workshop report...to kwale comprising of the different units with undp kenya (i.e pbcp, dgu, drr,...

Natural Resources Management for Sustainable Development in Kenya

EXTRACTIVE INDUSTRY

Training Workshop for CSOs, Kwale County Government Officials and Communities

8th -12th September 2014 (Swahili Beach Hotel)

WORKSHOP REPORT 19th September, 2014

Table of Contents Executive Summary ................................................................................................................ i

Acknowledgements ............................................................................................................... ii

INTRODUCTION .................................................................................................................... 1

Extractives Industry in Kwale ............................................................................................. 1

Scope and TOR of Community, Government officials and CSOs Workshop ......................... 2

METHODOLOGY ................................................................................................................... 3

Content delivery approaches ............................................................................................. 3

Evaluation and assessment ................................................................................................. 3

Profiling groups ................................................................................................................. 3

Challenges Encountered .................................................................................................... 4

Success Stories .................................................................................................................. 4

DAY 1 .................................................................................................................................... 5

Key Objectives .................................................................................................................. 6

Discussions on 8th September 2014 .................................................................................... 9

DAY 2 .................................................................................................................................. 12

Key Objectives ................................................................................................................ 13

Program of the day 9th September 2014 ............................................................................ 15

Discussions on 9th September 2014 .................................................................................. 15

PROFILE FOR CIVIL SOCIETY ORGANIZATIONS IN KWALE COUNTY .............................. 20

DAY 3 .................................................................................................................................. 24

Key Objectives ................................................................................................................ 25

Discussions on 11th September 2014 ................................................................................. 27

DAY 4 .................................................................................................................................. 30

Key Objective .................................................................................................................. 31

CONCLUSIONS AND RECOMMENDATIONS ........................................................................ 32

MINERAL DISTRIBUTION MAP OF KWALE COUNTY ............................................................ 33

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Executive Summary This workshop comes as result of consultations that have been on-going between the UN Resident Coordinator, UNDP Resident Representative and the Governor of Kwale County. They have been inspired by the recent announcement of oil discovery and other minerals which have propelled Kenya as a new player in the global market for hydrocarbons and valued minerals. However consistent opposition to the exploration and exploitation of minerals in Kwale County, in particular, is a matter of concern that calls for urgent attention.

To address this emerging private-public conflict the UNDP organized this workshop between 8th and 12th September 2014 in Kwale County with the objective of creating a sustainable working relationship and open a forum for communication among the stakeholders. The workshop training was to carry out a detailed profile of the Civil Society Organizations (CSOs) in Kwale County, understand the engagement among various stakeholders, initiate peace building efforts, evaluate the Corporate Social Responsibility (CSR) initiatives of Extractive Industry companies with the aim of improving Private-Public Dialogue (PPD) among others.

It was clear, from the onset, that lack of understanding and knowledge of the various players and operations in the Extractive Industry is responsible for the current poor state of affairs. So the training modules were designed to address this fundamental problem. The key subject matter touched on the legal and legislative aspects of the industry, Mineral distribution and potential of Kwale County, Advocacy, lobbying and negotiation skills, Management of Corporate Social Responsibility (CSR) Funds and Expectations, Case study of Extractive Industry CSR, Mediation and Peace building skills, Politics of Extractive Industry and Socio-economic impacts of EI in local communities. Particular attention was paid to the need to have full involvement of the participants and ownership of the products and process of the workshop. The best psychometric techniques were employed giving very satisfactory results.

The absence of some key players, such as Base Titanium, and lack of accurate Kiswahili translations for scientific and technical terminologies were a few of the challenges encountered. But these did not affect the outcome of the workshop which was to lay the foundation for peace-building in the extractive industry

Overall the workshop was very successful as indicated by the general change of attitude among the participants regarding the major industry players. From expressions of many contributors this was an eye opening experience that was very informative about the current status in the extractive industry.

The participants identified a number of challenges in the industry and suggested solutions to attain maxim benefit from mining. Some of the critical challenges include lack of capacity in the county to enable full engagement in the EI, communities not commensurately benefiting from the mining activities, negative environmental impacts, exploitation by middlemen, communities not involved in decision making, County government not getting appropriate remittances from Extractive Industry, lack of resources to enable local CSOs and CBOs carry out activities and lack of value addition technologies and industries among others.

There is need for more of these kinds of workshops as the number of issues and concerns raised could not be sufficiently addressed within the time allocated

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Acknowledgements

Appreciation and acknowledgement, first, goes to the UNDP for initiating, sponsoring and organizing this workshop. The County Government of Kwale is also equally acknowledged for supporting, participating and accepting to work with all stakeholders in the EI.

All participants from the Civil Society and Community representatives are greatly appreciated for their patience and valuable contributions during the workshop

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INTRODUCTION The management of extractive industries is one of the most critical challenges facing many resource-dependent developing countries today. Rather than stimulating broad-based economic development, reliance on resource extraction has tended to concentrate wealth and power in the hands of a few, exacerbate corruption and inequalities, lead to environmental degradation and pollution, while doing little to reduce poverty, economic disparities and generate employment. Worse still, in many countries extractive resources have fuelled violent conflicts1

Extractives Industry in Kwale

The recent announcement of oil discovery and other minerals has propelled Kenya as a new player in the global market for hydrocarbons and valued minerals. The International Monetary Fund (IMF) projects that oil production in Kenya is expected to start in six to seven years from now, giving the country time to prepare to manage its endowment to achieve its development goals as stipulated in the 2030 Vision.

Kwale County has a huge potential for mineral exploitation. Some of the already discovered minerals include Titanium (rutile, ilmenite, zircon) at Nguluku and Shimba Hills; Gemstones at Kuranze; Rare Earth Elements (niobium, phosphates) at Mrima Hills and Samburu; Silica Sands at Waa, Tiwi and Ramisi; Zinc, Lead and copper at Mkang‘ombe, Mwache, Dumbule and Dzitenge; Baryte at Lunga-lunga; Coal at MajiyaChumvi; Sandstones at Mariakani; Limestone at Shimoni and Waa; Coral rocks at coastline and a potential for offshore oil and gas.

Most recently, Cortec Mining Kenya Limited has announced that Mrima Hills in Kwale County has one of the largest rare earth mineral deposits in the world with a potential in-ground value of up to $62.4 billion.

In addition, the county has several on-going mining activities such as exploitation of limestone at Waa and Titanium at Nguluku and Mrima by Coast Calcium Limited and Base Titanium Limited respectively. Milli Glass Limited, Kenya Breweries Glass Limited and Eastern Chemicals are exploiting Silica Sands in the county as well. Other small scale mining of gemstones is ongoing in the county.

However there has been consistent opposition to the exploitation of minerals in Kwale County, local leaders, organized groups and the communities have opposed exploitation for various reasons including environmental considerations due to its perceived high radioactivity and environmental degradation to the issue of compensation for communal or individual land as well as community benefits-sharing amongst the various stakeholders. It’s for this reason that UNDP, in collaboration with other development agencies, has engaged the Kwale county government in seeking for an amicable, sustainable and beneficial relationship between communities and the extractive industry.

The UN Resident Coordinator and UNDP Resident Representative recently held consultations and dialogue with the Governor of Kwale County from 4th – 6th August 2014 to discuss ways of collaboration. It is envisioned that Kwale County will be part of the UNDP programming. One of the key recommendations of the meeting was for the UNDP to send a technical mission to Kwale comprising of the different Units with UNDP Kenya (i.e PBCP, DGU, DRR, Communications, EECCU and IEG).

1 Nicholas Shaxson (2007) Poisoned Wells: The Dirty Politics of African Oil

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As part of the first steps in supporting development agenda in the county, a training workshop was conceived to bring together all the stakeholders in the Extractive Industry and initiate a communication forum.

Scope and TOR of Community, Government officials and CSOs Workshop The key objective was to carry out a detailed profile of the Civil Society Organizations (CSOs) in Kwale County, understand their engagement with the various stakeholders and then carry out a five (5) day training workshop for the CSOs, Kwale Government officials and Communities to build on their engagement in community development, peace building, Corporate Social Responsibility (CSR) initiatives of Extractive Industry companies and Private-Public Dialogue (PPD) among others. The workshop was held inKwale County, at Swahili Beach Resort between 8th and 12th September 2014. This report is one of the key outputs from this assignment

Date Proposed Activity Mon., 8th– Wed., 10thSept.

Hold a 3 day training workshop for the Civil Society Organizations (CSOs), Government officials and communities to build on Corporate Social Responsibility (CSR) initiatives of EI companies

Thur., 11th Sept. Hold a one day meeting with the Kwale County and National Government Officials, mining companies and CSOs to facilitate public-private dialogue on the extractive industries in Kwale County

Friday, 12th Sept.

Engage the Kwale County Government and Communities in a peacebuilding forum for a day.

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METHODOLOGY Guided by the objectives of the workshop, which were to develop a detailed profile of the Civil Society Organizations, build on engagement in community development, peace building, Corporate Social Responsibility (CSR) initiatives of Extractive Industry companies and Private-Public Dialogue (PPD), relevant modules were designed to enhance the participants’ understanding and appreciation of the subject matter. The modules developed included the following

1. Legislative provisions governing Extractive Industry current and proposed 2. Mineral distribution and potential ofKwale County 3. Advocacy, lobbying and negotiation skills 4. Managing Corporate Social Responsibility Funds and Expectations 5. Case study of Extractive Industry CSR 6. Mediation and Peace building skills 7. Politics of Extractive Industry and Petroleum 8. Socio-economic impacts of EI in local communities

During the actual process of the workshop the following approaches were used to deliver content to ensure maximum impact and participation;

Content delivery approaches • Presentations in form of brief talks using illustrations demonstrations and narrations • Group Discussions and contributions in front of the congregation. This approach

is useful for ensuring that shy participants give their contribution in smaller groups

• Participants chairing sessions and guiding discussions ensures ownership of the final deliverables

• Use of videos to illustration real-life situations • Issuance of Handouts • Open discussion sessions in plenary

Evaluation and assessment To evaluate the impact of the workshop, the participants were asked to fill a simple questionnaire at the beginning to test their initial understanding of the module content before training. This was measured on the scale of good understanding, sufficient understanding, little understanding and No understanding. The same test was applied at the end of each group’s workshop enabling the measurement of the degree of appreciation of the module content. (The questionnaire is annexed to this report)

Profiling groups This workshop focused on three major stakeholder groups namely; community representatives, Civil Society Organizations and County government officials. However even within these groups there were diversities based on gender, education level, physical challenges and occupation. These are critical attributes for any group dynamics that would influence both the content and the style of delivery for effective learning.

Of key importance to this exercise was the profiling of CSOs. This was done by collecting information directly from the representatives present and was tabulated. The information collected included Name of the CSO, Postal Address, Registration No, Telephone. No., Contact Person, e-mail address, Year of Registration, Physical address, Main achievements, No. ofMembers/Collaborations (tabulated CSO profile available elsewhere in the report)

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Challenges Encountered Challenges encountered during the workshop were by and large surmountable except a few that are worth mentioning

1. Failure by some key stakeholders to send representatives to the workshop. A notable absence was Base Titanium which really missed the opportunity to showcase their laudable and elaborate CSRprogram and build bridges

2. Much of the module content consisted of technical terms (terms such as CSR etc) which may quite often not have direct Kiswahili translations, so for a purely Swahili audience there were challenges in content accuracy.

3. Time is always scarce and this exercise was no exception. The time available appeared really short for appropriate delivery of the content

Success Stories There were notable breakthroughs in this workshop that are worth mentioning, most of which were unexpected

1. The Kwale County Geologist Mr. Wafula encountered stiff resistance at Tsimba location when, at one time, he and his team had gone for coal exploration excursion. The residents of the area turned them away fearing that the team had come to start a mining venture without consulting them and that they would be relocated. So at the start of the workshop the representative from Tsimba location could not see eye to eye with the geologist. He was adamant and spoke with bitterness. But at the end of the workshop the two shook hands and the representative from Tsimba invited MrWafula to revisit the area and complete his exploration without any fear whatsoever after learning that what was going on was only an exploration.

2. At the end of the workshop the three groups participating agreed to form a secretariat chaired by the county minister for Lands, Mining and Natural Resources. This would provide the forum to iron out any communication difference and form a common front to face the challenges in the extractive Industry: Members of the secretariat included:

Government

i. Hon. Ali JumaMafimbo Minister forLands, Mining and Natural Resources (Chair) ii. Hon. SafinaKwekwe

iii. Hon. Mtsami Patrick

Civil Society

i. Mohamed Ali Mwasaro (Msambweni sub-county) ii. Everlyne David

Community representatives

i. FatumaMwachenda (Kinango sub-county) ii. SalimMwajawa (Matuga sub-county)

3. This workshop assisted a number of CSOs to appreciate the number of projectsthat

Base Titanium had established to support the local community. Most of them confessed ignorance of these efforts and underwent a diametrical mind shift in favor of the company

4. There was a notable improvement onthe understanding of workshop content and objectives by the participants. While at the beginning few if not none had a moderate understanding, at the end over 75% registered perfect understanding of the subject matter.

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DAY 1 Natural Resources Management for Sustainable Development in Kenya Training Workshop for Community Representatives from ward level 8th September 2014 (Swahili Beach Hotel)

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Key Objectives • Build on corporate Social Responsibility (CSR) initiative of Extractive Industry - Kwale

County • Facilitate public-private dialogue on the Extractive Industry in Kwale County • Engage the communities in a peace building forum

These are main module subjects and content covered in this session

Module Description Content

1 Legislative provisions governing Extractive Industry current and proposed

• Review of Old Mining Act • Highlight of the new Mining Bill • Loophole/strengths in the new Bill • Issues raised by Kwale County

2 Mineral distribution and potential of Kwale County

• Types of Minerals in Kwale County • Economic potential of the minerals • Issues affecting the industry

3 Advocacy, lobbying and negotiation skills

• bargaining power • legal context • Establishing community goals • What is negotiation? • Types of negotiation • Planning to negotiate • Factors for success • Language for negotiation • The Collective Bargaining Process • Sealing The Deal • Speaking out about injustices and

making the case for change. • Case studies of successful advocacy

movements. • Developing action plans based on

scenarios.

4 Managing Corporate Social Responsibility Funds and Expectations

• Effectiveness of CSR • Economic impact of CSR • assessing, aggregating and

understanding the costs of conflict • avoid the occurrence of conflict • The changing trends in CSR • CSR modes • Danger of community dependency • Community participation in decision-

making • Corporate-Community Interaction

5 Case study of Extractive Industry CSR • Magadi Soda model • Botswana Model

6 Mediation and Peace building skills

• The nature and trends of conflicts in the EI

• Characteristics of a mediator. • The importance of consent, trust and

long-term engagement • Models of mediation explained. • Perspectives of both upper-level and

grassroots level actors. • Introduction to nonviolence as a

strategy for change. • Documentary screening: Bringing

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Module Description Content down a Dictator (OTPOR, Serbia).

• Interactive session on protest movements in Kenya.

7 Politics of Extractive Industry and Petroleum

• The Paradox of Plenty • Managing Resources Effectively for

Equitable Development • Artisanal/Informal Sector Mining and

Large scale Modern Mining • Insufficient Returns to Governments • Self-interest • External involvement • Heightened expectation

8 Socio-economic impacts of EI in local communities

• Cultural impacts • Economic Impacts • Revenue utilization and Use • Gender Disparities • Projects, Funds, and Foundations • Supporting Small Local Businesses • Employment and SkillsDevelopment • Retrenchment • Community Health Initiatives • Mine Closure • Fly-in, Fly-out Operations • Community Participation in Decision-

making • Improved Social Impact Assessment

Group Profile

Total No Participants

Gender Physically Challenged

Education Level Occupation

Male Female Pri. Sec. Coll. Emp. Sel-Emp

40 25 12 3 20 15 5 2 38 100% 63% 30% 8% 50% 38% 13% 5% 95%

Level of appreciation and understanding of the subject matterbefore and after the training

Module Understanding Before Training Understanding After Training Good Sufficient Little None Good Moder Little None 1 1 5 3 31 14 17 9 0 2 4 11 12 13 24 15 1 0 3 0 1 5 34 20 17 2 0 4 0 1 2 37 18 20 2 0 5 0 0 1 39 28 10 2 0 6 0 1 1 38 19 21 0 0 7 0 2 1 37 20 18 2 0 8 0 1 2 37 14 25 1 0 % 2% 7% 8.4% 83% 50% 45% 6% 0%

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Program of the day 8th September 2014 Time Activity Resource Person SESSION I: CHAIRMAN- SERONI ANYONA 8 .00 – 8.30am Registration/ Prayers 8.30 – 8.45am Introduction of

Participants/Presentation of the Program of the day

SeroniAnyona

8.45 – 9.00am 9.00-9.10am Welcome remarks County official in

charge County Geologist-Wafula

9.10-9.15am Introduction of the seminar objectives /Overview of previous rapid assessment mission(with the CSOs)

Patrick Maingi(UNDP) /County government rep.

9.15-9.20am General overview of the EI in Kwale county/ Mineral distribution and potential of Kwale County

County Geologist(Wafula)

9.20-9.30am Advocacy, lobbying and negotiation skills/ Mediation and Peace building skills

SeroniAnyona

9.30-9.40am Politics of Extractive Industry and Petroleum/ Socio-economic impacts of EI in local communities

Lawrence Marube

9.40-10.00am Managing Corporate Social Responsibility Funds and Expectations

SeroniAnyona

10.00am – 10.20am Tea break 10.20am – 10.35am The Mining Act/ Legislative

provisions governing Extractive Industry current and proposed

Lawrence Marube – Ministry of Mining

10.35am – 11.10am Highlight of new Mining Bill SeroniAnyona 10.10am – 11.50am Group work on identification of

challenges & community expectations on Corporate Social Responsibility

11.50am – 1.00pm Group work presentations 1.00pm-2.00pm Lunch break 2.00pm-2.15pm Case study of Extractive Industry

CSR SeroniAnyona

2.15pm-3.20pm Plenary 3.20-3.40pm Way forward 3.40-3.50pm Closing remarks UNDP-Patrick

Maingi/County coordinator

4.00pm Departure

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Discussions on 8th September 2014 Issues raised by artisan miners and community representatives

• Poor infrastructure affecting their activities • Poor prices for their products • Quality of building blocks is low due to lack of modern equipment for cutting • Ballast broken by the artisans has been rejected by government due to the poor

quality of rock material used. They need technical advice to select appropriate rock materials

• Silica sand miners from Chimwaga Manga area expressed lack of knowledge on the appropriate value of the material and prices. Hence are exploited by middlemen

• Recommended that they need support to procure trucks to help transport their harvested silica sand to markets in order to fetch better prices

• Also recommended that an investor be sought to setup a glass making factory in the locality to help increase their income

• They observed that the county government should supporttheir activity as it collects cess(8,000-10,000/=) from them.

• They complained of non-indigenous people owning land at the expense of the indigenous

• They complained of lack of seedlings to replant mined land • The requirement to refill excavations presents a challenge • There is lack of geological information and whatever little there exist is not shared

among all • Community representatives complained of poor compensation for land during

relocation • They do not know how much money has been set aside (under the CSR) for communal

development and how it is used • Local people are not employed in the mining industry • There should be value addition programs instead of exporting raw materials • They complained of the failure of Base Titanium to send a representative to the

workshop • They wanted to understand clearly what the community can benefit from the Mrima

niobium deposits • They expressed disappointment that the commissioner of mines has so much power in

the old mining act (this is under review in Parliament) and desired to have the bill fast tracked for enactment

• They expressed a desire to have mining activities devolved • They felt that they were not sufficiently consulted before the Mining bill went to

parliament. The Environmental Impact Assessment is often done in secrecy • The assertion that the government owns minerals just below the land of a title owner

was most unacceptable and did not see the need to discuss the issue of minerals if it belongs to the government

• Affected persons during displacements, due to mining activities, should be shareholders in the concern companies

• They recommended that the county government should get a share of the income from the Extractive Industry

• They also requested to be trained and scholarships be made available for the youth from CSR funds

• That they be assisted to have good working relationship with the other stakeholders in EI and employment opportunities for the local community be made available.

• They recommended that EI players support community based organizations from the area

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Mr. Marube – Representative from the Ministry of Mining (National Government)

• Reported that at one moment there was a conflict between the people of Tsimba area when government officials when to explore for coal. The residents objected and chased the geologists away. Mr.Marube expressed disappointment for this misunderstanding due to poor communication.

County Geologist – Mr. Wafula

• The key problem is ignorance on the part of artisans as regards the geology and marketing of their products and the value chain

• He asserted that there were enough seedlings if communication among the artisans and concern government departments is streamlined

• There is also a attendance of the local people resisting advice and change in general • He regretted that middlemen were purchasing silica sand at a mere Kshs 3,000-5,000

then sell it at the glass factories at Ksh 100,000 per lorry • He said that a sodium silicate factory is earmarked to be built in the county • He advised the artisan miners to form Sacco’s to help bargain for better prices for

their products, buy lorries and rock cutting machines

IDENTIFIED CHALLENGES, RECOMMENDATIONS AND WAY FORWARD REACHED AT THIS WORKSHOP IDENTIFIED CHALLENGES SUGGESTED

RECOMMENDATIONS/WAY FORWARD

ROLE OF UNDP

1. Ignorance about the E.I 2. Non-involvement of the

community in decision making as regards E.I

3. Lack of employment opportunities for youth

4. Weak laws governing the E.I 5. Low literacy levels 6. Lack of funds to facilitate

community activities 7. Displacement affects

community 8. Negative environmental

impacts affecting communities 9. Poor working conditions in the

E.I 10. Mineral resources not under the

county government and not receiving direct payment from the E.I

11. Poor compensated to the affected people

12. Non-indigenous owning land at the expense of the indigenous

13. Poor prices for artisan mining products

14. Lack of efficient mining technology in artisan sector

1. Educate people on the extractive Industry

2. Investors to get green light from the mwananchi before commencement of mining

3. A certain percentage of income from the E.I should go o the community for development

4. Land owners, displaced and neighboring community should be given first priority for employment

5. Change the Mining ACT i.e. fast track the process of the passage and enactment of the new bill

6. Every sub-county in Kwale county should get scholarships for two student to learn earth science and mining technology

7. Any person displaced should be commensurately compensated and should possibly be a shareholder in the company

8. Wherever the displaced are

1. Train this group to also educate others on mining and prospecting rights as well as self-empowerment and negotiation skills

2. To supports in sourcing funds to facilitate activities

3. Support community based organizations

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IDENTIFIED CHALLENGES SUGGESTED RECOMMENDATIONS/WAY FORWARD

ROLE OF UNDP

15. Differences among miners over ownership of plots causing conflicts

16. Amounts set aside for the community a and its usage not known

17. Lack of Land title deeds

settled should be a good place worth of living and their children should be given scholarships by the companies

9. Infrastructure for the displaced and neighboring community should be improved

10. The environment and the neighboring community to be protected from the negative impacts of the mining activity

11. Respect the culture of the local community

12. Create good working environment in the industry for employees

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DAY 2 Natural Resources Management for Sustainable Development in Kenya Training Workshop for (Civil Society Organizations) 9th September 2014 (Swahili Beach Hotel)

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Key Objectives • Profile of the CSOs • Build on corporate Social Responsibility (CSR) initiative of Extractive Industry - Kwale

County • Facilitate public-private dialogue on the Extractive Industry in Kwale County • Engage the group in a peace building forum











scenarios.











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Module Description Content strategy for change.

• Documentary screening: Bringing down a Dictator (OTPOR, Serbia).









Group Profile Total No Participants



Male Female Pri. Sec. Coll. Emp. Sel-Emp 44 33 11 3 3 26 15 16 28 100% 75% 25% 7% 7% 59% 34% 36% 64%

Level of appreciation and understanding of the subject matterbefore and after the training

Module Understanding Before Training Understanding After Training Good Sufficient Little None Good Moder Little None 1 1 6 12 25 12 23 7 2 2 11 17 13 3 23 15 5 1 3 0 1 2 41 25 18 1 0 4 0 2 3 39 22 18 3 1 5 2 3 4 35 23 17 4 0 6 4 4 5 31 21 19 3 1 7 1 2 2 39 26 15 3 0 8 5 10 13 16 27 15 2 0 % 8% 14% 17% 72% 56% 44% 9% 1.6%

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Program of the day 9th September 2014 Time Activity Resource Person SESSION I: CHAIRMAN- SERONI ANYONA 8 .00 – 8.30am Registration/ Prayers 8.30 – 8.45am Introduction of

Participants/Presentation of the Program of the day

SeroniAnyona

8.45 – 9.00am 9.00-9.10am Welcome remarks County official in charge

County Geologist-Wafula 9.10-9.15am Introduction of the seminar

objectives /Overview of previous rapid assessment mission(with the CSOs)

Patrick Maingi(UNDP) /County government rep.

9.15-9.20am General overview of the EI in Kwale county/ Mineral distribution and potential of Kwale County

County Geologist(Wafula)

9.20-9.30am Advocacy, lobbying and negotiation skills/ Mediation and Peace building skills

SeroniAnyona

9.30-9.40am Politics of Extractive Industry and Petroleum/ Socio-economic impacts of EI in local communities

Lawrence Marube

9.40-10.00am Managing Corporate Social Responsibility Funds and Expectations

SeroniAnyona

10.00am – 10.20am Tea break 10.20am – 10.35am The Mining Act/ Legislative

provisions governing Extractive Industry current and proposed

Lawrence Marube – Ministry of Mining

10.35am – 11.10am Highlight of new Mining Bill SeroniAnyona 10.10am – 11.50am Group work on identification of

challenges & community expectations on Corporate Social Responsibility

11.50am – 1.00pm Group work presentations 1.00pm-2.00pm Lunch break 2.00pm-2.15pm Case study of Extractive Industry

CSR SeroniAnyona

2.15pm-3.20pm Plenary 3.20-3.40pm Way forward 3.40-3.50pm Closing remarks UNDP-Patrick

Maingi/County coordinator

4.00pm Departure

Discussions on 9th September 2014 • Issues raised by Civil Society Organizations • The issue of Tsimba location came about for fear for being relocated • 85% of employment opportunities should be set aside for people from the locality • The government should set a standard figure for compensation for people relocated

due to mining activity

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• They recommended that some Kshs 10million be set aside for public sensitization and Kshs 9 million for establishing a gemstone centre

• The community was advised not to resist mineral exploration exercises • They express a desire to partner with the UNDP and the government • Currently a mining company can be given a mining license before preparing an EIA.

So the participants recommended that this be reversed to make it mandatory to do and EIA before issuing a mining license.

• The county government should be get a portion of the loyalties and other taxations from the Extractive Industry

• Community agreements with mining companies should have force in law

Mr. Marube – Representative from the Ministry of Mining (National Government)

• Many accidents have been reported from the salt mining and other mining activities in Kwale

• The issue of common minerals such as sand, ballast etc has been devolved • The period for a mining lease should be decided collectively with all stakeholders • The current bill in parliament should require an independent auditor to audit mining

company books and not the commissioner of mines or cabinet secretary for mining • A conflict is ensuing between some residents living at the border between Base

Titanium and KISCOL (Kwale International Sugar Company Limited) jurisdictions at Vumbu location (village) Kinolo ward. Majorities of the affected population, who are supposed to be relocated, live within the KISCOL jurisdiction but do not want to be compensated by the KISCOL but rather by Base Titanium. This is because Base Titanium pays higher rates than KISCOL. On the other hand Base Titanium has rejected to compensate people outside their jurisdictions. This conflict is unresolved and it just goes to emphasize the need for public-private dialogue

• There is a general resentment among local communities against the non-indigenous carrying out mining activities. Their perception is that their wealth and land is being taken away or exploited without direct benefit

• They are unhappy with the tax being levied against them by the local government their mining activities

• Key problem sight was the lack of education and knowledge about the Extractive Industry

• They had high expectation after the establishment of various mining ventures. Looked forward for employment, sudden wealth accumulation, involvement in decision making and benefit from mineral loyalties for infrastructural development

• They sighted the involvement of agents and middlemen in land transactions as being responsible for the poor prices of land

• Identified the need to build schools and construct roads as one area companies involved in the extractive Industry can assist to avoid bad blood between them and companies

• Mineral explorations teams that have been going round in the county are raising expectations and anxiety

• One of the participants in the group sits in the Base Titanium Corporate Social Responsibility committee and gave a long list of community development projects carried out the company. These included Secondary school and Health center at Magaoni Boreholes at Bwiti Dispensaries Polytechnic at Mwabungu Ambulance at Msambweni Referral Hospital School dormitories at Mwamzandi area

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School fees for a number of students 20 scholarships for students admitted to Kenya Medical Training College Support to local football clubs among others

• The level of community representation to the CSR committees are quit detailed and ensures inclusion of all minority groups

• Members of Parliament, MCAs, the Senators religious groups are also represented in the committees

• This degree of community support by Base Titanium was unknown to most participants most of whom were impressed. Actually a number of CSOs who had been campaigning against the company’s CSR policy changed their mind on this day.

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IDENTIFIED CHALLENGES, RECOMMENDATIONS AND WAY FORWARD REACHED AT THIS WORKSHOP IDENTIFIED CHALLENGES SUGGESTED

RECOMMENDATIONS/WAY FORWARD

ROLE OF UNDP

1. The mining companies should have a sense of responsibility towards the community and environment (both ecological and social) in which it operates

2. Displacement of people due to mining activities

3. Low compensation to displaced people

4. Weak mining law 5. Community lack of

political will to confront issues in the E.I

6. lack of information regarding resource allocation

7. Corruption in the industry 8. Health impact of the

mining activities 9. Limited job opportunities

for locals 10. Biased employment 11. Poor treatment of workers

at workplace 12. People not involved in

decision making 13. Many work related

accidents in the E.I 14. County government not

getting any payment from mining companies

15. The commissioner of mines(carbonate secretary) has so much power currently/in new bill

16. People near Base Titanium having difficulties in carrying out farming

17. Ignorance about right and obligations in the E.I

18. Lack of resources to implement activities

1. Form engagement structures that are inclusive and representative

2. Facilitate thematic grassroots meetings using FGDS(Focused group discussions) methods to get wide participation

3. Facilitation to initiate startup workshops, sensitization meetings and trainings on community leadership

4. Facilitate baseline surveys before project start up to avoid the recurrent socio-economic issues

5. Establish scholarships for training young people in the community to study Mining and Mineral related courses to enable them take up decision making jobs in the Extractive Industry

6. Support the establishment of processing industries

7. Formalize community involvement Structures – Create a cluster of village representatives among other stakeholders at ward level headed by a lead CSO in affected areas i.e mining site, transport corridors

8. Develop an effective mechanism of information sharing

9. Calendar of meetings and reviews should be on quarterly basis

10. The entry point for any investor engaging the community should be the Ward Liaison committee

11. Capacity building on the understanding of the E.I.

1. Support the communities by providing value addition training to artisan miners

2. Support in Capacity building of CSO, funding to CSO on legal training and research on ecosystems and Linkages to facilitate communities affected by extraction industry

3. Assist in linking CSOs to local and international legal institutions to assist in advocacy

4. Help bridge the gap between CSOs and the county government

19

IDENTIFIED CHALLENGES SUGGESTED RECOMMENDATIONS/WAY FORWARD

ROLE OF UNDP

19. Poor leadership and organization skills

20. Lack of value addition technologies and industries

21. Environmental pollution and degradation

12. Community to participate in royalty negotiations

13. Conservation and protection of the environmental

14. Support community policing structures to keep the peace

15. Create, support and maintain a rapid response system to alert people on emerging issues

16. Change the Mining ACT i.e. fast track the process of the implementing the new act

17. Mining Company should be located where the raw materials are found

18. With the assistance from the county government establish cooperatives to control prices for artisan mining activities

19. Communities should have MoUs with companies before commencement of mining

20. There should be transparence and accountability in mining dealings and agreements

21. Utilization of locally available materials and content Mining companies should not be given the exploration or mining license before carrying out EIA

20

PROFILE FOR CIVIL SOCIETY ORGANIZATIONS IN KWALE COUNTY Natural Resources Management for Sustainable Development in Kenya Training Workshop for CSOs, Kwale County Government Officials and Communities - 9th September 2014 No. Name of CSO Postal

Address Registration No.

Tel. No. Contact Person

e-mail address No. of Members/Collaborations

Physical address

Main achievements Year of Reg.

1 Kwale County Natural Resources Network

P.O Box 86 – 80400 Ukunda

DSS/MSAMB/DN/A431/31/2012

0704646620(Mohamed Ali)

[email protected](www.kcnrn.org)

220(Indv.) 38(CBOs), 3(Private corp.) 1(H. Sch.) Collaboration- WWF, ILEG, EAWS, TI, Agakhan Foundation, NMK (national Museums of Kenya), County/National Govern. Member of National Civil society Alliance)

Mombasa Lungaluga Hwy Corner Musa Ukunda-(NMK Offices)

Engagement of the community county goernt. And private sector(EIAs) 5yr strategic plan Well represented at county

2011

2 Ng’ombeni Waa Youth network CBO

Box 96222 - Likoni

DSS/KWL/MTG/3501439/2014

0724479746(SaidiJumaMwawanzinda)

[email protected]

24(indv), 20 youth groups) Collabo-MUHURI

Ng’ombeni Three youth summits Organized forum to teach the youth about county budget

2014

3 Human Rights Agenda

Box 41169-80100 Mobasa

0722235219, 0202319001(Yusuf LuleMwatsefu)

[email protected]([email protected])

Taita, Kwale and Kilifi Collaboration-(Pwani University, TTUC, NYU(New York Univer.) Sch. of law, EA.Human rights adv. on good governance platform)

Heilleselasie Rd opp blue room rest. City grocers building

Did research to determine the extent of environmental compliance & EIA (draft copy available) MOU with TTUC –courses in Mining, Analysis of the legal framework that governs the mining sector)

2012

mailto:[email protected](www.kcnrn.org)�

mailto:[email protected](www.kcnrn.org)�

mailto:[email protected]�


mailto:[email protected]([email protected])�



21

No. Name of CSO Postal Address

Registration No.



Physical address


Working well with cost parliamentary group

4 Kwale Human rights network

Bo 427 Ukunda

DSS/KWL/MTG/130270/2010

0720701408(George Jaramba)

[email protected], [email protected]

1,500 (Indiv), 30(Corp.), Collaboration-(HURIA, Kenya Land Alliance, Kituo Cha Sheria, K. Human Rights

Lungalunga Rd TukutaneDianiUkunda

Engaged with Kwale County on citizen participation. Advocacy in governance, Social, community sensitization

2006

5 Kinango Community Development Network

Box 106 -80405 Kinango

0729684803(Richard Itambo)

[email protected] 22(Indv), Collaboration-Government, URIA, MUHURI, Plan International)

KinangoMariakani Road Salvation Army Building

HIV education, Social accountability, Tree planting in Prim Sch’s. Human Rights Activities

2012

6 Mbuguni Water Resource Users Asso.

96262 Likoni

0728717711(JumaMwabasi)

200(Indiv),5 (Corp.) Collabo.- (Coast Water services board and NEMA)

MwachipangaMbuguni location

Sensitization of spring conservation Tree conservation & panting, Charcoal burning

2011

7 MaendeleoYaWanawake

Box 0702147113(Amina Msau)

500 (Newly elected)

8 RanetKwale FM Radio station

274 Kwale 80003

308913 0722759415(HamisiMwachai)

[email protected]

204 Kwale Information Hse.

Providing weather and climate information to the public

2012

9 Apkwehu CBO

95 Kwale DGSD/KNG/KNG/A910/78/13

0729473361(maryMunyoki)

[email protected]

22(Indv) 10(corp) 4(Sch) Collabo-Ministries; Forestry, Agriculture, Livestock and ILISHE

KinangoLungalunga Rd NyondoHseKinango

Environmental. Education, Tree planting in sch’s

2012








22


Registration No.



Physical address


Trust) Funded by CDTF Opened water pans Gara goats

10 Lamukani CBO

427 Ukunda

0719542475(Malimwengu),0723670914(Mwabata)

[email protected]

50(Indv), 2(Corpr) Collabo:-Kituo Cha sheria ,TI, KLA, HURIA, Amani people’s Theater)

Mombasa-Lungalunga Rd Mwabungo Colorado

Supported dropout girls to get back to sch, Sensitize on children and Women rights

2002

11 Vanga Dev. Grp

115 Vanga DSS/MSAMB/LUNGA/20992/2014

0720059170(MwanatumuKadau)

[email protected]

22(indv) Vanga-Lungalunga Rd

Public Education on life skills

2014

12 KWEA(Kwale Welfare Education Association)

Box 133 80403 Kwale

DSS/KWL/KUB/130275/2010

0722823278(Mwachausa) 0721802844(RamadhanBungale-Chrm)

[email protected] www.kweacbo.org KWEA(Kwale Welfare Education Association)

30 (Indv) 10 (Honorary) Collabo:-County Governt, Base Titanium, Build Africa, COVAO, CDF, HURIA, all SChs, Univ. in cost, Leisure lodge Nakumat, Shanzu, Mikindani

KwalebehdWema Hotel

Educate the youth to have a positive attitude to education Organize supports child welfare Carry out annual Career expos(30 Sec Sch involved) 6 University in expo, 9 Colleges Gave 500 sanitary towels to sch. girls Support academic tours, 3 yr project to empower girl child

2010

13 SEGA Box 82 Lungalunga

A423 0727755979(MsilaMsau) 0727691966(Evelyne David)

[email protected] 50(Indiv) Collabo:- (Afia Plus, Marie Stopes)

Mombasa Lungalunga Rd PeraniMakt

HIV education Family planning Tree planting Eviron. education

2011

14 Agakhan Foundation

Box 99870 Mbsa

0720866510 [email protected]

Network Collabo:-County gover, human

Inside BondeniPri.

Citizen empowerment,






http://www.kweacbo.org/�




23


Registration No.



Physical address


resource network etc) Schmombasa

policy issues

15 Subira Women Grp

0726638743(Saidi Omar)

30(Indiv) Kikoneni 2014

16 Tupendane Disability Group

B0 01 Kinango

0717276249(ElinaBahati)

[email protected]

28(Indiv) Kinago-Vigurungani Rd

Sensitize the public and disabled on the rights of the disabled

2014

17 MUHURI(Muslim for Human Rights)

Box 42261-80100 Mombasa

OP218/051/2009/0109/564

0737388485(RahmaGulam)0720422744(ProgMangShalinNjeriNjoroge)

[email protected], www.muhuri.org

Collabo:-County govern. National Govern.)

Opp Digital City(Jomo Kenyatta Highway

Land Social audit CDF social audit in 6 constituencies,

2009

18 NduguSelf helpgrp

c/o87246 -80100 Mbsa

DSS/KWL/MTG/287193

0724966211(GavugaJumaSalim-Org Sec)

[email protected] 100(Indiv-50 active) Tsimba/Golini ward (Stamilivill)

Members supporting each other to raise sch fees, -projects, fish pond etc

2012

19 Kwale County Youth Bunge Network

Box 188 Kwale

0722211083(SeblinaMwawasi), 0705809445(Jonathan Wambua)

[email protected]

20(Board members),1,400(Indiv)

Ukunda Show ground

Public sensitization for peace and security Encouraging youth and elderly to take identity cards

2011





http://www.muhuri.org/�




24

DAY 3 Natural Resources Management for Sustainable Development in Kenya Training Workshop for (County Government Officials) 11th September 2014 (Swahili Beach Hotel)

25

Key Objectives • Build on corporate Social Responsibility (CSR) initiative of Extractive Industry - Kwale

County • Facilitate public-private dialogue on the Extractive Industry in Kwale County • Engage the group in a peace building forum











scenarios.











26

Module Description Content strategy for change.

• Documentary screening: Bringing down a Dictator (OTPOR, Serbia).









Group Profile Total No Participants



Male Female Pri. Sec. Coll. Emp. Sel-Emp 40 34 6 1 0 18 22 40 0 100% 85% 15% 3% 0% 45% 55% 100% 0%

Level of appreciation and understanding of the subject matter before and after the training Module Understanding Before Training Understanding After Training Good Sufficient Little None Good Moder Little None 1 15 15 5 5 31 8 1 0 2 12 11 8 9 33 7 0 0 3 2 5 25 8 28 9 3 0 4 7 16 10 7 29 9 2 0 5 11 10 9 10 34 6 0 0 6 8 9 18 5 27 9 4 0 7 10 13 14 3 32 5 3 0 8 10 12 7 11 35 4 1 0 % 23% 28% 30% 18% 78% 18% 4% 0%

27

Discussions on 11th September 2014 • The workshop was informed by the Minister of Mineral Resources, Hon. Ali JumaMafimbo, that

the proposed new Mining bill is in its second reading in Parliament and that the Kwale County government had written a proposal for amendments which was adopted by the council of governors as the representative amendment for all counties with existing Mining activity or Mineral potential.

• The Kwale county political leaders had organized to meet with Mombasa County counterparts to lobby for their proposed amendment to the Mining bill. One of their recommended amendments is to share revenue accrued from the Extractive Industry with the central government.

• They also wish to change the requirement in the bill for the government to sell geological information to investors. This will discourage investors and it’s not the common practice internationally

• It was recommended that CSR projects be synchronized with the county Integrated Development Plan to avoid overlaps and duplication.

• It was recommended that there be a legal framework to guide CSRs and exploration • AFREC is currently exploring for gas in Kwale County and has been encountering communal

resistance. However they have been contributing some Ksh.2million to each ward. • Companies involved in the Extractive Industry should be held to the standards of their

countries of origin especially regarding CSR • Foreign company by name B4 millennium has been contracted by Base Titanium to manage

CSR funds. It was however felt that they often carry out projects without consultation. • Major focus should be on capacity building and companies should train locals and avoid hiring

personnel from outside • There appears to be no monitoring mechanism to evaluate adherence to set standards and

principals by mining companies • It was observed that mining companies tend to mistake capitalized projects such as mineral

transport corridors for CSR. This way they may get some tax exemption when in actual fact the project is of economic value to company more than it is for the community. Hence there needs to be clarity on the definition of what CSR is. In Botswana, the government undertakes all infrastructural development thereby letting the companies focus on CSR

• It was recommended that a mining license should not be issued until a clear and acceptable CSR is developed

• Access to Information is a major challenge in the Extractive Industry • CSR should be entrenched into company planning and budgeting and a proposed 0.05% of the

profits could be set aside for supporting education • CSR funds should be channeled through the county and the county government should make

relevant legislation to enable this. • A kitty could be created into which companies involved in extractive industry could remit CSR

funds to assist in initiating development projects • Support for data collection and baseline information surveys

28

IDENTIFIED CHALLENGES, RECOMMENDATIONS AND WAY FORWARD AT THIS WORKSHOP Challenges Recommendations

Role of UNDP

1. There is no direct benefit to the common mwananchi and the County Government

The benefits to the locals and the County should be clearly spelt out in national legislation (Mining Bill).

Facilitate benchmarking on international best practices

2. Value addition The law should provide that refining be done in the County the mineral is from.

Facilitate benchmarking on international best practices

3. Environmental impact of mining to the locals

Enforcement of Environmental Impact Assessment reports. To restore the mined land

Facilitate the monitoring of EIA studies and implementation. Facilitate in terms of finance and expertise in both land, minerals and legal field

4. Corruption/ fraud in mining companies so that laws are not followed e.g. labor

The government bodies and stakeholders involved should uphold their mandate.

Facilitate community sensitization

5. Locals are not informed of their rights vis a vis the extractive industry

Need for awareness and sensitization on

Facilitate community sensitization

6. Lack of synchrony in CSR projects/programs

Coordination between the County government and the mining company

Facilitate dialogue between the parties

7. Legislation Develop the legislation / policy in extractive industry and related services including the CSR

Facilitate in terms of finance and expertise in both land, minerals and legal field

8. Lack of Data/ gaps Carry out survey to identify the gaps, status quo/ baseline

Facilitate in terms of finance and expertise in both land, minerals and legal field

9. Lack of finance Avail affordable sources of finance at cheap cost

Link us with donors, banks and other cheap financers

10. Lack of market Carry out Promotions through all available medium to both local and international Standardize our products to compete in the international arenas. E.g. putting KEBS stickers Intellectual property rights, getting patent for our products

Link the county with the outside world.

11. Lack of capacity SME training Protecting the small miners from big players Awareness to players by carrying out civic education on land rights and mining leases

Scholarship to study on issues of mining and related services Train faceting of gemstone to unskilled Exchange programs for exposure Technology advancement in mining processes for the small scale miners

29

Challenges Recommendations

Role of UNDP

12. Expectations of key stakeholders not harmonized

Need to harmonize expectations and carryout civic education

13. Weak linkages and coordination of stakeholders in the E.I.

Establish a coordinating body and capacities build on coordination and linkages. Bring together stakeholders in the industry

14. Limited local professional skill in E.I.

Support training in E.I.

15. Lack of proper and effective tools for small scale mine owners

Support for acquisition of proper tools

16. Royalties is not clearly defined in the Act

Royalty to clearly defined in the act

17. There is no denominator on CSRs

Issues SBPs in line with value of mining

18. The County Government is not consulted on the ideal CSR initiatives


19. The CSR initiatives are not complimenting the County Governments efforts


30

DAY 4 Natural Resources Management for Sustainable Development in Kenya Training Workshop for and Final Overview of All groups present 12th September 2014 (Swahili Beach Hotel)

31

Key Objective • Assessment of the seminar proceedings -recommendations

Time Activity Resource Person SESSION I: CHAIRMAN- SERONI ANYONA 8 .00 – 8.30am Registration 8.30 – 8.35am Prayers Two participants 8.35-8.45am Welcome and Introductory

remarks – Sub-County Admin Sub-County Admin -Hamisi

8.45-9.00am Introduction of all present and county government officials

Sub-County Admin

9.00-9.20am Overview of the seminar proceedings -recommendations

Sub-County Admin -Hamisi Patrick Maingi (UNDP) Lawrence Marube County Geologist-Wafula

9.20-9.40am Consolidated recommendations and assessment of seminar proceedings

SeroniAnyona

9.40 – 10.30am Open discussions and reactions SeroniAnyona 10.30am – 11.00am Formulate linkages among the 3

groups SeroniAnyona

11.00-11.20am Way forward Patrick Maingi (UNDP) 11.20-11.35am Closing remarks - CS for

Environment

12.00pm Departure

On this day all the recommendations and finding of the three groups were discussed and evaluated.

A secretariat was formed to harmonize the operations of the three groups and way forwards was reached (list of members of the secretariat is available elsewhere in the report)

32

CONCLUSIONS AND RECOMMENDATIONS 1. Generally there was an increased understanding of the subject matter at the end of the

training

All Modules Understanding Before Training Understanding After Training Good Sufficient Little None Good Sufficient Little None

Community Representatives

2% 7% 8.4% 83% 50% 45% 6% 0%

CSOs 8% 14% 17% 72% 56% 44% 9% 1.6% County Government Officials

23% 28% 30% 18% 78% 18% 4% 0%

2. There is a common feeling that communities are not commensurately benefiting from the

mining activities 3. Local communities continue to be affected by the negative environmental impacts of the

Extractive Industry due to poor enforcement of the EIA 4. The local communities and artisanal miners feel that they are being exploited by

middlemen and other interested parties due to their ignorance. So public sensitization and education is of critical importance

5. Local communities are not involved in decision making on matters affecting them such as choice of CSR projects and various agreements reached. More structured involvement is therefore required

6. There is a communication breakdown among stakeholders leading to misinformation and mistrust

7. Limited local professional and technical skills in E.I. hindering maximization of the benefits from the industry. This calls for a concerted effort by all stakeholders to train young members of the community to take leadership in the industry and build capacity.

8. Establishment of value addition technologies and industries to increase the income from the E.I

9. Lack of current and reliable data and information about the E.I. There is need to carry out baseline survey to identify the gaps and status quo

10. The laws governing the Extractive Industry are weak and need urgent review.(Speed up the Mining Bill currently before the parliament)

11. There is lack of resources to enable local CSOs and CBOs carry out activities and implement their mandate. So ways and means should be sought to assist them access resources

12. Environmental issues have not been given the attention they deserve. Therefore the key actors should take the necessary action to restore the state of the damaged environment.

13. County government not getting any payment from Extractive Industry. The necessary legal and administrative instruments should be put in place to enable county governments benefit directly from the industry

33

MINERAL DISTRIBUTION MAP OF KWALE COUNTY

34

Natural Resources Management for Sustainable Development in Kenya

Training Workshop for CSOs,Kwale County Government Officials and Communities

8th -12th September 2014 (Swahili Beach Hotel)

(All participants present)

PARTICIPANTS’UNDERSTANDING OF SUBJECT CONTENT EVALUATION QUESTIONNAIRE

Name: …………………………………………………………………………………………… Organization: ………………………………………………………………………………….. Gender: Male: Female: Education Level: Primary Secondary Collage (Post-Secondary) Indicate your level of understanding of the following subjects (Tick accordingly) 1. Legislative provisions governing EI: Good Sufficient Little None

2. Mineral distribution and potential of Kwale County: Good Sufficient Little None

3. Advocacy, lobbying and negotiation skills: Good Sufficient Little None

4. Managing Corporate CSR Funds and Expectations: Good Sufficient Little None

5. Case study of Extractive Industry CSR: Good Moderate Little None

6. Mediation and Peace building skills: Good Moderate Little None

7. Politics of Extractive Industry and Petroleum: Good Sufficient Little None

8. Socio-economic impacts of EI in local communities: Good Sufficient Little None

workshop report...to kwale comprising of the different units with undp kenya (i.e pbcp, dgu, drr,...

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