temporary berms must be constructed prior to clearing in order to contain any soils that may be eroded by heavy rainfall. These soils should be rehabilitated as soon as possible in order to prevent ingress into surrounding water courses.

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Where appropriate, slash and debris should be stockpiled above the high water mark to prevent materials from entering streams and dambos (wetlands) during maintenance activities. This should NEVER be disposed of in stream/river courses or in riparian zones.

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Avoid soil exposure and compaction to protect ground vegetation by avoiding the operation of wheeled or tracked equipment in proximity to the ordinary high-water mark for perennial streams, except on roads or at stream crossings.

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Minimise the number and size of stream crossings for vehicle movement within the riparian zones. Where crossings are necessary, international best practice in the use of bridges, hardened fords, pipes and culverts should be adopted. Recommended stream crossing measures should include:

Minimise vehicular movement over perennial and intermittent streams, and dambo (wetland) areas. Where crossing is necessary, a right angle approach should be used in addition to use of bridges, fords, pipe culverts, and other techniques to minimize impacts to stream banks, flow and water quality.

Crossing structures such as bridges, culverts and fords should be designed to withstand peak flows of high intensity storms, and ensure that movement of aquatic species is not impaired.

Vehicle movement over unprotected streambeds should be prevented. If crossing is necessary, a hard rock stream bottom is preferable.

Road drainage should be diverted to vegetation and not into the stream. Approaches to crossing should be stabilized with aggregate to avoid increased sediment entering the stream.

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

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Site infrastructure such as roads and fences should be aligned with the natural drainage lines to minimise additional erosion. √ √

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

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Mine water and surface run-off from the mining areas should be contained in sedimentation ponds before the clear surface water (if uncontaminated) is recycled and pumped to the processing plant.

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Contaminated water from the process plant should be stored in a dedicated storage reservoir and fed back to the process water reticulation together with the supernatant or decant water from the TSF.

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

Strict management of hazardous chemicals must be implemented. √ √ √

Prevention of hydrocarbon spills from machinery and vehicles by the use of drip-trays and permanent bunded areas for overnight parking if possible. This should include any workshops envisaged for the project. In addition, workshops should be fitted with oil traps and sumps to ensure that no contaminated water/hydrocarbons are allowed to escape.

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Should hydrocarbons spill onto exposed soils, the following mitigations are required: √ √ √





Bioremediation - Cleaning up oil spills immediately when they occur and bioremediating soils contaminated with petroleum hydrocarbons and dangerous organic compounds.

The bioremediation process should utilize beneficial microbes, surfactants, micronutrients and bio-stimulants to decompose contaminants transforming them into harmless by-products, i.e. water and carbon dioxide.

The bioremediation process should be performed in situ or ex situ. The in situ process should be adopted where excavation is impractical and involves either bio-stimulation or bio-augmentation.

Domestic effluent from the mine camp should be treated in an on-site waste water treatment works and final effluent should be of high quality and used for irrigation or mining purposes. Samples should be collected on site for monthly testing to take place.

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Temperature of discharged treated effluent must not result in an increase greater than 3°C of ambient water temperature at the discharge point or surrounding area.

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Discharge of effluent with Total Suspended Solids (TSS) of more than 10% of the receiving stream should not occur. √ √ √

Discharge of effluent with a pH that fluctuates more than 10% of the receiving stream should not occur. √ √ √

All liquid effluents from the mine to be treated to relevant discharge standards before being released into the environment. √ √ √

Compliance will require a monitoring programme to be developed and implemented. √ √ √

Monitoring of potential pollution from waste rock dumps, stockpiles of material awaiting processing (ROM pad), and the TSF.

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Demonstrating compliance will require an appropriate monitoring programme to be developed and implemented. √ √ √

TERRESTRIAL ENVIRONMENT (BOTANICAL)

Clearing must be kept to a minimum. To achieve this, a buffer of 10 m must be placed around the pit and TSF. Clearing must not occur outside of this footprint unless prior authorisation from the RM is obtained.

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Top soil (20 cm, where possible) containing seeds must be collected and stored in an area of low sensitivity during the mining process and later used for rehabilitation of the waste dumps and tailings storage facility.

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Impacted areas from the project such as laydown areas, which are no longer required, must be rehabilitated back to a functional system.

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Rehabilitation of impacted areas during the decommissioning phase must occur. √

Key representative portions of Secondary Miombo Woodland must be set aside as conservation areas within the DUAT (outside of the infrastructure footprint) and demarcated as such, so that they can continue to provide important sources of seed banks in addition to refugia for birds, reptiles, amphibians and mammals.

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Species of Conservation concern can be planted in these set asides to reduce the mines impact on SCC. √ √ √

A Rehabilitation Management SOP must be developed and implemented that details the required actions ad sequencing

of these rehabilitation efforts. It must include a protocol for the monitoring and management of alien invasive species √ √ √

Use existing access roads where feasible. √ √ √

Where feasible, realign roads to avoid natural vegetation and SCC. √ √ √

Set aside an ecological corridor within the study area to link the fragments of vegetation with the inselbergs further south. √ √ √

Align roads and pipelines within a single corridor. √ √ √





Keep the number of river crossings to a minimum. √ √ √

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

Rehabilitate road verges and laydown areas impacted on during the construction phase but no longer required during the operational phase.

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Dust emissions from outdoor stockpiles must be minimised by rehabilitation of the waste dump progressive with mining to minimise dust.

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Emission and ambient dust concentrations must be monitored regularly and measures employed to ensure that the concentrations do not exceed the limits imposed by national legislation.

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Employ dust suppression measures such as wetting of the project area and roads during dry, windy periods or via the use of chemical binders.

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TERRESTRIAL ENVIRONMENT (FAUNA)

Where possible, avoid sensitive habitat corridors, e.g. drainage lines and wetlands. √ √ √

Design infrastructure footprint and transport linkages (e.g. width of the access/haul roads) to be as uninstrusive as possible and thereby avoid unnecessary loss of faunal habitat.

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The dambo (wetland) area on the access road should be declared a no-go area. √ √ √

Where possible protect habitats such as rocky outcrops and wetlands which provides roosting, breeding and foraging sites and shelter many small faunal species.

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Ecological corridors that link undisturbed areas must be created within the project site. √ √ √

All clearing activities must deploy search and rescue teams in front of clearing machinery to assist in relocating slower moving faunal species e.g. tortoises out of the clearing path and relocating to ecological corridor.

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Wherever possible clearing of vegetation should be undertaken in winter months, when birds are not nesting and breeding and when numerous bat species rear young in tree roosts during the summer months.

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Prevent employees from hunting or killing snakes, reptiles, amphibians, mammals and birds through environmental awareness and training sessions.

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Educate staff which snakes are venomous/nonvenomous and differentiate between defensive and aggressive behaviour. Posters of venomous and non-venomous snakes should be used and selected staff members should be trained in snake handling to remove snakes safely from site.

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Where possible, limit project vehicles from driving on project roads during the hours of darkness. √ √ √

The inundation of the TSF should take place over an extended period of time (minimum 3 months) to allow for motile faunal species to disperse from the flood zone.

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Speed restrictions for all project vehicles (40km/h is recommended) should be in place to reduce the impact of faunal road mortalities on project roads.

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All excavation should have an access and egress point for people and fauna to climb out of the pit should they fall in.. √ √ √

Develop and implement a Pest Management SOP and monitor its effectiveness and update annually to ensure plan is

effective. This will aid to avoid the influx of prey for snakes and reduce the likelihood of entering the site. √ √ √

SOCIAL ENVIRONMENT

LOCAL LIVELIHOODS, LAND AND NATURAL RESOURCE USE





The communities that currently reside in the Nacate Village, Lapua Village, Mphuti Village, Matipane Village, Familia Village and the Nanhupo Village should be provided with the opportunity to collect their natural resources from the Balama Central Project site prior to restriction of access to the site.

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The company must identify, monitor and report on which households and their assets, living in locations within the proposed project area will be affected by both physical resettlement and economic displacement, or both. Careful consideration of PAC’s or households that are to be resettled is essential to ensure that these potential impacts are minimised as far as possible. Special care will need to be taken in the selection of alternative host areas for any resettled communities’ replacement housing as this will need to be in close proximity to the alternative farmland and natural resource use areas that will need to be identified for these resettled households, including those PAC’s that will be economically displaced only (loss of machambas and natural resources).

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If a Resettlement Action Plan (RAP) is required, it must be compiled by a suitably qualified specialist and implemented to ensure that the communities within the affected villages are compensated for their land and other assets that may be affected by the project.

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The company must also identify, monitor and report on the number and location of the machambas within the project study area. The proponent must determine through the RAP process which machambas will need to be relocated i.e. all machambas that fall within the project area. As for physical resettlement the host locations for identified alternative farmland require careful consideration during the RAP development process so as to minimise the potential impacts on these receiving areas.

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The RAP recommendations must include the resettlement of communities to areas with access to surface water resources. √ √

Suni Resources must assist with the replacement of any arable land parcels that are lost due to their mining activity as part of the RAP. This replacement must consider the ecological sensitivity of the replacement sites and areas of high ecological sensitivity must be avoided.

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Develop livelihood restoration strategies aimed at assisting households with re-establishing and improving their livelihoods. As the affected communities are primarily involved in artisanal agriculture, it makes sense to provide agricultural support and/or training as a livelihood restoration strategy. Options include supporting the crop production capacity of the area by investing in market access, seed provision and agricultural training programmes. A key focus of such programmes needs to be the empowerment of vulnerable children and youth, as well as women (especially female-headed households).

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Measures that would allow communities to access the woodland resources that are cleared must be implemented as this could help to meet local needs and reduce the pressure on the remaining woodland resources in the short term.

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Where possible, the developer should source unskilled and semi-skilled labour, from the Balama District. √ √ √

The company must ensure that recruitment is fair and transparent and that local job opportunities are maximised, working with the local communities to ensure this.

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The company’s community and environmental team will work with the surrounding communities to ensure that employment or SMME opportunities are communicated to the PACs.

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The proponent should commit, as far as reasonably possible, to source goods and services locally. √ √ √

The proponent is encouraged to provide on-the-job training, skills development and learnership opportunities to unskilled community members, who will gain workplace skills under the supervision of more experience staff.

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If significant levels of job seekers in-migrating to the project area are anticipated, an Influx Management Plan must be

developed to deal with the issue of in-migration in its entirety. These planning considerations should incorporate collaborative management strategies for in-migration, ensuring fair access to community benefits from the project as well as transparent and effective communication with local stakeholders. Collaboration with local/district government is crucial to manage the spatial (town planning) and governance (health and social service provision) implications of this potential in-migration.

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SOCIAL AND CULTURAL HERITAGE IMPACTS

The proponent must identify, monitor and report on which households and their assets, living in locations within the proposed project area will be affected by both physical resettlement and economic displacement, or both. Careful consideration of PAC’s or households that are to be resettled is essential to ensure that these potential impacts are minimised as far as possible. Special care will need to be taken in the selection of alternative host areas for any resettled communities’ replacement housing as this will need to be in close proximity to the alternative farmland and natural resource use areas that will need to be identified for these resettled households, including those PAC’s that will be economically displaced only (loss of machambas and natural resources).

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The proponent must identify, monitor and report on the number and location of the machambas within the project study area. The proponent must determine through the RAP process which machambas will need to be relocated for safety reasons i.e. all machambas that fall within the project area and some along access roads. . As for physical resettlement the host locations for identified alternative farmland require careful consideration during the RAP development process so as to minimise the potential impacts on these receiving areas.

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The affected farmers must be notified of such displacement/disturbance at least 3 months prior to any activities that may affect planting and harvesting abilities. No household’s land or machambas should be affected prior to the completion of the RAP.

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The provision of agricultural extension services to PAC as part of any Social Development Plan (SDP) projects initiated by the company should be considered. These extension services can be developed and implemented in consultation with the affected villages, local stakeholders (including NGOs) and government authorities to assist farmers to intensify and improve the productivity of their farming activities to adapt to the land shortage, the growth in markets and possible food insecurity. Some agricultural programmes that could be considered include:

Agricultural training aimed at farmers, using demonstration plots;

School garden programme, including education on nutrition and food security;

Food gardening or production of fruit trees, sales of produce to the mine canteens;

Improvements to water supply; and

Increased animal husbandry.

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A Stakeholder Engagement Plan (SEP), including a Grievance Mechanism is being developed that will allow community

members the latitude to inform the proponent of any machambas in the area; indicate where access to agricultural land is restricted; to report any other agricultural issues as a result of the project activities; to inform the proponent of any natural resources used; indicate where access to these resources is restricted; to report any other natural resource issues as a result of project activities; to inform the proponent of any sacred sites or gravesites in the project area not already identified; indicate if/where access to these sites are restricted and to report any other disturbance to these sites as a result of project activities.

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The proponent is recommended to provide foot access route(s) around the project area to allow local communities access to natural resources, ensuring no project or community safety risks are posed by this access.

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It is recommended that the natural resources in the proposed mining areas (i.e. wood for building, furniture and fuel, sand, wild foods and medicinal plants and animals) commonly used by the affected and surrounding communities are made available for harvesting prior to and as part of the mine’s land clearing activities Ideally, in the interests of supporting the maintenance of existing livelihoods, it would be advantageous if this process of clearing the land was staggered over the whole mining period. This would support the maintenance of local livelihoods and reduce the pressure on the remaining natural resources outside of the mining area.

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Any areas of land transferred to the mining company that are not yet used for the mining activities should be recognised and designated as natural resource use areas that can be managed by the direct PAC with support from the company.

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Where grave sites or sacred sites have been identified in the project area they must be recorded. If relocation of these is not deemed to be required by the company and affected person/family, a buffer area must be established around the grave

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or sacred site and an access route to the site identified and no activities associated with the proposed project will fall within this buffer or access route.

Should any sacred sites or grave sites be affected, the affected communities will be notified in advance and provided the option to receive compensation and/or assistance with reburial and related expenses, which will be determined during the RAP development process. A comprehensive list of cultural heritage features will be compiled during this process, in consultation with the PAC’s, in order to fulfil the following considerations:

Identification of sacred site or grave site in the area;

Measures to protect and/or relocate sites;

Cultural norms and values of local communities are respected; and

Measures to protect cultural heritage of the area.

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The Company must develop a Chance Find Procedure that will specify the actions necessary on discovery of

graves/heritage features and the actions /process to be followed. √ √ √

Through the SEP, continued and transparent community engagements should be held on a regular basis to address any feedback, concerns, issues and/or grievances. Minutes need to be kept of such meetings, all which should be distributed to and signed by the proponent and relevant local authorities. The company can commit to an ongoing collaborative relationship with the local land and government authorities to assist them with planning and managing the local urbanisation, economic development and social change processes.

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A clinic or health-centre at the mining site will offer on-site occupational and emergency services for its workforce only. The clinic should, however, develop its own health monitoring programme to track key health trends in the area. This should take the form of a Community Health and Safety Plan which includes an emergency preparedness and response plan for

any communicable disease, or other vector related disease, outbreaks or infection spikes.

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As part of the labour recruitment process, all potential employees should undergo a pre-employment health screening assessment prior to being employed and/or accommodated on site. This should include specific tests, but not limited to, for Tuberculosis (TB), Respiratory Tract Infections (RTI) or Bilharzia (Schistosomiasis). The results need to be shared with the local health authorities in a confidential manner, and workers with serious disease should firstly be treated prior to sharing contact with other workers

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The proponent could strengthen partnerships with local health authorities and NGOs by materially supporting certain health initiatives, or providing financial support for particular campaigns or programmes. The project could also consider supporting local clinics through the provision of supplies or medical equipment and improved facilities. Prior to the development and implementation of any healthcare assistance programme, it is proposed for the proponent to develop a memorandum of understanding (MoU) with the local leaders, health authorities and the Government to ensure that the project does not become the de facto government or service provider in the area, and that its development programmes are aligned with government’s.

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Provide free condoms at the mine’s clinic. √ √ √

The project may consider offering free Voluntary Counselling and Testing (VCT) for its workforce/community and closest PAC from which its labour is sourced from.

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Support existing malaria programmes or workshops in the area (or community based interventions), or develop new programmes specifically aimed at schools. Such programmes could be supported by local health workers.

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Labour accommodation units need to be properly planned to avoid overcrowding living conditions that can result in higher rated of communicable disease transmission amongst employees or contractors.

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Existing Water, Sanitation and Hygiene (WASH) community programmes could be supported. Additional WASH programmes could be initiated, using local community healthcare workers. In addition, free hand washing soap could be distributed to the workforce regularly with the aim of encouraging the practice of good hygiene.

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

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The ongoing identification and assistance to vulnerable households affected by project activities must be maintained as a priority in the construction phase.

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The company is required to develop a Social Development Plan (SDP) as part of the proponent’s as per the requirements in terms of the Corporate Social Responsibility Policy for the Extractive Industry of Mineral Resources, Resolution (No. 21/2014) and the Manual on the implementation of Social Corporate Responsibility for Extractive Industry of Minerals Resources (No. 8/2017).

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WASTE, INFRASTRUCTURE AND PROCESS RELATED ISSUES

WASTE AND HAZARDOUS MATERIALS

The siting of waste rock dump and TSF must take into consideration the location and proximity of water resources and human settlements. Furthermore, it must ensure that in the unlikely event of failure, pollution of soil and water as well as physical risk to communities is minimised.

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The integrity of the TSF must be inspected regularly by a suitably qualified and experienced engineer. This should include monitoring of the TSF embankment for early detection of movement. Regular formal inspections of the facilities by operators on a daily basis and annual formal inspections by the Engineer.

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The operation of the facility must ensure sufficient freeboard to ensure that the TSF does not overflow. √

When selecting chemicals (such as flocculants) for use in the process, preference should be given to alternatives with lower toxicity.

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The chemical profile of the stored water in the TSF sump should be monitored so that in the event of accidental discharge, the contaminants released into the environment are known.

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The quality of the stored process water should be monitored so that, in the event of accidental discharge, the contaminants released into the environment are known.

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Mine site surface and ground water monitoring must be implemented for early detection of water contamination which could impact on the health of communities who rely on natural water sources.

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Access to the TSF and waste rock dump should be restricted as far as practically possible and all local communities should be informed of the potential risks associated with these facilities through site notices and community meetings. The TSF must be fenced off and the gate locked at all times.

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Water bodies must be monitored routinely to detect occurrences of unrestricted access to the TSF. √

Flotation devices must be readily available around the TSF. √

Warning notices should be placed around such facilities for potential of drowning and discussions held with local communities to inform them of this danger.

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The Health & Safety induction training for employees and visitors should incorporate these risks. √ √ √

All chemicals used on site must be stored and disposed of according to the national legislation regarding the disposal of hazardous waste.

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Chemicals must be stored in secure, bunded designated areas. Chemicals that may react in a dangerous manner should not be stored within the same bunded area. The compatibility of chemicals must be confirmed prior to storage.

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Material Safety Data Sheets (MSDS) must be readily available for all chemicals at the point of storage and use. √ √ √

Signage showing the chemical names and hazardous properties of the chemicals should be visible in the designated temporary storage area in both English and Portuguese.

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Spill kits must be readily accessible at all areas of the site where hazardous bulk chemicals are stored or used. √ √ √

The Hazardous Materials Management SOP to be developed for the facility and must include the management and

handling protocols for these materials, as well as detailed spill response procedures. √ √ √

All wastes must be managed according to the requirements of Mozambican legislation. √ √ √

As far as practically possible, the philosophy of the waste management hierarchy should be applied to the management of all waste streams.

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All general wastes that cannot be reused or recycled should be stored temporarily in a dedicated area and then transported regularly to the assigned landfill for disposal.

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Should a general landfill site be implemented as part of the mine, it must be designed and operated in accordance with the requirement of the Mozambican legislation (Decree 83/2014 of December 31st) in order to isolate the wastes and prevent environmental contamination, particularly groundwater contamination. It must also be licenced by the developer early in the construction phase and, until such time as this facility is fully operational, all general waste produced during the construction phase must be stored on site in a secure access control area, in a legally-compliant manner that minimises environmental impacts.

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Should a general landfill site be implemented as part of the mine, it will be essential to implement a ground water monitoring system in the vicinity of the constructed landfill site in order to detect any changes to the quality of sub-surface water.

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All bins for temporary storage of waste that are located outdoors should be covered to prevent ingress of water and access by animals.

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All employees, contractors and visitors to the site must be informed of correct waste management procedures, including separation of general and hazardous waste at source.

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Waste storage and disposal areas must be located at least 100 m from surface water resources or important drainage lines. √ √ √

Prior to safe disposal, all hazardous wastes must be temporarily stored at a temporary hazardous waste storage facility. This facility should be designed to include secondary containment lined and covered to protect the contents from weather (sunlight and rain). If wastes are corrosive, the base of the storage facility should be lined with an acid-resistant coating.

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Where possible, empty containers for hazardous chemicals will be returned to suppliers. Where empty containers for hazardous chemicals (hydrocarbons, pesticides, laboratory chemicals, degreasing agents etc.) cannot be returned to the suppliers, they must be triple-rinsed, punctured and stored in a secure area until such time as they can be disposed of safely. Rinse water may not be discharged directly to the environment.

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Empty pesticide containers should be disposed of according to the Regulation for the Management of Hazardous Waste (Decree 83/2014 of December 31st) and the burning of empty pesticide containers should be strongly discouraged.

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

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There are two potential disposal options for medical waste which must be managed according to the management procedure described in Annex 3 of the ICRC Medical Waste Management (2011) and the requirements of the Mozambican legislation (Bio-medical waste Decree No.8/2003). Medical waste generated at the site should be incinerated and residues disposed of at the assigned landfill site. Alternatively, the medical waste can be stored temporarily at a designated and clearly demarcated facility prior to its transportation to a regional hospital which accepts medical waste.

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All domestic wash water and sewage from the mine must initially be diverted to the septic tanks (during construction) and then to the sewage treatment plant (during the later stages of construction and during operation) for treatment. Effluent discharge from these facilities must meet the Mozambique discharge standards, prior to being released into the environment. The priority would be to recycle treated water and sewage sludge from these facilities should be disposed in separate sludge drying beds and composted unless alternative approved arrangements are made for the correct disposal

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or use of sewage sludge. The stabilized sludge can then be dried and either disposed at an assigned landfill or alternatively, applied as a soil conditioner during rehabilitation of the mine, provided that levels of toxic constituents is sufficiently low. If soil application is adopted, soil contamination should be avoided and the soil standard prescribed by the AfDB should be used as a reference for determining the suitability of the soil for various applications;

The pre-treatment of oil and grease containing effluents from fuel bays and mechanical vehicle workshops will be collected in several sumps and will be disposed of as hazardous waste at the nearest hazardous waste treatment facility (e.g. Montepuez mine).

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Chemical toilets must be regularly serviced in a manner that does not pose a threat to the environment. Direct discharge of chemical contents from these facilities must not be discharged directly to the environment and must be treated at a sewage treatment facility. Alternatives such as Ventilated Improved Pits (VIPs) and dry composting toilets must be considered as preferred alternatives to standalone chemical toilets. If VIPs are used, they must be lined, maintained and sited in a way that minimises the risk of contamination of surface and sub-surface water resources.

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All sewage treatment facilities should be well maintained. To this end, at least one employee on site must be trained to maintain the systems.

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The performance of the sewage treatment systems and water recycling facilities must be monitored regularly. Where a system is found to be performing poorly, the cause of the poor performance must be investigated timeously and remediation measures put in place to restore performance.

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In the event that sludge must be removed from the system(s), it must be disposed in a manner that minimises potential risk to human health and the environment and should comply with the National legislation.

√ √ √

The environmental monitoring programme for the facility must incorporate monitoring points that are able to detect a negative impact on the environment associated with the discharge of treated sewage.

√ √ √

Any employees tasked with management of sewage and sanitation systems should be vaccinated against key diseases associated with these waste streams.

√ √ √

The management of all run-off must comply, as a minimum, with the requirements of Mozambican legislation (Decree No. 18/2004 as amended by the Decree No. 67/2010).

√ √ √

The Surface and Storm Water Management Plan must incorporate measures to divert clean stormwater away from

stockpiles, waste storage and disposal areas and other operation areas. √ √ √

Mitigation measures should be aimed at reducing contact between stormwater and hazardous chemicals. This needs to be considered during the planning of the stormwater drainage system for the mine facilities.

√ √ √

In terms of minimising discharge of pollutants and run-off quantity requiring treatment, all stormwater run-off must be properly segregated and clean water run-off diverted to prevent it mixing with water containing a high solids content, to minimize the volume of water to be treated prior to release.

√ √ √

All run-off from machine wash areas must pass through an oil trap and should be treated as hazardous due to the presence of hydrocarbons. All other run-off water must pass through a sediment trap to remove the majority of suspended solids prior to discharge to the environment. All settled material must be disposed of at an assigned landfill.

√ √ √

The quality of all liquid waste streams discharged from the site, including stormwater, must be monitored regularly to ensure compliance with the requirements of relevant legislation and standards.

√ √ √

Transportation of waste must only be undertaken by specific waste removal vehicles with closed spill-proof container. √ √ √

Waste must be properly packaged for its placement in the containerised trucks in order to prevent spilling or leaking along the transportation route(s).

√ √ √

Waste transporters must be trained to collect, transport and deliver waste products in a manner that does not result in any unnecessary spillage of waste.

√ √ √

Prior to leaving the site, all hazardous waste drums must be properly secured and the number of drums confirmed and signed by the transporter in the form of a waste disposal document.

√ √ √





Confirmation of receipt of all waste must be obtained on arrival and all records maintained throughout the operation of the mine.

√ √ √

Transportation of hazardous waste must be conducted in accordance with the necessary health and safety measures. √ √ √

A comprehensive Integrated Waste Management Plan should be developed for the site and it should include Key

Performance Indicators (KPIs) against which the management of wastes can be audited. Copies of this document should be made available at designated facilities where hazardous materials and hydrocarbons are stored, dispensed and used. The purpose of this procedure is to provide for the proper storage and handling of hydrocarbons on site, including waste hydrocarbons, and prevent any form of contamination.

√ √ √

NOISE

All diesel-powered equipment and plant vehicles should be kept at a high level of maintenance. This should particularly include the regular inspection and, if necessary, replacement of intake and exhaust silencers. Any change in the noise emission characteristics of equipment should serve as trigger for withdrawing it for maintenance.

√ √ √

In managing noise specifically related to vehicle traffic, efforts should be directed at:

Minimising individual vehicle engine, transmission, and body noise/vibration. This is achieved through the implementation of an equipment maintenance program.

Maintain road surfaces regularly to repair potholes etc.

Keep all roads well maintained and avoid steep inclines or declines to reduce acceleration/brake noise.

Avoid unnecessary idling times at all times.

Minimising the need for trucks/equipment to reverse. This will reduce the frequency at which disturbing but necessary reverse warnings will occur. Alternatives to the traditional reverse ‘beeper’ alarm such as a ‘self-adjusting’ or ‘smart’ alarm could be considered. These alarms include a mechanism to detect the local noise level and automatically adjust the output of the alarm is so that it is 5 to 10 dB above the noise level near the moving equipment. The promotional material for some smart alarms does state that the ability to adjust the level of the alarm is of advantage to those sites ‘with low ambient noise level’ (Burgess & McCarty, 2009). Also, when reversing, vehicles should travel in a direction away from noise sensitive areas if possible.

√ √ √

Where possible, other non-routine noisy activities such as construction, decommissioning, start-up and maintenance, should be limited to day-time hours.

√ √ √

A noise complaints register must be kept as part of the Grievance Mechanism. √ √ √

Provision of general notices to the community in the form of notice boards indicating blast times and dates. √ √ √

As the site or activity is in close proximity to noise sensitive areas, equipment and methods to be employed should be reviewed to ensure the quietest available technology is used. Equipment with lower sound power levels must be selected in such instances and vendors/contractors should be required to guarantee optimised equipment design noise levels. As far as is practically possible, source of significant noise should be enclosed. The extent of enclosure will depend on the nature of the machine and their ventilation requirements. Generators, pumps and blowers are examples of such equipment. It should be noted that the effectiveness of partial enclosures and screens can be reduced if used incorrectly, e.g. noise should be directed into a partial enclosure and not out of it, and there should not be any reflecting surfaces such as parked vehicles opposite the open end of a noise enclosure.

√ √ √

√ √ √

Plant and equipment should be sited as far away from noise sensitive areas as possible. √ √ √

Machines used intermittently should be shut down between work periods or throttled down to a minimum and not left running unnecessarily. This will reduce noise and conserve energy.

√ √ √

Plants or equipment from which noise generated is known to be particularly directional, should be orientated so that the noise is directed away from noise sensitive areas. Regular and effective maintenance of equipment and plants are essential

√ √ √





to noise control. Increases in equipment noise are often indicative of eminent mechanical failure. Also, sound reducing equipment/materials can lose effectiveness before failure and can be identified by visual inspection.

Acoustic covers of engines and compressors should be kept closed when in use or idling. √ √ √

Noise generated by vibrating machinery and equipment with vibrating parts can be reduced through the use of vibration isolation mountings or proper balancing. Cutting tools and saws must be kept sharp to reduce frictional noise. Noise generated by friction in conveyor rollers, trolley etc. can be reduced by sufficient lubrication.

√ √ √

Naturally, if noise activities can be minimised or avoided, the amount of noise reaching noise sensitive areas will be reduced. Alternatively, the distance between source and receiver must be increased, or noise reduction screens, barriers, or berms must be installed.

√ √ √

To increase the distance between source and receiver is often the most effective method of controlling noise since, for a typical point source at ground level, a 6-dB decrease can be achieved with every doubling in distance. It is however conceded that it might not always be possible.

√ √ √

If noise levels exceed the recommended threshold levels at the Mphuthi Primary School after controlling noise at the source and controlling the spread of noise, building control measures may then need to be considered at the school.

√ √ √

TRAFFIC

Investigate, in conjunction with local traffic and transport authorities, bridges, culverts and causeways along the road from Montepuez to site to ensure that they are strong enough to handle truck traffic of the weight and frequency anticipated. Upgrade the road and bridges accordingly.

√

Consideration must be given to designing the site access road to bypass settlements (Mphuti and Mphoti) where housing, a school and people are located very close to the road. In addition, the opportunity to widen the road and make safe is limited due to a lack of space to expand into. Realignment of the road between the mine site and the EN242 to bypass the main settlement of Mputhi may be necessary.

√

The road between the mine site and the EN242 must be wide enough to allow two heavy vehicles to pass safely. All improvements to public roads will in all likelihood need to be approved by the relevant Mozambican authorities.

√

The upgrade of the road between the mine site and EN242 must include measures to reduce the generation of fugitive dust, preferably by means of an industry standard aggregate sealing / wearing course suitable for all-weather use, but otherwise by regular and frequent application of dust suppressant, including water if it is available in sufficient quantities.

√

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

√ √ √

Reduced speed through villages and speed limits must be strictly observed. √ √ √

All drivers must receive training for each type of vehicle, including light vehicle training, heavy vehicle truck training and abnormal truck load (including low-bed and trailers) training before they are permitted to drive these. Drivers must be in possession of licences appropriate for all types of vehicles they are required to drive.

√ √ √

Deliveries by heavy vehicles must, as far as possible, be scheduled to avoid the formation of convoys. Sufficient distance, as specified in the Road and Transport Management SOP, must be maintained between heavy vehicles to allow light

vehicles to overtake safely. √ √ √

As far as possible deliveries of abnormal loads should be scheduled to avoid periods when significant volumes of traffic are making deliveries to site. Arrangements must be made with the appropriate traffic authorities for abnormal loads, and their requirements strictly adhered to. Measures will be taken to keep children and adults away from abnormal loads while moving near villages.

√ √ √





The required Emergency Preparedness and Response Plan must include provisions to deal with traffic accidents,

particularly accidents involving personal injuries, and all drivers must be made aware of the procedures to be followed. All vehicles must carry first aid kits.

√ √ √

Deliveries of material at night should be avoided. √ √ √

Determine the design standards of the public roads to determine safe loads for vehicles using them. √ √ √

Ensure that vehicles are not loaded beyond the design loadings of the roads they will use. √ √ √

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

√ √ √

Product trucks must have GPS tracking systems put in the vehicles to confirm location and record driver behaviour. √ √ √

Caution should be taken along unpaved routes. Drivers must be instructed to report poor road and/or surface conditions so that repairs can be effected without delay.

√ √ √

Based on the above specific recommendations for project related impacts, additional management plans will need to be drafted for the proposed project. These plans as well as the phase at which they need to be developed are outlined in Table 6.2 included below.

Table 6.2: Mitigation measures for project related impacts

DOCUMENT TITLE SCOPE

PRIOR TO THE CONSTRUCTION PHASE

Construction Phase Environmental Management Plan (CESMP)

The CESMP must deal with all E&S issues associated with establishing the project. Environmental impacts relating to all identified environmental aspects and including blasting, air quality, soil erosion and controls, noise, vegetation, surface and ground water, fauna, dust, vegetation, bulk earth works, materials handling and surface water run-off will need to be covered. The CESMP will also need to deal with the social impacts of the construction including labour requirements and how local labour will be selected and managed, and must:

Specify the E&S contractual obligations for contractors;

Define the role of Suni Resources and contractor staff; and

Apply any E&S aspects and management measures as applicable. In addition to the above, the CESMP will deal specifically with waste handling and disposal during construction (especially since there are no formalised hazardous waste sites in and around the project area), occupational health and safety specific to these facilities during construction, and any other specific aspects not covered elsewhere. The plans and procedures listed below will comprise the majority of the CESMP requirements and specifications

Stakeholder Engagement Plan (SEP) A SEP defines communication processes and involvement with surrounding communities. A SEP must outline roles and responsibilities of all stakeholders to manage expectations of local communities. Stakeholder engagement is a platform by which key environmental and social issues can be established and understood to improve decision-making, determine solutions to issues of concern.

Community Health and Safety Management Plan

Construction and operation of the mining facilities may present a number of hazards to local communities. As such, Suni Resources will develop a Community Health and Safety Management Plan. This Plan will include a detailed assessment of all hazards associated with operation of the mine facilities that may impact negatively on local communities. It will also include a clear set of procedures aimed at minimizing harm to community members.

Influx Management Plan (if deemed necessary)

The company must develop an Influx Management Plan if an influx of job seekers into the project areas is anticipated. The purpose of the plan is intended to provide a set of actions and responsibilities for the management of impacts linked to any potential project induced influx or in-migration into its extended area of influence over its lifespan. The objectives of atypical plan are to:




Avoid unplanned and unmanaged in-migration into the project’s area of influence;

Determine the potential migration routes and in-migrant settlement ‘hotspots’;

Monitor the rate and scale of influx and settlement into the project area once this occurs

Provide the initial framework approach to managing these impacts in order to ensure that these are minimised a far as possible, while also ensuring the potential benefits are distributed as equitably possible; and

Assign responsibilities and resources for the proposed management measures.

Occupational Health and Safety Plan

Construction and operation of the mine facilities will present a number of significant hazards to employees. As such, Suni Resources will implement a comprehensive Occupational Health and Safety Plan and/or quality system. This Plan will include a detailed assessment of all occupational hazards associated with operation of the mine and mineral processing and a clear set of procedures aimed at minimizing harm to employees during the course of their activities on site.

Emergency Preparedness and Response Plan

An Emergency Preparedness and Response Plan is required to deal with general spillages of any kind, as well as management procedures for emergencies during natural disasters, fire and accidents. Spillage response and management is particularly important in areas adjacent to riparian environments where spillages may easily enter these waters. Service providers and required facilities will need to be identified. The identification of upset conditions that can cause major environmental impacts (e.g. major storm events, catastrophic fires, explosions etc.) is required, and measures to effectively handle these must be developed. An Emergency Response Plan is therefore development inclusive of procedures for chemical spillages, disaster management and a facility evacuations strategy.

Integrated Waste Management Plan

The Integrated Waste Management Plan will include a commitment for Suni Resources to manage all waste streams in a manner that minimizes the likelihood of harm to the environment or human health. Furthermore, all waste streams will be managed according to the waste management hierarchy which requires that production of wastes is avoided and minimized. Wastes will then be re-used or recycled and where this is not possible, it will be disposed of in an environmentally responsible manner and in line with the relevant legal and other obligations. This SOP will cover all solid and liquid wastes, both hazardous and non-hazardous, and will also cover the management of leachate from the waste facilities, TSF and WRD.

Surface and Storm Water Management Plan

If not managed, storm water run-off can result in the pollution and contamination of the soils and the freshwater systems in the adjacent riparian area. The objective of the Surface and Storm Water Management Plan is to:

Protect the health, welfare and safety of the public and to protect property from flood hazards by safely routing and discharging storm water from developments.

Preserve the natural environment.

Incorporate measures to divert clean storm water away from sources of potential pollution, including waste storage and disposal areas and other operation areas.

Reduce the contact between storm water and hazardous chemicals or wastes.

Hazardous Materials Management Procedure

The construction and operation of the mine will involve the storage and use of hazardous materials such as hydrocarbons. If not managed correctly, these could result in harm to the environment, in particular soil and water, as well as workers and community members. Details of management requirement for hazardous chemicals and waste containing hazardous materials during construction, operation and decommissioning phases are contained in waste related mitigation measures. The objectives of this SOP are to ensure that:

The use and management of hazardous chemicals is carefully controlled and only used by authorised personnel.

The likelihood of harm to humans or the environment is minimised.

Approval and procurement of hazardous chemicals; storage of chemicals, disposal of expired chemicals and containers.

Emergency response.

Availability of Material Safety Data Sheets (MSDS).

Road and Transport Management Procedure

The construction and operational phases of the project will result in an increase in traffic volume which could pose a risk to the health and safety of the community and the mine employees. The objective of this SOP is therefore to reduce the risk of injury to community members and employees by:

Emphasizing safety aspects among drivers.

Improving driving skills and requiring licensing of drivers.

Adopting limits for trip duration and arranging driver rosters to avoid over tiredness.




Avoiding dangerous routes and times of day to reduce the risk of accidents.

Regular maintenance of vehicles and use of manufacturer approved parts to minimise potentially serious accidents caused by equipment failure.

Minimise pedestrian interaction with construction vehicles.

Using signage and flag persons to warn of dangerous conditions.

PRIOR TO THE OPERATIONAL PHASE

Operational Phase Environmental Management Plan (OESMP)

The OESMP must deal with all E&S issues associated with the operation of the facility. The scope of this plan will be similar to that of the CESMP, although the priority issues requiring careful consideration will be slightly different and longer term. As their focus is on the operation of the facility. Based on the ESIA findings, the issues that the OESMP will need to focus on are likely to be the following, amongst others:

Contamination of soil, surface and ground water

Ambient and workplace air quality

Ambient and workplace noise

Energy and water consumption

Community Land and Natural Resource Use

Conservation plans for Flora and Fauna

Conservation of unaffected areas

Waste management

Acid Mine/Rock Drainage (AMD/ARD) – if of significance

Traffic and Road Safety

Socio-Economic (Labour requirements and how local labour will be managed)

Occupational health and safety, including explosion risks

Community health and safety, including transport risks

Ongoing management of community expectations/Community conflict In addition to the above, the OESMP should include specific requirements for, and details on, the implementation of a formal Environmental and Social Management System (ESMS) and deal with any other specific aspects not covered elsewhere.

PRIOR TO THE DECOMMISSIONING PHASE

Decommissioning Phase Environmental Management Plan (DESMP) and Closure Plan

Refer to Chapter 10 for the Conceptual Closure Plan requirements and specifications. This will be incorporated in both the DESMP and Final Closure Plan to be developed in the last years of operational activity. A Rehabilitation Plan, to be incorporated into the DESMP, will provide guidelines and measures required to restore mined land and explore the options, possibilities and end-points along the path towards restoration. The monitoring of successful rehabilitation should include monitoring of vegetation cover, erosion and alien invasive species. Rehabilitation is a continuous process and should commence during operation through to closure phase. It may not always be possible to restore the land to its initial status at closure. The rehabilitation concepts to be explored are defined as follows:

Restoration: The return of a damaged ecosystem to its original state.

Rehabilitation: The return of a damaged ecosystem to its original state, taking into consideration that it is questionable if complete restoration

will be achieved.

Revegetation: The process of establishing vegetation on the degraded environment.

Replacement: The process where vegetation is established on the degraded environment, but this vegetation differs from pre-mining

vegetation. Such an option would most often result from post-mining conditions being incompatible with the original land-use. An example would be to plant economically or socially important crops instead of the original vegetation due to changed soil properties.



7. MONITORING PROGRAMME 7.1 INTRODUCTION

This Monitoring Programme outlines the E&S monitoring requirements for the Construction and Operational Phases of the Balama Central Graphite Project. This programme has been based on the findings of the ESIA and will be periodically reviewed and updated. National and International (where National standards are unavailable) standards are provided here and it should be noted that where standards are available for the host country, these will use to inform the monitoring protocol. This chapter does not address requirements related to monitoring of compliance with this ESMPr as these requirements, including the need for regular compliance audits, are covered separately in Chapter 8.

The objectives of the Environmental Monitoring Programme are:

To confirm compliance with commitments to legislative and non-legislative E&S Standards detailed in Chapter 4, specifically the: o Decree No. 18/2004: The Regulation on the Standards of Environmental Quality and of

Effluent Emission; o Ministerial Diploma of 18/2004: Regulation of the Quality of Water for Human Consumption; o Ministerial Diploma 180/2004: Regulation on water quality for human consumption.

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

To provide a baseline E&S data set;

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

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

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

Baseline data will be used to compare pre-project conditions with future phases of the project. Where baseline conditions are not known or deficient, this programme describes additional baseline data requirements.

This programme consists of various monitoring plans, each of which covers a separate element.

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

Discharge (Emission) Monitoring: - This will involve monitoring of contaminants being discharged or emitted from construction and operational activities into the environment. Discharge or emission monitoring will be undertaken either at the discharge point or within the local catchment area. Discharge monitoring will provide direct information concerning the concentrations and loads of contaminants being discharged from the operation, and will also serve as a link between ambient monitoring results and the operation itself.

Ambient Monitoring: - This involves the monitoring of background conditions and receiving environments that could be affected by project construction activities. While discharge monitoring should determine if environmentally significant releases have occurred, effects on the ultimate receptors within the receiving environment beyond the boundary of the facility can be determined only by ambient monitoring. Ambient monitoring will be undertaken for surface water (both upstream and downstream in project-affected rivers), groundwater, ambient dust and air quality within the boundaries of the project area.

Investigation Monitoring: - This will be completed as required to determine the occurrence,



nature and extent of possible impacts following an environmental incident, such as oil spillage, or to verify/refute third-party claims of environmental impacts. For example, investigation monitoring may be undertaken upstream of a routine monitoring point to identify a source of contamination.

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

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

Suni Resources will implement a Quality Assurance / Quality Control (QA/QC) programme as part of the monitoring programme. The programme will include the following requirements:

All sample vessels shall be clearly labelled;

Results of all duplicates and blanks must be checked against other samples for compliance. Where non-compliance is found, the laboratory will be notified and asked to re-run the test;

The regular maintenance and calibration of on-site monitoring equipment, as per the manufacturers’ instructions;

The regular use of appropriately qualified and regulated external laboratories to verify on-site monitoring results;

The regular use of duplicate samples, split samples, field blanks, and laboratory blanks and a comparison of basic anion cation balances;

Chain-of-custody procedures for sample handling and transportation;

Laboratory procedures manual for analytical methodologies; and

Standard sampling procedures for laboratory samples will be adhered to and every effort will be taken to have samples shipped to a certified laboratory within 48 hours as per procedure.

Data from the monitoring programme will be continually reviewed and trends will be identified. The monthly Environmental Report will subsequently become a basis for discussion on monitoring programme effectiveness and the need (if any) for changes to sampling sites, sampling frequencies and analytical methods. The environmental report will also include recommendations from MITADER regarding any necessary changes to the programme. Modification of the programme will also be required:

When the configuration or operation of the Project changes significantly; and/or

Where environmental or social impacts vary from initial predictions; and/or

In response to new company commitments, legislative / financing requirements or stakeholder concerns.



Monitoring results will be compiled by the HSEC/M for submission to the Resident Manager on a monthly basis. Environmental monitoring results shall be incorporated into quarterly, bi-annual and annual reports as applicable. 7.2 REGULATORY FRAMEWORK AND POLICY GUIDELINES The national regulatory framework and policy guidelines, as well as international guidelines and conventions, have been discussed in Chapter 4 of this report. Accordingly, Suni Resources needs to establish procedures to monitor and measure the effectiveness of the management programme, as well as compliance with any related legal and/or contractual obligations and regulatory requirements. Where the government or other third party has responsibility for managing specific risks and impacts and associated mitigation measures, Suni Resources will collaborate in establishing and monitoring such mitigation measures. Where appropriate, clients will consider involving representatives from Project Affected Communities to participate in monitoring activities. 7.3 MONITORING PHYSICAL ASPECTS

Topsoil stockpile monitoring should be periodically undertaken to ensure that soil quality and soil health is being maintained or improved. Soil contamination must be monitored visually at all times, especially around workshops, diesel pumps, parking areas and other sites likely to become contaminated by hydrocarbons and oils. All incidences of visible contamination must be documented, as well as all remedial actions taken to address the contamination. Evidence of soil erosion must be monitored monthly during all project phases. Where erosion is detected, efforts will be made to rehabilitate the affected areas and measures implemented to minimize the likelihood of reoccurrence.

7.3.2.1 Baseline Data The objective of the surface and groundwater baseline data collection is to provide a statistically robust baseline data set that adequately describes the pre-construction ambient water quality of the surface and groundwater bodies, major drainage lines in the project area, and upstream and downstream sites that can be used for comparative purposes during the future phases of the project. The baseline data for both surface and groundwater sources will be collected over a period of one year in both the wet and dry season in order to ensure that the baseline reflects natural seasonal variability. This data will then also facilitate calibration of hydrological models aimed at predicting and managing impacts to water resources. The groundwater quality and depth baseline will be established using a combination of community wells and dedicated monitoring boreholes across the project area. This approach is in accordance with international best practice. The proposed ground and surface water monitoring points are presented in Table 7.1 and their corresponding locations relative to the licence area are shown in Figure 7.1. It should be noted that Suni Resources requested that all monitoring points identified are within their concession area due to access difficulties when monitoring sites are located on properties outside of their control. As such, the position of monitoring points differ considerably from those recommended in the various specialist reports. In addition to monitoring boreholes identified in Table 7.1 and Figure 7.1, it would be required to install groundwater monitoring boreholes immediately upslope and downslope of the landfill site in order to detect any pollution originating from this facility.



Figure 7.1: Location of surface and groundwater monitoring points



Table 7.1: Proposed surface and groundwater monitoring points

NEW GROUND WATER MONITORING POINTS

Name Longitude (S) Latitude (E)

Bat01 38° 37' 51.624" 13° 20' 30.620"

Bat02 38° 37' 50.420" 13° 21' 8.978"

Bat03 38° 37' 13.104" 13° 21' 28.303"

Bat04 38° 37' 6.483" 13° 20' 15.393"

Bat05 38° 36' 46.083" 13° 20' 34.459"

Bat06 38° 37' 31.762" 13° 22' 33.595"

Bat07 38° 36' 20.439" 13° 23' 13.412"

Bat08 38° 37' 1.668" 13° 23' 1.408"

Bat09 38° 35' 43.537" 13° 22' 46.800"

Bat10 38° 37' 10.395" 13° 21' 45.578"

EXISTING GROUND WATER MONITORING POINTS

Mati14 38° 38' 37.356" 13° 22' 34.464"

Mati18 38° 38' 35.556" 13° 23' 4.272"

Mputi04 38° 36' 55.08" 13° 21' 17.244"

Fam01 38° 35' 44.448" 13° 20' 43.296"

Nac01 38° 34' 51.78" 13° 22' 43.572"

Nac07 38° 34' 19.92" 13° 22' 52.932"

Lau01 38° 35' 49.2" 13° 22' 5.124"

Nau01 38° 32' 23.892" 13° 22' 40.332"

Nan05 38° 37' 15.348" 13° 20' 6.972"

Bal02 38° 33' 53.784" 13° 21' 28.872"

Bal07 38° 34' 31.224" 13° 20' 44.412"

SURFACE WATER MONITORING POINTS

M4 38° 35' 59.370" 13° 21' 42.731"

M3 38° 36' 12.737" 13° 22' 3.603"

M1 38° 37' 13.013" 13° 23' 1.935"

M2 38° 37' 40.563" 13° 22' 33.665"

The monitoring programme must also incorporate control sites upstream of the project area that they are unlikely to be impacted by project-related activities. This sampling site should be upstream of the proposed mining area and located outside the cone of influence. Changes measured within the control area over time will provide some insight into longer term natural trends in water quality unrelated to project activities. The parameters to be monitored for baseline data are included in Tables 7.2-7.4. A number wells and surface water sites have been included in the monitoring programme since the communities are reported to use water from these sources for recreational and domestic/drinking purposes. The baseline water quality at these locations will have to be established and the drinking water standards should be maintained in areas where drinking water standards already exist (i.e. where ground water used by the communities has been shown to be within the standards prior to mining activities). Once sufficient ambient data has been collected, surface and ground water (receiving water) quality objectives will be established. The surface and groundwater monitoring points may then need to be revised in accordance with the findings of the baseline survey to ensure that impacts of project activities and effectiveness of management measures are being adequately monitored. Monitoring results must be compared against receiving water quality objectives derived from the baseline data sets for surface and groundwater. A list of variables to be monitored has been developed and provided in Tables 7.2-7.4.



Table 7.2: Proposed Guidelines for Ground and Surface Water Monitoring

VARIABLE UNITS LIMITS REFERENCES

Salinity, Electrical conductivity / salinity

mS/m or ppt

Total Dissolve Solids/Salts TDS (mg/l) = EC (mS/m) x 6.5 at 25 ºC.

DWAF 1996

Recommended range for groundwater TDS is 4.55 to 6207.5 mg/l (0.7 to 955 mS/m).

UK DWI 2006

For potable water TDS should be ≤600 mg/l and will be unpalatable at ≥1000 mg/l.

WHO 2011

pH @ 25ºC 1 – 14 pH units Surface water (freshwater) pH 6 to 9 ANZECC 2000

Groundwater pH 4.7 to 9.6 UK DWI 2006

Temperature ºC <3º differential IFC 2007

Dissolved Oxygen (DO)

Mg/L or % O2 Surface water (freshwater) 5.5 to 6 mg/l CCME 1999

Groundwater 0.1 to 14.7 mg/l UK DWI 2006

Turbidity NTU 5 NTU MITADER 2004

1 NTU WHO 2011

Colour TCU or Hazen units or mg/l Pt-Co scale

<15 TCU MITADER 2004

Aquatic life1 including

invertebrate sampling and analysis

SASS5 Score and Shannon Weiner Diversity Index (Invertebrate) DWAF 1996

Fish catch per unit effort numbers and fish species diversity.

1. Parameters related to aquatic life will only be relevant for surface water features

DWAF, SA Department of Water Affairs and Forestry; UK DWI, United Kingdom Drinking Water Inspectorate; WHO, World Health Organization; ANZECC, Australian and New Zealand Environment and Conservation Council; MITADER, Ministry of Coordination of Environmental Affairs and Rural Development; CCME, Canadian Council of Ministers of the Environment;

Table 7.3: Proposed Parameters for Surface Water Monitoring

POLLUTANT/MEASURE UNITS MITADER

Colour Present / Absent 1:20 dilution

Smell Present / Absent 1:20 dilution

Total Suspended Solids mg/l 60

pH S.U. 6-9

Chemical Oxygen Demand (COD) mg/l 150

Biological Oxygen Demand (BOD) mg/l -

Oil and Grease mg/l -

Total Nitrogen mg/l 15

Total Phosphorus mg/l 10y

Total Coliform bacteria MPNb/100ml

Temperature increase oC 35°z b: MPN = Most Probable Number y: 3 mg/l in sensitive zones z: Increase at the receiving medium q: Water used for irrigation

Table 7.4: Proposed Parameters for Mine Effluent Standards


Aluminium mg/l 1.5

Ammonia mg/l 0.4

Arsenic mg/l 0.05

Beryllium mg/l 1.5

Biological Oxygen Demand (BOD) mg/l <5

Boron mg/l 5

Cadmium mg/l 0.005

Chromium (Total) mg/l -

Chromium (VI) mg/l 0.05

Chemical Oxygen Demand (COD) mg/l -

Copper mg/l 0.05

Cyanide mg/l 0.005

Cyanide (Free) mg/l -

Cyanide (Total) mg/l -

Cyanide WAD mg/l -




Dissolved Oxygen mg/l ≤ 6

Floating material Present / Absent Absent

Fluorides mg/l 1.4

Iron (Total) mg/l 0.3

Lead mg/l 0.01

Manganese mg/l 0.1

Mercury mg/l 0.0001

Nickel mg/l 0.1

Nitrate mg/l 10

Nitrite mg/l 1

Nitrogen mg/l -

Oil and Grease Present / Absent Absent

pH S.U. 6.5 - 8.5

Phenols mg/l 0.001

Phosphorous mg/l -

Residual chlorine mg/l 0.01

Selenium mg/l 0.01

Silver mg/l 0.005

Substances that react with methylene blue

mg/l 0.5

Sulphite like hydrogen disulphide mg/l 0.002

Temperature ° C -

Tin mg/l 2

Total Suspended Solids (TSS) mg/l -

Uranium mg/l 0.5

Zinc mg/l 0.01

7.3.2.2 Routine Surface and Groundwater Quality Monitoring In order to track impacts and the effectiveness of proposed mitigation measures, key parameters will need to be monitored throughout the construction and operational phases of the project at the monitoring locations identified in Table 7.1 and Figure 7.1. This monitoring must cover quality for both surface and groundwater sources. As water from both of these sources is used by local communities, as well as being required for ecological functioning, the water quality for surface and ground water during the construction and operational phases should include all variables listed in Tables 7.2-7.4). Until a statistically-valid baseline has been established, the results will be compared with potable water guidelines (see Table 7.5) in order to identify areas of potential concern. Additional water quality monitoring points may need to be included depending on the outcome of activity-specific risk assessments. Similarly, the number of monitoring points may be reduced if this can be justified by the outcome of monitoring data and risk assessments. Table 7.5: Potable Water Quality Guidelines

POLLUTANT/MEASURE UNITS WHO

Arsenic mg/l 0.01

Barium mg/l 0.7

Boron mg/l 0.5

Bromine mg/l -

Chromium mg/l 0.05

Calcium mg/l -

Fluoride mg/l 1.5

Manganese mg/l 0.4

Magnesium mg/l -

Molybdenum mg/l 0.07

Selenium mg/l 0.01

Uranium mg/l 0.015

Cadmium mg/l 0.003

Cyanide mg/l 0.07

Mercury mg/l 0.006

Chloride mg/l 5

Chlorite μg/l 700

Antimony μg/l 20

Copper mg/l 2



POLLUTANT/MEASURE UNITS WHO

Lead μg/l 10

Nickel μg/l 70

7.3.2.3 Groundwater Level Monitoring

The objectives of the monitoring groundwater levels are as follows:

1. To establish the seasonal baseline ground water level; 2. To track levels relative to the pre-mining baseline; 3. To determine whether village water sources are adequately protected from mine-related

impacts; 4. To indicate when corrective or prevention measures are required to maintain water levels; and 5. To monitor the effectiveness of mitigation measures.

Groundwater is a relatively slow-moving medium and significant changes in the groundwater composition are not normally encountered over short timeframe (days). The location of groundwater level monitoring points, are indicated in Figure 7.1 and must be included in the water quantity monitoring regime. Changes in groundwater depth will be monitored using an electrical contact tape or pressure transducer. Depth to groundwater must be monitored quarterly during the pre-construction (one year) and construction phases of the project and must include monitoring in both the wet and dry season in order to establish natural seasonal variability. Monthly monitoring will continue throughout the operational phase of the project unless baseline data justifies a reduction in the frequency.

7.3.2.4 Potable Water Quality

The project will include the construction of a potable water plant for the production of drinking water. All water generated by this facility that is intended for human consumption must consistently meet the WHO drinking water standard (Table 7.5), as there is currently no Mozambique standard available.

7.3.2.5 Point Source Discharges

A wastewater and effluent monitoring programme with adequate resources and management oversight must be developed and implemented to meet the objective(s) of the monitoring programme. The wastewater monitoring programme must consider the following elements:

Monitoring parameters: The parameters selected for monitoring should be indicative of the pollutants of concern from the process, and should include parameters that are regulated under compliance requirements;

Monitoring type and frequency: Wastewater monitoring should take into consideration the characteristics of discharge from the site and process over time. Monitoring of discharges from processes with batch manufacturing or seasonal process variations should take into consideration of time-dependent variations in discharges and, therefore, is more complex than monitoring of continuous discharges. Effluents from highly variable processes may need to be sampled more frequently or through composite methods. Grab samples or, if automated equipment permits, composite samples may offer more insight on average concentrations of pollutants over a 24-hour period. Composite samplers may not be appropriate where analytes of concern are short-lived (e.g., quickly degraded or volatile).

Monitoring locations: The monitoring locations must be selected with the objective of providing representative monitoring data for all effluent discharges from the site including process effluent, storm water and sanitary effluent. Upstream monitoring points may be included in order to assist in isolating sources of specific pollutants.

Data quality: Monitoring programs must apply internationally approved methods for sample collection, preservation and analysis. Sampling should be conducted by or under the supervision of trained individuals and standard chain-of-custody protocols must be observed at all times. Analysis should be conducted by entities permitted or certified for this purpose. Sampling and



Analysis Quality Assurance/Quality Control (QA/QC) plans should be prepared and, implemented. QA/QC documentation should be included in monitoring reports.

Applicable Discharge Limits To ensure that effluent standards are met, the required standards for effluent discharge as prescribed by Mozambique legislation are provided in Table 7.6-7.7. The effluent standards are applicable to all process effluent streams and runoff, including storm water, leaving the site. These levels should be achieved, without dilution, at least 95 percent of the time that the plant or unit is operating, to be calculated as a proportion of annual operating hours. Table 7.6: Process Effluent Discharge Guidelines


Aluminium mg/l 1.5

Ammonia mg/l 0.4

Arsenic mg/l 0.05

Berelium mg/l 1.5

Biological Oxygen Demand (BOD) mg/l <5

Boron mg/l 5

Cadmium mg/l 0.005

Chromium (Total) mg/l -

Chromium (VI) mg/l 0.05

Chemical Oxygen Demand (COD) mg/l -

Copper mg/l 0.05

Cyanide mg/l 0.005

Cyanide (Free) mg/l -

Cyanide (Total) mg/l -

Cyanide WAD mg/l -

dissolved oxygen mg/l ≤ 6

Floating material Present / Absent Absent

Fluorides mg/l 1.4

Iron (Total) mg/l 0.3

Lead mg/l 0.01

Manganese mg/l 0.1

Mercury mg/l 0.0001

Nickel mg/l 0.1

Nitrate mg/l 10

Nitrite mg/l 1

Nitrogen mg/l -

Oil and Grease Present / Absent Absent

pH S.U. 6.5 - 8.5

Phenols mg/l 0.001

Phosphorous mg/l -

Residual chlorine mg/l 0.01

Selenium mg/l 0.01

Silver mg/l 0.005

Substances that react with methylene blue

mg/l 0.5

Sulphite like hydrogen disulphide mg/l 0.002

Temperature ° C -

Tin mg/l 2

Total Suspended Solids (TSS) mg/l -

Uranium mg/l 0.5

Zinc mg/l 0.01

Table 7.7: Sanitary Effluent Discharge Guidelines applicable to the project


Colour Present / Absent 1:20 dilution

Smell Present / Absent 1:20 dilution

Total Suspended Solids mg/l 60

pH S.U. 6-9

COD mg/l 150



BOD mg/l -

Oil and Grease mg/l -

Total Nitrogen mg/l 15

Total Phosphorus mg/l 10

Total Coliform bacteria MPNb/100ml

Temperature increase oC 35°

Effluent Sampling Locations Sites for monitoring of point source discharge including storm water run-off and sanitary effluent have not yet been identified but will be identified for inclusion by Suni Resources as part of its planning and implementation of its monitoring plans and procedures. This monitoring plan will then be updated accordingly.

7.3.2.6 Monitoring Frequency

The required surface and ground water monitoring frequency, is summarized in Table 7.8. Table 7.8: Water Monitoring Frequency

ASPECT FREQUENCY

Surface water Bi-monthly (every second month) monitoring during the pre-construction, construction and post-closure phases of the project and quarterly monitoring during the operational phase.

Treated Drinking Water Once a month for the life of the project

Groundwater Quarterly monitoring during the pre-construction, construction and post-closure phases of the project and monthly monitoring during the operational phase.

Process Effluent Once a month for the life of the project

Sanitary Effluent Quarterly for the life of the project

Mozambique’s Regulations on Emissions and Environmental Quality (of June 2004) that was promulgated on 31 December 2010 do not provide standards for dust, PM10 and PM2.5 thus these have been assessed against international criteria (World Bank and European Council Directive standards and guidelines). The IFC guidelines state that pollutant concentrations should not reach or exceed relevant ambient quality guidelines and standards by applying national legislated standards, or in their absence, the current WHO Air Quality Guidelines, or other internationally recognized sources. (IFC, 2007). Air Quality Performance indicators are usually selected to reflect both the source of the emission directly and the impact on the receiving environment. Background levels of gaseous pollutants, such as SO2, NOX and NO2 are always critical to determine if the environment is already under stress (e.g., there are currently numerous sources of atmospheric emissions within the project area, including vehicle exhaust emissions, domestic fuel combustion, biomass burning, informal refuse burning, charcoal production, fugitive emissions from vehicles and roads and wind erosion of open areas). These baseline conditions need to be taken into account when determining the air quality parameters to be used for monitoring purposes. For this reason baseline values will need to be established prior to construction being undertaken. The ambient air quality parameters that are to be measured and their applicable guidelines are provided in Table 7.9 and 7.10 below. Significant impacts to air quality should be prevented or minimised by ensuring that:

Emissions to air do not result in pollutant concentrations exceeding the relevant ambient air quality guidelines or standards. These guidelines or standards can be national guidelines or standards or in their absence WHO AQGs or any other international recognised sources

Emissions do not contribute significantly to the relevant ambient air quality guidelines or standards. It is recommended that 25% of the applicable air quality standards are allowed to enable future development in a given airshed.



sed on the proposed development it is likely that the pollutants of concern would be particulate matter (dust), PM10 and PM2.5, however this needs to be confirmed once the relevant baseline data is available.

No specific dust control regulations are available for Mozambique. Suni Resources will implement and maintain a dust monitoring programme during the project’s life cycle. This would assist to collate continuous dust deposition data and have a repository of records covering the construction, operation and closure phases of the proposed operation. Availability of such records will assist management in managing dust impacts, resulting in the reduction of respiratory diseases that are as a result of air pollution, reduced risk of damage to property, improved visibility, reduced disturbances to existing flora and fauna habitats, and a reduction in air pollution. Depositional dust that may be generated from active construction and operational areas (e.g. access roads and construction sites) will be monitored within the project area, at nearby villages and at suitable control sites and compared against established national, and where these are lacking, international standards. It is intended that duplicate samples and blank samples will be sent for analysis at accredited laboratories and the monitoring frequency will be monthly using fall out dust buckets (Table 7.9). Table 7.9: Acceptable dust fall rates as measured at and beyond the boundary of premises where dust originates

AREAS SITE ID 30-DAY AVERAGE DUST

FALL RATE (MG/M2/DAY) FREQUENCY

PERMITTED FREQUENCY

OF EXCEEDING DUST

FALL RATE

Residential Area Residential D < 600 Quarterly4 Two within a year but not

sequential months

Non-Residential

Area Plant

Sensitive Receptors D < 600

Other Areas

D < 1200

Quarterly Two within a year but not

sequential months

Table 7.10: Ambient air quality guidelines for applicable pollutants and various international organisations as accepted by the World Bank (IFC, 2007).

POLLUTANT AVERAGING

PERIOD MOZAMBIQUE

STANDARD

WHO GUIDELINE

VALUE (ΜG/M³)

EC DIRECTIVE

LIMITS (ΜG/M³)

US NAAQS (ΜG/M³)

Please note that as a baseline in terms of air quality has

not yet been established the most stringent

values (i.e. IT-3 for PM10 and PM2.5) has been used for the

monitoring programme. Once a

baseline is established it is

recommended that

Sulphur Dioxide (SO2)

1-year 40 µg/m³ N/A N/A N/A

24-hours 100 µg/m³ N/A N/A N/A

1-hour 800 µg/m³ N/A N/A N/A

10 minutes 500 µg/m³ N/A N/A N/A

Nitrogen Dioxide (NO2)

1-year 10 µg/m³ N/A N/A N/A

1-hour 190 µg/m³ N/A N/A N/A

4 If limits exceeded then monthly until the source has been identified and the limits are back to an acceptable level



Particulate Matter (PM10)

1-year - 30 (IT-3) 40 - these values are revised should they be below existing baseline values.

24-hours - 75 (IT-3) 50 150

Particulate Matter (PM2.5)

1-year - 15 (IT-3) 25 35

24-hours - 37.5 (IT-3) - 15

Ensuring that no visible evidence of windblown dust exist represents an example of a source-based indicator, whereas maintaining off-site dustfall levels to below 600 mg/m2/day represents an impact- or receptor-based performance indicator.

Source based performance indicators for the unpaved roads would be no visible dust when trucks/vehicles drive on the roads. It is recommended that dust fallout in the immediate vicinity of the road perimeter be less than 1200 mg/m2/day and less than 600 mg/m2/day at the sensitive receptors.

From all activities associated with the proposed activities, dust fallout rates should not exceed 600 mg/m2/day outside the MLA for on-site activities or at the sensitive receptor areas for on-site and off-site activities.

It is recommended that ambient PM2.5, PM10 and dust fall monitoring be conducted on a continuous basis as part of mine’s management plan. This can serve to meet various objectives, such as:

Compliance monitoring;

Validate dispersion model results;

Use as input for health risk assessment;

Assist in source apportionment;

Temporal trend analysis;

Spatial trend analysis;

Source quantification; and,

Tracking progress made by control measures.

It is recommended that an air quality specialist is appointed in order to determine appropriate monitoring sites based on the findings of the baseline data and the prevailing wind direction. PM10 measurement can be economically carried out by the use of a “mini-vol” apparatus. This consists of a battery-driven flow-controlled sampling pump drawing ambient air through a filter for 24 h. The pre-and post-exposure weighting of the filters provides daily average concentration values. The changing of batteries and filters can be carried out by site personnel with a minimum of training, while deployment at regular intervals (every 3 days or so, including weekends) provides a time series free of systematic sampling error, as well as a long-term average value. The filters can be sent to a suitable industrial hygiene laboratory by courier for weighing and metal analysis. As the mining activities move the monitoring network would have to migrate with it with the exception of any monitoring activity at the stationary plants and the on-site weather station.

Noise monitoring at sites where noise is an issue or may become an issue is essential. Annual noise sampling over a period of 10 to 30 minutes for day- and night-time at Site 1, Site 2, Site 3, Site 5, Site 6, Site 7 and Lapua Village should be incorporated in an annual environmental noise monitoring programme (Figure 7.2). Also, in the event that noise related complaints are received short term (24-hour) ambient noise measurements should be conducted as part of investigating the complaints. The results of the measurements should be used to inform any follow up interventions.



The investigation of complaints should include an investigation into equipment or machinery that likely result or resulted in noise levels annoying to the community. This could be achieved with source noise measurements. The following procedure should be adopted for all noise surveys:

Any surveys should be designed and conducted by a trained specialist.

Sampling should be carried out using a Type 1 SLM that meets all appropriate IEC standards and is subject to annual calibration by an accredited laboratory.

The acoustic sensitivity of the SLM should be tested with a portable acoustic calibrator before and after each sampling session.

Samples of 20 min to 24 hours in duration and sufficient for statistical analysis should be taken with the use of portable SLM’s capable of logging data continuously over the time period. Samples representative of the day- and night-time acoustic environment should be taken.

The following acoustic indices should be recoded and reported: LAeq (T), statistical noise level LA90,

LAFmin and LAFmax, octave band or 3rd octave band frequency spectra.

The SLM should be located approximately 1.5 m above the ground and no closer than 3 m to any reflecting surface.

Efforts should be made to ensure that measurements are not affected by the residual noise and extraneous influences, e.g. wind, electrical interference and any other non-acoustic interference, and that the instrument is operated under the conditions specified by the manufacturer. It is good practice to avoid conducting measurements when the wind speed is more than 5 m/s, while it is raining or when the ground is wet.

A detailed log and record should be kept. Records should include site details, weather conditions during sampling and observations made regarding the acoustic environment of each site.



Figure 7.2: Proposed noise monitoring stations

All waste streams should be managed according to the waste management hierarchy. This specifies that wherever possible, production of wastes should be prevented or minimised at source. Where prevention or further minimization is not possible, wastes should be re-used, recycled and then disposed of responsibly so as to minimise impacts to the environment. In the event that there are no national standards available, the proponent should comply with internationally recognised standards. In order to ensure best practice with respect to waste management, a Construction Waste Management Plan should been developed and will include regular qualitative and quantitative monitoring of all waste streams. As a minimum standard, all waste will be managed in accordance with Mozambique legislation. The parameters listed in Table 7.11 below will be monitored: Table 7.11: Monitoring Compliance for waste management

Key Performance Area Key Performance Indicators Checking Procedure Frequency

Compliance with plan

% contractors with approved waste management plans;

Number of reports of incorrect storage or disposal of waste;

Frequency of incidents of littering;

Audits Monthly



Key Performance Area Key Performance Indicators Checking Procedure Frequency

Integrity of waste storage facilities;

% compliance of treated effluent with relevant limits;

% compliance of storm water with relevant limits; and

State of storm water infrastructure.

Waste quantification

Quantity of non-hazardous waste requiring disposal; and

Quantity of hazardous waste requiring disposal.

Quantification by volume or mass

Monthly

Bunding and containment Integrity of bunded facilities and

secondary containment at waste storage facilities

Audits Monthly

Training % employees trained on management

of wastes.

Training records (including induction and more focussed training)

Continuous

Grievances Number of grievances or formal

cautions related to management of wastes.

Grievance records or cautions / fines

Continuous

7.4 BIODIVERSITY AND ECOLOGICAL MONITORING

Changes to the area (in ha) covered by alien invasive plant species must be monitored. This will be achieved through bi-annual visual surveys of disturbed areas and fixed point photographs. Monitoring of alien and invasive fauna will occur by recording the date, location and species of rodents observed and the date, location and number of pied crows observed.

All laydown and other areas disturbed for construction and operational purposes and not anticipated to be required any further, must have a minimum of 50% cover of herbaceous vegetation species and/or grass species in order to ensure that no erosion takes place. 7.5 SOCIAL MONITORING

Suni Resources in conjunction with the relevant authorities will be responsible for implementing all resettlement and compensation strategies developed and defined in the RAP. Suni Resources will therefore assume responsibility for providing the funding for monitoring of affected persons and project affected people. Such monitoring is required to ensure that resettlement is properly implemented, is in line with the RAP, that grievances are being attended to, and that any necessary changes to the overall process are being done in good time and sensibly. To be compliant with best practice, monitoring will need to take place at two levels. Internal Monitoring will be conducted by a suitably qualified person within the management of Suni Resources. The form that this monitoring takes is flexible and can be tailored to the personnel and capacity of the management team. However it is strongly recommended that monitoring have at least three data sources. These would be:

The Grievance

Register results and minutes of the local level engagement programmes as per the OP - Stakeholder Engagement

Qualitative monitoring database. External Monitoring will be conducted through a contracted independent body so as to provide external third party verification of social monitoring data gathered by the internal monitoring team.



Monitoring reports are a valuable tool in identifying problems in the implementation of the resettlement project and should be used as such. The monitoring team will revisit the monitoring plans after each monitoring exercise to evaluate findings and take necessary steps to rectify issues that have been highlighted by the monitoring reports. A manual for the usage of the protocols will be developed by the independent monitor. The external Monitoring Team will visit the project area upon completion of the first phase of resettlement and then two years later. The subsequent frequency can be determined after the first two visits. External monitoring will pay particular attention to the following aspects:

Ensure that any replacement housing for those who have had to move is of an adequate replacement standard.

Ensure that households who have lost crops and other forms of livelihood production have received fair compensation and that compensation rates are reviewed regularly.

Examine the livelihood restitution strategies as determined by the OP - Resettlement and measure their progress. Indicators will be developed as part to the OP - Resettlement.

The following indicators will form part of the socio-economic internal and external monitoring framework:

Suggested indicators for monitoring:

1. Food security (including aspects of nutritional/health status by age and gender) 2. Commercial agricultural and farming income-generation 3. Household incomes (not only money, but surrogate indicators such as suite of assets owned

(e.g. radios, bicycles, television, etc)). 4. Housing, quality of roof, walls, floor. 5. Expenditure patterns 6. Indebtedness/savings 7. Access/use of services (social and physical infrastructure) 8. Project Affected People’s views on progress toward restoration/enhancement especially

those to be physically relocated 9. Waged full/part-time jobs by household (Suni Resources and non-Suni Resources created

jobs) by development phase (construction/operations) 10. Small-scale ‘business’ startups 11. Numbers of shops/trading activities in villages/project area 12. Changes in gender livelihood-focused activities and incomes 13. Status of Vulnerable PAPs 14. Grievances and resolution outcomes 15. Livelihood diversity and relative contributions (numbers/incomes from charcoal production,

fishing, bee-keeping/honey production, fishing, etc.) 16. Improvement in production/income for women/youth.


1. Where applicable, primary and basic enrolment levels by gender. 2. School buildings and equipment, including chairs 3. Secondary enrolment levels by gender. 4. Pupil/teacher ratio.

a. Adult education enrolment level by gender 5. Distance to primary school.




1. Local hiring as per policy 2. Grievance and resolution outcomes 3. Market prices (bartering items) for key food items 4. Relevant information tracking from external parties 5. Costs of social/welfare provisions/services (schools and ‘equipment’ [pencils, notebooks,

uniforms]; clinics and medicines, local transport) 6. Inflation (food basket) 7. Influx/in-migration 8. Security/community incidents 9. Number of local companies involved in supplying goods and services/value of goods and

services provided (Suni Resources’ local purchasing) 10. Return of youths to villages 11. Village demographic changes (by age/sex) 12. Birth rates 13. Nationalization progress (expatriates to nationals) 14. Intra-household conflicts 15. Intra-community (villages) conflicts (elders/youths; political factionalism)

Immediately prior to initiation of any land preparation activities within an area that requires clearance for the construction of infrastructure and/or within the mining area, all cultural resources within the footprints will be clearly demarcated. Details of their locations, and the need to avoid damage to the demarcated resources will also be communicated to all parties involved in land preparation activities. Where mitigation involves the relocation or compensation for loss of cultural resources, these activities will be completed prior to the initiation of land preparation activities within the affected area. Land preparation and excavation activities may result in the identification of previously unknown items of cultural or archaeological significance (unanticipated discoveries). In such instances, the parties involved will adhere to the Chance Find procedure described in the section below.

7.5.5.1 Monitoring Cultural Sites

Once disturbance footprints have been established, taking into consideration the objective of avoiding damage to or loss of cultural resources, it will be necessary to develop and implement a monitoring programme to confirm that mitigation measures are effective. Suni Resources will be responsible for developing and implementing such a monitoring programme that will include:

Key performance areas and indicators

Performance targets

Monitoring methodologies

Monitoring frequencies Monitoring of cultural resources should involve consultation with local community members and review of any grievances related to cultural resources. Where monitoring identifies deficiencies in the effectiveness of mitigation measures, these measures will need to be reviewed and, where appropriate, revised with the aim of addressing deficiencies. Although monitoring of the status of cultural resources may be conducted internally by Suni Resources, the company should consider periodic third party audits.

7.5.5.2 Chance Find Procedure

In the event of discovery of any item of potential cultural heritage significance, the following steps must be followed in sequence:



1. If the activity that resulted in the discovery of the heritage item(s) has the potential to damage

the cultural heritage item, this activity must be stopped immediately. This will include, but not be limited to, clearing of vegetation or soil, land preparation or any other form of excavation.

2. If mobile vehicles are operating in the immediate vicinity of the find, the drivers of these vehicles will be informed of the discovery. All vehicles will then be moved to a safe distance of at least 20 meters from the discovery.

3. The Supervisor will be informed of the discovery within 15 minutes. 4. Within 30 minutes, the location of the heritage item(s) will be clearly demarcated and a “no

go” zone of 20 meters established. This “no go” zone must be clearly marked and the restriction will remain in place at least until such time as the significance of the find has been confirmed by an appropriate external specialist as appointed by the Ministry of Culture.

5. The Supervisor will immediately (within 30 minutes) inform the following individuals of the discovery:

The Manager of the area in which the discovery was made;

The Community Manager 6. Within 48 hours the Community Manager will review the find and communicate the details

thereof to the relevant government authority. 7. Suni Resources will then facilitate investigation and community communication of the find as

per the instructions of the relevant authorities. 8. The “no go” zone will remain in place until such time as the investigation has been concluded

or until such time as the relevant authority has confirmed in writing that the “no go” zone is no longer required.

9. Until conclusion of the investigation into the significance of the chance find, Suni Resources will take reasonable precautions to prevent any person from removing or damaging the find.

It is the responsibility of the Health, Safety, Environmental and Community Manager to oversee the management of occupational health and safety risks associated with mining activities. Monitoring will include the following:

Pre-employment medical examinations for all employees to ensure fitness for work;

Annual medical screening;

Daily inspections to monitor compliance with Occupational Health & Safety procedures including correct use of personal protective equipment;

Recording and investigation of all accidents and near misses on the site; and

Radom sampling of members of the workforce for alcohol and drug use on site. Records will be maintained of all audits, inspections and incident investigations and incident and accident statistics will be reported monthly to the Mine Manager.

The condition of all roads used by project related traffic, whether provided for exclusive use by project-related traffic or shared with the public, must be monitored regularly, and with sufficient frequency to ensure that damage is repaired timeously to safeguard road users and avoid disruption to traffic flows.



8. MANAGEMENT IMPLEMENTATION AND REVIEW 8.1 INTRODUCTION Suni Resources will establish procedures to monitor and measure the effectiveness of the E&S Monitoring Programme and ESMPr as well as compliance with any related legal and/or contractual obligations and regulatory requirements and applicable standards related to environmental and social performance. Where the Authorities or another third party has responsibility for managing specific risks and impacts through implementation of various mitigation measures, Suni Resources will collaborate with them in establishing and monitoring the implementation and effectiveness of such mitigation measures. Where appropriate, Suni Resources will consider involving representatives from Affected Communities to participate in monitoring activities. Ultimately, the MM will be responsible for ensuring full compliance of contractors and employees with the requirements of this ESMPr. 8.2 TRAINING AND AWARENESS PROGRAMMES

Information will be transferred in an appropriate manner and training courses will take language and education levels into consideration. In particular, the training of potentially illiterate staff will require the development of appropriate training material and approach. Suni Resources will ensure that its staff and other employed parties or their contractors, who carry out any aspects of the work, in any phase of the project, are adequately trained with regard to the implementation of this ESMPr and EMP’s described above. Contractors and third parties will be aware of their health, safety, environmental and social requirements and obligations, and these will be legally and contractually binding on them. A training-needs-analysis that would cover Health, Safety, Environmental & Community (HSEC) issues will need to be developed, and should identify the appropriate training areas and target groups prior to commencement of construction activity. The training staff will be appropriately qualified in their respective disciplines and will possess the skills necessary to train, inform and sensitise all personnel involved in the project. All personnel involved in the construction and operation of the project will be required to participate in a HSEC induction programme. Training programmes will be targeted at three distinct levels of employment, i.e. senior, technical management/supervisors and labour. These awareness training programmes will contain the following information:

The names, positions and responsibilities of personnel to be trained

The framework for appropriate training plans

The summarised content of each training course

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

Environmental Policy

Occupational Health and Safety (OHS) Policy

Community Health and Safety Policy

E&S Objectives and Targets

Organizational Structure and Responsibilities

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

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

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



Emergency Preparedness and Response

Channels of communication for discussing and reporting E&S issues

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

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

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

Culturally appropriate behaviour

Hygiene

Community engagement, security and grievances Additional training on cultural heritage and culturally appropriate behaviour, and on health, safety, environmental and social hazards which could arise from non-routine situations and corrective actions will be provided. Training will highlight the importance of incident reporting and completion of appropriate reports, channels of communication for reporting HSEC issues and incidents, documentation systems and responsibilities under national legislation. The site Environmental Handbook must be developed and distributed to all literate personnel at induction training. Once the mine becomes operational it is anticipated that the training and awareness programmes will be modified to be applicable to all operational, aspects, impacts and risks associated with these various activities. This is equally applicable to OHS training requirements. 8.3 EMERGENCY PREPAREDNESS AND RESPONSE Where the project involves specifically identified physical elements, aspects and facilities that are likely to have significant E&S impacts, Suni Resources should establish and maintain an Emergency Preparedness and Response Plan (EPRP) that should be included in the Occupational Health and Safety Management Plan, in collaboration with appropriately qualified third parties. The EPRP will be developed to respond to accidental and emergency situations associated with the project in a manner that will assist in preventing and mitigating any harm to people and/or the environment. In particular, the EPRP will address:

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

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

Response procedures

Provision of equipment and resources

Designation of responsibilities

Communication, including that with potentially affected communities

Periodic training to ensure effective response It is recommended that:

First aid facilities be established at the accommodation village and the process plant site respectively.

An emergency response container be provided at the process plant where all emergency response equipment will be stored in a locked container. The nearby security gatehouse will have keys to unlock the emergency response container if required.

The HSEC Manager will be the designated emergency response coordinator and if off site this responsibility will be passed to the Resident Manager.

Each contractor (accommodation village catering contractor, mining contractor, etc.) will be responsible to provide their own first aid facilities and trained first aid officers so that someone which is first aid certified is available on shift in all locations at all times.

The company will provide an equipped first aid clinic on site with basic level of equipment and a trained paramedic nurse. The clinic will be manned during normal daytime work hours with the paramedic nurse on call after hours. A Landcruiser Troop Carrier 4 wheel drive vehicle will be stationed at the first aid clinic and will be fitted out with emergency response, first aid equipment including a stretcher, flashing lights and siren.



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

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

A list of key personnel to be contacted

Details of emergency services applicable to various areas along the access route that components or product will need to be transported, and for the site itself (e.g. the fire department, spill clean-up services, etc.)

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

A risk assessment and Hazard and Operability Study (HAZOP) to identify all potential projects aspects/risks as it relates to potential and feasible incident and emergency scenarios

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

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

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

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

Accidental discharges to water and land

Accidental exposure of employees to hazardous substances

Medical evacuation

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

Accidental fires and fire drill

Vehicle accidents, including vehicle collisions with pedestrians

The above considerations are also directly applicable to potential risks to host communities’ health and safety. 8.4 CHECKING AND MONITORING The effectiveness of mitigation measures, procedures and structures aimed at minimising E&S risks and impacts and enhancing benefits of the project will be assessed regularly through the E&S monitoring programme. Checking and monitoring includes four key activities:

Defining objectives and targets;

Monitoring selected E&S quality variables as defined in the objectives and targets;

On-going inspections and continuous improvement of general state of the operations; and

Internal audits to assess the robustness of the ESMPr and SOPs or to focus on a particular performance issue.

Where performance fails to meet the standards specified in the monitoring programme or the ESMP, remedial measures will need to be implemented and the effectiveness of these assessed through subsequent monitoring. Details of this monitoring programme have been provided in Chapter 7. 8.5 PERFORMANCE OBJECTIVES AND TARGETS E&S performance objectives and targets (measurable indicators) against which the performance of



the project can be measured and monitored will be developed as part of CESMP and SOP and, where applicable, will be reflected in the E&S monitoring programme for the facility. These objectives and targets must be clearly defined and incorporated, where appropriate, as contractual obligations that have to be fulfilled by third parties. The latter is of particular relevance during the design and construction phases of the project. In so doing, Suni Resources will be better able to manage its Health, Safety and Environmental risks and obligations. Objectives and targets will be reviewed on a regular basis. In cases where objectives and targets are not met, new and revised method statements indicating proposed corrective measures will be developed and approved. 8.6 ON-GOING INSPECTIONS AND CONTINUOUS IMPROVEMENT On-going inspection and continuous improvement will form a key component of the ESMPr as this document will be regularly reviewed and updated. Research on certain aspects will be undertaken to refine environmental management and to ensure that the levels of environmental protection outlined in this ESMPr are achieved. Owing to the transient nature of the construction and operational phases, the greatest source of information will be obtained through on-going visual inspection. At the same time some potential impacts are difficult to monitor quantitatively, such as soil erosion and waste management. An on-going, but pragmatic inspection regime will be developed that allows for potential E&S non-conformances to be identified proactively so that mitigation can be quickly and effectively implemented. 8.7 INTERNAL AUDITS Internal audits of the environmental performance of the project will be undertaken on a quarterly basis by Suni Resources. The purpose of the audits will be to:

Assess compliance with the conditions of the Environmental Permit, and

Determine if the objectives and targets outlined in the ESMPr are being met. The findings of internal and informal environmental reviews will be recorded and items requiring action will be identified. The implementation of these actions will be assessed in the following audit. Where the monitoring data and the inspection reports highlight problems, the internal audit can be used to ascertain the source of the problem and to define action to prevent its recurrence. The three key areas for audit are operating efficiencies of facilities, project procedures and their implementation, and Contractor’s E&S performance. 8.8 INCIDENTS REPORTING, NON-COMPLIANCE AND CORRECTIVE ACTION

Suni Resources and its contractors will develop and implement procedures for recoding details of E&S incidents and accidents as well as near misses. Details of significant incidents and accidents will be reported to senior management and, to the extent required by legislation, to the relevant national authorities. Reports for significant incidents or accidents should include the following:

Description of the incident;

The location of the emergency or incident;

The name and telephone number of the designated contact person;

The time of the emergency or incident;

The suspected cause of the emergency or incident;

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

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



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

Documents associated with the ESMPr will be regularly reviewed and updated by all environmental management parties;

Internal environmental audits will be conducted monthly during the life of the project by Suni Resources. The purpose of the audits will be to assess compliance with the conditions of the ESMPr;

The findings of internal audits and informal environmental reviews will be recorded and items requiring action will be identified from the recommendations made and Action Plans developed;

Suni Resources is contractually obliged to fulfil any reasonable recommendations, and implementation of the ESMPr.

A procedure for reporting E&S-related complaints from the affected communities and employees (i.e., a Grievance Mechanism) will be developed and implemented.

The ESMPr is deemed not to have been complied with when:

There is evidence of contravention of the recommendations in the document, its environmental specifications or the developed Method Statements or Procedures;

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

Environmental damage ensues due to negligence;

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

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

There are several mechanisms for implementing corrective action and they include verbal instructions, written instructions and contract notices. Verbal instructions are likely to be the most frequently used form of corrective action and are given in response to minor transgressions that are evident during routine site inspections. Verbal instructions are also used to create further awareness amongst employees and contractors, as often the transgressions are a function of a lack of awareness. Written instructions will be given following an audit. The written instructions will indicate the source or sources of the deviations from desired performance and proposed solutions to those deviations. The implementation of these solutions can also be assessed in a follow-up audit and further written instructions issued if required. All written instructions will be centrally logged to ensure that there is an auditable record of such instructions and how they were responded to. A contract notice is a more extreme form of written notice because it reflects the transgression as a potential breach of contract. If there is not an adequate response to a contract notice then the next step can be to have the contractor or employee removed from the site and the contract cancelled. Contracts will be drafted with this in mind. 8.9 MANAGEMENT REVIEW The process of management review is in keeping with the principle of continual improvement. As such, Suni Resources will develop a management review procedure to ensure that the company defines and maintains a documented process and agenda for Senior Managers to periodically review the continuing suitability, adequacy and effectiveness of the ESMPr. The management review, which will be conducted at least annually, will include a review of internal and external audit reports as well



as the cost estimates for implementation of the ESMPr. The purpose of the review is to critically examine the effectiveness of the ESMPr and its implementation and to decide on potential modifications as and when necessary. 8.10 FINANCIAL RESOURCES Suni Resources will be responsible for ensuring that sufficient financial resources are made available for the effective implementation of the requirements of this ESMPr throughout the life of the project. Where applicable, Suni Resources will need to ensure that all contractors are aware of their obligations in terms of this ESMPr and that they have made appropriate financial provisions to ensure full compliance. 8.11 EXTERNAL ENVIRONMENTAL AUDITING AND VERIFICATION Audits of the E&S performance of the project will be undertaken regularly by an independent party to verify compliance with the requirements of the ESMPr. During the construction phase, such independent audits will be conducted annually during the operational phase. In this regard, Suni Resources will ensure that the independent audit team are provided with all relevant documentation (including a copy of the ESMPr) and that, as far as practical, they address recommended actions emerging from the independent audits within a reasonable period of time. The independent E&S auditor will be responsible for the following:

A preliminary review of all relevant documentation provided by Suni Resources. This will enable the auditor to assess the applicability of the instruments currently in place and to identify and review any other instruments not explicitly noted previously.

Compilation of the audit findings in the form of an audit report that describes all incidences of compliance, partial compliance or non-compliance against the reference framework with an assessment of the significance of degree of non-compliance and the potential risks to the project.

As non-compliances are identified the external auditor will progressively prepare a Draft Action Plan, which will describe the actions and activities required to remedy or address any deficiencies identified.



9. STAKEHOLDER ENGAGEMENT 9.1 INTRODUCTION The stakeholder and community engagement process is a crucial component of the ESIA process, and for the project’s future phases. It is vital that all project affected persons (PAP) are not only aware of the project and its possible negative implications, but also understand the project and its potential benefits to their communities and surrounding environment. Failure to do so could cause disputes and disagreements between communities, the developer and government authorities and the disruption of established structures such as community administration. 9.2 NATIONAL LEGISLATION ON STAKEHOLDER ENGAGEMENT Both the Constitution and Environment Law establish the rights of citizens to have information about, and to participate in, decision-making about activities which may affect the environment. In summary, the directive requires that a Stakeholder Engagement process is carried out whenever the proposed activity implies the permanent or temporary relocation of people or communities, and the relocation of goods or assets or restrictions on the use of or access to natural resources. Stakeholder Engagement is expected to identify the PAP, disseminate information to them, manage a dialogue with the proponent of the activity, assimilate and take into account public comments received and feedback the outcomes of the dialogue and inputs so as to demonstrate how these have been taken into account in the design of the activity. Stakeholder Engagement is an integral part of the ESIA process and will not end with the issuing of the environmental license but will continue during the construction and operational phases of the planned activity. 9.3 STAKEHOLDER ENGAGEMENT PLANNING A Stakeholder Engagement Plan (SEP) is the basis for building strong, constructive and responsive relationships that are essential for the successful management of a project's E&S impacts. This is an on-going process that may involve, in varying degrees, the following elements: Stakeholder engagement planning; disclosure and dissemination of information; consultation and participation; a Grievance Mechanism; and on-going reporting to affected communities. The main objectives of an SEP are as follows:

Disclosure of planned project activities

Identification of concerns and grievances from stakeholders

Harnessing of local expertise and knowledge from interested and affected people

Response to grievances and enquiries of stakeholders

Promoting collaborative efforts Stakeholder engagement is initiated during the ESIA process and continues for the duration of the project’s life cycle. As a minimum, the SEP should be:

Underpinned by the concept of free prior and informed consent

Structured in accordance with best practice guidelines such as the International Finance Corporation’s (IFC) guideline document “Stakeholder Engagement: A Good Practice Handbook for Companies Doing Business in Emerging Markets” (IFC, 2007)

According to the above source, eight central pillars of a SEP include the following:

1. Stakeholder identification and analysis 2. Information disclosure 3. Stakeholder consultation



4. Negotiation and partnership 5. Grievance management 6. Stakeholder involvement and project monitoring 7. Reporting to stakeholders 8. Management functions

Disclosure of relevant project information helps affected communities and other stakeholders understand the risks, impacts and opportunities of the project. Suni Resources will provide affected communities with access to relevant information, and consultation gives affected communities the opportunity to express their views on project risks, impacts and mitigation measures in a non-intimidating setting. In instances where stakeholder engagement is the responsibility of the national authorities, Suni Resources will collaborate with the responsible government agency, to the extent permitted by the agency, to achieve outcomes that are consistent with the required objectives. This is particularly relevant to the land use right application that is still to be concluded at the time of writing this report. In addition, where government capacity is limited, Suni Resources will play an active role during the stakeholder engagement planning, implementation and monitoring stages. Additional benefits of timely stakeholder engagement include the following:

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

It harnesses traditional knowledge which conventional approaches often overlook

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

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

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

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

It may avoid escalation of potential conflicts between the company and the stakeholders This approach is also fundamental to ensuring that if Social Development Plan (SDP) programmes and initiatives are developed by Suni Resources as part of its corporate social responsibility commitments, these are informed by these communities’ needs and desires.

9.4 PROPOSED STAKEHOLDER ENGAGEMENT PLAN Community engagement will be undertaken in accordance with the requirements of the national legislation and regulations. This will be achieved through the development of a SEP prior to any further project-related activities that affect the stakeholders and surrounding villages in any way. The SEP will include an External Communications and Grievance Mechanism procedure. These requirements are interpreted as follows:

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

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

Stakeholder engagement must be initiated early in the environmental, social and health assessment process (scoping phase) and continue on an on-going basis throughout the life of the project

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

As part of this process, Suni Resources will develop a list of stakeholders which will be captured in



the SEP. The list will be considered dynamic and will need regular updating, as the relationship between stakeholders and Suni Resources develops and changes. 9.5 EXTERNAL COMMUNICATIONS AND GRIEVANCE MECHANISM Suni Resources will implement and maintain a procedure for external communications that includes, at a minimum, methods to:

Receive and register external communications from the public

Screen and assess the issues raised and determine how to address them

Provide, track and document responses, if any

Adjust the management program, as appropriate. In addition, Suni Resources will make publicly available periodic reports on their E&S sustainability.

Suni Resources will establish a Grievance Mechanism to receive and facilitate resolution of affected communities’ concerns and grievances about its E&S performance. The Grievance Mechanism will allow for the resolution of concerns promptly, using an understandable and transparent consultative process that is culturally appropriate and readily accessible, and at no cost and without retribution to the party that originated the issue or concern. Judicial or administrative remedies will not be impeded by the implementation of the Grievance Mechanism and will inform the affected communities of the procedure and requirements of the mechanism during the stakeholder engagement process. Suni Resources will conduct periodic reporting to the affected communities on progress with implementation of the project, issues that involve on-going risk to or impacts on affected communities and issues that the consultation process or Grievance Mechanism have identified as a concern to those communities. The frequency of these reports will be proportionate to the concerns of affected communities but not less than once annually.



10. MINE CLOSURE AND DECOMISSIONING 10.1 WHY A PRELIMINARY MINE CLOSURE PLAN IS REQUIRED In accordance with the Mozambican legislation (Environmental Framework Act (Law No. 20/97, 1 October 1997), a Mine Closure Plan is required for the Suni Resources Graphite Project. The activities associated with mine closure and rehabilitation are designed to prevent or minimise adverse long-term environmental impacts, reduce risks to adjacent communities, and if possible to create a self-sustaining natural ecosystem. Alternatively, rehabilitation and closure could be towards an alternative land use, based on an agreed set of objectives linked to the mine closure and rehabilitation programme. This plan must support the operation in achieving a post closure status that leaves behind a positive legacy in the community. Health, safety, social, environmental, legal, governance and human resource aspects all need to be considered and addressed. The long term nature of the proposed operations (34 years), places limitations on the amount of detail that can be included in this current draft closure plan, and it should therefore be regarded as being ‘conceptual’. This current version of the closure plan would therefore need to be reviewed regularly to keep in line with legislative, environmental, technological and socio-economic changes over the operational period, and to align with any changes to the mining process. Mine rehabilitation must be viewed as an on-going programme designed to restore the physical, chemical and biological quality or potential of air, land and water regimes disturbed by mining to a state acceptable to the regulators and to post-mining land users. Rehabilitation can take place throughout the life of mine, whereas mine closure by definition refers to those activities that take place after production has ceased. The developed world (e.g. Australia and United Kingdom) are among the leading countries in developing mine closure and rehabilitation programmes and objectives. This is well articulated in the International Council on Minerals and Metals (ICMM) Planning for Integrated Mine Closure Toolkit. It is amongst the most widely used international guideline documents for mine closure. The recommendations included in this report draw from the ICMM Guidelines which are explained in more detail below (Figure 10.1). A Mine Closure Plan for the project will be developed by Suni Resources, initiated at this early stage as a Conceptual Closure Plan. These differ as a Conceptual Closure Plan should communicate the expected outcomes and goals of the closure activities, whereas the more a detailed plan includes timeframes and milestones, detailed methodologies for achieving goals, more detailed budgets, rehabilitation and site amelioration specifications, and monitoring and validation processes. This detail can only come later, when more details on the engineering designs of all components of the project are available. This Conceptual Closure Plan is developed now for use during pre-feasibility, feasibility and design phases of the project, and to inform the EIA process. Its active life may be a few years, but if well-defined and based on effective community and stakeholder engagement, it may not change much during the first five years of construction and mining. However, the closure plan must be reviewed every five years over the life of the mine, in order to accommodate any changes in mining area, approaches to mining and other technical refinements that are likely to take place during the start and ramp-up phases of the project. These changes would also trigger a revision of the Closure Plan budget, to ensure that sufficient funds are available to cover any additional costs. This rest of this section provides the broader principles and methodologies that will be adopted by the company to guide further closure planning, and provides the anticipated outcomes and objectives of the Conceptual Closure Plan. 10.2 TARGET CLOSURE OUTCOMES AND OBJECTIVES The target closure outcomes of the Mine Closure Plan should be to (ICMM, 2008):

Restore as much as possible of the mine area to a condition consistent with the pre-determined post closure land use objective.



Ensure that the mine area is left in a condition which poses an acceptable level of risk to public health and safety.

Reduce, as far as is practically possible, the need for post closure intervention, either in the form of monitoring or on-going remedial works.

Minimise or prevent post-closure environmental degradation (to the soils, water and air), by ensuring that the mine area is left in a condition that is chemically and physically stable.

As far as practical, minimise the immediate negative economic impacts to local communities associated with mine closure and maximise the likelihood of lasting benefits to local communities. This will include leaving infrastructure in place that has a post mining value to the communities.

Figure 10.1: The integrated mine closure planning approach as recommended by the ICMM (2008)

The objectives of the Mine Closure Plan are further expanded upon below:

Physical Stability - Mine structures that remain post closure should be physically stable such that they do not pose a hazard to public health and safety as a result of failure or gradual degradation. These structures should only erode and/or release solids into the environment to the extent that degradation of the surrounding area does not occur.

Chemical Stability - The infiltration, leachate or run-off from the mine site or waste storage facilities should not endanger public health and safety, or result in the pollution of soil, surface water or groundwater, or non-compliance with statutory water quality limits.

Land Use - Post closure, the mine site should be compatible with the surrounding land, to the extent that it is both practical and economical to do so.



Social - Post closure the mine should ensure that the needs of communities impacted and dependent on the mine are appropriately addressed. Social risks must be identified, and goals need to be defined and set for, inter alia, the following: poverty alleviation, education, health care, employment and employability, and improving social infrastructure. This will include leaving infrastructure in place that has a post mining value to the communities.

10.3 SITE SPECIFIC CLOSURE OUTCOMES, OBJECTIVES AND TARGETS At this stage, the proposed post closure land use will likely be a combination of agriculture (machambas) and natural vegetation within defined ecological corridors, although no final decision has been made. The following main objectives have been set:

Disturbed areas are to be returned to as close to their original state as practicable, by implementing a revegetation and replacement strategy.

The mine pits will be retained as voids, which will fill with water. They will be designed for long-term stability by sloping the perimeter walls of the open pits at 1:3 (18º) angles, and access will be controlled.

Waste rock dumps are to have a 1:5 slope and be covered with a minimum of 300 mm of topsoil and/or other suitable growing medium (e.g. saprolite covered with organic matter or wood chips) and vegetated with indigenous species.

The TSF is to be capped at closure with 300 mm of saprolite and covered with organic matter or wood chips, and must be dome shaped to avoid the ponding of water, and vegetated.

No topsoil shall be harvested from undisturbed areas for use in the rehabilitation and revegetation strategy.

Socio-economic impacts (including the loss of employment) will be minimised through careful planning and preparation for closure beginning three to five years before closure takes place.

Retrenchments and job losses are to be minimised by developing self-sustaining community development projects during the life of mine, as part of the company’s ongoing but yet to be developed Community Development Programme.

The above principles and concepts will be refined as part of on-going detailed closure planning and costing during the life of mine. 10.4 APPLICABLE MOZAMBICAN STANDARDS This Preliminary closure report has been compiled in fulfilment of the relevant Mozambican legislation. The overarching item of environmental legislation is the Environmental Framework Act (Law No. 20/97, 1 October 1997) which governs the use and correct management of the environment and its components, and to ensure sustainable development. It is the foundation for the legal instruments for the preservation of the environment. According to the Environment Act, the mining operation is liable for the costs of rehabilitating the degraded environment or restoration thereof. In terms of the above-mentioned Act, the ESIA conducted for the proposed mine must include a Closure Plan. The Closure Plan has to provide an indication of the rehabilitation costs related to the closure of the mine as mining activities are required to provide a bond to cover the costs of rehabilitation during mine closure. The value of the bond is set by the Government and is reviewed every two years. The bond may take the form of an insurance policy, a bank guarantee or a deposit in cash in a bank account that the Government maintains specifically for the purpose. 10.5 DECOMMISSIONING, REHABILITATION AND CLOSURE OF SPECIFIC COMPONENTS

The objective of pit rehabilitation is to ensure that the site is left in a state that poses minimal risk to the health and safety of humans and fauna (wildlife and livestock) and the health of the environment. The Lennox and Byron pits will disturb approximately 52 ha of land. It is not possible (from a cost and operational perspective) to backfill the pits with overburden. Thus, they will be left to fill with water in order to become in-pit lakes. Final pit slopes will be designed for long-term stability. This is normally



achieved by sloping the perimeter walls of the open pit at a 1:3 (18º) angle to the pit floor, or to the stable groundwater level that could establish within a reasonable period. This pit wall sloping renders the pit safe for humans and domestic animals. Where concerns exist regarding the risk that the pit water poses to humans and animals, it will be necessary to implement measures to reduce access to the pit. As fences would be stolen, this may be achieved by the construction of a sizable berm around the entire perimeter of the open pit to keep domestic animals out and restrict human access. A further option is to plant an impenetrable vegetation barrier around the pit, using a spiny, fast growing but non-invasive species such as sisal. Prior to making a choice about a suitable species, a risk assessment to determine the potential for the species to become invasive must be undertaken. Signs will be erected around the open pit and on all approach roads warning the public of the potential dangers of falling or drowning. These signs will be in Portuguese, local languages and symbols for illiterate people. Access ramps to the open pit will be closed off to prevent vehicle access. In addition, as part of the closure process, local communities will be informed directly of the potential hazards and precautionary measures to be observed around the pit. The mine closure plan and, in particular, the costing, will need to be updated to include these measures if they are considered necessary. In addition, the shape of the open pits could be optimised to establish a rich aquatic life layer post closure, maximising the shallow zones along the edges of the pit to have shallow water which will facilitate the formation of an aquatic habitat, and improve safety.

Two Waste Rock Dumps (WRD) will be established, one for the Byron Pit and one for the Lennox Pit. The WRD will consist of all overburden and waste material generated during mining. To significantly reduce the costs of rehabilitation, the final slope angle may be designed with an 18 degree angle (1:3) in the lower slopes and up to 37 degrees (1:1.32) in the upper slopes. Upon closure the WRD sides and tops must be covered with a minimum of 300 mm of topsoil and vegetated with indigenous species during the wet season. Generally, average re-profiled outer slopes that have been re-vegetated will curb storm water flow velocities on the slopes. In addition, this should reduce precipitation percolating into the WRD. Should the WRD not be decommissioned with a proper cover system, monitoring of geotechnical properties within the WRD must be undertaken on an on-going basis to ensure the stability of the WRD.

Figure 10.2: Cross section of the Balama Central Graphite Project waste dump design showing the angles of the slopes rehabilitated progressively with mining operations.

Chemical analysis must be undertaken for representative waste rock samples prior to construction and at regular intervals during the operational life of the mine. This test work is required to confirm whether the proposed waste rock could potentially be acid generating. This conceptual closure plan will then need to be updated to include the results from this analysis. It is recommended that the



shaping of the WRD slopes be undertaken during the operational phase of the mine and that if acid generating waste rock has been identified, that this be separated from non-acid generating waste rock. Acid generating waste rock will need to be encapsulated within non-acid generating waste rock in order to prevent/minimise the risk of acid mine drainage formation. Run-off from the surface of the waste rock dumps should be directed via the site drainage system into the open pit. This will minimise the risk of contamination of local watercourses. At closure the waste rock dumps must be covered with saprolite and then topsoil, if available. If not, then compost or wood chips will be required, as saprolite is not a suitable growing medium for plants. Top soil must not be collected from undisturbed areas for use in waste rock dump revegetation.

The TSF will be located north-east of the proposed plant location. The TSF is expected to cover a total footprint area of approximately 188.47 ha over the 34 year Life of Mine (LoM). Chemical analysis must be undertaken for representative tailings samples prior to construction and at regular intervals during the operational life of the mine. This test work is required to confirm whether the proposed tailings could potentially be acid generating. This conceptual closure plan will then need to be updated to include the results from this analysis. To minimise the potential negative environmental impacts (both chemical and physical) of the TSF at closure and post-closure, the following is proposed for the TSF:

During the construction phase topsoil must be stripped (at least 100-300 mm and subsoil/saprolite (minimum 300 mm)) before the TSF is constructed. These materials will be used to cover the WRDs and TSF post closure;

Construct a permanent spillway to ensure physical stability of the facility during storm events. This will be done during the construction phase of the TSF;

Cover the TSF with a saprolite layer (at least 300 mm thick, but contoured to ensure free drainage of surface runoff post-closure) followed by 100 to 300 mm topsoil, and then establish vegetation;

The TSF should be graded to form a dome, to allow incidental rainfall to run off the surface of the TSF and to reduce water ingress into the tailings mass;

The TSF should have an external slope of 1:3 (vertical:horizontal) to ensure that it remains a stable landform in the long term, and to make it suitable for revegetation; and

Monitoring of groundwater and surface water qualities around and downstream of the TSF area.

The proposed haul and access roads around the site should be ripped, except those needed to access the facilities for inspection after closure. Roads that can and will be used by other users post closure should, however, be left, provided this is agreed upon by all parties concerned. These roads should then be handed over to the relevant authority (such as the Department of Roads) in order to ensure its proper maintenance in the long term. Any roads which will no longer be required will be rehabilitated. In general the following will be undertaken:

Bridges, culverts and ducts will be removed where they are no longer required.

The natural water flow will be restored and any disturbed section of the watercourse will be stabilised and revegetated.

The road surface, shoulders and embankments will be graded to a slope suitable to prevent erosion. Cuttings will be assessed and where necessary measures to improve safety and erosion stability will be implemented.

Certain infrastructure may remain post closure. The objectives are to:



Hand over the haul road to the appropriate government department (i.e. Department of Roads) for utilisation by the local communities once mining has been completed.

Hand over the two weirs to the appropriate government department in order to provide a permanent water supply to the local communities in the area.

Hand over the clinic services to the local communities in the area, which will be of benefit of the local communities as healthcare facilities are scarce commodities within the region.

Consider handing over the administration facilities for modification into a secondary school for the area.

Consider handing over the workshop and maintenance area, and use this to support a post closure training programme for local community use. This will require the development of a technical training programme as part of the mine’s CSD programme prior to closure.

Once closure is complete, a decision to either demolish any other remaining facilities or hand them over to the local authorities for conversion into social infrastructure will need to be made through a consultative process. The structural integrity of any structures that are to remain on site for use by local communities must be assessed by an independent specialist prior to handover. Any structures that are found to be structurally defective must either be demolished or repaired prior to handover. All other infrastructure will be decommissioned as follows:

Any surface buildings and infrastructure which are no longer required will be demolished, unless specific directives to the contrary are received from the authorities. Such directives may result from communities’ requests. This will need to be confirmed through a stakeholder engagement process undertaken as part of the closure plan goal refinement exercise and responsibility post closure assumed by the party taking control.

A detailed plan indicating the location of any remaining infrastructure will form part of the closure plan.

All brick and concrete buildings associated with the processing plant will be demolished and the rubble buried either on site to a minimum depth of 1.0 m, or placed in the TSF and then covered with saprolite and top soil.

Foundations will either be removed or will be covered with a layer of soil, or soil forming material, the depth to be determined following trials to be undertaken.

Non-re-useable materials including rubble and waste will be disposed of at suitable sites in accordance with the waste management and disposal plan that will be developed.

Following the removal of the infrastructure, a soil contamination assessment will be undertaken by an independent specialist, and remediation and re-vegetation activities implemented where necessary.

Support infrastructure buried underground, such as tanks and their pipes, and other pipes and service tunnels will, depending on the proposed future use of the site, either be kept as is or be unearthed and removed from the site. If they are to be left in-situ, the integrity of all underground pipes and tanks will be assessed by an independent expert. If the integrity of sub-surface infrastructure is compromised, it must be removed.

Any sub-surface infrastructure (including but not limited to pipes and tanks) that are likely to contain hazardous chemicals (including fuel) must be removed.

Any remaining openings and access ways will be blanked.

Electrical equipment and infrastructure such as transmission towers, electric cables and transformers which are no longer required will be demolished and removed from the site. The soils in the vicinity of transformers will be assessed for contamination and appropriate decontamination measures will be implemented, in accordance with Mozambique regulatory requirements, if necessary.

All disused mining plant and equipment, such as winches, pumps and conveyors, concentrator equipment such as thickeners, and heavy machinery will be removed from the site. It is not anticipated that any of this machinery or equipment will be contaminated. However, the mine will confirm this before any machinery or equipment is removed from the site. If any of the machinery or equipment is found to be contaminated it will be appropriately decontaminated before being removed.

During the mitigation and rehabilitation works, particular attention will be paid to the places where equipment was parked. The mine will assess these sites and if the soils are contaminated



appropriate remedial measures will be taken in compliance with Mozambican regulatory requirements.

There will be a landfill on site for general waste. The design of this landfill has not yet been finalized. At closure the following will apply: o On completion of the land fill the covers will be completed and re-vegetation of the cover

undertaken. o The Closure Plan for the mine will include details for the closure of the landfill and will ensure

that the closure of this specific facility meets the requirements of Mozambique legislation and international best practice. Post-closure monitoring of these facilities may be required.

The soil and vegetation function in disturbed areas will be restored.

General surface rehabilitation should ensure the surface topography emulates the surrounding area, is free draining, has a “neat” appearance and is re-vegetated. Special attention must be given to shaping and removal of heaps of excess material, scrap and waste. The entire area is to be ripped, covered with 300 mm of topsoil and vegetated. The details of the revegetation must be documented in a comprehensive rehabilitation plan. 10.6 SOCIAL COMPONENTS OF CLOSURE

Post closure the mine should ensure that the project affected communities and those who have become dependent on the mine are suitably catered for. The following must be considered:

Ensure future public health and safety of local communities are not compromised;

Close the site so that the post-closure use of the site is beneficial and sustainable to the affected communities in the long term;

Minimize adverse socio-economic impacts are maximize socio-economic benefits. Although an SIA has been undertaken for the ESIA, the SIA focused on the construction and operation phase, with little detail on the decommissioning phase. As part of the mine closure process, Suni Resources should conduct a Closure Social Impact Assessment (SIA). This study can be used as a basis to engage with communities to understand perceived impacts, identify how best to manage adverse impacts and explore opportunities that mine closure may bring. The Closure SIA will take the following strategic issues into consideration:

Job losses – Prior to retrenchment, alternatives to retrenchment must be considered. Only if no viable alternative is available should retrenchment be implemented, in accordance with a retrenchment management plan that has been developed in order to minimise adverse impacts of retrenchment on workers. The retrenchment management plan must be non-discriminate and reflect sufficient consultation with workers, their relevant organisations and if applicable the government. In addition, the retrenchment management plan must comply with any existing bargaining agreements.

Psychological impacts (on employees and the broader community);

Impacts on suppliers (business planning workshops pre-closure with SMME to assist them moving on from reliance on the mine);

Health impacts;

Loss of income to the municipality and government (fiscal impacts);

Discontinuation of Social Labour Plan (SLP) and Corporate Social Responsibility (CSR) activities;

The nature of the current economic / social contribution compared to the future contribution / loss of contribution post closure.

General site hazards that pose a risk to the safety of local communities: Risk management strategies for general site hazards may include: o Restricting access to the site, through a combination of institutional and administrative

controls, with a focus on high risk structures or areas. This depends on site-specific situations, and might include fencing, signage and communication of risks to the local community.



o Removing hazardous conditions on sites that cannot be controlled effectively through site access restrictions. This should include covering openings to small confined spaces, ensuring a means of escape for larger openings such as trenches or excavations and removing hazardous materials.

The information that will be gathered from this study will provide room for engagement between the company and other interested and affected parties, such as local councils, government and other organizations, about impact mitigation policies and the legacy aspects of mine closure. In addition, engagement with internal and external stakeholders will be undertaken throughout the life cycle of the project, and to achieve lasting benefits at a local and regional level, Suni Resources appreciates that the views of external stakeholders must be understood. To ensure that these benefits are delivered, Suni Resources will identify key external stakeholders and engage with them to foster a two-way understanding of mutually beneficial outcomes. These outcomes will be explained and presented in the Comprehensive Closure Plan and disclosed to stakeholders in a manner consistent with the requirements of the applicable standards referred to above (Chapter 9). Engagement with affected communities throughout the life of the project is essential and to this end, the company will be guided by the approach recommended by the ICMM. It is recognized that to achieve effective closure that is beneficial to the operating company and the community that hosts it, the views, concerns, aspirations, efforts and knowledge of various internal and external stakeholders must be brought together. This should be determined using a multi-stakeholder process that includes regulatory agencies, local communities, traditional land users, adjacent leaseholders, civil society and other affected parties. For the Suni Resources mine this will involve:

Incorporating closure planning into the early stages of project development and operations;

Collating the goals and views of various stakeholders (project owner, local community, government, and non-governmental organizations (NGOs)) at the early feasibility (EIA) stage of project development to inform closure and post closure goals;

Acting to meet the goals by working with the relevant stakeholders;

Using the concepts of risk and opportunity to both minimize liability and maximize benefits to all relevant parties;

Using multidisciplinary expertise and multi-stakeholder processes to ensure that mitigation of risk in one area does not increase risks in another; and

Ensuring that the social closure phase ties in with the infrastructural and environmental closure phases.

10.7 POST CLOSURE MINE SITE INSPECTION, ENVIRONMENTAL MONITORING AND

REPORTING The post closure period usually comprises three phases:

Active phase, years 1-2

Passive phase, years 3-5

Inspection phase, years 5-8 During the active two-year period the company will continue supplying specific social services to surrounding communities in line with the corporate social responsibility agreements that would have been put in place during the mining operation. During the life of the mine, the company will continuously engage the local authorities and traditional leadership structures as part of the hand over process (i.e. handing over the infrastructure and services). All actions will be guided by the on-going dialogue between the mine and relevant stakeholders. The passive three-year period will most likely entail the handover of the infrastructure and services to the relevant local and/or provincial authority (i.e. handing over of roads to the Department of Roads). Suni Resources proposes that at the same time it will provide advice on technical or social issues that may arise during this 3-year period with a final sign off taking place in the 5th year post closure. Suni Resources will implement a programme of post closure environmental inspection and monitoring



to assess the success of mine reclamation and verify that the various components of the closed mine are not adversely impacting adjacent watercourses and groundwater, and do not pose a potential health risk and/or danger to the public. The purpose of monitoring is to ensure that the objectives of the rehabilitation programme are met and that the progressive rehabilitation process is followed as planned during the life of the mine. The regularity of the monitoring will be dependent on the aspect being monitored, for example dust and groundwater monitoring will be ongoing and will be initiated prior to construction to obtain baseline values, whereas biodiversity (mainly rehabilitation) monitoring will take place progressively throughout the operational and closure phases. An independent consultant will conduct the site inspection and environmental monitoring prior to final closure. Suni Resources proposes that post closure environmental inspection and monitoring be conducted bi-annually for the first 2 years to establish seasonal variations. Bi-annual site visits will be made before the rains and at the end of the rains (active phase). It is expected that final inspection and monitoring will be conducted 5 years after mine closure, but this will depend on the success of the closure and rehabilitation process (passive phase). The findings of this inspection will determine whether or not any further post closure site inspection is necessary (inspection phase), or whether further interventions to improve, for example, the revegetation of areas will be required. Detailed tracking of the progress of progressive rehabilitation will also permit the annual review of the closure plan to reflect this progress, thus reducing or increasing the quantum required for final closure costs. The physical aspects of rehabilitation should be carefully monitored during the operational phase as well as during closure, so that deviations from expectation can be catered for in subsequent versions of the mine closure plan and costing. Post closure environmental inspections will focus on:

TSF and WRD wall stability;

Pit wall stability and water levels;

Erosion on the waste rock dump sidewalls and upper surfaces;

Surface and ground water quality and quantity;

Success of establishing an indigenous vegetation cover in areas where it has been established;

Proportion of mined land that has been fully rehabilitated;

Any activity by the general public or persons unknown that may adversely affect the stability of disused mine structures, pose a danger to the community or possibly result in environmental degradation;

The condition of site access roads, bridges and culverts.

Alignment of actual final topography to agreed planned landform;

Depth of topsoil stripped and placed;

Chemical, physical and biological status of replaced soil;

Community health and safety; and

Socio-economic status of affected communities. Consultations will be held with local community leaders to listen to and record any issues of concern pertaining to the closed mine site. An external consultant should produce an annual post-closure environmental monitoring report at the end of years 1 and 2 and a final post closure environmental report at the end of year 5. These post closure environmental reports will be submitted to Mozambique government entities and made available to all stakeholders. The reports will present the findings of the mine site inspections/walkovers and the results of the environmental monitoring programmes. Where rehabilitation/reclamation activities have not obtained the desired result, the consultant will make recommendations on what additional reclamation work is required to achieve full reclamation. Any areas of concern will be highlighted. The reports will include a post closure photographic record of mine reclamation.



10.8 CALCULATION OF FUTURE FINANCIAL CLOSURE LIABILITY

The calculation of the financial closure liability associated with the proposed project has been undertaken by following best international practice methodology (Australia, USA, Canada and South Africa) as detailed in the Guideline Document for the Evaluation of the Quantum of Closure - Related Financial Provision Provided by a Mine as published by the South African Department of Mineral Resources, dated January 2005. The best practice procedure for calculating financial closure liability is summarised as follows:

Step 1: Determine the primary mineral and saleable mineral by-products.

Step 2: Determine the risk class of the mine.

Step 3: Determine the area sensitivity in which the mine is located.

Step 4.1: Determine the level of information available for calculating the financial liability.

Step 4.2: Determine the closure components associated with the mine.

Step 4.3: Determine the unit rates for the associated closure components.

Step 4.4: Determine and apply various weighting factors (site specific).

Step 4.5: Identify the areas of disturbance.

Step 4.6: Identify any specialist studies required.

Step 4.7: Calculate the closure liability using the guideline template provided.

The guideline requires that the type of mineral mined or processed, and the saleable mineral and by-products (not trace elements) be identified.

Mine/process type – Open Cast Mine

Saleable mineral – Graphite

By-products – Possibly Sulphur

According to the guideline, the Suni Resources Project is classified as a Class B – Medium Risk facility, as stockpiles of sub-economic ore may eventually develop acid seepage. Should further geochemical analysis show that this is unlikely, the project could potentially be downgraded to a Class C – Low Risk facility. The risk ranking class is used later to determine the multiplication factors applied to the master rate (see Step 4.3).

The Suni Resources Project is classified as having a High Environmental Sensitivity based on the classification criteria listed in Table 10.1 below. The environmental sensitivity ranking is used later to determine the multiplication factors applied to the master rate (see Step 4.3). Table 10.1: Sensitivity Ranking

SENSITIVITY SENSITIVITY CRITERIA

BIOPHYSICAL SOCIAL ECONOMIC

LOW

Largely disturbed from natural state,

Limited natural fauna and flora remains,

Exotic plant species evident,

Unplanned development,

Water resources disturbed and impaired.

The local communities are not within sighting distance of the mining operation,

Lightly inhabited area (rural).

The area is insensitive to development,

The area is not a major source of income to the local communities.

MEDIUM Mix of natural and exotic

fauna and flora,

Development is a mix of

The local communities are in proximity of the mining operation (within sighting

The area has a balanced economic development where a degree of income



disturbed and undisturbed areas, within an overall planned framework,

Water resources are well controlled.

distance),

Peri-urban area with density aligned with a development framework,

Area developed with an established infrastructure.

for the local communities is derived from the area,

The economic activity could be influenced by indiscriminate development.

HIGH

Largely in natural state,

Vibrant fauna and flora, with species diversity and abundance matching the nature of the area,

Well planned development,

Area forms part of an overall ecological regime of conservation value,

Water resources emulate their original state.

The local communities are in close proximity of the mining operation (on the boundary of the mine),

Densely inhabited area (urban or dense settlements),

Developed and well-established communities.

The local communities derive the bulk of their income directly from the area,

The area is sensitive to development that could compromise the existing economic activity.

The level of information available allows authorities to either accept (and/or independently review) the financial closure liability submitted, otherwise follow the ‘rule-based’ approach. Since no detailed Closure Plan for the Suni Resources Project has been developed and/or approved by the Mozambique Authorities, and subsequently no detailed breakdown of costs can be prepared and sufficiently motivated for, the step-by-step ‘rule-based’ approach for calculating closure liability should be followed.

The closure components relevant to the site-specific conditions are to be determined from the list provided below: 1. Dismantling of processing plant & related structures (incl. conveyors & power lines)? Yes

2. Demolition of steel buildings & structures? Yes

3. Demolition of reinforced concrete buildings & structures? Yes

4. Rehabilitation of access roads? No (it is assumed that these will remain to be utilised by the

local communities)

5. Demolition & rehabilitation of electrified railway lines? No

6. Demolition & rehabilitation of non-electrified railway lines? No

7. Demolition of housing &/or administration facilities? No (it is assumes that these will remain to

be utilised by the local communities)

8. Opencast rehabilitation including final voids & ramps? Yes

9. Sealing of shafts, adits & inclines (excl. backfill of decline voids)? No

10. Rehabilitation of overburden & spoils? Yes

11. Rehabilitation of processing waste deposits & evaporation ponds (basic, salt producing waste)?

No

12. Rehabilitation of processing waste deposits & evaporation ponds (acidic, metal-rich waste)? Yes

13. Rehabilitation of subsided areas? No

14. General surface rehabilitation? Yes

15. River diversions? No

16. Fencing? Yes

17. Water management? Yes

18. 2 to 3 years of maintenance & aftercare? Yes

A short summary of what each of the above closure components entails is included in the section

below:



Item 1 - Dismantling of processing plant and related structures:

All infrastructure and concrete buildings should be broken down to natural ground level and buried adjacent to the plant site.

Foundations, structures and conveyors should be broken down to natural ground level.

The areas should be shaped, top soiled with 300 mm of topsoil and vegetated or rehabilitated.

The master rate for this was considered to be extremely low at $1/m3 and thus the rate was adjusted and aligned to similar projects conducted.

Items 2 & 3 - Demolition of steel buildings and structures and demolition of reinforced concrete

buildings:

All structures should be demolished to 1m below ground level.

The rubble is to be buried adjacent to the sites, provided this adheres to the National Waste Management Strategy.

The areas should be shaped, top soiled with 300 mm of topsoil and vegetated.

Monitoring and maintenance is costed in the relevant areas.

Item 4 - Opencast rehabilitation including final voids and ramps:

The opencast pit perimeter walls must still be rendered safe for humans and domestic animals. This is normally achieved by means of the following: o Sloping the perimeter walls of the opencast pit at 1:3 (18°) to the pit floor or to the stable

groundwater level that could establish within a reasonable period within the opencast pit. o Providing enviro berms and ditches along the opencast pit perimeter when perimeter wall

flattening is not feasible, as in those cases where opencast mining has been conducted on steep mountainsides.

Item 5 - Rehabilitation of overburden and spoils:

Shaping to create a stable landform as it usually has a low potential for pollution.

The areas should be shaped, top soiled with 300 mm of topsoil and rehabilitated.

Item 6 - Rehabilitation of processing waste deposits (acid, metal rich waste) (specifically the TSF):

The generally accepted closure methods for acidic, metal-rich plant waste are primarily aimed at the following: o Limiting seepage of contaminants from the waste deposit. o Prevention of contaminated seepage entering local surface and groundwater sources.

The master rate thus includes allowances for slope modification, armouring and evaporative covers, linings, water management (i.e. stormwater drains and trenches) and surface and groundwater impact management.

This master rate could potentially be adjusted if further analysis shows no / low potential for AMD.

Item 7 - General Surface Rehabilitation:

Surface topography that emulates the surrounding areas and aligned to the general landscape character. Steep slopes in excess of 6 percent should also be avoided if possible.

Landscaping that would facilitate surface runoff and result in free draining areas. If possible, the drainage lines should be reinstated.

An area without unnecessary remnants of structures and surface infrastructure to give the rehabilitated area a “neat” appearance. Special attention must be given to shape and/or removal of heaps of excess material being the legacy of prolonged mining and related activity.

An area suitable for revegetation. Item 8 - Fencing:



Self-explanatory. Item 9 - Water Management:

Current practice is to provide in-pit evaporation dams for opencast pits. Ideally these dams should be monitored and coincide with pit final voids.

The dams should be sized that groundwater inflow into the pit plus rehabilitated spoils recharge can be evaporated from the dam. The dam perimeter as in the case of opencast pits must be shaped to render it safe.

Item 10 - Two to three years of maintenance and aftercare:

Annually fertilising of rehabilitated areas.

Monitoring of surface and subsurface water quality.

Control of alien plants.

General maintenance, including rehabilitation of cracks and subsidence.

The unit (Master) rates, for each closure component is taken from the Guideline Document for the Evaluation of the Quantum of Closure - Related Financial Provision Provided by a Mine as published by the South African Department of Mineral Resources, dated January 2005. Furthermore, a Multiplication Factor is applied depending on the Risk Ranking and the Environmental Sensitivity (calculated in Step 2 and 3 previously). Table 10.2: Master rates for rehabilitation

DESCRIPTION UNIT MASTER RATE

(US$) FACTOR

Item 1 - Dismantling of processing plant & related structures m3 (CES estimation in Table 10.5 below)

1.20

Item 2 - Demolition of steel buildings and structures m2 $14.10 1.20

Item 3 - Demolition of reinforced concrete structures m2 $20.77 1.20

Item 4 - Opencast rehabilitation including final voids and ramps ha $14,350.22 1.20

Item 5 - Rehabilitation of overburden & spoils ha $9,853.72 1.20

Item 6 - Rehabilitation of processing waste deposits (acidic, metal-rich waste)

ha $38,890.00 1.20

Item 7 - General surface rehabilitation ha $7,805.81 1.20

Item 8 - Fencing m $890.40 1.20

Item 9 - Water Management ha $2,967.99 -

Item 10 - Two to three years of maintenance & aftercare Years (CES estimation in Table 10.5 below)

1.20

Weighting factors based on the specific mine/process location presented in the table below. Table 10.3: Weighting Factors

Weighting factor 1 – Nature of terrain

Flat

Weighting 1.0

Undulating

Weighting 1.10

Rugged

Weighting 1.20

Weighting factor 2 – proximity to urban centre and services

Urban

Weighting 1.0

Peri-urban

Weighting 1.10

Rural

Weighting 1.20

The future areas of disturbance at the Suni Resources Project are listed as:

Byron and Lennox Pits

Processing plant,



Waste rock dumps,

Tailings storage facility,

Topsoil stockpiles,

Haul and access roads,

Construction camp,

Administration buildings, and

Landfill site.

The risk ranking identifies what type of specialist studies should be carried out to ensure successful closure of the mine and process operation. Table 10.4 details these categories: Table 10.4: Specialist study requirements

RISK RANKING SPECIALIST STUDIES

Class A – High risk Water pollution potential studies

Overall quantified risk assessment

Class B – High risk Screening level risk assessment

Class C – Low risk Screening level risk assessment

It is accepted that the proposed project is classified as a Class B risk ranking requiring the additional study presented above.

The provisionally estimated financial closure liability associated with the Suni Resources Project is US$ 12,908,152.63 for the future areas of disturbance (at the end of Life of Mine, LOM), and are presented in Table 10.5. Table 10.5: Projected project closure liability costs

The above costing and specifications will be reviewed during the mines operational phase for comprehensiveness, with the definitive Closure and Rehabilitation Plan that will be developed prior to the cessation of mining and operational activities detailing the definitive costs, actions and requirements for closure.

DESCRIPTION UNIT RATE (US$) QUANTITY MF W1 COST (US$)

Item 1 - Dismantling of processing plant & related structures

m3 - - - - Estimated $500,000

Item 2 - Demolition of steel buildings and structures

m2 $14.10 40000 1 1.2 $676,800.00

Item 3 - Demolition of reinforced concrete structures

m2 $20.77 40000 1 1.2 $996,960.00

Item 4 - Opencast rehabilitation including final voids and ramps

ha $14,350.22 52 1 1.2 $895,454.00

Item 5 - Rehabilitation of overburden & spoils

ha $9,853.72 169.6 1 1.2 $1,671,190.90

Item 6 - Rehabilitation of processing waste heaps

ha $38,890.00 188.47 0.9 1.2 $7,329,598.30

Item 7 - General surface rehabilitation ha $7,805.81 41.9 1 1.2 $327,063.43

Item 8 - Fencing m $10 1000 1 1.2 $12,000.00

Item 9 - Water Management ha $2,967.99 52 0.67 1.2 $124,086.00

Item 10 - Two to three years of maintenance & aftercare

Years $125,000,00 3 1 1.2 $375,000.00

TOTAL 12,908,152.63